Exhibit L - Environmental Assessment No. T-6376-P21-05373-P23-05090 [4-24-2025] — Fresno City Council, June 26, 2025 (part 1 of 4)

Exhibit L

1 APPENDIX G/INITIAL STUDY FOR A MITIGATED NEGATIVE DECLARATION Environmental Checklist Form for:

Environmental Assessment Application No. T-6376/P21-05373/P21-05090

1. Project title:

Environmental Assessment Application No. T-6376/P21-05373/P21-05090

2. Lead agency name and address:

City of Fresno
Planning and Development Department
2600 Fresno Street
Fresno, CA 93721

3. Contact person and phone number:

Juan Lara, Planner III
City of Fresno
Planning and Development Department
(559) 621-8039

4. Project location:

Located on the west side of S. Armstrong Avenue, between the San Joaquin Valley Railroad and East Church Avenue, in the City and County of Fresno County, California (see Figures 1 and 2).

Site Latitude: 36.7212 º N - 36º 43’ 16.41”
Site Longitude: 119.6754º W - 119 º 40’ 31.61”
Mount Diablo Base & Meridian, Township 14S, Range 21E, Section 15 Assessor’s Parcel Number(s): 316-160-16S, -17S, -43S, -59S and -61S. 2 5.

Project sponsor's name and address:

Bonadelle Communities
7030 N. Fruit Ave #101
Fresno, CA 93711

6. General & Community plan land use designation:

General Plan:

Current: Medium Density Residential
Proposed: Medium Density Residential
Community Plan: Roosevelt Community Plan

7. Zoning: Current: AL 20 (Limited Agriculture, 20 Acre Parcel) - Fresno County Proposed: RS-5/UGM (Residential Single-Family, Medium Density/Urban Growth Management)

8. Description of project:

Pre-zone Application No. P21-05373, Annexation Application No. P21-05090 and Vesting Tentative Tract Map No. 6376 were filed by Bonadelle Neighborhoods (herein, “Project Applicant”). The Project is located on the west side of South Armstrong Avenue, between the San Joaquin Valley Railroad and East Pitt Avenue, within Fresno County (APNs 316-160-16s, -17s, -43s, -59s, and -61s).

Pre-zone Application No. P21-05373 requests authorization to change to the City of Fresno official zone map for the Project site from the AL20 (Agriculture, 20-acre parcel, Fresno County) zone district to the City of Fresno RS-5/UGM (Single-Family Residential, Medium Density/Urban Growth Management) zone district.

Annexation Application No. P21-05090 proposes to detach from the King River Conservation District and Fresno County Fire Protection District and annexation to the City of Fresno.

Vesting Tentative Tract Map No. 6376 proposes the subdivision of the approximately

34.7-acre site into 202 single-family residential lots approximate lot size will range 3 from 6,300 square feet to 4,445 square feet with public streets, sidewalks and a 0.39- acre park. There will be three access points from S. Armstrong Avenue. All required improvements are proposed and will be installed by the developer as part of the Project. See Figure 3.

There are three existing residences with wells on the eastern portion of the site along S. Armstrong Avenue which will be demolished as part of the Project.

Construction
The proposed Project includes the construction of a 202-lot single-family development with the associated public road and utility improvements. The site currently consists of three residential dwellings with associated wells, and vacant land that is regularly disked for weed control. Construction will take approximately 24 months with construction starting in mid to late 2025.

It is anticipated that the following pieces of equipment would be used during construction activities:

1. Roller;

2. Large bulldozer;

3. Loaded trucks;

4. Excavator;

5. Generator;

6. Service truck; and

7. Air compressor.
4 9. Surrounding land uses and setting:

Planned Land Use Existing Zoning Existing Land Use
North
Residential,
Medium Low
Density
RS-4
Residential Single Family,
Medium Low Density (City of
Fresno)
Single-Family
Residential
East
Residential,
Medium Low
Density
RS-4
Residential Single Family,
Medium Low Density (City of
Fresno)
Single-Family
Residential
South Residential,
Medium Density
AL-20
Limited Agriculture (Fresno
County)
Agriculture
West Residential,
Medium Density
AL-20
Limited Agriculture (Fresno
County)
Vacant

10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):

Planning and Development Department, Building and Safety Services Division, Department of Public Works, Department of Public Utilities, Fire Department, Fresno Metropolitan Flood Control District, Fresno Irrigation District, PG&E, Sanger Unified School District, County of Fresno Department of Community Health, County of Fresno Department of Public Works and Planning, and San Joaquin Valley Air Pollution Control District.

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code 5 (PRC) Section 21080.3.1? If so, has consultation begun? The State requires lead agencies to consider the potential effects of proposed projects and consult with California Native American tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Resources through the California Environmental Quality Act (CEQA) Guidelines. Pursuant to PRC Section 21080.3.1, the lead agency shall begin consultation with the California Native American tribe that is traditionally and culturally affiliated with the geographical area of the proposed project. Such significant cultural resources are either sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a tribe which is either on or eligible for inclusion in the California Historic Register or local historic register, or, the lead agency, at its discretion, and support by substantial evidence, choose to treat the resources as a Tribal Cultural Resources (PRC Section 21074(a)(1-2)). According to the most recent census data, California is home to 109 currently recognized Indian tribes. Tribes in California currently have nearly 100 separate reservations or Rancherias. Fresno County has a number of Rancherias such as Table Mountain Rancheria, Millerton Rancheria, Big Sandy Rancheria, Cold Springs Rancheria, and Squaw Valley Rancheria. These Rancherias are not located within the city limits.

Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See PRC Section 21083.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per PRC Section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that PRC Section 21082.3(c) contains provisions specific to confidentiality.

Pursuant to Assembly Bill 52 (AB 52). The City of Fresno mailed notices of the proposed to the Table Mountain Rancheria Tribe and The Dumna Wo Wah Tribe on April 15, 2022, which included the required 30-day time period for tribes to request consultation, which ended on May 16, 2022. All tribes which were contacted declined consultation.
6 Figure 1 – Project Location
Figure 2 – Site Aerial
7 Figure 3 – Site Plan
8 FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Agriculture and Forestry Resources
☐ Air Quality ☐ Biological Resources
☐ Cultural Resources ☐ Energy
☐ Geology/Soils ☐ Greenhouse Gas Emissions
☐ Hazards and Hazardous Materials ☐ Hydrology/Water Quality ☐ Land Use/Planning ☐ Mineral Resources
☐ Noise ☐ Population/Housing
☐ Public Services ☐ Recreation
☐ Transportation ☐ Tribal Cultural Resources
☐ Utilities/Service Systems ☐ Wildfire
☐ Mandatory Findings of Significance
DETERMINATION: (To be completed by the Lead Agency)
On the basis of this initial evaluation:
___ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. 9 _X_
I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
___
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT (EIR) is required.
___ I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An EIR is required, but it must analyze only the effects that remain to be addressed.
___ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. _ _______________________________April 24, 2025_
Juan Lara, Planner III Date
City of Fresno, Planning and Development Department
EVALUATION OF ADDITIONAL ENVIRONMENTAL IMPACTS:
10 For purposes of this Initial Study, the following answers have the corresponding meanings:
a. “No Impact” means the specific impact category does not apply to the project, or that the record sufficiently demonstrates that project specific factors or general standards applicable to the project will result in no impact for the threshold under consideration.
b. “Less Than Significant Impact” means there is an impact related to the threshold under consideration, but that impact is less than significant. c. “Less Than Significant with Mitigation Incorporation” means there is a potentially significant impact related to the threshold under consideration, however, with the mitigation incorporated into the project, the impact is less than significant. d. “Potentially Significant Impact” means there is substantial evidence that an effect may be significant related to the threshold under consideration.

2. A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

3. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

4. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect may be significant.

If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required.

5. "Negative Declaration: Less Than Significant With Mitigation Incorporated" applies 11 where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less Than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from, "Earlier Analyses," as described in (6) below, may be cross-referenced).

6. Earlier analyses may be used where, pursuant to the tiering, Program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in the PEIR or another earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

7. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances).

Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

8. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

9. The explanation of each issue should identify:
a. The significance criteria or threshold, if any, used to evaluate each question; and b. The mitigation measure identified, if any, to reduce the impact to less than significance.
12 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
I. AESTHETICS – Except as provided in PRC Section 21099, would the project:
a) Have a substantial adverse
effect on a scenic vista? X
b) Substantially damage scenic
resources, including, but not
limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
X
c) In non-urbanized areas,
substantially degrade the existing
visual character or quality public
views of the site and its
surroundings? (Public views are
those that are experienced from
publicly accessible vantage point).

If the project is in an urbanized
area, would the project conflict
with applicable zoning and other
regulations governing scenic
quality?
X
d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
X

DISCUSSION
a) Have a substantial adverse effect on a scenic vista? 13 No Impact. A scenic vista is a viewpoint that provides a distant view of highly valued natural or man‐made landscape features for the benefit of the general public. Typical scenic vistas are locations where views of rivers, hillsides, and open space areas can be obtained as well as locations where valued urban landscape features can be viewed in the distance.

The City of Fresno General Plan (GP) identifies six locations along the San Joaquin River bluffs as designated vista points from which views should be maintained. The scenic views from the San Joaquin River bluffs are not expected to be substantially affected. As such, future development associated with the continued implementation of the approved General Plan would result in a less than significant impact on existing designated vista points.

According to the GP scenic views are also attributed to public views of buildings in Downtown Fresno that provide a skyline within the Planning Area. Due to relatively flat topography, intervening land uses, and landscaping, views of the skyline are primarily limited to areas within the Downtown Fresno area. Limited views of existing high‐rise buildings in Downtown Fresno are visible from portions of elevated freeways, including State Route (SR) 41, SR 99, and SR 180. The continued implementation of the approved General Plan would allow future development in the Downtown area, which could include additional high rises. While views of scenic resources in the Downtown Fresno area may be partially obstructed following future development as allowed by the approved General Plan, existing development in these areas currently inhibits views of scenic vistas.

The proposed Project site is located in an area designated for residential zoning uses by the City. The site is outside of the San Joaquin River bluffs and Downtown Fresno area. The parcels to the north and east, beyond S. Armstrong Avenue and the SJVR, have also been developed into subdivision neighborhoods. According to the biological due diligence letter (see Appendix B), a site survey was conducted on March 25, 2021.

At the time, the site consisted of loose, recently-disked soil, except for two residences on site, which will be demolished with Project implementation. Site vegetation is comprised mostly of grasses, but some low-growing forbs are also present. Plan height is currently low, with grasses and forbs 1-6 inches tall. The site can be characterized as annual grassland in the process of re-establishment. The existing topography of the site is nearly flat, with an elevation of approximately 323 feet above 14 mean sea level (amsl). There are no significant trees, rock outcroppings, and/or historic buildings located on the subject property that have been identified as important scenic resources.

There will be no impacts to scenic vistas.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. The Project site is in an agricultural and residential area in the City of Fresno and there are no scenic vistas or other protected scenic resources on or near the site. There are no scenic highways near the proposed site. The nearest eligible State Scenic Highway is Hwy 168, south of Shaw Avenue, approximately 7.3 miles to the northwest and Hwy 180 east of Frankwood Avenue, approximately 12 miles east of the site.1 Miles of intervening land uses separate the Project site from either stretch of eligible State Scenic Highway. As such, there is no impact. c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less Than Significant Impact. The proposed Project is located near the eastern Fresno City limit in an area historically utilized for agricultural development. The proposed Project site was used for agricultural purposes prior to 1937 but has been composed of the existing residences and associated outbuildings since 1979.2 These residences, along with existing features such as wells and power lines, will be demolished or removed as part of the Project. It has been designated by the General Plan for urban development. The proposed Project would alter the existing visual character of public views of the site from vacant land with two dilapidated single story residences to fully developed with a 202-lot single-family residential development which would include a mix of one and two story residences. Also included in the 1 California State Scenic Highway Map.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed December 2024.
2 Phase I Environmental Site Assessment for Simonian Estates. RMA GeoScience, October 27, 2023. 15 development are the associated improvements such as an internal roadway and landscaping. The Project design is subject to the City’s Design Guidelines adopted for the City’s General Plan which apply to site layout, building design, landscaping, interior street design, lighting, parking and signage. Detailed architectural plans, color palettes and building materials as well as landscaping plans will be submitted by the Project developer to the City of Fresno Planning and Development Department. The plans shall be required prior to issuance of any building permits.

The Project will require demolition of all existing structures, as well as removal of existing trees and shrubs. Curb and gutters, electrical panels and pedestrian sidewalks are incorporated into the project design, along with site landscaping.

As part of the proposed Project, the site will be annexed and pre-zoned from AL 20/Limited Agriculture (Fresno County) to RS-5/Medium Density Residential (City of Fresno), to be consistent with the proposed Project density and with the residential development immediately to the east and north. Once pre-zoned, the proposed Project will be in compliance with the requirements of the Medium Density Residential Zone.

The improvements such as those proposed by the Project are typical of large city urban areas and are generally expected from residents of the City. These improvements would not substantially degrade the visual character of the area and would not diminish the visual quality of the area, as they would be consistent with the existing visual setting and consistent with regulations governing scenic quality The Project itself is not visually imposing against the scale of the existing landscape and nature of the surrounding area.

Therefore, the Project would have less than significant impacts on the visual character of the area.
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant with Mitigation Incorporated. The proposed Project would result in new lighting sources on the site consistent with adjacent residential development. New lighting sources would include interior lighting from residences, street lighting, lighting from passing vehicles and security lighting. All street and 16 landscape lighting will be consistent with the lighting set forth in Section 15-2508 of the Fresno Municipal Code (FMC), which states that “lights shall be placed to deflect light away from adjacent properties and public streets, and to prevent adverse interference with the normal operation or enjoyment of surrounding properties.” It also states that “windows shall not cause glare that may disrupt adjoining properties, traffic on adjacent streets, etc.” Implementation of mitigation measure AES-1, which includes shielding street lighting to reduce glare, will further reduce potential impacts resulting from street lighting.

The proposed Project may produce temporary light and glare from construction activities, which could stem from construction vehicle and equipment lighting.

However, most construction work is anticipated to take place during daylight hours, and lighting will be directed away from surrounding homes to minimize disruption. The construction-related light will cease once Project construction has finished.

Adherence to the FMC and mitigation measure AES-1 will ensure potential impacts resulting from new sources of light and glare will remain less than significant.

Mitigation Measures:

The proposed Project shall implement and incorporate the Visual resource related mitigation measure as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

AES-1: Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residents. 17 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland,
Unique Farmland, or Farmland of
Statewide Importance (Farmland), as shown on the maps
prepared pursuant to the
Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use?
X
b) Conflict with existing zoning for
agricultural use, or a Williamson
Act contract?
X
18 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Conflict with existing zoning for,
or cause rezoning of, forest land
(as defined in Public Resources
Code section 12220(g)),
timberland (as defined by Public
Resources Code section 4526), or
timberland zoned Timberland
Production (as defined by
Government Code section
51104(g))?
X
d) Result in the loss of forest land
or conversion of forest land to
non-forest use?
X
e) Involve other changes in the
existing environment which, due
to their location or nature, could
result in conversion of Farmland,
to non-agricultural use or
conversion of forest land to nonforest use?
X

DISCUSSION
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
19 Less Than Significant Impact. The site is outside the City limits in an area historically used for agricultural purposes; however, the surrounding areas are now substantially built up with residential uses. This Project is contiguous to an existing urbanized area and would a be natural progression that allows orderly and consistent development of residences to meet the growing demand for housing in the City. The site is designated for residential development by the City of Fresno General Plan.

The California Department of Conservation, Important Farmland Finder Program considers the Project site to be primarily Farmland of Local Importance, 3 aside from
the portions of the parcels on the eastern boundary containing the residences, which are designated Urban and Built-Up Land. No Prime Farmland, Farmland of Statewide Importance, or Unique Farmland is found on the proposed Project site. As such, there would be no significant farmland conversion. Impacts resulting from farmland conversion are less than significant.
b) Conflict with existing zoning for agricultural use or a Williamson Act contract? No Impact. The site is zoned as AL-20 (Limited Agriculture) by Fresno County. The Applicant proposes re-zoning the Project site as RS-5/UGM (Residential Single Family, Medium Density), as per the City of Fresno General Plan zoning designations.

The site is not subject to a Williamson Act contract and no mitigation is required. There is no impact.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. The site is located on the floor of the San Joaquin Valley and does not contain any forest land or timberland. As mentioned in Impact b), above, the site is zoned as AL-20 (Limited Agriculture) by Fresno County. The Applicant proposes re3 California Department of Conservation. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/.

Accessed December 2024.
20 zoning the Project site as RS-5 (Residential Single Family, Medium Density), as per the City of Fresno General Plan zoning designations. The proposed Project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production, and no mitigation is necessary. There is no impact.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. As described in Impact c) above, there is no forest land on the Project site. There is no impact.
e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact. As discussed in Impacts a) and c) above, there is no impact to agricultural land and there is no forest land on-site. The proposed Project will not involve new other changes in the existing environment that could result in conversion of Farmland.

Impacts are less than significant.

Mitigation Measures
None are required.
21 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct
implementation of the applicable
air quality plan (e.g., by having
potential emissions of regulated
criterion pollutants which exceed
the San Joaquin Valley Air
Pollution Control Districts
(SJVAPCD) adopted thresholds
for these pollutants)?
X
b) Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is non-attainment
under an applicable federal or
state ambient air quality standard
(including releasing emissions
which exceed quantitative
thresholds for ozone precursors)?
X
c) Expose sensitive receptors to
substantial pollutant
concentrations?
X
22 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Result in other emissions (such
as those leading to odors)
adversely affecting a substantial
number of people?
X
The following analysis is based primarily on the Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum performed on behalf of the proposed Project by LSA Consulting, report dated December 24, 2024 (see Appendix A).

DISCUSSION
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact with Mitigation Incorporation.

CEQA requires that certain projects be analyzed for consistency with the applicable air quality plan. An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a non-attainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. To bring the San Joaquin Valley Air Basin (SJVAB) into attainment, the San Joaquin Valley Air Pollution Control District (SJVAPCD) adopted the 2016 Plan for the 2008 8-Hour Ozone Standard in June 2016 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8-hour ozone standard.

To assure the SJVAB’s continued attainment of the U.S. Environmental Protection Agency (USEPA) respirable particulate matter (PM10) standard, the SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007.

SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions) is designed to reduce PM10 emissions generated by human activity. The SJVAPCD adopted the 2018 plan for the 23 1997, 2006, and 2012 fine particulate matter (PM2.5) standard to address the USEPA federal annual PM2.5 standard of 12 µg/m3, established in 2012. The SJVAPCD has established project construction and operational emissions thresholds for criteria pollutants, as shown in Table 1 and 2 below. For a project to be consistent with SJVAPCD attainment plans, the pollutants emitted from project operation should not exceed the SJVAPCD daily thresholds, cause a significant impact on air quality, or the project must already have been included in the attainment plans projection.

Construction Emissions
During construction, short-term degradation of air quality may occur due to the release of particulate matter emissions (i.e. fugitive dust) generated by excavation activities.

Emissions from construction equipment are also anticipated and would include CO, NOx, reactive organic gases (ROGs), directly emitted PM2.5 or PM10, and TACs (e.g.

DPMs).

Sources of fugitive dust would include disturbed soils at the construction site. Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PMlO emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PMlO emissions would depend on soil moisture, silt content of soil, wind speed, and amount of operating equipment.

Larger dust particles would settle near the source, whereas fine particles would be dispersed over greater distances from the construction site.

Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. The SJVAPCD has established Regulation VIII measures for reducing fugitive dust emissions (PMl0). With the implementation of Regulation VIII measures, fugitive dust emissions from construction activities would not result in adverse air quality impacts.

In addition to dust-related PMl0 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, sulfur oxides {SOx}, NOx, ROGs, and some soot particulate {PM2.5 and PMl0} in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These 24 emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

Construction emissions were estimated for the Project using CalEEMod and are summarized in Table 1. Consequently, the construction emissions for the Project basis are less than significant.

Table 1: Construction Air Pollutant Emissions4
Year Emissions (tons per year)
ROG NOx CO PM10 PM2.5
2025 0.1 4.5 3.4 0.6 0.3
2026 0.1 2.5 2.2 0.2 0.1
2027 0.1 2.5 2.1 0.2 0.1
2028 1.3 1.5 1.3 0.1 0.1
Maximum Emissions 1.3 4.5 3.4 0.6 0.3

SJVAPCD
Significance threshold
(tons/year
10 10 100 15 15
Exceed threshold—
significant impact?
No No No No No
Notes: Source: Compiled by LSA (2024)
CO=carbon monoxide
NOX=nitrogen oxides
PM2.5=particulate matter less than 2.5 microns in size
PM10=particulate matter less that 10 microns in size
ROG=reactive organic gases
SJVAPCD=San Joaquin Valley Air Pollution Control District 4 Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum for Residential Tract 6376, LSA Consulting. Report dated December 24, 2024. Page 31.
25 As shown in Table 1, construction emissions associated with the proposed Project would not exceed the SJVAPCD's thresholds for ROG, NOx, CO, PMl0, and PM2.5 emissions. In addition to the construction period thresholds of significance, the SJVAPCD has implemented Regulation VIII measures for dust control during construction, which will further reduce construction emissions.

Operational Emissions
Long-term air pollutant emission impacts associated with the proposed Project are those related to mobile sources {e.g., vehicle trips), energy sources (e.g., natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment).

Mobile source emissions include ROG and NOX emissions that contribute to the formation of ozone. Additionally, PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways.

Energy source emissions result from activities in buildings for which natural gas is used. The quantity of emissions is the product of usage intensity {i.e., the amount of natural gas) and the emission factor of the fuel source.

Typically, area source emissions consist of direct sources of air emissions located at the Project site, including architectural coatings and the use of landscape maintenance equipment. Area source emissions associated with the Project would include emissions from the use of landscaping equipment and the use of consumer products.

Long-term operational emissions associated with the proposed Project were calculated using CalEEMod. Table 2 provides the proposed Project's estimated operational emissions.

Table 2: Operational Air Pollutant Emissions5
5 Ibid, page 33.
26 Source Emissions (tons per year)
ROG NOx CO PM10 PM2.5
Mobile 1.1 1.0 6.7 1.6 0.4
Area 1.8 <0.1 1.0 <0.1 <0.1
Energy 0.0 0.0 0.0 0.0 0.0
Total 2.9 1.1 8.3 1.6 0.4
Significance
threshold
10 10 100 15 15
Exceed
threshold—
significant
impact?
No No No No No
Notes: ROG = reactive organic gases NOx = nitrogen oxides CO = carbon monoxide PM10 and PM2.5 = particulate matter
Area source emissions include emissions from natural gas, landscape, and painting.

Source: Compiled by LSA (2024)
The results shown in Table 2 indicate the proposed Project would not exceed the significance criteria for annual ROG, NOX, CO, PMl0, or PM2.5 emissions. Therefore, operation of the proposed Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State AAQS. Thus, any impacts are considered less than significant.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant Impact. The Air Basin is in non-attainment for ozone, PM10, and PM2.5, which means that certain pollutants' exposure levels are often higher than the normal air quality requirements. The air quality standards have been set to protect 27 public health, particularly the health of vulnerable people. Therefore, if the concentration of those contaminants exceeds the norm, some susceptible individuals in the population are likely to experience health effects. The health effects are therefore a factor in the dose-response curve. Concentration of the pollutant in the air, the length of time exposed and the individual's reaction are factors that affect the extent and nature of the health effects. As shown in Table 1 and Table 2, the regional construction and operational emission analysis shows that the Project does not surpass the substantial thresholds of the District and that the Project is compliant with the Air Quality Attainment Plan applicable. Therefore, the Project would not result in significant cumulative health impacts. Impacts are less than significant. c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact.

Long-Term Microscale (CO Hot Spot) Analysis
Vehicular trips associated with the proposed Project would contribute to congestion at intersections and along roadway segments in the vicinity of the proposed Project site.

Localized air quality impacts would occur when emissions from vehicular traffic increase as a result of the proposed Project. The primary mobile-source pollutant of local concern is CO, a direct function of vehicle idling time and, thus, of traffic flow conditions. CO transport is extremely limited; under normal meteorological conditions, it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels, affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients).

Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient background CO concentrations, modeling is recommended to determine a project's effect on local CO levels.

An assessment of project-related impacts on localized ambient air quality requires that future ambient air quality levels be projected. Existing CO concentrations in the immediate Project vicinity are not available. Ambient CO levels monitored at FresnoGarland station, the closest station to the Project site, showed a highest recorded 1- 28 hour concentration of 2.2 ppm (the State standard is 20 ppm) and a highest 8-hour concentration of 1.8 ppm (the State standard is 9 ppm) during the past 3 years. The highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst-case analysis.

Reduced speeds and vehicular congestion at intersections result in increased CO emissions.

The proposed Project is estimated to generate 1,914 average daily trips, including 142 trips during the peak a.m. hour and 191 trips during the peak p.m. hour. Therefore, given the extremely low level of CO concentrations in the Project area and the vehicles are not expected to result in CO concentrations exceeding the State or federal CO standards. No CO hot spots would occur, and the Project would not result in any project-related impacts on CO concentrations.

The closest sensitive receptors to the Project site include a single-family home located east of the Project site within 135 feet. The nearest worker receptor to the Project site is located approximately 2,000 feet southeast of the Project site. The nearest school receptor to the Project site is located approximately 1,700 feet south of the Project site, across North South Armstrong Avenue.

A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed Project. Table 3, below, identifies the results of the analysis assuming the use of Tier 2 construction equipment as proposed by the Project.

Table 3: Health Risks from Project Construction to Off-Site Receptors6 6 Ibid, page 34.
29 Location Carcinogenic
Inhalation Health
Risk in One Million
Chronic Inhalation
Hazard Index
Acute Inhalation
Hazard Index
Residential
Receptor
Risk

11.57 <0.01 0.0
Worker
Receptor
Risk
<0.01 <0.01 0.0
School
Receptor

0.04 <0.01 0.0
Significance
threshold

20.0 in one million 1.0 1.0
Exceed
threshold—
significant
impact?
No No No
As shown in Table 3, the maximum cancer risk for the residential receptor MEI would be 11.57 in one million, which would not exceed the SJVAPCD cancer risk threshold of 20 in one million. The worker receptor risk would be less than 0.01 in 1 million and the school receptor MEI would be 0.04 in 1 million, which would not exceed the SJVAPCD cancer risk thresholds. The total chronic HI would be less than 0.01 all receptors, which is below the threshold of 1.0. In addition, the total acute HI would be nominal (0.000), which would also not exceed the threshold of 1.0. Therefore, construction of the proposed Project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.

Furthermore, the proposed Project would include the construction of a 202unit, singlefamily residential development. As identified in Table 2, Project operational emissions of criteria pollutants would be below SJVAPCD significance thresholds; thus, they are not likely to have a significant impact on sensitive receptors. In addition, the proposed 30 Project would be required to implement District Rule 9510, Indirect Source Review (ISR). Implementation of Rule 9510 would reduce operational emissions of NOX and PM10 by 33.3 percent and 50 percent, respectively. Compliance with SJVAPCD rules would further limit doses and exposures, reducing potential health risk related to gasoline vapors to a level that is not significant. Once the proposed Project is constructed, the proposed Project would not be a source of substantial emissions and would not result in new sources of TACs. Therefore, the Project would not expose sensitive receptors to substantial levels of TACs.

Naturally Occurring Asbestos
The Project is in Fresno County, which is among the counties found to have serpentine and ultramafic rock in their soils. However, according to the California Geological Survey, no such rock has been identified in the Project vicinity. Therefore, the potential risk for naturally occurring asbestos during Project construction is small and would not be significant.

Valley Fever
The Project site is surrounded primarily by residential uses. The closest sensitive receptors to the Project site include a single-family home located east and north of the Project site within 125 feet. Except under high wind conditions, this distance is sufficient that particulate matter would settle prior to reaching the nearest sensitive receptor. In addition, crosswinds influenced by the adjacent roadways would help dissipate any particulate matter associated with the construction phase of the Project.

Therefore, any Valley fever spores suspended with the dust would not be anticipated to reach the sensitive receptors. However, during Project construction, it is possible that workers could be exposed to Valley fever through fugitive dust. Dust control measures, such as regulating visible dust emissions, requiring soil stabilizers, and regulating on-site speed limits, consistent with SJVAPCD Regulation VIII, would reduce the exposure to the workers and sensitive receptors.

The Project should therefore not expose susceptible receptors to significant air pollutant concentrations during operation. Impacts to sensitive receptors will be less than significant.
d) Result in other emissions (such as those leading to odors) adversely affecting 31 a substantial number of people?
Less Than Significant Impact. The SJVAPCD addresses odor criteria within the GAMAQI. The district has not established a rule or standard regarding odor emissions, rather, the district has a nuisance rule: "Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact."
During Project construction, some odors may be present due to diesel exhaust.

However, these odors would be temporary and limited to the construction period.

Residential uses are not anticipated to emit any objectionable odors. Any odors in general would be confined mainly to the Project site and would readily dissipate.

Therefore, the proposed Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. Impacts resulting from creating objectionable odors are less than significant.

Mitigation Measures
None Required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IV. BIOLOGICAL RESOURCES – Would the project:
32 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse
effect, either directly or through
habitat modifications, on any
species identified as a candidate,
sensitive, or special status
species in local or regional plans,
policies, or regulations, or by the
California Department of Fish and
Game or U.S. Fish and Wildlife
Service?
X
b) Have a substantial adverse
effect on any riparian habitat or
other sensitive natural community
identified in local or regional
plans, policies, regulations or by
the California Department of Fish
and Game or US Fish and Wildlife
Service?
X
33 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Have a substantial adverse
effect on federally protected
wetlands as defined by Section
404 of the Clean Water Act
(including, but not limited to,
marsh, vernal pool, coastal, etc.)
through direct removal, filling,
hydrological interruption, or other
means?
X
d) Interfere substantially with the
movement of any native resident
or migratory fish or wildlife species
or with established native resident
or migratory wildlife corridors, or
impede the use of native wildlife
nursery sites?
X
e) Conflict with any local policies
or ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
X
34 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
f) Conflict with the provisions of an
adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan?
X
The following analysis is based primarily on the Biological Due Diligence letter prepared on behalf of the proposed Project by H.T. Harvey & Associates, dated April 15, 2021 (see Appendix B).

DISCUSSION
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? Less than Significant Impact with Mitigation Incorporation. The proposed Project includes five parcels, which are partially developed by three existing residences and other associated structures. The site consists of loose, recently-disked soil, except for the residences located on the property. Approximately 11 acres in the southwest corner and along the central part of the southern border have been disked since the spring 2020 growing season and are sparsely vegetated. The remainder of the site also shows signs of recent disking, but currently is approximately 95% covered in vegetation, with the remainder consisting of bare soil. Garbage is relatively abundant, especially in the northwest corner. Overall, the site conditions are currently unsuitable for special-status plant species. Vegetation on the site is comprised mostly of grasses, 35 but some low-growing forbs are also present (see Appendix B). Plant height is currently low, with grasses and forbs 1-6 inches tall. The site can be characterized as annual grassland in the process of re-establishment; however, as a result of past ground disturbance, the Project site is highly suitable for nonnative invasive plants.

The Project site is relatively far from recent records of special-status species. A query of California Natural Diversity Database records occurring within 5 miles of the Project site revealed seven special-status species occurrences, two of which are for Swainson’s hawk (Buteo swainsoni). The site falls within the extent of a Swainson’s hawk occurrence mapped over Fresno that has not been reconfirmed since 1956. The other Swainson’s hawk occurrence is based on observations from 2016 and is located

3.5 miles southwest of the project site. In addition, there are two occurrences of burrowing owls (Athene cunicularia), one located 4.2 miles to the north at Fresno Yosemite International Airport and another located 4.0 miles to the northwest in Clovis.

Also, double-crested cormorant (Phalacrocorax auritus) was documented at a collection of ponds 4.8 mi. to the north-northwest in 2012. The remaining records (for least Bell’s vireo [Vireo bellii pusillus] and western yellow-billed cuckoo [Coccyzus americanus occidentalis]) are both over 3.5 miles away from the site and have not been reconfirmed within the last 108 years.

The annual grassland in the Project area potentially provides habitat for common, rural and urban-adapted wildlife species, such as ground-foraging and -nesting birds, California ground squirrels (Otospermophilus beecheyi), pocket gophers (Thomomys bottae), and desert cottontail (Sylvilagus audobonii). Wildlife directly observed on the project site consisted of common bird species and the remains of two California ground squirrels. Several individuals of each of four common bird species (mourning dove [Zenaida macroura], California scrub-jay [Aphelocoma californica], dark-eyed junco [Junco hyemalis], and European starling [Sturnus vulgaris]) were observed perched on and flying around the line of trees on the southern border of the Project site. Numerous small mammal burrows occur on the Project site. Several active pocket gopher burrows were found scattered across the site. The site also currently supports a large population of California ground squirrels. Their burrows were abundant at the edge and along the slopes of the detention pond and were moderately abundant throughout the rest of the site. The California ground squirrel remains were located within 1 foot of burrows of this species and represent predation and/or 36 scavenging, perhaps by red-tailed hawks or other raptors. No signs of mammalian predators (e.g. coyotes [Canis latrans]) were observed. All animal species observed directly on or near (i.e., within 0.25 mi.) the Project site are listed in Appendix A within Appendix B. Many of the California ground squirrel burrows are large (about 3-5 inches in diameter), with large, unvegetated aprons, and thus are potentially suitable for use by burrowing owls, which is listed as Species of Special Concern by the State of California. No burrowing owls or signs of this species (e.g. pellets, feathers, or wash) were observed. However, the survey was conducted during conditions of light to moderately heavy rain in the middle of a rain event lasting several days. Any owls present would have been underground in their burrows, and their wash would have been rinsed away. The occurrence of potentially suitable burrows suggests that burrowing owls might be present. No direct evidence of special-status animal or plant species was observed and the site provides little or no value to sensitive plant and wildlife species with the exception of burrowing owl. The presence of burrowing owls on the property could constrain the development of the parcel or result in project delays. Burrowing owls, and their nests are protected under state laws and regulations, including the California Fish and Game Code Section 3503.5.

