Fresno City Council
August 14, 2025

From: Ben Granholm
To: Clerk; Todd Stermer
Cc: Ethan Smith
Subject: SUPPORT: ID 25-1026 – Crown Enterprises Project Date: Tuesday, August 12, 2025 9:23:11 AM
Attachments: 8.12.25 - INVEST Fresno - Crown Enterprises Letter.pdf External Email: Use caution with links and attachments
On behalf of INVEST Fresno—a coalition of Fresno residents, businesses, and community organizations committed to building a diverse and sustainable economy—we are writing to express our strong support for Annexation Application No. P21-05778; Pre-zone Application No. P21-05870; Development Permit Application No. P23-00149; and the related Environmental Assessment (collectively, the “Crown Enterprises Project”).

The Crown Enterprises Project embodies exactly the kind of investment Fresno should prioritize. Crown Enterprises has a long and respected history in our community. By continuing and expanding its operations here, the company is reaffirming its commitment to Fresno—bringing new jobs, generating additional tax revenue for critical city services, and exceeding environmental standards in the process.

Please don't hesitate to reach out with any questions.

Thank you,
--
Ben Granholm
Executive Director
INVEST Fresno
www.INVESTFresnoCA.com
INVESTFresnoCA.com
August 12, 2025
Mike Karbassi, President Submitted via Email
Fresno City Council
2600 Fresno Street
Room 3065
Fresno, CA 93721
RE: SUPPORT – ID 25-1026 – Annexation Application No. P21-05778; Prezone Application No. P21-05870; Development Permit Application No. P23- 00149; and related Environmental Assessment
Dear Council President Karbassi and City Council,
On behalf of INVEST Fresno—a coalition of Fresno residents, businesses, and community organizations committed to building a diverse and sustainable economy —we are writing to express our strong support for Annexation Application No.

P21-05778; Pre-zone Application No. P21-05870; Development Permit Application No. P23-00149; and the related Environmental Assessment (collectively, the “Crown Enterprises Project”).

The City of Fresno is at a pivotal moment—choosing whether to harness its unique advantages of location and workforce to build a next-generation economy, or risk forfeiting its position as the Valley’s economic leader to neighboring Madera and Tulare counties.

For the past two years, Fresno has faced budget deficits, a challenge tied directly to the strength of our local economy. Attracting new businesses and supporting the growth of existing ones expands and diversifies the city’s tax base, increasing property tax, sales tax, and business license revenue without raising rates on residents. A broader and more stable revenue base is key to sustainable economic development—development that grows city revenues, creates jobs, and enhances quality of life.

The Crown Enterprises Project embodies exactly the kind of investment Fresno should prioritize. Crown Enterprises has a long and respected history in our community. By continuing and expanding its operations here, the company is reaffirming its commitment to Fresno—bringing new jobs, generating additional tax revenue for critical city services, and exceeding environmental standards in the process.

The recent groundbreaking of the Scannell Properties project is a direct example of the types of investments that employers are willing to make in Fresno and its residents. We see firsthand how projects like this create ripple effects that go far beyond the construction site and bring a wide range of jobs to local families, generate revenue to support city services, and send a strong message that Fresno is a place worth investing in. As our community continues to grow, we need more smart, forward-looking development to meet the evolving needs of our people and economy.

SCSP Economic & Community Benefits
South Central Fresno is the city’s economic engine. While fewer than one-quarter of one percent of Fresno’s residents live within the 5,629-acre planning area, this area accounts for 7.5% of the city’s land, generated approximately $13 billion in economic activity in 2022 (35% of the city’s total output), and contributed over $102 million in tax revenue (21% of the General Fund). A full breakdown of these impacts is available at .com/EconomicImpact.

As Fresno addresses budget deficits, strengthening the General Fund through the approval of projects that bring new investment—while retaining and expanding long-standing businesses—benefits all residents. These revenues directly support essential services like public safety, parks, infrastructure improvements, and countless other community programs residents rely on daily.

Air Quality Improvements
The Valley’s geography and climate—surrounded by mountains and subject to temperature inversions—can trap pollutants, leading to high pollution rankings for cities like Fresno, Visalia, and Bakersfield. But the story is not without hope.

Since 1980, emissions from stationary sources have dropped by 85%. Federal regulations have cut mobile source emissions by 99% since 1970, with heavy-duty trucks now roughly 99% cleaner than their 1970 counterparts. Valley residents’ exposure to elevated ozone has fallen by 90%, and fine particulate matter (PM2.5) by 85%, resulting in a 95% reduction in cancer risk from air pollutants, according to the San Joaquin Valley Air Pollution Control District.

Importantly, these dramatic improvements occurred while Fresno’s population grew

2.5 times larger and its economy more than doubled in size—demonstrating that clean air and economic growth can and do work together.

Public Support
A 2024 public opinion survey commissioned by INVEST Fresno—representative of voters across all seven council districts—found overwhelming support for the city’s

From: DePew, Rosa@EDD
To: Clerk
Subject: Prezoning meeting August 14, 2025
Date: Tuesday, August 12, 2025 2:02:32 PM
Attachments: Fresno City Council Prezoning Letter August 12 2025.docx External Email: Use caution with links and attachments
Hello,
Here is a submission for the meeting on August 14, 2025 at 9 AM. Please present to the Fresno City Council
Sincerely,
Rosa DePew
Fresno CA 93706
August 12th, 2025
Fresno City Council
City Hall Council Chamber, 2nd Floor,
2600 Fresno Street, Fresno, CA 93721
Dear Fresno City Council,
My name is Rosa DePew. I am a resident of Fresno County. I am an officer on the school board of Orange Center Elementary. I am writing to you to urge you to deny Annexation Application No.P21-05778, Pre-zone Application No. P21-05870, and Development Permit Application No.

P23-00149 to protect the health, safety, and wellbeing of the students, teachers and staff who attend and work at Orange Center Elementary, and of the residents who live on Cherry Ave, Daleville, and surrounding disadvantaged unincorporated communities. I oppose this project because I am concerned about the impacts to our air quality from the emissions of heavy-duty truck traffic, traffic safety concerns, especially for the families commuting to Orange Center Elementary, and the longer-term implications of industrial development less than a mile away from an elementary school.

The proposed annexation, prezoning to heavy industrial, and development permit for Central Transport in South Central Fresno will exacerbate already poor environmental and health conditions in the community. Conditions in South Central Fresno are so critical that the community of South Central Fresno was selected as one of the first communities for the AB 617 Community Air Protection Program to develop a Community Emissions Reduction Program and the Community Air Monitoring Program. The community of South Central Fresno worked for at least a year to develop strategies to reduce emissions including rerouting truck traffic from Cherry Ave. The community has also heavily engaged in and pushed for the development and adoption of a South Central Specific Plan to provide safeguards to protect residents from further industrial development. At this point, the City should be working to address existing issues instead of considering more projects that will create a larger impact to residents.

In 2024, the City of Fresno conducted a Health Impact Assessment (HIA) which found that South Fresno residents were more likely to live closer to a major street, truck route, or freeway, and as a result residents were more exposed to PM 2.5, ozone, and diesel particulate matter. The HIA found that South Central Fresno residents had a significantly higher risk of experiencing a pre-term birth and infant mortality. Emergency room visits or hospitalization due to asthma or cardiovascular issues were found to be more prevalent in South Central Fresno than in other areas of the City, specifically for residents living within 1000 feet of a highway or truck route. In fact, residents in South and Southwest Fresno have a 20 year less life expectancy than residents in other areas of Fresno.

My experience living near industrial operations has contributed or impacted me by health issues that plagued my family members. My brothers, sister and father all died at a younger age after dealing with health issues that were worsened by air quality and contamination. My mother is dealing with health issues currently.

Our area of town may be seen to many as an undesirable area to live in. Modest homes with bad roads and bad air pollution to breathe. But we are proud humble people. We strive to live our lives humbly and respectfully and to contribute to the community. Our area has contributed many successful people to the community. Many are now doctors, lawyers, teachers, and respectful citizens of the community. South Central Fresno deserves to be treated with respect.

South Central Fresno needs to be allowed to continue to raise bright, healthy, contributing members of society. Please, for the sake of disadvantaged communities, stop industrial growth in South Central Fresno. Keep our communities safe and healthy! Again, I urge you to please deny Annexation Application No.P21-05778, Pre-zone Application No. P21-05870, and Development Permit Application No. P23-00149 to protect the community of South Central Fresno from continued industrial growth in our backyards.

Rosa DePew
Fresno CA 93706

August 13, 2025
Via E-Mail only
Mayor Dyer and
Members of the City Council
City of Fresno
2600 Fresno Street
Fresno, California 93721
[email protected]
Re: Comments on the Annexation, Rezoning, and Development Application for the Central Transport Regional Facility and related Initial Study/Mitigated Negative Declaration-Environmental Assessment No.P21-05778/P21- 05870/P23-00149
Mayor Dyer and Members of the City Council:

On behalf of the South Fresno Community Alliance (“SFCA”), we have reviewed the Initial Study/Mitigated Negative Declaration (“MND”) prepared in connection with the proposed Annexation Application No. P21-05778; Pre-zone Application No. P21- 05870; Development Permit Application No. P23-00149 for the Central Transport Regional Facility (“CTRF Project”).1 SFCA has serious concerns about the environmental impacts of the Project as currently proposed. As discussed below, the proposed CTRF Project and other future Heavy Industrial facilities would be located within .27 miles of Orange Elementary School and several residential communities.

Although there are residences located across the road from the CTRF Project site, and an elementary school only .27 miles away, the MND makes no meaningful effort to direct traffic away from these sensitive receptors or to decrease project emissions. Add Cite to Map. The Project’s environmental documentation should have included additional mitigation measures and an alternatives analysis to minimize the Project’s impacts, 1 Throughout this letter we refer to the proposed annexation/pre-zone/development permit applications together as the “Project” and we refer to the development permit application as the “CTRF Project.”
Mayor Dyer and Members of the City Council
August 13, 2025

including public safety, air pollution and noise impacts. Such alternatives—including a reduced scale alternative—would ensure that these impacts to existing residents and children are reduced.

The current MND for the Project violates the minimum standards for an environmental document under the California Environmental Quality Act (“CEQA”), Public Resources Code § 21000 et seq., and the CEQA “Guidelines,” California Code of Regulations, title 14, § 15000 et seq. As discussed below, the MND fails to adequately describe the existing conditions or the whole of the Project—including the entirety of the proposed annexation—fails to analyze the full range and severity of environmental impacts, including potentially significant effects related to transportation and public safety, air quality, noise, and loss of agricultural land; and fails to adequately mitigate for significant impacts. See Exhibit N to the Planning Commission June 18, 2025 Staff Report (containing the MND). All of these impacts must be more fully addressed and mitigated before the City may approve the Project.

In addition, as discussed throughout this letter, evidence in the record presents a fair argument that the Project will result in significant impacts that require that the City prepare an EIR so that the public and decision-makers receive a proper analysis of the Project’s significant environmental impacts and feasible mitigation for those impacts. See CEQA Guidelines § 15002(a)(1) (listing as one of the “basic purposes” of CEQA to “[i]nform governmental decision makers and the public about the potential, significant environmental effects of proposed activities”).

I. The City May Not Approve the Project Without Preparing an Environmental Impact Report Under CEQA.

CEQA is designed to ensure that “the long-term protection of the environment shall be the guiding criterion in public decisions.” Friends of College of San Mateo Gardens v. San Mateo County Community College District (2017) 11 Cal.App.5th 596, 604 [ “San Mateo Gardens II”] (quoting No Oil, Inc. v. Los Angeles (1974) 13 Cal.3d 68, 74). An agency evaluating a project’s environmental impacts must develop an EIR whenever “substantial evidence supports a fair argument that a proposed project ‘may have a significant effect on the environment.’” Committee for Re-Evaluation of T-Line Loop v. San Francisco Municipal Transportation Agency (2016) 6 Cal.App.5th 1237, 1245-46 (quoting Laurel Heights Improvement Assn. v. Regents of University of California (1993) 6 Cal.4th 1112, 1123).

The fair argument standard establishes a “low threshold” for requiring a lead agency to prepare an EIR. Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 928. Courts “owe no deference to the lead agency’s determination,” and Mayor Dyer and Members of the City Council
August 13, 2025

judicial review must show “a preference for resolving doubts in favor of environmental review.” Id. (italics in original). Further, where the agency fails to study an entire area of environmental impacts, deficiencies in the record “enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences.” Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 311.

Substantial evidence supporting a fair argument may consist of personal observations of local residents on nontechnical subjects (Oro Fino Gold Mining Corp. v.

Cty. of El Dorado (1990) 225 Cal.App.3d 872, 882; Protect Niles v. City of Fremont (2018) 25 Cal.App.5th 1129, 1152) as well as expert opinion supported by facts—even if that opinion is not based on a specific analysis of the project at issue (Pocket Protectors, 124 Cal.App.4th at 928). In marginal cases, where it is not clear whether there is substantial evidence that a project may have a significant impact and there is a disagreement among experts over the significance of the effect on the environment, the agency “must treat the effect as significant” and prepare an EIR. CEQA Guidelines § 15064(g); City of Carmel-By-The-Sea v. Board of Supervisors, (1986) 183 Cal.App.3d 229, 245.

As discussed below, ample evidence supports a “fair argument” that the Project may result in significant environmental impacts that were not properly analyzed and mitigated in the MND. Potentially significant impacts not adequately analyzed in the MND include, but are not limited to, transportation and public safety, air quality, noise, and loss of agricultural land. Because the Project has the potential to result in significant impacts, the City is required to prepare an EIR before it may approve the Project.

The MND’s failings will most directly and significantly impact low-income, disadvantaged residents and communities in South Fresno, especially communities of color. The City must prepare an EIR to provide the community and the broader public an accurate assessment of the environmental issues at stake, and a mitigation strategy— developed before Project approval—that fully addresses the Project’s significant impacts.

The City must also take a serious look at alternatives that can avoid or lessen most of the Project’s significant impacts.

II. The MND’s Flawed Description of the Existing Environmental Setting and the Proposed Project Does Not Permit Meaningful Environmental Review.

A. Existing Setting
The MND fails to describe the Project’s environmental setting as required by CEQA. An environmental document “must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice Mayor Dyer and Members of the City Council
August 13, 2025

of preparation is published, or if a notice of preparation is not published, at the time environmental analysis is commenced, from both a local and regional perspective.” CEQA Guidelines § 15125(a). This description of the environmental setting constitutes the baseline physical conditions against which a lead agency determines the significance of an impact. Id. “Knowledge of the regional setting is critical to the assessment of environmental impacts.” CEQA Guidelines § 15125(c). Without such an understanding, any impacts analysis or proposed mitigation becomes meaningless.

Accurate and complete information pertaining to the setting of the project and surrounding uses is critical to an evaluation of a project’s impact on the environment. San Joaquin Raptor/Wildlife Center v. Stanislaus County, 27 Cal.App.4th 713, 728 (1994); see also Friends of the Eel River v. Sonoma County Water Agency, 108 Cal.App.4th 859, 875 (2003) (incomplete description of the Project’s environmental setting fails to set the stage for a discussion of significant effects). Here, the MND’s deficiencies in describing the Project’s environmental setting undermine its adequacy as an informational document.

The MND fails to present important contextual information related to residential communities in the area around the Project. For example, the MND disregards existing residences located immediately adjacent to the proposed Project site. Instead, the MND skips over a description of the existing setting and highlights planned uses, existing zoning, and existing uses (which do not acknowledge all of the residences). MND at PDF p. 9. The MND’s analysis of the Central Transport Regional Facility’s potential to change the visual character of the area similarly states that the “proposed site is located in an industrialized area, within and adjacent to the City, surrounded primarily by commercial logistics, warehouses, and auto repair businesses.” MND at PDF p. 17. As discussed below, this is a blatant mischaracterization of the area surrounding the proposed development site.

The proposed CTRF facility would be located in close proximity to several residential communities, with several residences located immediately adjacent and across the street from the facility. Attach. A, Figure Showing Residential Areas near CTRF Project site and whole annexation/rezoning area. These and other nearby communities have been designated as “Disadvantaged Communities” by the California Office of Health Hazard Assessment (“OEHHA”).2 Attach. B, CalEnviroScreen Data for Census Tracts 6019001500, 6019001700, and 6019001800. The census tracts surrounding the Project site and nearby designated truck routes predominantly identify as Hispanic, and 2 See Disadvantaged Communities Map, California Office of Environmental Health Hazard Assessment, available at https://oehha.maps.arcgis.com/apps/View /index.html?appid=c3e4e4e1d115468390cf61d9db83efc4.

Mayor Dyer and Members of the City Council
August 13, 2025

are already heavily burdened by pollution—particularly ozone, PM2.5, and diesel emissions. Id.3 Local residents rank in the 90th-100th percentile for pollution burden and experience high levels of asthma, poverty, unemployment, and housing burden.4 Moreover, the community of Daleville, located just one-half mile south of the CTRF Project site, is designated as a Disadvantaged Unincorporated Community (“DUC”) in the Local Agency Formation Commission (LAFCO) Disadvantaged Unincorporated Communities Database.5 Attach. N LAFCO Disadvantaged Unincorporated Communities Database at p. 13. Accordingly, nearby residents are those most at risk of environmental harm from the proposed Project. Notwithstanding these data, the MND fails to take these neighbors into account.

In addition, the MND fails to incorporate critical findings from the Truck Reroute Study, and its associated Fresno Health Impact Assessment (“Fresno HIA”) by UC Merced regarding the severity of existing air quality and health risk conditions in the South Fresno and City of Fresno as a whole. See South Central Fresno AB 617 Community Truck Reroute Study Truck Routing and Implementation Strategies Report April 2024, attached as Attach. C and Fresno Community Environmental Health Impact Assessment, April 2024, attached as Attach. D. Cherry Avenue is identified as a Citydesignated truck route in the Fresno 2005 Truck Route Map. However, Cherry Avenue is only designated a truck route for the section under City jurisdiction. Attach. C at 28.

Notably, the proposed truck reroute map removes Cherry Avenue as a designated truck route, thus traffic calming on Cherry Ave. would require diverting trucks altogether. Id. at Figure 4 (showing no “Future Planned Route” on Cherry Avenue south of North Avenue). Removing Cherry Avenue as a designated truck route is supported by the Fresno HIA, which recommends developing truck routes outside of a 1,000 foot buffer from areas where people live, work, and play. See, Attach. D Fresno HIA at 34. Approval of the Project would be directly counter to this recommendation, which was adopted in recognition of the existing pollution burden on South Fresno residents. 3 Data may be viewed by clicking on individual census tracts, including but not limited to census tracts 6019001500, 6019001700, and 6019001800. For convenience, selected data for these tracts are attached hereto as Attach. B.
4 Id.
5 Northeast Cherry and Central (Atkins Tract): This DUC is also known as “Daleville” and it consists of 42 properties. LAFCo estimates that there are 42 dwelling units located in an area of approximately 26 acres; the community has 68 registered voters. The Median Household Income was $38,973 between 2012 and 2016. The DUC is located within the Fresno SOI at the northeast corner of Cherry Avenue and Central Avenue.

Mayor Dyer and Members of the City Council
August 13, 2025

In addition, The research conducted in the HIA found that South Fresno residents were more likely to live closer to a major street, truck route, or freeway, and as a result residents were more exposed to PM 2.5, ozone, and diesel pm. The HIA found that South Central Fresno residents had a significantly higher risk of experiencing a pre-term birth (PTB) and infant mortality (IM). Emergency room visits or hospitalization due to asthma or cardiovascular issues were found to be more prevalent in South Central Fresno than in other areas of the City, specifically for residents living within 1000 feet of a highway or truck route. The HIA also found that 43% of residents reported having at least one chronic health condition, According to the HIA, women of reproductive age (18-46 years) reported having an adverse pregnancy outcome, such as miscarriage (22%), stillbirth (3%), infant mortality (0.8%), or having a child with a birth defect (1.6%)6 Moreover, a 2015 health risk assessment prepared for the Downtown Neighborhoods Community Plan (DNCP), which is immediately adjacent to the South Central Fresno area, showed particulate matter concentrations from vehicle emissions near SR 99, SR 41, and SR 180 in the DNCP area indicate existing cancer risk to sensitive receptors exceeds 100 in a million at distances from 1,000 to 5,000 feet from the freeways. By omitting data and recommendations from these reports, the MND failed to incorporate information about the existing poor air quality conditions and impacts in the Project area. Describing these existing conditions is critical because they affect analysis of multiple issues, including cumulative impacts to air quality, public health, and public safety, among others.

As a result of these incomplete baseline characterizations, it is not possible to accurately determine the full scope or extent of the physical impacts that would result from the Project, which violates CEQA. The MND’s inaccurate description of the Project’s environmental setting frustrates the core goals of CEQA: to allow intelligent public participation and to provide an adequate environmental impact analysis. See County of Inyo v. City of Los Angeles, (1977) 71 Cal.App.3d 185, 197.

B. Project Description
Under CEQA, a clear and comprehensive description of the proposed project is critical to meaningful public review. County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 193. “An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient” environmental document. San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 730 (quoting County of Inyo v. City of Los Angeles (1997) 71 Cal.App.3d 185, 193). As a 6 See, Attach D Fresno Community Environmental Health Impact Assessment April 2024, University of California Merced. Pg.8.

Mayor Dyer and Members of the City Council
August 13, 2025

result, courts have found that, the use of a “truncated project concept” violates CEQA and mandates the conclusion that the lead agency did not proceed in a manner required by law. Id.

Furthermore, “[a]n accurate project description is necessary for an intelligent evaluation of the potential environmental effects of a proposed activity.” Id. (citation omitted). Thus, an inaccurate or incomplete project description renders the analysis of environmental impacts inherently unreliable. While extensive detail is not necessary, the analysis should describe proposed projects with sufficient detail and accuracy to permit informed decision-making. See CEQA Guidelines §15124.

Here, the MND’s description of the Project is critically flawed for multiple reasons. First, and most egregiously, the MND fails to provide any description of the annexation beyond the CTRF Project site (aside from a statement that the Project area would be rezoned to Heavy Industrial) and of potential uses that could be developed once the entire area is annexed. The City has an obligation to describe what types of projects would be allowed under the new zoning, the type of infrastructure likely required, utilities and services likely needed, and other pertinent information.

Under well-settled law, an CEQA document must analyze a planning amendment's maximum development potential. As City of Redlands v. County of San Bernardino explained, "an evaluation of a first phase-general plan amendment must necessarily include a consideration of the larger project, i.e., the future development permitted by the amendment." (2002) 96 Cal.App.4th 398, 409 (emphasis added). Environmental review of potential development allowed by planning enactments must occur. Christward Ministry v. Super. Ct. (1986) 184 Cal.App.3d 130, 194-95; City of Carmel-by-the-Sea v.

County of Monterey (1986) 183 Cal.App.3d 229, 235, 240-41 (an EIR must be prepared for rezoning even if "no expanded use of the property was proposed").

In this case, the proposed rezoning to an IH zoning district would allow the following uses by right on all private property throughout the annexation area:

Motorcycle Riding Club, Maintenance and Repair Services, Construction and Materials Yard (includes Concrete Batch Plants, Storage Yards, and Similar Uses), Custom Manufacturing, Freight/Truck Terminals and Warehouses, and Major Utilities. See Fresno Municipal Code Table 15-1302: Land Use Regulations – Employment Districts.

The rezoning needs to be analyzed for the foreseeable impacts resulting from the development of uses allowed in the zoning district. Rezoning to IH zoning will allow this area to transition in the same way as a number of adjacent uses. Similar uses within a one-mile radius of the proposed rezoning area, include numerous warehouse and logistics facilities, including Federal Express, Amazon, Kraft Foods, and Home Depot Distribution Center. All of these facilities, generate enormous amounts of truck traffic and related Mayor Dyer and Members of the City Council
August 13, 2025

noise and emissions. An EIR for the Project must include a description and impact analysis for the annexation and rezoning of the whole area.

Second, the MND fails to provide a stable, accessible project description at the start of the Initial Study as CEQA requires. Spreading a project description across multiple chapters and hiding the basic elements of the proposed action in appendices is impermissible. San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 659 (“decision makers and [the] general public should not be forced to sift through obscure minutiae or appendices in order to ferret out” fundamental aspects of the project’s description); Vineyard, supra, 40 Cal.4th at 442 (“[I]nformation ‘scattered here and there in EIR appendices,’” or a report “buried in an appendix,” is not a substitute for “a good faith reasoned analysis”). The MND’s fractured, cryptic and muddled project description frustrates CEQA’s goal of making the agency’s decision-making accessible to the public. Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 392.

The MND does precisely what the courts have explicitly struck down. It presents a skeletal description of the Project at the beginning of the MND that offers scant information beyond the approvals being sought. The MND’s project description lists the acreage and Accessor Parcel Numbers for the parcels being rezoned, the square footage of the various CTRF buildings proposed, and three paragraphs that briefly describe the fuel system, the proposed operating hours, the assumed number of truck and car trips, and one sentence regarding project operations. Additional information is scattered throughout the 889 pages of the MND. For instance, not until PDF page 195, in an attachment, does the MND include a proposed site plan. Similarly, the CTRF Project construction schedule is found on PDF page 140 and the construction equipment at PDF page 141. This approach hinders the reader’s review of the Project.

In some cases, project features are not described at all. For example, the MND fails to describe what the facility will look like. No visual simulations, elevations, or information on building materials is provided. The MND states that “[D]etailed 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” and that the plans shall be required prior to issuance of any building permits. MND at PDF p. 17. The time for the City to gather information about what the CTRF Project will look like is now, not after project approval when it is too late for the public and decisionmakers to review and comment on the CTRF Project.

Moreover, this lack of information about how the Project will look implicates the MND’s aesthetics analysis. Specifically, the MND’s analysis of potential changes to visual character and other visual impacts is deficient in part due to the omitted details.

Mayor Dyer and Members of the City Council
August 13, 2025

The MND’s assertion that “Developments such as those proposed by the Project are typical of large city industrialized areas and are generally expected from residents of the City” does not relieve the City from the obligation of analyzing the impacts from proposed and foreseeable development. MND at PDF p. 17. Therefore, the MND’s analysis of the Project’s impacts to visual character is inadequate and an EIR for the Project must evaluate these impacts.

In another example, the MND indicates that the Project will include street lighting and landscaping, but fails to include information on either one. MND at PDF p.79. Once again, project details, such as lighting design, should have been disclosed as part of this MND so that the public and decision-makers can understand the planned illumination for the site. Lighting on the site would affect light and glare experienced by nearby residents, yet these impacts cannot be evaluated because the lighting design has not been included.

Similarly, the MND states that landscaping will provide visual screening of the CTRF Project facility from vehicles travelling along S. Cherry Avenue, yet these impacts cannot be evaluated with a landscape plan.

In other cases, the MND makes vague references regarding key Project features.

For example, the MND states that the construction of a sidewalk and bike lanes will close gaps in pedestrian and bicycle access. MND at PDF p. 106. However, the MND fails to provide any information on where these features are located or how these features would connect to other facilities. In another example, the site plan shows a “Proposed Temporary Basin”, but the MND text never mentions this project feature, let alone provide any details about how it would operate. MND at PDF p. 195.

Similarly, the MND does not disclose the amount of impervious surfaces resulting from construction of the CTRF Project or provide information on the design and construction of the associated drainage system. Thus, the MND provides no evidence to support the conclusion that development project runoff would not result in flooding and that it would not exceed the capacity of stormwater drainage systems or result in sources of polluted runoff. MND at PDF p. 86. The MND states that:
“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.”
MND at PDF p. 122. However the MND fails to include the referenced SWPPP or the Water Quality Management Plan, nor does it indicate what kinds of BMPs will be Mayor Dyer and Members of the City Council
August 13, 2025

required. These omissions render the project description incomplete and result in deferred analysis, which is also impermissible. Sundstrom, 202 Cal.App.3d at 306-07.

Moreover, the MND indicates that the applicant will move all operations from their existing location at 2440 East Church Avenue to the proposed CTRF Project site.

Fresno Planning Commission Agenda, June 18, 2025, Supplemental Exhibit Q – Staff Presentation at slide 9. The applicant’s existing operation appears to have 26 dock doors.

See Attach. E, Google Aerial image and Google Streetview Map. However, despite the fact that the Site Plan provided in the MND is barely legible, careful review reveals that the proposed CTRF facility would have 106 doors, which is four times the capacity of the existing facility. MND at PDF p. 195. The MND fails to mention this expansion of the applicant’s operation capacity, which is a key feature for determining transportation, air quality, and noise impacts.

The failure to describe the whole of the Project is a serious and pervasive deficiency in the MND’s environmental impact analyses and discussion of potential mitigation measures and alternatives to minimize those impacts. The City must prepare an EIR for the Project and provide a sufficient description of off-site improvements associated with the Project, information regarding required plans to minimize Projectrelated construction and operational impacts, details of anticipated construction activities, and any other Project details. This information is necessary for decision makers, the public and responsible agencies to evaluate potential environmental impacts.

III. The MND Fails to Adequately Analyze or Mitigate the Project’s Impacts.

As explained below, the MND fails to adequately analyze the Project’s numerous environmental impacts, including those affecting air quality, noise, and public health and safety. This is in large part because the MND fails to consider the impacts of annexing all of the 81 acres included in the Project. These inadequacies require that the City prepare an EIR so that the public and decision-makers receive a proper analysis of the Project’s significant environmental impacts and feasible mitigation for those impacts.

A. The MND Fails to Evaluate the Impacts Related to Annexing and Rezoning the Project Area to Heavy Industrial Uses and There Is a Fair Argument that the Project May Have Significant Environmental Impacts.

While the whole of the Project is to annex 81 acres and rezone 51.72 acres from Limited Agriculture (AL-20) to Heavy Industrial/Annexed Rural Residential Transitional Overly (IH), the impact analysis solely assesses the potential impacts of the proposed development site (the CTRF Project), which is only 15.95 acres. The remaining 35.52 Mayor Dyer and Members of the City Council
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acres that are proposed to be rezoned and annexed into the City of Fresno are completely ignored in the CEQA analysis, despite the fact that with the rezoning, the IH zoning district would allow the following uses by right: Motorcycle Riding Club, Maintenance and Repair Services, Construction and Materials Yard (includes Concrete Batch Plants, Storage Yards, and Similar Uses), Custom Manufacturing, Freight/Truck Terminals and Warehouses, and Major Utilities. See Fresno Municipal Code Table 15-1302: Land Use Regulations – Employment Districts.

This approach is flawed because CEQA requires that an agency take an expansive view of any particular project as it conducts the environmental review for that project.

See McQueen v. Bd. of Directors (1988) 202 Cal.App.3d 1136, 1143 (disapproved on other grounds in Western States Petroleum Assn. v. Superior Court (1995) 9 Cal.4th 559, 570) (term “project” is interpreted so as to “maximize protection of the environment”).

The MND appears to assume that because no specific development is being contemplated on 64.5 acres of the area proposed for annexation (the whole annexation area minus the 15.95-acre CTRF Project development site), that no environmental analysis is required. This assumption is incorrect. Inasmuch as the annexation is the first discretionary approval that will ultimately result in development within the area, this environmental document must analyze the environmental impacts from the development in as detailed a manner as possible.

The City made a similar error last year when the Court struck down the City’s Program EIR that purported to review implementation of the General Plan, an amendment to the General Plan’s Mobility and Transportation Element, and an update to the City’s Greenhouse Gas Reduction Plan. The Court held that a program-level document and the possibility of future environmental review did not excuse the City’s current failure to adequately analyze reasonably foreseeable significant impacts or allow the City to defer analysis to a later project-specific EIR. South Fresno Community Alliance v. City of Fresno, Fifth Appellate District No. F086180, Opinion, August 6, 2024.

The same error is present here. CEQA recognizes that environmental impacts from plan amendments might be less definite than those associated with specific construction projects, but that does not excuse an analysis from taking place. In fact, case law supports CEQA Guidelines that all actions considered part of the project must be considered. City of Redlands v. County of San Bernardino (2002) 96 Cal.App.4th 398, 410 (setting aside a negative declaration after finding the project description in the initial study inadequate for inaccurately characterizing substantive amendments to a general plan as mere clarifications). Nelson v. County of Kern (2010) 190 Cal.App.4th 252, 267 (“The scope of the environmental review conducted for the initial study must include the Mayor Dyer and Members of the City Council
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entire project.”) (emphasis added). The project in Nelson v. County of Kern (2010) 190 Cal.App.4th 252 consisted of a mining operation and a reclamation plan to restore the land thereafter. 190 Cal.App. at 259. The court set aside the mitigated negative declaration, holding the project description to be inadequate where the initial study analyzed only the reclamation plan, and not the mining and thus did not describe the entire project. 190 Cal.App. at 272-3. These holdings point to the fact that annexation and rezoning is part of Project and thus must be included in the project description and its impacts must be analyzed.

An EIR for the whole of the Project must analyze the impacts from development that would be allowable under the proposed annexation and rezoning together with impacts from the proposed CTRF Project development. Once the analysis is completed, the EIR must identify feasible mitigation measures and identify feasible alternatives to avoid or minimize any significant impacts to the extent practicable.

B. The MND’s Transportation Analysis Is Inadequate, and There Is a Fair Argument that the Project May Have Significant Transportation Impacts.

The MND’s analysis of transportation impacts fails to inform decisionmakers and the public about the potential significant environmental effects of the Project. Guidelines § 15002(a). CEQA requires “adequacy, completeness, and a good-faith effort at full disclosure” in an environmental document. Id. § 15003(i). The MND here does not meet these requirements for several reasons. As an initial matter, the omitted analysis of foreseeable uses on the whole of the Project renders the transportation analysis incomplete. Further, the MND’s transportation analysis for the CTRF Project relies on trip generation figures that appear to be substantially under-estimated. In addition, the MND relies on artificially constrained traffic patterns even though nothing limits truck traffic to the analyzed routes. The MND’s conclusion that the Project would not result in any potentially significant transportation impacts is therefore not supported by substantial evidence.

1. The MND’s Assumptions Regarding Project Trip Generation Are Grossly Underestimated and Misleading.

The MND states that the applicant’s operations at the current site at the Southwest Corner of Church and Cherry Avenue would relocate to the proposed CTRF Project site.

Fresno Planning Commission Agenda, June 18, 2025, Supplemental Exhibit Q at slide

12. The current facility appears to have 26 dock doors. By contrast, the proposed CTRF facility has 106 dock doors, or four times as many as the existing facility.

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The MND claims that the CTRF Project would generate 84 truck trips per day and 120 passenger vehicle trips per day.7 MND at PDF pp. 7, 8 and 773. However, as discussed above, the site plan for the proposed CTRF Project indicates that the 68,570 square foot cross-dock transfer platform would include 106 dock doors. Id. and at PDF p. 195. According to industrial real estate/logistics expert Chuck Berger, if the CTRF facility was operating at full capacity, it would generate a substantially larger number of trucks than assumed in the MND. Attach. F, “How Many Dock Positions Do I Need?” August 2025 and article “ LTL Terminals: Key Locations for Efficient Freight Handling”. According to Mr. Berger’s studies of LTL facilities, a conservative estimate has a LTL facility handling 2-3 times the number of truck dock doors over an 8-hour workday. Therefore, a 106-door truck dock terminal is conservatively estimated to manage between 210 and 320 truck visits per day. That translates to approximately 2 to 3 trucks per dock per day, depending on factors like shift schedules (single vs. multiple shifts); average dwell times (duration of time trucks are on site); operational efficiency and scheduling; and whether trucks arrive at peak vs. off-peak hours. Accounting for one ingress trip and one egress trip per truck, 210 to 320 trucks per day would equate to 420 to 640 truck trips over a typical 8-hour workday. Given that the facility would operate 24 hours a day during the week (with multiple shifts) and during the morning on Saturday, the daily truck trip number is likely to be far higher. The MND’s Energy section discloses that the CTRF Project would result in a total of 8,381 daily VMT and more than three million annual VMT. MND at Table 11, PDF pp. 50 and 51. This amount of VMT also suggests that the number of truck trips used in the MND’s transportation analysis is far too low. Moreover, this increase in truck trips exceeds the City’s threshold of 500- average-daily-trips that would trigger the need for a more detailed VMT analysis. MND at PDF p. 70 and 114.

The Project Conditions of Approval have no cap on the amount of truck volume allowed at the CTRF facility, so once the CTRF Project is built, the market – not the MND transportation analysis – would determine the actual daily truck volume at the site.

Based on the above LTL logistics analysis, if the applicant only needs to plan for 84 truck trips per day (42 trucks in and 42 trucks out), their facility could be much smaller, roughly a quarter of the size being proposed. With 106 truck dock doors available, completing an analysis for this facility based on the claim of 84 truck trips/day is completely unrealistic and misleading. An EIR must evaluate the CTRF Project’s 7 The MND states that calculations for trip generation rates and average daily trips are based on information provided by the applicant, but does not explain how this information is accurate. MND at PDF p. 106 and 780.

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transportation impacts based on realistic estimates of truck traffic tied to the number of dock doors at the site and realistic industry practices.