Based on current understanding of burrowing owl distribution in the Central Valley, burrowing owls are unlikely to occupy this site. The size of the parcel and the adjacent similar parcel west combined with the number of suitable burrows on the site, however, warrant a cautious approach. Implementation of Mitigation Measure BIO-1, which includes measures outlined in the CDFW Staff Report on Burrowing Owl, such as conducting construction during non-nesting season, will ensure that a less than significant impact to burrowing owl occurs.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
No Impact. There are no riparian habitats or other sensitive natural communities identified in local or regional plans, policies, or regulation or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service in the subject site. Additionally, there are no natural waterways or sensitive natural communities on the subject site or in the immediate vicinity. As such, there is no impact. 37 c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. There are no state or federally protected wetlands on the subject site.7 As such, there is no impact.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than Significant Impact with Mitigation Incorporation. As previously mentioned, the site contains single-family residences and highly disturbed vacant land, periodically disked for weed control, and is substantially surrounded by urban development. This precludes the ability of wildlife species to freely move throughout the area creating a migratory corridor. Project development could, however, impede the use of nursery sites for native birds protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC). Migratory birds could potentially nest on and near the trees surrounding the existing buildings on the Project site.

Construction disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings or otherwise lead to nest abandonment. Disturbance that causes nest abandonment or loss of reproductive effort can be considered a “take” under the MBTA and CFGC. Loss of fertile eggs or nesting birds, or any activities resulting in nest abandonment, could constitute a significant effect if the species is particularly rare in the region. Construction activities such as excavating, trenching, and grading that disturb a nesting bird on the Project site or immediately adjacent to the construction zone could constitute a significant impact Mitigation Measure BIO-2, which includes conducting construction during non-nesting season, shall be implemented to reduce the potential effect to a less than significant level. e) Conflict with any local policies or ordinances protecting biological resources, 7 US Fish and Wildlife Service. National Wetlands Inventory Surface Waters and Wetlands Mapper. https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed December 2024. 38 such as a tree preservation policy or ordinance?
Less Than Significant Impact. The City’s General Plan Parks, Open Space, and Schools Element contains several objectives and policies pertaining to the protection of biological resources. Most of the policies pertain to general long-term protection and preservation of biological resources including providing buffers for natural areas, implementing habitat restoration where applicable, protection/enhancement of the San Joaquin River area, and other similar policies. Since the Project is located in a highly disturbed area with minimal biological resources and does not include significant impacts to protected plant or animal species, the Project does not conflict with any adopted policies pertaining to biological resources. The Project is also required to implement Fresno Municipal Code Chapter 13, Article 3 – Street Trees and Parkways pertaining to tree removal and replacement. Therefore, there is a less than significant impact.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The Pacific Gas & Electric (PG&E) San Joaquin Valley Operation and Maintenance (O&M) Habitat Conservation Plan (HCP) was approved in 2007 and covers portions of nine counties, including Fresno County and the city of Fresno. This HCP covers PG&E activities which occur as a result of ongoing O&M that would have an adverse impact on any species covered by the HCP. The HCP also provides incidental take coverage from the USFWS and CDFW.

The proposed Project site is not located within the boundaries of any other approved or draft Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other adopted local, regional or state HCP. Therefore, development of the proposed Project would not result in any impacts to an adopted HCP or NCCP. There is no impact.

Mitigation Measures
39 The proposed project shall implement and incorporate the biological resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

BIO-1: In addition to implementation of the measures included in the Staff Report on Burrowing Owl Mitigation (CDFG 2012), if construction activities occur during the avian nesting season (generally, February 1 through August 31), preconstruction surveys for nesting birds by a qualified ornithologist should be conducted to ensure that no active nests are disturbed during construction. The survey should be conducted no more than seven days before construction activities begin. During this survey, all potential nesting areas should be inspected in and immediately adjacent to the impact areas for nests. If an active nest is found sufficiently close to work areas to be disturbed by these activities, the ornithologist should determine the extent of a construction-free buffer zone to be established around the nest (typically, 300 ft. for raptors and 25–100 ft. for other species) to ensure that no active nests of species protected by the California Fish and Game Code would be disturbed during project construction.

BIO-2: To the extent practicable, construction shall be scheduled to avoid the nesting season, which extends from February through August. If it is not possible to schedule construction between September and January, preconstruction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no active nests would be disturbed during the implementation of the Project. A pre-construction survey shall be conducted no more than 14 days prior to the initiation of construction activities. During this survey, the qualified biologist shall inspect all potential nest substrates in and immediately adjacent to the impact areas. If an active nest is found close enough to the construction area to be disturbed by these activities, the qualified biologist shall determine the extent of a construction-free buffer to be established around the nest. If work cannot proceed without disturbing the nesting birds, work may need to be halted or redirected to other areas until nesting and fledging are completed or the nest has otherwise failed for non-construction related reasons.
40 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse
change in the significance of a
historical resource as defined in
Section 15064.5?
X
b) Cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to Section 15064.5?
X
c) Disturb any human remains,
including those interred outside of
formal cemeteries?
X
A Phase I Cultural Resources Survey was conducted by Hudlow Cultural Resource Associates, report date November 2024 (see Appendix C). The Phase I Cultural Resources Survey consisted of a pedestrian survey and a cultural resource record search and is the basis for analysis of the discussion below.

DISCUSSION
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
41 Less Than Significant Impact with Mitigation Incorporated. For purposes of this section, the term "historical resources" shall include the following: (1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 14 CCR, Section 4850 et seq.). (2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. (3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency's determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub.

Res. Code, § 5024.1, Title 14 CCR, Section 14 CCR, Section 4852) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history.

A record search of the Project area and the environs within one half-mile was conducted at the Southern San Joaquin Information Center. Information Center staff conducted the record search, RS# 24-299, on July 8, 2024. The record search 42 revealed that one cultural resource survey has been conducted within one half-mile of the Project area. No cultural resource surveys have previously addressed the parcel in question. No cultural resources have been located on the current Project area; however, one cultural resource has been recorded within one half-mile of the current Project area, the former Southern Pacific Railroad line, which is operated by the San Joaquin Valley Railroad, which is directly on the project’s northern boundary.

Additionally, on November 12-13, 2024, Scott M. Hudlow conducted a pedestrian archaeological survey of the entire proposed Project area. Hudlow surveyed in north/south transects across the lot in 10-meter (33 feet) intervals. No cultural resources were identified or observed; however, three homes were located on the property as recently as 2022, on the west side of Armstrong Avenue. No remains from these three homes survived demolition, except for a non-historic concrete block retaining wall along Armstrong Avenue. If archaeological resources are encountered during the course of construction, a qualified archaeologist should be consulted for further evaluation.

Although no cultural or archaeological resources, paleontological resources or human remains have been identified in the Project area to date, the possibility exists that such resources or remains may be discovered during Project site preparation, excavation and/or grading activities. As such, Mitigation Measure CUL-1 shall be implemented to protect undiscovered resources. Adherence to this mitigation measure will result in a less than significant impact.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less Than Significant Impact with Mitigation Incorporated. As discussed in Impact a) above, no surface or recorded evidence of sensitive cultural resources have been recorded. However, the possibility exists that such resources or remains may be discovered during Project site preparation, excavation and/or grading activities.

Mitigation Measure CUL – 1 will be implemented to ensure that Project will result in less than significant impact.
c) Disturb any human remains, including those interred outside of formal cemeteries?
43 Less Than Significant Impact with Mitigation Incorporated. The discovery of human remains is regulated by California Health and Safety Code Section 7050.5, which states that:

In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation…until the coroner…has determined…that the remains are not subject to…provisions of law concerning investigation of the circumstances, manner and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible…. The coroner shall make his or her determination within two working days from the time the person responsible for the excavation, or his or her authorized representative, notifies the coroner of the discovery or recognition of the human remains. If the coroner determines that the remains are not subject to his or her authority and…has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

Compliance with California Health and Safety Code Section 7050.5 would reduce potential impacts to human remains to less than significant.

Mitigation Measures
The proposed project shall implement and incorporate the cultural resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

CUL – 1: Should evidence of prehistoric archeological resources be discovered during construction, the contractor shall halt all work within 25 feet of the find and the resource shall be evaluated by a qualified archaeologist. If evidence of any archaeological, cultural, and/or historical deposits is found, hand excavation and/or mechanical excavation shall proceed to evaluate the deposits for determination of significance as defined by the CEQA guidelines. The archaeologist shall submit reports, to the satisfaction of the City of Fresno, describing the testing program and subsequent results.

These reports shall identify any program mitigation that the project 44 proponent shall complete in order to mitigate archaeological impacts (including resource recovery and/or avoidance testing and analysis, removal, reburial, and curation of archaeological resources). 45 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VI. ENERGY – Would the project:
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
X
b) Conflict with or obstruct a state
or local plan for renewable energy
or energy efficiency?
X
The following analysis is based primarily on the Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum performed on behalf of the proposed Project by LSA Consulting, report dated December 24, 2024 (see Appendix A).

DISCUSSION
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant Impact. The Project includes construction of a 202-lot singlefamily residential unit development, including a 0.39-acre park and other associated 46 improvements. The Project would increase energy usage on a site that is presently demanding minimal energy.

Construction
The anticipated construction schedule assumes that the proposed Project would be built in approximately three years. Construction-specific phases were assessed for their energy consumption under each construction sub-phase: grading, site preparation, building construction, paving, and architectural coating activities.

Construction would require energy for the manufacture and transportation of construction materials, preparation of the site for grading and building activities, and construction of the building. All or most of this energy would be derived from nonrenewable resources.

Petroleum fuels (e.g., diesel and gasoline) would be the primary sources of energy for these activities. However, construction activities are not anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the Project. One common practice is to utilize Global Positioning System (GPS) technology on grading equipment to efficiently grade the site. Energy (i.e., fuel) usage on the Project site during construction would be temporary in nature and would be relatively small in comparison to the State's available energy sources.

Operation
Energy use associated with the proposed Project would consist of natural gas, electricity, and vehicle fuel use associated with Project operations.

Table 4 shows the estimated potential increased electricity, gasoline, and diesel demand associated with the proposed Project. The electricity and natural gas rates are from the CalEEMod analysis, and the gasoline and diesel rates are based on the traffic analysis in conjunction with USDOT fuel efficiency data and use the USEPA's fuel economy estimates for 2020 and the California diesel fuel economy estimates for 2021. Energy and Fuel Calculations output sheets are included in Appendix A.

Table 4: Estimated Annual Energy Use of the Proposed Project8 8 Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum for Residential Tract 6376, LSA Consulting. Report dated December 24, 2024. Page 37.
47 Electricity Use
(kWh per year)
Natural Gas Use
(kBTU per year)
Gasoline
(gallons per
year)
Diesel
(gallons per
year)
Proposed
Project
1,897,356 0 159,991 122,720
Source: Compiled by LSA (2024).
kBTU= thousand British thermal units kWh= kilowatt hours As shown in Table 4, the estimated increase in electricity demand associated with the operation of the proposed Project would be 1,897,356 kWh per year. Total electricity consumption in Fresno County in 2022 was 8,384,408,687 kWh; therefore, operation of the proposed Project would negligibly increase the annual electricity consumption in Fresno County by approximately less than 0.1 percent.

As shown in Table 4, there would not be an increase in natural gas use as the Project is all electric. Therefore, operation of the proposed Project would not increase the annual natural gas consumption in Fresno County.

In addition, the Project would result in energy usage associated with motor vehicle gasoline to fuel project-related trips. As shown above in Table 4, the proposed Project would result in the consumption of 159,991 gallons of gasoline and 122,720 gallons of diesel per year. Based on fuel consumption obtained from EMFAC2021, approximately 337.0 million gallons of gasoline and approximately 154.4 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2028. Therefore, vehicle trips associated with the proposed project would increase the annual fuel use in Fresno County by approximately less than 0.1 percent for gasoline fuel usage and approximately less than

0.1 percent for diesel fuel usage. The proposed Project would result in fuel usage that is a small fraction of current annual fuel use in Fresno County, and fuel consumption associated with vehicle trips generated by Project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Therefore, gasoline demand generated by vehicle trips associated with the proposed Project would be a minimal fraction of gasoline and diesel fuel consumption in California.
48 Furthermore, the proposed Project would be constructed using energy efficient modern building materials, such as highly efficient insulation, multiple-pane windows and solar panels , and the proposed Project also would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). The expected energy consumption during construction and operation of the proposed Project would be consistent with typical usage rates for residential uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings.

PG&E is the private utility that would supply the proposed Project's electricity. In 2021, a total of 50 percent of PG&E's delivered electricity came from renewable sources, including solar, wind, geothermal, small hydroelectric, and various forms of bioenergy. PG&E reached California's 2020 renewable energy goal in 2017 and is positioned to meet the State's 60 percent by 2030 renewable energy mandate set forth in SB 100. In addition, PG&E plans to continue to provide reliable service to its customers and upgrade its distribution systems as necessary to meet future demand. As such, the proposed Project would not result in a potential significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operation.

As such, any impacts are less than significant.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact. The California Energy Commission (CEC) recently adopted the 2023 Integrated Energy Policy Report. The 2023 Integrated Energy Policy Report provides the results of the CEC's assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs. The 2023 Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecasts, and the California Energy Demand Forecast. 49 As indicated above, energy usage on the Project site during construction would be temporary in nature and would be relatively small in comparison to the State's available energy sources. In addition, energy usage associated with operation of the proposed Project would be relatively small in comparison to the region's available energy sources, and energy impacts would be negligible at the regional level. Because California's energy conservation planning actions are conducted at a regional level, and because the Project's total impact on regional energy supplies would be minor, the proposed Project would not conflict with or obstruct California's energy conservation plans as described in the CEC's 2023 Integrated Energy Policy Report. Therefore, the proposed Project would not lead to new or substantially more severe energy impacts.

For the above reasons, the proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

Mitigation Measures
None required.
50 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or Indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:
i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? Refer
to Division of Mines and Geology
Special Publication 42.

X
ii) Strong seismic ground
shaking?
X
iii) Seismic-related ground failure,
including liquefaction?
X
iv) Landslides? X
b) Result in substantial soil
erosion or the loss of topsoil?
X
51 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Be located on a geologic unit or
soil that is unstable, or that would
become unstable as a result of the
project, and potentially result in
on- or off-site landslide, lateral
spreading, subsidence,
liquefaction or collapse?
X
d) Be located on expansive soil,
as defined in Table 18-1-B of the
Uniform Building Code (1994),
creating substantial risks to life or
property?
X
e) Have soils incapable of
adequately supporting the use of
septic tanks or alternative waste
water disposal systems where
sewers are not available for the
disposal of waste water?
X
f) Directly or indirectly destroy a
unique paleontological resource
or site or unique geologic feature?
X

DISCUSSION
a) Directly or indirectly cause potential substantial adverse effects, including 52 the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Less Than Significant Impact. According to the Fault Rupture Zones Map prepared by the California Department of Conservation in 2018, the Project site is not located within a Fault‐Rupture Hazard Area.9 Moreover, no active faults have been identified within the City of Fresno. The nearest zoned fault to the City is a portion of the Nunez Fault, located approximately 48 miles southwest of the City. Therefore, because no active faults occur within the City, impacts associated with fault rupture would be less than significant. ii. Strong seismic ground shaking?
Less Than Significant Impact. It is anticipated that the proposed Project site would be subject to some ground acceleration and ground shaking associated with seismic activity during its design life. The Project site would be engineered and constructed in strict accordance with the earthquake resistant design requirements contained in the latest edition of the California Building Code (CBC) for seismic zone III, as well as Title 24 of the California Administrative Code, and therefore would avoid potential seismically induced hazards on planned structures. The impact of strong seismic ground shaking on the Project would be less than significant.
iii. Seismic-related ground failure, including liquefaction? Less Than Significant Impact. The potential for soil liquefaction within the City of Fresno ranges from very low to moderate due to the variable density of the subsurface soils and the presence of shallow groundwater. The proposed Project will be subject to policies in the Fresno Municipal Code, including 9 California Department of Conservation. California Geological Survey. Fault Activity Map of California. https://maps.conservation.ca.gov/cgs/fam/. Accessed December 2024. 53 Section 11-101, which would reduce potential settlement and lateral spread impacts to less than significant levels.
iv. Landslides?
Less Than Significant Impact. Landslides are the release of rock, soil, or other debris and its subsequent movement down a slope or hillside. Landslides occur during earthquakes, triggered by the strain induced in soil and rock by ground shaking vibrations, and during non-earthquake conditions, most frequently during the rainy season. Any slope of 15 degrees or greater is susceptible to mud or landslides. The Project area is generally flat in nature, with slopes nearly at zero degrees. As such, the Project site is not susceptible to mud or landslides during non-earthquake conditions during the dry or rainy season.

Additionally, the proposed Project site is not located in an earthquake fault zone as delineated by the 1972 Alquist-Priolo Earthquake Fault Zoning Map Act. No active faults have been mapped within the Project boundaries, so there is no potential for fault rupture. It is anticipated that the proposed Project site would be subject to some ground acceleration and ground shaking associated with seismic activity during its design life. The Project site would be engineered and constructed in strict accordance with the earthquake resistant design requirements contained in the latest edition of the California Building Code (CBC) for seismic zone III, as well as Title 24 of the California Administrative Code, and therefore would avoid potential seismically induced hazards on planned structures. The impact of landslides on the Project would be less than significant.
b) Result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Construction activities associated with the Project involves ground preparation work for the new residential development, streets, and the associated improvements. These activities could expose barren soils to sources of wind or water, resulting in the potential for erosion and sedimentation on and off the Project 54 site. During construction, nuisance flow caused by minor rain could flow off-site. The City and/or contractor would be required to employ appropriate sediment and erosion control Best Management Practices (BMPs) as part of a Stormwater Pollution Prevention Plan (SWPPP) that is in the California National Pollution Discharge Elimination System (NPDES). In addition, soil erosion and loss of topsoil would be minimized through implementation of the SVJAPCD fugitive dust control measures (See Section III). Once construction is complete, the Project would not result in soil erosion or loss of topsoil.

Adherence to local and state requirements will ensure that any impacts are less than significant.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? Less Than Significant Impact. As discussed in Impact a) above, the site is not at significant risk from earthquakes, ground shaking, liquefaction, or landslide and is otherwise considered geologically stable. Subsidence is typically related to overextraction of groundwater from certain types of geologic formations where the water is partly responsible for supporting the ground surface. However, the City of Fresno is not recognized by the U.S. Geological Service as being in an area of subsidence.10 Impacts are considered less than significant.
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated), creating substantial direct or indirect risks to life or property?
Less Than Significant Impact. Surface and near-surface soils throughout the city of Fresno consist of varying combinations of clays, silts, sands, gravels, and cobbles.

The Project site is underlain by Exeter sandy loam (NCRS 2023). This soil type is considered well drained with a low ability for water storage, which means they are unlikely 10 U.S. Geological Service. Areas of Land Subsidence in California. https://ca.water.usgs.gov/land_subsidence/californiasubsidence-areas.html. Accessed December 2024. 55 to expand.11 Any impacts are less than significant.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. Under the approved City of Fresno General Plan, all development within the City limits is required to install public sewage collection and disposal systems. The Project does not include the construction or replacement of septic tanks or alternative wastewater disposal systems. Any existing on-site septic tanks and systems will be abandoned according to county standards. The Project will be required to tie into existing sewer services (See Utilities section for more details). Therefore, there is no impact. f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant Impact with Mitigation. There are no unique geological features on site or in the area. As discussed previously in this document, there are no known cultural or historical resources on or near the site. (See Section V. for more details).

Mitigation Measure CUL-1 is included to reduce potential impacts to undiscovered resources. Therefore, there is a less than significant impact with mitigation.

Mitigation Measures
See CUL-1 in Section V.
11 USDA Natural Resources Conservation Service. Custom Soil Resource Report for Eastern Fresno Area, California. 56 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
X
b) Conflict with an applicable plan,
policy or regulation adopted for
the purpose of reducing the
emissions of greenhouse gases?
X
The following analysis is based primarily on the Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum performed on behalf of the proposed Project by LSA Consulting, report dated December 24, 2024 (see Appendix A).

DISCUSSION
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact.

Construction Greenhouse Gas Emissions
Construction activities associated with the proposed Project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder 57 fossil-based fuels created GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

The SJVAPCD does not have an adopted threshold of significance for constructionrelated GHG emissions. However, lead agencies are encouraged to quantify and disclose GHG emissions that would occur during construction. Using CalEEMod, it is estimated that the total emissions associated with construction of the proposed Project would be approximately 1,562.8 metric tons (MT) of CO2e. Construction GHG emissions were amortized over the life of the Project (assumed to be 30 years) and added to the operational emissions. When annualized over the life of the Project, amortized construction emissions would be approximately 52.1 MT CO2e per year.

Operational Greenhouse Gas Emissions
Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle and truck trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile-source GHG emissions would include projectgenerated vehicle trips to and from the Project. Area-source emissions would be associated with activities such as landscaping and maintenance on the Project site.

Energy source emissions would be generated at off-site utility providers as a result of increased electricity demand generated by the Project. Waste source emissions generated by the proposed Project include energy generated by land filling and other methods of disposal related to transporting and managing Project generated waste.

In addition, water source emissions associated with the proposed Project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.

GHG emissions for operation of the Project were calculated using CalEEMod. Based on the analysis results, summarized in Table 5, the proposed Project would result in emissions of approximately 2,018.7 MT CO2e per year. These estimated emissions are provided for informational purposes, and the significance of the proposed Project is further analyzed below.
58 Table 5: Greenhouse Gas Emissions12
Emission Type Total CO2 CH4 N2O CO2E
Mobile 1,684.7 0.1 0.1 1,716
Area 2.5 <0.1 <0.1 2.5
Energy 175.6 <0.1 <0.1 177
Water 6.1 0.3 0.3 14.7
Waste 16.1 1.6 0.0 56.4
Amortized Construction Emissions 52.1
Total Operational Emissions 2,018.7
Notes: Due to rounding, total may be marginally different from CalEEMod output.

CH4 = methane CO2E = carbon dioxide equivalent
Co2 = carbon dioxide N20 = nitrous oxide
Source: Compiled by LSA (2024).

As discussed above, the SJVAPCD has not established a numeric threshold for GHG emissions, and the City does not have a current GHG Reduction Plan. In the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed Project for consistency with the BAAQMD Justification Report, which identifies project design elements as the applicable thresholds of significance. If a 12 Air Quality, Energy and Greenhouse Gas Emissions Technical Memorandum for Residential Tract 6376, LSA Consulting. Report dated December 24, 2024. Page 39.
59 project is designed and built to incorporate design elements related to natural gas, energy, VMT, and EVs, then it would contribute its portion of what is necessary to achieve California's long-term climate goals-its "fair share"-and an agency reviewing the project under CEQA can conclude that the project would not make a cumulatively considerable contribution to global climate change.

Per the significance thresholds described above, a less than significant GHG impact would occur if the Project were consistent with the identified design standards, as evaluated below.

Natural Gas Usage. A less than significant GHG impact would occur if the Project does not include natural gas appliances or natural gas plumbing. The proposed Project would not include natural gas. Therefore, the proposed Project would be consistent with this design element.

Energy Usage. Under this design criterion, the Project must not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

Energy use consumed by the proposed Project would be associated with electricity consumption associated with the Project. Energy consumption was estimated for the Project using default energy intensities by land use type in the CalEEMod output, which is included in Appendix A.

As shown in Table 5 above, the estimated potential increase in electricity demand associated with the operation of the proposed Project is 1,897,356878,579 kWh per year. Total electricity consumption in Fresno County in 2022 was 8,384,408,687 kWh.

Therefore, operation of the proposed Project would increase the annual electricity consumption in Fresno County by approximately 0.1 percent.

In addition, the proposed Project would be constructed to current Title 24 standards, which would require energy-saving building features. As such, based on this analysis, as required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines, the proposed Project would not result in the wasteful, inefficient, or unnecessary consumption of fuel or energy and would incorporate renewable energy and energy efficiency measures into the building design, equipment use, and 60 transportation. As such, the proposed Project would be consistent with this design element.

Electric Vehicle Requirements. The final project design element that the proposed Project should include to ensure that it is achieving its "fair share" of GHG emission reductions is compliance with off-street EV requirements in the most recently adopted version of the CALGreen Code Tier 2 measures. The proposed Project would include an EV charging station for each home, consistent with CALGreen Tier 2 standards.

Therefore, the proposed Project would be consistent with this design element.

The proposed Project would be consistent with the project design elements related to natural gas, energy, VMT, and EVs. Therefore, the proposed Project would be consistent with the GHG emission thresholds identified for this Project. As such, the proposed Project would have a less than significant impact on the environment. b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less Than Significant Impact. The proposed Project is further analyzed for consistency with the City of Fresno General Plan policies, the 2022 Scoping Plan, and Fresno COG's RTP/SCS.

City of Fresno General Plan
The City's General Plan, including the Resources Conservation and Resilience Element as well as land use policies, includes objectives and policies that work to achieve and maintain reductions in GHG emissions and all strategies that reduce the 61 causes of climate change. A consistency analysis with the applicable policies from the Resources Conservation and Resilience Element and other relevant General Plan policies and objectives is presented below.

The proposed Project would be consistent with the following policies:

RC-5-a: In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take timely, necessary, and the most cost-effective actions to achieve and maintain reductions in greenhouse gas emissions and all strategies that reduce the causes of climate change in order to limit and prevent the related potential determinant effects upon public health and welfare of present and future residents of the Fresno community.

RC-5-d: SCS and CAP Conformity Analysis. Ensure that the City includes analysis of a project’s conformity to an adopted regional Sustainable Community Strategy or Alternative Planning Strategy (APS), an adopted Climate Action Plan (CAP), and any other applicable City and regional greenhouse gas reduction strategies in affect at the time of project review.

RC-5-e: Ensure Compliance. Ensure ongoing compliance with GHG emissions reduction plans and programs by requiring that air quality measures are incorporated into projects’ design, conditions of approval and mitigation measures.

RC-5- g: Evaluate Impacts with Models. Continue to use computer models such as those used by the SJVAPCD to evaluate greenhouse gas impacts of plans and projects that require such review.

RC 7: Promote water conservation through standards, incentives and capital investments.

RC 7-h: Landscape Water Conservation Standards. Refine landscape water conservation standards that will apply to new development installed landscapes, buildingon the State Model Water Efficient Landscape Ordinance and other State regulations.
• Evaluate and apply, as appropriate, augmented xeriscape, “water-wie,” and 62 “green gardening” practices to be implemented in public and private landscaping design and maintenance.
• Facilitate implementation of the State’s Water Efficient Landscape Ordinance by developing alternative compliance measures that are easy to understand and observe.

RC 11: Strive to reduce the solid waste going to landfills to zero by 2035..

The proposed Project would construct a 203-unit single-family development in a vacant lot and would provide infill development to an already established neighborhood in the City. Thus, the Project would be consistent with land use policies and strategies established in the General Plan including:

UF 12: Locate roughly one-half of future residential development in infill area – defined as being within the City on December 31, 2012 – including the Downtown core area and surrounding neighborhoods, mixed-use centers and transit-oriented development along major BRT corridors, and other non-BRT corridor infill areas, and vacant land.

UF 12-a: BRT corridors – Design land uses and integrate development site plans along BRT corridors, with transit-oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops.

RC 2-a:Link Land Use to Transportation – Promote mixed-use, higher density infill development in multi-modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher-intensity development. Discourage investment in infrastructure that would not meet these criteria.

In addition, the proposed Project would comply with the 2022 CALGreen Code building measures and Title 24 standards for solar and EVs. Thus, the proposed Project would incorporate the appropriate energy and water conservation standards, facilitate incentives for the incorporation of bicycle and pedestrian amenities, and would encourage the use of alternative modes of transportation.

The proposed Project would also provide complete streets for all internal roadway improvements, which would increase connectivity with the surrounding land uses and neighborhoods. Therefore, the proposed Project would also be consistent with the 63 applicable strategies under policy RC-5-c and policies related to energy conservation, land use planning, and transportation demand outlined in the General Plan such as MT 4, MT 4-c, MT 5, MT 6, MT 8, and MT 8-b. Moreover, the proposed Project would provide recycling canisters and would implement techniques for solid waste segregation, disposal, and reduction, consistent with the CalRecycle Waste Diversion and Recycling Mandate. Therefore, the proposed Project would be consistent with waste diversion and recycling strategies under RC 11-a.

As further discussed in the following section, the proposed Project would also be consistent with the goals outlined in the Fresno COG 2022 RTP/SCS and would not interfere with the Fresno COG's ability to achieve the region's GHG reductions.

Therefore, the Project would also be consistent with policy RC-5-d. Furthermore, PG&E is the private utility that would supply the proposed Project's electricity. Future residents would have the option to join an energy savings program, which would help educate homeowners on green energy. Therefore, the proposed Project would be consistent with policy RC-5-f. The analysis presented is conducted with the latest CalEEMod version, consistent with policy RC-5-g.

Through consistency with supporting and implementing the General Plan objectives and policies, the proposed Project is consistent with and would not conflict with or obstruct the implementation of the City's General Plan. 2022 Scoping Plan
The following discussion evaluates the proposed project according to the goals of the 2022 Scoping Plan,49 EO B-30-15, SB 32, and AB 197.

EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the 2030 target set by EO B-30-15 and codified by SB

32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps California on the path toward achieving the State's 2050 objective of reducing emissions to 80 percent below 1990 levels. The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional 64 direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California will be zeroemission by 2035, and all other fleets will have transitioned to zero-emission as fully possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.

Energy efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California's new and existing inventory of buildings. As discussed in the Energy section of this document, the proposed Project would not result in the wasteful or inefficient use of energy. The proposed Project would be required to comply with the latest Title 24 standards of the CCR, established by the CEC, regarding energy conservation and green building standards. Therefore, the proposed project would comply with applicable energy measures.
65 Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions.

The Project would comply with the CALGreen Code, which includes a variety of different measures, including the reduction of wastewater and water use. In addition, the proposed Project would be required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the proposed Project would not conflict with any of the water conservation and efficiency measures.

Fresno COG's 2022 RTP/SCS
The Fresno COG RTP/SCS reflects transportation planning for Fresno County through 2046. The vision, goals, and policies in the 2022 RTP are intended to serve as the foundation for both short and long-term planning and guide implementation activities.

The core vision in the 2022 RTP is to create a region of diverse, safe, resilient, and accessible transportation options that improve the quality of life for all residents by fostering sustainability, equity, a vibrant economy, clean air, and healthy communities.

The 2022 RTP contains transportation projects to help more efficiently distribute population, housing, and employment growth, as well as forecast development that is generally consistent with regional-level general plan data. The actions in the 2022 RTP address all transportation modes (e.g., highways, local streets and roads, mass transportation, rail, bicycle, and aviation facilities and services) and consists of short and long-term activities that address regional transportation needs. While the actions are organized by the five key policy areas, many of them support multiple goals and policies. Some actions are intended to support the SCS and reduce GHG emissions directly, while others are focused on the RTP's broader goals. The 2022 RTP does 66 not require that local General Plans, Specific Plans, or zoning be consistent with the 2022 RTP, but provides incentives for consistency for governments and developers.

The proposed Project would not interfere with the Fresno COG's ability to achieve the region's GHG reductions. Furthermore, the proposed Project is not regionally significant per State CEQA Guidelines Section 15206, and it would not conflict with the 2022 RTP targets because those targets were established and are applicable on a regional level. While the proposed Project site would require rezoning for the proposed land use, the proposed Project would result in a baseline VMT well above the per-capita threshold established by the City to support the region achieving the State's GHG reductions included under SB 743. Based on the average number of residents per household in Fresno of 2.96, the proposed Project would result in an estimated population increase of approximately 601 residents, well within the estimated population growth of 647,980 residents in 2030 as included in the 2022 RTP. Therefore, it is anticipated that implementation of the proposed Project would not interfere with Fresno COG's ability to implement the regional strategies outlined in the 2022 RTP. The proposed Project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in the 2022 RTP and would be consistent with applicable State plans and programs designed to reduce GHG emissions.

Therefore, the proposed Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions.

The Project would not result in the emission of substantial GHG emissions.

Additionally, the Project would not conflict with local or regional plans and policies for GHG emission reductions, nor with the State's GHG emissions reductions objectives embodied in the 2022 Scoping Plan.

Therefore, the proposed Project's incremental contribution to cumulative GHG emissions would not be cumulatively considerable. The impact would be considered less than significant.