2. The MND Relies on Artificially Constrained Traffic Patterns.

The MND’s discussion of anticipated truck route use and analysis of truck trip distribution that is vague and unclear about its methodology. Specifically, the MND indicates that CTRF Project trip distribution “was based on the most logically traveled routes for traffic accessing the project and a review of the potential draw from population centers within the region as well as the types of land uses involved.” MND at PDF p. 773 (emphasis added). However, the MND fails to elaborate on this vague statement regarding what constitutes a “logically traveled route;” how the traveled routes, specifically the truck routes, were determined; or what percentage of trucks would travel each route. MND at PDF p. 773. The MND refers the reader to Figure 4 for project distribution, which shows a study area intersection analysis only for intersections along North Avenue and Cherry Avenue. MND at PDF p. 775. Presumably, this means that the MND assumes CTRF Project-related trucks would all travel to and from the site using SR 41 via North Avenue and Cherry Avenue. MND at PDF p. 775. As discussed below, this assumption is unrealistic given the multiple truck routes available in the area. Fresno Planning Commission Agenda, June 18, 2025, Supplemental Exhibit Q PDF at p.13 There are four primary regional connectors for the proposed Project site: State Route (“SR”) 41, which is the nearest freeway to the CTRF Project site; State Route 99, which connects with SR 41 to the north; I-180, which connects with both SR 41 and SR 99; and I-168, which is located to the northeast of the City. The MND and its supporting analysis identify SR 41 in the “Existing Streets” description, but do not include any of the other highways. As the MND acknowledges, designated or planned truck routes exist on all major thoroughfares in the area. Id.

Therefore, in reality, trucks coming to and leaving from the CTRF Project site will have multiple paths available to the City’s four main regional connectors. The MND inexplicably appears to assume that 100 percent of truck trips to and from the Project site will use the SR-41 via corridor. MND at PDF p. 773-775. The City has not offered any evidentiary basis to justify using this artificially constrained trip distribution to evaluate the Project’s traffic impacts. The City states that CTRF Project-related truck traffic will enter and exit the site through two ingress/egress points on S. Cherry, and trucks will turn north onto S. Cherry. Staff Presentation to Planning Commission. June 18, 2025, Supplemental Exhibit Q. However, the MND includes no measure to constrain truck operators from using different truck routes than those assumed. MND at PDF pp. 114 and 115 (includes no mitigation measures to ensure trucks use one certain routes).

Mayor Dyer and Members of the City Council
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Even the City’s proposed Condition of Approval to limit trucks arriving to the CTRF site to travel southbound only from E. North Avenue and to limit trucks departing from the site to travel northbound from S. Cherry Avenue to East North Avenue is inadequate to ensure the truck-related impacts on the community are minimized. Planning Commission Agenda, June 18, 2025, Exhibit K – Conditions of Approval [6-18-2025] at Condition 7. Truck traffic on S. Cherry Avenue is already heavy so that drivers will most likely avoid turning left from the CTRF facility onto S. Cherry as prescribed. Despite conditions constraining truck routes for other projects, area residents find that many trucks in the area travel off-route and violate the conditions.

Taken together, the availability of alternative truck routes to major regional thoroughfares and the City’s existing truck traffic patterns show that the City’s decision to assume a singular truck route is not only unsupported, but is also contradicted by substantial evidence. This error is fatal to the MND because it masks several potentially significant impacts and thus renders the MND insufficient as an informational document.

For example, it is well established that “[t]ruck traffic can present substantial safety issues,” particularly where that “traffic passes through residential areas, school zones, or other places where pedestrians are common and extra caution is warranted.” California Attorney General’s Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act at pg. 9-10, attached as Attach.

G. Here, without further mitigations to ensure use of the identified route, trucks could use S. Cherry Avenue south of the proposed CTRF Project site, which the map in Attach. A illustrates, passes right next to residences and at least one school. Without analyzing all available truck routes to and from the Project site, the City cannot know whether further mitigation—such as designing entrances/exits oriented to face north and/or including physical barriers “[r]estricting the turns trucks can make entering and exiting the facility to route trucks away from sensitive receptors” (Warehouse Best Practices at pg. 10)—is needed. The MND says trucks have to turn left onto S. Cherry when exiting the facility but without a physical barrier, the City cannot rely on the trucks complying.

The prevalence of impacts from trucks travelling close to sensitive receptors are evidenced in the attached declarations from an area resident and from the Superintendent of the Orange Center School District document impacts experienced by the community from increased truck traffic from industrial development-related traffic. See, Attach. H and Attach. I, Declarations from T. Hirschfield and K. Taylor.

An EIR for the Project must provide a robust analysis of truck routes and related impacts. The EIR should evaluate effective mitigations, such as orienting truck ingress/egress driveways facing north on the site so that access to the site can only take place if a truck arrives from S. Cherry Ave. travelling southbound from E. North Ave. or departs from the site headed northbound on S. Cherry Ave. A thorough evaluation of Mayor Dyer and Members of the City Council
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truck routes in the Project area is important because, as explained in the Community Truck Reroute Study of 2024, freight-impacted communities in the area have high asthma rates and cardiovascular disease impacts, along with high rates of poverty, and unemployment. South Central Fresno AB617 Community Truck Reroute Study, April 2024 at p. 2. Such truck impacts include air pollution, noise, traffic crashes, traffic congestion, active transportation conflicts, and residential and school impacts, among others. Id.

The artificial constraints placed on the traffic analysis also infect the MND’s analysis of air quality and noise impacts. Because the MND assumes use of limited truck routes without ensuring that all operational truck traffic would proceed along the S.

Cherry Avenue/E. North Avenue corridor, the MND fails to analyze the Project’s air quality, public health and safety, and noise impacts at sensitive receptors along other likely truck routes. Id. Without further analysis, neither the City nor the public can fully understand the potentially significant environmental impacts of the Project.

3. The MND’s VMT Analysis Failed to Include VMT from Trucks.

In addition, the MND’s vehicle miles travelled (“VMT”) analysis is flawed because it only included passenger vehicles in the analysis. The MND explains that because the City’s VMT guidelines only require analysis of VMT from passenger vehicles, heavy truck trips were not analyzed. MND at PDF p. 791. However, this approach is irrational given that the proposed development project consists of a heavyduty truck facility.

Guidance from the California Governor’s Office of Planning and Research (“OPR”) regarding the evaluation VMT impacts makes clear that truck VMT can be included. Attach. J, OPR Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018 at p. 4. Therefore, nothing prevents the City from analyzing VMT from trucks where it makes sense to do so as it does here. Nonetheless, as discussed above, the MND’s Energy section discloses that the CTRF Project would result in a total of 8,381 daily VMT and more than three million annual VMT. MND at Table 11, PDF pp. 50 and 51. This amount of VMT suggests that the number of truck trips used in the MND is too low. Moreover, the MND failed to estimate VMT from future uses in the whole of the Project to account for the change in zoning from Limited Agriculture to Heavy Industrial. An EIR for the Project should analyze all anticipated VMT and identify mitigation measures to minimize impacts.

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4. The MND Fails to Sufficiently Analyze Impacts Related to Pedestrian and Bicyclist Safety.

The City has a duty under CEQA to consider whether a project would . . . “create[s] risks to pedestrians in and around the project site.” City of Maywood v. Los Angeles Unified School Dist. (2012) 208 Cal.App.4th 362, 391. The MND, however, fails to adequately analyze the Plan’s potential danger to pedestrians, cyclists, or other residents who may be vulnerable to traffic hazards. It neglects to examine the impact of increased truck traffic near sensitive existing uses in and near the proposed Project Area, such as around Orange Center Elementary School.

The extent of the MND’s so-called analysis of impacts to pedestrian and bicyclist safety is a single paragraph of accident data from the Statewide Integrated Traffic Records System in an attachment to the MND. MND at PDF p. 789. The data reveal that there were 46 accidents at the four intersections studied for the CTRF Project area from July 2018 to July 2023. Id. Here too, the MND fails to fully analyze the potential for increased accidents with the Project, and fails to provide adequate detail for an intelligent evaluation of public safety impacts.

First, given that the Project would allow heavy industrial development on all 80 acres, the MND should have evaluated impact areas beyond the four intersections chosen near the CTRF Project. Moreover, the MND fails to provide any details from these data.

For instance, how many of the accidents involved injuries or fatalities? How many of the accidents involved trucks or cars? How many of the accidents involved pedestrians, bicycles or drivers? Answers to these questions would provide decision-makers and the public information on existing roadway hazards that can be incorporated into an analysis of hazards from having increased truck and car traffic in the area.

The City must also disclose the extent of increased truck traffic and identify where there are cyclists, pedestrians, or other sensitive receptors who would be impacted by them. In the City of Maywood, the court invalidated an EIR for a parallel problem as here—the EIR lacked sufficient detail and analysis to provide a basis on which to assess risks to pedestrians. 208 Cal.App.4th at 387. While the Maywood EIR and accompanying safety study expressly contemplated some traffic safety hazards, it crucially failed to evaluate the issue in detail, and “[t]he record [did] not contain any evidence that the [planner] considered or otherwise addressed these issues.” Id. at 395.

Similarly, here, the MND should have reasonably described the characteristics of proposed uses in the whole of the Project area and the proposed CTRF Project’s features and how they would impact pedestrian and traffic safety—particularly for areas where safety considerations were most pressing. If community members had been adequately Mayor Dyer and Members of the City Council
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consulted, the MND might have noted the following traffic safety hot spots, where residents feel the most acute danger from truck traffic. For instance, Orange Center Elementary School is located in close proximity to the proposed CTRF Project, on South Cherry Avenue between East Central Ave and East North Avenue. The school is a block from the CA-41 freeway. Elementary-age students and their guardians walking to and from school are particularly vulnerable to safety issues brought by increased truck traffic.

The MND omits any mention of Orange Center Elementary in the context of traffic safety The MND does not, as required, provide an analysis of the safety risk that the increased Project-related traffic might cause.

In addition, residential communities exist in close proximity to industrial uses throughout the South Fresno area, to which the proposed Project area would be a part.

These communities already face danger from truck traffic brought by warehouse development within the past decade. Residents report that trucks pass right in front of their homes, and that the increase in traffic has led them to feel unsafe walking or driving in their neighborhoods. See, Attach. H and Attach. I, declarations from T. Hirschfield and K. Taylor. For a number of communities in South Central Fresno, light and heavy industrial uses and business park uses are located immediately adjacent to known residential areas. The MND entirely fails to contemplate how residents of these communities will be impacted by truck and other traffic the proposed Project’s uses will inevitably bring.

The MND’s complete failure to evaluate potential traffic safety harms renders the analysis legally deficient. The City therefore cannot approve the Project unless it prepares an EIR that (1) includes a realistic estimate of trip generation from the whole of the Project; (2) models all truck routes available to the CTRF Project operator (3) analyzes VMT for the whole of the Project (including all of the annexed area); and (4) analyzes safety impacts from increased traffic to area residents. Once a full analysis is performed the City should adopt Project alternatives or mitigation measures that restrict Projectrelated traffic to the analyzed routes. See Guidelines § 15002(a); see also Pub. Resources Code § 21002; Guidelines §§ 15002(a)(3), 15021(a)(2); Citizens for Quality Growth v.

City of Mount Shasta (1988) 198 Cal.App.3d 433, 443-45.

C. The MND’s Air Quality Analysis is Inadequate and There Is a Fair Argument that the Project May Have Significant Air Quality and Greenhouse Gas Emission Impacts.

The City of Fresno, and the surrounding San Joaquin Valley Air Basin, suffer from some of the nation’s worst air quality. South Central Fresno where the proposed Project is located, experiences poor air quality due to a large concentration of industrial uses and high volumes of truck traffic. South Central Fresno was prioritized and selected Mayor Dyer and Members of the City Council
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by the California Air Resources Board (CARB) for additional emissions monitoring, adoption of a community emission reduction plan, including measures that will result in quantifiable emission reductions, and investment of additional resources under Assembly Bill 617 due to the community’s disproportionate cumulative air pollution exposure burden. Attach. K, Community Emissions Reduction Program, South Central Fresno, September 19, 2019 at p. 1. Therefore, it is imperative that the City provide an accurate assessment of the Project’s potential to further degrade air quality and public health.

Here, the air quality analysis and the conclusion that the Project would have less than significant impacts on residents and schoolchildren in the area are based on an incomplete description of the Project and are completely unsupported by evidence.

Mobile emission sources significantly impact South Central Fresno from VMT on major freeways including State Route 180, State Route 99, and State Route 41, and major interchanges including the Belmont Avenue, Mckinley, and Olive interchanges. In addition, South Central Fresno also has multiple designated truck routes, most of which directly bisect through residential communities exposing residents to toxic air contaminants and pollution. According to the South Central Fresno CERP, the community was found to exceed the 24-hour average PM2.5 concentration prioritization factor levels during the 2014-2016 period and the 8-hour average ozone concentration prioritization factor during 2014-2016 period. Attach. K, Community Emissions Reduction Program, South Central Fresno, September 19, 2019 at p. 19.

Despite plentiful evidence that the South Central area of Fresno suffers from poor air quality, the MND fails to adequately analyze the Project’s air quality emissions for several reasons. First, because the MND failed to adequately describe the environmental setting of the area, including consistently poor air quality, the analysis fails to capture the cumulative impacts from the Project’s emissions combined with existing poor air quality.

Id. at 1. Second, the analysis only includes the CTRF Project, and fails to take into account emissions from trucks and vehicles resulting from planned heavy industrial uses on the remaining 36 acres, it only considers a fraction of the polluting emissions that will result from the whole of the Project. Third, because the transportation analysis grossly underestimates truck trips from the CTRF Project, what analysis the MND does provide is incomplete and misleading. Fourth, the MND’s myopic assumption that CTRF-related truck trips will only use one truck route artificially constrains the analysis and fails to adequately analyze air pollutant impacts on residents and schoolchildren along other available truck routes. Once all of these elements are analyzed, the air emissions are likely to be much higher.

The MND’s analysis of greenhouse gas emission (“GHG”) impacts is similarly lacking. The MND begins the discussion by explaining that the City has done nothing to evaluate or mitigate city-wide greenhouse gas emissions. The City has not adopted a Mayor Dyer and Members of the City Council
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GHG reduction plan, and has not completed a GHG inventory, benchmarking, or goalsetting process required to identify a reduction target. MND at PDF p. 64. The MND also states that the San Joaquin Valley Air District has adopted a Climate Action Plan, but that none of the measures are applicable to the Project. Id. For these reasons, the MND qualitatively evaluates consistency with CARB’s adopted Scoping Plan.

The MND however, limits its discussion to how the Project will comply with the law and concludes that, because it will comply with legal requirements as they are adopted, the Project would be consistent with State policy for reaching carbon neutrality.

MND at PDF p. 75 and 76. Simply stating compliance with the law is not enough. The analysis must demonstrate how the Project aligns with the Scoping Plan's objectives and measures, and how it contributes to achieving state climate goals. The Scoping Plan makes clear that local efforts to reduce greenhouse gases are also required for the State to meet the goal of net neutrality. The Scoping Plan states that jurisdictions without formal climate action plans “can still take actions that effectively translate key state plans, goals, and targets, including those articulated in this Scoping Plan for local action.” Attach. L 2022 Scoping Plan for Achieving Carbon Neutrality at p. 269. Furthermore, in its Appendix D Local Actions, the Scoping Plan specifies that “a substantial portion of California’s GHG reduction potential comes from activities over which local governments have authority or influence” and that local government actions are crucial for supporting attainment of the States’s Climate Goals. Attach. M, 2022 Scoping Plan for Achieving Carbon Neutrality, Appendix D Local Actions at p. 3. Therefore, it is not enough to rely on compliance with state laws alone to reduce greenhouse gas emissions.

Local jurisdictions must demonstrate how the Project complies with the Plan’s objectives, but also how it contributes to achieving emissions reductions that advance the state climate goals.

Under the California Supreme Court findings for Center for Biological Diversity v.

Department of Fish & Wildlife (2015) 62 Cal.4th 204 (“Newhall Ranch”) a project’s GHG emissions should be evaluated based on its effect on California’s efforts to meet the State’s long-term climate goals. As the Supreme Court held in that case, a project that would be consistent with meeting those goals can be found to have a less-than-significant impact on climate change under CEQA. If a project would contribute its “fair share” of what will be required to achieve those long-term climate goals. Id. at 220–223. But an agency may only rely on statewide documents like the Scoping Plan if it has substantial evidence of the local action and project-specific reductions needed to achieve compliance with the state goal. See id. at 227-28. The MND lacks any such substantial evidence for its assertion that the Project is consistent with the Scoping Plan.

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Here, the Project would allow for approximately 52 acres of heavy industrial uses, including almost 16 acres of proposed trucking facilities that will result in hundreds of additional trucks on City roads every day, and more than three million VMT annually.

MND at Table 11, PDF pp. 50 and 51. Build-out of the whole Project area will add millions more VMT and would increase polluting emissions, including GHG emissions.

Therefore, the MND’s conclusion that the Project would have less than significant GHG impacts borders on the absurd. An EIR must include an evaluation of all of the Project’s emissions, including GHGs, and identify mitigation measures or alternatives to minimize those impacts.

The EIR must also take into account and include recommendations from the Truck Reroute Study and the Fresno HIA. For example, the Truck Reroute Study recommends policy strategies applicable to Cherry, Central and North Ave including: transitioning to zero emission trucks, time-of-day restrictions, and enforcement. Requiring zero emission trucks is vital for reducing emissions on Cherry Avenue to reduce the health impacts on residents living on Cherry Avenue and the students, parents, and staff at Orange Center Elementary. Without transitioning to zero emission trucks, the City continues to expose residents to significant levels of PM 2.5, Ozone, and diesel PM thus contributing to their risk of suffering preterm births, infant mortality, needing emergency car or hospitalization due to asthma or cardio-cerebrovascular disease. Attach. C Truck Reroute Study at pp. 32-33.

The fact is that this Project will have a devastating impact on local and regional air quality. Disadvantaged communities and people of color, who already suffer from health impacts of poor air quality, will feel these impacts more acutely than other City residents.

Unfortunately, the details of these impacts remain unknown because the MND does not provide anything close to a complete analysis of these issues. These egregious flaws in the air quality analysis must be remedied in a thorough evaluation in an EIR.

D. The MND’s Noise Analysis Is Inadequate, and There Is a Fair Argument that the Project May Have Significant Noise Impacts.

The MND’s failure to fully and accurately analyze the whole of the Project infects the MND’s analysis of noise impacts and results in incomplete disclosure of the whole of the Project’s impacts.

The type and amount of potential noise to be generated by the uses allowed by right in the IH zoning district must be analyzed if the property is rezoned to allow these uses. The analysis cannot be deferred to some point in the future, such as when a new business applies for a business license or a building permit to begin operations that are already allowed by right in the IH zoning district. The MND does not describe any Best Mayor Dyer and Members of the City Council
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Management Practices or Standard Conditions of Approval that would be applied to new development in the IH district, or to the CTRF Project specifically, that would minimize noise impacts on nearby sensitive receptors.

Furthermore, the MND calculated noise impacts based on the truck trip volumes as identified in the CTRF Project traffic impact analysis. The future conditions noise modeling described in the acoustical analysis completed for the CTRF Project is based on inaccurate anticipated project-generated truck trip volumes. As discussed elsewhere in this letter, the anticipated truck trip volume (a mere 126 trucks per day stated in the MND) were studied in the transportation and air quality analyses. This trip number is well under the volume of heavy truck traffic that could be generated by a 106-door lessthan-truckload facility that is open 24 hours/day five days a week plus Saturday mornings, which would expect a minimum of 2 to 3 times that volume.8 Therefore, at its core, the future conditions noise modeling for the CTRF Project is inaccurate. The analysis needs to include accurate truck trip volumes for the CTRF Project, as well as assumptions for the entirety of the area proposed to be rezoned from Limited Agriculture to Heavy Industrial uses.

It is critical that the City understand the whole of the Project’s noise impacts.

Truck trips can create severe impacts for sensitive receptors, including schools and medical facilities. A diesel truck traveling 40 miles per hour generates 84 decibels at a distance of 50 feet. Noise Sources and Their Effects, Purdue University.9 The City is aware that noise levels in this area are already excessive. The acoustical analysis completed as part of the MND, and included as Appendix D, notes that “[R]eference to Table IV indicates that existing noise levels in the vicinity the project vicinity (along S Cherry Avenue) exceed applicable City of Fresno noise level standards in every statistical category during every hour of the 24‐hour measurement period. Table IV also provides the average daytime (7:00 a.m. to 10:00 p.m.) and average nighttime (10:00 p.m. to 7:00 a.m.) noise levels, as measured at site LT‐1. MND Appendix D, Acoustical Analysis for CTRF dated August 25, 2023 at p. 7
The acoustical analysis was for the CTRF Project only, and even then it was limited. The acoustical analysis did not study the noise impacts of construction equipment to be used throughout the 51.72 acres of property that would be rezoned IH, nor did it study the construction noise impacts of work at the proposed 15.95 acre CTRF Project site.
8 See logistics expert Check Berger: https://www.chuckberger.com/blog/2020/08/25/calculating-dock-positionrequirements?rq=truck%20 9 Noise Sources and Their Effects is available at https://www.chem.purdue.edu/ chemsafety/Training/PPETrain/dblevels.htm.

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Also the MND did not include a noise analysis for ongoing operations for the whole of the Project. If existing noise levels already exceed City standards, one can only imagine what the noise environment will be like once the whole of the Project is assessed. Where significant noise impacts and disturbing noise events are already present, tolerance is very low for any increase in either the frequency of events, the decibel level of the events, or the duration of the events. Here, the proper question is not the relative amount of noise resulting from the Project, but “whether any additional amount of [noise] should be considered significant” in light of existing conditions. Los Angeles Unified School District v. City of Los Angeles (1997) 58 Cal.App.4th 1019, 1025-26 (citation omitted) (“LA Unified”). The conclusion that the noise impacts of the project are less than significant is not based on accurate data or a complete and thorough analysis of future project conditions, and is relying on incomplete evidence for support.

While the noise analysis in the MND is lacking evidence and completeness, the vibration analysis in the MND is non-existent. The MND simply skips to a conclusion of less than significant without any evidence for the claim. The entire vibration analysis is contained on a single page. It includes a table of typical vibration levels for different pieces of construction equipment (sourced from Caltrans) and the following conclusion:
“After full Project build out, it is not expected that ongoing operational activities will result in any vibration impacts at nearby sensitive uses. Additional mitigation is not required. There are no aspects of construction or daily operations that would create groundborne vibration. As such, any impacts would be less than significant.” See MND at PDF p. 96.

This conclusion cannot be supported. The IH zoning district allows many uses by right that would have vibration impacts, including Motorcycle Riding Club, Maintenance and Repair Services, Construction and Materials Yard (includes Concrete Batch Plants, Storage Yards, and Similar Uses), Custom Manufacturing, Freight/Truck Terminals and Warehouses, and Major Utilities. Construction and materials yards, for instance, often use equipment for loading/stockpiles and, at times, vibratory rollers and large dozers.

Another allowed use, Major Utilities, could include operations with blowers, pumps, and turbines, which could have vibration (and noise) impacts. Neither the MND, nor any technical appendix, provides a discussion of data of existing conditions, or data on future conditions based on expected construction or operational conditions. There is absolutely no evidence or support for a conclusion that vibration impacts resulting from the rezoning or proposed CTRF Project will be less than significant.

Based on the numerous failures of the acoustical analysis, the MND thus fails as an informational document. CEQA Guidelines §§ 15002(a), 15003(i); see also Friends of the Eel River, 108 Cal.App.4th at 875 (incomplete description of the Project’s environmental setting fails to set the stage for a discussion of significant effects). The Mayor Dyer and Members of the City Council
August 13, 2025

City cannot approve the Project without first conducting additional analysis of noise impacts for the whole of the Project that uses accurate truck trip volumes for the part of the analysis that is specific to the CTRF Project site, as well as providing evidence for conclusions reached on the impacts of construction and operational vibrations.

E. The MND’s Land Use Analysis Is Inadequate, and There Is a Fair Argument that the Project May Have Significant Land Use Impacts.

The MND’s analysis of land use impacts fails to achieve CEQA’s most basic purpose: informing governmental decisionmakers and the public about the potential significant environmental effects of a proposed activity. Guidelines § 15002(a). CEQA requires “adequacy, completeness, and a good-faith effort at full disclosure” in an environmental document. Id. § 15003(i). The MND here does not meet these requirements. Specifically, the MND’s asks if the project will “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?” The MND claims the CTRF Project is consistent with the Fresno General Plan goals and objectives related to land use and urban form. However, because the MND is only considering the CTRF Project, no analysis is provided on how the whole of the Project is consistent with General Plan goals and objectives related to land use and urban form. The MND completely ignores the application of the North Avenue Industrial Triangle Specific Plan to the whole of the Project area and includes no assessment of consistency.

The MND’s conclusion that the Project would not result in any potentially significant land use impacts is therefore not supported by substantial evidence.

IV. Conclusion
As set forth above, the MND does not come close to satisfying CEQA’s requirements. At a fundamental level, it fails to describe the Project setting and the Project, and fails to provide a complete analysis of Project impacts and feasible mitigation measures. At the same time, ample evidence demonstrates that a fair argument exists that the Project may result in significant environmental impacts. In light of this evidence, CEQA requires that an EIR be prepared. For this reason, SFCA respectfully requests that the City Council not approve the proposed Project until an EIR is prepared to fully evaluate the Project’s impacts.

From: Kristi Bascom
To: Clerk
Cc: Edward T. Schexnayder; Carmen J. Borg
Subject: Public comment on 8/14/2024 City Council agenda Item ID 25-1026 - Email 1 of 2 Date: Tuesday, August 12, 2025 6:08:56 PM
Attachments: image001.png
SMW-SFCA letter Attachments A-J.pdf
External Email: Use caution with links and attachments
First email with attachments to comment letter on behalf of South Fresno Community Alliance for 8/14/2025 City Council agenda item # ID 25-1026. Attachments A through J included in this email.

Kristi Bascom, AICP
Urban Planner
Shute, Mihaly & Weinberger LLP
396 Hayes Street
San Francisco, CA 94102-4421
o: 415/552-7272 x 202 c: 925/872-6327
www.smwlaw.com | A San Francisco Green Business
Attachment A

Attachment B
Census Tract: 6019001500
Population: 2,206
CalEnviroScreen 3.0 Percentile: 95-100% (highest scores) The following numbers represent the percentile score for that component or indicator. A higher percentile indicates a higher relative burden. Scroll to the bottom for a pie chart of race/ethnicity.

Pollution Burden Percentile:
100
Population Characteristics
Percentile: 93
Ozone: 98
PM 2.5: 97
Diesel: 58
Pesticides: 95
Toxic Releases: 98
Traffic: 24
Drinking Water: 99
Cleanups: 97
Groundwater Threats: 92
Hazardous Waste: 100
Impaired Water: 0
Solid Waste: 100
Asthma: 90
Low Birth Weight: 39
Cardiovascular Disease: 92
Education: 91
Linguistic Isolation: 74
Poverty: 90
Unemployment: 94
Housing Burden: 84
Census Tract: 6019001700
Population: 5,701
CalEnviroScreen 3.0 Percentile: 95-100% (highest scores) The following numbers represent the percentile score for that component or indicator. A higher percentile indicates a higher relative burden. Scroll to the bottom for a pie chart of race/ethnicity.

Pollution Burden Percentile:
97 Population Characteristics
Percentile: 87
Ozone: 98
PM 2.5: 97
Diesel: 42
Pesticides: 93
Toxic Releases: 70
Traffic: 39
Drinking Water: 98
Cleanups: 56
Groundwater Threats: 32
Hazardous Waste: 47
Impaired Water: 0
Solid Waste: 96
Asthma: 85
Low Birth Weight: 76
Cardiovascular Disease: 81
Education: 77
Linguistic Isolation: 69
Poverty: 72
Unemployment: 79
Housing Burden: 53
Census Tract: 6019001800
Population: 4,615
CalEnviroScreen 3.0 Percentile: 95-100% (highest scores) The following numbers represent the percentile score for that component or indicator. A higher percentile indicates a higher relative burden. Scroll to the bottom for a pie chart of race/ethnicity.

Pollution Burden Percentile:
98 Population Characteristics
Percentile: 85
Ozone: 98
PM 2.5: 97
Diesel: 25
Pesticides: 93
Toxic Releases: 73
Traffic: 11
Drinking Water: 99
Cleanups: 87
Groundwater Threats: 59
Hazardous Waste: 88
Impaired Water: 0
Solid Waste: 100
Asthma: 95
Low Birth Weight: 83
Cardiovascular Disease: 89
Education: 72
Linguistic Isolation: 55
Poverty: 64
Unemployment: 68
Housing Burden: 31
1949866.1
Attachment C

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024 Contents
1 Introduction and Background ......................................................................................................... 2 2 Strategy Development ................................................................................................................... 3 3 Strategy List ................................................................................................................................. 9 4 Strategy Map .............................................................................................................................. 27 5 Proposed Truck Routes ................................................................................................................ 28 6 Non-Infrastructure Strategies ....................................................................................................... 32 7 Implementation .......................................................................................................................... 34

7.1 Policy Strategies ................................................................................................................... 34

7.2 Funding Strategies ................................................................................................................ 35

7.3 Prioritization Framework........................................................................................................ 43 8 Next Steps .................................................................................................................................. 59

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
2 1 Introduction and Background
The City of Fresno and the San Joaquin Valley Air Pollution Control District (SJVAPCD) is seeking to develop innovative and implementable mobility solutions and strategies to support the South-Central Fresno community. There is a significant industrial presence operating in the southwest portion of the community, which includes a fossil fuel electric power generation facility along with several other industrial sources. Industrial uses in the South-Central Fresno community have created a high cumulative air pollution exposure burden. This has in turn impacted a considerable number of census tracts that have been designated as disadvantaged communities, as well as sensitive locations including schools, daycares, and hospitals.

The community was prioritized by the San Joaquin Valley’s AB 617 Environmental Justice Steering Committee. The San Joaquin Valley has been the focus of numerous air quality studies which lay the necessary foundation for the development of an emissions reduction program in this urban community. The community also has high asthma rates and cardiovascular disease impacts, along with high rates of poverty, unemployment, and linguistic isolation. The Truck Reroute Study will identify, analyze, and evaluate potential strategies that freight-impacted communities in the AB 617 area might take in cooperation with the City of Fresno to abate truck impacts. Such truck impacts include air pollution, noise, polluted runoff, traffic crashes, traffic congestion, active transportation conflicts, residential and school impacts, and excess wear for local pavements and bridges.

This study will ultimately determine whether heavy-duty trucks travelling within the community can be rerouted to reduce emissions exposure of South-Central Fresno community residents. However, the purpose of this report is to recommend specific strategies to mitigate negative freight impacts, improve air quality, and improve the overall quality of life for members of the South-Central Fresno community. This report also recommends a potential implementation plan that considers funding sources and availability, project performance metrics, as well as a prioritization framework for the proposed strategies.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
3 2 Strategy Development
The South-Central Fresno Truck Reroute Study identified a host of truck routing strategies to implement throughout South-Central Fresno. The strategies were developed by combining findings from the assessment of existing conditions, community input from outreach events and stakeholder meetings, UC Merced (UCM)’s ongoing public health study, as well as truck routing best practices, while maintaining productivity of the goods and produce movement. This approach is summarized in Figure 1 below. Once implemented, the strategies aim to enhance health, safety, and mobility conditions for residents throughout South-Central Fresno, as well as streamline truck routing in the region.

FIGURE 1: KEY CONSIDERATIONS FOR FEASIBLE REROUTE

STRATEGIES

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
4 In development of the truck routing strategies, a truck reroute strategies toolkit was created. The truck reroute strategies toolkit introduces nine unique strategy categories utilizing treatments that promote resident safety or divert truck traffic along existing truck routes. Figure 2 illustrates the City’s existing truck routes last published in 2005.

The chosen strategy categories originated from any one or multiple sources, including assessment of existing conditions, the ongoing public health study, community input from outreach events and stakeholder meetings, previous plan and study goals and objectives, as well as truck routing best practices. Since public input is critical to this study, it should be noted that the feedback received during the first round of public outreach can be categorized into three major themes:

FIGURE 2: EXISTING TRUCK ROUTES (2005)
South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
5 • Pedestrian and bicyclist safety issues:
o Missing sidewalks and crosswalks near important destinations o Not enough separation between trucks and other users
o Lack of bike lanes
o Queueing at freeway onramps causes unsafe conditions
• Truck behavior issues:
o Trucks drive at unsafe speeds and don’t observe signs, especially near schools o Idling due to unsynchronized traffic signals
• Roadway infrastructure issues
o Damaged street surfaces, potholes
Careful attention to these themes and detailed feedback from residents and stakeholders helped to develop the strategy categories. The nine strategy categories in the truck reroute strategies toolkit, their descriptions, and the origin of the toolkit strategies, are shown in Table 1 below. Previous plan goals within Table 1 are accompanied by a number that directly relates to a section heading from the Existing Conditions Report.

Similarly, best practices within Table 1 are accompanied by a number that relates to a section heading in the Best Practices Report.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
8 City’s truck route ordinance is described in the policy strategy section (Section 7.1) of this report.

The truck regulated areas do not limit any freeway entry or exit access point on any freeway, including SR 41, SR 99, and SR 180. Nevertheless, the truck regulated areas may result in diversion of trucks on specific arterial and collector streets that carry any number of sensitive receptors. Though the truck regulated areas were recommended to reduce truck bypass near sensitive receptors, they are designed in a way to maintain major truck connections without heavily disrupting throughput. The recommended truck regulated areas were also informed by the health impact assessment being performed by UC Merced, which found that pre-term birth (PTB) and infant mortality (IM) rates were highest among those living within 1000 feet of a highway or truck route. The truck regulated areas were designed to reduce the number of residential areas living within this buffer zone, thus reducing risk of health outcomes such as pre-term birth and infant mortality. The addition of truck regulated areas aims to reduce the number of truck routes present in residential areas. The incorporation of this recommendation is discussed further in Section 5, which presents the new proposed truck route map.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
10 The next table lists each strategy and the project type it is categorized as, the proposed location, length or area size for each improvement, and which funding category the strategy falls into. Project types are listed below for reference:
 Highway/Roadway
 Active Transportation
 Transportation System Management (TSM)
 Transportation Demand Management (TDM)
 Sustainability
 Freight
This breakdown will be helpful for future cost analysis where cost per unit is relevant.

The funding categories listed in this table coincide with those listed in Section 6.1 of this report, where grants are categorized by funding category.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024

4 Strategy Map
Following the project list, a detailed map shows the locations of each of the proposed strategies. The project list corresponds directly with the project map below where strategies have been categorized by color. It should be noted that multiple “corridor” strategies can fall under the same corridor. For instance, the corridor for Chestnut Avenue from Jensen Avenue to Central Avenue features two separate strategies for New Sidewalks as well as New Crosswalks. Shapefiles with the corresponding strategies will be delivered to the City of Fresno for future use and consideration.

FIGURE 3: DRAFT STRATEGIES MAP
South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
28 5 Proposed Truck Routes
Four truck reroutes have been proposed in alignment with truck route removals and the thirteen recommended truck regulated areas in South Central Fresno. As mentioned above, truck regulated areas would prohibit trucks from entering local roadways within the designated areas. The implementation of these areas require some existing truck routes to be removed and re-routed around them. Reroutes are recommended along California Avenue, Kearney Avenue, Fruit Avenue, and E Street. The proposed truck routes and reroutes, as well as the recommended truck regulated areas are reflected in Figure 4 below. The figure also includes the location of the permanent Belmont Avenue interchange closure along SR 99. Caltrans will upgrade the Olive Avenue interchange to accommodate traffic flows and mitigate impacts to freight vehicles traveling on SR

99. Given the existing network, trucks would likely use the McKinley Avenue or Olive Avenue interchanges following the closure.

FIGURE 4: PROPOSED TRUCK ROUTES & TRUCK REGULATED AREAS South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
29 For further context, as discussed in Section 2, a 1,000-foot buffer around designated truck routes was used to guide where truck regulated areas would be most beneficial to residential areas based on the findings of the UC Merced Health Impact Assessment. The figure below reflects the South-Central Fresno residential areas, 1,000-foot buffers around designated truck routes, as well as the recommended truck regulated areas. Schools, which are also critical sensitive receptors, are also displayed on the map.

FIGURE 5: PROPOSED TRUCK REGULATED AREAS AND RESIDENTIAL AREAS WITHIN 1,000 FEET OF PROPOSED TRUCK ROUTES
Major diversion streets and sensitive receptors within each truck regulated area are described below:

Central Fresno Truck Regulated Area
• Reduces truck traffic on Tulare Street, Divisadero Street, and Fresno Street • Reduces truck traffic near Courthouse Park, businesses on Fulton Street, and Chukchansi Park • Trucks may divert to H Street, Tuolumne Street, Ventura Avenue, and E Street Mural District Truck Regulated Area
South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
30 • Reduces truck traffic on Fulton Street, Van Ness Avenue, and Stanislaus Street • Reduces truck traffic near the Cultural Arts District Park, and residences • Trucks may divert to Divisadero Street, Stanislaus Street, and H Street Tower Truck Regulated Area
• Reduces truck traffic on Olive Avenue, Palm Avenue, and Wishon Avenue • Reduces truck traffic near Muir Elementary School, Susan B Anthony Elementary School, businesses in Olive Avenue, and residences
• Trucks may divert to McKinley Avenue, Weber Avenue, Belmont Avenue, and Blackstone Avenue
Southwest Fresno Truck Regulated Area
• Reduces truck traffic on California Avenue, Church Avenue, B Street, Thorne Avenue, MLK Jr Boulevard, and Annadale Avenue
• Reduces truck traffic near Franklin School, Edison High School, Frank H Ball Center, Lincoln Elementary School, Columbia Elementary School, Cecil C Hinton Community Center, Fresno City College, Rutherford B Gaston Middle School, Computech Middle School, King Elementary School, Maxie L. Parks Community Center, Kirk Elementary School, W.E.B. DuBois Academy, Mary Ella Brown Center and Park, West Fresno Middle/Elementary Schools, and residences
• Trucks may divert to Walnut Avenue, North Avenue, West Avenue, Jensen Avenue, and SR 99 Tulare East A Truck Regulated Area
• Reduces truck traffic on Tulare Avenue, Huntington Boulevard, and Maple Avenue • Reduces truck traffic near Rowell Elementary School, Jackson Elementary School, and residences
• Trucks may divert to Belmont Avenue, First Street, and Ventura Avenue/ Kings Canyon Road Tulare East B Truck Regulated Area
• Reduces truck traffic on Tulare Avenue, Huntington Boulevard, and Maple Avenue • Reduces truck traffic near Roosevelt High School and residences • Trucks may divert to Belmont Avenue, Chestnut Avenue, and Ventura Avenue/ Kings Canyon Road
Roosevelt East A Truck Regulated Area
• Reduces truck traffic on Butler Avenue Maple Avenue, and Church Avenue • Reduces truck traffic near Winchell Elementary School, Vang Pao Elementary School, Sequoia Middle School, Aynesworth Elementary School, and residences • Trucks may divert to Railroad Avenue, East Avenue, California Avenue, and Ventura Avenue/ Kings Canyon Road
Roosevelt East B Truck Regulated Area
• Reduces truck traffic on Butler Avenue Maple Avenue, and Chance Avenue South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
31 • Reduces truck traffic near Baldera Elementary School, Aynesworth Elementary School, Calwa Elementary/ Preschool, Mosqueda Complex, and residences • Trucks may divert to Railroad Avenue, Jensen Avenue Bypass, California Avenue, and Ventura Avenue/ Kings Canyon Road
Malaga Truck Regulated Area
• Reduces truck traffic on Ward Avenue, Calvin Avenue, Hardin Avenue • Reduces truck traffic near Malaga Elementary School, Malaga Community Park and Recreation Center, and residences
• Trucks may divert to SR 99 and Golden State Boulevard Divisadero West Regulated Area
 Reduces truck traffic on McKenzie Avenue, Voorman Avenue, and Nevada Avenue  Reduces truck traffic near Lowell Elementary School and Dickey Park  Trucks may divert to SR 99, Divisadero Street, and Blackstone Avenue McKinley East Regulated Area
 Reduces truck traffic on Olive Avenue, Floradora Avenue, and Fisher Street  Reduces truck traffic near Yosemite Middle School and Mayfair Elementary School  Trucks may divert to SR 180, N 1st Street, and McKinley Avenue North Blackstone Regulated Area
 Reduces truck traffic on Olive Avenue, Floradora Avenue, and Fresno Street  Reduces truck traffic near San Joaquin Memorial High School, Restart Alternative School, and Webster Early Learning Center
 Trucks may divert to N Abby Street, SR 180, SR 41, and McKinley Avenue South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
32 6 Non-Infrastructure Strategies
There are numerous truck-related improvements that can be implemented within South-Central Fresno that cannot be placed on a map but are equally important. These improvements can include education and outreach programming, truck fuel-type, emissions and idling standards, truck specific GPS administration, time-of-day restrictions, and enforcement. All of these strategies are beneficial in maximizing the benefit of the draft strategies presented previously.

Education and Outreach Programming
• Education and outreach programming is a critical element in ensuring road safety is maximized while accidents are minimized. Proper education and outreach allows drivers to adapt efficiently to changes, optimizing their routes and supply chain management. The education component allows drivers to understand the wider benefits of rerouting and actively support these initiatives.
• The education component also would provide truck drivers with information on truck restrictions enforced by the City of Fresno that may impact where they are able to travel, park, and load.

Truck Fuel-type, Emissions, and Idling Standards
• These standards allow trucks to operate efficiently to produce fewer emissions, promoting improved air quality in residential areas. This can be achieved through enforcement of stringent maintenance and emission control technologies.

Zero-Emission Trucks
 Currently, commercial trucks are one of the largest contributors of GHG and NOx emissions.

These emissions are known to negatively impact the health of communities living alongside high volume truck corridors. The South-Central Fresno Community can significantly lower these harmful emissions by transitioning to zero-emission commercial trucks, which is a recommendation presented in the UC Merced Health Impact Assessment.  Transitioning to zero-emission commercial trucks is also in line with Executive Order N-79-20, which aims to reach a 100 percent zero-emission drayage truck and off-road equipment population by 2035 and 100 percent zero-emission medium- and heavy-duty vehicle population by 2045, where feasible.1
Truck-specific GPS Administration
• Truck-specific GPS devices provide information for crucial route restrictions that allow drivers to avoid sensitive receptors while ensuring safe and efficient navigation. Truck specific GPS technology may need to be implemented in coordination with the City of Fresno to take potential time of day truck restrictions and regulations into consideration. Additionally, this 1 “Learn Why and How the State Plans to Transition Medium- and Heavy-Duty Vehicles to this New Technology and What the Zero-Emission Vehicle Market Looks Like Today”. California Air Resources Board. 2024.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
33 technology should be implemented in coordination with Fresno local businesses to identify key times of day for delivery that will not interfere with curbside access for customers. • The implementation of truck-specific GPS may require some additional education campaigns for truck drivers that are not familiar with this technology. This can help truck drivers to use GPS devices correctly and ensure they do not violate any truck restrictions enforced by the City of Fresno.

Time-of-Day Restrictions
• Time-of-day restrictions are useful during peak times to minimize congestion and improve safety. These restrictions would be paired with clear considerations for off-peak truck schedules, as to avoid an impact on residents during peak times of personal vehicle traffic. • This strategy should be implemented in coordination with Fresno local businesses to understand when business areas are busiest. This can help mitigate competition for curb space between truck drivers and customers during peak times.

Enforcement
• Clear mechanisms and penalties for non-compliance helps maintain order and safety on roadways. The regulations and rules should aim to deter violations that could jeopardize safety or disrupt sensitive receptors.

When paired with on-the-ground improvements, implementation of these proposed strategies would result in an efficient and cohesive truck routing program that minimizes excessive and disproportionate negative impacts to South-Central Fresno residents and sensitive receptors.

The City of Fresno’s municipal code should also be updated to discuss the proposed truck regulated areas and truck reroutes. More specifically, the municipal code should highlight that truck passthrough traffic is restricted in truck regulated areas and highlight rerouted truck routes that truck drivers should take instead. An update to the municipal code should be made in coordination with local businesses to ensure they are aware of changes in freight flows and to ensure deliveries are not negatively impacted for their businesses. The amended municipal code should be enforced by the City of Fresno’s Parking Services. Truck travel and parking violations may come in the form of parking citations.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
34 7 Implementation
This section provides an overview of how projects could be implemented within the South-Central Fresno Study Area. Implementation considerations include funding availability and a recommended prioritization framework.

7.1 Policy Strategies
It is in the best interest of the City of Fresno to adopt an amended truck route ordinance in order to implement the recommendations of the study, namely the proposed modifications to truck routes and truck regulated areas. Residents of the AB 617 Community have highlighted their concern that high volumes of truck traffic have imposed negative air quality, noise, and traffic impacts.

Section 14-1303 of the City of Fresno Municipal Code establishes the designation of an official list of truck routes by City Council. The proposed amended truck ordinance should further regulate truck routes by establishing the truck regulated areas proposed by this study. As discussed above, the thirteen recommended truck regulated areas will regulate truck traffic through the most vulnerable neighborhoods within the South-Central Fresno community, including residential areas, communities near schools and community spaces, and areas prioritized for non-truck travel. Specific truck traffic regulations within each truck regulated area will be recommended based on the needs of the community within each truck regulated area. More specifically, trucks should be restricted from entering truck regulated areas unless trying to reach their origin or destination point, but it should not be used for pass through traffic. Where this approach is not feasible, we recommend implementing alternative strategies like speed and time of day limitations to help mitigate truck impacts to the truck regulated area. For example, in truck regulated areas near schools, truck access should be confined to non-school hours.

The regulation of truck access in truck regulated areas will reduce truck emissions, volumes, and idling of heavy-duty trucks near sensitive receptors.

The amended truck ordinance is in alignment with the California Vehicle Code, which provides the legal basis for restricting truck access and providing alternate routes. California Vehicle Codes 35701, 35702, 35703, 35712, 35714 refer to local authorities’ abilities to regulate truck access on local roads. These codes also state that restrictions to truck access cannot impede truck access to state highways or from making pick-ups or deliveries. These requirements are in alignment with the recommended truck regulated areas, which only encompass local roads.

The ordinance should specify that truck access within these truck regulated areas will be regulated through signage placed at regular intervals along corridors within truck regulated areas and enforced by law enforcement. Enforcement will occur through occasional patrolling and issuing of tickets from the Fresno Police Department for violations. As part of this new regulation, the City of Fresno will coordinate with the Police Department to conduct enforcement training on the new regulations to ensure law enforcement is aware of the new restrictions. The City should also consider a “grace period” for ticketing while businesses and enforcement staff adjust to the truck regulations. Additionally, the City and law enforcement should meet at the 1-year mark to re-evaluate the truck traffic ticket data and understand if the amended truck ordinance needs modification.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
35 Additionally, the City should consider a policy ordinance requiring a transition to zero-emission commercial trucks. This is in line with California Executive Order N-79-20, which aims to reach a 100 percent zero-emission drayage truck and off-road equipment population by 2035 and 100 percent zeroemission medium- and heavy-duty vehicle population by 2045, where feasible. The City should also implement a policy that designates the necessary funding and space required for implementing charging infrastructure to support zero-emission trucks.

7.2 Funding Strategies
The following section summarizes a comprehensive list of potential funding sources for project implementation. The list includes the agency, funding source, description, eligible projects, eligibility requirements, and application due dates. The list does not preclude the potential for Public-Private Partnerships (P3) as a funding strategy to deliver certain projects.

It should also be noted that due to the recent signing of the Surface Transportation Authorization, with the Infrastructure Investment and Job Act (IIJA), several of the descriptions, project types, eligibility requirements, and application deadlines for the funding sources listed below may be altered. More specifically, federal funding sources associated with the FAST Act may differ with the future implementation of this authorization. These funding sources are listed below:
• RAISE Grant
• Highway Safety Improvement Program (HSIP) – FAST Act
• Surface Transportation Block Grant (STBG)
• INFRA Grant
• New Starts and Small Starts (FTA Section 5309)
• Congestion Mitigation & Air Quality Improvement (CMAQ) • EPA Office of Sustainable Communities Greening America’s Communities Program State funding source descriptions, project types, eligibility requirements and application deadlines are provided based on the information given for the 2023 grant cycle. Therefore, descriptions, project types, eligibility requirements, and application deadlines are subject to change in the 2024 grant cycle. These funding sources are listed below:
• Active Transportation Program – Cycle 7
• Cap & Trade: Low Carbon Transit Operations Program (LCTOP) • State Transportation Improvement Program (STIP)
• State Highway Operations Protection Program (SHOPP)
• SB 1 – State of Good Repair
• Trade Corridor Enhancement (TCEP)
• Local Partnership Program (LPP)
Transit & Intercity Rail
• Solutions for Congested Corridors Program
• Measure C – Regional Transportation Program
South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024
36 • San Joaquin Valley Air Quality District – Public Benefit Grant Program Table 4 below presents a comprehensive summary of potential federal, state, regional, and local funding sources that could be available should any of the recommendations be pursued. As noted previously, any recommendation that progresses into project development would be subject to rigorous traffic impact analysis, engineering and design, associated environmental studies, and permitting.

South Central Fresno AB 617 Community Truck Reroute Study | Truck Routing and Implementation Strategies Report APRIL 2024 8 Next Steps
This report provided a comprehensive toolkit and list of both infrastructure and noninfrastructure strategies that aim to mitigate the negative impacts of freight truck travel within South-Central Fresno, as well as the new proposed truck route map. Additionally, the implementation section of this report provided a draft framework for the implementation of the recommended strategies within the study area based on funding availability, performance metrics, and scoring. The draft strategy toolkit and list will be revised to incorporate feedback received from the City, TSC, CAG, and community in Spring 2024. The final strategy toolkit, list, and map will be provided in the final report.

Attachment D
APRIL 2024
[ 1 ]

TABLE OF CONTENTS
List of tables............................................................................................................................................ 3 List of figures.......................................................................................................................................... 4 Contributors and acknowledgements.................................................................................................... 6 Principal investigator.......................................................................................................................... 6 Contributors ....................................................................................................................................... 6 Funding and acknowledgements........................................................................................................ 6 Executive summary (English).................................................................................................................. 7 Executive summary (Spanish) - Resumen ejecutivo ............................................................................10 Introduction and background...............................................................................................................13 Study objectives ...................................................................................................................................14 Chapter 1. Pollution and adverse birth outcomes in Fresno, California ..............................................16

1.1 Background................................................................................................................................. 16

1.2 Methods .....................................................................................................................................17

1.2.1 Participants..........................................................................................................................17

1.2.2 Exposure assessment ..........................................................................................................17

1.2.3 Outcome assessment ..........................................................................................................19

1.2.4 Statistical analyses...............................................................................................................19

1.3 Results ........................................................................................................................................21

1.3.1 Descriptive statistics............................................................................................................21

1.3.2 Effects of proximity to freeways, major roads, and truck routes........................................26

1.3.3 Effects of cumulative exposures to diesel, traffic, and air pollution...................................31

1.3.4 Acute exposures to PM2.5 and ozone ..................................................................................31

1.4 Summary.....................................................................................................................................33

1.5 Recommendations......................................................................................................................34 Chapter 2. Air pollution and asthma in Fresno, California ...................................................................35

2.1 Background................................................................................................................................. 35

2.2 Methods .....................................................................................................................................36

2.2.1 Data and participants..........................................................................................................36

2.2.2 Exposure assessment ..........................................................................................................36

2.2.3 Outcome assessment ..........................................................................................................36

2.2.4 Statistical analyses...............................................................................................................37

2.3 Results ........................................................................................................................................37

2.3.1 Descriptive statistics............................................................................................................37 [ 2 ]

2.3.2 Impacts of air pollution on asthma .....................................................................................39

2.3.3 Excess asthma events due to air pollution exposures.........................................................44

2.4 Summary.....................................................................................................................................46

2.5 Recommendations......................................................................................................................46 Chapter 3. Air pollution and cardio-cerebrovascular disease in Fresno, California.............................47

3.1 Background................................................................................................................................. 47

3.2 Methods .....................................................................................................................................48

3.2.1 Data and participants..........................................................................................................48

3.2.2 Exposure assessment ..........................................................................................................48

3.2.3 Outcome assessment ..........................................................................................................49

3.2.4 Statistical analysis................................................................................................................49

3.3 Results ........................................................................................................................................50

3.3.1 Descriptive statistics............................................................................................................50

3.3.2 Effects of air pollution on cardio-cerebral vascular events.................................................53

3.3.3 Excess cardio-cerebral vascular events associated with air pollution. ...............................58

3.4 Summary.....................................................................................................................................60

3.5 Recommendations......................................................................................................................61 Chapter 4. Community-based health survey in South Fresno AB 617 communities...........................62

4.1 Background................................................................................................................................. 62

4.2 Methods .....................................................................................................................................62

4.3 Results ........................................................................................................................................64

4.3.1 Study participants................................................................................................................64

4.3.2 Residents’ environmental health concerns.........................................................................65

4.3.3 Health conditions ................................................................................................................69

4.3.4 Civic engagement ................................................................................................................77

4.4 Summary.....................................................................................................................................77

4.5 Recommendations......................................................................................................................78 Glossary ................................................................................................................................................79 Appendices...........................................................................................................................................82 References............................................................................................................................................84 [ 3 ]

LIST OF TABLES
Table 1.1 Data sources................................................................................................................................18 Table 1.2. Characteristics of singleton live births in Fresno, California, 2009-2019...................................21 Table 1.3. Long-term exposures by community boundaries......................................................................25 Table 1.4. Associations between proximity to freeways, major roads, and truck routes and perinatal outcomes ....................................................................................................................................................30 Table 1.5. Associations between cumulative exposures and birth outcomes............................................31 Table 1.6. Associations between chronic exposures and infant mortality by race/ethnicity.....................31 Table 1.7. Associations between acute air pollution and adverse perinatal outcomes.............................32 Table 1.8. Excess cases of PTB and IM in relation to pollution exposure...................................................33 Table 2.1. Characteristics of emergency department visits and hospitalizations related to asthma in Fresno, 2011-2020 ......................................................................................................................................38 Table 2.2. Rates of asthma ED visits within and outside of the South Fresno community boundaries.....39 Table 2.3. Estimates for associations between pollution and asthma ED visits and hospitalizations........41 Table 2.4. Associations between air pollution and asthma within and outside South Fresno AB 617 Community boundaries ..............................................................................................................................42 Table 2.5. Associations between air pollution and asthma ED visits by race/ethnicity .............................43 Table 2.6. Associations between air pollution and asthma hospitalization by race/ethnicity...................43 Table 2.7. Excess cases of asthma-related ED visits and hospitalizations associated with each 5-unit increase in air pollution exposures.............................................................................................................45 Table 3.1. ICD codes to identify cardio-cerebral vascular diseases............................................................49 Table 3.2. Characteristics of emergency department visits and hospitalizations related to cardiovascular diseases in Fresno, 2011-2020....................................................................................................................50 Table 3.3. Rates of CCVD within and outside of the Fresno AB 617 community boundaries ....................52 Table 3.4. Associations between pollution and cardio-cerebral vascular ED visits and hospitalizations...55 Table 3.5. Associations between air pollution and cardio-cerebral vascular diseases within and outside the South Fresno community boundaries ..................................................................................................56 Table 3.6. Associations between air pollution and cardio-cerebral vascular ED visits by race/ethnicity...57 Table 3.7. Associations between air pollution and cardio-cerebral vascular disease hospitalizations by race/ethnicity..............................................................................................................................................57 Table 3.8. Excess CCVD cases associated with pollutants ..........................................................................58 Table 4.1. Comparison of study sample and target population ................................................................. 64 Table 4.2. Characteristics of survey participants (n=1,766)........................................................................65 [ 4 ]

LIST OF FIGURES
Figure 1.1. Road features in Fresno (Source: Fresno GIS Hub)...................................................................19 Figure 1.2. Case-crossover study design schematic....................................................................................20 Figure 1.3. Spatial distribution of preterm birth (rates per 100) and infant mortality (rates per 1,000) by zip code in Fresno, California, 2009-2019...................................................................................................23 Figure 1.4. Rates of preterm birth (A) and infant mortality (B) by time in Fresno, 2009-2019..................24 Figure 1.5. Temporal distribution of PM2.5 and ozone during the study period.........................................24 Figure 1.6. Spatial distribution of cumulative air pollution indicators in Fresno (source: CalEnviroScreen

4.0) ..............................................................................................................................................................25 Figure 1.7. Relationship between residential distance to freeways and air pollution exposures.............26 Figure 1.8. Relationship between residential distance to truck routes and air pollution exposures.........27 Figure 1.9. Relationship between residential distance to major roads and air pollution exposures.........28 Figure 1.10. Graphical correlation between residential proximity to road sources and adverse pregnancy outcomes ....................................................................................................................................................29 Figure 2.1. Rates of asthma ED visits (A) and hospitalization (B) in Fresno, 2011-2020 ............................39 Figure 2.2. Associations between air pollution and asthma ED visits by season and lag...........................40 Figure 2.3. Associations between air pollution and asthma hospitalization by season and lag.................40 Figure 2.4. Excess asthma associated with air pollution exposure in Fresno during the study period......45 Figure 3.1. Distribution of CCVD ED visits by zip codes..............................................................................51 Figure 3.2. Distribution of CCVD hospitalizations by zip codes ..................................................................52 Figure 3.3. Associations between air pollution and ED visits (A) and hospitalizations (B) for all cardiocerebral vascular events.............................................................................................................................53 Figure 3.4. Associations between air pollution and ED visits (A) and hospitalizations (B) for stroke ........53 Figure 3.5. Associations between air pollution and ED visits (A) and hospitalizations (B) for acute myocardial infarction (heart attack)...........................................................................................................54 Figure 3.6. Associations between air pollution and ED visits (A) and hospitalizations (B) for cardiac arrest ....................................................................................................................................................................54 Figure 3.7. Associations between air pollution and ED visit (A) and hospitalization (B) for heart failure..55 Figure 3.8. Excess number of ED visits (A) and hospitalizations (B) associated with air pollution in Fresno during the study period ..............................................................................................................................58 Figure 4.1. Survey area ...............................................................................................................................63 Figure 4.2. Residents’ concerns about the environment in their community............................................66 Figure 4.3. Importance of local government to address environmental issues within the next few years ....................................................................................................................................................................67 Figure 4.4. Residents’ preference for new roads that direct truck traffic away from local streets ...........67 Figure 4.5. Impacts of heat on rest and work.............................................................................................68 Figure 4.6. Impacts of air pollution and traffic noise on home rest ...........................................................69 Figure 4.7. South Fresno Residents’ chronic health conditions..................................................................70 Figure 4.8. Self-reported health conditions by race/ethnicity....................................................................70 Figure 4.9. Self-reported chronic health conditions by age........................................................................71 Figure 4.10. Self-reported chronic health condition by sex........................................................................71 Figure 4.11. Self-reported chronic health condition by educational attainment.......................................72 Figure 4.12. Self-reported chronic health condition by annual income.....................................................72 [ 5 ]
Figure 4.13. Chronic health condition by environmental health concerns ................................................73 Figure 4.14. Prevalence of having one or more chronic health conditions by proximity to pollution sources........................................................................................................................................................73 Figure 4.15. Prevalence of selected pregnancy outcomes among reproductive-aged women .................74 Figure 4.16. Adverse pregnancy outcomes by race/ethnicity ....................................................................75 Figure 4.17. Adverse pregnancy outcome by maternal age.......................................................................75 Figure 4.18. Adverse pregnancy outcomes by educational attainment.....................................................76 Figure 4.19. Adverse pregnancy outcomes by income...............................................................................76 Figure 4.20. Prevalence of having any adverse pregnancy outcome by proximity to pollution sources...77 [ 6 ]

CONTRIBUTORS AND ACKNOWLEDGEMENTS

PRINCIPAL INVESTIGATOR
Sandie Ha, PhD, MPH
Department of Public Health
University of California, Merced

CONTRIBUTORS
Department of Public Health, UC Merced
Sneha Ghimire, PhD student
Valerie Martinez, M.S., PhD student
Sandy Rubio, BA, former student
Ericka Ramsey, BA, former student
Community and Labor Center, UC Merced
Keila Luna, Junior Specialist
Rodrigo Alatriste-Diaz, MA, Associate Specialist
Ingrid Brostrom, Climate and Jobs Program Director
Edward Flores, PhD, Director
Paul Almeida, PhD, Professor
Evelyn Arana, Communication Specialist
GIS Center, UC Merced
Erin Mutch, PhD, Director
Amy Newsam, GIS Specialist
Valley Forward
Reyes Uviedo, Program Director
Maria Argueta Contreras, Project Manager
The interviewing team

FUNDING AND ACKNOWLEDGEMENTS
The project is funded by the City of Fresno and the State of California AB 617 Community Air Protection Program
We thank the San Joaquin Valley Air Pollution Control District and the Fresno Truck Reroute Study Community Advisory Committee for their valuable feedback throughout the study. We also thank the South Fresno survey respondents for their time and participation. Although their information appears as data in this report, we acknowledge that their participation in the study is invaluable for communityengaged efforts to mitigate the impact of pollution on health in Fresno.

Lastly, we thank the California Department of Public Health Office of Vital Statistics and the California Department of Health Care Access and Information for granting us permission to use their data, as well as the Fresno residents who contributed to these data.
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EXECUTIVE SUMMARY
Fresno County has some of the nation’s greatest environmental inequalities. In 2022, Fresno had the highest short-term particle pollution, second highest year-round particle pollution, and fourth highest ozone pollution in the nation. Assembly Bill 617, effective in 2017, created the Community Air Protection Program (CAPP), to more effectively reduce pollution exposure and preserve public health.

This bill directs the California Air Resources Board (CARB) and all local air districts, including the San Joaquin Valley Air Pollution Control District, to take measures to protect communities who are disproportionately impacted by air pollution.

In 2022, the San Joaquin Valley Air Pollution Control District (hereafter the Air District) and the City of Fresno collaborated to undertake the South-Central Fresno AB 617 Community Truck Reroute Study. The aim of the study is to identify, analyze, and evaluate potential strategies that the city might implement, in cooperation with freight-impacted communities, to abate truck impacts (e.g., health, pollution, noise, etc.). In the same year, the City of Fresno commissioned the UC Merced Community and Labor Center to conduct a Health Impact Assessment (HIA) in Fresno. The results of the Fresno HIA, presented in this report, are intended to inform the ongoing South Fresno Truck Reroute Study The Fresno HIA has two main components. The first is a large, city-wide assessment. This assessment contains air district data, birth data, emergency department visits, as well as all Fresno patient discharge data. The second Fresno HIA component is the South Fresno Community Survey, which is a representative, community-based survey of South Fresno residents’ health, wellbeing, and concerns with local environmental issues.
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KEY FINDINGS:

Part 1: Population-Based Assessment
» South Fresno residents were, on average, more likely to live closer to a major street, truck route, or freeway.
» Exposures to air pollutants such as fine particles <2.5 microns (PM2.5), ozone, and diesel, were associated with higher risk of the following: preterm birth, infant mortality, and emergency room visits or hospitalization due to asthma, or diseases related to the blood vessels of the heart and brain (e.g. heart attack, stroke, etc.).
» Pregnant people who lived within 1,000 feet of a freeway, 1,000 feet of a truck route, or 300 feet of a major road had significantly higher risk of adverse pregnancy outcomes, including preterm birth and infant mortality.1
» Preterm birth, infant mortality, and asthma rates were higher among residents in the South Fresno community boundaries compared to the rest of the city.
» Even at the same level of exposure, residents within the South Fresno community boundaries and communities of color experienced higher health risks.
» The effects of PM2.5 were stronger in the cold season (November-April) whereas the effects of ozone were stronger in the warm season (May-October).

Part 2: South Fresno Community Survey
» Among residents within the South Fresno community boundaries, there is a high level of environmental health concern related to road conditions, pollution, and climate change. » Most South Fresno residents support local efforts to direct trucks away from local residential areas.
» Almost half of residents (43%) reported having at least one chronic health condition. » Over a quarter of women of reproductive age (18-46 years) reported having an adverse pregnancy outcome, such as miscarriage (22%), stillbirth (3%), infant mortality (0.8%), or having a child with a birth defect (1.6%).
» A significant proportion of residents reported that they “sometimes, “often,” or “always” were unable to rest because of air pollution (61%) and traffic/truck noise (49%). These residents were more likely to have health problems.
» Residents who lived within 1,000 feet of a truck route, freeway, or major road had a higher prevalence of chronic health conditions and adverse pregnancy outcomes.1 1 These distances best distinguish the risks among residents inside and outside the buffers. As such, our findings do not suggest those living outside of this buffer have negligible risks. [ 9 ]
KEY RECOMMENDATIONS:
» The South-Central Fresno AB 617 Community Truck Reroute Study should propose options that minimize, to the greatest degree possible, truck routes and traffic within 1,000 feet of residential areas.
» A more conservative buffer should be considered, given that residents within the South Fresno AB 617 community, and communities of color, bear higher health risks for the same exposures to pollution.
» Implement season-specific strategies to mitigate truck emissions. Acute exposure was shown to have significant health impacts. The summer presented the greatest risk for exposure to ozone, while the winter presented the greatest risk for exposure to PM2.5 particles. » The use of zero-emission commercial trucks is also recommended to reduce population exposures to air pollution.

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de pacientes entre todos los residentes de Fresno; y 2) una encuesta representativa, basada en la comunidad 617, sobre la salud, el bienestar y las preocupaciones de los residentes del sur de Fresno con respecto a los problemas medioambientales locales.

PRINCIPALES RESULTADOS:

Parte 1: Evaluación de la Salud de la Población
» Los residentes del sur de Fresno tenían una mayor probabilidad de vivir cerca de una calle principal, una ruta de camiones o una autopista.
» Ser expuesto a contaminantes de aire como las PM2.5, el ozono y el diésel son asociados con un mayor riesgo de parto prematuro, mortalidad infantil y más visitas de urgencias u hospitalización por asma o enfermedades relacionadas con los vasos sanguíneos del corazón y el cerebro (por ejemplo, infarto de miocardio, accidente cerebrovascular, etc.). » Las personas embarazadas que vivían entre 1,000 pies de una autopista, 1,000 pies de una ruta de camiones o 300 pies de una carretera principal tenían un riesgo significativamente mayor de sufrir un embarazo adverso, incluso el parto prematuro y la mortalidad infantil. 2 » Las tasas de nacimientos prematuros, mortalidad infantil y asma eran más altas entre los residentes de los límites de la comunidad del Sur de Fresno en comparación con el resto de la ciudad.
» Incluso con el mismo nivel de ser expuesto a la contaminación del aire, los residentes dentro de los límites de la comunidad del Sur de Fresno y las comunidades de color sufrieron mayores riesgos de salud.
» Los efectos de PM2.5 fueron más elevados durante la temporada de frio (noviembre-abril) mientras que los efectos del ozono fueron más elevados durante la temporada de calor (mayo-octubre).

Parte 2: Encuesta Comunitaria del Sur Fresno
» Los residentes dentro de los límites de la comunidad del Sur de Fresno, expresaron un alto nivel de preocupación por la salud ambiental relacionada con las condiciones de las carreteras, la contaminación y el cambio climático.
» La mayoría de los residentes del Sur de Fresno apoyan los esfuerzos locales para alejar los camiones de las zonas residenciales locales.
» Casi la mitad de los residentes (43%) declararon tener al menos un problema de salud crónico, y más de una cuarta parte de las mujeres en edad reproductiva (18-46 años) declararon haber tenido un resultado adverso en el embarazo, como aborto espontáneo (22%), muerte fetal (3%), mortalidad infantil (0.8%) o haber tenido un hijo con un defecto congénito (1.6%). » La mayoría de los residentes declararon que "a veces", "a menudo" o "siempre" no poder descansar debido a la contaminación de aire (61%) y el ruido del tráfico/camiones (49%). Estos residentes son más probables de tener problemas de salud. 2 Estos límites son los que mejor distinguen los riesgos entre los residentes dentro y fuera. Por tanto, nuestros resultados no sugieren que los que viven fuera de esta zona tengan riesgos insignificantes. [ 12 ]
» Los que vivían entre 1,000 pies de un ruta de camiones, autopista o carretera principal tenían una mayor prevalencia de problemas de salud crónicos y resultados adversos del embarazo. 3 RECOMENDACIONES CLAVE:
» El Estudio de Desvió de Camiones del Sur de Fresno debe proponer opciones que minimicen, de la mayor manera posible, las rutas de camiones y el tráfico dentro de 1,000 pies de las zonas residenciales.
» Se debe considerar una zona de mayor protección, dado que los residentes dentro de la comunidad AB617 del Sur de Fresno, y las comunidades de color, corren mayores riesgos de salud por ser expuestos a los mismos niveles de contaminación » Aplicar estrategias basada en las temporadas específicas para reducir las emisiones de los camiones. Se demostró que la exposición aguda tiene importantes consecuencias para la salud; y mientras que el verano presenta el mayor riesgo de exposición al ozono, el invierno presenta el mayor riesgo de exposición a las partículas PM2.5.
» También se recomienda el use de camiones comerciales de cero emisiones para reducir la exposición de la población a la contaminación de aire.
3 Estos límites son los que mejor distinguen los riesgos entre los residentes dentro y fuera. Por tanto, nuestros resultados no sugieren que los que viven fuera de esta zona tengan riesgos insignificantes. [ 13 ]

INTRODUCTION AND BACKGROUND
Air pollutants, including fine particles and ozone, have been consistently linked to many health outcomes across the lifespan, ranging from minor respiratory irritation to cardiorespiratory complications and even premature death.1-6 Biologic mechanisms linking air pollution to adverse health outcomes include oxidative stress, systemic inflammation, and endocrine disruption.7,8 Despite a significant body of work, very few studies have comprehensively evaluated the health impacts of air pollution in Central California, an area with significant air pollution levels, marked health disparities, and severely limited access to care.9,10
Fresno, home to almost 545,000 residents, is the fifth largest city of California and is located in the San Joaquin Valley (SJV). It is characterized by some of the nation’s greatest environmental inequalities. In 2022, Fresno ranked highest for short-term particle pollution, second highest for year-round particle pollution, and fourth highest for ozone pollution in the nation.11 Reasons contributing to the high pollution levels in the SJV include topography and, more importantly, the numerous pollution sources.

The SJV is surrounded by mountain ranges that can trap air pollutants for an extended time. The weather conditions (e.g., heat, sunlight) are conducive to pollution formation and retention. The area also has heavy truck traffic, many diesel-burning locomotives, and other sources of pollution on I-5 and Highway 99 as well as other sources. These sources emit significant amounts of fine particles and precursors to ozone including nitrogen oxides (NOx) and volatile organic compounds (VOC). These precursors react with heat and sunlight to form harmful ground-level ozone, which often exceeds recommended standards. Although the levels of ozone and fine particles in the SJV have generally declined in recent years, these pollutants remain significant public health concerns.12 As such, continued efforts to reduce emission and population exposure are critical.

In 2017, the California governor signed Assembly Bill 617, which aims to develop a new communityfocused program to more effectively reduce exposure to air pollution and preserve public health. This bill directs the CARB and all local air districts, including the Air District, to take measures to protect communities disproportionally impacted by air pollution. [ 14 ]
In 2022, The Air District and the City of Fresno joined forces to undertake the South-Central Fresno AB 617 Community Truck Reroute Study, which will identify, analyze, and evaluate potential strategies that freight-impacted communities might implement to abate truck impacts (e.g., health, pollution, noise, etc.). In the same year, UC Merced was commissioned by the City of Fresno to conduct a Health Impact Assessment (HIA) within the city. The results of the Fresno HIA are intended to inform the ongoing South Fresno Truck Reroute Study.

STUDY OBJECTIVES
The primary objective of the Fresno HIA is to assess the impact of air pollution (and proximity to truck traffic) on the risk of common health outcomes across the lifespan. These health outcomes include infant mortality, preterm delivery, asthma, and cardio cerebral vascular events in the city of Fresno from 2009 to 2020. Second, to inform policy and planning efforts, we also calculated the excess number of cases that are attributed to air pollution in the region. Stated differently, these estimates refer to the number of cases that could be prevented if air pollution levels are minimized. Additionally, we also explored how the health impacts of air pollution differ within subgroups of the Fresno population. Third, we conducted a South Fresno community-based health survey to understand residents’ concerns, health outcomes, and health needs that are relevant to the South Fresno Truck Reroute Study.

The HIA utilizes both large population-based datasets from the Department of Health Care Access and Information (HCAi) and a representative sample community-based survey. The study also makes use of publicly available data. Detailed data sources associated with each study component are described in Table 1.

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CHAPTER 1. POLLUTION AND ADVERSE BIRTH OUTCOMES IN FRESNO,

CALIFORNIA

1.1 BACKGROUND
Pregnant women and their unborn fetuses are extremely vulnerable to environmental pollution. 14-16 Due to the rapid and complex changes, pregnancy is considered the ultimate stress test.17,18 During a normal pregnancy, bodily organs and systems change in different ways at different times in a tightly coordinated manner to accommodate the growing fetus.19 Thus, exposure to hazardous environmental factors during pregnancy result in both immediate and cascading long-term effects, especially for the growing fetus. Meanwhile, the placenta supports exchanges of nutrients, gases, and metabolites while gatekeeping the transfer of harmful pathogens and environmental chemicals to the growing fetus.

However, recent studies have shown that fine particles can cross the placental barriers and reach the developing fetus.20,21 These concerning effects of air pollution on pregnancy merit further attention, especially in regions with high pollution and a high burden of adverse pregnancy outcomes.

Preterm birth (PTB), defined as a birth occurring before 37 weeks of gestation, is a common and serious pregnancy outcome. In 2021, PTB occurred in approximately 9% of all pregnancies in California, but the rate is higher in Fresno, affecting about 11% of pregnancies.22 In the same year, PTB rates were highest for American Indian/Alaskan Natives (15.2%), followed by Black (14.8%), multi-race (11.3%), Hispanic (10.1%), Asian (9.7), and White (9.3%).23 PTB is known to be associated with multiple immediate and long-term health complications for affected babies. Because babies need the final weeks in the womb to further develop, PTB results in many problems, including issues related to breathing, temperature [ 17 ]
control, digestion, and metabolic and immune functions.24 Due to these health complications, a delivery affected by PTB, on average, costs about four times more than a healthy delivery.22 More importantly, babies born preterm have a significantly higher risk of developing many health complications later in life, including asthma, obesity, cardiovascular disease, mental health complications, learning disabilities, poorer academic performance, and even cancer.25-33 Another devastating birth outcome is infant mortality (IM), defined as death occurring to a live birth within the first year of life. Although IM is rarer, occurring at 3.9 per 1,000 live births in 2020 in California, it is a devastating outcome affecting families in unimaginable ways.34
Air pollutants, including fine particulate matter less than 2.5 microns in diameter (PM2.5) and ozone, have been consistently linked to adverse pregnancy outcomes including pregnancy loss, restricted fetal growth, preterm birth, and infant death35-41 through biologic mechanisms including oxidative stress, systemic inflammation, and endocrine disruption.7,8 Studies also suggest that living close to major air pollution sources such as freeway, major roads, and truck routes are also associated with health risks.42- 46 Despite a significant body of work, no existing studies have evaluated risks of adverse pregnancy outcomes in relation to air pollution exposures in Fresno, an area with significant air pollution, marked health disparities, and severely limited access to care.9,10 The aims of Chapter 1 are as follows:

1. Assess the distribution/patterns of PTB and IM in Fresno.

2. Assess the distribution of pollution burden in Fresno.

3. Evaluate the relationship between residential proximity to freeways, major roads, and truck routes and PTB and IM.

4. Evaluate the effects of acute as well as cumulative exposures to air pollution on PTB/IM.

Estimate the number of PTB and IM that can be attributed to short-term air pollution.