Mitigation Measures:

None are required.
67 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IX. HAZARDS AND HAZARDOUS MATERIAL – Would the project:
a) Create a significant hazard to
the public or the environment
through the routine transport, use,
or disposal of hazardous
materials?
X
b) Create a significant hazard to
the public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of hazardous
materials into the environment?
X
c) Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile of
an existing or proposed school?
X
68 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Be located on a site which is
included on a list of hazardous
materials sites compiled pursuant
to Government Code Section
65962.5 and, as a result, would it
create a significant hazard to the
public or the environment?
X
e) For a project located within an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project result in a safety hazard for
people residing or working in the
project area?
X
f) Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
X
g) Expose people or structures,
either directly or indirectly, to a
significant risk of loss, injury or
death involving wildland fires?
X
69 DISCUSSION
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less Than Significant Impact. Construction of the Project would require the use and transport of hazardous materials, including fuels, oils, and other chemicals (e.g., paints, lead, adhesives, etc.) typically used during construction. It is likely that these hazardous materials and vehicles would be stored by the contractor(s) on-site during construction activities. Improper use and transportation of hazardous materials could result in accidental releases or spills, potentially posing health risks to workers, the public, and the environment. However, all materials used during construction would be contained, stored, and handled in compliance with applicable standards and regulations established by the Department of Toxic Substances Control (DTSC), the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA), as regulated by the Fresno County Department of Public Health. In addition, as discussed previously, a Storm Water Pollution Prevention Plan (SWPPP) is required for the Project and shall include emergency procedures for incidental hazardous materials releases. The SWPPP also includes Best Management Practices which includes requirements for hazardous materials storage.

The operational phase of the proposed Project would occur after construction is completed and residents move in to occupy the structures on a day-to-day basis.

Residential land uses do not typically routinely transport, use, or dispose of hazardous materials, or dispose of hazardous materials, or present a reasonably foreseeable release of hazardous materials, with the exception of common residential hazardous materials such as cleaners, paint, petroleum products, etc. The use of hazardous materials would mostly be confined to the Project construction period. Any impacts are less than significant.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
70 Less Than Significant. The proposed Project includes the development of a 202-lot single-family residential development, including a 0.39-acre park and other associated improvements. As discussed in Impact a) above, the use of hazardous materials would be primarily confined to the Project construction period and those materials would be contained, stored, and handled in compliance with applicable standards and regulations. As such, there are less than significant impacts regarding the release of hazardous materials into the environment.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Less Than Significant Impact. Sequoia Elementary School is located approximately

0.6 miles southeast of the Project site, located at 1820 Armstrong Avenue. Sanger West High School is located approximately 0.8 miles southwest of the Project site, located at 1850 S. Fowler Avenue. There are no schools located within one-quarter mile of the proposed Project site. Any hazardous materials contained, stored, or handled on site would be in compliance with applicable standards and regulations established by the Department of Toxic Substances Control (DTSC), the U.S.

Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). The immediate area surrounding the Project site is primarily comprised of residential purposes. Any impacts would be less than significant. d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? Less Than Significant Impact with Mitigation Incorporation. The proposed Project site is not located on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Geotracker13 and Envirostor14 databases – 13 California State Water Resources Control Board, GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Fresno. Accessed December 2024. 14 California Department of Toxic Substances Control, EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/.

Accessed December 2024.
71 accessed in December 2024). However, a database search performed in the Phase I ESA on behalf of the Project (RMA GeoScience) found that fuel underground storage tanks (UST) are listed at 1099 and 1183 Armstrong Avenue (See Appendix D). There were no records of leaks, spills, or the UST being removed from the location.

Additional testing was performed to assess the possible presence of contaminated soil, utilizing soil gas probes in the area in question (See Appendix E). Soil gas samples collected from the former UST locations revealed concentrations of freon 113, acetone, carbon disulfide, chloroform, carbon tetrachloride, PCE, 2-butanone, 4- methyl-2-pentanone, toluene, ethylbenzene, xylenes, and 1,2,4-trimethylbenzene to be present in soil gas. However, with the exception of PCE, the concentrations detected are all below their respective ESL. The concentration of PCE detected in SGP-2-5 was reported at 22 ug/m3. The Residential ESL for PCE is 15 ug/m3.

The residential ESL for PCE is extremely conservative and should not be confused with regulatory cleanup standards. The presence of PCE in excess of the ESL does not necessarily indicate that an adverse impact to human health or the environment has occurred, it simply indicates that an adverse risk does exist, and that additional investigation may be warranted.

Soil samples collected from within the upper 18 inches of soil along the northern and eastern property boundary contained concentrations of metals that are consistent with normal background levels in the area of the Site. Soil samples collected from the central, eastern, and western portions of the Site contained low levels of organochlorine pesticides, however, the concentrations detected were all below their respective residential ESLs. No detectable concentrations of organophosphorus pesticides, SVOCs, or herbicides were detected above the laboratory reporting limits in any of the samples submitted for analysis.

Mitigation Measure HAZ-1 includes additional soil gas sampling once overexcavation, site grading, and other earthwork activities have been completed to confirm the low-level detections of PCE do not pose a vapor intrusion threat to future residential units. With this mitigation implemented, any impacts would remain less than significant.
72 e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
Less than Significant Impact. The Project site is located just outside the Precision Approach Zone for the Airport Influence Area (AIA) of Fresno-Yosemite International Airport,
15 which lies approximately 3.7 miles to the northwest.

As the Project is outside the AIA of the Fresno-Yosemite International Airport, impacts resulting from creating a safety hazard for potential residents are less than significant. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant. The City of Fresno maintains an Emergency Preparedness Office (EPO) function for its jurisdictional responsibility area and coordinates with Fresno County OES regarding disaster preparedness, response, and recovery activities. The site plan’s three ingress and egress points onto S. Armstrong Avenue have been reviewed by Public Works Traffic Planning to ensure that the Project does not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan. Thus, the Project would not impair the implementation of. Or physically interfere with, any adopted emergency response plan or emergency evacuation plans. No impact would occur.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
No Impact. Implementation of the Project would not change the degree of exposure to wildfires because there are no wildlands in the Project vicinity, thus precluding the 15 Fresno County Airport Land Use Compatibility Plan, December 2018, Part Two. Exhibit D1, Fresno-Yosemite INTL. Airport Influence Area and Safety Zones. https://fresnocog.wpenginepowered.com/wp-content/uploads/2019/01/fresno-final-alucp113018-r_part2.pdf. Accessed December 2024. 73 possibility of wildfires. Therefore, there is no impact.

Mitigation Measures:

The proposed project shall implement and incorporate the hazardous materials related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

HAZ – 1 Additional soil gas sampling shall be performed near the former southeastern UST once over-excavation, site grading, and other earthwork activities have been completed to confirm the low-level detections of PCE do not pose a vapor intrusion threat to future residential dwellings. If PCE levels are above the California Department of Toxic Substances Control (DTSC) soil gas thresholds, sub-slab vapor barriers, or another construction method which will reduce PCE levels to less than DTSC soil gas threshold shall be implemented.
74 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface or
ground water quality?
X
b) Substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the project
may impede sustainable
groundwater management of the
basin?
X
c) Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river, or through the
addition of impervious surfaces, in
a manner which would:

X
75 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
i) Result in a substantial erosion or
siltation on- or off-site;
X
ii) Substantially increase the rate
or amount of surface runoff in a
manner which would result in
flooding on- or off-site:

X
iii) create or contribute runoff
water which would exceed the
capacity of existing or planned
stormwater drainage systems or
provide substantial additional
sources of polluted runoff; or
X
iv) impede or redirect flood flows? X
d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
X
e) Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
X
76 DISCUSSION
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less Than Significant Impact. The Project has the potential to impact water quality standards and/or waste discharge requirements during construction (temporary impacts) and operation. Impacts are discussed below.

Construction
Although the proposed Project site is relatively small in scale, grading, excavation and loading activities associated with construction activities could temporarily increase runoff, erosion, and sedimentation. Construction activities also could result in soil compaction and wind erosion effects that could adversely affect soils and reduce the revegetation potential at construction sites and staging areas.

Three general sources of potential short-term construction-related stormwater pollution associated with the proposed Project are: 1) the handling, storage, and disposal of construction materials containing pollutants; 2) the maintenance and operation of construction equipment; and 3) earth moving activities which, when not controlled, may generate soil erosion and transportation, via storm runoff or mechanical equipment.

Generally, routine safety precautions for handling and storing construction materials may effectively mitigate the potential pollution of stormwater by these materials. These same types of common sense, “good housekeeping” procedures can be extended to non-hazardous stormwater pollutants such as sawdust and other solid wastes.

Poorly maintained vehicles and heavy equipment leaking fuel, oil, antifreeze, or other fluids on the construction site are also common sources of stormwater pollution and soil contamination. In addition, grading activities can greatly increase erosion processes. Two general strategies are recommended to prevent construction silt from entering local storm drains. First, erosion control procedures should be implemented for those areas that must be exposed. Secondly, the area should be secured to control offsite migration of pollutants. These BMPs would be required in the Stormwater Pollution Prevention Plan (SWPPP) to be prepared prior to commencement of Project 77 construction. When properly designed and implemented, these “good-housekeeping” practices are expected to reduce short-term construction-related impacts to less than significant.

In accordance with the National Pollution Discharge Elimination System (NPDES) Stormwater Program, the Project will be required to comply with existing regulatory requirements to prepare a SWPPP designed to control erosion and the loss of topsoil to the extent practicable using BMPs that the Regional Water Quality Control Board (RWQCB) has deemed effective in controlling erosion, sedimentation, runoff during construction activities. The specific controls are subject to review and approval by the RWQCB and are an existing regulatory requirement.

Operation
The long-term operations of the proposed Project could result in long-term impacts to surface water quality from urban stormwater runoff. The proposed Project would result in new impervious areas associated with site improvements, including new asphalt, concrete and the proposed structures on site. Urban runoff typically contains oils, grease, fuel, antifreeze, byproducts of combustion (such as lead, cadmium, nickel, and other metals) and other household pollutants. Precipitation early in the rain season displaces these pollutants into storm water resulting in high pollutant concentrations in initial wet weather runoff. This initial runoff with peak pollutant levels can be referred to as the "first flush" of storm events.

The proposed Project would install storm water drainage facilities (e.g. storm drainage mechanisms and storm water pipes) that would be in compliance with the City of Fresno and Fresno Metropolitan Flood Control District (FMFCD) Design Standards.

In accordance with the City’s storm water management regulations and National Pollutant Discharge Elimination System (NPDES) Stormwater Program (General Stormwater Permit), BMPs would be implemented to reduce the amount of pollution in stormwater discharged from the Project site. The management of water quality through the requirement to obtain a General Stormwater Permit and implement appropriate BMPs would ensure that water quality does not degrade to levels that would violate water quality standards. These are existing regulatory requirements. 78 In addition, the Project will generate typical wastewater (sewer) associated with residential developments and will connect to the City’s sewer system. The Project will not result in a violation of any water quality standards or waste discharge requirements.

Therefore, any impacts are less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact. The proposed Project includes a 202-lot singlefamily residential development. Each home will be equipped with typical restroom facilities. The proposed Project consists of 202 dwelling units, and the average household size in the City of Fresno is 2.97,
16 therefore the Project will house
approximately 600 people. As such, the proposed Project would result in estimated water demand of 118,800 gallons per day (600 people x 198 gallons/day17 = 118,800 gallons/day).

Water service would be provided to the Project by the City of Fresno. Based on the assumptions in the City’s Urban Water Management Plan (UWMP), 18 the Project
would not negatively impact water supplies or otherwise deplete groundwater supplies. Moreover, the proposed Project is not anticipated to interfere with groundwater recharge efforts being implemented by the City. The City’s UWMP contains a detailed evaluation of existing sources of water supply, anticipated future water demand, extensive conservation measures, and the development of new water supplies (recycled water, increased recharge, surface water treatment, etc.).

Measures contained in the UWMP as well as the City’s General Plan are intended to reduce demands on groundwater resources by augmenting supply and introducing 16 U.S. Census Bureau. QuickFacts. Fresno City. 2017-2017. https://www.census.gov/quickfacts/fact/table/fresnocitycalifornia,fresnocountycalifornia/PST045222. Accessed December 2024.
17 City of Fresno 2020 Urban Water Management Plan. July 2021. Pg. ES-4. https://www.fresno.gov/wpcontent/uploads/2023/03/Fresno-2020-UWMP_Final_2021-07-21-1.pdf. Accessed December 2024. 18 Ibid.
79 conservation measures and other mitigation strategies. As such, a less than significant impact to a groundwater management basin would occur. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? Less Than Significant Impact. The Project site is comprised of single-family residences and vacant disturbed land. The site is surrounded by urban development and agriculture. The existing on-site single-family residences would be demolished and would be cleared of vegetation and leveled to accommodate construction. The Project requires a Soils Report (i.e., Geotechnical Investigation) prior to granting of a grading permit. Because the Project would disturb more than one acre of land, a National Pollution Discharge Eliminate System (NPDES) permit and preparation of a Stormwater Pollution Prevention Plan (SWPPP) would also be required prior to granting a grading permit. Preparation of the soils report as well as implementation of standard best management practices (e.g., silt fences, fiber rolls, rumble grate, etc.) which would be identified in the SWPPP would be effective in reducing erosion and siltation impacts on or off-site to less than significant levels. Therefore, impacts with regard to substantial erosion or siltation on or off-site are considered less than significant.
ii. Substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site?
Less Than Significant Impact. Development of the Project site would result in the addition of impervious surfaces in the form of 202 residential buildings, internal driveways and roadways. This will result in an increase in storm water runoff as well as the potential for contaminated runoff to enter FMFCD drainage basins. The Project site is surrounded by existing storm drainage infrastructure. The proposed Project is designated and planned for urban development. Accordingly, infrastructure has considered this level of development in its capacity. Therefore, the Project will result in a less than significant impact regarding on- or off-site flooding.
80 iii. Create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Less Than Significant Impact. Site runoff from precipitation currently either percolates into the ground where there are no impervious surfaces or drains into the City’s stormwater system and eventually into drainage basins that serve the area. Site development will result in the addition of impervious surfaces in the form of additional foundations, buildings, streets, and other paved surfaces. This will result in an increase in storm water runoff from the site and will increase the potential for contaminated runoff to enter FMFCD drainage basins or for drainage basins to overflow and cause flooding. However, the proposed Project will be designed to FMFCD and City of Fresno standards to prevent drainage overflow and flooding and the potential for contaminated runoff. The Project site has been anticipated for residential urban use by the City of Fresno General Plan. As with all developments, existing policies and standards are required to be complied with, which are assessed during design and review of entitlements by the City and FMFCD to ensure that none of the water quality standards are violated and that waste discharge requirements are adhered to during construction and operation of the Project. The proposed Project will connect to the City of Fresno’s existing stormdrain system and pay drainage fees pursuant to the Drainage Fee Ordinance.

Impacts resulting from polluted runoff will be less than significant. iv. Impede or redirect flood flows?
Less Than Significant Impact. The Project site is outside of any Special Flood Hazard Areas or Other Areas of Flood Hazard, FEMA Flood Map 06019C2135H, effective 2/18/2009. As discussed above in Impacts ii, the Project site is served with stormwater infrastructure that has been sized to accommodate urban development.

The Project would not impede or redirect flood flows as it has been designed with on-storm drainage infrastructure that will connect with the City’s system. The impact will be less than significant.
81 d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less Than Significant Impact. The Project site is outside of any Special Flood Hazard Areas or Other Areas of Flood Hazard, FEMA Flood Map 06019C2135H, effective 2/18/2009. There are no bodies of water near the site that would create a potential risk of hazards from seiche, tsunami or mudflow. The Project will not conflict with any water quality control plans or sustainable groundwater management plan.

As mentioned in Impact c) above, all new development within the City of Fresno Planning Area must conform to standards and plans detailed by the Fresno Metropolitan Flood Control District. By conforming to all standards and policies as outlined, any impacts will remain less than significant. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant Impact. The City of Fresno is part of the North Kings Groundwater Sustainability Agency (GSA) which is one of the seven GSA’s within the Kings Groundwater Subbasin. The North Kings GSA submitted the Groundwater Sustainability Plan to the CA Department of Water Resources in January 2020. The City of Fresno relies on natural groundwater recharge, subsurface inflow, and intentional recharge to replenish groundwater. As the City of Fresno will provide water to the proposed Project (upon approval), and the City will be subject to the requirements of the GSA, the proposed Project does not conflict with any adopted water quality or sustainable groundwater management plan.

Potential stormwater flows would discharge to on-site stormwater infrastructure and be conveyed to FMFCD retention basins. No stormwater flows would directly discharge to the San Joaquin River thereby avoiding water quality impacts. Any impacts would be less than significant.

Mitigation Measures
None required.
82 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established
community?
X
b) Cause a significant
environmental impact due to a
conflict with any land use plan,
policy, or regulation adopted for
the purpose of avoiding or
mitigating an environmental
effect?
X

DISCUSSION
a) Physically divide an established community?
Less Than Significant Impact. The proposed Project site is currently designated by the City of Fresno General Plan for Residential, Medium Density planned land use.

The site is currently occupied by three single-family residences and vacant disturbed land. The site does not include an established community. The proposed Project land use designation allows for densities between 5 to 12 units per acre, intended to provide for single-family detached housing. The proposed Project would include 202 units on approximately 34.7 acres of land, for a density of approximately 6 dwelling units per acre. Pursuant to Fresno Municipal Code Section 15-303, fractions of onehalf (0.5) or greater shall be rounded up to the nearest whole number and fractions of 83 less than one-half (0.5) shall be rounded down to the nearest whole number. Specific to residential density rounding, fractions only apply to minimum density, but not maximum density. In this case, 5.82 dwelling units per acre would be rounded up to six dwelling units per acre, which is consistent with the minimum density requirement per the Fresno General Plan. Within the Project vicinity, there are single-family residences, active agricultural land, and vacant land surrounding the proposed Project. The proposed residential use is allowed within this land use designation, after the approval of an annexation, Rezone, TTM and Planned Development Permit. The Project is not dividing an established community. The Project is not being built in a pre-existing community area and would not create any physical barrier between an established community. Any impacts are less than significant. b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
No Impact. The proposed Project is located in an area that is planned for residential and urban development by the City. The site is currently designated as Medium Density Residential by the City of Fresno General Plan and is currently zoned as AL - 20 (Limited Agriculture) by Fresno County. As part of the proposed Project, the site will be rezoned to RS-5 / UGM (Residential Single Family, Medium Density/Urban Growth Management.

The proposed development is planned for single-family residential uses. The Project proposes to rezone to change the property from AL-20 to RS-5, which increases the density allowed on the site. However, the site is adjacent to existing residential subdivisions to the north and east and will be consistent with nearby residential densities.

The proposed subdivision is a standard infill development being proposed in compliance with the City’s planned land use designation within the City limits. Infill development contributes to environmental preservation by reducing agricultural land conversion, reduce costs to build and maintain infrastructure, and improving air quality by overall reducing travel distances and subsequent greenhouse gas emissions. 84 Further, through the entitlement process, the Project has been reviewed for compliance with applicable regulations inclusive of those adopted for the purpose of avoiding or mitigating environmental effects. Overall, the entitlement process would ensure that the proposed Project complies with the General Plan, FMC, and any other applicable policies and regulations. Less than significant impacts will occur.

Mitigation Measures
None are required.
85 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability
of a known mineral resource that
would be of value to the region
and the residents of the state?
X
b) Result in the loss of availability
of a locally-important mineral
resource recovery site delineated
on a local general plan, specific
plan or other land use plan?
X

DISCUSSION
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
No Impact. Mineral resources are concentrated along the San Joaquin River Corridor.

The proposed Project is not located along the San Joaquin River Corridor, there are no known mineral resources in the proposed Project area, and none are identified in the City’s General Plan near the Project site. Therefore, there is no impact. 86 b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. As discussed in Impact a) above, there are no known mineral resources identified in the City’s General Plan in the proposed Project area. There is no impact.

Mitigation Measures
None are required.
87 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial
temporary or permanent increase
in ambient noise levels in the
vicinity of the project in excess of
standards established in the local
general plan or noise ordinance,
or applicable standards of other
agencies?
X
b) Generation of excessive
groundborne vibration or
groundborne noise levels?
X
c) For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project expose people residing or
working in the project area to
excessive noise levels?
X
An Acoustical Analysis was performed on behalf of the proposed Project by WJVA 88 Acoustics, Inc. (report date October 25, 2023, update July 12, 2024) and is the basis of analysis for the discussion below. The Acoustical Analysis is provided in Appendix F.

DISCUSSION
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or in other applicable local, state, or federal standards?
Less Than Significant Impact.

Short-term (Construction) Noise Impacts
Proposed Project construction related activities will involve temporary noise sources.

Typical construction related equipment includes graders, trenchers, small tractors, and excavators. During the proposed Project construction, noise from construction related activities will contribute to the noise environment in the immediate vicinity.

Activities involved in construction will generate maximum noise levels, as indicated in Table 6, ranging from 80 to 95 dBA at a distance of 50 feet.

Table 6: Typical Construction Equipment Noise Levels19
Equipment Description Maximum Noise Level
(Lmax) at 50 Feet
Backhoes 80
Compactor (ground) 80
Cranes 85
Dozers 85
Dump Trucks 84
19 Federal Highway Administration. Roadway Construction Noise Model (January 2006). 89 Excavators 85
Flat Bed Trucks 84
Front-end Loaders 80
Graders 85
Impact Pile Drivers 95
Jackhammers 85
Pick-up Truck 55
Pneumatic Tools 85
Pumps 77
Rock Drills 85
Rollers 85
Scrapers 85
Tractors 84
The distinction between short-term construction noise impacts and long-term operational noise impacts is a typical one in both CEQA documents and local noise ordinances, which generally recognize the reality that short-term noise from construction is inevitable and cannot be mitigated beyond a certain level. Thus, local agencies frequently tolerate short-term noise at levels that they would not accept for permanent noise sources. A more severe approach would be impractical and might preclude the kind of construction activities that are to be expected from time to time in urban environments. Most residents of urban areas recognize this reality and expect to hear construction activities on occasion.
90 Construction activities would not occur between the hours of 10:00 PM and 7:00 AM, Monday through Saturday, and not at all on Sundays, in accordance with Fresno Municipal Code Section 10-109, which limits work hours “to between the hours of 7 AM and 10 PM on any day except Sunday.”
Long-term (Operational) Noise Impacts
The proposed Project includes future residential uses. The immediate vicinity consists of existing and planned residential uses, which produce noise levels that are likely similar to long-term noise levels produced by the proposed Project. Additionally, all surrounding properties are adjacent to collector and arterial streets, which increase the ambient noise of the Project site. The proposed Project is not projected to be a long-term noise source due to the Project being a use consistent with neighboring land uses.

Project Site Noise Exposure
The Project site is located on the west side of S. Armstrong Avenue, north of E. Church Avenue, in Fresno, California. The Project site is exposed to traffic noise associated with vehicles on S. Armstrong Avenue and train noise associated with train operations on the San Joaquin Valley Railroad (SJVR). The distance from center of the backyards of the closest proposed lots to the centerline of S. Armstrong Avenue is approximately 80 feet. The distance from the center of the backyards of the closest proposed lot to the SJVR line is approximately 70 feet (lot 76). Additionally, the backyards of the remaining lots along the south side of E. Erin Avenue would be located approximately 115 feet from the SJRV line.

Traffic Noise Exposure: Noise exposure from traffic on S. Armstrong Avenue was calculated for existing and future (2046). From Table 7 it may be determined that the traffic noise levels predicted by the FHWA Model were 1.5 dB lower than those measured for the conditions observed at the time of the noise measurements for S.

Armstrong Avenue. This is considered to be reasonable agreement with the model and therefore no adjustments to the model are necessary.

Table 7:

Comparison of Measured and Predicted (FHWA Model) Noise Levels for Tract 6376, Fresno
91 Annual Average Daily Traffic (AADT) data for S. Armstrong Avenue in the Project vicinity was obtained from Fresno COG. Truck percentages and the day/night distribution of traffic were estimated by WJVA, based upon previous studies conducted in the Project vicinity since project‐specific data were not available from government sources. A speed limit of 40 mph (as posted) was assumed for the roadway. Table 8 summarizes annual average traffic data used to model noise exposure within the Project site.

Table 8:

Traffic Noise Modeling Assumptions for Tract 6376, Fresno Using data from Table 8, the FHWA Model, annual average traffic noise exposure was calculated for the closest proposed backyards from S. Armstrong Avenue. The calculated noise exposures for existing and future (2046) traffic conditions for the closest proposed setbacks to S. Armstrong Avenue were approximately 55 dB Ldn for existing traffic conditions and approximately 56 dB Ldn future (2046) traffic conditions. 92 Such noise exposure levels are below the City’s 65 dB Ldn exterior noise level standard and further mitigation of traffic noise is therefore not required.

Railroad Noise Exposure: The San Joaquin Valley Railroad (SJVR) line is located approximately 70 feet from the backyard of lot 76. Additionally, the backyards of the remaining lots along the south side of E. Erin Avenue would be located approximately 115 feet from the SJRV line. The railroad consists of jointed rails with the top of the rails being approximately one foot above the grade of the project site.

Train engineers are required to sound warning horns when within approximately ¼ mile of a grade crossing. As the entire project site railroad frontage is located within ¼ mile of the S. Armstrong Avenue grade crossing, all lots adjacent to the SJRV line would be impacted by train warning horns.

According to data obtained from the U.S. Department of Transportation Federal Railroad Administration (FRA), trains along this portion of the railroad line do not exceed 25 mph in speed. According to the local trainmaster they typically pass by at speeds in the range of 10‐20 mph. Additionally, according to both the FRA and the SJVR trainmaster, typical operations consist of two train movements per day along the line, typically one occurring during daytime hours and one occurring during nighttime hours. There is a grade crossing at South Armstrong Avenue where locomotive engineers are required to blow their warning horn.

WJVA observed one train movement on January 22, 2018 at a different project site located along the same section of SJVR railroad line, east of the Project site. A westbound freight train passby occurred at approximately 2:45 p.m. Noise levels were measured from two locations along the track using automated sound level meters.

Both meters were located approximately 50 feet from the tracks. One meter was located approximately 500 feet west of the grade crossing, and noise levels of the train event were measured to 102.8 dB (SEL). The second meter was located approximately 1,300 feet from the grade crossing at South Temperance, and noise levels of the train event were measured to be 98.6 dB (SEL). The difference in noise levels is a result of varying distances from the grade crossing, where the engineer is required to sound their warning horn. WJVA also reviewed other noise measurements obtained along the SJVR to assess noise levels for parcels closer to grade crossings along the SJVR railroad line, and determined the average SEL at the closest lots 93 adjacent to the SJVR railroad line to be 105.8 dB (SEL).

Railroad noise exposure may be quantified in terms of the Ldn using the following formula:

Ldn =SEL+ 10 log Neq – 49.4
where,
SEL is the average SEL for a train pass‐by, Neq is the equivalent number of pass‐bys in a typical 24‐hour period determined by adding 10 times the number of nighttime movements (10 p.m.‐7 a.m.) to the actual number of daytime movements (7 a.m.‐10 p.m.). 49.4 is a time constant equal to 10 times the log of the number of seconds in a day.

Using the above‐described formula, railroad operations data (assuming one train event during daytime hours and one train event during nighttime hours) and noise measurement results, the railroad noise exposure within the backyards of the proposed lots closest to the SJVR line. Using the above‐described train noise measurements and calculations, SJVR train noise was calculated to be as follows:

1. Lot 76: 68 dB Ldn

2. Lots along south side of E. Erin Avenue: 65 dB Ldn
These noise levels indicate that exterior noise levels along the lots closest to the SJVR railroad line exceed the City’s exterior maximum noise level standard, and mitigation measures must be incorporated into Project design.

Based on the Acoustical Analysis’ findings, Mitigation Measure NOI-1, which includes constructing a sound wall, and NOI-2, which requires air conditioning units in all residences to allow for windows to stay shut for indoor insulation shall be implemented which will reduce potential impacts to less than significant with mitigation incorporation.
b) Generation of excessive groundborne vibration or groundborne noise levels? Less Than Significant Impact. The dominant sources of man‐made vibration are sonic booms, blasting, pile driving, pavement breaking, demolition, diesel 94 locomotives, and rail‐car coupling. None of these activities are anticipated to occur with construction or operation of the proposed Project. Vibration from construction activities could be detected at the closest sensitive land uses, especially during movements by heavy equipment or loaded trucks and during some paving activities (if they were to occur). Typical vibration levels at distances of 100 feet and 300 feet are summarized by Table 9. These levels would not be expected to exceed any significant threshold levels for annoyance or damage, as provided above in Table 9.

Table 9: Typical Vibration Levels During Construction
Equipment
PPV (in/sec)
@100’ @300’
Bulldozer (Large) 0.011 0.006
Bulldozer (Small) 0.0004 0.00019
Loaded Truck 0.01 0.005
Jackhammer 0.005 0.002
Vibratory Roller 0.03 0.013
Caisson Drilling 0.01 0.006
Source: Caltrans
After full Project build out, it is not expected that ongoing operational activities will result in any vibration impacts at nearby sensitive uses. There are no aspects of construction or daily operations that would create groundborne vibration. As such, any impacts would be less than significant.
c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
95 Less Than Significant Impact. The closest airport or airstrip is the Fresno Yosemite International Airport, located approximately 3.7 miles northwest of the Project site.

The site is outside of the Airport Land Use Compatibility Plan (ALUCP). The City of Fresno has created specific designations to prioritize development in the urban portions of the city. These “Urban Core” areas are used by the City of Fresno to identify areas that should be prioritized for development from the City of Fresno’s perspective.

The Handbook, in Figure 4G, includes provisions for developing safety criteria for urban areas which includes no limit for intensity or density. Using the City of Fresno’s “Urban Core” areas, there is no limit for non‐residential intensity in areas designated as Urban.

The proposed Project is outside the noise level contours identified in the ALUCP. In conclusion, the proposed Project would not expose people residing or working in the Project site to excessive noise levels associated with such airport facilities, and there would be less than significant impact.

As such, impacts will remain less than significant.

Mitigation Measures:

The proposed project shall implement and incorporate the noise related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

NOI – 1 A sound wall shall be constructed along the entire project site frontage with the SJVR railroad line. In the vicinity of Lot 76, the wall shall be constructed to a minimum height of eight feet six inches (8’6”) above project site grade, and the sound wall shall be constructed to a minimum height of seven (7) feet above project site grade along the remainder of the SJVR project site frontage. In order to be effective, the sound wall shall be turned inward (southward) for a minimum distance of twenty (20) feet along the east side of Lot 76. The locations and heights of the required sound walls are provided on Figure 1 of Appendix F. Suitable construction materials include concrete blocks, masonry, or stucco on both sides of a wood or steel stud wall.
96 NOI – 2 Mechanical ventilation or air conditioning shall be provided for all homes so that windows and doors can remain closed for sound insulation purposes. 97 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned
population growth in an area,
either directly (for example, by
proposing new homes and
businesses) or indirectly (for
example, through extension of
roads or other infrastructure)?
X
b) Displace substantial numbers
of existing people or housing,
necessitating the construction of
replacement housing elsewhere?
X

DISCUSSION
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant Impact. As of July of 2023, the population in Fresno is 545,716 people with an average household size of 2.97.
20 The Project will construct
housing with 202 dwelling units, which will house approximately 600 persons. The 20 U.S. Census Bureau. QuickFacts. Fresno City. 2017-2017. https://www.census.gov/quickfacts/fact/table/fresnocitycalifornia,fresnocountycalifornia/PST045222. Accessed December 2024.
98 City’s General Plan encourages residential developments to meet the future population growth needs. This project accommodates this anticipated increase in City’s population by providing 202 new residences for existing and future residents.

The Project site has a proposed designation of Medium Density Residential as per the City’s General Plan and a proposed rezoning of RS-5 (Medium Density Residential).

Upon approval, the Project will be consistent with both the General Plan and zoning ordinance. Therefore, the Project would not induce substantial unplanned population growth in an area, either directly or indirectly. Impacts would be less than significant. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Less Than Significant Impact. The Project site is occupied by three single-family residences and is surrounded primarily by residential development. As proposed, the Project will displace existing housing; however, the Project will provide 202 new homes to a community in need of additional housing in the area. There is a less than significant impact.

Mitigation Measures
None are required.
99 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XV. PUBLIC SERVICES – Would the project:
a) Result in substantial adverse
physical impacts associated with
the provision of new or physically
altered governmental facilities,
need for new or physically altered
governmental facilities, the
construction of which could cause
significant environmental impacts,
in order to maintain acceptable
service ratios, response times or
other performance objectives for
any of the public services:

Fire protection?
X
Police protection?
X
Schools? X
Parks?
X
Other public facilities? X
100

DISCUSSION
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
a) Fire protection?
Less Than Significant. The Project includes construction of a 202-lot single-family residential unit development, including a 0.39-acre park and other associated improvements.

The City of Fresno Fire Department (Fire Department) offers a full range of services including fire prevention, suppression, emergency medical care, hazardous materials, urban search and rescue response, as well as emergency preparedness planning and public education coordination within the Fresno City limit, in addition to having mutual aid agreements with the Fresno County Fire Protection District, and the City of Clovis Fire Departments.

The City of Fresno Fire Department operates its facilities under the guidance set by the National Fire Protection Association in NFPA 1710, the Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operation to the Public by Career Fire Departments. NFPA 1710 sets standards for turnout time, travel time, and total response time for fire and emergency medical incidents, as well as other standards for operation and fire service. The Fire Department has established the objectives set forth in NFPA 1710 as department objectives to ensure the public health, safety, and welfare.

The proposed Project would be served by the current Fire Station 15, which is located at 5630 E. Park Circle Drive, approximately 1.5 miles northwest of the Project site. After reviewing the Project, the Fire Department has determined that the Project can be adequately serviced by the current local Fire Facilities and Personnel, 101
consistent with National Fire Protection Association 1710 Objectives. Additionally, the Project will also be subject to Fire Facilities Fees.

Project implementation will result in less than significant impacts. b) Police protection?
Less Than Significant. The Project includes construction of a 202-lot single-family residential unit development, including a 0.39-acre park and other associated improvements. The surrounding area is currently protected by the existing Southeast Police District, approximately 1.8 miles to the northwest at 224 S. Argyle Avenue. The Fresno Police Department provides a full range of police services including uniformed patrol response to calls for service, crime prevention, tactical crime and enforcement (including gang and violent crime suppression), and traffic enforcement/accident prevention. The proposed Project would also be protected by the Southeast Police District and would be subject to pay development impact fees to offset any potential impacts to police protection. Additionally, the Fresno Police Department reviewed the Project and had no comments. Any impacts are considered less than significant.
c) Schools?
Less Than Significant. According to the Sanger Unified School District, the schools that will serve the proposed project are Sequioa Elementary School, approximately

0.7 miles southeast of the Project, Washington Academic Middle School approximately 6.4 miles southeast of the Project, and Sanger West High School also approximately 0.7 miles southeast of the Project.

The proposed residential uses result in the generation of students, which would impact the District’s student classroom capacity. Any future development occurring as a result of the proposed project may have an effect on the Sanger Unified School District’s student housing capacity. The District, through local funding, is in a position to mitigate its shortage of classrooms to accommodate planned population growth for the foreseeable future. However, the District recognizes that the legislature, as a matter of law, has deemed under Government Code Section 65996 that all school facilities impacts are mitigated as a consequence of SB 50 Level 1, 2, and 3 developer fee legislative provisions. The developer will pay appropriate impact fees 102
at time of building permits. The proposed Project will not result in the need for construction of new school facilities. Impacts would be less than significant. d) Parks?
Less Than Significant. The Project includes construction of a 202-lot singlefamily residential unit development, including a 0.39-acre park and other associated improvements.

The nearest park is South Sunnyside Granville Greenpark, approximately 0.7 miles southwest of the Project. The City of Fresno maintains a park goal to provide five acres of city park space per 1,000 residents. A 0.39-acre park is included in the proposed Project’s design; however, Project review and approval process will ensure that all additional park related fees are paid by the applicant.

These requirements will ensure that the proposed Project does not significantly affect park and recreation facilities. Impacts would be less than significant. e) Other public facilities?
Less Than Significant. The Department of Public Utilities (DPU) has determined that adequate sanitary sewer and water services are available to serve the project site subject to compliance with the conditions submitted by the DPU for this project and implementation of the Fresno General Plan policies and the mitigation measures of the related Master Environmental Impact Report; and, the construction and installation of public facilities and infrastructure in accordance with Department of Public Works standards, specifications and policies.

For sanitary sewer service, these infrastructure improvements and facilities include typical requirements for the construction and extension of sanitary sewer mains and branches. The proposed Project will also be required to provide payment of sewer connection charges.

No significant adverse impacts are expected to occur as a result of the construction of any such facilities or improvements associated with the proposed Project. Impacts would be less than significant.

Mitigation Measures
103
None are required.
104

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVI. RECREATION–- Would the project:
a) Increase the use of existing
neighborhood and regional parks
or other recreational facilities such
that substantial physical
deterioration of the facility would
occur or be accelerated?
X
b) Does the project include
recreational facilities or require
the construction or expansion of
recreational facilities which might
have an adverse physical effect
on the environment?
X

DISCUSSION
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less Than Significant. The Project includes construction of a 202-lot single-family residential unit development, including a 0.39-acre park and other associated improvements. The proposed Project may result in the physical deterioration of existing parks or recreational facilities.
105
The South Sunnyside Granville Greenpark lies approximately 0.7 miles to the southwest of the Project and a pocket park located at 5626 Burns Avenue is 1.4 miles to the southwest of the Project. There are also two schools with sports fields and other outdoor areas located within a mile of the Project; one to the southwest and one to the southeast.

Park and recreation fees, per the Quimby Act, are collected for new residential developments. The Project review and approval process will ensure that all park related fees are paid by the applicant. These requirements will ensure that the proposed Project does not significantly affect park and recreation facilities. Impacts would be less than significant.
b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
Less Than Significant. As discussed above, the Project includes construction of a 202-lot single-family residential unit development, including a 0.39-acre park and other associated improvements. Through the standard City building process for the future park and payment of the required development fees, the Project will not significantly affect park and recreation facilities. The Project would not result in any new recreational, environmental impacts and are considered to be less than significant.

Mitigation Measures
None are required.
106

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle and
pedestrian facilities?
X
b) Conflict or be inconsistent with
CEQA Guidelines § 15064.3,
subdivision (b)?
X
c) Substantially increase hazards
due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment)?
X
d) Result in inadequate
emergency access?
X
A Traffic Impact Analysis Report (TIA) was performed on behalf of the proposed Project by JLB Traffic Engineering, Inc., report date December 9, 2024 (See Appendix G).

Additionally, the City of Fresno Urban Form VMT Calculator was utilized to address potential VMT impacts and is included as Appendix H. The following discussion is based 107
primarily on those two resources.

DISCUSSION
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less Than Significant with Mitigation. The proposed Project is located on the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad in the City of Fresno. The Project proposes to develop approximately 202 single-family residential units. The potential traffic impacts of the proposed Project were evaluated in accordance with the standards set forth by the Level of Service (LOS) policies of the City of Fresno and Fresno County.

The following intersections and study segments are included in the traffic analysis:

Intersections:
• Fowler Avenue / Hamilton Avenue
• Armstrong Avenue / Hamilton Avenue
• Temperance Avenue / Hamilton Avenue
• Armstrong Avenue / California Avenue
• Temperance Avenue / California Avenue (future intersection) • Fowler Avenue / Church Avenue
• Armstrong Avenue / Church Avenue
Study Segments:

Armstrong Avenue between Geary Avenue and Church Avenue Roadway Descriptions
Fowler Avenue is an existing north-south three-lane divided arterial in the vicinity of the proposed Project site. In this area, Fowler Avenue is a four-lane divided arterial between the State Route 180 Interchange and Kings Canyon Road, a two to threelane arterial divided by a two-way left-turn lane between Kings Canyon Road and the San Joaquin Valley Railroad, a two to three-lane divided arterial between the San Joaquin Valley Railroad and Jensen Avenue and a two-lane undivided arterial 108
between Jensen Avenue and North Avenue. The Fresno General Plan Circulation Element designates Fowler Avenue as a four-lane divided arterial between State Route 180 and Kings Canyon Road, a two-lane arterial between Kings Canyon Road and Hamilton Avenue and Hamilton Avenue, a four-lane arterial between Hamilton Avenue and Jensen Avenue and a two-lane collector between Jensen Avenue and North Avenue.

Armstrong Avenue is an existing north-south three-lane undivided collector adjacent to the proposed Project. In this area, Armstrong Avenue is a three- to four-lane undivided collector between Kings Canyon Road and Hamilton Avenue, a three to four-lane collector divided by a two-way left-turn lane between Hamilton Avenue and Truman Avenue, a two-lane undivided collector between Truman Avenue and North Avenue. The Fresno General Plan Circulation Element designates Armstrong Avenue as a four-lane collector between Kings Canyon Road and Jensen Avenue and a twolane collector between Jensen Avenue and North Avenue.

Temperance Avenue is an existing north-south two-lane undivided super arterial in the vicinity of the proposed Project. In this area, Temperance Avenue is a two-lane undivided super arterial between Kings Canyon Road and Butler Avenue, a four-lane divided super arterial between Butler Avenue and Hamilton Avenue and a two-lane undivided super arterial between Hamilton Avenue and North Avenue. The Fresno General Plan Circulation Element designates Temperance Avenue as a six-lane super arterial between Kings Canyon Road and Jensen Avenue and a four-lane super arterial between Jensen Avenue and North Avenue.

Hamilton Avenue is an existing east-west two-lane collector divided by a two-way left-turn lane in the vicinity of the proposed Project. In this area, Hamilton Avenue exists as a two-lane collector divided by a two-way left-turn lane between Fowler Avenue and Temperance Avenue. The Fresno General Plan Circulation Element designates Hamilton Avenue as a two-lane collector between Fowler Avenue and Temperance Avenue.

California Avenue is an existing east-west four-lane collector west of Fowler Avenue and east of Armstrong Avenue. Through the Project, California Avenue is proposed to 109
be designed as a modified collector which will include a single vehicle lane in each direction divided by a 16-foot wide raised median with landscaping and a curbside Class II or Class IV bikeways. In this area, California Avenue exists between Armstrong Avenue and approximately 100 feet west of Temperance Avenue. The Fresno General Plan Circulation Element designates California Avenue as a four-lane collector between Fowler Avenue and Temperance Avenue. However, the Fresno COG traffic forecasting and the LOS operations within this TIA support the proposed cross section with a maximum of one vehicular lane per direction. Based on information provided by City of Fresno staff, the easterly extension of California Avenue to Temperance Avenue will be constructed and operational by early 2026.

Church Avenue is an existing east-west two-lane undivided collector in the vicinity of the proposed Project site. In this area, Church Avenue is a four-lane collector divided by a two-way left-turn lane between Peach Avenue and Sunnyside Avenue, a threelane divided collector between Sunnyside Avenue and Fowler Avenue, a two-lane undivided collector between Fowler Avenue and Temperance Avenue and a two-lane undivided roadway between Temperance Avenue and Leonard Avenue. The Fresno General Plan Circulation Element designates Church Avenue as a four-lane collector between Willow Avenue and Temperance Avenue and a two-lane local roadway between Temperance Avenue and Highland Avenue.

Study Scenarios
Existing Traffic Conditions: This scenario evaluates the Existing Traffic Conditions based on existing traffic volumes and roadway conditions from traffic counts and field surveys conducted in June, August and September of 2024. The traffic counts for the existing study intersections and segments are contained in Appendix G.

Existing plus Project Traffic Conditions: This scenario evaluates total traffic volumes and roadway conditions based on the Existing plus Project Traffic Conditions. The Existing plus Project traffic volumes were obtained by adding the Project Only Trips to the Existing Traffic Conditions. The Project Only Trips to the study facilities were developed based on existing travel patterns, the Project Select Zone, the surrounding roadway network, engineering judgment, data provided by the developer, knowledge of the study area, existing residential and commercial densities, and the Fresno 110
General Plan Circulation Element in the vicinity of the Project site. The Fresno COG Project Select Zone results are contained in Appendix G.

Near Term plus Project Traffic Conditions: This scenario evaluates total traffic volumes and roadway conditions based on the Near Term plus Project Traffic Conditions. The Near Term plus Project traffic volumes were obtained by adding the Near Term related trips to the Existing plus Project Traffic Conditions scenario.

Cumulative Year 2046 plus Project Traffic Conditions: This scenario evaluates total traffic volumes and roadways conditions based on the Cumulative Year 2046 plus Project Traffic Conditions. The Cumulative Year 2046 plus Project traffic volumes were obtained by using a combination of the Fresno COG activity-based model (ABM) (Base Year 2019 and Cumulative Year 2046) and existing traffic counts. Under this scenario, the increment method, as recommended by the Model Steering Committee was utilized to determine the Cumulative Year 2046 traffic volumes. The Fresno COG ABM results provided by Kittelson & Associates are contained in Appendix G.

Results Under Each Study Scenario
Existing Traffic Conditions
A search was conducted of the Statewide Integrated Traffic Records System (SWITRS) to obtain collision reports for the most recent five-year period. Based on a review of the collision reports, a total of twenty-three (23) collisions were reported within the influence zone of the study intersections. Based on the number of correctable collisions, changes to the existing traffic controls at any of these intersections as a result of collision activity is not recommended. At present, all study intersections and the study segments operate at an acceptable LOS.

Existing plus Project Traffic Conditions
The locations of the existing and proposed roadways and access points were analyzed. This review revealed that all access points are located at points that minimize traffic operational impacts to existing and future roadway networks. At buildout, the proposed Project is estimated to generate a maximum of 1,905 daily trips, 111
141 AM peak hour trips and 190 PM peak hour trips. Under this scenario, all study intersections and segments are projected to continue operating at an acceptable LOS.

Near Term plus Project Traffic Conditions
The total trip generation for the Near-Term Projects is 96,426 weekday daily trips, 6,883 weekday AM peak hour trips and 8,598 weekday PM peak hour trips. Under this scenario, the intersections of Temperance Avenue at Hamilton Avenue and Armstrong Avenue at Church Avenue are projected to exceed their LOS threshold during AM peak period. Accordingly, the following improvements (Mitigation Measure TRA-1) will be included with the Project:

Traffic signal pole(s), less signal mast arms, including all related pull boxes and conduit associated with said pole(s), as necessary for a future four-leg intersection at California Avenue and Armstrong Avenue.

These improvements will reduce LOS impacts to less than significant.

Cumulative Year 2046 plus Project Traffic Conditions
Under this scenario, the intersections of Temperance Avenue at Hamilton Avenue, Temperance Avenue at California Avenue and Armstrong Avenue at Church Avenue are projected to exceed their LOS threshold during one or both peak periods. As such, Mitigation Measure TRA-1 shall be implemented which will include improvements at the intersections of Temperance Avenue at Hamilton Avenue, Temperance Avenue and California Avenue and Armstrong Avenue at Church Avenue. These improvements will reduce LOS impacts to less than significant.

Active Transportation Plan
The Fresno Active Transportation Plan (ATP) is an extensive guide detailing the conception for active transportation in the City of Fresno that was adopted in December 2016. This ATP aims to improve safety, increase non-motorized trips, improve access and fill in gaps in networks for Fresno's pedestrians and bicyclists. In order to achieve these goals for active transportation, this ATP proposes a comprehensive network of citywide bikeways, trails and sidewalks. The recommended network would add 166 miles of Class I Bike Paths, 691 miles of Class II Bike Lanes, 69 miles of Class III Bike Routes, 21 miles of Class IV Separated Bikeways and 661 miles of sidewalks. This ATP also recommends bicycle detection at traffic signals, 112
destination signage, bicycle parking, showers and changing facilities and bikeway maintenance. This network will be constructed in conjunction with adjacent land developments, roadway maintenance and active transportation infrastructure projects using funds from different local, state and federal sources.

Bikeways
The Fresno ATP classifies bicycle facilities into the following types:
• Class I Bikeway (Bike Path) – Provides a completely separated right-of-way for exclusive use of bicycles and pedestrians with crossflow minimized. • Class II Bikeway (Bike Lane) – Provides a striped lane for one-way bike travel on a street or highway.
• Class III Bikeway (Bike Route) – Provides a shared use with pedestrians or motor vehicle traffic, typically on lower volume roadways. • Class IV Bikeways (Separated Bikeways) – Provides a protected lane for oneway bike travel (one-way cycle track) and protected lanes for two-way bike travel (two-way cycle track) on a street or highway.

Class II (Bike Lane) Bikeways exist in the vicinity of the Project site along portions of Fowler Avenue, Armstrong Avenue, Hamilton Avenue, California Avenue and Church Avenue. The Fresno ATP recommends that Class II Bikeways be implemented adjacent to and in the vicinity of the Project site. Adjacent to the Project site, a Class II Bikeway is planned along the west side of Armstrong Avenue. In the vicinity of the Project site, Class II Bikeways are planned on remaining stretches Fowler Avenue, Armstrong Avenue, Temperance Avenue, Hamilton Avenue, California Avenue and Church Avenue. In the vicinity of the Project site, a Class I Bikeway is planned on Temperance Avenue between SR 180 and North Avenue. Mitigation Measure TRA-2 is included to require that the Project construct a Class II Bikeway on its frontages to Armstrong Avenue and California Avenue, as required by the Fresno ATP.

Walkways
The Fresno ATP classifies pedestrian facilities into sidewalks and Class I Bike Paths.

Pedestrian sidewalks exist in the vicinity of the Project site along portions of Fowler Avenue, Armstrong Avenue, Temperance Avenue, Hamilton Avenue, California 113
Avenue and Church Avenue. The Fresno ATP recommends that pedestrian sidewalks be implemented in the vicinity of the Project site along remaining stretches of Fowler Avenue, Armstrong Avenue, Temperance Avenue, Hamilton Avenue, California Avenue and Church Avenue. Therefore, Mitigation Measure TRA-2 is included to require the Project construct ADA compliant pedestrian sidewalks along internal streets connecting all uses to external sidewalks and along its frontages to Armstrong Avenue and California Avenue, in compliance with the Fresno ATP.

Transit
Fresno Area Express (FAX), is the transit operator in the City of Fresno. At present, there are two (2) FAX transit routes that operate in the vicinity of the proposed Project site, Routes 1 and 22. FAX Route 1, which runs on a portion of Kings Canyon Road, operates at 15-minute intervals on weekdays and weekends. The nearest stop on this route to the Project site is located along the north side of Kings Canyon Road approximately 750 feet east of Clovis Avenue. This route provides a direct connection to the River Park Shopping Center, Manchester Center, Fresno City College, Downtown Fresno, the Big Fresno Fair grounds and Sunnyside High School. FAX Route 22, which runs on Clovis Avenue, operates at 30minute intervals on weekdays and weekends. The nearest stop on this route to the Project site is located along the west side of Burgan Avenue approximately 100 feet north of Lyell Avenue and is only used during peak hours. This route provides a direct connection Roosevelt High, the Amtrak Station, Central Library, Downtown Transit Center, Downtown Fresno, Community Center, Talking Book Library, West Lan Shopping Center and Fig Garden Library. It is worth noting that retention of the existing and expansion of future transit routes is dependent on transit ridership demand and available funding.

In conclusion, upon implementation of Mitigation Measures TRA-1 and TRA-2, the proposed Project will not require any additional changes to existing transportation systems and will have less than significant impact on any plans, ordinances, or policies related to the effectiveness or performance of transit, pedestrian and bicycle facilities. The Project will comply with all applicable City development standards. Any impacts would be less than significant with mitigation incorporation. b) Would the project conflict or be inconsistent with CEQA Guidelines section 114
15064.3, subdivision (b)?
Less Than Significant Impact. Senate Bill (SB) 743 requires that relevant CEQA analysis of transportation impacts be conducted using a metric known as vehicle miles traveled (VMT) instead of Level of Service (LOS). VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto our roads, the project may cause a significant transportation impact.

The State CEQA Guidelines were amended to implement SB 743, by adding Section 15064.3. Among its provisions, Section 15064.3 confirms that, except with respect to transportation projects, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, LOS measures of impacts on traffic facilities is no longer a relevant CEQA criteria for transportation impacts.

CEQA Guidelines Section 15064.3(b)(4) states that “[a] lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate used to estimate vehicle miles traveled and any revision to model outputs should be documented and explained in the environmental document prepared for the project.

The standard of adequacy in Section 15151 shall apply to the analysis described in this section.”
On June 25, 2020, the City of Fresno adopted CEQA Guidelines for Vehicle Miles Traveled Thresholds pursuant to Senate Bill 743 to be effective of July 1, 2020. The thresholds described therein are referred to herein as the City of Fresno VMT Thresholds. The City of Fresno VMT Thresholds document was prepared and adopted consistent with the requirements of CEQA Guidelines Sections 15064.3 and 15064.7.

The December 2018 Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory) published by the Governor’s Office of Planning and Research (OPR), was utilized as a reference and guidance document in the preparation of the Fresno VMT Thresholds.
115
The City of Fresno VMT Thresholds adopted a screening standard and criteria that can be used to screen out qualified projects that meet the adopted criteria from needing to prepare a detailed VMT analysis.

The City of Fresno VMT Thresholds Section 3.0 regarding Project Screening discusses a variety of projects that may be screened out of a VMT analysis including specific development and transportation projects. For development projects, conditions may exist that would presume that a development project has a less than significant impact. These may be size, location, proximity to transit, or trip‐making potential. For transportation projects, the primary attribute to consider with transportation projects is the potential to increase vehicle travel, sometimes referred to as “induced travel.”
Trip generation rates for the proposed Project were obtained from the 11th Edition of the Trip Generation Manual published by the Institute of Transportation Engineers (ITE) (see Appendix G), the proposed Project will generate 1,905 Average Daily Trips (ADT), 141 AM peak hour trips and 190 PM peak hour trips.

One of the eligible screening criteria is whether a residential project is located within an area with low VMT, as designated in the screening map for residential uses (Figure 6) in the City of Fresno’s CEQA Guidelines for VMT Thresholds Technical Advisory.

These low VMT areas were calculated using Fresno County as the region. The Fresno County average VMT per capita is 16.90. The City of Fresno’s Urban Form VMT Calculator was utilized on behalf of the Project and indicated that the Project had an adjusted VMT per capita of 14.00 (See Appendix H). This results in a less than significant impact.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less Than Significant Impact. Access to and from the proposed Project site will be from four (4) access points along future California Avenue west of Armstrong Avenue, and 2 (two) along the west side of Armstrong Avenue at buildout. The Project proposes to construct California Avenue west of Armstrong Avenue within the Project 116
site for approximately 1,300 feet. The four (4) access points along California Avenue include two (2) access points located on either side of future California Avenue approximately 1,150 feet west of Armstrong Avenue and two (2) access point located on either side of future California Avenue approximately 550 feet west of Armstrong Avenue. All four (4) access points are proposed to have full access to California Avenue. The two (2) access points proposed along the west side of Armstrong Avenue are located approximately 330 feet north of California Avenue and approximately 600 feet south of California Avenue. Both of these access points are proposed to have full access to Armstrong Avenue. Furthermore, one (1) outlet on the south, one (1) outlet on the west and California Avenue on the west can all be connected to for more access in the future.

A review of the existing and proposed roadways and access points indicates that they are located at points that minimize traffic operational impacts to existing and future roadway networks. The Project will be designed to current standards and safety regulations. All intersections will be constructed to comply with the City and Caltrans regulations, and design and safety standards of Chapter 33 of the California Building Codes (CBC) and the guidelines of Title 24 in order to create safe and accessible roadways.

Vehicles exiting the subdivision will be provided with a clear view of the roadway without obstructions. Landscaping associated with the entry driveways could impede such views, if improperly installed. Specific circulation patterns and roadway designs will incorporate all applicable safety measures to ensure that hazardous design features or inadequate emergency access to the site or other areas surrounding the project area would not occur. Therefore, with the incorporated design features and all applicable rules and regulations, the Project will have a less than significant impact.
d) Result in inadequate emergency access?
Less Than Significant Impact. State and City Fire Codes establish standards by which emergency access may be determined. The proposed Project would have to provide adequate unobstructed space for fire trucks to turn around. The Fresno City Fire Department reviewed the proposed Project plans and determined access is 117
acceptable as proposed. The proposed project site would have adequate internal circulation capacity including entrance and exit routes to provide adequate unobstructed space for fire trucks and other emergency vehicles to gain access and to turn around. The proposed Project would not inhibit the ability of local roadways to continue to accommodate emergency response and evacuation activities. Impacts would be less than significant.

Mitigation Measures:

The proposed Project shall implement and incorporate the transportation related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.

TRA – 1: The proposed Project shall implement the following intersection improvements to reduce impacts to LOS:
• The developer shall install traffic signal pole(s) less signal mast arms including all related pull boxes and conduit associated with said pole(s), as necessary for a future four-leg intersection at California Avenue and Armstrong Avenue.

TRA – 2: The following measures shall be implemented to ensure compliance with the Fresno Active Transportation Plan:
o The Project shall construct a Class II Bikeway on its frontages to Armstrong Avenue and California Avenue.
o The Project shall construct ADA compliant pedestrian sidewalks along internal streets connecting all uses to external sidewalks and along its frontages to Armstrong Avenue and California Avenue.
118

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVIII. TRIBAL CULTURAL RESOURCES – Would the project:
119

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse
change in the significance of a
tribal cultural resource, defined in
PRC section 21074 as either a
site, feature, place, cultural
landscape that is geographically
defined in terms of the size and
scope of the landscape, sacred
place, or object with cultural value
to a California Native American
tribe, and that is:
i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
PRC section 5020.1(k), or,
X
120

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
ii) A resource determined by the
lead agency, in its discretion and
supported by substantial evidence, to be significant pursuant to criteria set forth in subdivisionI)
of PRC section 5024.1. In
applying the criteria set forth in
subdivisI (c) of PRC section
5024.1, the lead agency shall
consider the significance of the
resource to a California Native
American tribe.

DISCUSSION
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
Less Than Significant Impact with Mitigation. A Tribal Cultural Resource (TCR) is defined under Public Resources Code section 21074 as a site, 121
feature, place, cultural landscape that is geographically defined in terms of size and scope, sacred place, and object with cultural value to a California Native American tribe that are either included and that is listed or eligible for inclusion in the California Register of Historic Resources or in a local register of historical resources. Pursuant to Assembly Bill 52 (AB 52), the Table Mountain Rancheria Tribe and the Dumna Wo Wah were invited to consult under both AB 52. The City of Fresno mailed notices of the proposed Project to each of these tribes on April 15, 2022, which included the required 30-day time period for tribes to request consultation. Following the close of the 30-day comment period, City staff confirmed that no comments were received. Because the Tribes did not request consultation, because of compliance with California Health and Safety Code Section 7050.5 as discussed in Section V, and because of the implementation of CUL-1 which will protect any unknown resources, any impacts to TCR’s are less than significant. ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less Than Significant Impact. The State requires lead agencies to consider the potential effects of proposed projects and consult with California Native American tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Resources through the California Environmental Quality Act (CEQA) Guidelines. Pursuant to PRC Section 21080.3.1, the lead agency shall begin consultation with the California Native American tribe that is traditionally and culturally affiliated with the geographical area of the proposed project. Such significant cultural resources are either sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a tribe which is either on or eligible for inclusion in the California Historic Register or local historic register, or, the lead agency, at its discretion, and support by substantial evidence, choose to treat the resources as a Tribal Cultural 122
Resources (PRC Section 21074(a)(1-2)). According to the most recent census data, California is home to 109 currently recognized Indian tribes. Tribes in California currently have nearly 100 separate reservations or Rancherias. Fresno County has a number of Rancherias such as Table Mountain Rancheria, Millerton Rancheria, Big Sandy Rancheria, Cold Springs Rancheria, and Squaw Valley Rancheria. These Rancherias are not located within the city limits.

Native American tribes traditionally and culturally affiliated with the project area were invited to consult regarding the project based on a list of contacts provided by the Native American Heritage Commission (NAHC). This list includes tribes that requested notification pursuant to Assembly Bill 52 (AB 52). The City of Fresno mailed notices of the proposed project to each of these tribes on April 15, 2022, which included the required 30-day time period for tribes to request consultation, which ended on May 16, 2022. All tribes which were contacted declined consultation. Therefore, there is a less than significant impact.

Mitigation Measures

1. The proposed project shall implement and incorporate the tribal cultural resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated April 24, 2025.
123
CUL-1: If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study. The qualified historical resources specialist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines and the City’s Historic Preservation Ordinance.

If the resources are determined to be unique historical resources as defined under Section 15064.5 of the CEQA Guidelines, measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds.

No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these. Any historical artifacts recovered as a result of mitigation shall be provided to a City-approved institution or person who is capable of providing long-term preservation to allow future scientific study.
124

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the
relocation or construction of new
or expanded water, wastewater
treatment or storm water
drainage, electric power, natural
gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effect?
X
b) Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry
and multiple dry years?
X
c) Result in a determination by the
waste water treatment provider,
which serves or may serve the
project that it has adequate
capacity to serve the project’s
projected demand in addition to
the provider’s existing
commitments?
X
125

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Generate solid waste in excess
of state or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?
X
e) Comply with federal, state, and
local management and reduction
statutes and regulations related to
solid waste?
X

DISCUSSION
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less Than Significant Impact. The proposed Project will require construction of new infrastructure to connect to the existing utility infrastructure. This will include water, wastewater, and storm water drainage connections. Additionally, the Project will include connections for electric power, natural gas, and telecommunications facilities. The installation of this infrastructure will not require any major upsizing or other offsite construction activities that would cause a significant impact. The new infrastructure would be connected to the existing infrastructure that is adjacent to the Project site.
126
Impacts to storm drainage facilities have been previously discussed under the Hydrology and Water Quality section included within this analysis herein above. As described in Section VII, Geology and Soils, and in compliance with NPDES General Construction Permit requirements, the proposed Project would design and submit a site-specific SWPPP to minimize the discharge of wastewater during construction and a Water Quality Management Plan that includes best management practices (BMPs) for runoff control as required. Therefore, the proposed Project would not require new stormwater drainage facilities to manage stormwater runoff during construction or operation.

The proposed Project would be subject to the payment of any applicable connection charges and/or fees and extension of services in a manner that is compliant with the Department of Public Utilities standards, specifications, and policies.

Sanitary sewer and water service under City of Fresno jurisdiction, delivery is also subject to payment of applicable connection charges and/or fees; compliance with the Department of Public Utilities standards, specifications, and policies; the rules and regulations of the California Public Utilities Commission and California Health Services; and, implementation of the City-wide program for the completion of incremental expansions to facilities for planned water supply, treatment, and storage.

Impacts would be less than significant.
b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less Than Significant Impact. As discussed under the Section VII Hydrology and Water Quality section of this Initial Study, the Fresno General Plan recognizes regional water resource planning efforts, such as, the Kings Basin’s Integrated Regional Water Management Plan, the Fresno-Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resource Management Plan and cites the findings of the City of Fresno 2020 UWMP. The purpose of these management plans is to provide safe, adequate, and dependable water supplies in order to adequately meet existing and future needs of the Kings Basin regions and the Fresno-Clovis metropolitan area in an economical manner; protect groundwater quality from further degradation and overdraft; and provide a plan of reasonably implementable measures and facilities. Through routing to the applicable 127
departments and agencies, the City has determined that adequate water supply exists to serve the proposed Project. Additionally, the applicant will be required to comply with all requirements of the City of Fresno Department of Public Utilities to reduce the Project’s water impacts to less than significant. c. Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant Impact. See Impact (b) above. The City of Fresno acts as the Regional Sewer Agency and is responsible for operating the Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF) and the North Fresno Wastewater Treatment Facility (NFWTF). The Regional Facility provides wastewater treatment for a service area that includes most of the Cities of Fresno and Clovis, and some unincorporated areas of Fresno County. The City is currently evaluating upgrades and modifications to the existing Regional Facility that may result in a capacity rating increase of 15.0 MGD. The City of Clovis owns 9.3 MGD of wastewater treatment capacity at the Regional Facility, and the City of Fresno owns the remaining capacity.

The NFWTF was constructed in late 2006 to provide wastewater treatment service for residential and commercial development in the surrounding area of north Fresno.

The permitted capacity of the NFWTF is 0.71 MGD, as an average monthly flow, and

1.07 MGD, as a maximum daily flow. The City's master plan for the NFWTF calls for ultimate expansion to an average monthly flow capacity of 1.07 MGD upon full development of the NFWRF service area.

The City of Fresno Department of Public Utilities has reviewed the Project and determined that sanitary sewer facilities are available to provide service to the site, subject to the required conditions of approval. The City will provide sewer connection.

The conditions of approval include payment of the applicable sanitary sewer fees, which would eventually be used to provide funding for the improvements at the RWRF and NFWTF in order to expand. The proposed Project will not result in a determination by the wastewater treatment provider that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing 128
commitments. Impacts would be less than significant.
d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant Impact. The City of Fresno Department of Public Utilities, Solid Waste Division has reviewed the Project for compliance with any federal, State, and local management and reduction statutes and regulations related to solid waste.

Solid waste disposed of in the City of Fresno is taken to Cedar Avenue Recycling and Transfer Station. Once the trash has been off‐loaded at the transfer station, it is sorted, and non‐recyclable solid waste is loaded onto large trucks and taken to the American Avenue Landfill located approximately six miles southwest of Kerman.

American Avenue Landfill is owned and operated by Fresno County and began operations in 1992 for both public and commercial solid waste haulers. The American Avenue Landfill is a sanitary landfill, meaning that it is a disposal site for a nonhazardous solid waste spread in layers, compacted to the smallest practical volume, and covered by material applied at the end of each operating day.

The American Avenue Landfill (i.e., American Avenue Disposal Site 10‐AA‐0009) has a maximum permitted capacity of 32,700,000 cubic yards and a remaining capacity of 29,358,535 cubic yards, with an estimated closure date of August 31, 2031. The maximum permitted throughput is 2,200 tons per day.

In the operational phase, typical household refuse would be generated by residences. According to CalRecycle, residential units average 12.23 lbs.21 of household refuse per day. The proposed 202 units would generate approximately 2,470.5 lbs. per day, or approximately 409 tons per year. The site is designated by the General Plan for residential uses and as such, site development has been accounted for in the City’s infrastructure planning documents, including waste management. Additionally, the Project would be required to comply with the City’s Resolution which would curb solid waste generation in keeping with the provisions of 21 CalRecycle. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed December 2024.
129
AB 939. The Project will comply with any statutes and regulations related to solid waste. Therefore, the proposed Project would not result in any waste related environmental impacts, and impacts would be less than significant. e. Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant Impact. While there are no applicable federal regulations, the proposed Project would be required to comply with State and local statutes and regulations related to solid waste. Pursuant to the provisions of AB 939, the City is required to divert 50 percent of solid waste generated in its jurisdiction away from landfills. The Project will comply with any statutes and regulations related to solid waste. Impacts would be less than significant.