1.2 METHODS

1.2.1 PARTICIPANTS
We obtained birth certificate data from the California Department of Health Vital Statistics Office for 106,411 babies born in the city of Fresno from 2009-2019. These birth certificates were also deterministically linked to death certificates if a live birth died within one year. Given the fact that multiple gestations (i.e., twins, triplets, etc.) are predisposed to additional risks of preterm birth and infant mortality, we excluded these births from our analysis. The final analyses included 103,566 singleton babies born in the city of Fresno from 2009 to 2019. Our study has been approved by the Institutional Review Boards from the State of California and the University of California, Merced.

1.2.2 EXPOSURE ASSESSMENT
We obtained daily concentration of two common air pollutants—fine particulate matter less than 5 microns (PM2.5, 24-hr. average) and ozone (maximum 8-hr. average)—from the Air District. These daily concentrations were estimated by the Air District using a regression-based mathematical model with

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Euclidian distance from each address to the nearest existing road feature. Euclidean distance can be thought of as distance from bird’s-eye view. Figure 1.1 provides a map of road features in the city of Fresno. We note here that “freeway” here includes what locals refer to as “highway” (e.g., Highway 99), as indicated in red. We use this language to be consistent with city documents.

Figure 1.1. Road features in Fresno (source: Fresno GIS Hub)

1.2.3 OUTCOME ASSESSMENT
The main pregnancy outcomes of interest in this study include preterm birth and infant mortality. Both outcomes were ascertained using birth and death certificates. Specifically, preterm birth (PTB) was defined as a birth occurring before 37 completed weeks of gestation, and infant mortality (IM) was defined as death within the first year of a live birth.

1.2.4 STATISTICAL ANALYSES
Basic statistical tests including t-tests and chi-square tests were used to describe and compare study participant characteristics. Briefly, t-tests and chi-square tests are common statistical methods used to compare two averages (means) and two or more proportions, respectively. We also used basic plots and heat maps to describe the distributions of exposures and outcomes among participants.

To determine the impacts of air pollution and residential proximity to freeways, major streets, and truck routes on adverse pregnancy outcomes, we implemented two different methods. First, we used mixed models to determine the relationship between each pregnancy outcome (PTB and IM) with residential proximity to freeway, major streets, truck routes, diesel emission, traffic, and long-term PM2.5 and ozone exposures. In these analyses of cumulative exposures, we compared the risks of PTB and IM between those with varying levels of exposure. We considered potential confounders such as maternal age, race, education, and neighborhood income.

Note: some features may overlap
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Second, to investigate the impacts of time-varying air pollution on adverse pregnancy outcomes, we used a time-stratified case-crossover analysis.50 This strategy is a preferred method to examine the short-term relationship between transient exposures (i.e., air pollution) and acute health outcomes (i.e., preterm birth and infant death) due to its ability to allow complete control for non-time-varying confounders.51 More specifically, in this analysis, we only selected cases who were impacted by the health outcomes of interest. We then compared exposures (i.e., PM2.5 and ozone) during a hazard period shortly before the event (preterm birth or infant death) to exposures during control periods during which the event did not happen. The hazard period was defined as the day of event (lag 0) and each of the six days before the event (lags 1-6). Control periods were selected using the time-stratified approach, where controls were selected as the same day of the week within the same month as the case period.52 For example, if a pregnant person had a preterm birth on Monday, March 12, 2018, then this will be the case period (lag 0). The control periods for this person would be selected as Mondays the 5th, the 19th, and the 26th of the same month of March (Figure 1.2). This approach allows control for days of the week and month and minimizes time-trend bias. Since the comparisons were made within the same person, this approach allows complete control for non-time-varying confounders (or factors that could explain the observed associations). Conditional logistic regression models were used to estimate the risks of adverse pregnancy outcomes associated with 5-unit increase in air pollution exposures.

To calculate excess cases of PTB due to air pollution, also known as the attributable risk (AR), we used the formula:

𝐴𝐴𝐴𝐴 = 𝐼𝐼𝑒𝑒 − 𝐼𝐼𝑢𝑢
where 𝐼𝐼𝑢𝑢 is the average rate of event in the study population (i.e., background rate), and 𝐼𝐼𝑒𝑒 is the incidence of event among those exposed to the higher pollutants and is calculated as 𝐼𝐼𝑢𝑢 times the odds ratio. 𝐼𝐼𝑢𝑢 represents the background risks (i.e., average in the population) and was calculated as the total number of PTB in the city of Fresno divided by the total annual number of births.

We also stratified our analyses by season (warm: May-October, cold: November – April), maternal characteristics, and residential area (within vs. outside of AB 617 community boundaries) to explore the potential differential effects between different groups. All analyses were performed using SAS 4.0 (Cary, NC), and ArcGIS Pro (Redlands, CA).

Figure 1.2. Case-crossover study design schematic

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Figure 1.4. Rates of preterm birth (A) and infant mortality (B) by time in Fresno, 2009-2019 The red-shaded region represents the rates within South Fresno and the blue-shaded region represents the rates for the rest of the city.

During the study period, daily PM2.5 and ozone concentrations varied by season as expected. PM2.5 concentrations were higher during the colder months and ozone concentrations were higher during the warmer months. They appeared to be similar within and outside of the South Fresno AB 617 Community boundaries (Figure 1.5). Annual average concentrations of PM2.5 decreased slightly but concentrations of ozone remained consistent.

Figure 1.5. Temporal distribution of PM2.5 and ozone during the study period Meanwhile, there is spatial variation in cumulative diesel, traffic, PM2.5 and ozone levels (Figure 1.6).

More specifically, diesel particle and traffic exposures were higher in census tracts along freeways and areas with more roads. Cumulative PM2.5 and ozone exposures were higher in the western part of the city compared to the rest. Data also show that traffic levels (972.2 vs. 845.7), diesel emissions (0.36 vs.

0.20), and cumulative PM2.5 concentrations (13.8 vs. 13.5) were higher in zip codes within the South Fresno AB 617 Community boundaries compared to the rest of the city (Table 1.3).

[ 26 ]

1.3.2 EFFECTS OF PROXIMITY TO FREEWAYS, MAJOR ROADS, AND TRUCK ROUTES On average, pregnant people who lived closer to freeways, truck routes, or major streets were exposed to higher concentrations of pollutants (Figure 1.7 – Figure 1.9). More specifically, the closer pregnant people lived to freeways, the greater the exposures to PM2.5, diesel, and traffic they were exposed (Figure 1.7). Similarly, people living closer to truck routes (Figure 1.8) and major streets (Figure 1.9) were exposed to higher PM2.5, ozone, diesel emissions, and traffic.

Figure 1.7. Relationship between residential distance to freeways and air pollution exposures [ 27 ]
Figure 1.8. Relationship between residential distance to truck routes and air pollution exposures [ 28 ]
Figure 1.9. Relationship between residential distance to major roads and air pollution exposures In general, proximity to freeways, truck routes, and major roads were correlated with increased probability of PTB or IM (Figure 1.10). More specifically, the predicted risk of both PTB and IM increased as distance from freeways and truck routes decreased. While distance from major streets was negatively correlated with PTB risk, this observation was not seen for IM. [ 29 ]
Figure 1.10. Graphical correlation between residential proximity to road sources and adverse pregnancy outcomes
The red dash line represents the average rate in the study population.

Our mixed models suggest that every 500 feet closer to a freeway or major road was associated with a 1% increase in PTB risks. Similarly, 500 feet closer to a truck route was associated with about a 2% increase in PTB risk. Although these estimates are small, the public health impact is substantial given the large population living close to freeways and truck routes (Table 1.2). Based on the data above, we also explored the different distance thresholds at which risks of PTB and IM increased substantially. Based on exploratory evidence and the literature, we considered multiple buffers (in feet), including 300, 500, 600, 700, 800, 900, and 1,000 feet.

Compared to those living >1,000 feet from a freeway, those living ≤1,000 feet had 11% increased risk in PTB, and 44% increased risks of IM. These risks remained consistent for smaller buffers. After adjusting for key characteristics including maternal age, race/ethnicity, maternal education, and area level poverty level, the associations remained significant for IM (Table 1.4), where infants who lived within 1,000 feet of a freeway had a 23% increased risk of dying within the first year of life.

A similar pattern of association was observed for proximity to truck routes in relation to PTB. More specifically, living within 1,000 feet of a truck route was associated with about 5% increased risk of PTB, and these risks remained consistent for closer buffers. These associations remained elevated after adjusting for covariates, but the estimates were less precise. There appeared to be no association between proximity to truck routes and IM, which could potentially be because of the low number of IM cases.

Those who lived within 300 feet of a major road had about 4-5% increased risk of PTB and IM after adjusting for potential confounders. However, estimates for IM were not precise due to the small number of cases.

[ 34 ]
the summer and PM2.5 in the winter season. These observations are consistent with the known seasonal variability of the two pollutants, where ozone is much higher in the warm season due to the abundance of sunlight and heat, and PM2.5 is higher in the colder season due to temperature inversion.

This study also has had the notable merit of being the first study in the area to evaluate the impacts of proximity to freeways and truck routes. The modelled air pollution data by the Air District has been validated and shows high accuracy.58 These data are also used for air pollution forecasts and policy decisions in the area. Thus, findings will have direct implications for policy decision. Lastly, the casecrossover nature of our analyses eliminates confounding, which ensures that the effects of air pollution on PTB are unlikely driven by other characteristics.

In summary, our findings generally suggest that living in areas with more pollution sources and pollution concentration (both long-term and short-term) exposes people to significant risks of developing adverse pregnancy outcomes. With evidence of heightened concerns within our AB 617 community boundaries, and communities of color, we recommend future policies take these risks into account and prioritize efforts to reduce pollution emission overall, but especially in highly impacted areas.

1.5 RECOMMENDATIONS
With respect to the Fresno Truck Reroute Study, we specifically recommend:

1. Developing truck routes outside of a 1,000-foot buffer around residential areas. Where appropriate, a bigger buffer could also be used, especially in areas with more vulnerable populations.

2. Planning future truck routes to be at least 1,000 feet from areas where people live, work and play. It would be prudent to avoid truck routes near locations where vulnerable populations are located, such as schools, daycare, and hospitals.

3. Due to the fact that there is seasonal variation in health effects, creative strategies to address seasonal changes may be helpful. For example, seasonal truck regulation may be considered.

4. We also recommend the use of zero-emission commercial trucks when possible to minimize population exposure
[ 35 ]
CHAPTER 2. AIR POLLUTION AND ASTHMA IN FRESNO, CALIFORNIA

2.1 BACKGROUND
Asthma is a common but serious respiratory illness in California, occurring to about 8.8% of the population in 2021.59 For the Fresno population, the prevalence of asthma is about 12.8%.60 Asthma can cause morbidity, sleep disturbance, loss of productivity (e.g., school, work), and reduced quality of life. If unmanaged, asthma can also lead to severe morbidity, hospitalization, and even death.

Studies around the world have linked air pollution to asthma risk with well-established biologic mechanisms.61,62 However, very few studies have assessed impacts of air pollution on asthma in the San Joaquin Valley (much less Fresno), an area with known concerns related to pollution and heightened asthma risks.

The purpose of this analysis is to estimate the effects of air pollution on asthma among Fresno residents, with regard to major roads, truck routes, and freeways. In addition, we estimated the amount of asthma that could have been prevented by a given decline in localized air pollution. [ 36 ]

2.2 METHODS

2.2.1 DATA AND PARTICIPANTS
In this chapter, we examine California Department of Health Care Access and Information (HCAi) Emergency Department (ED) visits and Patient Discharge Data (PDD) between the years 2011 and 2020.63 These are the latest available data. ED datasets consist of demographic, clinical, and facility information of all emergency department face-to-face encounters with a healthcare provider in California hospitals licensed to provide emergency medical services. Meanwhile, the PDD dataset consists of records for each inpatient discharge from any California-licensed hospital. Licensed hospitals can include general acute care, acute psychiatric care, chemical dependency recovery facilities, and psychiatric health facilities.

For this study, we only selected ED visits and hospitalization from Fresno zip codes. We further restricted the datasets to ED visits and inpatient visits for those with asthma as the primary diagnosis.

We also note that due to the lack of personally identifiable information, we cannot follow individuals longitudinally and we therefore have to treat each ED visit or hospitalization as an independent event.

We note that people visit the ED and end up being admitted, they only show up under the hospitalization data. In other words, no person would be counted twice for the same encounter.

2.2.2 EXPOSURE ASSESSMENT
We estimated daily exposures to PM2.5 and ozone using a similar approach described in Chapter 1, Section 1.2.2. Briefly, we obtained daily concentration of two common air pollutants, fine particulate matter less than 5 microns (PM2.5, 24-hr. average PM2.5) and ozone (maximum 8-hr. average), from the Air District. These daily concentrations were estimated by the Air District using a regression-based mathematical model with inputs from local air monitors and the Community Multilevel Air Quality (CMAQ) model output from the California Air Resources Board.47,48 These data were estimated at the zip code level for spatiotemporal linkages to the health data. Participants were then spatiotemporally linked to daily air pollution data based on their residential zip code at the time of event. We specifically focused on acute air pollution exposure and its effects within seven days following prior knowledge in the field.

Due to the lack of residential addresses from HCAi datasets, we were unable to geocode participants for detailed spatial analyses more granular than the zip code level (such as those in Chapter 1).

2.2.3 OUTCOME ASSESSMENT
We utilized the 9th and 10th version of the International Classification of Disease codes with clinical modification (ICD-9-CM and ICD-10-CM) to identify asthma ED visits and hospitalizations. More specifically, for data prior to 2015, we identified asthma cases as those who had an ED visit or hospitalization with an ICD-9-CM code starting with 493 as the principal diagnosis code. In 2015 and [ 37 ]
later years, we used ICD-10-CM code J45. To ensure that we capture cases more accurately, we used both ICD-9 and ICD-10 codes in the transition year 2015.

2.2.4 STATISTICAL ANALYSES
To determine the impacts of air pollution on asthma in Fresno, we employed the time-stratified casecrossover analysis to minimize confounding by factors that can also explain risks of asthma. A detailed description of this method is described in section Chapter 1, section 1.2.4 above. Briefly, in this analysis, we only selected cases that were impacted by asthma. We then compared exposures (i.e., PM2.5 and ozone) during a hazard period shortly before the event to exposures during control periods during which the event did not happen. The hazard period was defined as the day of the event (lag 0) and each of the six days before the event (lags 1-6). Control periods were selected using the time-stratified approach, where controls were selected as the same day of the week within the same month as the case period.52 For example, if someone visited the ED or got hospitalized because of asthma on Monday, March 12, 2018, then this will be the case period (lag 0). Their control period will be selected as Mondays the 5th, the 19th, and the 26th of the same month of March (Figure 1.2). This approach allows control for days of the week and month and minimizes time-trend bias. Since the comparisons were made for the same person, this approach allows complete control for non-time-varying confounders (or factors that could explain the observed associations). Conditional logistic regression models were used to estimate the risks of asthma associated with a 5-unit increase in air pollution exposures. We found meaningful seasonal differences and presented results by season (cold: November – April, warm: May-October). We additionally explored effects by AB 617 residence status and race/ethnicity.

We calculated the access number of asthma ED visits and hospitalizations due to pollution, also known as the attributable risk (AR), using the following formula:

𝐴𝐴𝐴𝐴 = 𝐼𝐼𝑒𝑒 − 𝐼𝐼𝑢𝑢
where 𝐼𝐼𝑢𝑢 is background rate of event in the population, and 𝐼𝐼𝑒𝑒 is the incidence of events among those exposed to the higher pollutants and is calculated as 𝐼𝐼𝑢𝑢 times the odds ratio. 𝐼𝐼𝑢𝑢 was calculated as the average annual number of events in the city of Fresno divided by the total population estimated by the 2020 Census (n=545,567).64
All analyses were completed in ArcGIS Pro (Redlands, CA), SAS 9.2 (Cary, NC) and Microsoft Excel (Redmond, WA).

2.3 RESULTS

2.3.1 DESCRIPTIVE STATISTICS
The analysis included 45,455 asthma ED visits and 7,296 inpatient hospitalizations among participants in Fresno zip codes (Table 2.1).

[ 40 ]
Figure 2.2. Associations between air pollution and asthma ED visits by season and lag Models adjusted for temperature, humidity, and co-pollutants. Time-unvarying factors were controlled by study design. Estimates were obtained for each 5-unit increase in pollutants. The numbers on the x-axis represent lag, which can be interpreted as the number of days after exposure. For example, lag 0 = risk on the day of exposure, lag 1 = risk one day after exposure, etc. Cold season: Nov. – Apr., warm season: MayOct. Abbreviations: ED, emergency department; PM, particulate matter; CI, confidence intervals.

The effects of PM2.5 and ozone on asthma hospitalization are similar to those of asthma ED visits described above (Figure 2.3, Table 2.3). A 5-unit increase in PM2.5 exposure during the cold season is associated with about 2-3% increase in risk of being hospitalized for asthma within one week. During the warm season, a 5-unit increase in ozone is associated with a 5-8% increased risk of being hospitalized by asthma.

Figure 2.3. Associations between air pollution and asthma hospitalization by season and lag

0.85 0.90

0.95 1.00

1.05 1.10
0 1 2 3 4 5 6 0 1 2 3 4 5 6 0 1 2 3 4 5 6 0 1 2 3 4 5 6 PM2.5 Ozone PM2.5 Ozone
Cold season Warm season
Odds ratio (95% CI)

0.70 0.75

0.80 0.85

0.90 0.95

1.00 1.05

1.10 1.15
0 1 2 3 4 5 6 0 1 2 3 4 5 6 0 1 2 3 4 5 6 0 1 2 3 4 5 6 PM2.5 Ozone PM2.5 Ozone
Cold season Warm season
Ods ratio (95% CI)

[ 47 ]
CHAPTER 3. AIR POLLUTION AND CARDIO-CEREBROVASCULAR DISEASE IN

FRESNO, CALIFORNIA

3.1 BACKGROUND
Cardio-cerebrovascular disease (CCVD) is an overarching category of serious health outcomes encompassing various heart and brain conditions associated with vascular issues, including atherosclerosis, hypertension (high blood pressure), myocardial hypertrophy, and strokes.65 CCVDs can manifest independently, but can coexist in varying degrees.66 CCVDs pose significant public health concerns, marked by high morbidity, high disability rate, frequent recurrences, and elevated mortality rates.66 Roughly one out of three adults in California, equating to more than 8 million individuals, live with some form of CCVD.67 CCVD is the number one cause of death and disability in California.68 In Fresno County, heart disease was ranked the number one leading cause of death among residents in 2021.69
Studies around the world consistently linked air pollution exposures to CCVD. Recent systematic reviews and meta-analyses have suggested that exposures to both PM2.5 and ozone are associated with CCVD risks.70-75 Despite the high pollution and high burden of CCVD in Fresno, no studies have evaluated these impacts in this region.

The purpose of this chapter is to evaluate the impacts of PM2.5 and ozone exposures on the risks of going to the emergency room or being hospitalized due to CCVD in the city of Fresno. We further estimated [ 48 ]
the number of excess cases due to air pollution, and explored whether certain subgroups of the population may be more impacted by air pollution.

3.2 METHODS
The approach for this study is similar to that described in Chapter 2.

3.2.1 DATA AND PARTCIPANTS
In this chapter, we examined data from the California Department of Health Care Access and Information (HCAi), including Emergency Department (ED) visits and Patient Discharge Data (PDD) between the years 2011 and 2020.63 These are the latest available data. ED datasets consist of demographic, clinical, and facility information of all emergency department face-to-face encounters with a healthcare provider in California hospitals licensed to provide emergency medical services.

Meanwhile, the PDD dataset consists of records for each inpatient discharge from any Californialicensed hospital. Licensed hospitals can include general acute care, acute psychiatric care, chemical dependency recovery facilities, and psychiatric health facilities.

For this study, we only selected ED visits and hospitalizations from Fresno zip codes. We further restricted the datasets to ED visits and inpatient visits for those with the following cardio-cerebral vascular (CCVD) conditions as the primary diagnosis: acute myocardial infarction (stroke), heart failure, cardiac arrest, and cerebral infarction (stroke). We also note that, due to the lack of personally identifiable information, we cannot follow individuals longitudinally and we therefore have to treat each ED visit or hospitalization as an independent event. If someone visits the ED and ends up being admitted, the individual only shows up under the hospitalization data. In other words, no person would be counted twice for the same encounter.

3.2.2 EXPOSURE ASSESSMENT
We estimated daily exposures to PM2.5 and ozone using an approach similar to that described in Chapter 1, Section 1.2.2 and Chapter 2 section 2.2.2. Briefly, we obtained data for daily concentration of two common air pollutants, fine particulate matter less than 5 microns (PM2.5, 24-hr. average PM2.5) and ozone (maximum 8-hr. average), from the Air District. These daily concentrations were estimated by the Air District using a regression-based mathematical model with inputs from local air monitors and the Community Multilevel Air Quality (CMAQ) model output from the California Air Resources Board.47,48 The data was estimated at the zip code level for spatiotemporal linkages to the health data. Participants were then spatiotemporally linked to daily air pollution data based on their residential zip code at the time of the event. We specifically focused on acute air pollution exposure and its effects within 7 days.

Due to the lack of residential addresses from HCAi datasets, we were unable to geocode participants for detailed spatial analyses more granular than the zip code (like those in Chapter 1).

[ 53 ]

3.3.2 EFFECTS OF AIR POLLUTION ON CARDIO-CEREBRAL VASCULAR EVENTS Exposures to PM2.5 and ozone were both positively associated with CCVD events, but these associations varied by season, where the detrimental effects of PM2.5 and ozone were only observed in the cold and warm season, respectively (Figure 3.2, Table 3.4). Each 5-unit increase in ozone was associated with a 2- 4% increased risk of CCVD events within 4-6 days. PM2.5 was linked to increased incidents of CCVD as soon as one day after exposure and the risks increased over the next few days.

The associations remained consistent when we separated the analyses for specific CCVD types, including stroke (Figure 3.3), heart attack (Figure 3.4), cardiac arrest (Figure 3.5), and heart failure (Figure 3.6).

Figure 3.3. Associations between air pollution and ED visits (A) and hospitalizations (B) for all cardiocerebral vascular events Models adjusted for temperature, humidity, and co-pollutants. Time-unvarying factors were controlled by study design. Estimates were obtained for each 5-unit increase in pollutants. Cold season: Nov. – Apr., warm season: May-Oct. Numbers on x-axis represent lags, which can be interpreted as the number of days after exposure. For example, lag 0 = risk on the day of exposure, lag 1 = risk one day after exposure, etc.

Abbreviations: ED, emergency department; PM2.5, particulate matter <2.5 microns.

Figure 3.4. Associations between air pollution and ED visits (A) and hospitalizations (B) for stroke Models adjusted for temperature, humidity, and co-pollutants. Time-unvarying factors were controlled by study design. Estimates were obtained for each 5-unit increase in pollutants. Cold season: Nov. – Apr., warm season: May-Oct. Numbers on x-axis represent lags, which can be interpreted as the number of days after exposure. For example, lag 0 = risk on the day of exposure, lag 1 = risk one day after exposure, etc.

Abbreviations: ED, emergency department; PM2.5, particulate matter <2.5 microns.

0.94 0.96

0.98 1.00

1.02 1.04

1.06 1.08
0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)

0.96 0.97

0.98 0.99

1.00 1.01

1.02 1.03

1.04 1.05
0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)

0.85 0.90

0.95 1.00

1.05 1.10
0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
Odds ratio (95% CI)
A

0.94 0.96

0.98 1.00

1.02 1.04

1.06 0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
[ 54 ]
Figure 3.5. Associations between air pollution and ED visits (A) and hospitalizations (B) for acute myocardial infarction (heart attack)
Models adjusted for temperature, humidity, and co-pollutants. Time-unvarying factors were controlled by study design. Estimates were obtained for each 5-unit increase in pollutants. Cold season: Nov. – Apr., warm season: May-Oct. Numbers on x-axis represent lags, which can be interpreted as the number of days after exposure. For example, lag 0 = risk on the day of exposure, lag 1 = risk one day after exposure, etc.

Abbreviations: ED, emergency department; PM2.5, particulate matter <2.5 microns.

Figure 3.6. Associations between air pollution and ED visits (A) and hospitalizations (B) for cardiac arrest
Models adjusted for temperature, humidity, and co-pollutants. Time-unvarying factors were controlled by study design. Estimates were obtained for each 5-unit increase in pollutants. Cold season: Nov. – Apr., warm season: May-Oct. Numbers on x-axis represent lags, which can be interpreted as the number of days after exposure. For example, lag 0 = risk on the day of exposure, lag 1 = risk one day after exposure, etc.

Abbreviations: ED, emergency department; PM2.5, particulate matter <2.5 microns.

0.80 0.90

1.00 1.10

1.20 1.30
0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
Odds ratio (95% CI)
A

0.90 0.95

1.00 1.05

1.10 0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
B

0.92 0.94

0.96 0.98

1.00 1.02

1.04 1.06

1.08 0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
Odds ratio (95% CI)
A

0.92 0.94

0.96 0.98

1.00 1.02

1.04 1.06

1.08 1.10
0 1 2 3 4 5 6 0 1 2 3 4 5 6
Ozone (warm season) PM2.5 (cold season)
B

[ 61 ]

3.5 RECOMMENDATIONS
Based on the findings in this chapter, our recommendations are as follows:

1. Previously mentioned recommendations to reduce air pollution (through a 1,000 foot-buffer for truck traffic) should be adhered to and strengthened in Fresno.

2. Such efforts should also consider vulnerable populations, which include those living within the South Fresno AB 617 community boundaries and racial/ethnic minorities.

3. We also recommend the use of zero-emission commercial trucks when possible to minimize population exposure
[ 62 ]
CHAPTER 4. COMMUNITY-BASED HEALTH SURVEY IN SOUTH FRESNO AB 617

COMMUNITIES

4.1 BACKGROUND
While population-based health data presented in Chapters 1 through Chapter 3 are critical and provide a comprehensive way to assess the health of populations, we also value the concerns and needs from residents of South Fresno. Such data are not available in population datasets, necessitating new data collection. Working closely with multiple community partners, the city, and the Air District, we sought to hear from residents in one of the most polluted areas in Fresno regarding their environmental health concerns, health needs, civic engagement, and policy preferences towards environmental issues.

4.2 METHODS
The study took place within the South Fresno area (Figure 4.1). We obtained all residential addresses (without identifiable information) from the region from the City of Fresno GIS Hub.79 To ensure representativeness of the data, we randomly selected addresses within the study area. Centrally trained researchers went to the selected addresses to administer an approximately 15-minute survey, which asked about demographics, environmental health concerns, health needs, civic engagement, and policy preferences towards environmental issues. The survey took place from February to June, 2023, and was conducted in either English or Spanish.
[ 63 ]
Figure 4.1. Survey area
Source: California Air Resources Board
Our survey instrument was developed with several rounds of input from the SJV Air District, the Community Steering Committee, and community-based organization partners. We also obtained feedback during early surveys to improve our survey questionnaire.

To be eligible for the study, we selected the head of the household or significant other who was a) at least 18 years old, b) lived in the study area for at least one year, and c) speaks Spanish or English. A total of 1,766 residents participated in our survey. Although the survey is a random sample, we performed post-hoc weighting by age and race/ethnicity to optimize data generalizability. More specifically, we obtained five-year estimates (2017-2021) from the Census Bureau's American Community Survey (ACS) Public Use Microdata Sample (PUMS) data.64 The PUMS contains records about a representative of individual people or housing units within specific regions of the U.S. From this data, we obtained information about individuals living within the study area and determined their demographic characteristics. These estimates represent known characteristics of the study area. We then used these estimates to create weights for our study sample to ensure it is representative of the rest of the population living in the study region.

Table 4.1 below shows that our study sample is very similar to the population characteristics of the study area, especially after weighting.

The study was approved by the UC Merced Institutional Review Board. All analyses were done in SAS 9.2 (Cary, NC) and Microsoft Excel.

[ 74 ]

PREGNANCY OUTCOMES
Among reproductive-aged adult female respondents ages 18-46 years (n=541), about a quarter reported having at least one adverse pregnancy outcome including miscarriage, stillbirth, birth defects, or infant death. Twenty two percent (22%) reported having had a miscarriage and 3% reported stillbirth (Figure

4.15). Additionally, approximately 0.8% reported having a child who died within one year of life, and

1.6% reported having a child with a birth defect. We note that many of these estimates are high compared to the expected prevalence in the general population, but also recognize that these outcomes are rare and can contribute to unstable estimates in a relatively small survey.

Figure 4.15. Prevalence of selected pregnancy outcomes among reproductive-aged women Reproductive age is defined as 18-46 years.

Adverse pregnancy outcomes varied by sociodemographic characteristics such as race/ethnicity, age, education, and income (Figures 4.16 - 4.19). However, we also recognize that once restricted to only reproductive-age women, our sample became smaller and less stable, especially when some of the health outcomes were rare. In general, adverse pregnancy conditions were more common among Black women, especially stillbirths and infant death. These pregnancy outcomes were generally higher among women with higher maternal age, except for infant death, where younger women tended to have higher prevalence.
0%
5%
10%
15%
20%
25%
30%
≥1 Pregnancy
health condition
Miscarriage Stillbirth Birth defect Infant death
Percent

[ 78 ]
within 1,000 feet of a freeway, truck route, or major road had a higher prevalence of health problems compared to their counterparts. We also observed that living within 1,000 feet of a distribution center/warehouse was associated with a higher prevalence of health concerns.

4.5 RECOMMENDATIONS
Our two major recommendations from this chapter are as follows:

1. Although the 1,000 feet buffer best distinguishes the risks between residents inside and outside the buffer zone, our findings do not suggest that risks outside of 1,000 feet are insignificant. In fact, we recommend using a more conservative distance whenever possible, especially around more vulnerable receptors. Given significant health concerns in the region, it is critical to continue and strengthen efforts to reduce air pollution exposures in South Fresno.

2. Where appropriate, our goal is to engage South Fresno residents in the Fresno Truck Reroute Study’s civic efforts. This is especially necessary given the significant proportion of South Fresno residents indicating concern with the environment, support for rerouting truck traffic, and interests in civic engagement.
[ 79 ]

GLOSSARY
AB 617: Assembly Bill 617 (AB 617) is a California state bill that was signed into law in 2017. The primary purpose of AB 617 is to address air quality issues in communities that are disproportionately affected by pollution. The law aims to enhance community air monitoring, improve air quality data, and involve local communities in the decision-making process to reduce air pollution. AB 617 establishes the Community Air Protection Program, which identifies communities with the highest cumulative exposure to air pollutants, referred to as AB 617 communities in this report.

Acute exposure: Short-term exposures to air pollution, typically within a couple of weeks. The idea is to see whether the exposures (like air pollution) have short-term health effects (i.e., within a few days of exposures).

Adverse pregnancy outcome: generally, any unfavorable health condition(s) that occurs during pregnancy. In this report, we chose to focus on preterm birth and infant mortality, two very serious outcomes.

American Community Survey (ACS): An ongoing survey conducted by the U.S. Census Bureau. It collects detailed demographic, social, economic, and housing information from a sample of households across the United States every year. This data source is commonly used in research that involves neighborhood or contextual factors.

Association: Correlation or relationship between two factors. Although associations do not always mean causation, in well-designed studies, associations estimate the causal relationship between two factors.

CalEnviroScreen: A tool developed by the California Environmental Protection Agency (CalEPA) to identify communities in California that are disproportionately burdened by multiple sources of pollution and are more vulnerable to environmental and public health hazards. CalEnviroScreen can be accessible at https://oehha.ca.gov/calenviroscreen.

California Air Resources Board (CARB): A state agency charged with protecting the public from the harmful effects of air pollution and developing programs and actions to fight climate change.

Department of Health Care Access and Information (HCAi): A state agency whose mission is to expand equitable access to quality affordable health care for all Californians through resilient facilities, actionable information, and the health workforce each community needs. Among the many things it does, HCAi collects data on all healthcare encounters in the state. This data source is unique and valuable for research efforts across the state.

California Department of Public Health’s Office of Vital Statistics: An office within the California Department of Public Health which maintains birth, death, fetal death/still birth, marriage, and divorce records for California. The branch provides valuable data for population-based research due to the high state-level coverage.

Case-crossover analysis: A unique type of study design where people can serve as their own controls, which allows complete elimination of factors that can influence the quantifiable relationship. This is the reason we used this study for this study.
[ 80 ]
Confidence intervals (CI): The range of values that the true estimate can be if the sample/study was repeated infinite times. In this study, we used the 95% CI, which means that if the sample/study was conducted 100 times, the estimates will be in the range indicated 95% of the time.

Cardio-cerebral vascular diseases: Disease related to the blood vessels of the heart and brain.

Cumulative exposures: Exposures to a certain factor (like air pollution) over a period of time.

Emergency department (ED) visits: Medical encounters in emergency rooms across the state.

Excess cases: The number of cases of health outcomes as the result of a certain exposure (i.e., air pollution). Excess cases can also be interpreted as the number of cases that could be prevented if a certain amount of air pollution is reduced, which in this study is by 5 units.

Exposure: Refers to factors that may impact health. In this report, exposures refer to environmental exposures, including air pollution and proximity to pollution sources.

South Central Fresno Truck Reroute Study: A study aiming to identify, analyze, and evaluate potential strategies that freight-impacted communities might implement, in cooperation with the city of Fresno, to abate truck impacts. The study is led by the city of Fresno Public Works Department in partnership with the SJV Air District. More information can be found here:
https://www.fresno.gov/publicworks/south-central-truck-re-route-study/ International Classification of Disease codes (ICD-10, ICD-9): A set of standardized codes used internationally to identify specific diseases. These codes are used mostly for billing reasons but are also an accurate way to identify specific health outcomes of interest from medical records.

Infant mortality (IM): Death of a live birth within the first year of life.

Lags: an indicator of delayed health effects. Lag 0 refers to health effects on the same day of exposure; lags 1-7 refer to health effects 1 through 7 days after exposure.

Odds ratio (OR): The ratio of the odds (estimates of the risks) in one group (usually those with the exposure) compared to another group (usually those without the exposure). OR is a common approach to quantify the relationship between exposures like air pollution and health outcomes.

Ozone: An odorless, colorless gaseous pollutant common in the SJV. This pollutant is formed from precursors including nitrogen oxides, volatile organic compounds, and heat/sunlight.

Outcome: Refers to health conditions or health risks (such as asthma, cardiovascular disease, stroke) that could be caused by or associated with an exposure; in this case, air pollution Patient Discharge Data (PDD): These datasets contain all inpatient discharges from any licensed hospital in the state of California. The purpose of the data is to capture those people who ended up hospitalized for conditions evaluated in this study (asthma, cerebral cardiovascular disease).

PM2.5: Fine particles with a diameter of <2.5 microns. These are small particles that are inhalable and have been known to cause many health problems worldwide. [ 81 ]
Proximity: Refers to how close people lived from a source of pollutants, such as freeways, major roads, or truck routes). In this study, the proximity was evaluated by determining the distance from the closest source of pollutants.

Preterm birth: Birth occurring before 37 weeks of gestation. This is an adverse pregnancy outcome with potential serious short- and long-term consequences, because the baby is born too early and does not have enough time to develop inside the mother.

Prevalence: The proportion of the population with a specific health condition.

Risks: The probability or chance of having a health condition.

San Joaquin Valley Air Pollution Control District: A regional public health agency with the mission to improve the health and quality of life for residents through efficient and effective air quality management strategies. Website: https://ww2.valleyair.org/about/ Stratified analysis: An analysis that is separated by certain characteristics. For example, if an analysis is stratified by season, it means the researchers conducted the analysis separately by season to determine the effects of air pollution by season.
[ 82 ]

APPENDICES
Limitations of study
Chapter 1
We note that the study is limited by a few factors. First is the lack of residential relocation history in birth certificate data. It is possible that some pregnant people moved during the study period, causing potential misclassification of the exposure in the cumulative exposure analyses. However, we also know that although about 10-30% of pregnant people move during pregnancy, most relocated within a short distance.80 Thus, residential relocation likely did not profoundly affect our results. Furthermore, in the acute exposure analyses, since we compared exposures within one month, it is unlikely that relocation had significant influence. The second limitation is the lack of personally monitored air pollution exposure. Since pregnant people have different daily patterns of activity, their actual exposures may not be the same as that at their residential address. A more accurate way to estimate exposure would be to personally monitor air pollution concentrations where people were during the day. Such an approach would not have been feasible for a large population. The use of modelled air pollution estimation is indirect but offers a more cost-effective strategy to learn how air pollution impacts pregnant people in Fresno. We also note that this study likely underestimated the true effects of air pollution on PTB and IM given the control period (or comparison group) is within the same person who are already highly exposed to air pollution because they live in the valley. The ideal comparison would be people who are exposed to significantly lower pollution, but given the fact that the SJV has more pollution compared to other regions within the state, the control group had inflated exposures. Lastly, given the lack of data on source-specific pollution (such as wildfire), our estimates were for general PM2.5 and ozone exposures, regardless of the source. However, given the fact that sources like wildfires contribute a smaller proportion of long-term air pollution, we feel reassured that we have captured the impacts of major sources like traffic and transportation in the area, especially when our findings for pollutant-specific effects are consistent with distance from freeway and truck routes. Both are major sources of pollution.