Mitigation Measures
None are required.
130

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
X
b) Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks, and thereby expose
project occupants to pollutant
concentrations from a wildfire or
the uncontrolled spread of a
wildfire?
X
c) Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water
sources, power lines or other
utilities) that may exacerbate fire
risk or that may result in temporary
or ongoing impacts to the
environment?
X
131

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Expose people or structures to
significant risks, including
downslope or downstream
flooding or landslides, as a result
of runoff, post-fire slope instability,
or drainage changes?
X
Setting
There are no State Responsibility Areas (SRAs) within the vicinity of the Project site. The Project site is not categorized as a "Very High" Fire Hazard Severity Zone (FHSZ) by CalFire. Although this CEQA topic only applies to areas within an SRA or Very High FHSZ, out of an abundance of caution, these checklist questions are analyzed below.

DISCUSSION
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
No Impact. The City of Fresno does have an adopted Emergency Operations Plan (EOP); however the EOP does not designate evacuation routes, which may not be necessary since Fresno does not face any expected natural hazards from likely sources or locations.22 The Project site will connect to an existing network of City streets. The Project site is located in an area with several alternative access roads allowing access in the event of an emergency. Access to the alternative access roads would be maintained throughout construction, and appropriate detours would be e Fresno General Plan. Chapter 9: Noise and Safety. Page 9-40. https://www.fresno.gov/wpcontent/uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf. Accessed December 2024. 132
provided in the event of potential road closures. The City of Fresno Fire Department oversees emergency response and preparedness.

Therefore, no significant impacts related to the impairment of the implementation of or physical interference with an adopted emergency response plan or emergency evacuation plan would occur. The Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. There is no impact.
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less Than Significant Impact. The risk of wildfire is related to a variety of parameters, including fuel loading (vegetation), fire weather (winds, temperatures, humidity levels and fuel moisture contents) and topography (degree of slope). Steep slopes contribute to fire hazard by intensifying the effects of wind and making fire suppression difficult. Fuels such as grass are highly flammable because they have a high surface area to mass ratio and require less heat to reach the ignition point. The Project site is located in an area that is predominately urban, which is not considered a significant risk for wildlife. There are minimal amounts of highly flammable fuels such as dry grass in the area. Therefore, in the unlikely event of a wildfire, the Project would not expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. Impacts will be less than significant. c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No Impact. The Project includes development of infrastructure (water, sewer, and storm drainage) required to support the proposed residential uses. The Project site is surrounded by existing and future urban development. The Project would not require the installation or maintenance of infrastructure that may exacerbate fire risk.

However, the development will meet local and State development codes and regulations related to fire protection and prevention. There is no impact. 133
d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The proposed Project would require the installation of storm drainage infrastructure to ensure that storm waters properly drain from the Project site and do not result in downstream flooding or major drainage changes. A storm drainage plan would be designed and engineered to ensure the proper construction of storm drainage infrastructure to control runoff and prevent flooding, erosion, and sedimentation.

Upon development of the site, stormwater would flow to the existing storm drains in the adjacent roadways. Any further storm drain requirements will be processed by the Fresno Metropolitan Flood Control District and constructed per the District’s standards. Additionally, the Project site is outside of any Special Flood Hazard Areas or Other Areas of Flood Hazard, FEMA Flood Map 06019C2135H, effective 2/18/2009. Further, because the site is essentially flat and located in an existing urbanized area of the City, downstream landslides would not occur.

Landslides include rockfalls, deep slope failure, and shallow slope failure. Factors such as the geological conditions, drainage, slope, vegetation, and others directly affect the potential for landslides. One of the most common causes of landslides is construction activity that is associated with road building (i.e., cut and fill). The Project site is relatively flat; therefore, the potential for a landslide in the Project site is essentially non-existent. There is no impact.

Mitigation Measures
None are required.
134

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the
potential to degrade the quality of
the environment, substantially
reduce the habitat of a fish or
wildlife species, cause a fish or
wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or animal
community, reduce the number or
restrict the range of a rare or
endangered plant or animal or
eliminate important examples of
the major periods of California
history or prehistory?
X
135

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Does the project have impacts
that are individually limited, but
cumulatively considerable?
("Cumulatively considerable"
means that the incremental
effects of a project are
considerable when viewed in
connection with the effects of past
projects, the effects of other
current projects, and the effects of
probable future projects)?
X
c) Does the project have
environmental effects which will
cause substantial adverse effects
on human beings, either directly
or indirectly?
X

DISCUSSION
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory? 136
Less than Significant Impact. The proposed Project site is developed with a singlefamily residence and highly disturbed vacant land that is regularly disked for weed control. The site includes the development of 202 residential units and the associated improvements. As evaluated in this IS/MND, the proposed Project would not substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below selfsustaining levels; threaten to eliminate a plant or animal community; reduce the number or restrict the range of an endangered, rare, or threatened species; or eliminate important examples of the major periods of California history or prehistory.

Mitigation measures have been included to lessen the significance of potential impacts. Similar mitigation measures would be expected of other projects in the surrounding area, most of which share similar cultural paleontological and biological resources. Consequently, the incremental effects of the proposed Project, after mitigation included in this Initial Study, would not contribute to an adverse cumulative impact on these resources. Therefore, the project would have a less than significant impact.
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
Less than Significant Impact. CEQA Guidelines Section 15064(h) states that a Lead Agency shall consider whether the cumulative impact of a project is significant and whether the effects of the project are cumulatively considerable. The assessment of the significance of the cumulative effects of a project must, therefore, be conducted in connection with the effects of past projects, other current projects, and probable future projects. Due to the nature of the Project and consistency with environmental policies, incremental contributions to impacts are considered less than cumulatively considerable. All Project-related impacts were determined to be either less than significant, or less than significant after mitigation. The proposed Project would not contribute substantially to adverse cumulative conditions or create any substantial indirect impacts (i.e., increase in population could lead to an increased need for housing, increase in traffic, air pollutants, etc.). Due to buildout of the area and existing land constraints, it is not anticipated that further unplanned substantial residential 137
development will occur in the area in the foreseeable future. As such, Project impacts are not considered to be cumulatively considerable given the lack of proposed new development in the area and the insignificance of Project-induced impacts. The impact is therefore less than significant.
c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Less than Significant Impact with Mitigation. The analyses of environmental issues contained in this Initial Study indicate that the Project is not expected to have substantial impact on human beings, either directly or indirectly. Project-specific mitigation measures have been incorporated as described in each specific impact area which will reduce all potentially significant impacts to less than significant.

References
California Department of Transportation. State Scenic Highway Map. https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc 8e8057116f1aacaa. Accessed December 2024.

California Department of Conservation. California Important Farmland Finder. https://maps.conservation.ca.gov/dlrp/ciff/. Accessed December 2024.

California Department of Conservation. California Geological Survey. Fault Activity Map of California. https://maps.conservation.ca.gov/cgs/fam/. Accessed December 2024.

California Department of Conservation. California Agricultural Land Evaluation and Site Assessment (LESA) Model. Instruction Manual. 1997.Page 2. https://www.conservation.ca.gov/dlrp/Pages/qh_lesa.aspx. Accessed December 2024.

California Department of Toxic Substances Control, EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/. Accessed December 2024. 138
California State Water Resources Control Board, GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Fresno.

December 2024.

CalRecycle. Estimated Solid Waste Generation Rates.
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed December 2024.

City of Fresno 2020 Urban Water Management Plan. July 2021. Pg. ES-4. https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-2020-UWMP_Final_2021- 07-21-1.pdf. Accessed December 2024.

Fresno County Airport Land Use Compatibility Plan, December 2018, Part Two. Exhibit D1, Fresno-Yosemite INTL. Airport Influence Area and Safety Zones. https://fresnocog.wpenginepowered.com/wp-content/uploads/2019/01/fresno-finalalucp-113018-r_part2.pdf. Accessed December 2024.

Fresno General Plan. Chapter 9: Noise and Safety. Page 9-40. https://www.fresno.gov/wp-content/uploads/2023/03/upload_temp_Consolidated-GP-10- 13-2022_compressed.pdf. Accessed May, 2024.

Fresno General Plan Program Environmental Impact Report Public Review Draft. March 2020. https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-GP-Public-ReviewDraft-Program-EIR.pdf. Accessed May 2024. Page 4.4-3.

U.S. Census Bureau. QuickFacts. Fresno City. 2017-2017. https://www.census.gov/quickfacts/fact/table/fresnocitycalifornia,fresnocountycalifornia/ PST045222. Accessed November 2024.

USDA Natural Resources Conservation Service. Custom Soil Resource Report for Eastern Fresno Area, California.

U.S. Geological Service. Areas of Land Subsidence in California. https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html. Accessed October 2024.
139
US Fish and Wildlife Service. National Wetlands Inventory Surface Waters and Wetlands Mapper. https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed November 2024.

MITIGATION MONITORING AND REPORTING
PROGRAM – April 24, 2025
This Mitigation Monitoring and Reporting Program (MMRP) has been formulated based upon the findings of the Initial Study/Mitigated Negative Declaration (IS/MND) for the City of Fresno’s T6376/P21-05373/P21-05090 Residential Project (proposed Project). The MMRP lists mitigation measures recommended in the IS/MND for the proposed Project and identifies monitoring and reporting requirements as well as conditions recommended by responsible agencies who commented on the project.

The first column of the Table identifies the mitigation measure. The second column, entitled “Party Responsible for Implementing Mitigation,” names the party responsible for carrying out the required action. The third column, “Implementation Timing,” identifies the time the mitigation measure should be initiated. The fourth column, “Party Responsible for Monitoring,” names the party ultimately responsible for ensuring that the mitigation measure is implemented. The last column will be used by the City to ensure that individual mitigation measures have been monitored.

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
BIO-1: In addition to implementation of the measures
included in the Staff Report on Burrowing Owl
Mitigation (CDFG 2012), if construction activities
occur during the avian nesting season (generally,
February 1 through August 31), preconstruction
surveys for nesting birds by a qualified ornithologist
should be conducted to ensure that no active nests
are disturbed during construction. The survey should
be conducted no more than seven days before
construction activities begin. During this survey, all
potential nesting areas should be inspected in and
immediately adjacent to the impact areas for nests. If
an active nest is found sufficiently close to work areas to be disturbed by these activities, the ornithologist
should determine the extent of a construction-free
buffer zone to be established around the nest
(typically, 300 ft. for raptors and 25–100 ft. for other species) to ensure that no active nests of species
protected by the California Fish and Game Code
would be disturbed during project construction.

Project
Applicant and
Qualified
Biologist
Prior to initiation of any
site
preparation/construction
City of
Fresno,
Planning and
Development
Department
BIO-2: To the extent practicable, construction shall be scheduled to avoid the nesting season, which extends
from February through August. If it is not possible to
schedule construction between September and
January, pre-construction surveys for nesting birds
shall be conducted by a qualified biologist to ensure
that no active nests would be disturbed during the
implementation of the Project. A pre-construction
survey shall be conducted no more than 14 days prior
Project
Applicant and
Qualified
Biologist
Prior to initiation of any
site
preparation/construction
City of
Fresno,
Planning and
Development
Department
Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
to the initiation of construction activities. During this survey, the qualified biologist shall inspect all potential nest substrates in and immediately adjacent to the
impact areas. If an active nest is found close enough
to the construction area to be disturbed by these
activities, the qualified biologist shall determine the extent of a construction-free buffer to be established
around the nest. If work cannot proceed without
disturbing the nesting birds, work may need to be
halted or redirected to other areas until nesting and
fledging are completed or the nest has otherwise
failed for non-construction related reasons.

CUL-1: If previously unknown resources are
encountered before or during grading activities,
construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist
shall be consulted to determine whether the resource
requires further study. The qualified historical
resources specialist shall make recommendations to
the City on the measures that shall be implemented to
protect the discovered resources, including but not
limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA
Guidelines and the City’s Historic Preservation
Ordinance. If the resources are determined to be
unique historical resources as defined under Section
15064.5 of the CEQA Guidelines, measures shall be
identified by the monitor and recommended to the
Lead Agency. Appropriate measures for significant
Project
Applicant and
qualified
historical
resources
specialist
Planning and
Development
Department to review
construction
specifications to ensure
inclusion of provisions
included in mitigation
measure.

City of
Fresno,
Planning and
Development
Department
Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
resources could include avoidance or capping,
incorporation of the site in green space, parks, or
open space, or data recovery excavations of the finds.

No further grading shall occur in the area of the
discovery until the Lead Agency approves the
measures to protect these resources. Any historical
artifacts recovered as a result of mitigation shall be
provided to a City‐approved institution or person who
is capable of providing long‐term preservation to allow future scientific study.

HAZ-1: Additional soil gas sampling shall be
performed near the former southeastern UST once
over-excavation, site grading, and other earthwork
activities have been completed to confirm the lowlevel detections of PCE do not pose a vapor intrusion threat to future residential dwellings. If PCE levels are above the California Department of Toxic Substances
Control (DTSC) soil gas thresholds, sub-slab vapor
barriers, or another construction method which will
reduce PCE levels to less than DTSC soil gas
threshold shall be implemented.

Project
Applicant
After earthwork
activities have been
completed, prior to
constructing residential
foundations.

City of
Fresno,
Planning and
Development
Department
NOI-1: A sound wall shall be constructed along the
entire project site frontage with the SJVR railroad line.

In the vicinity of Lot 76, the wall shall be constructed to a minimum height of eight feet six inches (8’6”)
above project site grade, and the sound wall shall be
constructed to a minimum height of seven (7) feet
Project
Applicant
Construction shall be
completed prior to
occupancy permit.

City of
Fresno,
Planning and
Development
Department
Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
above project site grade along the remainder of the
SJVR project site frontage. In order to be effective, the sound wall shall be turned inward (southward) for a
minimum distance of twenty (20) feet along the east
side of Lot 76. The locations and heights of the
required sound walls are provided on Figure 1 of
Appendix F. Suitable construction materials include
concrete blocks, masonry, or stucco on both sides of
a wood or steel stud wall.

NOI-2: Mechanical ventilation or air conditioning shall be provided for all homes so that windows and doors
can remain closed for sound insulation purposes.

Project
Applicant
Planning and
Development
Department to review
construction
specifications to ensure
inclusion of provisions
included in mitigation
measure.

City of
Fresno,
Planning and
Development
Department
TRA-1: The proposed Project shall install traffic signal pole(s) less signal mast arms including all related pull boxes and conduit associated with said pole(s), as
necessary for a future four-leg intersection at
California Avenue and Armstrong Avenue.

Project
Applicant
Planning and
Development
Department to review
construction
specifications to ensure
inclusion of provisions
included in mitigation
measure.

City of
Fresno,
Planning and
Development
Department
TRA-2: The following measures shall be implemented
to ensure compliance with the Fresno Active
Transportation Plan:

Project
Applicant
Planning and
Development
Department to review
construction
specifications to ensure
City of
Fresno,
Planning and
Development
Department
Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
oThe Project shall construct a Class II Bikeway
on its frontages to Armstrong Avenue and
California Avenue.
oThe Project shall construct ADA compliant
pedestrian sidewalks along internal streets
connecting all uses to external sidewalks and
along its frontages to Armstrong Avenue and
California Avenue.
inclusion of provisions
included in mitigation
measure.

CARLSBAD
CLOVIS
IRVINE

LOS ANGELES

PALM SPRINGS

POINT RICHMOND

RIVERSIDE

ROSEVILLE

SAN LUIS OBISPO
2565 Alluvial Avenue, Suite 112, Clovis, California 93611 559.490.1210 www.lsa.net

MEMORANDUM
DATE: December 24, 2024
TO: Emily Bowen, Crawford & Bowen Planning, Inc.

FROM: Jessica Coria, Associate
SUBJECT: Air Quality, Energy, and Greenhouse Gas Emissions Technical Memorandum for the Proposed Aster Place Residential Development Project in Fresno, California

INTRODUCTION
LSA has prepared this Air Quality, Energy, and Greenhouse Gas Emissions Technical Memorandum to evaluate the impacts associated with construction and operation of the proposed Aster Place Residential Development Project (project) in Fresno, Fresno County, California. This analysis was prepared using methods and assumptions recommended in the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI).1 This analysis includes a description of the existing regulatory framework, an assessment of project construction and operation period emissions, and an assessment of greenhouse gas (GHG) emissions and energy impacts resulting from the proposed project.

PROJECT DESCRIPTION
The proposed project is located at East California Avenue and Armstrong Avenue in Fresno, Fresno County, California. The proposed project includes the development of a single-family residential project consisting of 203 units on approximately 38.76 acres, to be developed in two phases. The proposed project would include the development of 203 single-family residential lots, as well as the extension of East California Avenue through the proposed project site and the development of internal project roadways. Figure 1 shows the Project Location and Figure 2 shows the Project Site Plan (all figures are provided in Attachment A).

The site is bounded to the north by the San Joaquin Valley Railroad, to the west by a vacant lot, to the south by an orchard, and to the east by South Armstrong Avenue. Sensitive receptors near the proposed project site include single-family homes to the east of the project site, across South Armstrong Avenue, and to the north within 115 feet of the proposed project site boundaries. 1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. March 19. Website: www.valleyair.org/transportation/ceqa_idx.htm (accessed December 2024).
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2 The proposed project is expected to include demolition, site preparation, grading, building construction, paving, and architectural coating during construction phases and would include 11,310 cubic yards of soil import. Construction is expected to begin at the beginning of 2025 and last approximately 4 years. Moreover, the proposed project would generate approximately 1,914 average daily trips. In addition, consistent with SJVAPCD Rule 4901,2this analysis assumes that the proposed project would not include any wood burning (or natural gas) fireplaces.

SENSITIVE RECEPTORS IN THE PROJECT AREA
For this analysis, sensitive receptors are considered areas of the population that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools, daycare centers, hospitals, parks, and similar uses that are sensitive to air quality. Impacts on sensitive receptors are of particular concern because those receptors are the population most vulnerable to the effects of air pollution. The project site is surrounded primarily by residential, agricultural, and educational uses. The Sequoia Elementary School is approximately 3,100 feet from the proposed project site boundary, and the Sanger West High School is approximately 3,500 feet from the project boundary. The areas adjacent to the project site include the following:
• North: Residential, open space
• East: Residential, agricultural
• South: Agricultural, educational
• West: Residential, agricultural
The proposed project is bound by South Armstrong Avenue to the east, East Church Avenue to the south and South Fowler Avenue to the west. The closest sensitive receptors are single-family residential uses to the east, approximately 130 feet from the project boundary, and single-family residential uses to the west, approximately 925 feet from the project boundary. Table A shows the proposed project activity, the nearest sensitive receptor, and point of analysis in distance (feet).

Table A: Summary of Analysis Distances by Impact Category Activity Nearest Sensitive Receptor Points of Analysis Distance (feet)
Construction1 Single-family homes on
South Armstrong Avenue
Perimeter of construction activities to centroid of
nearest sensitive receptor
125
Operations Single-family homes on
South Armstrong Avenue
Emissions sources on-site generalized at the centroid
of the project site to centroid of nearest sensitive
receptor
770
Source: Compiled by LSA (2024).
1 Distance for construction air quality impact potential includes the assumption that heavy construction equipment would operate adjacent to the proposed project boundary, which is 30 feet from the nearest off-site structures where a person would live. 2 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
3 EXISTING LAND USES IN THE PROJECT AREA
The existing land use for the proposed project site is medium-density residential. Currently, the existing zoning is medium-density residential per the City of Fresno (City). Therefore, the proposed project would be consistent with current zoning and land uses.

Current transportation ingress and egress access points for the proposed project are from South Armstrong Avenue. Erin Avenue will be expanded along the northern project boundary, East Geary will be expanded to the west and south of the project boundaries, and East California Avenue will be expanded through the center of the proposed project. The expansion of these arterial ways will support circulation for the proposed project.

Air Quality Background
Air quality is primarily a function of local climate, local sources of air pollution, and regional pollution transport. The amount of a given pollutant in the atmosphere is determined by the amount of the pollutant released and the atmosphere’s ability to transport and dilute the pollutant.

The major determinants of transport and dilution are wind, atmospheric stability, terrain and, for photochemical pollutants, sunshine.

A region’s topographic features have a direct correlation with air pollution flow and therefore are used to determine the boundary of air basins. The proposed project is in Fresno County and is within the jurisdiction of the SJVAPCD, which regulates air quality in the San Joaquin Valley Air Basin (SJVAB).

The SJVAB is comprised of approximately 25,000 square miles and covers all of seven counties (including Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare) and the western portion of an eighth, Kern. The SJVAB is defined by the Sierra Nevada mountains in the east (8,000 to 14,000 feet in elevation), the Coast Ranges in the west (averaging 3,000 feet in elevation), and the Tehachapi mountains in the south (6,000 to 8,000 feet in elevation). The valley is topographically flat with a slight downward gradient to the northwest. The valley opens to the sea at the Carquinez Straits where the San Joaquin-Sacramento Delta empties into San Francisco Bay. An aerial view of the SJVAB would simulate a “bowl” opening only to the north. These topographic features restrict air movement through and out of the basin.

Both the State and federal government have established health-based ambient air quality standards for six criteria air pollutants: carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter (particulate matter less than 2.5 microns in diameter [PM2.5] and particulate matter less than 10 microns in diameter [PM10]). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles.

These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Two criteria pollutants, O3 and NO2, are considered regional pollutants because they (or their precursors) affect air quality on a regional scale. Pollutants such as CO, SO2, and Pb are considered local pollutants that tend to accumulate in the air locally.

Air quality monitoring stations are located throughout the nation and are maintained by the local air districts and State air quality regulating agencies. Data collected at permanent monitoring stations 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
4 are used by the United States Environmental Protection Agency (USEPA) to identify regions as “attainment” or “nonattainment” depending on whether the regions meet the requirements stated in the applicable National Ambient Air Quality Standards (NAAQS). Nonattainment areas are imposed with additional restrictions as required by the USEPA. In addition, different classifications of attainment (e.g., marginal, moderate, serious, severe, and extreme) are used to classify each air basin in the State on a pollutant-by-pollutant basis. The classifications are used as a foundation to create air quality management strategies to improve air quality and to comply with the NAAQS. As shown in Table B, the SJVAB is designated as nonattainment by federal standards for O3 and PM2.5 and nonattainment by State standards for O3, PM10, and PM2.5.

Table B: Attainment Status of Criteria Pollutants in the San Joaquin Valley Air Basin Pollutant State Federal
Ozone (1-hour) Revoked Nonattainment/Severe
Ozone (8-hour) Nonattainment/Extreme Nonattainment
PM10 Attainment Nonattainment
PM2.5 Nonattainment Nonattainment
Carbon Monoxide Attainment/Unclassified Attainment/Unclassified Nitrogen Dioxide Attainment/Unclassified Attainment
Lead No Designation/Classification Attainment
Sulfur Dioxide Attainment/Unclassified Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Source: San Joaquin Valley Air Pollution Control District (2024).

PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter Ozone levels, as measured by peak concentrations and the number of days over the State 1-hour standard, have declined substantially as a result of aggressive programs by the SJVAPCD and other regional, State, and federal agencies. The reduction of peak concentrations represents progress in improving public health; however, the SJVAPCD still exceeds the State standard for 1-hour and 8-hour O3 levels. In addition, the SJVAB was designated as a serious nonattainment area for the federal 1997 8-hour ozone level in June 2004. The USEPA lowered the 1997 0.80 parts per million (ppm) federal 8-hour ozone standard to 0.75 ppm in 2008 and then to 0.70 ppm on October 1, 2015.

The SJVAB is classified as nonattainment for the 1-hour and 8-hour ozone standards at the State and federal levels, although a request for redesignation as attainment of the 1-hour ozone standard was submitted to the USEPA in 2014.

Federal and State standards have also been established for PM2.5 over 24-hour and yearly averaging periods. PM2.5, because of the small size of individual particles, can be especially harmful to human health. PM2.5 is emitted by common combustion sources such as cars, trucks, buses, and power plants, in addition to ground-disturbing activities. On February 7, 2024, the USEPA strengthened the NAAQS for PM2.5 by revising the primary (health-based) annual standard from 12.0 micrograms per cubic meter (µg/m3) to 9.0 µg/m3; however, a new attainment designation has not been issued. The SJVAB is considered a nonattainment area for the PM2.5 standard at the State and federal levels. 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
5 The SJVAPCD is classified as a PM10 nonattainment area at the State level and was redesignated from serious nonattainment to attainment of the federal PM10 standard in 2008. Because the SJVAPCD was redesignated from nonattainment to attainment, a PM10 maintenance plan was adopted in 2007 and is required to be updated every 10 years.

No exceedances of the State or federal CO standards have been recorded at any of the region’s monitoring stations since 1991. The SJVAB is currently considered an attainment area for State and federal 8-hour and 1-hour CO standards.

Toxic Air Contaminant Background
The public’s exposure to toxic air contaminants (TACs) is a significant environmental health issue in the State of California. In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. Health and Safety Code Section 39655 defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” A substance that is listed as a hazardous air pollutant pursuant to Subsection (b) of United States Code [USC] Title 42, Section 7412, is a TAC. Under State law, the California Environmental Protection Agency (CalEPA), acting through the California Air Resources Board (CARB), is authorized to identify a substance as a TAC if it determines the substance is an air pollutant that may cause or contribute to an increase in mortality or an increase in serious illness, or that may pose a present or potential hazard to human health.

California regulates TACs primarily through Assembly Bill (AB) 1807 (the Tanner Air Toxics Act), AB 2588 (the Air Toxics “Hot Spot” Information and Assessment Act of 1987), and Senate Bill (SB) 25 (the Children’s Environmental Health Protection Act). The Tanner Air Toxics Act sets forth a formal procedure for CARB to designate substances as TACs. Once TACs are identified, CARB adopts an “airborne toxics control measure” for sources that emit designated TACs. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology (T-BACT) to minimize emissions.

Air toxics from stationary sources are also regulated in California under AB 2588 (the Air Toxics “Hot Spot” Information and Assessment Act of 1987). Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the designated air quality management district or air pollution control district. High-priority facilities are required to perform a Health Risk Assessment (HRA) and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings.

To date, CARB has designated nearly 200 compounds as TACs. Additionally, CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from TACs can be attributed to relatively few compounds, the most important being particulate matter from diesel-fueled engines (i.e., diesel particulate matter [DPM]).
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6 Air Quality Monitoring Results
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution control district and State air quality regulating agencies. The SJVAPCD, together with the CARB, maintains ambient air quality monitoring stations in the SJVAB. The air quality monitoring stations closest to the project area are Fresno Drummond Street station located at 4706 East Drummond Street, Fresno, Fresno County, California, and the Fresno Garland station located at 3727 North First Street, Fresno, Fresno County, California.

Pollutant monitoring results for years 2021 to 2023 at the nearby ambient air quality monitoring stations, shown in Table C, indicate that air quality in the area has generally been moderate. As indicated in the monitoring results, the State PM10 standard was exceeded 20 times in 2021, 133 times in 2022, and 120 times in 2023. In addition, the federal PM10 standard was not exceeded in the 3-year period. The federal PM2.5 standard had 30 exceedances in 2021, 12 exceedances in 2022, and 4 exceedances in 2023. The State 1-hour ozone standard was exceeded 9 times in 2021 and 3 times in 2022 and 2023. The State 8-hour ozone standard was exceeded 41 times in 2021, 8 times in 2022, and 24 times in 2023. The federal 8-hour ozone standard was exceeded 39 times in 2021, 8 times in 2022, and 20 times in 2023. The federal CO maximum 1-hour and federal CO maximum 8- hour standards was not exceeded in the 3-year period with no available State data. The federal SO2 standard was not exceeded between 2021 and 2023. The State SO2 standard had an unknown number of exceedances for the 3-year period. The State NO2 maximum 1-hour standard had no exceedances for the 3-year period.

Table C: Ambient Air Quality Monitored in the Project Vicinity Pollutant Standard 2021 2022 2023
Carbon Monoxide (CO) 1
Maximum 1-hr concentration (ppm) 1.9 2.1 2.2
Number of days exceeded: State: > 20 ppm ND ND ND
Federal: > 35 ppm 0 0 0
Maximum 8-hr concentration (ppm) 1.7 1.8 1.7
Number of days exceeded: State: ≥ 9.0 ppm ND ND ND
Federal: ≥ 9.0 ppm 0 0 0
Ozone (O3)
2 Maximum 1-hr concentration (ppm) 0.125 0.111 0.102
Number of days exceeded: State: > 0.09 ppm 9 3 3
Maximum 8-hr concentration (ppm) 0.099 0.089 0.088
Number of days exceeded: State: > 0.070 ppm 41 8 24
Federal: > 0.070 ppm 39 8 20
Coarse Particulates (PM10)
2 Maximum 24-hr concentration (µg/m3) 151.8 73.4 131.1
Number of days exceeded: State: > 50 µg/m3 20 133 120
Federal: > 150 µg/m3 0 0 0
Annual arithmetic average concentration (µg/m3) 43.8 31.2 42.7 Exceeded for the year: State: > 20 µg/m3 Yes Yes Yes
Federal: > 50 µg/m3 No No No
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7 Table C: Ambient Air Quality Monitored in the Project Vicinity Pollutant Standard 2021 2022 2023
Fine Particulates (PM2.5)
1 Maximum 24-hr concentration (µg/m3) 99.9 53.3 39.1
Number of days exceeded: Federal: > 35 µg/m3 30 12 4
Annual arithmetic average concentration (µg/m3) 15.6 12.9 10.4 Exceeded for the year: State: > 12 µg/m3 Yes Yes No
Federal: > 15 µg/m3 Yes No No
Nitrogen Dioxide (NO2)
2 Maximum 1-hr concentration (ppm) 0.0645 0.0583 0.0581 Number of days exceeded: State: > 0.18 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.011 0.012 0.010 Exceeded for the year: State: > 0.030 ppm No No No
Federal: > 0.053 ppm No No No
Sulfur Dioxide (SO2)
1 Maximum 24-hr concentration (ppm) 0.0027 0.0012 0.0023 Number of days exceeded: State: > 0.04 ppm ND ND ND
Federal: > 0.14 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.00043 0.00034 0.00043 Exceeded for the year: Federal: > 0.030 ppm No No No
Sources: 2021–2023 Air Quality Data, Website: www.epa.gov/outdoor-air-quality-data/monitor-values-report (United States Environmental Protection Agency 2024) and iADAM: Air Quality Data Statistics, Website: www.arb.ca.gov/adam/index.html (California Air Resources Board 2024).
1 Data taken from the Fresno Garland station located at 3727 North First Street, Fresno, Fresno County, California. 2 Data take from the Fresno Drummond Street station located at 4706 East Drummond Street, Fresno, Fresno County, California. µg/m3 = micrograms per cubic meter
hr = hour
ND = no data available
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size ppm = parts per million
Energy
Electricity
Electricity is a manmade resource. The production of electricity requires the consumption or conversion of energy resources (including water, wind, oil, gas, coal, solar, geothermal, and nuclear resources) into energy. Electricity is used for a variety of purposes (e.g., lighting, heating, cooling, and refrigeration, and for operating appliances, computers, electronics, machinery, and public transportation systems).

According to the most recent data available, in 2022, California’s electricity was generated primarily by natural gas (47.5 percent), renewable sources (52.2 percent), large hydroelectric (7.2 percent), nuclear (8.7 percent), coal (<1.0 percent), and other unspecified sources. Total electric generation in California in 2022 was 287,220 gigawatt-hours (GWh), up 3.4 percent from the 2021 total generation of 287,220 GWh.3
3 California Energy Commission (CEC). 2022. 2022 Total System Electric Generation. Website: https://www. energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2022-total-system-electricgeneration (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
8 The project site receives its electricity from Pacific Gas and Electric (PG&E). According to the California Energy Commission (CEC), total electricity consumption in the PG&E service area in 2022 was 77,887.0 GWh (27,210.0 GWh for the residential sector and 50,677.0 GWh for the nonresidential sector).4 Total electricity consumption in Fresno County in 2022 was 8,384.4 GWh (or 8,384,408,687 kilowatt-hours [kWh]).5
Natural Gas
Natural gas is a nonrenewable fossil fuel. Fossil fuels are formed when layers of decomposing plant and animal matter are exposed to intense heat and pressure under the surface of the Earth over millions of years. Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas is found in naturally occurring reservoirs in deep underground rock formations. Natural gas is used for a variety of uses (e.g., heating buildings, generating electricity, and powering appliances such as stoves, washing machines and dryers, gas fireplaces, and gas grills).

Natural gas consumed in California is used for electricity generation (45 percent), residential uses (21 percent), industrial uses (25 percent), and commercial uses (9 percent). California continues to depend on out-of-state imports for nearly 90 percent of its natural gas supply.6 PG&E is the natural gas service provider for the project site. According to the CEC, total natural gas consumption in the PG&E service area in 2022 was 4,421.06 million therms (1,856.1 million therms for the residential sector and 2,564.9 million therms for the nonresidential sector).7 Total natural gas consumption in Fresno County in 2022 was 319.4 million therms (319,435,645 therms).8 Fuel
Petroleum is also a nonrenewable fossil fuel. Petroleum is a thick, flammable, yellow-to-black mixture of gaseous, liquid, and solid hydrocarbons that occurs naturally beneath the Earth’s surface.

Petroleum is primarily recovered by oil drilling. It is refined into a large number of consumer products, primarily fuel oil, gasoline, and diesel.

The average fuel economy for light‐duty vehicles (autos, pickups, vans, and sport utility vehicles [SUVs]) in the United States has steadily increased from about 14.9 miles per gallon (mpg) in 1980 to 4 CEC. 2021a. Electricity Consumption by Entity. Website: http://www.ecdms.energy.ca.gov/elecbyutil.aspx (accessed November 2024).
5 CEC. 2020a. Electricity Consumption by County. Websites: http://www.ecdms.energy.ca.gov/ elecbycounty.aspx and http://www.ecdms.energy.ca.gov/elecbyutil.aspx (accessed November 2024). 6 CEC. 2021c. Supply and Demand of Natural Gas in California. Website: https://www.energy.ca.gov/datareports/energy-almanac/californias-natural-gas-market/supply-and-demand-natural-gas-california (accessed November 2024).
7 CEC. 2021b. Gas Consumption by Entity. Website: http://www.ecdms.energy.ca.gov/gasbyutil.aspx (accessed November 2024).
8 CEC. 2020b. Gas Consumption by County and Entity. Website: http://www.ecdms.energy.ca.gov/gasby county.aspx and http://www.ecdms.energy.ca.gov/gasbyutil.aspx (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
9 22.9 mpg in 2021.9Federal fuel economy standards have changed substantially since the Energy Independence and Security Act was passed in 2007. This act, which originally mandated a federal fuel economy standard of 35 mpg by year 2020,
10 applies to cars and light trucks of Model Years
2011 through 2020. In March 2020, the USEPA and National Highway Traffic Safety Administration (NHTSA) finalized the Corporate Average Fuel Economy standards for Model Years 2024–2026 Passenger Cars and Light Trucks, further detailed below.

Gasoline is the most-used transportation fuel in California, with 97 percent of all gasoline being consumed by light-duty cars, pickup trucks, and SUVs. According to the most recent data available, in 2022, total gasoline consumption in California was 316,425 thousand barrels or 1,597.6 trillion British Thermal Units (BTU).11 Of the total gasoline consumption, 299,304 thousand barrels or 1,511.2 trillion BTU were consumed for transportation.12 Based on fuel consumption obtained from CARB’s California Emissions Factor Model, Version 2021 (EMFAC2021), approximately 366.2 million gallons of gasoline and approximately 157.8 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2024.

Greenhouse Gas Background
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are:
• Carbon dioxide (CO2);
• Methane (CH4);
• Nitrous oxide (N2O);
• Hydrofluorocarbons (HFCs);
• Perfluorocarbons (PFCs); and
• Sulfur hexafluoride (SF6).

Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally occurring GHGs (e.g., CO2, CH4, and N2O), some gases (e.g., HFCs, PFCs, and SF6) are completely new to the atmosphere.
9 United States Department of Transportation (USDOT). n.d. Table 4‐23: Average Fuel Efficiency of U.S. Light Duty Vehicles. Website: https://www.bts.dot.gov/bts/bts/content/average-fuel-efficiency-us-light-dutyvehicles (accessed November 2024). 10 United States Department of Energy. 2007. Energy Independence & Security Act of 2007. Website:
https://www.afdc.energy.gov/laws/eisa (accessed November 2024). 11 United States Energy Information Administration (EIA). 2022. California State Profile and Energy Estimates, Data. Website: www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_ mg.html&sid=CA (accessed November 2024).
12 Ibid.
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10 Certain gases (e.g., water vapor) are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.

These gases vary considerably in terms of global warming potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to CO2, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of CO2 equivalents (CO2e).

REGULATORY FRAMEWORK
This section provides regulatory background information for air quality, GHGs, and energy.

Air Quality
Federal Regulations
The 1970 federal Clean Air Act (CAA) authorized the establishment of national health-based air quality standards and set deadlines for their attainment. The CAA Amendments of 1990 changed deadlines for attaining national standards as well as the remedial actions required for areas of the nation that exceed the standards. Under the CAA, State and local agencies in areas that exceed the national standards are required to develop State Implementation Plans to demonstrate how they will achieve the national standards by specified dates.

State Regulations
In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain California Ambient Air Quality Standards (CAAQS) for CO, O3, SO2, and NO2 by the earliest practical date. The CCAA provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in districtwide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.

The CARB is the State’s “clean air agency.” The CARB’s goals are to attain and maintain healthy air quality, protect the public from exposure to toxic air contaminants, and oversee compliance with air pollution rules and regulations.
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11 Regional Regulations
San Joaquin Valley Air Pollution Control District. The SJVAPCD has specific air quality-related planning documents, rules, and regulations.13 This section summarizes the local planning documents and regulations that may be applicable to the proposed project as administered by the SJVAPCD with CARB oversight.
• Rule 8011—General Requirements: Fugitive Dust Emission Sources. Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, including construction operations, must control fugitive dust emissions in accordance with SJVAPCD Regulation VIII. According to Rule 8011, the SJVAPCD requires the implementation of control measures for fugitive dust emission sources.
• Regulation VIII—Fugitive PM10 Prohibitions. Rules 8011–8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, and carryout and track out. All development projects that involve soil disturbance are subject to at least one provision of the Regulation VIII series of rules. • Rule 2201—New and Modified Stationary Source Review Rule. This rule provides the review of new and modified stationary sources of air pollution to operate without interfering with the attainment or maintenance of ambient air quality standards and results in no net increase in emissions above specified thresholds.
• Rule 4901—Wood Burning Fireplaces and Wood Burning Heaters. The purpose of this rule is to limit emissions of carbon monoxide and particulate matter from wood burning fireplaces, wood burning heaters, and outdoor wood burning devices.
• Rule 9510—Indirect Source Review. This rule reduces the impact of nitrogen oxides (NOx) and PM10 emissions from new development projects. The rule places application and emission reduction requirements on development projects meeting applicability criteria in order to reduce emissions through on-site mitigation, off-site SJVAPCD‐administered projects, or a combination of the two. Compliance with SJVAPCD Rule 9510 reduces emissions impacts through incorporation of on-site measures as well as payment of an off-site fee that funds emission reduction projects in the SJVAB. The emissions analysis for Rule 9510 is detailed and is dependent on the exact project design that is expected to be constructed or installed.

Compliance with Rule 9510 is separate from the California Environmental Quality Act (CEQA) process, though the control measures used to comply with Rule 9510 may be used to mitigate significant air quality impacts.

Guidance for Assessing and Mitigating Air Quality Impacts. The SJVAPCD prepared the GAMAQI to assist lead agencies and project applicants in evaluating the potential air quality impacts of projects in the SJVAB. The GAMAQI provides SJVAPCD-recommended procedures for evaluating potential air 13 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
12 quality impacts during the CEQA environmental review process. The GAMAQI provides guidance on evaluating short-term (construction) and long-term (operational) air emissions. The most recent version of the GAMAQI, adopted on March 19, 2015, was used in this evaluation. It contains guidance on the following:
• Criteria and thresholds for determining whether a project may have a significant adverse air quality impact
• Specific procedures and modeling protocols for quantifying and analyzing air quality impacts • Methods to mitigate air quality impacts
• Information for use in air quality assessments and environmental documents, including air quality, regulatory setting, climate, and topography data Fresno Council of Governments. Fresno Council of Governments (Fresno COG) is responsible for regional transportation planning in Fresno County and participates in developing mobile source emission inventories used in air quality attainment plans.

Regional Transportation Plan/Sustainable Communities Strategy. Regional Transportation Plans (RTPs) are State-mandated plans that identify long-term transportation needs for a region’s transportation network. Fresno COG’s 2022 RTP charts the long‐range vision of regional transportation in Fresno County through 2046.14 The RTP identifies existing and future transportation-related needs, while considering all modes of travel, analyzing alternative solutions, and identifying priorities for the anticipated available funding for the 1,100 projects and multiple programs included within the RTP. SB 375, which went into effect in 2009, added statutes to the California Government Code to encourage planning practices that create sustainable communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every 4 years. The SCS is intended to show how integrated land use and transportation planning can lead to lower GHG emissions from automobiles and light trucks. Fresno COG has included the SCS in its 2022 RTP.

Local Regulations
City of Fresno General Plan. The City’s General Plan Resources Conservation and Resilience Element includes objectives and policies that work to achieve and maintain compliance with State and 14 Fresno Council of Governments (Fresno COG). 2022. Regional Transportation Plan and Sustainable Communities Strategy. Website: https://www.fresnocog.org/project/regional-transportation-plan/ (accessed November 2024).
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13 federal air quality standards for criteria pollutants.15 The following policies related to air quality are applicable to the proposed project:
• Policy RC-4-a: Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and mobile sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan. • Policy RC-4-b-: Conditions of Approval. Develop and incorporate air quality maintenance requirements, compatible with Air Quality Attainment and Maintenance Plans, as conditions of approval for General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals
• Policy RC-4-c: Evaluate Impacts with Models. Continue to require the use of computer models used by SJVAPCD to evaluate the air quality impacts of plans and projects that require such environmental review by the City.
• Policy RC-4-d: Forward Information. Forward information regarding proposed General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals that require air quality evaluation, and amendments to development regulations to the SJVAPCD for their review of potential air quality and health impacts. • Policy RC-4-e: Ensure Compliance. Ensure ongoing compliance with GHG emissions reduction plans and programs by requiring that air quality measures are incorporated into projects’ design, conditions of approval, and mitigation measures.

Energy
Federal and State agencies regulate energy use and consumption through various means and programs. On the federal level, the United States Department of Transportation (USDOT), the United States Department of Energy, and the USEPA are three federal agencies with substantial influence over energy policies and programs. Generally, federal agencies influence and regulate transportation energy consumption through establishment and enforcement of fuel economy standards for automobiles and light trucks, through funding of energy-related research and development projects, and through funding for transportation infrastructure improvements. On the State level, the California Public Utilities Commission (CPUC) and the CEC are two agencies with authority over different aspects of energy.

The CPUC regulates privately owned electric, natural gas, telecommunications, water, railroad, rail transit, and passenger transportation companies and serves the public interest by protecting consumers and ensuring the provision of safe, reliable utility service and infrastructure at 15 City of Fresno. 2014. Fresno General Plan. December 18. Website: https://www.fresno.gov/wp-content/ uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf (accessed November 2024).
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14 reasonable rates, with a commitment to environmental enhancement and a healthy California economy.

The CEC is the State’s primary energy policy and planning agency. The CEC forecasts future energy needs, promotes energy efficiency, supports energy research, develops renewable energy resources, and plans for/directs State response to energy emergencies. The applicable federal, State, regional, and local regulatory framework is discussed below.

Federal Regulations
Energy Policy Act of 2005. The Energy Policy Act of 2005 seeks to reduce reliance on nonrenewable energy resources and provide incentives to reduce current demand on these resources. For example, under this Act, consumers and businesses can obtain federal tax credits for purchasing fuel-efficient appliances and products (including hybrid vehicles), building energy-efficient buildings, and improving the energy efficiency of commercial buildings. Additionally, tax credits are available for the installation of qualified fuel cells, stationary microturbine power plants, and solar power equipment.

Corporate Average Fuel Economy Standards. On March 31, 2022, the NHTSA finalized the Corporate Average Fuel Economy (CAFE) standards for Model Years 2024–2026 Passenger Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024 to 2025, and 10 percent annually for model year 2026. The final standards are estimated to save about 234 billion gallons of gasoline between model years 2030 to 2050.

State Regulations
Assembly Bill 1575, Warren-Alquist Act. In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted AB 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of the CEC is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger; develop energy technologies and renewable energy resources; plan for and direct State responses to energy emergencies; and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code (PRC) Section 21100(b)(3) and State CEQA Guidelines Section 15126.4 to require Environmental Impact Reports (EIRs) to include, where relevant, mitigation measures proposed to minimize the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created Appendix F to the State CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy and the means of achieving this goal, including (1) decreasing overall per capita energy consumption; (2) decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3) increasing reliance on renewable energy sources.

Senate Bill 1389, Energy: Planning and Forecasting. In 2002, the State Legislature passed SB 1389, which required the CEC to develop an integrated energy plan every 2 years for electricity, natural 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
15 gas, and transportation fuels for the California Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for zero emission vehicles (ZEVs) and their infrastructure needs, and encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate pedestrian and bicycle access.

In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report every 2 years and an update every other year. The most recently adopted report includes the 2023 Integrated Energy Policy Report.16 The Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecast, and the California Energy Demand Forecast. The Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs.

Renewable Portfolio Standard. SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially required that 20 percent of electricity retail sales be served by renewable resources by 2017; however, this standard has become more stringent over time. In 2006, SB 107 accelerated the standard by requiring that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that 33 percent of electricity retail sales be served by renewable resources by 2020. In 2015, SB 350 established tiered increases to the Renewable Portfolio Standards of 40 percent by 2024, 45 percent by 2027, and 50 percent by 2030. In 2018, SB 100 increased the requirement to 60 percent by 2030 and required that all the State’s electricity come from carbonfree resources by 2045. SB 100 took effect on January 1, 2019.17 California Energy Code. Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards in Part 6 of Title 24 of the California Code of Regulations (CCR), known as the Energy Code. The CEC first adopted the Building Energy Efficiency Standards for Residential and Non-residential Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The Energy Code is updated every 3 years, with the most recent update consisting of the 2022 Energy Code that became effective January 1, 2023. Mid-cycle supplements to the 2022 Code will become effective on July 1, 2024. The efficiency standards apply to both new construction and rehabilitation of both residential and nonresidential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting. The building efficiency standards are enforced through the local building permit process. Local government 16 CEC. 2023. 2023 Integrated Energy Policy Report. California Energy Commission. Docket Number: 23-IEPR01. 17 California Public Utilities Commission (CPUC). 2019. Renewables Portfolio Standard Program. Website:
cpuc.ca.gov/rps (accessed December 2024).
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16 agencies may adopt and enforce energy standards for new buildings, provided these standards meet or exceed those provided in the Energy Code.

California Green Building Standards Code (CALGreen Code). In 2010, the California Building Standards Commission (CBSC) adopted Part 11 of the Title 24 Building Energy Efficiency Standards, referred to as the CALGreen Code. The CALGreen Code took effect on January 1, 2011. The CALGreen Code is updated on a regular basis, with the most recent update consisting of the 2022 CALGreen Code standards that became effective January 1, 2023. The CALGreen Code established mandatory measures for residential and nonresidential building construction and encouraged sustainable construction practices in the following five categories: (1) planning and design, (2) energy efficiency, (3) water efficiency and conservation, (4) material conservation and resource efficiency, and (5) indoor environmental quality. Although the CALGreen Code was adopted as part of the State’s efforts to reduce GHG emissions, the CALGreen Code standards have co-benefits of reducing energy consumption from residential and nonresidential buildings subject to the standard.

California Energy Efficiency Strategic Plan. On September 18, 2008, the CPUC adopted California’s first Long-Term Energy Efficiency Strategic Plan, presenting a roadmap for energy efficiency in California. The Strategic Plan was updated in 2011. The Plan articulates a long-term vision and goals for each economic sector and identifies specific near-term, mid-term, and long-term strategies to assist in achieving those goals. The Plan also reiterates the following four specific programmatic goals known as the “Big Bold Energy Efficiency Strategies” that were established by the CPUC in Decisions D.07-10-032 and D.07-12-051:
• All new residential construction will be zero net energy (ZNE) by 2020. • All new commercial construction will be ZNE by 2030.
• 50 percent of commercial buildings will be retrofitted to ZNE by 2030. • 50 percent of new major renovations of State buildings will be ZNE by 2025.

Local Regulations
City of Fresno General Plan. The City of Fresno’s General Plan18 Resource and Conservation Element includes objectives and policies that work to reduce the consumption of non-renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources. The following policies related to energy are applicable to the proposed project:Policy RC8- a: Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations. • Policy RC8-b: Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 KWh per year and non-residential electricity use to 2,700 KWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost-effective savings.
18 City of Fresno. 2014. Fresno General Plan. December 18. Website: https://www.fresno.gov/wp-content/ uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf (accessed November 2024).
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17 • Policy RC-8-c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by 15 percent. • Policy RC-8-d: Incentives. Establish an incentive program for residential developers who commit to building all of their homes to ENERGY STAR performance guidelines. • Policy RC8-i: Renewable Target. Adopt and implement a program to increase the use of renewable energy to meet a given percentage of the city’s peak electrical load within a given time frame.
• Policy RC8-j: Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

Greenhouse Gas Emissions
This section describes regulations related to global climate change at the federal, State, and local level.

Federal Regulations
The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to regulate CO2 emissions under the CAA.

While there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change, including the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the CAA, finding that seven GHGs (CO2, CH4, N2O, HFCs, NF3, PFCs, and SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to federal GHG emission standards.

State Regulations
The CARB is the lead agency for implementing climate change regulations in the State. Since its formation, the CARB has worked with the public, the business sector, and local governments to find solutions to California’s air pollution problems. Key efforts by the State are described below.

Assembly Bill 32 (2006), California Global Warming Solutions Act. California’s major initiative for reducing GHG emissions is AB 32, passed by the State legislature on August 31, 2006. This effort set a GHG emission reduction target to reduce GHG emissions to 1990 levels by 2020. The CARB has established the level of GHG emissions in 1990 at 427 million metric tons (MMT) CO2e. The emissions target of 427 MMT CO2e requires the reduction of 169 MMT from the State’s projected business-as-usual 2020 emissions of 596 MMT. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
18 contribute to global climate change. The CARB approved the Scoping Plan on December 11, 2008. It contains the main strategies California will implement to achieve the reduction of approximately 169 MMT CO2e, or approximately 30 percent, from the State’s projected 2020 emission level of 596 MMT CO2e under a business-as-usual scenario (this is a reduction of 42 MMT CO2e, or almost 10 percent from 2002–2004 average emissions). The Scoping Plan also includes CARB-recommended GHG reductions for each emissions sector of the State’s GHG inventory. The Scoping Plan calls for the largest reductions in GHG emissions to be achieved by implementing the following measures and standards:
• Improved emissions standards for light-duty vehicles (estimated reduction of 31.7 MMT CO2e); • The Low-Carbon Fuel Standard (15.0 MMT CO2e);
• Energy efficiency measures in buildings and appliances and the widespread development of combined heat and power systems (26.3 MMT CO2e); and
• A renewable portfolio standard for electricity production (21.3 MMT CO2e).

The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020 and sets the groundwork to reach long-term goals set forth in Executive Orders (EOs) S-3-05 and B-16-2012. The Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use. The CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,19 to reflect the 2030 target set by EO B-30-15 and codified by SB 32.

The 2022 Scoping Plan20 was approved in December 2022 and assesses progress towards achieving the SB 32 2030 target and lay out a path to achieve carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

Senate Bill 375 (2008). Signed into law on October 1, 2008, SB 375 supplements GHG reductions from new vehicle technology and fuel standards with reductions from more efficient land use patterns and improved transportation. Under the law, the CARB approved GHG reduction targets in February 2011 for California’s 18 federally designated regional planning bodies, known as Metropolitan Planning Organizations (MPOs). The CARB may update the targets every 4 years and 19 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. Website: ww2.arb.ca.gov/sites/ default/files/classic/cc/scopingplan/scoping_plan_2017.pdf (accessed December 2024). 20 CARB. 2022. 2022 Scoping Plan Update. Website: https://ww2.arb.ca.gov/sites/default/files/2022- 12/2022-sp.pdf (accessed December 2024).
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19 must update them every 8 years. MPOs, in turn, must demonstrate how their plans, policies, and transportation investments meet the targets set by the CARB through SCSs. The SCSs are included with the Regional Transportation Plan, a report required by State law. However, if an MPO finds that its SCS will not meet the GHG reduction target, it may prepare an Alternative Planning Strategy (APS). The APS identifies the impediments to achieving the targets.

Executive Order B-30-15 (2015). Governor Jerry Brown signed EO B-30-15 on April 29, 2015, which added the immediate target of:
• GHG emissions should be reduced to 40 percent below 1990 levels by 2030.

All State agencies with jurisdiction over sources of GHG emissions were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. The CARB was directed to update the AB 32 Scoping Plan to reflect the 2030 target, and, therefore, is moving forward with the update process. The mid-term target is critical to help frame the suite of policy measures, regulations, planning efforts, and investments in clean technologies and infrastructure needed to continue reducing emissions.

Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act. SB 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030:
• Raise California’s renewable portfolio standard from 33 percent to 50 percent; and • Increase energy efficiency in buildings by 50 percent by the year 2030.

The 50 percent renewable energy standard will be implemented by the CPUC for the private utilities and by the CEC for municipal utilities. Each utility must submit a procurement plan showing it will purchase clean energy to displace other nonrenewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law. The addition made by this legislation requires State energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197. In summer 2016, the Legislature passed and the Governor signed SB 32 and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps California on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an Intergovernmental Panel on Climate Change analysis of the emission trajectory that would stabilize atmospheric GHG concentrations at 450 ppm CO2e and reduce the likelihood of catastrophic impacts from climate change.

The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
20 easier public access to air pollutant emissions data that are collected by the CARB was posted in December 2016.

Senate Bill 100. On September 10, 2018, Governor Brown signed SB 100, which raises California’s renewable portfolio standard requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a State policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all State agencies by December 31, 2045.

Under the bill, the State cannot increase carbon emissions elsewhere in the Western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.

Executive Order B-55-18. EO B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs the CARB to work with relevant State agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

Assembly Bill 1279. AB 1279 was signed in September of 2022 and codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative GHG emissions thereafter.

This bill also requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels by 2045 and directs CARB to work with relevant state agencies to achieve these goals.

Regional Regulations
San Joaquin Valley Air Pollution Control District. Fresno County is located within the SJVAB, which is under the jurisdiction of the SJVAPCD. The SJVAPCD has regulatory authority over certain stationary and industrial GHG emission sources and provides voluntary technical guidance on addressing GHGs for other emission sources in a CEQA context. SJVAPCD initiatives related to GHGs are described below:

Climate Change Action Plan. The San Joaquin Valley Air Pollution Control District Climate Change Action Plan (CCAP) was adopted on August 21, 2008. The CCAP includes suggested best performance standards (BPS) for proposed development projects. However, the SJVAPCD’s CCAP was adopted in 2009 and was prepared based on the State’s 2020 GHG targets, which are now superseded by State policies (i.e., the 2022 California Green Building Code) and the 2030 GHG targets, established in SB 32.

San Joaquin Valley Carbon Exchange and Rule 2301. The SJVAPCD initiated work on the San Joaquin Valley Carbon Exchange in November 2008. The Exchange was implemented with the adoption of Amendments to Rule 2301 Emission Reduction Credit Banking on January 19, 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
21 2012.21 The purpose of the carbon exchange is to quantify, verify, and track voluntary GHG emissions reductions generated within the San Joaquin Valley.

The SJVAPCD incorporated a method to register voluntary GHG emission reductions with amendments to Rule 2301. The purposes of the amendments to the rule include the following:
• Provide an administrative mechanism for sources to bank voluntary GHG emission reductions for later use
• Provide an administrative mechanism for sources to transfer banked GHG emission reductions to others for any use
• Define eligibility standards, quantitative procedures, and administrative practices to ensure that banked GHG emission reductions are real, permanent, quantifiable, surplus, and enforceable
The SJVAPCD is participating in a new program developed by the California Air Pollution Control Officers Association (CAPCOA) to encourage banking and use of GHG reduction credits referred to as the CAPCOA Greenhouse Gas Reduction Exchange (GHGRx). The GHGRx provides information on GHG credit projects within participating air districts. The SJVAPCD is one of the first districts to have offsets available for trading on the Exchange.

Local Regulations
City of Fresno General Plan. The City of Fresno’s General Plan22 Resources Conservation and Resilience Element includes objectives and policies that work to achieve and maintain reductions in GHG emissions and strategies that reduce the causes of climate change. The following policies related to GHG emissions from the General Plan would be applicable to the proposed project:
• Policy RC-5-a: Support State Goal to Reduce Statewide GHG Emissions. As is consistent with State law, strive to meet AB 32 goal to reduce greenhouse gas emissions to 1990 levels by 2020 and strive to meet a reduction of 80 percent below 1990 levels by 2050 as stated in Executive Order S-03-05. As new statewide GHG reduction targets and dates are set by the State update the City’s Greenhouse Gas Reduction Plan to include a comprehensive strategy to achieve consistency with those targets by the dates established. • Policy RC-5-b: Greenhouse Gas Reduction Plan. n. As is consistent with State law, prepare and adopt a Greenhouse Gas Reduction Plan as part of the Master Environmental Impact Report to be concurrently approved with the Fresno General Plan in order to achieve compliance with State mandates, assist development by streamlining the approval process, and focus on feasible 21 SJVPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 22 City of Fresno. 2014. Fresno General Plan. December 18. Website: https://www.fresno.gov/wp-content/ uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf (accessed November 2024).
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22 actions the City can take to minimize the adverse impacts of growth and development on global climate change
• Policy RC-5-c: GHG Reduction through Design and Operations. Increase efforts to incorporate requirements for GHG emission reductions in land use entitlement decisions, facility design, and operational measures subject to City regulation through the following measures and strategies:
○ Promote appropriate energy and water conservation standards and facilitate mixed-use projects, new incentives for infill development, and the incorporation of mass transit, bicycle and pedestrian amenities into public and private projects. ○ Require energy and water audits and upgrades for water conservation, energy efficiency, and mass transit, pedestrian, and bicycle amenities at the time of renovation, change in use, change in occupancy, and change in ownership for major projects meeting review thresholds specified in an implementing ordinance.
• Policy RC-5-d: SCS and CAP Conformity Analysis. Ensure that the City includes analysis of a project’s conformity to an adopted regional Sustainable Community Strategy or Alternative Planning Strategy (APS), an adopted Climate Action Plan (CAP), and any other applicable City and regional greenhouse gas reduction strategies in affect at the time of project review. • Policy RC-5-e: Ensure Compliance. Ensure ongoing compliance with GHG emissions reduction plans and programs by requiring that air quality measures are incorporated into projects’ design, conditions of approval, and mitigation measures. • Policy RC-5-g: Evaluate Impacts with Models. Continue to use computer models such as those used by SJVAPCD to evaluate greenhouse gas impacts of plans and projects that require such review.
• Policy RC 7-a: Water Conservation Program Target. Maintain a comprehensive conservation program to help reduce per capita water usage in the city’s water service area to 243 gallons per capita per day (gpcd) by 2020 and 190 gpcd by 2035, by adopting conservation standards and implementing a program of incentives, design and operation standards, and user fees. • Policy RC 7-h: Landscape Water Conservation Standards. Refine landscape water conservation standards that will apply to new development installed landscapes, building on the State Model Water Efficient Landscape Ordinance and other State regulations. • Policy RC 11-a: Waste Reduction Strategies. Maintain current targets for recycling and re-use of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
○ Continue to require recyclable material collection and storage areas in all residential development.
○ Expand yard waste collection to divert compostable waste from landfills. 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
23 METHODOLOGY
Construction Emissions
Construction activities can generate a substantial amount of air pollution. Construction activities are considered temporary; however, short-term impacts can contribute to exceedances of air quality standards. Construction activities include site preparation, earthmoving, and general construction.

The emissions generated from these common construction activities include fugitive dust from soil disturbance, fuel combustion from mobile heavy-duty diesel- and gasoline-powered equipment, portable auxiliary equipment, and worker commute trips.

The California Emissions Estimator Model (CalEEMod) Version 2022.1 computer program was used to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site. Construction of the proposed project is anticipated to begin in 2025 and would occur for approximately three years, which was included in CalEEMod. The proposed project would require the import of 11,310 cubic yards of soil, which was also included in CalEEMod. This analysis also assumes use of Tier 2 construction equipment. The proposed project would also comply with the SJVAPCD Regulations VIII measures for fugitive dust.23 Other detailed construction information is currently unavailable; therefore, this analysis utilizes CalEEMod default assumptions.

Construction Health Risk Assessment
A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed project, and the analysis is presented below. To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including DPM), a dispersion model was used to translate an emission rate from the source location to a concentration at the receptor location of interest (i.e., a nearby residence and worksites). Dispersion modeling varies from a simpler, more conservative screening-level analysis to a more complex and refined detailed analysis. This refined assessment was conducted using the CARB exposure methodology with the air dispersion modeling performed using the USEPA’s American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD). The model provides a detailed estimate of exhaust concentrations based on site and source geometry, source emissions strength, distance from the source to the receptor, and meteorological data.

Operational Emissions
The air quality analysis includes estimating emissions associated with long-term operation of the proposed project. Consistent with the SJVAPCD guidance for estimating emissions associated with land use development projects, the CalEEMod computer program was used to calculate the longterm operational emissions associated with the project.

As discussed previously in the Project Description section, the proposed project would include the construction of 203 single-family residential units and associated site improvements. The proposed project analysis was conducted using land use codes Single Family Housing and Recreational City 23 SJVPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
24 Park. Trip generation rates used in CalEEMod for the project were based on the traffic study conducted for the proposed project, which identifies that the proposed project would generate approximately 1,914 average daily trips.24 In addition, consistent with SJVAPCD Rule 4901,25 this analysis assumes that the proposed project would not include any wood burning (or natural gas) fireplaces. Where project-specific data were not available, default assumptions (e.g., energy usage, water usage, and solid waste generation) from CalEEMod were used to estimate project emissions.

CalEEMod output sheets are included in Attachment B.

Energy Use
The analysis focuses on the four sources of energy that are relevant to the proposed project: natural gas, electricity, the equipment fuel necessary for project construction, and vehicle fuel necessary for project operations. For the purposes of this analysis, the amounts of electricity, natural gas, construction fuel, and fuel use from operations are quantified and compared to that consumed in Fresno County. The electricity and natural gas uses of the proposed project are analyzed on an annual basis. Electricity and natural gas uses were estimated for the project using default energy intensities by land use type in CalEEMod.

Greenhouse Gas Emissions
GHG emissions associated with the project would occur over the short term from construction activities, consisting primarily of emissions from equipment exhaust. There would also be long-term GHG emissions associated with project-related area sources, energy consumption, water conveyance and treatment, and waste generation.

THRESHOLDS OF SIGNIFICANCE
Air Quality
The State CEQA Guidelines indicate that a project would normally have a significant adverse air quality impact if project-generated pollutant emissions would do any of the following:
• Conflict with or obstruct implementation of the applicable air quality plan; • Result in a cumulatively considerable net increase of any criteria pollutant for which the project is nonattainment under applicable federal or State ambient air quality standards; • Expose sensitive receptors to substantial pollutant concentrations; or • Result in other emissions (such as those leading to odors) affecting a substantial number of people.
24 Crawford & Bowen Planning, Inc. 2024. Fresno Residential Trip Generation. May. 25 SJVPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
25 Regional Emissions Thresholds
The SJVAPCD defines emissions thresholds in the GAMAQI, established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks. The related impacts are discussed further in the Project Impacts section. The SJVAPCD regional emission thresholds for construction and operation are shown in Table D.

Table D: Regional Thresholds for Construction and Operational Emissions Emissions Source Pollutant Emissions Threshold (Tons per Year) CO NOX ROG SOX PM10 PM2.5
Construction 100 10 10 27 15 15
Operations 100 10 10 27 15 15
Source: Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015).

CO = carbon monoxide
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
ROG = reactive organic gas
SJVAPCD = San Joaquin Valley Air Pollution Control District SOX = sulfur oxides
Local Microscale Concentration Standards
The significance of localized project impacts under CEQA depends on whether ambient CO levels in the vicinity of the project are above or below State and federal CO standards. Because ambient CO levels are below the standards throughout the SJVAB, a project would be considered to have a significant CO impact if project emissions result in an exceedance of one or more of the 1-hour or 8-hour standards. The following are applicable local emission concentration standards for CO:
• California State 1-hour CO standard of 20 ppm
• California State 8-hour CO standard of 9 ppm
Health Risk Thresholds
Both the State and federal governments have established health-based ambient air quality standards (AAQS) for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level.

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the SJVAB:
• MICR: MICR is the estimated probability of a maximum exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 70 years for adults and 9 years for children in residential locations, 350 days per year. The SJVAPCD’s Update to the District’s Risk 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
26 Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 20 in 1 million.26
• Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multipathway consideration when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location.
• Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

Energy
The State CEQA Guidelines indicate that a project would normally have a significant adverse impact related to energy if the project would:
• Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or • Conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

Greenhouse Gas Thresholds
The State CEQA Guidelines indicate that a project would normally have a significant adverse greenhouse gas emission impact if the project would:
• Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

Section 15064.4 of the State CEQA Guidelines states that: “A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project.” In performing that analysis, the lead agency has discretion to determine whether to use a model or methodology to quantify GHG emissions or to rely on a qualitative analysis or performance-based standards. In making a determination as to the significance of potential impacts, the lead agency then considers the extent to which the project may increase or reduce GHG emissions as compared to the existing 26 SJVAPCD. 2020. Update to the District’s Risk Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document. Website: https://ww2.valleyair.org/media/0shm0mlk/apr1906.pdf#RiskManagement (accessed December 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
27 environmental setting, whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

In the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed project for consistency with the Bay Area Air Quality Management District (BAAQMD) Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (Justification Report).27
In April 2022, the BAAQMD adopted the Justification Report28 document, which identifies applicable GHG significance thresholds. These thresholds establish whether a project would be consistent with California’s efforts to meet long-term climate goals, including achieving carbon neutrality by 2045. If a project is designed and built to incorporate design elements related to natural gas, energy, VMT, and EVs, then it would contribute its portion of what is necessary to achieve California’s long-term climate goals—its “fair share”—and an agency reviewing the project under CEQA can conclude that the project would not make a cumulatively considerable contribution to global climate change.

The Justification Report provides substantial evidence supporting the use of their thresholds for projects throughout California because the thresholds are applicable to meeting the State’s established GHG reduction goals. In the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed project for consistency with the identified project design elements as the applicable thresholds of significance to establish if the proposed project is achieving its “fair share” of emission reductions to support long-term State goals for GHG emissions and carbon neutrality.