Furthermore, given wildfires are generally short-term and occur in the warm season, they do not explain the effects we consistently observed in the cold season for PM2.5.

Chapters 2 and 3
The study has a few notable limitations. First, as with most air pollution studies, we did not have data on personal exposure. We relied on an air pollution model to estimate personal exposures. Since people move around during the day and may work in a different zip code than their residential zip code, there is a certain degree of misclassification. We expect this misclassification to underestimate the effects of air pollution, making our estimate rather conservative. We did not have identifiable information to track people over time and thus lacked the ability to assess event reoccurrence within the same person.

Similar to Chapter 1, we note that our air pollution exposures captured all sources. However, given our findings for pollutant-specific effects are consistent with distance from freeway and truck routes, we feel confident that the estimates can be attributed to these sources.

In addition, the HCAi data only captured cases with medical encounters, which by nature are more serious. As a result, we were not able to capture minor instances that may not have been serious enough for people to end up in the ED or hospital. Lastly, all health conditions may be underreported [ 83 ]
with the hospital/emergency room data based on sociodemographic characteristics (uninsured, immigration status, etc.) as obstacles to reporting or seeking medical treatment.

Chapter 4
It is reassuring that the findings in this Chapter are aligned with previous analyses in this report.

However, we note a few potential limitations in the data. First, the cross-sectional nature of the survey does not allow us to make conclusions about temporality between certain risk factors (i.e., reporting restlessness due to pollution) and health outcomes. In other words, restlessness could lead to health outcomes, but health outcomes could lead to restlessness. Nevertheless, the fact that exposed residents had more health concerns warrants attention. Second, given the rarity of many health outcomes, we were unable to implement more sophisticated models to further explore factors and mechanisms that can explain risks.
[ 84 ]

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Attachment E

Street-view of truck docks at current Central Transport Facility at 2440 E Church Ave.

Dock numbers are noted at each door. The building is double-loaded and there are dock doors on each side. There are a total of 26 truck docks.

Attachment F

of the internal and external factors which affect the amount of dock high positions required. The internal factors can include the amount of trucks serviced by the docks over a period of time (average and peak), the time to load and unload each trailer per dock, staging and cross-docking requirements, work hours over a period of time, employee breaks, drop trailer requirements, trash / bailing requirements, shifts, and shipping preferences.

External factors can include time of truck arrivals and departures, the reliability of carriers, whether carriers will back haul drop trailers, types of trailers used by carriers, and truck driver capabilities. A comprehensive understanding of these and any other internal and external factors will result in more precise understandings of an operation's dock high requirements.

In general, the minimum number of dock high positions are calculated based upon a formula involving their use, the amount of time they can be used, and a safety factor. Below are three examples of manual calculations using some of the internal and external factors above. • Number of Truck Positions Needed = ((Number of Trucks per Year x Hours it takes to Load / Unload a Truck) / Work Hours per Year) x Safety Factor [1] ○ Inputs
■ 7,000 trucks per year
■ 2.5 hours for loading / unloading
■ 2080 work hours per year
■ Safety factor of 25%
○ Calculation
■ (7,000 trucks per year x 2.5 hours for loading / unloading) / 2080 work hours per year) = 8.4 x 1.25 safety factor = 10.5 docks or 11 dock high positions needed at a minimum
• Number of Truck Positions Needed = Number of Trucks per Hour x Turnaround Time per Hour [2]
Chuck Berger Home IndustrialRE Insights Talk to Chuck
8/12/25, 2:30 PM How Many Dock Positions Do I Need? — Chuck Berger https://www.chuckberger.com/blog/2020/08/25/calculating-dock-position-requirements 2/6

■ 150 minute turnaround time
○ Calculation
■ (20 trucks per day / 8 hour work day) = 2.5 trucks per hour x (150 minute turnaround time / 60 minutes per hour = 2.5 turnaround time) = 6.25 dock positions needed or 7 positions needed
■ If all trucks arrive in AM, then work day would be shortened to 4 hours and the dock requirements would be 12.5 or 13 positions needed
• ((Peak trucks per day) x (Average dock time per truck) x (Safety factor of 1.5 to 2)) / Number of hours in work day [3]
○ Inputs
■ 20 trucks per day
■ 2.5 hours per truck
■ 8 hour work day
○ Calculation
■ ((20 trucks per day) x (2.5 hours per truck) x (1.5 safety factor)) / 8 hour work day =

9.375 docks required or 10 docks needed
These three calculations show that depending on the formula used, roughly the same inputs will yield slightly to drastically different minimum dock requirements. Where formulas 1 and 3 resulted in 11 and 10 positions required, formula 2 resulted in only 7. Not surprisingly, formula 2 did not employ a safety factor. Safety factors are used to account for unforeseen variability such as disruptions in deliveries or labor.

Companies may also employ manual simulations of dock requirements.  These simulations include the detailed logging of docks used by the various types of vehicles that deliver or ship to a facility.

These simulations can show how to improve dock assignments or delivery schedules for better dock utilization and determining of minimum docks required.[4] Chuck Berger Home IndustrialRE Insights Talk to Chuck
8/12/25, 2:30 PM How Many Dock Positions Do I Need? — Chuck Berger https://www.chuckberger.com/blog/2020/08/25/calculating-dock-position-requirements 3/6

Chuck Berger Home IndustrialRE Insights Talk to Chuck
8/12/25, 2:30 PM How Many Dock Positions Do I Need? — Chuck Berger https://www.chuckberger.com/blog/2020/08/25/calculating-dock-position-requirements 6/6 LTL Terminals: Key Locations for Efficient
Freight Handling
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Key Locations for Efficient Freight Handling
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Did you know LTL freight shipping is only 10% to 15% of the industry? Yet, it’s vital for many businesses. LTL terminals are the backbone of this system, moving goods across the country.

LTL terminals handle millions of shipments every year. They are key hubs where smaller loads are combined and sorted. This makes it affordable for small businesses to ship across the country.

As e-commerce grows, LTL (https://parcelpath.com/LTL/) terminals will become even more important. U.S. e-commerce sales are expected to jump from $657 billion to $1.9 trillion by 2029. These facilities will manage the rise in parcels and pallets.

Exploring LTL terminals reveals their role in shaping freight handling’s future. They are more than just stops on the way. They are the heart of modern logistics (https://www.facebook.com/ParcelPath/).

Key Takeaways
LTL shipping accounts for 10-15% of transportation industry volume LTL terminals are crucial for consolidating and distributing smaller freight loads E-commerce growth is increasing the importance of LTL terminals These facilities enable cost-effective shipping for businesses of all sizes LTL terminals are key to efficient supply chain management Understanding LTL Freight Terminal Networks
LTL terminals are key in freight networks. They handle shipments from 150 to 15,000 pounds. These networks use a hub-and-spoke model to move goods efficiently. 8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 2/17 Hub-and-Spoke Distribution Model
The hub-and-spoke system sends shipments through central hubs for sorting. This method helps carriers save money and work better. A typical LTL truck (https://parcelpath.com/ltl-freight/) stops 5-15 times a day for pickups.

Terminal Network Infrastructure
LTL terminals are important in freight networks. They can handle different shipments, from small pallets to big loads. The system supports 18 freight classes, from 50 to 500, as set by the National Motor Freight Traffic Association.

Cross-Docking Operations
Cross-docking is a big part of LTL shipping. It moves shipments quickly between vehicles. This makes shipping faster, cheaper, and more efficient. Cross-docking keeps goods moving smoothly through networks.

LTL Shipping Metric Value
Typical Shipment Weight Range 150 – 15,000 pounds
Number of Freight Classes 18
Average Daily Truck Stops 5 – 15
Maximum Linear Feet of Trailer Space 12 feet
The Role of LTL Terminals in Supply Chain
Management
LTL terminals are key in supply chain management. They are important hubs for handling freight. These places help businesses manage their logistics better and meet customer needs.

In today’s e-commerce world, LTL (https://parcelpath.com/freight-shipping/) shipping is very important. It works for all kinds of products and orders. LTL terminals handle shipments from 100 to 10,000 pounds, with 1 to 6 pallets. 8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 3/17 LTL terminals make supply chains more efficient. They help combine multiple LTL shipments into one big truckload. This saves money and boosts logistics performance.

It’s especially helpful for suppliers working with big retailers like Walmart.

LTL Shipping Aspect Impact on Supply Chain
Shipment Size Flexibility Handles 100-10,000 lbs, 1-6 pallets Cost Reduction Shared loads, maximized trailer space
Warehouse Efficiency Reduced storage costs
Real-time Tracking Enhanced shipment visibility
LTL terminals help make supply chains stronger. They offer real-time tracking and help with flexible shipping plans. As the logistics world changes, these terminals keep things running smoothly and cost-effective.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 4/17 Key Components of Modern LTL Terminals
LTL terminals are the heart of efficient freight handling. They have modern parts that work together for smooth operations and on-time deliveries. Let’s explore the main parts that make LTL shipping strong in the transport world.

Loading Dock Facilities
The loading dock is where it all starts. It’s the entrance and exit for freight. Modern LTL terminals have many bays with adjustable dock levelers for different truck sizes.

This setup helps trucks move in and out fast. It also makes handling different shipments easy.

Sorting and Processing Areas
After freight gets in, it goes to the sorting area. Here, conveyor systems and barcode scanners help sort packages. They make sure each item goes to the right truck.

This high-tech sorting makes shipping cheaper and more efficient.

Storage and Staging Zones
Not all freight moves right away. Storage and staging zones hold it until it’s ready. These areas are set up for easy access and quick loading.

Terminal Component Function Impact on Efficiency
Loading Docks Freight entry/exit point Reduces turnaround time Sorting Areas Package direction Optimizes load consolidation Storage Zones Temporary freight holding Enhances scheduling flexibility
These modern parts work together well. They help the global LTL market (https://parcelpath.com/ltl-market/) grow. By improving these areas, LTL terminals can cut shipping costs, speed up deliveries, and keep shipments on time. 8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 5/17 Terminal Operations and Workflow Processes
LTL terminals are busy places where freight moves around a lot. They have special steps to make sure goods get from one place to another quickly.

Inbound Freight Processing
When freight comes to an LTL terminal, it gets checked and documented. Each shipment gets a special number for tracking. This first step helps everything run smoothly.

Sorting and Consolidation
Then, freight is sorted and combined with other shipments going the same way. This is key in LTL shipping. It helps save space and money on transport.

Outbound Distribution
The last step is getting freight ready to move again. Terminal operations change as needed. For example, if roads change, new routes are found to keep things moving.

Aspect Details
Freight Movement Multi-terminal operations (e.g., BCTERM to QCTERM via MBTERM)
Operational Strategy Freight bill merges, adaptive routing (e.g., ABTERM as alternative)
Planning Real-time updates, historical record keeping
Contingency Emergency reroutes (e.g., ONTERM as
intermediate terminal)
Delivery Focus Continuous plan updates for timely delivery Knowing how LTL terminals work is important. Each step is vital for fast and reliable freight transport.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 6/17 Technology Integration in LTL Terminals
LTL terminals are using new tech to make things run smoother. They handle many shipments from different places. This means they need to manage lots of data accurately.

Even a tiny mistake can cause big problems. It can lead to late deliveries and wrong bills.

To fix these issues, LTL terminals are using tech. Optical Character Recognition (OCR) helps read data quickly and correctly. GPS tracking lets them watch shipments in real time. This helps them find the best routes and saves time.

Machine learning also helps a lot. It makes tasks like billing faster by doing less manual work.

The effects of using technology in LTL terminals are huge:
25% better safety for terminals and drivers
40% more accurate delivery times
10% less empty miles thanks to AI
3% less total miles driven
Cloud-based systems keep important data safe. This tech makes things run better and helps the planet too. For example, using Electronic Delivery Receipts (EDR) cuts down on paper waste.

Company LTL Terminals Equipment Employees
Pitt Ohio 25 1,600+ tractors,
4,100+ trailers
5,400+
Sutton Transport 13 850+ pieces 700+
As LTL terminals keep using new tech, things will get even better. They’ll be more efficient, accurate, and make customers happier. The future of LTL shipping looks bright with these tech advancements.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 7/17 Location Strategies for LTL Terminals
Choosing the right spot for LTL terminals is like playing chess. Every move counts.

Smart placement can make or break a shipping network. Let’s explore the key factors that shape these decisions.

Geographic Considerations
LTL terminals thrive near major highways and population hubs. They aim to be close to customers and key transport routes. Coastal areas with ports often host terminals to link sea and land freight.

Market Access Factors
Terminals position themselves to serve bustling industries and regions. They look at local business landscapes and growth trends. This smart placement helps cut costs and boost efficiency for shippers.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 8/17 Transportation Infrastructure
Good roads and railways are vital for LTL terminals. They need smooth connections to move freight fast. Areas with strong transport networks often see more terminal development.

Factor Impact on LTL Terminal Location
Proximity to Highways Reduces transit times, improves accessibility Population Density Increases potential customer base
Industrial Zones Provides steady freight flow, reduces empty miles
Rail Access Enables intermodal shipping options
LTL terminals play a crucial role in efficient freight handling. Their location strategies focus on geographic reach, market access, and solid infrastructure. This careful planning ensures smooth operations and happy customers in the competitive world of shipping.

Terminal Safety and Security Measures
LTL terminals focus on safety and security. They protect workers and cargo with strong measures. These steps make sure the place is safe for handling and moving freight.

Keeping workers safe is key. They wear hard hats (https://parcelpath.com/how-to-shiphats/) and safety glasses to avoid injuries. The terminals have strict rules for handling dangerous materials. This keeps the work area safe for everyone.

Security is also a big deal. The terminals use advanced cameras to watch what’s happening. Only people who are allowed in can get in. They also track cargo closely to prevent theft or loss.

Cargo theft went up by 49% in the first half of the year. There were 787 cases in the U.S.

In Los Angeles, thieves took over $5 million in Nike shoes from containers.

A worker in Memphis was caught stealing about $1 million in cargo.

To fight these problems, LTL terminals use different tactics:
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 9/17 Security Measure Description
Advanced Tracking GPS and RFID track cargo in real-time Access Control Biometric systems and ID checks limit entry Video Surveillance 24/7 camera monitoring of terminal activities Security Personnel Trained guards patrol the premises
With these safety steps and security plans, LTL terminals make a safe space. They protect goods and keep workers safe during their journey.

Optimizing LTL Terminal Efficiency
LTL terminals are key in the shipping world. Their work affects costs and how fast things get delivered. With LTL rates up 60% since 2018, making things run smoothly is more important than ever.

Workforce Management
Getting the right people in place is crucial. It helps terminals deal with changing shipment numbers well. This way, they save on labor costs without sacrificing quality.

Equipment Utilization
Using equipment well is essential. LTL terminals use tech to keep track of their assets.

For example, they offer a full domestic rating and booking system, making things run better.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 10/17 Schedule Optimization
Good scheduling is vital in LTL shipping. Shipments might go through up to seven terminals over 2,000 miles. This means efficient planning can cut down on delays and damage.

By working on these areas, LTL terminals can do better. Customers who use LTL pool distribution save 15-30% on costs. This shows the real benefits of making things more efficient.

Environmental Considerations in LTL Terminals
LTL terminals are now using eco-friendly ways to lessen their harm to the environment.

They are finding new ways to be more sustainable while still moving goods efficiently.

They are installing energy-saving lights and HVAC systems. These changes cut down on energy use and lower costs. They also have recycling programs to reduce waste and use resources wisely.

Electric vehicles are becoming more common for short trips in ltl terminals. This move cuts down on pollution and noise in cities. They also focus on better routes to use less fuel and lower emissions.
8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 11/17 LTL shipping helps the environment too. By combining shipments, fewer trucks are on the road. This means less pollution. It also helps businesses save money and reduce their carbon footprint.

Environmental Initiative Impact
Energy-efficient lighting Reduced energy consumption
Electric vehicles Lower emissions and noise pollution
Route optimization Decreased fuel consumption
Shipment consolidation Fewer trucks on the road
These steps show the ltl industry’s (https://parcelpath.com/ltl-industry/) dedication to green logistics. As technology improves and awareness grows, we’ll see more creative ways to make freight handling better for the planet.

ParcelPath’s Role in LTL Shipping Solutions
ParcelPath is changing the game in LTL shipping. It offers services for all businesses, from small startups to big corporations. With advanced tech and partnerships, ParcelPath makes shipping cheaper and easier.

Discount Shipping Options
ParcelPath’s big feature is its discounts. You can save 60% to 89% on shipping. This makes LTL shipping cheaper for all businesses. You can see prices before you sign up, so you always get a good deal.

PalletPath Integration
For big items, ParcelPath has PalletPath. It gives big discounts on pallet shipping. This makes shipping big goods cheaper and easier. Using both ParcelPath and PalletPath helps businesses ship all kinds of goods well.

Small Business Solutions
ParcelPath helps small businesses a lot. It gives them access to good rates and services. This lets small businesses compete better and save money. 8/12/25, 2:31 PM LTL Terminals: Key Locations For Efficient Freight Handling https://parcelpath.com/ltl-terminals/?utm_source=chatgpt.com 12/17 ParcelPath is changing how businesses handle shipping. It saves a lot of money and offers solutions for all shipping needs. It’s a key tool for businesses to stay ahead in today’s market.

Conclusion
LTL terminals are key to efficient freight handling in the shipping world. They handle shipments from 150 to 15,000 pounds. This usually means 1-10 pallets.

LTL shipping lets businesses share truck space. This can save a lot of money compared to full truckload options.

How long it takes to ship depends on the distance. Shipments within the same state take 1-2 days. Cross-country trips take 4-6 business days.

Even though it’s a bit longer than FTL shipping, LTL is cheaper. Companies like Mothership and ShipBob are making it better. They offer nationwide service and smart inventory placement to cut costs and times.

As online shopping grows, LTL terminals will become even more important. Knowing how LTL shipping works helps businesses improve their logistics. The future of LTL terminals looks bright, promising more efficiency and green practices in freight handling.

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l
ROB BONTA State of California
Attorney General DEPARTMENT OF JUSTICE
Warehouse Projects: Best Practices and
Mitigation Measures to Comply with the
California Environmental Quality Act
Table of Contents
I. Background .......................................................................................................................... 1 II. Proactive Planning: General Plans, Local Ordinances, and Good Neighbor Policies ......... 3 III. Community Engagement ..................................................................................................... 4 IV. Warehouse Siting and Design Considerations ..................................................................... 5 V. Air Quality and Greenhouse Gas Emissions Analysis and Mitigation ................................ 7 VI. Noise Impacts Analysis and Mitigation ............................................................................. 10 VII. Traffic Impacts Analysis and Mitigation ........................................................................... 11 VIII. Other Significant Environmental Impacts Analysis and Mitigation .................................. 12 IX. Conclusion ......................................................................................................................... 13 Updated September 2022
1 In carrying out its duty to enforce laws across California, the California Attorney General’s Bureau of Environmental Justice (Bureau)1
regularly reviews proposed warehouse
projects for compliance with the California Environmental Quality Act (CEQA) and other laws.

When necessary, the Bureau submits comment letters to lead agencies regarding warehouse projects, and in rare cases the Bureau has filed litigation to enforce CEQA.2 This document builds upon the Bureau’s work on warehouse projects, collecting information gained from the Bureau’s review of hundreds of warehouse projects across the state.3 It is meant to help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals.4
While CEQA analysis is necessarily project-specific,
this document provides information on feasible best practices and mitigation measures, nearly all of which have been adapted from actual warehouse projects in California.

I. Background
In recent years, the proliferation of e-commerce and rising consumer expectations of rapid shipping have contributed to a boom in warehouse development.5 California, with its ports, population centers, and transportation network, has found itself at the center of this trend.

In 2020, the Ports of Los Angeles, Long Beach, and Oakland collectively accounted for over 34% of all United States international container trade.6 The Ports of Los Angeles and Long Beach alone generate about 35,000 container truck trips every day.7 Accordingly, the South Coast Air Basin now contains approximately 3,000 warehouses of over 100,000 square feet each, with a total warehouse capacity of approximately 700 million square feet, an increase of 20 percent over the last five years.
8 This trend has only accelerated, with e-commerce growing to 1 https://oag.ca.gov/environment/justice. 2 https://oag.ca.gov/environment/ceqa; People of the State of California v. City of Fontana (Super. Ct. San Bernardino County, No. CIVSB2121829); South Central Neighbors United et al. v. City of Fresno et al. (Super. Ct. Fresno County, No. 18CECG00690). 3 This September 2022 version revises and replaces the prior March 2021 version of this document.
4 Anyone reviewing this document to determine CEQA compliance responsibilities should consult their own attorney for legal advice.
5 As used in this document, “warehouse” or “logistics facility” is defined as a facility consisting of one or more buildings that stores cargo, goods, or products on a short- or long-term basis for later distribution to businesses and/or retail customers. 6 Data from the Bureau of Transportation Statistics, Container TEUs (Twenty-foot Equivalent Units) (2020), https://data.bts.gov/stories/s/Container-TEU/x3fb-aeda/ (Ports of Los Angeles, Long Beach, and Oakland combined for 14.157 million TEUs, 34% of 41.24 million TEUs total nationwide) (last accessed September 18, 2022).
7 U.S. Dept. of Transportation, Federal Highway Administration, FHWA Operations Support – Port Peak Pricing Program Evaluation (2020), available at https://ops.fhwa.dot.gov/publications/fhwahop09014/sect2.htm (last accessed September 18, 2022).
8 South Coast Air Qual. Mgmt. Dist., Final Socioeconomic Assessment for Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program and Proposed Rule 316 – Fees for Rule 2305, at 7-8, 41 (May 2021).

Updated September 2022
2 13% of all retail sales and 2021 being a second consecutive record year for new warehouse space leased.9
The latest data and forecasts predict that the next wave of warehouse development will be in the Central Valley.10
When done properly, these activities can contribute to the economy and consumer welfare. However, imprudent warehouse development can harm local communities and the environment. Among other pollutants, diesel trucks visiting warehouses emit nitrogen oxide (NOx)—a primary precursor to smog formation and a significant factor in the development of respiratory problems like asthma, bronchitis, and lung irritation—and diesel particulate matter (a subset of fine particular matter that is smaller than 2.5 micrometers)—a contributor to cancer, heart disease, respiratory illnesses, and premature death. 11 Trucks and on-site loading activities
can also be loud, bringing disruptive noise levels during 24/7 operation that can cause hearing damage after prolonged exposure.12 The hundreds, and sometimes thousands, of daily truck and passenger car trips that warehouses generate contribute to traffic jams, deterioration of road surfaces, and traffic accidents.

These environmental impacts also tend to be concentrated in neighborhoods already suffering from disproportionate health impacts and systemic vulnerability. For example, a comprehensive study by the South Coast Air Quality Management District found that communities located near large warehouses scored far higher on California’s environmental justice screening tool, which measures overall pollution and demographic vulnerability.13 That 9 U.S. Census Bureau News, Quarterly Retail E-Commerce Sales 4th Quarter 2021 (February 22, 2022), https://www.census.gov/retail/mrts/www/data/pdf/ec current.pdf (last accessed September 18, 2022); CBRE Research, 2022 North America Industrial Big Box Report: Review and Outlook, at 2-3 (March 2022), available at https://www.cbre.com/insights/reports/2022- north-america-industrial-big-box#download-report (last accessed September 18, 2022). 10 CBRE Research, supra note 9, at 4, 36; New York Times, Warehouses Are Headed to the Central Valley, Too (Jul. 22, 2020), available at
https://www.nytimes.com/2020/07/22/us/coronavirus-ca-warehouse-workers.html. 11 California Air Resources Board, Nitrogen Dioxide & Health, https://ww2.arb.ca.gov/resources/nitrogen-dioxide-and-health (last accessed September 18, 2022) (NOx); California Air Resources Board, Summary: Diesel Particular Matter Health Impacts, https://ww2.arb.ca.gov/resources/summary-diesel-particulate-matter-health-impacts (last accessed September 18, 2022); Office of Environmental Health Hazard Assessment and American Lung Association of California, Health Effects of Diesel Exhaust, https://oehha.ca.gov/media/downloads/calenviroscreen/indicators/diesel4-02.pdf (last accessed September 18, 2022) (DPM).
12 Noise Sources and Their Effects,
https://www.chem.purdue.edu/chemsafety/Training/PPETrain/dblevels.htm (last accessed September 18, 2022) (a diesel truck moving 40 miles per hour, 50 feet away, produces 84 decibels of sound).
13 South Coast Air Quality Management District, “Final Socioeconomic Assessment for Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program and Proposed Rule 316 – Fees for Rule 2305” (May 2021), at 4-5.

Updated September 2022
3 study concluded that, compared to the South Coast Air Basin averages, communities in the South Coast Air Basin near large warehouses had a substantially higher proportion of people of color; were exposed to more diesel particulate matter; had higher rates of asthma, cardiovascular disease, and low birth weights; and had higher poverty and unemployment rates.14 Each area has its own unique history, but many of these impacts and vulnerabilities reflect historic redlining practices in these communities, which devalued land and concentrated poverty, racial outgroups, and pollution into designated areas.
15 II. Proactive Planning: General Plans, Local Ordinances, and Good Neighbor Policies To systematically guide warehouse development, we encourage local governing bodies to proactively plan for logistics projects in their jurisdictions. Proactive planning allows jurisdictions to prevent land use conflicts before they materialize and direct sustainable development. Benefits also include providing a predictable business environment, protecting residents from environmental harm, and setting consistent expectations jurisdiction-wide.

Proactive planning can take many forms. Land use designation and zoning decisions should channel development into appropriate areas. For example, establishing industrial districts near major highway and rail corridors but away from sensitive receptors16 can help attract investment while avoiding conflicts between warehouse facilities and residential communities.

Transition zones with lighter industrial and commercial land uses may also help minimize conflicts between residential and industrial uses.

In addition, general plan policies, local ordinances, and good neighbor policies should set minimum standards for logistics projects. General plan policies can be incorporated into existing economic development, land use, circulation, or other related general plan elements. Many jurisdictions alternatively choose to consolidate policies in a separate environmental justice element. Adopting general plan policies to guide warehouse development may also help 14 Id. at 5-7.
15 Beginning in the 1930s, federal housing policy directed investment away from Black, immigrant, and working-class communities by color-coding neighborhoods according to the purported “riskiness” of loaning to their residents. In California cities where such “redlining” maps were drawn, nearly all of the communities where warehouses are now concentrated were formerly coded “red,” signifying the least desirable areas where investment was to be avoided.

See University of Richmond Digital Scholarship Lab, Mapping Inequality, https://dsl.richmond.edu/panorama/redlining/#loc=12/33.748/-118.272&city=los-angeles-ca (Los Angeles), https://dsl.richmond.edu/panorama/redlining/#loc=13/32.685/-117.132&city=sandiego-ca (San Diego), https://dsl.richmond.edu/panorama/redlining/#loc=11/37.81/- 122.38&city=oakland-ca (Oakland),
https://dsl.richmond.edu/panorama/redlining/#loc=13/37.956/-121.326&city=stockton-ca (Stockton), https://dsl.richmond.edu/panorama/redlining/#loc=12/36.751/-119.86&city=fresnoca (Fresno) (all last accessed September 18, 2022). 16 In this document, “sensitive receptors” refers to residences, schools, public recreation facilities, health care facilities, places of worship, daycare facilities, community centers, or incarceration facilities.

Updated September 2022
4 jurisdictions comply with their obligations under SB 1000, which requires local government general plans to identify objectives and policies to reduce health risks in disadvantaged communities, promote civil engagement in the public decision making process, and prioritize improvements and programs that address the needs of disadvantaged communities.17 Local ordinances and good neighbor policies that set development standards for all warehouses in the jurisdiction are a critical and increasingly common tool that serve several goals. When well-designed, these ordinances direct investment to local improvements, provide predictability for developers, conserve government resources by streamlining project review processes, and reduce the environmental impacts of industrial development. While many jurisdictions have adopted warehouse-specific development standards, an ordinance in the City of Fontana provides an example to review and build upon.18 Good neighbor policies in Riverside County and by the Western Riverside Council of Government include additional measures worth consideration.19
The Bureau encourages jurisdictions to adopt their own local ordinances that combine the strongest policies from those models with measures discussed in the remainder of this document.

III. Community Engagement
Early and consistent community engagement is central to establishing good relationships between communities, lead agencies, and warehouse developers and tenants. Robust community engagement can give lead agencies access to community residents’ on-the-ground knowledge and information about their concerns, build community support for projects, and develop creative solutions to ensure new logistics facilities are mutually beneficial. Examples of best practices for community engagement include:
• Holding a series of community meetings at times and locations convenient to members of the affected community and incorporating suggestions into the project design.
• Posting information in hard copy in public gathering spaces and on a website about the project. The information should include a complete, accurate project description, maps and drawings of the project design, and information about how the public can provide input and be involved in the project approval process. The 17 For more information about SB 1000, see https://oag.ca.gov/environment/sb1000. 18 https://oag.ca.gov/system/files/attachments/pressdocs/Final%20Signed%20Fontana%20Ordinance.pdf (last accessed September 18, 2022). 19 For example, the Riverside County policy requires community benefits agreements and supplemental funding contributions toward additional pollution offsets, and the Western Riverside Council of Governments policy sets a minimum buffer zone of 300 meters between warehouses and sensitive receptors. https://www.rivcocob.org/wpcontent/uploads/2020/01/Good-Neighbor-Policy-F-3-Final-Adopted.pdf (last accessed September 18, 2022) (Riverside County);
http://www.wrcog.cog.ca.us/DocumentCenter/View/318/Good-Neighbor-Guidelines-for-SitingWarehouse-Distribution-Facilities-PDF?bidId= (last accessed September 18, 2022) (Western Riverside Council of Governments).

Updated September 2022
5 information should be in a format that is easy to navigate and understand for members of the affected community.
• Providing notice by mail to residents and schools within a certain radius of the project and along transportation corridors to be used by vehicles visiting the project, and by posting a prominent sign on the project site. The notice should include a brief project description and directions for accessing complete information about the project and for providing input on the project. • Providing translation or interpretation in residents’ native language, where appropriate.
• For public meetings broadcast online or otherwise held remotely, providing for access and public comment by telephone and supplying instructions for access and public comment with ample lead time prior to the meeting. • Partnering with local community-based organizations to solicit feedback, leverage local networks, co-host meetings, and build support.
• Considering adoption of a community benefits agreement, negotiated with input from affected residents and businesses, by which the developer provides benefits to the affected community.
• Creating a community advisory board made up of local residents to review and provide feedback on project proposals in early planning stages. • Identifying a person to act as a community liaison concerning on-site construction activity and operations, and providing contact information for the community liaison to the surrounding community.
• Requiring signage in public view at warehouse facilities with contact information for a local designated representative for the facility operator who can receive community complaints, and requiring any complaints to be answered by the facility operator within 48 hours of receipt.

IV. Warehouse Siting and Design Considerations
The most important consideration when planning a logistics facility is its location.

Warehouses located in residential neighborhoods or near sensitive receptors expose community residents and those using or visiting sensitive receptor sites to the air pollution, noise, traffic, and other environmental impacts they generate. Therefore, placing facilities away from sensitive receptors significantly reduces their environmental and quality of life harms on local communities. The suggested best practices for siting and design of warehouse facilities does not relieve lead agencies’ responsibility under CEQA to conduct a project-specific analysis of the project’s impacts and evaluation of feasible mitigation measures and alternatives; lead agencies’ incorporation of the best practices must be part of the impact, mitigation and alternatives analyses to meet the requirements of CEQA. Examples of best practices when siting and designing warehouse facilities include:

Updated September 2022
6 • Per California Air Resources Board (CARB) guidance, siting warehouse facilities so that their property lines are at least 1,000 feet from the property lines of the nearest sensitive receptors.
20 • Providing adequate amounts of on-site parking to prevent trucks and other vehicles from parking or idling on public streets and to reduce demand for off-site truck yards.
• Establishing setbacks from the property line of the nearest sensitive receptor to warehouse dock doors, loading areas, and truck drive aisles, and locating warehouse dock doors, loading areas, and truck drive aisles on the opposite side of the building from the nearest sensitive receptors—e.g., placing dock doors on the north side of the facility if sensitive receptors are near the south side of the facility.
• Placing facility entry and exit points from the public street away from sensitive receptors—e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. • Ensuring heavy duty trucks abide by the on-site circulation plans by constructing physical barriers to block those trucks from using areas of the project site restricted to light duty vehicles or emergency vehicles only. • Preventing truck queuing spillover onto surrounding streets by positioning entry gates after a minimum of 140 feet of space for queuing, and increasing the distance by 70 feet for every 20 loading docks beyond 50 docks. • Locating facility entry and exit points on streets of higher commercial classification that are designed to accommodate heavy duty truck usage. • Screening the warehouse site perimeter and onsite areas with significant truck traffic (e.g., dock doors and drive aisles) by creating physical, structural, and/or vegetative buffers that prevent or substantially reduce pollutant and noise dispersion from the facility to sensitive receptors.
• Planting exclusively 36-inch box evergreen trees to ensure faster maturity and four-season foliage.
• Requiring all property owners and successors in interest to maintain onsite trees and vegetation for the duration of ownership, including replacing any dead or unhealthy trees and vegetation.
• Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Including signs and drive aisle pavement markings that clearly identify onsite circulation patterns to minimize unnecessary onsite vehicle travel. • Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.
20 CARB, Air Quality and Land Use Handbook: A Community Health Perspective (April 2005), at ES-1. CARB staff has released draft updates to this siting and design guidance which suggests a greater distance may be warranted in some scenarios. CARB, Concept Paper for the Freight Handbook (December 2019), available at https://ww2.arb.ca.gov/sites/default/files/2020- 03/2019.12.12%20-%20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf (last accessed September 18, 2022).

Updated September 2022
7 V. Air Quality and Greenhouse Gas Emissions Analysis and Mitigation Emissions of air pollutants and greenhouse gases are often among the most substantial environmental impacts from new warehouse facilities. CEQA compliance demands a proper accounting of the full air quality and greenhouse gas impacts of logistics facilities and adoption of all feasible mitigation of significant impacts. Although efforts by CARB and other authorities to regulate the heavy-duty truck and off-road diesel fleets have made excellent progress in reducing the air quality impacts of logistics facilities, the opportunity remains for local jurisdictions to further mitigate these impacts at the project level. Lead agencies and developers should also consider designing projects with their long-term viability in mind. Constructing the necessary infrastructure to prepare for the zero-emission future of goods movement not only reduces a facility’s emissions and local impact now, but it can also save money as demand for zero-emission infrastructure grows. In planning new logistics facilities, the Bureau strongly encourages developers to consider the local, statewide, and global impacts of their projects’ emissions.

Examples of best practices when studying air quality and greenhouse gas impacts include:
• Fully analyzing all reasonably foreseeable project impacts, including cumulative impacts. In general, new warehouse developments are not ministerial under CEQA because they involve public officials’ personal judgment as to the wisdom or manner of carrying out the project, even when warehouses are permitted by a site’s applicable zoning and/or general plan land use designation.21 • When analyzing cumulative impacts, thoroughly considering the project’s incremental impact in combination with past, present, and reasonably foreseeable future projects, even if the project’s individual impacts alone do not exceed the applicable significance thresholds.
• Preparing a quantitative air quality study in accordance with local air district guidelines.
• Preparing a quantitative health risk assessment in accordance with California Office of Environmental Health Hazard Assessment and local air district guidelines.
• Refraining from labeling compliance with CARB or air district regulations as a mitigation measure—compliance with applicable regulations is required regardless of CEQA.
• Disclosing air pollution from the entire expected length of truck trips. CEQA requires full public disclosure of a project’s anticipated truck trips, which entails calculating truck trip length based on likely truck trip destinations, rather than the distance from the facility to the edge of the air basin, local jurisdiction, or other truncated endpoint. All air pollution associated with the project must be considered, regardless of where those impacts occur.
21 CEQA Guidelines § 15369.

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8 • Accounting for all reasonably foreseeable greenhouse gas emissions from the project, without discounting projected emissions based on participation in California’s Cap-and-Trade Program.

Examples of measures to mitigate air quality and greenhouse gas impacts from construction are below. To ensure mitigation measures are enforceable and effective, they should be imposed as permit conditions on the project where applicable. • Requiring off-road construction equipment to be hybrid electric-diesel or zeroemission, where available, and all diesel-fueled off-road construction equipment to be equipped with CARB Tier IV-compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground-disturbing and construction activities.
• Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day.
• Using electric-powered hand tools, forklifts, and pressure washers, and providing electrical hook ups to the power grid rather than use of diesel-fueled generators to supply their power.
• Designating an area in the construction site where electric-powered construction vehicles and equipment can charge.
• Limiting the amount of daily grading disturbance area. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
• Forbidding idling of heavy equipment for more than three minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications. • Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts.
• Using paints, architectural coatings, and industrial maintenance coatings that have volatile organic compound levels of less than 10 g/L.
• Providing information on transit and ridesharing programs and services to construction employees.
• Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.