According to the Justification Report, a project would have a less than significant impact related to GHG emissions if it would include the following project design elements:29

1. Buildings
a. The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).
b. The project will not result in any wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.
27 Bay Area Air Quality Management District (BAAQMD). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. April. 28 Ibid.
29 Ibid.
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28 2. Transportation
a. Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA:

1. Residential projects: 15 percent below the existing VMT per capita

2. Office projects: 15 percent below the existing VMT per employee

3. Retail projects: no net increase in existing VMT
b. Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

The City of Fresno adopted CEQA Guidelines for Vehicle Miles Traveled Thresholds (VMT Guidelines)30 that identify specific screening criteria for projects, as well as establishing City thresholds as 14.1 VMT per capita threshold for residential land uses and a 22.3 VMT per employee threshold for employee-based land uses. The screening criteria included in the VMT Guidelines are utilized in this analysis.

These project design elements are utilized in the following analysis as the thresholds of significance to evaluate the project’s potential GHG emissions impact, given the absence of City or SJVAPCD specified thresholds. The proposed project is also evaluated for consistency with the CARB 2022 Scoping Plan and the Fresno COG RTP/SCS.31

PROJECT IMPACTS
This section identifies the air quality, GHG, and energy impacts associated with implementation of the proposed project.

Air Quality
Air pollutant emissions associated with the project would occur over the short term from construction activities and over the long term from operational activities associated with the proposed land uses.

Consistency with Applicable Air Quality Plans
The proposed project is in a region classified as a nonattainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air 30 City of Fresno. 2020. CEQA Guidelines for Vehicle Miles Traveled Thresholds. Website:
https://www.fresno.gov/wp-content/uploads/2023/03/CEQA-Guidelines-for-Vehicle-Miles-TraveledFinal-Adopted-Version.pdf (accessed November 2024). 31 Fresno COG. 2022. Regional Transportation Plan and Sustainable Communities Strategy. Website:
https://www.fresnocog.org/project/regional-transportation-plan/ (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
29 quality standards. To bring the San Joaquin Valley into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8-Hour Ozone Standard in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8-hour ozone standard.32 To ensure the SJVAB’s continued attainment of the USEPA PM10 standard, the SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007.33 The SJVAPCD adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards in November 2018 to address the USEPA 1997 annual PM2.5 standard of 15 µg/m3 and 24-hour PM2.5 standard of 65 µg/m3, the 2006 24-hour PM2.5 standard of 35 μg/m³, and the 2012 annual PM2.5 standard of 12 μg/m³.34 CEQA requires that certain proposed projects be analyzed for consistency with the applicable air quality plan. For a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant impact on air quality. In addition, emission reductions achieved through implementation of offset requirements are a major component of the SJVAPCD air quality plans. As discussed below, the proposed project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. Therefore, the proposed project would not conflict with or obstruct implementation of SJVAPCD air quality plans.

Criteria Pollutant Analysis
The SJVAB is currently designated nonattainment for the federal and State standards for O3 and PM2.5. In addition, the SJVAB is in nonattainment for the PM10 standard. The SJVAB’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of an ambient air quality standard. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. The following analysis assesses the potential construction- and operation-related air quality impacts. 32 SJVAPCD. 2016. 2016 Plan for the 2008 8-Hour Ozone Standard. June 16. Website: www.valleyair.org/ Air_Quality_Plans/Ozone-Plan-2016.htm (accessed November 2024). 33 SJVAPCD. 2007. 2007 PM10 Maintenance Plan and Request for Redesignation. Website: www.valleyair.org/ Air_Quality_Plans/docs/Maintenance%20Plan10-25-07.pdf (accessed November 2024). 34 SJVAPCD. 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15. Website:
http://valleyair.org/pmplans/documents/2018/pm-plan-adopted/2018-Plan-for-the-1997-2006-and2012-PM2.5-Standards.pdf (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
30 Construction Emissions. During construction, short-term degradation of air quality may occur due to the release of particulate matter emissions (i.e., fugitive dust) generated by excavation activities.

Emissions from construction equipment are also anticipated and would include CO, NOx, reactive organic gases (ROGs), directly emitted PM2.5 or PM10, and TACs (e.g., DPMs).

Project construction would include site preparation, grading, building construction, paving, and architectural coating activities. Construction-related effects on air quality from the proposed project would be greatest during the disturbance of soils. If not properly controlled, these activities would temporarily generate particulate emissions. Sources of fugitive dust would include disturbed soils at the construction site. Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and amount of operating equipment. Larger dust particles would settle near the source, whereas fine particles would be dispersed over greater distances from the construction site.

Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. The SJVAPCD has established Regulation VIII measures for reducing fugitive dust emissions (PM10).35 With the implementation of Regulation VIII measures, fugitive dust emissions from construction activities would not result in adverse air quality impacts.

In addition to dust-related PM10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, sulfur oxides (SOx), NOx, ROGs, and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

Construction emissions were estimated for the project using CalEEMod and are summarized in Table E.
35 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
31 Table E: Short-Term Regional Construction Emissions
Construction Year Annual Pollutant Emissions (Tons per Year) ROG NOx CO SOX Total PM10 Total PM2.5
2025 0.1 4.5 3.4 <0.1 0.6 0.3
2026 0.1 2.5 2.2 <0.1 0.2 0.1
2027 0.1 2.5 2.1 <0.1 0.2 0.1
2028 1.3 1.6 1.3 <0.1 0.1 0.1
Maximum Emissions 1.3 4.5 3.4 <0.1 0.6 0.3
SJVAPCD Threshold 10.0 10.0 100.0 27.0 15.0 15.0
Significant? No No No No No No
Source: Compiled by LSA (2024).

RCM AIR-1 Consistent with San Joaquin Valley Air Pollution Control District (SJVAPCD) Regulation VIII (Fugitive PM10 Prohibitions), the following controls are required to be included as specifications for the proposed project and implemented at the construction site:
• All disturbed areas, including storage piles, that are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant or covered with a tarp or other suitable cover or vegetative ground cover.
• All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant. • All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking. • When materials are transported off site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least 6 inches of freeboard space from the top of the container shall be maintained. 36 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
32 • All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. (The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.)
• Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/ suppressant.

Construction emissions associated with the proposed project would be less than significant with implementation of RCM AIR-1. Therefore, construction of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard.

Operational Air Quality Impacts. Long-term air pollutant emission impacts associated with the proposed project are those related to mobile sources (e.g., vehicle trips), energy sources (e.g., natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment).

Mobile source emissions include ROG and NOX emissions that contribute to the formation of ozone.

Additionally, PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways.

Energy source emissions result from activities in buildings for which natural gas is used. The quantity of emissions is the product of usage intensity (i.e., the amount of natural gas) and the emission factor of the fuel source.

Typically, area source emissions consist of direct sources of air emissions located at the project site, including architectural coatings and the use of landscape maintenance equipment. Area source emissions associated with the project would include emissions from the use of landscaping equipment and the use of consumer products.

Long-term operational emissions associated with the proposed project were calculated using CalEEMod. Table F provides the proposed project’s estimated operational emissions.

The results shown in Table F indicate the proposed project would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Therefore, operation of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State AAQS. 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
33 Table F: Project Operational Emissions
Emission Type Pollutant Emissions (Tons per Year)
ROG NOX CO SOX Total PM10 Total PM2.5
Mobile Sources 1.1 1.0 6.7 <0.1 1.6 0.4
Area Sources 1.8 <0.1 1.0 <0.1 <0.1 <0.1
Energy Sources 0.0 0.0 0.0 0.0 0.0 0.0
Total Project Emissions 2.9 1.1 8.3 <0.1 1.6 0.4
SJVAPCD Threshold 10.0 10.0 100.0 27.0 15.0 15.0
Exceeds Threshold? No No No No No No
Source: Compiled by LSA (2024).

Note: Some values may not appear to add correctly due to rounding.

CO = carbon monoxide
NOx = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
ROG = reactive organic gas
SJVAPCD = San Joaquin Valley Air Pollution Control District SOX = sulfur oxides
Long-Term Microscale (CO Hot Spot) Analysis. Vehicular trips associated with the proposed project would contribute to congestion at intersections and along roadway segments in the vicinity of the proposed project site. Localized air quality impacts would occur when emissions from vehicular traffic increase as a result of the proposed project. The primary mobile-source pollutant of local concern is CO, a direct function of vehicle idling time and, thus, of traffic flow conditions. CO transport is extremely limited; under normal meteorological conditions, it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels, affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients).

An assessment of project-related impacts on localized ambient air quality requires that future ambient air quality levels be projected. Existing CO concentrations in the immediate project vicinity are not available. Ambient CO levels monitored at Fresno-Garland station, the closest station to the project site, showed a highest recorded 1-hour concentration of 2.2 ppm (the State standard is 20 ppm) and a highest 8-hour concentration of 1.8 ppm (the State standard is 9 ppm) during the past 3 years. The highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst-case analysis. Reduced speeds and vehicular congestion at intersections result in increased CO emissions.

As described in the Project Description section, the proposed project is estimated to generate 1,914 average daily trips, including 142 trips during the peak a.m. hour and 191 trips during the peak p.m. hour.37 Therefore, given the extremely low level of CO concentrations in the project area and the lack of traffic impacts at any intersections after the implementation of mitigation, project-related 37 Crawford & Bowen Planning, Inc. 2024. Fresno Residential Trip Generation. May. 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
34 vehicles are not expected to result in CO concentrations exceeding the State or federal CO standards. No CO hot spots would occur, and the project would not result in any project-related impacts on CO concentrations.

Health Risk on Nearby Sensitive Receptors
Sensitive receptors are defined as residential uses, schools, daycare centers, nursing homes, and medical centers. Individuals particularly vulnerable to diesel particulate matter are children, whose lung tissue is still developing, and the elderly, who may have serious health problems that can be aggravated by exposure to diesel particulate matter. The project site is surrounded primarily by residential and agricultural uses. The closest sensitive receptors to the project site include a singlefamily home located east of the project site within 135 feet. The nearest worker receptor to the project site is located approximately 2,000 feet southeast of the project site. The nearest school receptor to the project site is located approximately 1,700 feet south of the project site, across North South Armstrong Avenue.

A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed project. Table G, below, identifies the results of the analysis assuming the use of Tier 2 construction equipment as proposed by the project. Model snapshots of the sources are shown in Attachment C.

Table G: Health Risks from Project Construction to Off-Site Receptors Location
Carcinogenic
Inhalation Health Risk
in One Million
Chronic Inhalation
Hazard Index
Acute Inhalation
Hazard Index
Residential Receptor Risk 11.57 <0.01 0.000
Worker Receptor Risk <0.01 <0.01 0.000
School Receptor 0.04 <0.01 0.000
SJVAPCD Significance Threshold 20.0 in one million 1.0 1.0 Significant? No No No
Source: Compiled by LSA (December 2024).

SJVAPCD = San Joaquin Valley Air Pollution Control District As shown in Table G, the maximum cancer risk for the residential receptor MEI would be 11.57 in one million, which would not exceed the SJVAPCD cancer risk threshold of 20 in one million. The worker receptor risk would be less than 0.01 in 1 million and the school receptor MEI would be 0.04 in 1 million, which would not exceed the SJVAPCD cancer risk thresholds. The total chronic HI would be less than 0.01 all receptors, which is below the threshold of 1.0. In addition, the total acute HI would be nominal (0.000), which would also not exceed the threshold of 1.0. Therefore, construction of the proposed project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.

Furthermore, the proposed project would include the construction of a 203-unit, single-family residential development. As identified in Table F, project operational emissions of criteria pollutants would be below SJVAPCD significance thresholds; thus, they are not likely to have a significant impact on sensitive receptors. In addition, the proposed project would be required to implement 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
35 District Rule 9510, Indirect Source Review (ISR).38 Implementation of Rule 9510 would reduce operational emissions of NOX and PM10 by 33.3 percent and 50 percent, respectively. Compliance with SJVAPCD rules would further limit doses and exposures, reducing potential health risk related to gasoline vapors to a level that is not significant. Once the proposed project is constructed, the proposed project would not be a source of substantial emissions and would not result in new sources of TACs. Therefore, the project would not expose sensitive receptors to substantial levels of TACs.

Odors
The SJVAPCD addresses odor criteria within the GAMAQI. The district has not established a rule or standard regarding odor emissions, rather, the district has a nuisance rule: “Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.”39
During project construction, some odors may be present due to diesel exhaust. However, these odors would be temporary and limited to the construction period. The proposed uses are not anticipated to emit any objectionable odors. Any odors in general would be confined mainly to the project site and would readily dissipate. Therefore, the proposed project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Naturally Occurring Asbestos
The project is in Fresno County, which is among the counties found to have serpentine and ultramafic rock in their soils.40 However, according to the California Geological Survey, no such rock has been identified in the project vicinity. When demolition is proposed during construction, the demolition of existing buildings may expose asbestos used in building materials. However, the proposed project would not involve any demolition or renovation as no current development exists on the project site. Therefore, the potential risk for naturally occurring asbestos during project construction is small and would not be significant.

Valley Fever
The project site is surrounded primarily by residential uses. The closest sensitive receptors to the project site include a single-family home located east of the project site within 125 feet. Except under high wind conditions, this distance is sufficient that particulate matter would settle prior to reaching the nearest sensitive receptor. In addition, crosswinds influenced by the adjacent roadways would help dissipate any particulate matter associated with the construction phase of the project.

Therefore, any Valley fever spores suspended with the dust would not be anticipated to reach the sensitive receptors. However, during project construction, it is possible that workers could be exposed to Valley fever through fugitive dust. Dust control measures, consistent with SJVAPCD 38 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 39 Ibid.
40 California Department of Conservation (DOC). n.d. California Geological Survey. Asbestos. Website:
https://www.conservation.ca.gov/cgs/minerals/mineral-hazards (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
36 Regulation VIII,41 would reduce the exposure to the workers and sensitive receptors. Therefore, dust from the construction of the project is not anticipated to significantly add to the existing exposure of people to Valley fever.

Energy Use
This section discusses energy use resulting from implementation of the proposed project and evaluates whether the proposed project would result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy and energy efficiency.

Construction
The anticipated construction schedule assumes that the proposed project would be built in approximately three years. Construction-specific phases were assessed for their energy consumption under each construction sub-phase: grading, site preparation, building construction, paving, and architectural coating activities.

Construction would require energy for the manufacture and transportation of construction materials, preparation of the site for grading and building activities, and construction of the building.

All or most of this energy would be derived from nonrenewable resources. Petroleum fuels (e.g., diesel and gasoline) would be the primary sources of energy for these activities. However, construction activities are not anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the project. Energy (i.e., fuel) usage on the project site during construction would be temporary in nature and would be relatively small in comparison to the State’s available energy sources.

Operation
Energy use associated with the proposed project would consist of natural gas, electricity, and vehicle fuel use associated with project operations.

Table H shows the estimated potential increased electricity, gasoline, and diesel demand associated with the proposed project. The electricity and natural gas rates are from the CalEEMod analysis, and the gasoline and diesel rates are based on the traffic analysis in conjunction with USDOT fuel efficiency data and use the USEPA’s fuel economy estimates for 2020 and the California diesel fuel economy estimates for 2021. Energy and Fuel Calculations output sheets are included in Attachment D.
41 SJVAPCD. 2024. Current District Rules and Regulations. Website: ww2.valleyair.org/rules-andplanning/current-district-rules-and-regulations (accessed November 2024). 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
37 Table H: Estimated Annual Energy Use of Proposed Project Electricity Use
(kWh per year)
Natural Gas Use
(kBTU per year)
Gasoline
(gallons per year)
Diesel
(gallons per year)
Proposed Project 1,897,356 0 159,991 122,720
Source: Compiled by LSA (2024).
kBTU = thousand British thermal units
kWh = kilowatt hours
As shown in Table H, the estimated increase in electricity demand associated with the operation of the proposed project would be 1,897,356 kWh per year. Total electricity consumption in Fresno County in 2022 was 8,384,408,687 kWh;
42 therefore, operation of the proposed project would
negligibly increase the annual electricity consumption in Fresno County by approximately less than

0.1 percent.

As shown in Table H, there would not be an increase in natural gas use as the project is all electric.

Therefore, operation of the proposed project would not increase the annual natural gas consumption in Fresno County.

In addition, the project would result in energy usage associated with motor vehicle gasoline to fuel project-related trips. As shown above in Table H, the proposed project would result in the consumption of 159,991 gallons of gasoline and 122,720 gallons of diesel per year. Based on fuel consumption obtained from EMFAC2021, approximately 337.0 million gallons of gasoline and approximately 154.4 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2028. Therefore, vehicle trips associated with the proposed project would increase the annual fuel use in Fresno County by approximately less than 0.1 percent for gasoline fuel usage and approximately less than 0.1 percent for diesel fuel usage. The proposed project would result in fuel usage that is a small fraction of current annual fuel use in Fresno County, and fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Therefore, gasoline demand generated by vehicle trips associated with the proposed project would be a minimal fraction of gasoline and diesel fuel consumption in California.

Furthermore, the proposed project would be constructed using energy efficient modern building materials and construction practices, and the proposed project also would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). The expected energy consumption during construction and operation of the proposed project would be consistent with typical usage rates for residential uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings.
42 CEC. 2022. Electricity Consumption by County. Website: www.ecdms.energy.ca.gov/elecbycounty.aspx (accessed December 2024).
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38 PG&E is the private utility that would supply the proposed project’s electricity. In 2021, a total of 50 percent of PG&E’s delivered electricity came from renewable sources, including solar, wind, geothermal, small hydroelectric, and various forms of bioenergy.43 PG&E reached California’s 2020 renewable energy goal in 2017 and is positioned to meet the State’s 60 percent by 2030 renewable energy mandate set forth in SB 100. In addition, PG&E plans to continue to provide reliable service to its customers and upgrade its distribution systems as necessary to meet future demand. As such, the proposed project would not result in a potential significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation.

Conflict with or Obstruction of a State or Local Plan for Renewable Energy or Energy Efficiency The CEC recently adopted the 2023 Integrated Energy Policy Report.44 The 2023 Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs. The 2023 Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecasts, and the California Energy Demand Forecast.

As indicated above, energy usage on the project site during construction would be temporary in nature and would be relatively small in comparison to the State’s available energy sources. In addition, energy usage associated with operation of the proposed project would be relatively small in comparison to the region’s available energy sources, and energy impacts would be negligible at the regional level. Because California’s energy conservation planning actions are conducted at a regional level, and because the project’s total impact on regional energy supplies would be minor, the proposed project would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s 2023 Integrated Energy Policy Report. Therefore, the proposed project would not lead to new or substantially more severe energy impacts.

Greenhouse Gas Emission Impacts
Generation of Greenhouse Gas Emissions
The following sections describe the proposed project’s construction- and operation-related GHG impacts and consistency with applicable GHG reduction plans.

Construction Greenhouse Gas Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder 43 PG&E. 2021. Exploring Clean Energy Solutions. Website: https://www.pge.com/en_US/about-pge/ environment/what-we-are-doing/clean-energy-solutions/clean-energy-solutions.page?WT.mc_id= Vanity_cleanenergy (accessed December 2024).
44 CEC. 2023. 2023 Integrated Energy Policy Report. California Energy Commission. Docket Number:
23-IEPR-01.
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39 supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

The SJVAPCD does not have an adopted threshold of significance for construction-related GHG emissions. However, lead agencies are encouraged to quantify and disclose GHG emissions that would occur during construction. Using CalEEMod, it is estimated that the total emissions associated with construction of the proposed project would be approximately 1,562.8 metric tons (MT) of CO2e. Construction GHG emissions were amortized over the life of the project (assumed to be 30 years) and added to the operational emissions. When annualized over the life of the project, amortized construction emissions would be approximately 52.1 MT CO2e per year.

Operational Greenhouse Gas Emissions. Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle and truck trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile-source GHG emissions would include project-generated vehicle trips to and from the project. Area-source emissions would be associated with activities such as landscaping and maintenance on the project site. Energy source emissions would be generated at off-site utility providers as a result of increased electricity demand generated by the project. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project generated waste. In addition, water source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.

GHG emissions for operation of the project were calculated using CalEEMod. Based on the analysis results, summarized in Table I, the proposed project would result in emissions of approximately 2,018.7 MT CO2e per year. These estimated emissions are provided for informational purposes, and the significance of the proposed project is further analyzed below.

Table I: Greenhouse Gas Emissions
Emission Type Operational Emissions (metric tons per year) Total CO2 CH4 N2O CO2e
Mobile Sources 1,684.7 0.1 0.1 1,716
Area Sources 2.5 <0.1 <0.1 2.5
Energy Sources 175.6 <0.1 <0.1 177
Water Sources 6.1 0.3 <0.1 14.7
Waste Sources 16.1 1.6 0.0 56.4
Amortized Construction Emissions 52.1
Total Operational Emissions 2,018.7
Source: Compiled by LSA (2024).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
N2O = nitrous oxide
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40 As discussed above, the SJVAPCD has not established a numeric threshold for GHG emissions, and the City does not have a current GHG Reduction Plan. In the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed project for consistency with the BAAQMD Justification Report,45 which identifies project design elements as the applicable thresholds of significance. If a project is designed and built to incorporate design elements related to natural gas, energy, VMT, and EVs, then it would contribute its portion of what is necessary to achieve California’s long-term climate goals—its “fair share”—and an agency reviewing the project under CEQA can conclude that the project would not make a cumulatively considerable contribution to global climate change.

Per the significance thresholds described above, a less than significant GHG impact would occur if the project were consistent with the identified design standards, as evaluated below.

Natural Gas Usage. A less than significant GHG impact would occur if the project does not include natural gas appliances or natural gas plumbing. The proposed project would not include natural gas.

Therefore, the proposed project would be consistent with this design element.

Energy Usage. Under this design criterion, the project must not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines. Energy use consumed by the proposed project would be associated with electricity consumption associated with the project. Energy consumption was estimated for the project using default energy intensities by land use type in the CalEEMod output, which is included in Attachment B.

As shown in Table H above, the estimated potential increase in electricity demand associated with the operation of the proposed project is 1,897,356878,579 kWh per year. Total electricity consumption in Fresno County in 2022 was 8,384,408,687 kWh. Therefore, operation of the proposed project would increase the annual electricity consumption in Fresno County by approximately 0.1 percent.

In addition, the proposed project would be constructed to current Title 24 standards, which would require energy-saving building features. As such, based on this analysis, as required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines, the proposed project would not result in the wasteful, inefficient, or unnecessary consumption of fuel or energy and would incorporate renewable energy and energy efficiency measures into the building design, equipment use, and transportation. As such, the proposed project would be consistent with this design element.

Vehicle Miles Traveled. As discussed above, development that meets a locally adopted SB 743 VMT target would be considered to have a less than significant GHG emissions impact from transportation sources. A project specific VMT analysis was conducted for the project utilizing the VMT Calculator tool developed by the City of Fresno and the project was found to be less than the 45 BAAQMD. 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans. April.
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41 screening thresholds established by the City to evaluate project consistency with the City’s SB 743 VMT significance thresholds.
46 Therefore, the proposed project would be consistent with this project design element.

Electric Vehicle Requirements. The final project design element that the proposed project should include to ensure that it is achieving its “fair share” of GHG emission reductions is compliance with off-street EV requirements in the most recently adopted version of the CALGreen Code Tier 2 measures. The proposed project would include an EV charging station for each home, consistent with CALGreen Tier 2 standards. Therefore, the proposed project would be consistent with this design element.

The proposed project would be consistent with the project design elements related to natural gas, energy, VMT, and EVs. Therefore, the proposed project would be consistent with the GHG emission thresholds identified for this project. As such, the proposed project would not result in the generation of GHG emissions that would have a significant impact on the environment.

Consistency with Greenhouse Gas Reduction Plans
The proposed project is further analyzed for consistency with the City of Fresno General Plan policies, the 2022 Scoping Plan, and Fresno COG’s RTP/SCS.

City of Fresno General Plan. The City’s General Plan, including the Resources Conservation and Resilience Element as well as land use policies, includes objectives and policies that work to achieve and maintain reductions in GHG emissions and all strategies that reduce the causes of climate change.47 A consistency analysis with the applicable policies from the Resources Conservation and Resilience Element and other relevant General Plan policies and objectives is presented below.

The proposed project would be consistent with policies RC-5-a, RC-5-b, RC-5-c, RC-5-d, RC-5-e, RC-5- g, RC 7-a, RC 7-h, and RC 11-a. The proposed project would construct a 203-unit single-family development in a vacant lot and would provide infill development to an already established neighborhood in the City. Thus, the project would be consistent with land use policies and strategies established in the General Plan including UF 12, UF 12-a, and RC 2-a. In addition, the proposed project would comply with the 2022 CALGreen Code building measures and Title 24 standards for solar and EVs. Thus, the proposed project would incorporate the appropriate energy and water conservation standards, facilitate incentives for the incorporation of bicycle and pedestrian amenities, and would encourage the use of alternative modes of transportation.

The proposed project would also provide complete streets for all internal roadway improvements, which would increase connectivity with the surrounding land uses and neighborhoods. Therefore, the proposed project would also be consistent with the applicable strategies under policy RC-5-c and 46 DKB. 2024. City of Fresno- Uban Form VMT Calculator. Received via email correspondence from Emily Bowen, dated December 4, 2024.
47 City of Fresno. 2014. Fresno General Plan. December 18. Website: https://www.fresno.gov/wp-content/ uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_compressed.pdf (accessed November 2024).
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42 policies related to energy conservation, land use planning, and transportation demand outlined in the General Plan such as MT 4, MT 4-c, MT 5, MT 6, MT 8, and MT 8-b. Moreover, the proposed project would provide recycling canisters and would implement techniques for solid waste segregation, disposal, and reduction, consistent with the CalRecycle Waste Diversion and Recycling Mandate. Therefore, the proposed project would be consistent with waste diversion and recycling strategies under RC 11-a.

As further discussed in the following section, the proposed project would also be consistent with the goals outlined in the Fresno COG 2022 RTP/SCS48 and would not interfere with the Fresno COG’s ability to achieve the region’s GHG reductions. Therefore, the project would also be consistent with policy RC-5-d. Furthermore, PG&E is the private utility that would supply the proposed project’s electricity. Future residents would have the option to join an energy savings program, which would help educate homeowners on green energy. Therefore, the proposed project would be consistent with policy RC-5-f. The analysis presented is conducted with the latest CalEEMod version, consistent with policy RC-5-g.

Through consistency with supporting and implementing the General Plan objectives and policies, the proposed project is consistent with and would not conflict with or obstruct the implementation of the City’s General Plan.
2022 Scoping Plan. The following discussion evaluates the proposed project according to the goals of the 2022 Scoping Plan,49 EO B-30-15, SB 32, and AB 197.

EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,50 to reflect the 2030 target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps California on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels. The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others and is designed to meet the State’s long-term 48 Fresno COG. 2022. Regional Transportation Plan and Sustainable Communities Strategy. Website:
https://www.fresnocog.org/project/regional-transportation-plan/ (accessed November 2024). 49 CARB. 2022. 2022 Scoping Plan Update. Website: https://ww2.arb.ca.gov/sites/default/files/2022- 12/2022-sp.pdf (accessed December 2024).
50 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. 6/3/25 (K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx)
43 climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California will be zero-emission by 2035, and all other fleets will have transitioned to zero-emission as fully possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.

Energy efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. As discussed in the Energy section of this document, the proposed project would not result in the wasteful or inefficient use of energy. The proposed project would be required to comply with the latest Title 24 standards of the CCR, established by the CEC, regarding energy conservation and green building standards. Therefore, the proposed project would comply with applicable energy measures.

Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. The project would comply with the CALGreen Code, which includes a variety of different measures, including the reduction of wastewater and water use. In addition, the proposed project would be required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the proposed project would not conflict with any of the water conservation and efficiency measures.

The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction targets for passenger vehicles. Specific regional emission targets for transportation emissions would not directly apply to the proposed project. The second phase of Pavley II (LEV III) Advanced Clean Cars Program will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulting in a 3 percent decrease in average vehicle emissions for all vehicles by 2020. Vehicles traveling to and from the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program. Therefore, the proposed project would not conflict with the identified transportation and motor vehicle measures.
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44 Fresno COG’s 2022 RTP/SCS. The Fresno COG RTP/SCS reflects transportation planning for Fresno County through 2046.51 The vision, goals, and policies in the 2022 RTP are intended to serve as the foundation for both short and long-term planning and guide implementation activities. The core vision in the 2022 RTP is to create a region of diverse, safe, resilient, and accessible transportation options that improve the quality of life for all residents by fostering sustainability, equity, a vibrant economy, clean air, and healthy communities. The 2022 RTP contains transportation projects to help more efficiently distribute population, housing, and employment growth, as well as forecast development that is generally consistent with regional-level general plan data. The actions in the 2022 RTP address all transportation modes (e.g., highways, local streets and roads, mass transportation, rail, bicycle, and aviation facilities and services) and consists of short and long-term activities that address regional transportation needs. While the actions are organized by the five key policy areas, many of them support multiple goals and policies. Some actions are intended to support the SCS and reduce GHG emissions directly, while others are focused on the RTP’s broader goals. The 2022 RTP does not require that local General Plans, Specific Plans, or zoning be consistent with the 2022 RTP, but provides incentives for consistency for governments and developers.

The proposed project would not interfere with the Fresno COG’s ability to achieve the region’s GHG reductions. Furthermore, the proposed project is not regionally significant per State CEQA Guidelines Section 15206, and it would not conflict with the 2022 RTP targets because those targets were established and are applicable on a regional level. While the proposed project site would require rezoning for the proposed land use, the proposed project would result in a baseline VMT well above the per-capita threshold established by the City to support the region achieving the State’s GHG reductions included under SB 743. Based on the average number of residents per household in Fresno of 2.96,
52 the proposed project would result in an estimated population increase of approximately 601 residents, well within the estimated population growth of 647,980 residents in 2030 as included in the 2022 RTP. Therefore, it is anticipated that implementation of the proposed project would not interfere with Fresno COG’s ability to implement the regional strategies outlined in the 2022 RTP. The proposed project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in the 2022 RTP and would be consistent with applicable State plans and programs designed to reduce GHG emissions.

Therefore, the proposed project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions.

CONCLUSION
Based on the analysis presented above, with implementation of RCM AIR-1, construction and operational activities associated with the proposed project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. In addition, the proposed project is not expected to produce significant emissions that would affect nearby sensitive 51 Fresno COG. 2022. Regional Transportation Plan and Sustainable Communities Strategy. Website:
https://www.fresnocog.org/project/regional-transportation-plan/ (accessed November 2024). 52 United States Census Bureau. 2020. Census Data. Fresno City. Residential Population. Household and Family. Website: https://data.census.gov/table/ACSST1Y2023.S1101?q=residents%20per%20household &g=160XX00US0627000 (accessed December 2024).
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45 receptors. The proposed project would also not result in objectionable odors affecting a substantial number of people.

The proposed project would also not result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy and energy efficiency. The project would not result in the emission of substantial GHG emissions. Additionally, the project would not conflict with local or regional plans and policies for GHG emission reductions, nor with the State’s GHG emissions reductions objectives embodied in the 2022 Scoping Plan.

Therefore, the proposed project’s incremental contribution to cumulative GHG emissions would not be cumulatively considerable.

Attachments: A: Figures
B: CalEEMod Outputs
C: HRA Model Snapshots and Output
D: Energy and Fuel Calculations and Output

AI R QU A L I T Y , EN E R G Y , A N D GR E E N H O U S E GAS T E C H N I C A L ME M O R A N D U M DE C E M B E R 2024

AS T E R PL A C E RE S I D E N T I A L DE V E L O P M E N T P R O J E C T

F R E S N O, C A L I F O R N I A
K:\Master Files - Tract Maps\'6300 to 6399 maps\Tract 6376 - California & Armstrong, 172 lots - LR to JL\2024\`PC\Exhibits\New Exhibits\Word\Aster Place Development AQ_E_GHG Memo.docx (06/03/25)

ATTACHMENTS
April 15, 2021
Zach Gomes, Vice President of Operations
KB Home Central California
744 P Street, Third Floor, Suite 321
Fresno, CA 93721
Subject: Simonian Project, Fresno, California—Biological Due Diligence Dear Mr. Gomes:

In support of the Simonian Project, H. T. Harvey & Associates conducted a site survey for an approximately 38.8-acre residential development identified as APN 316-160-16S, 17S, 43S, 59S and 61S located on the west side of south Armstrong Ave, between the San Joaquin Valley Railroad and East Pitt Ave, in the Fresno County, California. This survey was requested by KB Home Central California in due diligence to assess whether any species federally or state listed as threatened, endangered, or candidate or any state species of special concern (collectively referred to as special-status species) occur or are likely to occur on the project site.

A qualified H. T. Harvey & Associates ecologist performed a biological survey of the project site on March 25, 2021, to determine the potential presence of special-status plant and wildlife species. The ecologist surveyed the entire site by walking east-west transects spaced approximately 100 feet (ft.) apart. This provided full visual coverage of the project site for assessing habitat composition and species presence. In addition, the ecologist visually surveyed all areas within a quarter-mile of project site boundaries for signs of current or prior nesting (e.g., existing nests) by raptors species.