Examples of measures to mitigate air quality and greenhouse gas impacts from operation include:
• Requiring all heavy-duty vehicles engaged in drayage22 to or from the project site to be zero-emission beginning in 2030.
22 “Drayage” refers generally to transport of cargo to or from a seaport or intermodal railyard.

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9 • Requiring all on-site motorized operational equipment, such as forklifts and yard trucks, to be zero-emission with the necessary charging or fueling stations provided.
• Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
• Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
• Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager. • Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building’s projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible.
• Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Running conduit to designated locations for future electric truck charging stations. • Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Constructing and maintaining electric light-duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance) • Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light-duty charging stations. • Installing and maintaining, at the manufacturer’s recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.
• Installing and maintaining, at the manufacturer’s recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
• Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of Updated September 2022
10 trucks.
• Requiring operators to establish and promote a rideshare program that discourages single-occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking. • Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking.
• Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations.
• Posting signs at every truck exit driveway providing directional information to the truck route.
• Improving and maintaining vegetation and tree canopy for residents in and around the project area.
• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARBapproved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request.
• Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

VI. Noise Impacts Analysis and Mitigation
The noise associated with logistics facilities can be among their most intrusive impacts to nearby sensitive receptors. Various sources, such as unloading activity, diesel truck movement, and rooftop air conditioning units, can contribute substantial noise pollution. These impacts are exacerbated by logistics facilities’ typical 24-hour, seven-days-per-week operation. Construction noise is often even greater than operational noise, so if a project site is near sensitive receptors, developers and lead agencies should adopt measures to reduce the noise generated by both construction and operation activities.

Examples of best practices when studying noise impacts include:
• Preparing a noise impact analysis that considers all reasonably foreseeable project noise impacts, including to nearby sensitive receptors. All reasonably foreseeable project noise impacts encompasses noise from both construction and operations, including stationary, on-site, and off-site noise sources. • Adopting a lower significance threshold for incremental noise increases when baseline noise already exceeds total noise significance thresholds, to account for the cumulative impact of additional noise and the fact that, as noise moves up the decibel scale, each decibel increase is a progressively greater increase in sound Updated September 2022
11 pressure than the last. For example, 70 dBA is ten times more sound pressure than 60 dBA.
• Disclosing and considering the significance of short-term noise levels associated with all aspects of project operation (i.e. both on-site noise generation and off-site truck noise). Considering only average noise levels may mask noise impacts sensitive receptors would consider significant—for example, the repeated but short-lived passing of individual trucks or loading activities at night.

Examples of measures to mitigate noise impacts include:
• Constructing physical, structural, or vegetative noise barriers on and/or off the project site.
• Planning and enforcing truck routes that avoid passing sensitive receptors. • Locating or parking all stationary construction equipment as far from sensitive receptors as possible, and directing emitted noise away from sensitive receptors. • Verifying that construction equipment has properly operating and maintained mufflers.
• Requiring all combustion-powered construction equipment to be surrounded by a noise protection barrier
• Limiting operation hours to daytime hours on weekdays. • Paving roads where truck traffic is anticipated with low noise asphalt. • Orienting any public address systems onsite away from sensitive receptors and setting system volume at a level not readily audible past the property line.

VII. Traffic Impacts Analysis and Mitigation
Warehouse facilities inevitably bring truck and passenger car traffic. Truck traffic can present substantial safety issues. Collisions with heavy-duty trucks are especially dangerous for passenger cars, motorcycles, bicycles, and pedestrians. These concerns can be even greater if truck traffic passes through residential areas, school zones, or other places where pedestrians are common and extra caution is warranted.

Examples of measures to mitigate traffic impacts include:
• Designing, clearly marking, and enforcing truck routes that keep trucks out of residential neighborhoods and away from other sensitive receptors. • Installing signs in residential areas noting that truck and employee parking is prohibited.
• Requiring preparation and approval of a truck routing plan describing the facility’s hours of operation, types of items to be stored, and truck routing to and from the facility to designated truck routes that avoids passing sensitive receptors.

The plan should include measures for preventing truck queuing, circling, stopping, and parking on public streets, such as signage, pavement markings, and queuing analysis and enforcement. The plan should hold facility operators responsible for violations of the truck routing plan, and a revised plan should be required from any new tenant that occupies the property before a business license Updated September 2022
12 is issued. The approving agency should retain discretion to determine if changes to the plan are necessary, including any additional measures to alleviate truck routing and parking issues that may arise during the life of the facility. • Constructing new or improved transit stops, sidewalks, bicycle lanes, and crosswalks, with special attention to ensuring safe routes to schools. • Consulting with the local public transit agency and securing increased public transit service to the project area.
• Designating areas for employee pickup and drop-off.
• Implementing traffic control and safety measures, such as speed bumps, speed limits, or new traffic signs or signals.
• Placing facility entry and exit points on major streets that do not have adjacent sensitive receptors.
• Restricting the turns trucks can make entering and exiting the facility to route trucks away from sensitive receptors.
• Constructing roadway improvements to improve traffic flow. • Preparing a construction traffic control plan prior to grading, detailing the locations of equipment staging areas, material stockpiles, proposed road closures, and hours of construction operations, and designing the plan to minimize impacts to roads frequented by passenger cars, pedestrians, bicyclists, and other non-truck traffic.

VIII. Other Significant Environmental Impacts Analysis and Mitigation Warehouse projects may result in significant environmental impacts to other resources, such as to aesthetics, cultural resources, energy, geology, or hazardous materials. All significant adverse environmental impacts must be evaluated, disclosed and mitigated to the extent feasible under CEQA. Examples of best practices and mitigation measures to reduce environmental impacts that do not fall under any of the above categories include:
• Appointing a compliance officer who is responsible for implementing all mitigation measures, and providing contact information for the compliance officer to the lead agency, to be updated annually.
• Creating a fund to mitigate impacts on affected residents, schools, places of worship, and other community institutions by retrofitting their property. For example, retaining a contractor to retrofit/install HVAC and/or air filtration systems, doors, dual-paned windows, and sound- and vibration-deadening insulation and curtains.
• Sweeping surrounding streets on a daily basis during construction to remove any construction-related debris and dirt.
• Directing all lighting at the facility into the interior of the site. • Using full cut-off light shields and/or anti-glare lighting. • Requiring submission of a property maintenance program for agency review and approval providing for the regular maintenance of all building structures, landscaping, and paved surfaces.
• Using cool pavement to reduce heat island effects.

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13 • Planting trees in parking areas to provide at least 35% shade cover of parking areas within fifteen years to reduce heat island impacts. • Using light colored roofing materials with a solar reflective index of 78 or greater. • Including on-site amenities, such as a truck operator lounge with restrooms, vending machines, and air conditioning, to reduce the need for truck operators to idle or travel offsite.
• Designing skylights to provide natural light to interior worker areas. • Installing climate control and air filtration in the warehouse facility to promote worker well-being.

IX. Conclusion
California’s world-class economy, ports, and transportation network position it at the center of the e-commerce and logistics industry boom. At the same time, California is a global leader in environmental protection and environmentally just development. The guidance in this document furthers these dual strengths, ensuring that all can access the benefits of economic development. The Bureau will continue to monitor proposed projects for compliance with CEQA and other laws. Lead agencies, developers, community advocates, and other interested parties should feel free to reach out to us as they consider how to guide warehouse development in their area.

Please do not hesitate to contact the Environmental Justice Bureau at [email protected] if you have any questions.

Attachment H

Attachment I

Attachment J

ON EVALUATING TRANSPORTATION

IMPACTS IN CEQA

TECHNICAL ADVISORY
December 2018
Contents
A. Introduction ...................................................................................................................................... 1 B. Background ....................................................................................................................................... 2 C. Technical Considerations in Assessing Vehicle Miles Traveled......................................................... 4

1. Recommendations Regarding Methodology ................................................................................ 4 D. General Principles to Guide Consideration of VMT .......................................................................... 7 E. Recommendations Regarding Significance Thresholds.................................................................... 8

1. Screening Thresholds for Land Use Projects...............................................................................12

2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects.......................15

3. Recommendations Regarding Land Use Plans............................................................................18

4. Other Considerations..................................................................................................................19 F. Considering the Effects of Transportation Projects on Vehicle Travel ...........................................19

1. Recommended Significance Threshold for Transportation Projects..........................................22

2. Estimating VMT Impacts from Transportation Projects .............................................................23 G. Analyzing Other Impacts Related to Transportation ......................................................................25 H. VMT Mitigation and Alternatives....................................................................................................26 Appendix 1. Considerations About Which VMT to Count .......................................................................29 Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches ............32 1 | Page
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A. Introduction
This technical advisory is one in a series of advisories provided by the Governor’s Office of Planning and Research (OPR) as a service to professional planners, land use officials, and CEQA practitioners. OPR issues technical assistance on issues that broadly affect the practice of land use planning and the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). (Gov. Code, § 65040, subds. (g), (l), (m).) The purpose of this document is to provide advice and recommendations, which agencies and other entities may use at their discretion. This document does not alter lead agency discretion in preparing environmental documents subject to CEQA. This document should not be construed as legal advice.

Senate Bill 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3, § 15000 et seq.) regarding the analysis of transportation impacts. As one appellate court recently explained: “During the last 10 years, the Legislature has charted a course of long-term sustainability based on denser infill development, reduced reliance on individual vehicles and improved mass transit, all with the goal of reducing greenhouse gas emissions. Section 21099 is part of that strategy . . . .” (Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 729.) Pursuant to Section 21099, the criteria for determining the significance of transportation impacts must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” (Id., subd. (b)(1); see generally, adopted CEQA Guidelines, § 15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) To that end, in developing the criteria, OPR has proposed, and the California Natural Resources Agency (Agency) has certified and adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s transportation impacts. With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)

This advisory contains technical recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. Again, OPR provides this Technical Advisory as a resource for the public to use at their discretion. OPR is not enforcing or attempting to enforce any part of the recommendations contained herein. (Gov. Code, § 65035 [“It is not the intent of the Legislature to vest in the Office of Planning and Research any direct operating or regulatory powers over land use, public works, or other state, regional, or local projects or programs.”].) This December 2018 technical advisory is an update to the advisory it published in April 2018. OPR will continue to monitor implementation of these new provisions and may update or supplement this advisory in response to new information and advancements in modeling and methods. 2 | Page
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B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.

The transportation sector has three major means of reducing GHG emissions: increasing vehicle efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air Resources Board (CARB) has provided a path forward for achieving these emissions reductions from the transportation sector in its 2016 Mobile Source Strategy. CARB determined that it will not be possible to achieve the State’s 2030 and post-2030 emissions goals without reducing VMT growth. Further, in its 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, CARB found that despite the State meeting its 2020 climate goals, “emissions from statewide passenger vehicle travel per capita [have been] increasing and going in the wrong direction,” and “California cannot meet its [long-term] climate goals without curbing growth in single-occupancy vehicle activity.”1 CARB also found that “[w]ith emissions from the transportation sector continuing to rise despite increases in fuel efficiency and decreases in the carbon content of fuel, California will not achieve the necessary greenhouse gas emissions reductions to meet mandates for 2030 and beyond without significant changes to how communities and transportation systems are planned, funded, and built.”2

Thus, to achieve the State’s long-term climate goals, California needs to reduce per capita VMT. This can occur under CEQA through VMT mitigation. Half of California’s GHG emissions come from the transportation sector3
, therefore, reducing VMT is an effective climate strategy, which can also result in co-benefits.
4 Furthermore, without early VMT mitigation, the state may follow a path that meets GHG targets in the early years, but finds itself poorly positioned to meet more stringent targets later. For example, in absence of VMT analysis and mitigation in CEQA, lead agencies might rely upon verifiable offsets for GHG mitigation, ignoring the longer-term climate change impacts resulting from land use development and infrastructure investment decisions. As stated in CARB’s 2017 Scoping Plan:
“California’s future climate strategy will require increased focus on integrated land use planning to support livable, transit-connected communities, and conservation of agricultural and other lands. Accommodating population and economic growth through travel- and energy-efficient land use provides GHG-efficient growth, reducing GHGs from both transportation and building energy use. GHGs can be further reduced at the project level through implementing energyefficient construction and travel demand management approaches.”5 (Id. at p. 102.)

1 California Air Resources Board (Nov. 2018) 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, pp. 4, 5, available at https://ww2.arb.ca.gov/sites/default/files/2018-11/Final2018Report SB150 112618 02 Report.pdf. 2 Id., p. 28. 3 See https://ca50million.ca.gov/transportation/ 4 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the Co-Benefits of Reducing Vehicle Miles Traveled. 5 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 102, available at https://www.arb.ca.gov/cc/scopingplan/scoping plan 2017.pdf. 3 | Page
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In light of this, the 2017 Scoping Plan describes and quantifies VMT reductions needed to achieve our long-term GHG emissions reduction goals, and specifically points to the need for statewide deployment of the VMT metric in CEQA:
“Employing VMT as the metric of transportation impact statewide will help to ensure GHG reductions planned under SB 375 will be achieved through on-the-ground development, and will also play an important role in creating the additional GHG reductions needed beyond SB 375 across the State. Implementation of this change will rely, in part, on local land use decisions to reduce GHG emissions associated with the transportation sector, both at the project level, and in long-term plans (including general plans, climate action plans, specific plans, and transportation plans) and supporting sustainable community strategies developed under SB 375.”6

VMT and Other Impacts to Health and Environment. VMT mitigation also creates substantial benefits (sometimes characterized as “co-benefits” to GHG reduction) in both in the near-term and the longterm. Beyond GHG emissions, increases in VMT also impact human health and the natural environment.

Human health is impacted as increases in vehicle travel lead to more vehicle crashes, poorer air quality, increases in chronic diseases associated with reduced physical activity, and worse mental health.

Increases in vehicle travel also negatively affect other road users, including pedestrians, cyclists, other motorists, and many transit users. The natural environment is impacted as higher VMT leads to more collisions with wildlife and fragments habitat. Additionally, development that leads to more vehicle travel also tends to consume more energy, water, and open space (including farmland and sensitive habitat). This increase in impermeable surfaces raises the flood risk and pollutant transport into waterways.7
VMT and Economic Growth. While it was previously believed that VMT growth was a necessary component of economic growth, data from the past two decades shows that economic growth is possible without a concomitant increase in VMT. (Figure 1.) Recent research shows that requiring development projects to mitigate LOS may actually reduce accessibility to destinations and impede economic growth.8,9

6 Id. at p. 76. 7 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the Co-Benefits of Reducing Vehicle Miles Traveled, available at https://ncst.ucdavis.edu/wpcontent/uploads/2017/03/NCST-VMT-Co-Benefits-White-Paper Fang March-2017.pdf. 8 Haynes et al. (Sept. 2015) Congested Development: A Study of Traffic Delays, Access, and Economic Activity in Metropolitan Los Angeles, available at http://www.its.ucla.edu/wpcontent/uploads/sites/6/2015/11/Haynes Congested-Development 1-Oct-2015 final.pdf. 9 Osman et al. (Mar. 2016) Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the San Francisco Bay Area, available at http://www.its.ucla.edu/wpcontent/uploads/sites/6/2016/08/Taylor-Not-so-Fast-04-01-2016 final.pdf. 4 | Page
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Figure 1. Kooshian and Winkelman (2011) VMT and Gross Domestic Product (GDP), 1960-2010.

C. Technical Considerations in Assessing Vehicle Miles Traveled Many practitioners are familiar with accounting for VMT in connection with long-range planning, or as part of the CEQA analysis of a project’s greenhouse gas emissions or energy impacts. This document provides technical information on how to assess VMT as part of a transportation impacts analysis under CEQA. Appendix 1 provides a description of which VMT to count and options on how to count it.

Appendix 2 provides information on induced travel resulting from roadway capacity projects, including the mechanisms giving rise to induced travel, the research quantifying it, and information on additional approaches for assessing it.

1. Recommendations Regarding Methodology
Proposed Section 15064.3 explains that a “lead agency may use models to estimate a project’s vehicle miles traveled . . . .” CEQA generally defers to lead agencies on the choice of methodology to analyze impacts. (Santa Monica Baykeeper v. City of Malibu (2011) 193 Cal.App.4th 1538, 1546; see Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 409 [“the issue is not whether the studies are irrefutable or whether they could have been better” … rather, the “relevant issue is only whether the studies are sufficiently credible to be considered” as part of the lead agency’s overall evaluation].) This section provides suggestions to lead agencies regarding methodologies to analyze VMT associated with a project.

Vehicle Types. Proposed Section 15064.3, subdivision (a), states, “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for example, where models or data provide combined auto and heavy truck VMT). For an apples-to-apples 5 | Page
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comparison, vehicle types considered should be consistent across project assessment, significance thresholds, and mitigation.

Residential and Office Projects. Tour- and trip-based approaches10 offer the best methods for assessing VMT from residential/office projects and for comparing those assessments to VMT thresholds. These approaches also offer the most straightforward methods for assessing VMT reductions from mitigation measures for residential/office projects. When available, tour-based assessment is ideal because it captures travel behavior more comprehensively. But where tour-based tools or data are not available for all components of an analysis, a trip-based assessment of VMT serves as a reasonable proxy.

Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT reduction due to mitigation should be comparable. For example:
• A tour-based assessment of project VMT should be compared to a tour-based threshold, or a trip-based assessment to a trip-based VMT threshold.
• Where a travel demand model is used to determine thresholds, the same model should also be used to provide trip lengths as part of assessing project VMT. • Where only trip-based estimates of VMT reduction from mitigation are available, a trip-based threshold should be used, and project VMT should be assessed in a trip-based manner.

When a trip-based method is used to analyze a residential project, the focus can be on home-based trips. Similarly, when a trip-based method is used to analyze an office project, the focus can be on home-based work trips.

When tour-based models are used to analyze an office project, either employee work tour VMT or VMT from all employee tours may be attributed to the project. This is because workplace location influences overall travel. For consistency, the significance threshold should be based on the same metric: either employee work tour VMT or VMT from all employee tours.

For office projects that feature a customer component, such as a government office that serves the public, a lead agency can analyze the customer VMT component of the project using the methodology for retail development (see below).

Retail Projects. Generally, lead agencies should analyze the effects of a retail project by assessing the change in total VMT11 because retail projects typically re-route travel from other retail destinations. A retail project might lead to increases or decreases in VMT, depending on previously existing retail travel patterns.

10 See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches. 11 See Appendix 1, Considerations About Which VMT to Count, “Assessing Change in Total VMT” section, for a description of this approach.
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Considerations for All Projects. Lead agencies should not truncate any VMT analysis because of jurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside the jurisdiction or by discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQA Guidelines, § 15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a project, the lead agency should apply them to do so. Where those VMT effects will grow over time, analyses should consider both a project’s short-term and long-term effects on VMT.

Combining land uses for VMT analysis is not recommended. Different land uses generate different amounts of VMT, so the outcome of such an analysis could depend more on the mix of uses than on their travel efficiency. As a result, it could be difficult or impossible for a lead agency to connect a significance threshold with an environmental policy objective (such as a target set by law), inhibiting the CEQA imperative of identifying a project’s significant impacts and providing mitigation where feasible.

Combining land uses for a VMT analysis could streamline certain mixes of uses in a manner disconnected from policy objectives or environmental outcomes. Instead, OPR recommends analyzing each use separately, or simply focusing analysis on the dominant use, and comparing each result to the appropriate threshold. Recommendations for methods of analysis and thresholds are provided below.

In the analysis of each use, a mixed-use project should take credit for internal capture.

Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority Area (i.e., the project is within a ½ mile of an existing or planned major transit stop or an existing stop along a high quality transit corridor) may employ VMT as its primary metric of transportation impact for the entire project. (See Pub. Resources Code, § 21099, subds. (a)(7), (b)(1).) Cumulative Impacts. A project’s cumulative impacts are based on an assessment of whether the “incremental effects of an individual 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.” (Pub. Resources Code, § 21083, subd. (b)(2); see CEQA Guidelines, § 15064, subd. (h)(1).) When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would imply a less than significant cumulative impact, and vice versa. This is similar to the analysis typically conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as a threshold of significance. (See Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal.4th 204, 219, 223; CEQA Guidelines, § 15064, subd. (h)(3).) 7 | Page
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D. General Principles to Guide Consideration of VMT
SB 743 directs OPR to establish specific “criteria for determining the significance of transportation impacts of projects[.]” (Pub. Resources Code, § 21099, subd. (b)(1).) In establishing this criterion, OPR was guided by the general principles contained within CEQA, the CEQA Guidelines, and applicable case law.

To assist in the determination of significance, many lead agencies rely on “thresholds of significance.” The CEQA Guidelines define a “threshold of significance” to mean “an identifiable quantitative, qualitative12 or performance level of a particular environmental effect, non-compliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant.” (CEQA Guidelines, § 15064.7, subd. (a) (emphasis added).) Lead agencies have discretion to develop and adopt their own, or rely on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384 (emphasis added); Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1108-1109.)
Additionally, the analysis leading to the determination of significance need not be perfect. The CEQA Guidelines describe the standard for adequacy of environmental analyses:

An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure.
(CEQA Guidelines, § 15151 (emphasis added).)
These general principles guide OPR’s recommendations regarding thresholds of significance for VMT set forth below.

12 Generally, qualitative analyses should only be conducted when methods do not exist for undertaking a quantitative analysis.

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• Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990 levels by 2050.
• Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below 1990 levels by 2050 specifically for transportation.
• Executive Order B-55-18 (2018) established an additional statewide goal of achieving carbon neutrality as soon as possible, but no later than 2045, and maintaining net negative emissions thereafter. It states, “The California Air Resources Board shall work with relevant state agencies to develop a framework for implementation and accounting that tracks progress toward this goal.”
• Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in GHGs below 1990 levels by 2050.
• The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy for containing air pollutant emissions from vehicles, and quantifies VMT growth compatible with achieving state targets.
• The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing GHG emissions from vehicles, and quantifies VMT growth compatible with achieving state targets.

Considering these various targets, the California Supreme Court observed:

Meeting our statewide reduction goals does not preclude all new development. Rather, the Scoping Plan … assumes continued growth and depends on increased efficiency and conservation in land use and transportation from all Californians. (Center for Biological Diversity v. California Dept. of Fish & Wildlife, supra, 62 Cal.4th at p. 220.) Indeed, the Court noted that when a lead agency uses consistency with climate goals as a way to determine significance, particularly for long-term projects, the lead agency must consider the project’s effect on meeting long-term reduction goals. (Ibid.) And more recently, the Supreme Court stated that “CEQA requires public agencies . . . to ensure that such analysis stay in step with evolving scientific knowledge and state regulatory schemes.” (Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 3 Cal.5th 497, 504.)
Meeting the targets described above will require substantial reductions in existing VMT per capita to curb GHG emissions and other pollutants. But targets for overall GHG emissions reduction do not translate directly into VMT thresholds for individual projects for many reasons, including:
• Some, but not all, of the emissions reductions needed to achieve those targets could be accomplished by other measures, including increased vehicle efficiency and decreased fuel carbon content. The CARB’s First Update to the Climate Change Scoping Plan explains:
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“Achieving California’s long-term criteria pollutant and GHG emissions goals will require four strategies to be employed: (1) improve vehicle efficiency and develop zero emission technologies, (2) reduce the carbon content of fuels and provide market support to get these lower-carbon fuels into the marketplace, (3) plan and build communities to reduce vehicular GHG emissions and provide more transportation options, and (4) improve the efficiency and throughput of existing transportation systems.”13 CARB’s 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act states on page 28 that “California cannot meet its climate goals without curbing growth in single-occupancy vehicle activity.” In other words, vehicle efficiency and better fuels are necessary, but insufficient, to address the GHG emissions from the transportation system. Land use patterns and transportation options also will need to change to support reductions in vehicle travel/VMT. • New land use projects alone will not sufficiently reduce per-capita VMT to achieve those targets, nor are they expected to be the sole source of VMT reduction. • Interactions between land use projects, and also between land use and transportation projects, existing and future, together affect VMT.
• Because location within the region is the most important determinant of VMT, in some cases, streamlining CEQA review of projects in travel efficient locations may be the most effective means of reducing VMT.
• When assessing climate impacts of some types of land use projects, use of an efficiency metric (e.g., per capita, per employee) may provide a better measure of impact than an absolute numeric threshold. (Center for Biological Diversity, supra.) Public Resources Code section 21099 directs OPR to propose criteria for determining the significance of transportation impacts. In this Technical Advisory, OPR provides its recommendations to assist lead agencies in selecting a significance threshold that may be appropriate for their particular projects. While OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider thresholds of significance . . . recommended by other public agencies, provided the decision to adopt those thresholds is supported by substantial evidence.” (CEQA Guidelines, § 15064.7, subd. (c).) Based on OPR’s extensive review of the applicable research, and in light of an assessment by the California Air Resources Board quantifying the need for VMT reduction in order to meet the State’s long-term climate goals, OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold.

Fifteen percent reductions in VMT are achievable at the project level in a variety of place types.14 Moreover, a fifteen percent reduction is consistent with SB 743’s direction to OPR to select a threshold that will help the State achieve its climate goals. As described above, section 21099 states that the

13 California Air Resources Board (May 2014) First Update to the Climate Change Scoping Plan, p. 46 (emphasis added).
14 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, p. 55, available at http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf. 11 | Page
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criteria for determining significance must “promote the reduction in greenhouse gas emissions.” In its document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals15, CARB assesses VMT reduction per capita consistent with its evidence-based modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from 1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. Applying California Department of Finance population forecasts, CARB finds per-capita light-duty vehicle travel would need to be approximately 16.8 percent lower than existing, and overall per-capita vehicle travel would need to be approximately 14.3 percent lower than existing levels under that scenario. Below these levels, a project could be considered low VMT and would, on that metric, be consistent with 2017 Scoping Plan Update assumptions that achieve climate state climate goals.

CARB finds per capita vehicle travel would need to be kept below what today’s policies and plans would achieve.

CARB’s assessment is based on data in the 2017 Scoping Plan Update and 2016 Mobile Source Strategy.

In those documents, CARB previously examined the relationship between VMT and the state’s GHG emissions reduction targets. The Scoping Plan finds:
“While the State can do more to accelerate and incentivize these local decisions, local actions that reduce VMT are also necessary to meet transportation sector-specific goals and achieve the 2030 target under SB 32. Through developing the Scoping Plan, CARB staff is more convinced than ever that, in addition to achieving GHG reductions from cleaner fuels and vehicles, California must also reduce VMT. Stronger SB 375 GHG reduction targets will enable the State to make significant progress toward needed reductions, but alone will not provide the VMT growth reductions needed; there is a gap between what SB 375 can provide and what is needed to meet the State’s 2030 and 2050 goals.”16
Note that, at present, consistency with RTP/SCSs does not necessarily lead to a less-than-significant VMT impact.17 As the Final 2017 Scoping Plan Update states, VMT reductions are necessary to achieve the 2030 target and must be part of any strategy evaluated in this Plan. Stronger SB 375 GHG reduction targets will enable the State to make significant progress toward this goal, but alone will not provide all of the VMT growth reductions that will be needed. There is a gap between what SB 375 can provide and what is needed to meet the State’s 2030 and 2050 goals.”18

15 California Air Resources Board (Jan. 2019) California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals, available at https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan-identified-vmt-reductions-andrelationship-state-climate. 16 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 101. 17 California Air Resources Board (Feb. 2018) Updated Final Staff Report: Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets, Figure 3, p. 35, available at https://www.arb.ca.gov/cc/sb375/sb375 target update final staff report feb2018.pdf. 18 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 75. 12 | Page
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Also, in order to capture the full effects of induced travel resulting from roadway capacity projects, an RTP/SCS would need to include an assessment of land use effects of those projects, and the effects of those land uses on VMT. (See section titled “Estimating VMT Impacts from Transportation Projects” below.) RTP/SCSs typically model VMT using a collaboratively-developed land use “vision” for the region’s land use, rather than studying the effects on land use of the proposed transportation investments.

In summary, achieving 15 percent lower per capita (residential) or per employee (office) VMT than existing development is both generally achievable and is supported by evidence that connects this level of reduction to the State’s emissions goals.

1. Screening Thresholds for Land Use Projects
Many agencies use “screening thresholds” to quickly identify when a project should be expected to cause a less-than-significant impact without conducting a detailed study. (See e.g., CEQA Guidelines, §§ 15063(c)(3)(C), 15128, and Appendix G.) As explained below, this technical advisory suggests that lead agencies may screen out VMT impacts using project size, maps, transit availability, and provision of affordable housing.

Screening Threshold for Small Projects
Many local agencies have developed screening thresholds to indicate when detailed analysis is needed.

Absent substantial evidence indicating that a project would generate a potentially significant level of VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, projects that generate or attract fewer than 110 trips per day19 generally may be assumed to cause a less-thansignificant transportation impact.

Map-Based Screening for Residential and Office Projects Residential and office projects that locate in areas with low VMT, and that incorporate similar features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps created with VMT data, for example from a travel survey or a travel demand model, can illustrate areas that are

19 CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to allow for maximum planned development and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd. (e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint (i.e., general office building, single tenant office building, office park, and business park) generate or attract an additional 110-124 trips per 10,000 square feet.

Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a significant impact. 13 | Page
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currently below threshold VMT (see recommendations below). Because new development in such locations would likely result in a similar level of VMT, such maps can be used to screen out residential and office projects from needing to prepare a detailed VMT analysis.

Figure 2. Example map of household VMT that could be used to delineate areas eligible to receive streamlining for VMT analysis. (Source: City of San José, Department of Transportation, draft output of City Transportation Model.)
Presumption of Less Than Significant Impact Near Transit Stations Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop20 or an existing stop

20 Pub. Resources Code, § 21064.3 (“‘Major transit stop’ means a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.”).
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along a high quality transit corridor21 will have a less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or location-specific information indicates that the project will still generate significant levels of VMT. For example, the presumption might not be appropriate if the project:
● Has a Floor Area Ratio (FAR) of less than 0.75
● Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking) ● Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization) ● Replaces affordable residential units with a smaller number of moderate- or high-income residential units
A project or plan near transit which replaces affordable residential units22 with a smaller number of moderate- or high-income residential units may increase overall VMT because the increase in VMT of displaced residents could overwhelm the improvements in travel efficiency enjoyed by new residents.23 If any of these exceptions to the presumption might apply, the lead agency should conduct a detailed VMT analysis to determine whether the project would exceed VMT thresholds (see below).

Presumption of Less Than Significant Impact for Affordable Residential Development Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT.
24,25 Further, “… low-wage workers in particular would be more likely to choose a residential location close to their workplace, if one is available.”26 In areas where existing jobshousing match is closer to optimal, low income housing nevertheless generates less VMT than market-

21 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”).
22 Including naturally-occurring affordable residential units. 23 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4, pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 24 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobshousing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and housing by linking the affordability of locally available housing with local wage levels are likely to be associated with reduced commuting distances”).
25 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing shortages.
26 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing shortages.
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rate housing.
27,28 Therefore, a project consisting of a high percentage of affordable housing may be a basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a presumption of less than significant impact for a 100 percent affordable residential development (or the residential component of a mixed-use development) in infill locations. Lead agencies may develop their own presumption of less than significant impact for residential projects (or residential portions of mixed use projects) containing a particular amount of affordable housing, based on local circumstances and evidence. Furthermore, a project which includes any affordable residential units may factor the effect of the affordability on VMT into the assessment of VMT generated by those units.

2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects
Recommended threshold for residential projects: A proposed project exceeding a level of 15 percent below existing VMT per capita may indicate a significant transportation impact. Existing VMT per capita may be measured as regional VMT per capita or as city VMT per capita. Proposed development referencing a threshold based on city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the number of units specified in the SCS for that city, and should be consistent with the SCS.

Residential development that would generate vehicle travel that is 15 or more percent below the existing residential VMT per capita, measured against the region or city, may indicate a less-thansignificant transportation impact. In MPO areas, development measured against city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the population or number of units specified in the SCS for that city because greater-than-planned amounts of development in areas above the region-based threshold would undermine the VMT containment needed to achieve regional targets under SB 375.

For residential projects in unincorporated county areas, the local agency can compare a residential project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate population-weighted VMT per capita of all cities in the region. In MPO areas, development in unincorporated areas measured against aggregate city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the population or number of units specified in the SCS for that city because greater-than-planned amounts of development in areas above the regional threshold would undermine achievement of regional targets under SB 375.
27 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 28 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf. 16 | Page
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These thresholds can be applied to either household (i.e., tour-based) VMT or home-based (i.e., tripbased) VMT assessments. 29 It is critical, however, that the agency be consistent in its VMT measurement approach throughout the analysis to maintain an “apples-to-apples” comparison. For example, if the agency uses a home-based VMT for the threshold, it should also be use home-based VMT for calculating project VMT and VMT reduction due to mitigation measures.

Because new retail development typically redistributes shopping trips rather than creating new trips, 30 estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and without the project) is the best way to analyze a retail project’s transportation impacts.

By adding retail opportunities into the urban fabric and thereby improving retail destination proximity, local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally may presume such development creates a less-than-significant transportation impact. Regional-serving retail development, on the other hand, which can lead to substitution of longer trips for shorter ones, may tend to have a significant impact. Where such development decreases VMT, lead agencies should consider the impact to be less-than-significant.

Many cities and counties define local-serving and regional-serving retail in their zoning codes. Lead agencies may refer to those local definitions when available, but should also consider any project-

29 See Appendix 1 for a description of these approaches. 30 Lovejoy, et al. (2013) Measuring the impacts of local land-use policies on vehicle miles of travel:

The case of the first big-box store in Davis, California, The Journal of Transport and Land Use.

Recommended threshold for retail projects: A net increase in total VMT may indicate a significant transportation impact.

Office projects that would generate vehicle travel exceeding 15 percent below existing VMT per employee for the region may indicate a significant transportation impact. In cases where the region is substantially larger than the geography over which most workers would be expected to live, it might be appropriate to refer to a smaller geography, such as the county, that includes the area over which nearly all workers would be expected to live.

Office VMT screening maps can be developed using tour-based data, considering either total employee VMT or employee work tour VMT. Similarly, tour-based analysis of office project VMT could consider either total employee VMT or employee work tour VMT. Where tour-based information is unavailable for threshold determination, project assessment, or assessment of mitigation, home-based work trip VMT should be used throughout all steps of the analysis to maintain an “apples-to-apples” comparison.

Recommended threshold for office projects: A proposed project exceeding a level of 15 percent below existing regional VMT per employee may indicate a significant transportation impact. 17 | Page
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specific information, such as market studies or economic impacts analyses that might bear on customers’ travel behavior. Because lead agencies will best understand their own communities and the likely travel behaviors of future project users, they are likely in the best position to decide when a project will likely be local-serving. Generally, however, retail development including stores larger than 50,000 square feet might be considered regional-serving, and so lead agencies should undertake an analysis to determine whether the project might increase or decrease VMT.

Mixed-Use Projects
Lead agencies can evaluate each component of a mixed-use project independently and apply the significance threshold for each project type included (e.g., residential and retail). Alternatively, a lead agency may consider only the project’s dominant use. In the analysis of each use, a project should take credit for internal capture. Combining different land uses and applying one threshold to those land uses may result in an inaccurate impact assessment.

Other Project Types
Of land use projects, residential, office, and retail projects tend to have the greatest influence on VMT.

For that reason, OPR recommends the quantified thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location-specific information, may develop their own more specific thresholds, which may include other land use types. In developing thresholds for other project types, or thresholds different from those recommended here, lead agencies should consider the purposes described in section 21099 of the Public Resources Code and regulations in the CEQA Guidelines on the development of thresholds of significance (e.g., CEQA Guidelines, § 15064.7).

Strategies and projects that decrease local VMT but increase total VMT should be avoided. Agencies should consider whether their actions encourage development in a less travel-efficient location by limiting development in travel-efficient locations.

Redevelopment Projects
Where a project replaces existing VMT-generating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to a less-than-significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds described above should apply.

As described above, a project or plan near transit which replaces affordable31 residential units with a smaller number of moderate- or high-income residential units may increase overall VMT, because

31 Including naturally-occurring affordable residential units. 18 | Page
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displaced residents’ VMT may increase.
32 A lead agency should analyze VMT for such a project even if it otherwise would have been presumed less than significant. The assessment should incorporate an estimate of the aggregate VMT increase experienced by displaced residents. That additional VMT should be included in the numerator of the VMT per capita assessed for the project.

If a residential or office project leads to a net increase in VMT, then the project’s VMT per capita (residential) or per employee (office) should be compared to thresholds recommended above. Per capita and per employee VMT are efficiency metrics, and, as such, apply only to the existing project without regard to the VMT generated by the previously existing land use.

If the project leads to a net increase in provision of locally-serving retail, transportation impacts from the retail portion of the development should be presumed to be less than significant. If the project consists of regionally-serving retail, and increases overall VMT compared to with existing uses, then the project would lead to a significant transportation impact.

RTP/SCS Consistency (All Land Use Projects)
Section 15125, subdivision (d), of the CEQA Guidelines provides that lead agencies should analyze impacts resulting from inconsistencies with regional plans, including regional transportation plans. For this reason, if a project is inconsistent with the Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS), the lead agency should evaluate whether that inconsistency indicates a significant impact on transportation. For example, a development may be inconsistent with an RTP/SCS if the development is outside the footprint of development or within an area specified as open space as shown in the SCS.

3. Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over which the plan may substantively affect travel patterns, including beyond the boundary of the plan or jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split between origin and destination. (Emissions inventories have sometimes spit cross-boundary trips in order to sum to a regional total, but CEQA requires accounting for the full impact without truncation or discounting).