The site consists of loose, recently-disked soil, except for two residence located on the property. Approximately 11 acres in the southwest corner and along the central part of the southern border have been disked since the spring 2020 growing season and are sparsely vegetated. The remainder of the site also shows signs of recent disking, but currently is approximately 95% covered in vegetation, with the remainder consisting of bare soil. Garbage is relatively abundant, especially in the northwest corner. Overall, the site conditions are currently unsuitable for special-status plant species. Vegetation on the site is comprised mostly of grasses, but some low-growing forbs are also present. Plant height is currently low, with grasses and forbs 1-6 inches tall. The site can be characterized as annual grassland in the process of re-establishment. As a result of past ground disturbance, the project site is highly suitable for nonnative invasive plants. We understand that all vegetation in construction areas will be cleared and that the use of site-specific best management practices will minimize the dispersal of nonnative invasive plants. 8080 N. Palm Avenue, Suite 205 ● Fresno, CA 93711 ● Ph: 559.476.3160 ● F: 559.476.3170 H. T. HARVEY & ASSOCIATES
2 The project site is relatively far from recent records of special-status species. A query of California Natural Diversity Database (CNDDB 20211) records occurring within 5 miles (mi) of the project site revealed seven special-status species occurrences, two of which are for Swainson’s hawk (Buteo swainsoni). The site falls within the extent of a Swainson’s hawk occurrence mapped over Fresno that has not been reconfirmed since 1956. The other Swainson’s hawk occurrence is based on observations from 2016 and is located 3.5 miles (mi.) southwest of the project site. In addition, there are two occurrences of burrowing owls (Athene cunicularia), one located 4.2 mi. to the north at Fresno Yosemite International Airport and another located 4.0 mi. to the northwest in Clovis. Also, double-crested cormorant (Phalacrocorax auritus) was documented at a collection of ponds 4.8 mi. to the north-northwest in 2012. The remaining records (for least Bell’s vireo [Vireo bellii pusillus] and western yellow-billed cuckoo [Coccyzus americanus occidentalis]) are both over 3.5 mi. away from the site and have not been reconfirmed within the last 108 years.

Numerous small mammal burrows occur on the Project site. Several active pocket gopher burrows were found scattered across the site. The site also currently supports a large population of California ground squirrels. Their burrows were abundant at the edge and along the slopes of the detention pond and were moderately abundant throughout the rest of the site. The California ground squirrel remains were located within 1 ft. of burrows of this species and represent predation and/or scavenging, perhaps by red-tailed hawks or other raptors. No signs of mammalian predators (e.g. coyotes [Canis latrans]) were observed. All animal species observed directly on or near (i.e., within 0.25 mi.) the project site are listed in Appendix A.

Many of the California ground squirrel burrows are large (about 3-5 inches in diameter), with large, unvegetated aprons, and thus are potentially suitable for use by burrowing owls, which is listed as Species of Special Concern by the State of California. No burrowing owls or signs of this species (e.g. pellets, feathers, or wash) were observed. However, the survey was conducted during conditions of light to moderately heavy rain in the middle of a rain event lasting several days. Any owls present would have been underground in their burrows, and their wash would have been rinsed away.

The occurrence of potentially suitable burrows suggests that burrowing owls might be present.

No direct evidence of special-status animal or plant species was observed and the site provides little or no value to sensitive plant and wildlife species with the exception of burrowing owl. The presence of burrowing owls on the 1 [CNDDB] California Natural Diversity Database. 2021. Results of electronic records search. Rarefind 5. California Department of Fish and Wildlife. <https://map.dfg.ca.gov/rarefind/view/RareFind.aspx>. Accessed January 2021.

H. T. HARVEY & ASSOCIATES
3 property could constrain the development of the parcel or result in project delays. Burrowing owls, and their nests are protected under state laws and regulations, including the California Fish and Game Code Section 3503.5.

Based on our understanding of burrowing owl distribution in the Central Valley, burrowing owls are unlikely to occupy this site. The size of the parcel and the adjacent similar parcel west combined with the number of suitable burrows on the site, however, warrant a cautious approach. We recommend implementation of the measures included in the Staff Report on Burrowing Owl Mitigation (CDFG 20122) including surveys of the project site.

In addition to implementation of the measures included in the Staff Report on Burrowing Owl Mitigation (CDFG 2012, if construction activities occur during the avian nesting season (generally, February 1 through August 31), preconstruction surveys for nesting birds by a qualified ornithologist should be conducted to ensure that no active nests are disturbed during construction. The survey should be conducted no more than 7 days before construction activities begin. During this survey, all potential nesting areas should be inspected in and immediately adjacent to the impact areas for nests. If an active nest is found sufficiently close to work areas to be disturbed by these activities, the ornithologist should determine the extent of a construction-free buffer zone to be established around the nest (typically, 300 ft. for raptors and 25–100 ft. for other species) to ensure that no active nests of species protected by the California Fish and Game Code would be disturbed during project construction.

Please feel free to contact me at 559.960.0849 or [email protected] regarding these survey results.

Sincerely,
Jeff Seay
Senior Wildlife Ecologist
2 [CDFG] California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. March 7.

H. T. HARVEY & ASSOCIATES
A-1
Appendix A. Animal Species Observed On or Within 0.25
Mile of the Simonian Project Site
Common Name Scientific Name
Birds
Mourning dove Zenaida macroura
Red-tailed hawk Buteo jamaicensis
California scrub-jay Aphelocoma californica
Unidentified swallow
species Family Hirundinidae
Dark-eyed junco Junco hyemalis
European starling Sturnus vulgaris
Mammals
California ground squirrel Otospermophilus beecheyi
Note: None of the observed species are special-status species.

PHASE I CULTURAL RESOURCE SURVEY,

SW CORNER OF ARMSTRONG AVENUE

AND THE SAN JOAQUIN VALLEY RAILROAD RIGHT-OF-WAY,
TRACT 6376,

CITY OF FRESNO, CALIFORNIA
Submitted to:

Crawford and Bowen Planning
113 N. Church Street #302
Visalia, California 93291
Keywords:

Malaga 7.5' Quadrangle, City of Fresno,
California Environmental Quality Act
Submitted by:

Hudlow Cultural Resource Associates
1405 Sutter Lane
Bakersfield, California 93309
Author:

Scott M. Hudlow
November 2024
2 Management Summary
At the request of Crawford and Bowen Planning, a Phase I Cultural Resource Survey was conducted at the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad Right-of-Way, in the City of Fresno, California for Tract 7376. The Phase I Cultural Resource Survey consisted of a cultural resource survey and a cultural resource record search.

No cultural resources were identified; however, three homes were located on the property as recently as 2022, on the west side of Armstrong Avenue. No remains from these three homes survive demolition, except for a non-historic concrete block retaining wall along Armstrong Avenue. No further work is required. If archaeological resources are encountered during the course of construction, a qualified archaeologist should be consulted for further evaluation.

If human remains or potential human remains are observed during construction, work in the vicinity of the remains will cease, and the remains will be treated in accordance with the provisions of State Health and Safety Code Section 7050.5. The protection of human remains follows California Public Resources Codes, Sections 5097.94, 5097.98, and 5097.99. 3 Table of Contents
Management Summary............................................................................................... 2 Table of Contents......................................................................................................... 3 List of Figures ................................................................................................................. 3

1.0 Introduction....................................................................................................... 4

2.0 Project Location................................................................................................ 6

3.0 Record Search .................................................................................................. 6

4.0 Environmental Background.............................................................................. 6

5.0 Prehistoric Archaeological Context .………………………………………………6

6.0 Ethnographic Background............................................................................. 10

7.0 Historic Overview ............................................................................................ 11

8.0 Field Procedures and Methods...................................................................... 13

9.0 Report of Archaeological Findings................................................................ 13

10.0 Management Recommendations ................................................................ 13

11.0 References ...................................................................................................... 13 Appendix I................................................................................................................... 15 Appendix II.................................................................................................................. 19 List of Figures
1 Project Area Location Map ............................................................................. 7 2 Project Area, View towards the Southeast..................................................... 9 3 Project Area, View towards the Southwest .................................................... 9 4 1.0 Introduction
At the request of Crawford and Bowen Planning, Hudlow Cultural Resource Associates conducted a Phase I Cultural Resource Survey in accordance with the California Environmental Quality Act for a proposed single-family residential development. The property, Tract 7376, is located at the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad right-of-way in the City of Fresno, California. This parcel totals 40 acres. The Phase I Cultural Resource Survey consisted of a pedestrian survey and a cultural resource record search. This project is being undertaken in accordance with the California Environmental Quality Act (CEQA) with the City of Fresno responsible as Lead Agency to implement CEQA. The Phase I Cultural Resource Survey consisted of a pedestrian survey and a cultural resource record search.

CEQA is a California statute passed in 1970. Governor Ronald Reagan signed it into law, after the federal government passed the National Environmental Policy Act (NEPA).

CEQA institutes a statewide policy of environmental protection. CEQA does not directly regulate land uses, but instead requires state and local agencies within California to follow a protocol of analysis and public disclosure of environmental impacts of proposed projects and, in a departure from NEPA, adopt all feasible measures to mitigate those impacts. CEQA makes environmental protection a mandatory part of every California state and local agency's decision making process.

CEQA was signed into law in 1970, in a time of increasing public concern for the environment. The statute required that for any public project, the government must conduct an environmental study to examine what impacts the project might have on things like air/water quality, noise, transportation, biological resources, or cultural resources, and generate an Environmental Impact Report (EIR) documenting the impacts as well as any potential and planned mitigations. In 1972, state courts interpreted a public project as a development project that needed government approval.

In 1969, NEPA passed into law. It is similar to CEQA in that both statutes set forth a policy of environmental protection, and a protocol by which all agencies in their respective jurisdictions make environmental protection part of their decision making process. NEPA is narrower in scope than CEQA. NEPA applies only to projects receiving federal funding or approval by federal agencies, while CEQA applies to projects receiving any form of state or local approval, permit, or oversight. Thus, development projects in California funded only by private sources and not requiring approval by a federal agency would be exempt from NEPA; but would likely be subject to CEQA.

The CEQA statute, California Public Resources Code § 21000 et seq., codifies a statewide policy of environmental protection. According to CEQA, state and local agencies must give consideration to environmental protection in regulating public and private activities and should not approve projects for which feasible and environmentally superior mitigation measures or alternatives exist.

CEQA mandates actions that all state and local agencies must do to advance this policy. Specifically, for any project under CEQA's jurisdiction with potentially significant 5 environmental impacts, agencies must identify mitigation measures and alternatives by preparing an Environmental Impact Report and must approve projects with feasible mitigation measures and the environmentally superior alternative. The California Natural Resources Agency promulgates the CEQA Guidelines, California Code of Regulations Title 14 § 15000 et seq., which detail the protocol by which state and local agencies must comply with CEQA requirements. CEQA originally applied to only public projects, but California Supreme Court interpretation of the statute, as well as later revisions, expanded CEQA's jurisdiction to nearly all projects within California, including those proposed by private businesses and individuals. § 21002.1 states "Each public agency shall mitigate or avoid the significant effects on the environment of projects that it carries out or approves whenever it is feasible to do so." For private projects, CEQA applies when a discretionary government permit or other entitlement for use is necessary.

For purposes of this section, the term "historical resources" shall include the following: (1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 14 CCR, Section 4850 et seq.). (2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. (3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency's determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 14 CCR, Section 4852) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;
(B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history.

The lead agency, the City of Fresno, is responsible for conducting the CEQA review and has final approval of the project. The City of Fresno is also responsible for coordinating with the project applicant, public, and associated agencies during the CEQA process. 6 2.0 Project Location
The project area is in the City of Fresno. This project area at the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad Right-of Way. The project area is the NE ¼ of the NW ¼ of Section 15, T.14S., R.21E., Mount Diablo Baseline and Meridian, as displayed on the United States Geological Survey (USGS) Malaga 7.5-minute quadrangle map (Figure 1). The proposed single-family development is located at the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad Right-of Way in the City of Fresno, California.

3.0 Record Search
A record search of the project area and the environs within one half-mile was conducted at the Southern San Joaquin Information Center. Information Center staff conducted the record search, RS# 24-299, on July 8, 2024. The record search revealed that one cultural resource survey has been conducted within one half-mile of the project area. No cultural resource surveys have previously addressed the parcel in question. No cultural resources have been located on the current project area; however, one cultural resource has been recorded within one half-mile of the current project area, the former Southern Pacific Railroad line, which is operated by the San Joaquin Valley Railroad, which is directly on the project’s northern boundary.

4.0 Environmental Background
The project area is located at an elevation of 320 feet above mean sea level in the Great Central Valley, which is composed of two valleys-the Sacramento Valley and the San Joaquin Valley. The parcel is located south of Fancher Creek, a branch of the Kings River. The former agricultural field is now fallow and was covered in alfalfa straw. No native vegetation survives (Figures 2 and 3).

5.0 Prehistoric Archaeological Context
A limited amount of archaeological research has been conducted in the southern San Joaquin Valley. Thus, consensus on a generally agreed upon regional cultural chronology has yet to be developed. Most cultural sequences can be summarized into several distinct time periods: Early, Middle, and Late. Sequences differ in their inclusion of various "horizons," "technologies," or "stages." A prehistoric archaeological summary of the southern San Joaquin Valley is available in Moratto (Moratto 1984).

Despite the preoccupation with chronological issues in most of the previous research, most suggested chronological sequences are borrowed from other regions with minor modifications based on sparse local data.

The following chronology is based on Parr and Osborne's Paleo-Indian, Proto-Archaic, Archaic, Post-Archaic periods (Parr and Osborne 1992:44-47). Most existing chronologies focus on stylistic changes of time-sensitive artifacts such as projectile points and beads rather than addressing the socioeconomic factors, which produced the myriad variations. In doing so, 7 Figure 1
Project Area Location Map
8 these attempts have encountered similar difficulties. These cultural changes are implied as environmentally determined, rather than economically driven.

Paleo-Indians, whom roamed the region approximately 12,000 years ago, were highly mobile individuals. Their subsistence is assumed to have been primarily big game, which was more plentiful 12,000 years ago than in the late twentieth century. However, in the Great Basin and California, Paleo people were also foragers who exploited a wide range of resources.

Berries, seeds, and small game were also consumed. Their technology was portable, including manos (Parr and Osborne 1992:44). The paleo period is characterized by fluted Clovis and Folsom points, which have been identified throughout North America. The Tulare Lake region in Kings County has yielded several Paleo-Indian sites, which have included fluted points, scrapers, chipped crescents, and Lake Mojave-type points (Morratto 1984:81-2).

The Proto-Archaic period, which dates from approximately 11,000 to 8,000 years ago, was characterized by a reduction in mobility and conversely an increase in sedentism. This period is classified as the Western Pluvial Lake Tradition or the Proto-Archaic, of which the San Dieguito complex is a major aspect (Moratto 1984: 90-99; Warren 1967). An archaeological site along Buena Vista Lake in southwestern Kern County displays a similar assemblage to the San Dieguito type site. Claude Warren proposes that a majority of Proto-Archaic southern California could be culturally classified as the San Dieguito Complex (Warren 1967). The Buena Vista Lake site yielded manos, millingstones, large stemmed and foliate points, a mortar, and red ochre. During this period, subsistence patterns began to change. Hunting focused on smaller game and plant collecting became more integral. Large stemmed, lancelote (foliate) projectile points represents lithic technology. Millingstones become more prevalent. The increased sedentism possibly began to create regional stylistic and cultural differences not evident in the paleo period.

The Archaic period persisted in California for the next 4000 years. In 1959, Warren and McKusiak proposed a three-phase chronological sequence based on a small sample of burial data for the Archaic period (Moratto 1984:189; Parr and Osborne 1992:47). It is distinguished by increased sedentism and extensive seed and plant exploitation. Millingstones, shaped through use, were abundant. Bedrock manos and metates were the most prevalent types of millingstones (Parr and Osborne 1992:45). The central valley began to develop distinct cultural variations, which can be distinguished by different regions throughout the valley, including Kern County.

In the Post-Archaic period enormous cultural variations began manifesting themselves throughout the entire San Joaquin Valley. This period extends into the contact period in the seventeenth, eighteenth and nineteenth centuries. Sedentary village life was emblematic of the Post-Archaic period, although hunting and gathering continued as the primary subsistence strategy. Agriculture was absent in California, partially due to the dense, predictable, and easily exploitable natural resources. The ancestral Yokuts have possibly been in the valley for the last three thousand years, and by the eighteenth century were the largest pre-contact population, approximately 40,000 individuals, in California (Moratto 1984). 9 Figure 2
Project Area, View towards the Southeast
Figure 3
Project Area, View towards the Northwest
10 6.0 Ethnographic Background
The Yokuts are a Penutian-speaking, non-political cultural group. Penutian speakers inhabit the San Joaquin Valley, the Bay Area, and the Central Sierra Nevada Mountains. The Yokuts are split into three major groups, the Northern Valley Yokuts, the Southern Valley Yokuts, and the Foothill Yokuts.

The southern San Joaquin Valley in the Fresno area was home to the Yokuts tribelet, Choinumne. The tribelet had approximately 500 people, had a special name for themselves, and spoke a unique dialect of Yokuts. Land was owned collectively, and every group member enjoyed the right to utilize food resources. The Choinumne occupied the west bank of the Kings River, south of Dry Creek (Latta 1999).

The Southern Valley Yokuts had a mixed economy emphasizing fishing, hunting, fowling, and collecting shellfish, roots, and seeds. Fish were the most prevalent resource and was a productive activity throughout the entire year. Fish were caught in many different manners, including nets, conical basket traps, catching with bare hands, shooting with bows and arrows, and stunning fish with mild floral toxins. Geese, ducks, mud hens and other waterfowl were caught in snares, long-handled nets, stuffed decoys, and brushing brush to trick the birds to fly low into waiting hunters. Mussels were gathered and steamed on beds of tule. Turtles and dogs were consumed (Wallace 1978:449-450).

Wild seeds and roots provided a large portion of the Yokuts’ diet. Tule seeds, grass seeds, fiddleneck, alfilaria were also consumed. Acorns, the staple crop for many California native cultures, were not common in the San Joaquin Valley. Acorns were traded into the area. Land mammals, such as rabbits, ground squirrels, antelope and tule elk, were not taken often (Wallace 1978:450).

The Yokuts occupied permanent structures in permanent villages for most of the year.

During the late and early summer, families left for several months to gather seeds and plant foods, shifting camp locations when changing crops. Several different types of fiber-covered structures were common in Yokuts settlements. The largest was a communal tule matcovered, wedge-shaped structure, which could house upward of ten individuals. These structures were established in a row, with the village chief’s house in the middle and his messenger’s houses were located at the ends of the house row. Dance houses and assembly buildings were located outside the village living area (Nabokov and Easton 1989:301).

The Yokuts also built smaller, oval, single-family tule dwellings. These houses were covered with tall mohya stalks or with sewn tule mats. Bent-pole ribs that met a ridgepole held by two crotched poles framed these small houses. The Yokuts also built a cone-shaped dwelling, which was framed with poles tied together with a hoop and then covered with tule or grass. These cone-shaped dwellings were large enough to contain multiple fireplaces (Nabokov and Easton 1989:301). Other structures included mat-covered granaries for storing food supplies, and a dirt-covered, communally owned sweathouse.

Clothing was minimal, men wore a breechclout or were naked. Women wore a narrow-fringed apron. Cold temperatures brought out rabbitskin or mud hen blankets.

Moccasins were worn in certain places; however, most people went barefoot. Men wore no 11 head coverings, but women wore basketry caps when they carried burden baskets on their heads. Hair was worn long. Women wore tattoos from the corners of the mouth to the chin; both men and women had ear and nose piercings. Bone, wood or shell ornaments were inserted (Wallace 1978:450-451).

Tule dominated the Yokut’s material culture. It was used for many purposes, including sleeping mats, wall coverings, cradles, and basketry. Ceramics are uncommon to Yokuts culture as is true throughout most California native cultures. Basketry was common to Yokuts culture. Yokuts made cooking containers, conical burden baskets, flat winnowing trays, seed beaters, and necked water bottles. Yokuts also manufactured wooden digging sticks, fire drills, mush stirrers, and sinew-backed bows. Knives, projectile points, and scraping tools were chipped from imported lithic materials including obsidian, chert, and chalcedony. Stone mortars and pestles were secured in trade. Cordage was manufactured from milkweed fibers, animal skins were tanned, and awls were made from bone. Marine shells, particularly olivella shells, were used in the manufacture of money and articles of personal adornment. Shells were acquired from the Chumash along the coast (Wallace 1978:451-453).

The basic social and economic unit was the nuclear family. Lineages were organized along patrilineal lines. Yokuts fathers transmitted totems, particular to each paternal lineage, to each of his children. The totem was an animal or bird that no member would kill or eat and that was dreamed of and prayed to. The mother’s totem was not passed to her offspring; but was treated with respect. Families sharing the same totem formed an exogamous lineage.

The lineage had no formal leader nor did it own land. The lineage was a mechanism for transmitting offices and performing ceremonial functions. The lineages formed two moieties, East and West, which consisted of several different lineages. Moieties were customarily exogamous. Children followed the paternal moiety. Certain official positions within the villages were associated with certain totems. The most important was the Eagle lineage from which the village chief was appointed. A member of the Dove lineage acted as the chief’s assistant. He supervised food distribution and gave commands during ceremonies. Another hereditary position was common to the Magpie lineage, was that of spokesman or crier.

7.0 Historical Overview
Fresno County was settled in the 1850s, soon after California joined the United States after the passage of the Compromise of 1850. The Compromise of 1850 allowed California to join the Union as a free state even though a major portion of the state lied beneath the Missouri Compromise line; and was potentially subject to southern settlement and slavery.

Americans had long been visiting and working in California prior to the admission of California into the Union.

The Spanish moving north from Baja California into Alta California began European settlement of California 1n 1769. Father Junipero Serra, a Franciscan friar founded Mission San Diego de Alcala, beginning California active European settlement. However, Spanish mission efforts were focused on California’s coastal regions. Spanish exploration of the San Joaquin Valley region begins in the 1770s. In 1772, Pedro Fages arrived in the San Joaquin Valley searching for army deserters. Father Francisco Garces, a Franciscan priest, soon visited the vicinity in 1776. The Spanish empire collapsed in 1820, all of Spain’s former Central and South American colonies became independent nations. As a result, California became Mexican 12 territory. California stayed in Mexican hands until the Mexican-American War. Mexican California remained a coastal society with little interest in settling in California’s hot, dry interior valleys.

American exploration of the San Joaquin Valley begins in the 1820s with Jedediah Smith, Kit Carson, and Joseph Walker looking for commercial opportunities. The United States government began exploring California in the 1830s. Soon, the Americans will be searching for intercontinental railroad routes to link the eastern and western halves of the continent.

The defeat of the Mexicans during the Mexican-American War and the subsequent discovery of gold will drastically alter the complicated political realities of the west. The Mexican-American War was ostensible fought to settle a boundary dispute with the Mexicans over the western boundary of the newly-annexed state of Texas, which had fought a successful rebellion against the Mexican Army in the mid 1830s. The Republic of Texas was an independent country for nine years until Texas was annexed by the United States in 1845. One major outcome of the Mexican-American War was that Mexico rescinded its claims to much of the American southwest. In 1848 these territories were folded into the United States, including California.

In January 1848, the discovery of gold in Coloma, California changed the settlement of California, forever. In the summer of 1848, when the gold strike was publicly announced, the overnight settlement of California began. The Mexican population of California was small and limited to the coasts and a few of southern California’s interior valleys. A sizable native population settled the remainder of California; Fresno County was Yokuts territory. The Gold Rush tipped the balance of native communities throughout California, as many of California’s natives were decimated.

In 1856, Fresno County was created from the northern half of Tulare County. The first county seat was at Millerton. Anthony Easterby established a wheat farm in 1867 in what would become Fresno. By 1871, he created an irrigation system and in 1872, the Central Pacific Railroad established a nearby rail stop. By 1885, Fresno had grown to the point that it incorporated as a city.

While farmers were settling the valley, cattle ranchers, timber mill operators, and resort operators settled the heavily timbered highlands of the southern Sierra Mountains. Road builders, such as John Jordan, opened the mountains, following native (Yokuts) trails into the mountains. By 1865, timber mills were found in the general vicinity, and were responsible for opening areas for settlement and for providing lumber to fuel the local economy. Cattle ranchers and shepherds grazed their animals throughout the region until 1903, when the laws changed.

As access to the San Joaquin Valley was secured via new and better roads, the mountains opened to permanent settlements. Small towns were established, such as Springville. Avon M. Coburn founded Springville in 1890. Coburn established a box factory and sawmill along the Tule River, near where Bear Creek empties into the middle fork of the Tule River. Springville flourished connecting the Tule River valley to the San Joaquin Valley via the wagon road to Porterville, which had been established in 1864. 13 As the areas to the west grew, the need for steady economical power arose. Albert Wishon, a local real estate agent, convinced the new (1895) San Joaquin Power Company, (later the San Joaquin Light and Power Company), which later merged with Pacific Gas and Electric Company in 1930, to build a hydroelectric dam on the Tule River in 1900. The pack road east of Springville was upgraded to a wagon road, and Camp Wishon was established as a construction camp, located below the Doyle Ranch. Construction on the power plant began in 1904. The power plant not only provided reliable power to the San Joaquin Valley to the west, but also opened areas to the east.

8.0 Field Procedures and Methods
On November 12-13, 2024, Scott M. Hudlow (for qualifications see Appendix I) conducted a pedestrian archaeological survey of the entire proposed project area. Hudlow surveyed in north/south transects across the lot in 10-meter (33 feet) intervals.

9.0 Report of Archaeological Findings
No cultural resources were identified.

10.0 Management Recommendations
At the request of Crawford and Bowen Planning, a Phase I Cultural Resource Survey was conducted at the southwest corner of Armstrong Avenue and the San Joaquin Valley Railroad Right-of-Way, in the City of Fresno, California for Tract 7376. The Phase I Cultural Resource Survey consisted of a cultural resource survey and a cultural resource record search.

11.0 References
Latta, Frank F.
1999 Handbook of Yokuts Indians. Coyote Press, Salinas, California.

Moratto, Michael J.
1984 California Archaeology. Academic Press, Orlando, Florida.

Nabokov, Peter and Robert Easton
1989 Native American Architecture. Oxford University Press, New York, New York. 14 Parr, Robert E. and Richard Osborne
1992 Route Adoption Study for Highway 58, Kern County, California. Report on file, Southern San Joaquin Archaeological Information Center, California State University, Bakersfield, Bakersfield, California.

Wallace, William J.
1978 "Southern Valley Yokuts" in Handbook of North American Indians. Vol. 8, California, Robert F. Heizer, ed. Washington, D.C.: Smithsonian Institution, pp. 437-445.

Warren, Claude N. and M. B. McKusiak
1959 A Burial Complex from the southern San Joaquin Valley. Los Angeles: University of California, Los Angeles, Archaeological Survey Annual Report, 1959: 17-26.

Warren, Claude N.
1967 "The San Dieguito Complex: A Review and Hypothesis" American Antiquity 32(2):
168-185.
15 Appendix I
16 17
Scott M. Hudlow
1405 Sutter Lane
Bakersfield, California 93309
(661) 834-9183
Education
The George Washington University
M.A. American Studies, 1993
Specialization in Historical Archaeology
and Architectural History
University of California, Berkeley
B.A. History, 1987
B.A. Anthropology, 1987
Specialization in Historical Archaeology
and Colonial History
Public Service
3/94-12/02 Historic Preservation Commission. City of Bakersfield, Bakersfield, California 93305. 7/97-12/01 Newsletter Editor. California History Action, newsletter for the California Council for the Promotion of History.

Relevant Work Experience
8/96- Adjutant Faculty. Bakersfield College, 1801 Panorama Drive, Bakersfield, California, 93305. Teach History 17A, Introduction to American History and Anthropology 5, Introduction to North American Indians.

Owner, Sole Proprietorship. Hudlow Cultural Resource Associates. 1405 Sutter Lane, Bakersfield California 93309. Operate small cultural resource management business. Manage contracts, respond to RFP's, bill clients, manage temporary employees. Conduct Phase I archaeological and architectural surveys for private and public clients; including the cultural resource survey, documentary photography, measured drawings, mapping of structures, filing of survey forms, historic research, assessing impact and writing reports.

Evaluated archaeological and architectural sites and properties in lieu of their eligibility for the National Register of Historic Places in association with Section 106 and 110 requirements of the National Historic Preservation Act of 1966 and CEQA (California Environmental Quality Act).

Full resume available upon request.
18 19
Appendix II
20 21
22 23
24 25

PHASE I ENVIRONMENTAL SITE ASSESSMENT
FOR

SIMONIAN ESTATES
APNS: 316-160-16S, -17S, -43S, -59S, AND -61S
1099, 1139, AND 1183 SOUTH ARMSTRONG AVENUE
FRESNO, CALIFORNIA 93727
for
KB Home Central California
744 P Street, Suite 321
Fresno, California 93721
October 27, 2023
Project Number 07-230797-1
3897 North Ann Avenue, Fresno, CA 93727 | T: 559.708.8865 | F: 559.228.9488 | www.rmacompanies.com October 27, 2023 Project No. 07-230797-1
KB Home Central California
744 P Street, Suite 321
Fresno, California 93721
Attention: Mr. Zach Gomes
[email protected]
Subject: Phase I Environmental Site Assessment
Simonian Estates
APNs: 316-160-16s, -17s, -43s, -59s, and -61s
1099, 1139, and 1183 South Armstrong Avenue
Fresno, California 93727
Dear Mr. Gomes;
Pursuant to your request and authorization, a Phase I Environmental Site Assessment has been performed at the subject property in accordance with the current Standard of Practice for Phase I Environmental Site Assessments per the ASTM: E1527-21 guidelines. This report is presented for the sole use of the KB Home Central California and their representatives and/or associates to use as an indication whether hazardous materials and or soil contamination may be present on the subject property. This report may not contain sufficient information for other uses.

If you have any questions regarding the information presented in this report, please do not hesitate to contact our office. We appreciate the opportunity to be of service to you.

Sincerely,
RMA GeoScience, Inc.

Jim Vue, GIT Josue A. Montes, GE 2904
Staff Geologist Principal Engineer
Distribution: Addressee (1 pdf copy to [email protected]) Simonian Estates October 27, 2023
Fresno, California RMA No. 07-230797-1

TABLE OF CONTENTS

1.0 INTRODUCTION................................................................................................................................................................1

1.1 Purpose..................................................................................................................................................................1

1.2 Site Location and Description ................................................................................................................................1

1.3 Scope of Work........................................................................................................................................................1

1.4 General Limitations and Exceptions.......................................................................................................................2

1.5 Special Terms and Conditions................................................................................................................................3

1.6 User Provided Information ....................................................................................................................................3

2.0 SITE OVERVIEW................................................................................................................................................................4

2.1 Site Observations...................................................................................................................................................4

2.1.1 Exterior Observations ........................................................................................................................................4

2.2 Hazardous Substances & Petroleum Containers/Products....................................................................................4

2.3 Aboveground Storage Tanks (ASTs).......................................................................................................................4

2.4 Underground Storage Tanks (USTs).......................................................................................................................5

2.5 Polychlorinated Biphenyls (PCBs) ..........................................................................................................................5

2.6 Stressed Vegetation, Pits, Ponds and Lagoons and Standing Water .....................................................................5

2.7 Solid Waste, Mounds, or Depressions Suggesting Trash or Solid Waste Disposal.................................................5

2.8 Wastewater or Stormwater...................................................................................................................................5

2.9 Existing or Abandoned Oil and Water Wells..........................................................................................................5

2.10 Septic Systems ......................................................................................................................................................5

2.11 Railroad Lines or Spurs..........................................................................................................................................6

2.12 Site Reconnaissance of Adjacent Properties..........................................................................................................6

2.13 Current Site Use.....................................................................................................................................................6

2.14 Drains and Sumps ..................................................................................................................................................6

3.0 GEOLOGY AND HYDROGEOLOGY .....................................................................................................................................6

3.1 Geology ..................................................................................................................................................................6

3.2 Hydrogeology.........................................................................................................................................................7

4.0 RESULTS OF RECORDS SEARCH ........................................................................................................................................7

4.1 Aerial Photograph Review .....................................................................................................................................7

4.2 Sanborn Map Review...........................................................................................................................................10

4.3 Topographic Map Review ....................................................................................................................................10

4.4 Governmental Agency Database Review.............................................................................................................12

4.4.1 Target Property Search Results........................................................................................................................13

4.4.2 Surrounding Facilities Search Results ..............................................................................................................14

4.5 City Directory Review...........................................................................................................................................15

4.6 State and Local Agencies......................................................................................................................................16

5.0 INTERVIEWS ...................................................................................................................................................................16

5.1 Present Owner.....................................................................................................................................................16

6.0 FINDINGS........................................................................................................................................................................17

6.1 Recognized Environmental Conditions................................................................................................................17

6.2 Controlled Recognized Environmental Conditions..............................................................................................17

6.3 Historical Recognized Environmental Conditions................................................................................................17

6.4 Business Environmental Risk ...............................................................................................................................18

6.5 De minimis Conditions.........................................................................................................................................18

6.6 Data Gap and Data Failure...................................................................................................................................18 Simonian Estates October 27, 2023
Fresno, California RMA No. 07-230797-1

7.0 CONCLUSIONS ................................................................................................................................................................19

7.1 Conclusions..........................................................................................................................................................19

8.0 QUALIFICATIONS ............................................................................................................................................................21

9.0 LIMITATIONS ..................................................................................................................................................................21

10.0 REFERENCES.................................................................................................................................................................22 Figures:

Figure 1, Site Vicinity Map
Figure 2, Site Map
Site Photographs
Enclosures:

EDR Radius Report
EDR Aerial Photographs
EDR Topographic Maps
EDR Sanborn Map Report
EDR City Directory Search
User Questionnaire
Interview Questionnaire
Record Requests and Responses
Documents and Reports
Qualifications
Simonian Estates October 27, 2023
Fresno, California RMA No. 07-230797-1

Page 1 ends

Fresno City CouncilJune 26, 2025

Fresno City Council
June 26, 2025