Analysis of specific plans may employ the same thresholds described above for projects. A general plan, area plan, or community plan may have a significant impact on transportation if proposed new residential, office, or retail land uses would in aggregate exceed the respective thresholds recommended above. Where the lead agency tiers from a general plan EIR pursuant to CEQA Guidelines sections 15152 and 15166, the lead agency generally focuses on the environmental impacts that are specific to the later project and were not analyzed as significant impacts in the prior EIR. (Pub. Resources Code, § 21068.5; Guidelines, § 15152, subd. (a).) Thus, in analyzing the later project, the lead agency

32 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4, pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 19 | Page
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would focus on the VMT impacts that were not adequately addressed in the prior EIR. In the tiered document, the lead agency should continue to apply the thresholds recommended above.

Thresholds for plans in non-MPO areas may be determined on a case-by-case basis.

4. Other Considerations
Rural Projects Outside of MPOs
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns), fewer options may be available for reducing VMT, and significance thresholds may be best determined on a case-by-case basis. Note, however, that clustered small towns and small town main streets may have substantial VMT benefits compared to isolated rural development, similar to the transit oriented development described above.

Impacts to Transit
Because criteria for determining the significance of transportation impacts must promote “the development of multimodal transportation networks” pursuant to Public Resources Code section 21099, subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may interfere with transit functions. Lead agencies should consult with transit agencies as early as possible in the development process, particularly for projects that are located within one half mile of transit stops.

When evaluating impacts to multimodal transportation networks, lead agencies generally should not treat the addition of new transit users as an adverse impact. An infill development may add riders to transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds destinations, improving proximity and accessibility. Such development also improves regional vehicle flow by adding less vehicle travel onto the regional network.

Increased demand throughout a region may, however, cause a cumulative impact by requiring new or additional transit infrastructure. Such impacts may be adequately addressed through a fee program that fairly allocates the cost of improvements not just to projects that happen to locate near transit, but rather across a region to all projects that impose burdens on the entire transportation system, since transit can broadly improve the function of the transportation system.

F. Considering the Effects of Transportation Projects on Vehicle Travel Many transportation projects change travel patterns. A transportation project which leads to additional vehicle travel on the roadway network, commonly referred to as “induced vehicle travel,” would need to quantify the amount of additional vehicle travel in order to assess air quality impacts, greenhouse gas emissions impacts, energy impacts, and noise impacts. Transportation projects also are required to 20 | Page
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examine induced growth impacts under CEQA. (See generally, Pub. Resources Code, §§ 21065 [defining “project” under CEQA as an activity as causing either a direct or reasonably foreseeable indirect physical change], 21065.3 [defining “project-specific effect” to mean all direct or indirect environmental effects], 21100, subd. (b) [required contents of an EIR].) For any project that increases vehicle travel, explicit assessment and quantitative reporting of the amount of additional vehicle travel should not be omitted from the document; such information may be useful and necessary for a full understanding of a project’s environmental impacts. (See Pub. Resources Code, §§ 21000, 21001, 21001.1, 21002, 21002.1 [discussing the policies of CEQA].) A lead agency that uses the VMT metric to assess the transportation impacts of a transportation project may simply report that change in VMT as the impact. When the lead agency uses another metric to analyze the transportation impacts of a roadway project, changes in amount of vehicle travel added to the roadway network should still be analyzed and reported. 33 While CEQA does not require perfection, it is important to make a reasonably accurate estimate of transportation projects’ effects on vehicle travel in order to make reasonably accurate estimates of GHG emissions, air quality emissions, energy impacts, and noise impacts. (See, e.g., California Clean Energy Com. v. City of Woodland (2014) 225 Cal.App.4th 173, 210 [EIR failed to consider project’s transportation energy impacts]; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th 256, 266.) Appendix 2 describes in detail the causes of induced vehicle travel, the robust empirical evidence of induced vehicle travel, and how models and research can be used in conjunction to quantitatively assess induced vehicle travel with reasonable accuracy.

If a project would likely lead to a measurable and substantial increase in vehicle travel, the lead agency should conduct an analysis assessing the amount of vehicle travel the project will induce. Project types that would likely lead to a measurable and substantial increase in vehicle travel generally include:
• Addition of through lanes on existing or new highways, including general purpose lanes, HOV lanes, peak period lanes, auxiliary lanes, or lanes through grade-separated interchanges Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis, include:
• Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the condition of existing transportation assets (e.g., highways; roadways; bridges; culverts; Transportation Management System field elements such as cameras, message signs, detection, or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do not add additional motor vehicle capacity
• Roadside safety devices or hardware installation such as median barriers and guardrails

33 See, e.g., California Department of Transportation (2006) Guidance for Preparers of Growth-related, Indirect Impact Analyses, available at http://www.dot.ca.gov/ser/Growthrelated IndirectImpactAnalysis/GRI guidance06May files/gri guidance.pdf. 21 | Page
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• Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used as automobile vehicle travel lanes
• Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety • Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not utilized as through lanes
• Addition of roadway capacity on local or collector streets provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit • Conversion of existing general purpose lanes (including ramps) to managed lanes or transit lanes, or changing lane management in a manner that would not substantially increase vehicle travel
• Addition of a new lane that is permanently restricted to use only by transit vehicles • Reduction in number of through lanes
• Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles • Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority (TSP) features
• Installation of traffic metering systems, detection systems, cameras, changeable message signs and other electronics designed to optimize vehicle, bicycle, or pedestrian flow • Timing of signals to optimize vehicle, bicycle, or pedestrian flow • Installation of roundabouts or traffic circles
• Installation or reconfiguration of traffic calming devices • Adoption of or increase in tolls
• Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase • Initiation of new transit service
• Conversion of streets from one-way to two-way operation with no net increase in number of traffic lanes
• Removal or relocation of off-street or on-street parking spaces • Adoption or modification of on-street parking or loading restrictions (including meters, time limits, accessible spaces, and preferential/reserved parking permit programs) • Addition of traffic wayfinding signage
• Rehabilitation and maintenance projects that do not add motor vehicle capacity • Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within existing public rights-of-way
• Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve nonmotorized travel • Installation of publicly available alternative fuel/charging infrastructure • Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do not increase overall vehicle capacity along the corridor 22 | Page
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1. Recommended Significance Threshold for Transportation Projects As noted in Section 15064.3 of the CEQA Guidelines, lead agencies for roadway capacity projects have discretion, consistent with CEQA and planning requirements, to choose which metric to use to evaluate transportation impacts. This section recommends considerations for evaluating impacts using vehicle miles traveled. Lead agencies have discretion to choose a threshold of significance for transportation projects as they do for other types of projects. As explained above, Public Resources Code section 21099, subdivision (b)(1), provides that criteria for determining the significance of transportation impacts must promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. (Id.; see generally, adopted CEQA Guidelines, § 15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) With those goals in mind, OPR prepared and the Agency adopted an appropriate transportation metric.

Whether adopting a threshold of significance, or evaluating transportation impacts on a case-by-case basis, a lead agency should ensure that the analysis addresses:
• Direct, indirect and cumulative effects of the transportation project (CEQA Guidelines, § 15064, subds. (d), (h))
• Near-term and long-term effects of the transportation project (CEQA Guidelines, §§ 15063, subd. (a)(1), 15126.2, subd. (a))
• The transportation project’s consistency with state greenhouse gas reduction goals (Pub.

Resources Code, § 21099)34
• The impact of the transportation project on the development of multimodal transportation networks (Pub. Resources Code, § 21099)
• The impact of the transportation project on the development of a diversity of land uses (Pub.

Resources Code, § 21099)
The CARB Scoping Plan and the CARB Mobile Source Strategy delineate VMT levels required to achieve legally mandated GHG emissions reduction targets. A lead agency should develop a project-level threshold based on those VMT levels, and may apply the following approach:

1. Propose a fair-share allocation of those budgets to their jurisdiction (e.g., by population);

34 The California Air Resources Board has ascertained the limits of VMT growth compatible with California containing greenhouse gas emissions to levels research shows would allow for climate stabilization. (See The 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Target (p. 78, p. 101); Mobile Source Strategy (p. 37).) CARB’s Updated Final Staff Report on Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets illustrates that the current Regional Transportation Plans and Sustainable Communities Strategies will fall short of achieving the necessary on-road transportation-related GHG emissions reductions called for in the 2017 Scoping Plan (Figure 3, p. 35). Accordingly, OPR recommends not basing GHG emissions or transportation impact analysis for a transportation project solely on consistency with an RTP/SCS. 23 | Page
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2. Determine the amount of VMT growth likely to result from background population growth, and subtract that from their “budget”;

3. Allocate their jurisdiction’s share between their various VMT-increasing transportation projects, using whatever criteria the lead agency prefers.

2. Estimating VMT Impacts from Transportation Projects
CEQA requires analysis of a project’s potential growth-inducing impacts. (Pub. Resources Code, § 21100, subd. (b)(5); CEQA Guidelines, § 15126.2, subd. (d).) Many agencies are familiar with the analysis of growth inducing impacts associated with water, sewer, and other infrastructure. This technical advisory addresses growth that may be expected from roadway expansion projects.

Because a roadway expansion project can induce substantial VMT, incorporating quantitative estimates of induced VMT is critical to calculating both transportation and other impacts of these projects.

Induced travel also has the potential to reduce or eliminate congestion relief benefits. An accurate estimate of induced travel is needed to accurately weigh costs and benefits of a highway capacity expansion project.

The effect of a transportation project on vehicle travel should be estimated using the “change in total VMT” method described in Appendix 1. This means that an assessment of total VMT without the project and an assessment with the project should be made; the difference between the two is the amount of VMT attributable to the project. The assessment should cover the full area in which driving patterns are expected to change. As with other types of projects, the VMT estimation should not be truncated at a modeling or jurisdictional boundary for convenience of analysis when travel behavior is substantially affected beyond that boundary.

Transit and Active Transportation Projects
Transit and active transportation projects generally reduce VMT and therefore are presumed to cause a less-than-significant impact on transportation. This presumption may apply to all passenger rail projects, bus and bus rapid transit projects, and bicycle and pedestrian infrastructure projects. Streamlining transit and active transportation projects aligns with each of the three statutory goals contained in SB 743 by reducing GHG emissions, increasing multimodal transportation networks, and facilitating mixed use development.

Roadway Projects
Reducing roadway capacity (for example, by removing or repurposing motor vehicle travel lanes) will generally reduce VMT and therefore is presumed to cause a less-than-significant impact on transportation. Generally, no transportation analysis is needed for such projects. 24 | Page
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Building new roadways, adding roadway capacity in congested areas, or adding roadway capacity to areas where congestion is expected in the future, typically induces additional vehicle travel. For the types of projects previously indicated as likely to lead to additional vehicle travel, an estimate should be made of the change in vehicle travel resulting from the project.

For projects that increase roadway capacity, lead agencies can evaluate induced travel quantitatively by applying the results of existing studies that examine the magnitude of the increase of VMT resulting from a given increase in lane miles. These studies estimate the percent change in VMT for every percent change in miles to the roadway system (i.e., “elasticity”). 35 Given that lead agencies have discretion in
choosing their methodology, and the studies on induced travel reveal a range of elasticities, lead agencies may appropriately apply professional judgment in studying the transportation effects of a particular project. The most recent major study, estimates an elasticity of 1.0, meaning that every percent change in lane miles results in a one percent increase in VMT.36 To estimate VMT impacts from roadway expansion projects:

1. Determine the total lane-miles over an area that fully captures travel behavior changes resulting from the project (generally the region, but for projects affecting interregional travel look at all affected regions).

2. Determine the percent change in total lane miles that will result from the project.

3. Determine the total existing VMT over that same area.

4. Multiply the percent increase in lane miles by the existing VMT, and then multiply that by the elasticity from the induced travel literature:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project] A National Center for Sustainable Transportation tool can be used to apply this method:
https://ncst.ucdavis.edu/research/tools
This method would not be suitable for rural (non-MPO) locations in the state which are neither congested nor projected to become congested. It also may not be suitable for a new road that provides new connectivity across a barrier (e.g., a bridge across a river) if it would be expected to substantially 35 See U.C. Davis, Institute for Transportation Studies (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion; Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway capacity brief.pdf. 36 See Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.
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shorten existing trips. If it is likely to be substantial, the trips-shortening effect should be examined explicitly.

The effects of roadway capacity on vehicle travel can also be applied at a programmatic level. For example, in a regional planning process the lead agency can use that program-level analysis to streamline later project-level analysis. (See CEQA Guidelines, § 15168.) A program-level analysis of VMT should include effects of the program on land use patterns, and the VMT that results from those land use effects. In order for a program-level document to adequately analyze potential induced demand from a project or program of roadway capacity expansion, lead agencies cannot assume a fixed land use pattern (i.e., a land use pattern that does not vary in response to the provision of roadway capacity). A proper analysis should account for land use investment and development pattern changes that react in a reasonable manner to changes in accessibility created by transportation infrastructure investments (whether at the project or program level).

Mitigation and Alternatives
Induced VMT has the potential to reduce or eliminate congestion relief benefits, increase VMT, and increase other environmental impacts that result from vehicle travel.37 If those effects are significant, the lead agency will need to consider mitigation or alternatives. In the context of increased travel that is induced by capacity increases, appropriate mitigation and alternatives that a lead agency might consider include the following:
• Tolling new lanes to encourage carpools and fund transit improvements • Converting existing general purpose lanes to HOV or HOT lanes • Implementing or funding off-site travel demand management • Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger throughput on existing lanes
Tolling and other management strategies can have the additional benefit of preventing congestion and maintaining free-flow conditions, conferring substantial benefits to road users as discussed above.

G. Analyzing Other Impacts Related to Transportation
While requiring a change in the methodology of assessing transportation impacts, Public Resources Code section 21099 notes that this change “does not relieve a public agency of the requirement to analyze a project’s potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation.” OPR expects that lead agencies will continue to

37 See National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015- NCST Brief InducedTravel CS6 v3.pdf; see Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376. 26 | Page
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address mobile source emissions in the air quality and noise sections of an environmental document and the corresponding studies that support the analysis in those sections. Lead agencies should continue to address environmental impacts of a proposed project pursuant to CEQA’s requirements, using a format that is appropriate for their particular project.

Because safety concerns result from many different factors, they are best addressed at a programmatic level (i.e., in a general plan or regional transportation plan) in cooperation with local governments, metropolitan planning organizations, and, where the state highway system is involved, the California Department of Transportation. In most cases, such an analysis would not be appropriate on a projectby-project basis. Increases in traffic volumes at a particular location resulting from a project typically cannot be estimated with sufficient accuracy or precision to provide useful information for an analysis of safety concerns. Moreover, an array of factors affect travel demand (e.g., strength of the local economy, price of gasoline), causing substantial additional uncertainty. Appendix B of OPR’s General Plan Guidelines summarizes research which could be used to guide a programmatic analysis under CEQA.

Lead agencies should note that automobile congestion or delay does not constitute a significant environmental impact (Pub. Resources Code, §21099(b)(2)), and safety should not be used as a proxy for road capacity.

H. VMT Mitigation and Alternatives
When a lead agency identifies a significant impact, it must identify feasible mitigation measures that could avoid or substantially reduce that impact. (Pub. Resources Code, § 21002.1, subd. (a).) Additionally, CEQA requires that an environmental impact report identify feasible alternatives that could avoid or substantially reduce a project’s significant environmental impacts.

Indeed, the California Court of Appeal recently held that a long-term regional transportation plan was deficient for failing to discuss an alternative which could significantly reduce total vehicle miles traveled.

In Cleveland National Forest Foundation v. San Diego Association of Governments, et al. (2017) 17 Cal.App.5th 413, the court found that omission “inexplicable” given the lead agency’s “acknowledgment in its Climate Action Strategy that the state’s efforts to reduce greenhouse gas emissions from on-road transportation will not succeed if the amount of driving, or vehicle miles traveled, is not significantly reduced.” (Cleveland National Forest Foundation, supra, 17 Cal.App.5th at p. 436.) Additionally, the court noted that the project alternatives focused primarily on congestion relief even though “the [regional] transportation plan is a long-term and congestion relief is not necessarily an effective longterm strategy.” (Id. at p. 437.) The court concluded its discussion of the alternatives analysis by stating:
“Given the acknowledged long-term drawbacks of congestion relief alternatives, there is not substantial evidence to support the EIR’s exclusion of an alternative focused primarily on significantly reducing vehicle trips.” (Ibid.)
Several examples of potential mitigation measures and alternatives to reduce VMT are described below.

However, the selection of particular mitigation measures and alternatives are left to the discretion of 27 | Page
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the lead agency, and mitigation measures may vary, depending on the proposed project and significant impacts, if any. Further, OPR expects that agencies will continue to innovate and find new ways to reduce vehicular travel.

Potential measures to reduce vehicle miles traveled include, but are not limited to:
• Improve or increase access to transit.
• Increase access to common goods and services, such as groceries, schools, and daycare. • Incorporate affordable housing into the project.
• Incorporate neighborhood electric vehicle network.
• Orient the project toward transit, bicycle and pedestrian facilities. • Improve pedestrian or bicycle networks, or transit service. • Provide traffic calming.
• Provide bicycle parking.
• Limit or eliminate parking supply.
• Unbundle parking costs.
• Provide parking cash-out programs.
• Implement roadway pricing.
• Implement or provide access to a commute reduction program. • Provide car-sharing, bike sharing, and ride-sharing programs. • Provide transit passes.
• Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ridematching services. • Providing telework options.
• Providing incentives or subsidies that increase the use of modes other than single-occupancy vehicle.
• Providing on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms.
• Providing employee transportation coordinators at employment sites. • Providing a guaranteed ride home service to users of non-auto modes.

Notably, because VMT is largely a regional impact, regional VMT-reduction programs may be an appropriate form of mitigation. In lieu fees have been found to be valid mitigation where there is both a commitment to pay fees and evidence that mitigation will actually occur. (Save Our Peninsula Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 140-141; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359; Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 727–728.) Fee programs are particularly useful to address cumulative impacts. (CEQA Guidelines, § 15130, subd. (a)(3) [a “project’s incremental contribution is less than cumulatively considerable if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative impact”].) The mitigation program must undergo CEQA evaluation, either on the program as a whole, or the in-lieu fees or other mitigation must be evaluated 28 | Page
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on a project-specific basis. (California Native Plant Society v. County of El Dorado (2009) 170 Cal.App.4th 1026.) That CEQA evaluation could be part of a larger program, such as a regional transportation plan, analyzed in a Program EIR. (CEQA Guidelines, § 15168.)
Examples of project alternatives that may reduce vehicle miles traveled include, but are not limited to:
• Locate the project in an area of the region that already exhibits low VMT. • Locate the project near transit.
• Increase project density.
• Increase the mix of uses within the project or within the project’s surroundings. • Increase connectivity and/or intersection density on the project site. • Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or roadway lanes.
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Appendix 1. Considerations About Which VMT to Count
Consistent with the obligation to make a good faith effort to disclose the environmental consequences of a project, lead agencies have discretion to choose the most appropriate methodology to evaluate project impacts.38 A lead agency can evaluate a project’s effect on VMT in numerous ways. The purpose of this document is to provide technical considerations in determining which methodology may be most useful for various project types.

Background on Estimating Vehicle Miles Traveled
Before discussing specific methodological recommendations, this section provides a brief overview of modeling and counting VMT, including some key terminology.

Here is an illustrative example of some methods of estimating vehicle miles traveled. Consider the following hypothetical travel day (all by automobile):

1. Residence to Coffee Shop

2. Coffee Shop to Work

3. Work to Sandwich Shop

4. Sandwich Shop to Work

5. Work to Residence

6. Residence to Store

7. Store to Residence
Trip-based assessment of a project’s effect on travel behavior counts VMT from individual trips to and from the project. It is the most basic, and traditionally the most common, method of counting VMT. A trip-based VMT assessment of the residence in the above example would consider segments 1, 5, 6 and

7. For residential projects, the sum of home-based trips is called home-based VMT.

A tour-based assessment counts the entire home-back-to-home tour that includes the project. A tourbased VMT assessment of the residence in the above example would consider segments 1, 2, 3, 4, and 5 in one tour, and 6 and 7 in a second tour. A tour-based assessment of the workplace would include segments 1, 2, 3, 4, and 5. Together, all tours comprise household VMT.

38 The California Supreme Court has explained that when an agency has prepared an environmental impact report:
[T]he issue is not whether the [lead agency’s] studies are irrefutable or whether they could have been better. The relevant issue is only whether the studies are sufficiently credible to be considered as part of the total evidence that supports the [lead agency’s] finding[.]
(Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 409; see also Eureka Citizens for Responsible Gov’t v. City of Eureka (2007) 147 Cal.App.4th 357, 372.) 30 | Page
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Both trip- and tour-based assessments can be used as measures of transportation efficiency, using denominators such as per capita, per employee, or per person-trip.

Trip- and Tour-based Assessment of VMT
As illustrated above, a tour-based assessment of VMT is a more complete characterization of a project’s effect on VMT. In many cases, a project affects travel behavior beyond the first destination. The location and characteristics of the home and workplace will often be the main drivers of VMT. For example, a residential or office development located near high quality transit will likely lead to some commute trips utilizing transit, affecting mode choice on the rest of the tour.

Characteristics of an office project can also affect an employee’s VMT beyond the work tour. For example, a workplace located at the urban periphery, far from transit, can require an employee to own a car, which in turn affects the entirety of an employee’s travel behavior and VMT. For this reason, when estimating the effect of an office development on VMT, it may be appropriate to consider total employee VMT if data and tools, such as tour-based models, are available. This is consistent with CEQA’s requirement to evaluate both direct and indirect effects of a project. (See CEQA Guidelines, § 15064, subd. (d)(2).)
Assessing Change in Total VMT
A third method, estimating the change in total VMT with and without the project, can evaluate whether a project is likely to divert existing trips, and what the effect of those diversions will be on total VMT.

This method answers the question, “What is the net effect of the project on area VMT?” As an illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips from more distant stores could reveal a net VMT reduction. The analysis should address the full area over which the project affects travel behavior, even if the effect on travel behavior crosses political boundaries.

Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and estimate VMT (see Appendix F of the preliminary discussion draft). To the extent possible, lead agencies should choose models that have sensitivity to features of the project that affect VMT.

Those tools and resources can also assist in establishing thresholds of significance and estimating VMT reduction attributable to mitigation measures and project alternatives. When using models and tools for those various purposes, agencies should use comparable data and methods, in order to set up an “apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates.

Models can work together. For example, agencies can use travel demand models or survey data to estimate existing trip lengths and input those into sketch models such as CalEEMod to achieve more 31 | Page
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accurate results. Whenever possible, agencies should input localized trip lengths into a sketch model to tailor the analysis to the project location. However, in doing so, agencies should be careful to avoid double counting if the sketch model includes other inputs or toggles that are proxies for trip length (e.g., distance to city center). Generally, if an agency changes any sketch model defaults, it should record and report those changes for transparency of analysis. Again, trip length data should come from the same source as data used to calculate thresholds to be sure of an “apples-to-apples” comparison.

Additional background information regarding travel demand models is available in the California Transportation Commission’s “2010 Regional Transportation Plan Guidelines,” beginning at page 35. 32 | Page
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Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches Induced travel occurs where roadway capacity is expanded in an area of present or projected future congestion. The effect typically manifests over several years. Lower travel times make the modified facility more attractive to travelers, resulting in the following trip-making changes:
● Longer trips. The ability to travel a long distance in a shorter time increases the attractiveness of destinations that are farther away, increasing trip length and vehicle travel. ● Changes in mode choice. When transportation investments are devoted to reducing automobile travel time, travelers tend to shift toward automobile use from other modes, which increases vehicle travel.
● Route changes. Faster travel times on a route attract more drivers to that route from other routes, which can increase or decrease vehicle travel depending on whether it shortens or lengthens trips.
● Newly generated trips. Increasing travel speeds can induce additional trips, which increases vehicle travel. For example, an individual who previously telecommuted or purchased goods on the internet might choose to accomplish those tasks via automobile trips as a result of increased speeds.
● Land Use Changes. Faster travel times along a corridor lead to land development farther along that corridor; that new development generates and attracts longer trips, which increases vehicle travel. Over several years, this induced growth component of induced vehicle travel can be substantial, making it critical to include in analyses.

Each of these effects has implications for the total amount of vehicle travel. These effects operate over different time scales. For example, changes in mode choice might occur immediately, while land use changes typically take a few years or longer. CEQA requires lead agencies to analyze both short-term and long-term effects.

Evidence of Induced Vehicle Travel. A large number of peer reviewed studies39 have demonstrated a causal link between highway capacity increases and VMT increases. Many provide quantitative estimates of the magnitude of the induced VMT phenomenon. Collectively, they provide high quality evidence of the existence and magnitude of the induced travel effect.

39 See, e.g., Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway capacity brief.pdf; National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/research/researchreports/reports/2015/10-12-2015- NCST Brief InducedTravel CS6 v3.pdf.
33 | Page
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Most of these studies express the amount of induced vehicle travel as an “elasticity,” which is a multiplier that describes the additional vehicle travel resulting from an additional lane mile of roadway capacity added. For example, an elasticity of 0.6 would signify an 0.6 percent increase in vehicle travel for every 1.0 percent increase in lane miles. Many of these studies distinguish “short run elasticity” (increase in vehicle travel in the first few years) from “long run elasticity” (increase in vehicle travel beyond the first few years). Long run elasticity is larger than short run elasticity, because as time passes, more of the components of induced vehicle travel materialize. Generally, short run elasticity can be thought of as excluding the effects of land use change, while long run elasticity includes them. Most studies find a long run elasticity between 0.6 and just over 1.0, 40 meaning that every increase in lanes
miles of one percent leads to an increase in vehicle travel of 0.6 to 1.0 percent. The most recent major study finds the elasticity of vehicle travel by lanes miles added to be 1.03; in other words, each percent increase in lane miles results in a 1.03 percent increase in vehicle travel. 41 (An elasticity greater than 1.0
can occur because new lanes induce vehicle travel that spills beyond the project location.) In CEQA analysis, the long-run elasticity should be used, as it captures the full effect of the project rather than just the early-stage effect.

Quantifying Induced Vehicle Travel Using Models. Lead agencies can generally achieve the most accurate assessment of induced vehicle travel resulting from roadway capacity increasing projects by applying elasticities from the academic literature, because those estimates include vehicle travel resulting from induced land use. If a lead agency chooses to use a travel demand model, additional analysis would be needed to account for induced land use. This section describes some approaches to undertaking that additional analysis.

Proper use of a travel demand model can capture the following components of induced VMT:
• Trip length (generally increases VMT)
• Mode shift (generally shifts from other modes toward automobile use, increasing VMT) • Route changes (can act to increase or decrease VMT)
• Newly generated trips (generally increases VMT)
o Note that not all travel demand models have sensitivity to this factor, so an off-model estimate may be necessary if this effect could be substantial.

However, estimating long-run induced VMT also requires an estimate of the project’s effects on land use. This component of the analysis is important because it has the potential to be a large component of

40 See Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, p. 2, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway capacity brief.pdf. 41 Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.
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the overall induced travel effect. Options for estimating and incorporating the VMT effects that are caused by the subsequent land use changes include:

1. Employ an expert panel. An expert panel could assess changes to land use development that would likely result from the project. This assessment could then be analyzed by the travel demand model to assess effects on vehicle travel. Induced vehicle travel assessed via this approach should be verified using elasticities found in the academic literature.

2. Adjust model results to align with the empirical research. If the travel demand model analysis is performed without incorporating projected land use changes resulting from the project, the assessed vehicle travel should be adjusted upward to account for those land use changes. The assessed VMT after adjustment should fall within the range found in the academic literature.

3. Employ a land use model, running it iteratively with a travel demand model. A land use model can be used to estimate the land use effects of a roadway capacity increase, and the traffic patterns that result from the land use change can then be fed back into the travel demand model. The land use model and travel demand model can be iterated to produce an accurate result.

A project which provides new connectivity across a barrier, such as a new bridge across a river, may provide a shortened path between existing origins and destinations, thereby shortening existing trips. In rare cases, this trip-shortening effect might be substantial enough to reduce the amount of vehicle travel resulting from the project below the range found in the elasticities in the academic literature, or even lead a net reduction in vehicle travel overall. In such cases, the trip-shortening effect could be examined explicitly.

Whenever employing a travel demand model to assess induced vehicle travel, any limitation or known lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example, model insensitivity to one of the components of induced VMT described above) should be disclosed and characterized, and a description should be provided on how it could influence the analysis results. A discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis, such as greenhouse gas emissions, air quality, energy, and noise.

From: Kristi Bascom
To: Clerk
Cc: Edward T. Schexnayder; Carmen J. Borg
Subject: Public comment on 8/14/2024 City Council agenda Item ID 25-1026 - Email 2 of 2 Date: Tuesday, August 12, 2025 6:09:40 PM
Attachments: image001.png
SMW-SFCA letter Attachments K-N.pdf
External Email: Use caution with links and attachments
Second email with attachments to comment letter on behalf of South Fresno Community Alliance for 8/14/2025 City Council agenda item # ID 25-1026. Attachments K, L, M, and N included in this email.

Kristi Bascom, AICP
Urban Planner
Shute, Mihaly & Weinberger LLP
396 Hayes Street
San Francisco, CA 94102-4421
o: 415/552-7272 x 202 c: 925/872-6327
www.smwlaw.com | A San Francisco Green Business
Attachment K

South Central Fresno Community Emissions Reduction Program September 19, 2019 1 | P a g e

EXECUTIVE SUMMARY
The air quality challenges that the communities in the San Joaquin Valley face are unmatched by any other region in the nation. The San Joaquin Valley, due to its unique geography, topography, and meteorology, continues to face daunting challenges in meeting the latest federal health-based air quality standards. Since 1992, the San Joaquin Valley Air Pollution Control District (District) has implemented nearly 650 rules and regulations to control air pollution in the Valley Air Basin. Numerous plans to improve Valley air quality and attain state and federal air quality standards have detailed a wide-range of strategies, including regulatory measures, extensive incentive investment to promote clean-air technologies in Valley communities, and other first-oftheir kind measures.

As a result of the District’s stringent and comprehensive air quality management strategy, along with significant investments made by Valley businesses and residents, PM2.5 and ozone levels are now at historically low levels, and the Valley continues to be in attainment of the PM10 federal air quality standard. Emissions from stationary sources have been reduced by 85%, cancer risk from exposure to air pollutants has been reduced by 95%, population exposure to elevated PM2.5 levels have been reduced by 85%, and population exposure to elevated ozone levels have been reduced by 90%.

Despite these regional air quality improvements, significant concern has been expressed by the California legislature about potential localized impacts of air pollution in disadvantaged communities throughout the state. In answer to that concern, Assembly Bill (AB) 617, signed into law in July 2017, initiated a state-wide effort to monitor and reduce air pollution, and improve public health, in communities that experience disproportionate burdens from exposure to air pollutants through new community-focused and community-driven actions. The community of South Central Fresno was prioritized by the Air District and subsequently selected by the California Air Resources Board (CARB) as one of two first-year communities in the San Joaquin Valley to receive clean air resources newly available under AB 617, based on a technical analysis of several pollution and poverty-related criteria.

AB 617 provides mechanisms and resources to implement community-specific air quality monitoring networks; to develop, implement, and track emission reduction programs; to improve availability of data and other technical information; and to invest substantial funding in the community through voluntary incentive funding measures.

Importantly, these measures are guided by advice and knowledge of local community members, through their input and involvement on Steering Committees for each AB 617-selected community.

Air pollution emission reduction and exposure reduction measures implemented under AB 617 programs will further advance ongoing state and District efforts to reduce regional and community exposure to air pollutants. In the preparation of this South Central Fresno Community Emissions Reduction Program September 19, 2019 2 | P a g e
Community Emissions Reduction Program, the District has worked closely with CARB, the Community Steering Committee, and the public, including other local agencies, community-based organizations, community members, environmental organizations, regulated industry representatives, and other key stakeholders to develop strategies and an implementation plan to reduce harmful air pollutants in the community of South Central Fresno. The plan developed through this collaborative process employs proven and innovative strategies, and significant resources, to improve community health by reducing exposure to air pollutants in South Central Fresno.

This Community Emission Reduction Program (CERP) provides a description of the community of South Central Fresno, including geographical boundaries and socioeconomic factors impacting community residents. A technical analysis describes the sources of pollution impacting the community, as well as the location of sensitive receptors within the community. Sources of pollution that are of particular concern to community members are highlighted, and possible strategies for reducing pollution impacts from these sources are evaluated. The strategies that were ultimately selected for implementation in the community are outlined, including incentive funding measures, public engagement strategies, enforcement strategies, regulatory strategies, and strategies that will be completed in partnership with other agencies and local organizations. Finally, an implementation schedule and metrics for tracking emission reductions in annual reporting and at the five-year milestone are discussed in detail.

This draft CERP anticipates investing $44.3 million in emission reduction incentives for cleaner cars and trucks, and a variety of other clean air projects in the South Central Fresno area. Additional measures have been developed to reduce exposure to air pollution for sensitive receptors, including schools and residences. These efforts are projected to achieve approximately 278 tons of PM2.5 reductions and 1662 tons of NOx reductions as well as significant reductions in air toxics emissions in the community, particularly with respect to diesel particulate matter from mobile sources, the main contributor to community air toxics health risk. Additional regulatory and outreach strategies will provide for further reductions and increased awareness of the community’s air quality challenges and the resources available to help the public reduce emissions and avoid exposure to air pollution.

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TABLE OF CONTENTS
Executive Summary.............................................................................................................. 1

1. Introduction ................................................................................................................. 5

1.1 Implementation of AB 617 in South Central Fresno .....................................................................5

1.2 Health Based Air Quality Objectives .............................................................................................7

2. Community Partnerships and Public Engagement .............................................................. 10

2.1 Community Kick-off Meeting .......................................................................................................10

2.2 Community Steering Committee .................................................................................................11

2.3 Community Steering Committee Charter ....................................................................................14

2.4 Community Webpage..................................................................................................................15

2.5 Community Partners ...................................................................................................................16

2.6 Additional Community Engagement............................................................................................17

3. Understanding the Community....................................................................................... 18

3.1 Community Profile.......................................................................................................................18

3.2 Technical Assessment to Understand Community Pollution Impacts.........................................23

3.2.1 Community Emissions Inventory Approach ........................................................................23

3.2.2 Community Emissions Inventory Overview.........................................................................23

3.2.3 Agency Collaborations ........................................................................................................24

3.2.4 Community Emission Inventory Summaries .......................................................................24

3.2.5 Sensitive Receptors and Land Use.....................................................................................31

3.3 Existing Air Quality Programs .....................................................................................................35

4. Strategies to Reduce The Cumulative Exposure Burden in South Central Fresno ..................... 46

4.1 Community Identified Air Quality Priorities..................................................................................46 Heavy Duty Mobile Sources ................................................................................................. 49 Older/High Polluting Passenger Cars ..................................................................................... 61 Residential Burning ............................................................................................................ 65 Agricultural Operations........................................................................................................ 69 Industrial Sources .............................................................................................................. 76 Emissions Exposure Due and Land Use ................................................................................. 87 Solar Deployment in the Community ...................................................................................... 95 Commercial Cooking .......................................................................................................... 98 Dust in the Community ...................................................................................................... 101 Lawn and Garden Equipment ............................................................................................. 105 Public Fleets ................................................................................................................... 108 Exposure Reduction Strategies for Sensitive Receptors ........................................................... 111 Exposure Reduction Strategies for Schools ........................................................................... 113 Indoor Air Quality ............................................................................................................. 116 Urban Greening ............................................................................................................... 118 Vegetative Barriers in South Central Fresno........................................................................... 122 Reducing Automobile Idling Near Sensitive Receptors ............................................................. 125 Community Outreach Strategies.......................................................................................... 127 Additional Regulatory measures to reduce emissions in the community ....................................... 131 BARCT Expedited Schedule.................................................................................................................131 South Central Fresno Community Emissions Reduction Program September 19, 2019 4 | P a g e
Permitting: BACT and T-BACT Determinations....................................................................................137 Facility Risk Reduction Audits-Ab 2588 (Air Toxics Hot Spots Information And Assessment Act)......137 Enforcement Strategies ........................................................................................................................141 Statewide Strategies......................................................................................................... 142 Overview of California Air Resources Board’s Statewide Actions ................................................ 142 Regulatory Programs........................................................................................................................143 Enforcement Programs ....................................................................................................................144 Incentive Programs...........................................................................................................................145 CARB Actions Related to the South Central Fresno Community ....................................................146 Emission Reduction Targets............................................................................................... 152

5. Enforcement Plan ..................................................................................................... 155

5.1 Introduction................................................................................................................................155

5.2 Overview of San Joaquin Valley Air Pollution Control District Enforcement Program..............155

5.3 San Joaquin Valley Air Pollution Control District Enforcement History in South Central Fresno Community............................................................................................................................................160

5.3.1 Response to Public Air Pollution Complaints....................................................................160

5.3.2 District Enforcement Actions .............................................................................................164

5.4 California Air Resources Board Program Overview and Enforcement History in South Central Fresno Community ...............................................................................................................................166

5.4.1 California Air Resources Board Three Year Enforcement History....................................167

5.4.2 Motor Vehicle Fuels...........................................................................................................171

5.4.3 Consumer Products Program Descriptions.......................................................................172

5.4.4 Summary of Complaints Received and Their Resolution .................................................173

5.5 Leveraging Community Involvement in Enforcing Rules to Reduce Air Pollution ....................173

5.6 Enforcement Strategies.............................................................................................................174

5.6.1 District Enforcement Strategies.........................................................................................174

5.6.2 CARB Enforcement Strategies..........................................................................................176

6. Metrics to Track Progress ........................................................................................... 179

6.1 Metrics to Track Progress in Annual Reports ...........................................................................179

6.2 Metrics for Five-Year Milestone Evaluation ..............................................................................180

7. California Environmental Quality Act (CEQA) Project Review ............................................. 186 A. Appendix A: Community Outreach Materials……………………..………………………………………...A-1 B. Appendix B: Steering Committee Charter……………………………………………..…………………….B-1 C. Appendix C: Source Apportionment and Community Inventories…………………….……………….....C-1 D. Appendix D: Public Resource:Existing Control of Sources of Concern………………..………………..D-1 E. Appendix E: Facility Risk Reduction Audits under AB 2588-Facility Reassessment Status….............E.1 F. Appendix F: Enforcement Plan Attachments………………………………………………………........….F-1 G. Appendix G: Health Impacts of Air Pollution………………………………………………………………..G-1 H. Appendix H. Letters Received from Steering Committee Members…………………………………...…H.1 I. Appendix I: Comments and Responses……………………………………………………………………....I-1 South Central Fresno Community Emissions Reduction Program September 19, 2019 5 | P a g e

1. INTRODUCTION

1.1 IMPLEMENTATION OF AB 617 IN SOUTH CENTRAL FRESNO
The implementation of Assembly Bill (AB) 617 (C. Garcia, Chapter 136, Statutes of 2017) has brought additional clean air resources and strategies to Valley communities that are burdened by socioeconomic disadvantages and air pollution, despite significant emissions reductions that have already been achieved regionally. AB 617 provides mechanisms and resources to adopt expedited schedules for the implementation of advanced control technologies for existing stationary source facilities; increased stringency of reporting requirements for stationary sources; to develop and implement community-specific air quality monitoring networks; to implement, and track localized emission reduction programs; to improve availability of data and other technical information; and to invest substantial funding in the community through voluntary incentive funding measures. Resources available through this legislation have allowed the San Joaquin Valley Air Pollution Control District (District), through a comprehensive public outreach and community engagement process, to expand regional programs for community protection and develop a robust plan for reducing local exposure to fine particulate matter and toxic air contaminants in the AB 617-selected community of South Central Fresno.

Several requirements of AB 617 will serve to reduce air pollution in disadvantaged communities throughout the San Joaquin Valley. AB 617 legislation requires districts that are in nonattainment for one or more air pollutants to adopt expedited schedules by January 2019 for the implementation of Best Available Retrofit Control Technology (BARCT). The District Governing Board adopted this schedule at a public hearing held in December 2018, which set the path forward for the District to research and potentially amend applicable rules. The expedited BARCT implementation schedule is discussed in more detail later in this document. Additionally, AB 617 requires "Stationary Sources" to report their criteria pollutant emissions inventory as well as their air toxics emissions inventory to the State on an annual basis. These emissions inventories will be presented in the Uniform Statewide Reporting System, once developed by California Air Resources Board (CARB). Under AB 617, a Stationary Source is defined as facility meeting any one of the following:
 Required to submit Greenhouse Gas emissions under the CH&SC § 38530 (Mandatory GHG Emissions Reporting),
 A facility that is authorized by a permit issued by a district to emit 250 or more tons per year of any nonattainment pollutant or its precursors, or  A facility that receives an elevated prioritization score based on cancer or noncancer health impacts pursuant to Section CH&SC § 44360 (Air Toxics Hot Spots, Chapter 4: Risk Assessment).

The District has worked with closely with CARB, regulated entities, and other stakeholders to implement this new reporting requirement in the Valley. Further information on the implementation of the AB 617 stationary source criteria pollutant emissions inventory reporting requirement is available at:

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https://ww2.arb.ca.gov/news/carb-adopts-uniform-statewide-system-reporting-criteriaair-pollution-emissions-data The District’s initial community identification and prioritization analysis for the first year of AB 617 implementation was based on extensive air quality analysis, numerous health indicators from the state’s CalEnviroScreen model (version 3.0), and various other socioeconomic indicators. In developing San Joaquin Valley community recommendations for additional clean air resources and public engagement under AB 617, the District conducted an extensive public engagement process to seek input from Valley residents, businesses, agencies, and other stakeholders through a variety of public workshops and meetings throughout the Valley.

Based on this extensive public engagement effort and the District’s comprehensive identification and prioritization analysis, South Central Fresno was recommended by the District Governing Board as a first-year community. Located Sources that affect South Central Fresno include freight operations, industry, and freeways. The South Central Fresno community has a high cumulative air pollution exposure burden, a significant number of sensitive receptors, and includes census tracts designated as disadvantaged communities. After further technical review and public engagement, the community of South Central Fresno was ultimately selected by the CARB Governing Board for the development of a community air monitoring plan and an emissions reduction program designed to reduce pollution impacts in the selected community.

In accordance with the community-driven nature of AB 617 directives, in September 2018, the District Governing Board directed staff to immediately convene a community steering committee under a set of guiding principles. The selected Steering Committee is comprised of residents, businesses, non-governmental organizations, and public agencies, acting in an advisory capacity to the District in the development of community air monitoring plans and community emission reduction programs. To ensure successful implementation of AB 617, residents, businesses, non-profits, agencies, and other stakeholders from all sectors within selected communities must be involved in the development of community-specific plans. Towards that end, the District has worked closely with the Community Steering Committees to develop effective strategies, including engaging with Valley residents, businesses, agencies, and other stakeholders to identify and move forward with clean air investments in AB 617 communities.

The South Central Fresno community air monitoring plan was developed with the advice of the community Steering Committee, and deployed beginning in June, 2019. This community-specific air monitoring network provides an expanded monitoring capacity designed to provide scalable, portable, and rapidly deployable air monitoring equipment to the community. This includes a combination of air monitoring platforms equipped with highly specialized analyzers capable of monitoring a full range of criteria and toxic pollutants. Various monitoring platforms include larger air monitoring trailers, mobile air monitoring vans, and compact air monitoring sensors. Monitoring data from these sensors is made available to members of the public in real-time, and can be found at the following location http://community.valleyair.org/selected-communities/south-central- South Central Fresno Community Emissions Reduction Program September 19, 2019 7 | P a g e
fresno/air-monitoring/. The full community air monitoring plan, with further details on selected monitoring equipment and monitoring locations, is available at http://community.valleyair.org/media/1308/fresno_camp_v1_2019_july-1.pdf.

As a culmination of the community-driven actions and engagement called for under AB 617, the District has developed and begun implementation of a Community Emissions Reduction Program, or CERP, in partnership with CARB, residents, affected sources, and local government bodies in the affected community. Steering Committee input and other comments received from the public in the community have provided instrumental information, critical to implementing community-specific measures and addressing community concerns. Strong collaboration between the District, CARB, other local agencies, and community members has resulted in the development of an ambitious plan for reducing localized pollution and associated health impacts in South Central Fresno.

This CERP provides a description of the community of South Central Fresno, including geographical boundaries and socioeconomic factors impacting community residents. A technical analysis describes the sources of pollution impacting the community, as well as the location of sensitive receptors within the community. Sources of pollution that are of particular concern to community members are highlighted, and possible strategies for reducing pollution impacts from these sources are evaluated. The strategies that were ultimately selected for implementation in the community are outlined, including incentive funding measures, public engagement strategies, enforcement strategies, regulatory strategies, and strategies that will be completed in partnership with other agencies and local organizations. Finally, an implementation schedule and metrics for tracking emission reductions in annual reporting and at the five-year milestone are discussed in detail.

1.2 HEALTH BASED AIR QUALITY OBJECTIVES
Community Emission Reduction Programs implemented under AB 617 are designed to reduce emissions of pollutants that have been shown to have adverse impacts on public health, including fine particulate matter and toxic air contaminants. As specified in CARB’s Community Air Protection Program Blueprint, Appendix C (Criteria for Community Emission Reduction Programs), this plan will focus on reducing individual criteria air pollutant and toxic air contaminant emissions to address the impacts of community exposure to multiple pollutants. While each community faces distinct healthbased challenges, CARB guidance states that broad health-based air quality objectives provide a consistent foundation for determining the appropriate levels of emissions reductions for CERPs statewide.

The U.S. Environmental Protection Agency and the State of California have established ambient air quality standards, which set health-protective levels for the following criteria pollutants: ozone, particulate matter with a diameter of 10 microns or smaller (PM10), particulate matter with a diameter of 2.5 microns or smaller (PM2.5), carbon monoxide, nitrogen dioxide, sulfur dioxide, and lead. California also has standards for sulfates, vinyl chloride, and hydrogen sulfide. Due to the implementation of the most stringent South Central Fresno Community Emissions Reduction Program September 19, 2019 8 | P a g e
control measures in the nation for emissions from stationary sources, and an effective incentive program to reduce emissions from sources not under the District’s regulatory authority, the Valley Air Basin is in attainment for many of these standards. However, due to the region’s topography and meteorology, the Valley is classified as Serious nonattainment for the federal PM2.5 standards, and Extreme nonattainment for federal ozone standards.

Particulate Matter: Particulate matter is a mixture of solid particles and liquid droplets in the air. PM can be emitted directly into the atmosphere (primary PM), or can form as secondary particulates in the atmosphere through the photochemical reactions of precursors (when precursors are energized by sunlight). Thus, PM is made up of a number of components, including acids (such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles. PM10 is particulate matter that is 10 microns or less in diameter, and the PM2.5 subset includes smaller particles that are

2.5 microns or less in diameter.

Any particles 10 microns or less are considered respirable, meaning they can be inhaled into the body through the mouth or nose. PM10 can generally pass through the nose and throat and enter the lungs. PM2.5 can be inhaled more deeply into the gas exchange tissues of the lungs, where it can be absorbed into the bloodstream and carried to other parts of the body. The potential health impacts of particle pollution are linked to the size of the particles, with the smaller particles having larger impacts.

Numerous studies link PM2.5 to a variety of health problems, including aggravated asthma, increased respiratory symptoms (irritation of the airways, coughing, difficulty breathing), decreased lung function in children, development of chronic bronchitis, irregular heartbeat, non-fatal heart attacks, increased respiratory and cardiovascular hospitalizations, lung cancer, and premature death. Children, older adults, and individuals with heart or lung diseases are the most likely to be affected by PM2.5.

Many studies have quantified and documented the health benefits of attaining the U.S.

Environmental Protection Agency (EPA) air quality standards for PM. The Valley Air Basin is in attainment of the federal standards for PM10, but is currently classified as Serious nonattainment for the federal PM2.5 standards. The District, in partnership with CARB, recently released the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards, which details strategies to move the region towards attainment of the federal PM2.5 standards. More information is available at: http://valleyair.org/pmplans. This plan is also discussed in further detail in Chapter 3.

Ozone: Ozone is a regional air pollutant that is formed through complex chemical reactions in the atmosphere. In contrast, PM2.5 concentrations are the result of both local and regional emissions, and reducing localized emissions of PM2.5 can reduce disparities in exposure experienced in communities with high cumulative exposure burdens. CARB Office of Community Air Protection guidance states that, because ozone formation is driven by regional rather than localized source contributions, ozone should be addressed in regional air quality improvement efforts through the State Implementation Plan. Therefore, ozone and related precursors have not been South Central Fresno Community Emissions Reduction Program September 19, 2019 9 | P a g e
addressed as a part of this CERP development. The District’s current plan for attainment of health-based ozone standards throughout the San Joaquin Valley Air Basin can be found here: http://valleyair.org/Air_Quality_Plans/Ozone_Plans.htm Toxic air contaminants: Toxic air contaminants (TACs) also contribute to a community’s cumulative exposure burden. Exposure to TACs can increase the risk of acute and chronic health impacts as well as cancer. Diesel particulate matter is a large concern in areas with high exposure to diesel engine emissions, such as the community of South Central Fresno. Other toxic air contaminants can contribute to localized health risks, including metals; air toxics related to fossil fuel production, such as benzene and toluene; and compounds associated with combustion, including polycyclic aromatic hydrocarbons and dioxins. The California Office of Environmental Health Hazard Assessment (OEHHA) establishes threshold concentrations for toxic air contaminants at which exposure is not expected to trigger non-cancer health effects. For carcinogens, OEHHA guidance states that there are no safe exposure thresholds. Reducing emissions in the community will be based on identifying technologies and practices that offer the maximum level of toxic air contaminant emissions reductions achievable to address both types of health effects
With the support of community members, this CERP will build upon regional efforts to improve air quality throughout the Valley Air Basin. The South Central Fresno CERP focuses on reducing emissions of and exposure to PM2.5 and toxic air contaminants from localized sources that contribute to cumulative exposure burdens within the community. Pollution reduction strategies, targets, goals, and metrics included in this CERP have been developed in accordance with these health-based air quality objectives and are presented in more detail in Section 4 of this document.

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2. COMMUNITY PARTNERSHIPS AND PUBLIC ENGAGEMENT
Meaningful community engagement, significant outreach and a robust public process have guided the development of this Community Emissions Reduction Plan (CERP).

Key features of these efforts included hosting a kick-off meeting and conducting initial public outreach; establishing a Community Steering Committee; holding monthly facilitated bilingual meetings; presentations by entities such as the District, local government, CARB, and the City of Fresno; providing materials in multiple languages via email, mail and a webpage; and live-streaming and recording of all Community Steering Committee meetings. In addition, numerous interactions between Community Steering Committee members and District staff occurred in one-on-one or small group meetings allowing for in-depth discussions on joint development of the CERP. See the community webpage (http://community.valleyair.org/selected-communities/southcentral-fresno) for more details.

2.1 COMMUNITY KICK-OFF MEETING
In October 2018, District staff conducted multilingual outreach, worked collaboratively with environmental justice organizations, distributed trilingual flyers (Figure 2-1) to local schools, and invested approximately $3,500 in social media advertisements targeted at the South Central Fresno zip codes to encourage attendance at the official kick-off meeting.

Figure 2-1: Trilingual Community Flyers Distributed
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The Community Kick-Off Meeting in the South Central Fresno Community was held on Thursday, November 1, 2018, at Vang Pao Elementary School (Figure 2-2).

Approximately 70 people attended the meeting. In addition to information about AB 617, attendees were invited to visit booths, which provided information about monitoring technology and District incentive programs. Spanish and Hmong interpretation was provided for the meeting. Community members were encouraged to apply to be on the South Central Fresno Community Steering Committee at the Kick-off meeting, and additional time was given for individuals to apply via email or mail.

Figure 2-2: South Central Fresno Kick-off Meeting

2.2 COMMUNITY STEERING COMMITTEE
Two rounds of Community Steering Committee member solicitation occurred, one prior to the initial Community Steering Committee meeting, and a second after the Community Steering Committee made the decision to expand the community boundaries in March, 2019.

Of the 65 individuals who applied to be on the Community Steering Committee, the final committee consisted of 25 community residents; 25 individuals representing either an environmental justice organization working in the community, a health care organization, an educational entity or a business within the community; and six nonvoting government officials with some of these members having an alternate. A full roster of membership is available in Table 2-1.

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Table 2-1: South Central Fresno Steering Committee Members, and Alternates South Central Fresno Community Emissions Reduction Program September 19, 2019 13 | P a g e
The South Central Community Steering Committee met at least once a month, usually on the second Wednesday of the month at the various locations within the community.

These meetings were initially facilitated by Southwest Strategies (Figure 2-3). With the end of the District’s fiscal year in June, the Institute for Local Government was brought on board to facilitate meetings from August onward.

Figure 2-3: Facilitating a South Central Fresno Steering Committee meeting South Central Fresno Community Emissions Reduction Program September 19, 2019 14 | P a g e
Meals were provided at each meeting, as well as kid’s activities. Real-time English and Spanish interpretation was provided with all members being given headsets and all materials distributed in both languages. High quality video recordings were made by the Community Media Access Collaborative (CMAC) at each meeting and posted to the South Central community website as well as on CMAC public access government television channel. In addition, Facebook was used to Livestream the meetings in realtime for the public to watch, while also providing a video archive of the meetings (Figure 2-4).

Figure 2-4: South Central Fresno Steering Committee Meeting Livestream See Appendix A for full documentation of meeting dates, agendas, attendance, materials and summaries.

2.3 COMMUNITY STEERING COMMITTEE CHARTER
A Charter was developed for the South Central Fresno Community Steering Committee and a draft was presented to the members at Meeting #1, in December, 2018. The Charter and a potential expansion to the community boundary to include the area of Fresno targeted through the Transformative Climate Communities (TCC) program was discussed at several subsequent meetings. Both the charter and the expanded boundary were finalized after Meeting #4, in March, 2019 (see maps on subsequent pages). The final Charter can be found in Appendix B, and at http://community.valleyair.org/selected-communities/south-central-fresno/steeringcommittee-documents/.

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2.4 COMMUNITY WEBPAGE
A community webpage has been created for the South Central Fresno AB 617 community, and is regularly updated with new information (http://community.valleyair.org/selected-communities/south-central-fresno). The webpage includes information about upcoming meetings, meeting materials (flyers, agendas, presentations, handouts, audio and video links, meeting summaries), interactive maps, community steering committee roster and committee charter, membership process, and the Community Air Monitoring Plan (CAMP) and CERP documents. All documents were made available in English and Spanish. A screenshot of the community webpage is shown in Figure 2-5.

Figure 2-5 Community Webpage for South Central Fresno
(http://community.valleyair.org/selected-communities/south-central-fresno) In addition to being a portal for access to meeting materials and documents, the webpage also includes interactive maps that present data about the community (https://sjvapcd.maps.arcgis.com/apps/webappviewer3d/index.html?id=f81aaec7a1b840 4b88072190e92fc48e). Figure 2-6 is an example of an interactive map that was created for the South Central Fresno community. These interactive maps provide data on land use, locations of facilities, schools, hospitals, and the air quality concerns identified by the South Central Fresno Steering Committee and members of the public.

This information was provided to help inform air quality priorities for the CERP.

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Figure 2-6 Interactive map created for South Central Fresno Steering Committee

2.5 COMMUNITY PARTNERS
After the South Central Fresno Community Steering Committee identified priorities for the community, partner agencies and organizations were invited to the meetings to provide updates, input and presentations on current and future efforts. CARB staff attended meetings regularly and provided information to the committee. California Department of Transportation staff presented current and future transportation projects affecting the community (Figure 2-7). The City of Fresno also attended regularly and provided an update on planning efforts in the community and the TCC program.

Coordination with the TCC program will be ongoing.

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Figure 2-7: California Department of Transportation Project Manager presenting to the South Central Fresno Steering Committee

2.6 ADDITIONAL COMMUNITY ENGAGEMENT
Since late 2018, District staff has worked to engage and educate the public with regard to AB 617 and the efforts being made in the South Central Fresno Community, including inviting public comment at each Steering Committee meeting. Staff has met with community members, environmental justice organizations, industry and other stakeholders to provide assistance and/or prompt responses to concerns raised about the AB 617 process. Staff also attended and often made presentations at local civic organizations, city and county government meetings, the District’s Environmental Justice Advisory Group meetings, the District’s Citizens Advisory Committee meetings, the District’s Governing Board meetings, environmental justice meetings, and industry professional group meetings to promote participation in the development and implementation of the CERP. In addition, staff often discussed AB 617 at media interviews and during outreach events and health fairs. A full list of outreach is available in Appendix A.

Staff will continue to work with the South Central Fresno Community Steering Committee to implement the CERP actions after its adoption in September, 2019, by the District Governing Board, and to provide periodic community updates on implementation progress. Community engagement is essential to the success of the CERP as well as the AB 617 program as a whole, and all parties are committed to build and improve upon existing outreach efforts in the coming months and years.

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3. UNDERSTANDING THE COMMUNITY

3.1 COMMUNITY PROFILE
The AB 617-selected community of South Central Fresno is a densely populated community within the City of Fresno, downwind of emissions from the northern portion of Fresno. As shown in Figure 3-1, this community is geographically bounded by McKinley Avenue to the north, Chestnut Avenue to the east, American Avenue to the south, and includes the community of Malaga and its surrounding industrial area to the southeast. The western portion of the boundary ranges from Nielsen and Brawley Avenues in the northwest to Hwy 41 and American Avenue in the southwest, which incorporates residential neighborhoods and industrial areas along Hwy 99 and west of Hwy 41, such as the Industrial Triangle and parts of West Fresno. The South Central Fresno community also includes downtown Fresno, Chinatown, Roeding Park, and encompasses multiple hospitals, schools, small businesses, and densely populated residential areas. The total population in this South Central Fresno community is estimated to be over 150,000.

Figure 3-1: The Community of South Central Fresno
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The city of Fresno is the largest metropolitan area in the San Joaquin Valley, the fifth largest city in California, and is the largest inland city in California. The current estimated population for Fresno is over 530,000. A number of heavily trafficked freeways transverse through the City of Fresno, including highways 99, 41, 180, and 168, contributing a significant amount to the mobile source emissions in the community.

The population in the San Joaquin Valley is expected to be one of the fastest growing regions in the state. The Demographic Research Unit of the Department of Finance released interim revised population growth projections in March 2019 and expects approximately 22% population growth in Fresno County during the 2019 to 2039 period1.

The majority of emissions impacting the South Central Fresno community come from passenger vehicle and heavy-duty truck emissions from major freeways, interchanges, and main regional roads that run through the community. In addition to the emissions originating from mobile sources in the area, this community also includes industrial development and area-wide sources of pollution such as gas stations, commercial cooking, and consumer products that also contribute significantly to the community’s emissions levels. Based on emissions inventory and current air monitoring data in this community, pollutants of concern include particulate matter less than 2.5 micrometers in diameter (PM2.5), Black Carbon (BC), Oxides of Nitrogen (NOx), Carbon Monoxide (CO), Ozone (O3) and Volatile Organic Compounds (VOCs). Refer to the South Central Fresno Community Air Monitoring Plan for further details.

Based on District air quality analysis modeling, the South Central Fresno community was found to have exceeded the 24-hour average PM2.5 concentration prioritization factor levels of 12, 35, 55, and 65 µg/m3 a total of 134, 22, 7, and 4 days, annually, on average during the 2014-2016 period, respectively. In addition, this community was found to have exceeded the 8-hour average ozone concentration prioritization factor levels of 70, 75, and 84 ppb a total of 39, 21, and 5 days, annually, on average during the 2014-2016 period, respectively. Details about the nature and formation of local air pollution and its adverse health impacts on the community of South Central Fresno is summarized in Appendix G.

The South Central Fresno community is impacted across a number of health indicators.

The following table summarizes the average and highest percentile scores (based on statewide comparison) from CalEnviroScreen among the census tracts located with the community boundaries for a number of key indicators. As this summary indicates, the South Central Fresno community includes high average percentiles among its census tracts within the majority of indicators, with many averages exceeding the 90th percentile for the state. Specifically, the average Overall CalEnviroScreen Score and Population Characteristics values are both above the 97th percentile.

1 State Population Projections (2010-2060). Total Population by County (1-year increments). (2018, January) Retrieved from:
http://www.dof.ca.gov/Forecasting/Demographics/Projections/

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3.2 TECHNICAL ASSESSMENT TO UNDERSTAND COMMUNITY

POLLUTION IMPACTS
Conducting a technical assessment is a necessary step in community emissions reduction program development. The technical assessment relies on results from a variety of analyses to characterize emissions in the community and inform community emissions reduction program development and implementation. This assessment will provide the baseline from which emissions reductions can be measured.

The source attribution technical approach established by CARB provides a methodology for assessing, identifying, and estimating the relative contribution of sources or categories of sources, including but not limited to mobile, stationary, and area-wide sources, to elevated exposure to air pollution in impacted communities. The District’s source attribution analysis is based on the following:
 Assesses the share of mobile, area-wide, and stationary source emissions generated in the community,
 Is based on best available data in order to characterize the contribution of emissions sources in the community,
 Follows one of CARB’s recommended source attribution approaches.

Based on the above, the District has implemented CARB’s Community Emissions Inventory Approach. The following section discusses the community emissions inventory approach and summarizes emission sources in the community. A detailed community-level inventory and source apportionment are included in Appendix C.

3.2.1 COMMUNITY EMISSIONS INVENTORY APPROACH
A community level emissions inventory estimates air pollutant emissions from mobile sources (e.g., cars, heavy-duty trucks, locomotives), area-wide sources (e.g., fireplaces, charbroilers, fugitive dust), and stationary sources (e.g., gas stations, auto body shops, manufacturing facilities) within the community.

The community level inventory consists of the mobile, area-wide, and stationary sources spatially allocated in the community. A community emissions inventory is the compilation of criteria pollutant and air toxics emissions data from air pollution sources that are within the community. The community emissions inventory includes emissions of volatile organic compounds / reactive organic gases (VOC/ROG), oxides of nitrogen (NOx), particulate matter of 2.5 microns (PM2.5), and toxic air contaminants (e.g. diesel PM).

3.2.2 COMMUNITY EMISSIONS INVENTORY OVERVIEW
Emissions inventories are estimates of the amount and type of pollutants emitted into the atmosphere by industrial facilities, mobile sources, and area-wide sources.

Additionally, emission inventories are the foundation for any emission reduction program and provide information on the existing air emissions and related air quality in the community, and support development of emission reduction strategies and future emission targets to improve air quality in the community.

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Existing traditional criteria pollutant and air toxics emission inventories (that provide combined coverage of mobile and stationary sources) are generally regional in geographic scale and may not adequately characterize emission impacts at the community-level. Developing community-scale emission inventories for understanding existing baseline emissions and tracking future emission reductions within communities selected for community emission reduction programs and monitoring plans is an important piece of AB 617.

3.2.3 AGENCY COLLABORATIONS
CARB and District staff worked in parallel to develop a comprehensive set of emissions inventory data for the community. The District worked with stationary source facilities in the community to develop the point source emission estimates.

CARB staff developed the community-level emission inventory for mobile and areawide sources. CARB worked with several State and local agencies such as the Department of Transportation (Caltrans), the Department of Motor Vehicles (DMV), the Department of Pesticide Regulation (DPR), and the California Energy Commission (CEC) to assemble activity information necessary to develop the community-level mobile and area-wide source emission estimates. CARB and District staff conducted a thorough review of the community inventory to ensure that the emission estimates reflect the most recent data for stationary sources, and that estimates for mobile and area-wide sources are based on the most recent models and methodologies.

The emissions inventory also includes future forecasted values. The forecasted community-level emissions inventory is based on the growth profiles for stationary sources, mobile, and area-wide source categories provided by CARB. Forecasted emissions include growth and control factors that reflect historical trends, current conditions, and recent economic and demographic forecasts.

3.2.4 COMMUNITY EMISSION INVENTORY SUMMARIES
What types of sources contribute to air pollution in Shafter? Permitted stationary sources in the area include gasoline dispensing operations, manufacturers, and distribution centers. The largest sources of emissions in and around the community include heavy duty vehicles, medium duty vehicles, and passenger cars, as well as trains, truck refrigeration units, and commercial equipment.

Paved road dust, residential fuel combustion, construction emissions, and commercial cooking also contribute significantly to the community’s emissions inventory.

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Figure 3-2: Sources of PM2.5 Pollution in the Community The largest sources of PM2.5 emissions in South Central Fresno are cooking and onroad mobile vehicles. Road dust, off-road equipment, and residential wood burning are also significant sources of PM2.5 in the community.

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Figure 3-3: Sources of NOx Emissions in the Community
The majority of NOx emissions in South Central Fresno are from mobile sources. On road mobile sources account for 59% of NOx emissions in South Central Fresno, including 31.8% of the NOx inventory from heavy duty diesel trucks. Off road mobile sources, including trains, aircraft, and equipment such as yard trucks, produce 25% of the NOx emissions in the community. Fuel combustion at stationary sources is also a significant source of NOx emissions in the community.

PM2.5 Speciation: What type of PM2.5 is in the ambient air? PM2.5 in South Central Fresno is comprised of many species that contribute to the total PM2.5 concentration measured by air monitors, as summarized in Table 3-3 below.

This complex mixture is attributable to stationary, mobile, and area-wide sources described above, as well as naturally occurring emissions. Although the list of species contributing to PM2.5 in South Central Fresno is lengthy, it can be grouped into larger representative categories. The following is a brief description of how each of these larger species categories are formed and emitted into the atmosphere. The following figures show the speciation of PM2.5 in Shafter, based on modeling data.

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ammonium nitrate is generally regarded as having relatively low toxicity compared to other PM2.5 species like elemental carbon.

How will the community inventory change in the future?
The tables and graphs below summarize the total South Central Fresno emissions inventories for years 2017, 2024, and 2029: These graphs show the proportion of PM2.5, NOx, and VOC emissions that originate from stationary, area, and mobile sources of emissions. The projected inventories show how the South Central Fresno community-level inventory is expected to change into the future in years 2024 and 2029.

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Figure 3-9: City of Fresno General Plan Land Use and Circulation Map The location of sensitive receptors is important to assess the impacts of emissions on public health. Sensitive Receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include schools, parks and playgrounds, daycare centers, nursing homes, hospitals, and residential dwelling unit(s). The map below shows sensitive receptor locations within the community. The sensitive receptors currently in the community include 49 schools, 88 licensed daycare facilities, and 17 medical care facilities. Sensitive receptors within the community are located in proximity to manufacturing and industrial sources, train routes, off-road mobile equipment, residential fuel combustion sources, and mobile on-road sources.

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Figure 3-10: Sensitive Receptor Locations in SC Fresno
Where can I get more information about air pollution in South Central Fresno? To provide detailed community-level data to the Steering Committee and the general public, District staff have created an interactive mapping tool that shows the locations of sensitive receptors, as well as the locations of and emissions inventory for stationary sources, area sources, and both on-road and off-road mobile emissions. Examples of the emissions data available through this mapping tool are shown in the figures below.

Please visit the District website to zoom in and explore the community:
https://sjvapcd.maps.arcgis.com/apps/webappviewer3d/index.html?id=f81aaec7a1b840 South Central Fresno Community Emissions Reduction Program September 19, 2019 34 | P a g e
Figure 3-11: District mapping tool showing types and locations of stationary source operations within community
Figure 3-12: District mapping tool showing concentrations of area-wide emissions within the community
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3.3 EXISTING AIR QUALITY PROGRAMS
District Plans for Attainment of Health-Based Air Quality Standards For more than two decades, the District has adopted numerous attainment plans to reduce ozone and particulate precursor emissions. The District’s multifaceted approach to reducing emissions in the San Joaquin Valley consists of a combination of innovative regulatory and non-regulatory measures. The U.S. Environmental Protection Agency (EPA) periodically reviews and establishes health-based national air quality standards (also referred to as NAAQS) for ozone, particulates, and other criteria air pollutants guided by the Clean Air Act. The District has adopted numerous air quality attainment plans over the years that identify measures needed in the Valley to attain EPA’s increasingly stringent health-based NAAQS.

The District’s plans include emissions inventories that identify sources of air pollutants, evaluations for feasibility of implementing potential opportunities to reduce emissions, sophisticated computer modeling to estimate future levels of pollution, and a strategy for how air pollution will be further reduced. District plans also include innovative alternative strategies for accelerating attainment through non-regulatory measures such as incentive programs; technology advancement programs; the District’s legislative platform; community outreach and education programs; and additional strategies such as energy efficiency, eco-driving, green purchasing and contracting, supporting urban heat island mitigation efforts, and encouraging cleaner methods of generating electrical energy and mechanical power.

Measures implemented for these Valley-wide strategies also apply to the AB 617 community of South Central Fresno and have resulted in tremendous emissions reductions being achieved, to the benefit of the health of all Valley residents. Most recently, after an extensive 3-year public process, the District, in coordination with CARB and EPA, adopted the 2018 PM2.5 Plan. This historic plan builds on decades of air quality improvement efforts and establishes a comprehensive strategy for continuing to improve the Valley’s air quality and meet the latest federal PM2.5 standards. Further information on the comprehensive rules, regulations, and other programs that have been developed as a part of the District’s attainment planning process are detailed in the District’s plans for attainment of state and federal air quality standards, with links provided to each attainment plan below:

PM2.5 Plans for Attainment
 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards The District adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards on November 15, 2018. This plan addresses the EPA federal 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.
 2016 Moderate Area Plan for the 2012 PM2.5 Standard
The District adopted the 2016 Moderate Area Plan for the 2012 PM2.5 Standard on September 15, 2016. This plan addresses the EPA federal annual PM2.5 South Central Fresno Community Emissions Reduction Program September 19, 2019 36 | P a g e
standard of 12 µg/m³, established in 2012. This plan includes an attainment impracticability demonstration and request for reclassification of the Valley from Moderate nonattainment to Serious nonattainment.
 2015 Plan for the 1997 PM2.5 Standard
The District adopted the 2015 Plan for the 1997 PM2.5 Standard on April 16, 2015. This plan addresses EPA’s annual PM2.5 standard of 15 µg/m³ and 24- hour PM2.5 standard of 65 µg/m³, established in 1997.
 2012 PM2.5 Plan
The District adopted the 2012 PM2.5 Plan in December, 2012. This plan addresses EPA’s 24-hour PM2.5 standard of 35 µg/m³, which was established by EPA in 2006.
 2008 PM2.5 Plan
The District adopted the 2008 PM2.5 Plan in April, 2008. This plan addresses EPA’s annual PM2.5 standard of 15 µg/m³, which was established by EPA in 1997.

PM10 Plans for Attainment
 2007 PM10 Maintenance Plan
The District adopted the 2007 PM10 Maintenance Plan in September, 2007, to assure the San Joaquin Valley’s continued attainment of EPA’s PM10 standard.

EPA designated the Valley as an attainment/maintenance area for PM10.

Ozone Plans for Attainment
 2016 Plan for the 2008 8-Hour Ozone Standard
The District adopted the 2016 Plan for the 2008 8-Hour Ozone Standard in June 2016. This plan satisfies Clean Air Act requirements and ensures expeditious attainment of the 75 parts per billion 8-hour ozone standard.  2014 RACT SIP
The District adopted the Reasonably Available Control Technology (RACT) Demonstration for the 8-Hour Ozone State Implementation Plan in June, 2014.  2013 Plan for the Revoked 1-Hour Ozone Standard
The District adopted the 2013 Plan for the Revoked 1-Hour Ozone Standard in September, 2013.
 2009 RACT SIP
The District adopted the Reasonably Available Control Technology (RACT) Demonstration for Ozone State Implementation Plans (SIP) in April, 2009.  2007 Ozone Plan
The District adopted the 2007 Ozone Plan in April 2007. This plan addresses South Central Fresno Community Emissions Reduction Program September 19, 2019 37 | P a g e
EPA’s 8-hour ozone standard of 84 parts per billion (ppb), which was established by EPA in 1997.

As a result of the District’s stringent and comprehensive air quality management strategy along with significant investments made by Valley businesses and residents, PM2.5 and ozone levels are now at historically low levels, and the Valley continues to be in attainment of the PM10 NAAQS. Emissions from stationary sources have been reduced by 85%, cancer risk from exposure to air pollutants has been reduced by 95%, population exposure to elevated PM2.5 levels have been reduced by 85%, and population exposure to elevated ozone levels have been reduced by 90%. This success in reducing emissions Valley-wide provides assurance that targeted strategies will provide the desired results in helping to improve the air quality in AB 617 selected communities.

Regulatory Measures
The District has implemented a comprehensive regulatory control strategy for decades.

Since 1992, the District has adopted nearly 650 rules to implement this aggressive control strategy. Many current rules are fourth or fifth generation, meaning that they have been revised and emissions limits have been lowered several times, as new emission control technology has become available and cost effective. Building on decades of developing and implementing active and effective air pollution control strategies, District rules implement the most stringent measures, best available control measures, and best available retrofit control technologies feasible to require in the San Joaquin Valley. The District’s stringent and innovative rules have set benchmarks for other air agencies throughout California and the nation. Regulations implemented by the District have reduced emissions from stationary sources by over 80% to date and will continue to achieve significant emissions reductions in the coming years.

District rules reduce emissions of criteria air pollutants and toxic air contaminants from sources in and around the community. Emission sources in and around the community of South Central Fresno that are regulated by the District include residential wood burning, construction activities, restaurants, agricultural crop production operations, automotive body repair and paint shops, concrete batch plants, cotton ginning, crude oil and natural gas production, drywall manufacturing, fabricated metal products, fire protection facilities, gasoline dispensing operations, government services, health centers, metal fabrication, metal parts coatings, skilled nursing care facilities, soil and groundwater remediation, and telecommunications facilities. District rules that reduce emissions from local sources in the community of South Central Fresno are outlined in the following table:

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While California and the federal government have direct authority to regulate tailpipe emissions from mobile sources, the District has also adopted innovative regulations such as the Indirect Source Review (discussed in more detail later in this section) and Employer-based Trip Reduction rules to reduce emissions from mobile sources within the District’s limited jurisdiction over these sources. A complete listing of the District’s current rules and regulations is available at the following link:
http://www.valleyair.org/rules/1ruleslist.htm
For the recently adopted 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards 2018 PM2.5 Plan, the District performed an exhaustive evaluation of all potential additional opportunities for reducing emissions and committed to amend several rules to achieve expeditious attainment of the health-based federal PM2.5 air quality standards (see Section IV). This comprehensive analysis also demonstrated that the District’s rules and regulations are at least as stringent, or more stringent, than all other rules in the nation. Furthermore, in accordance with AB 617 requirements, the District adopted an expedited schedule in December, 2018, for performing further determination of best available retrofit control technology to ensure that applicable sources are utilizing the cleanest technologies feasible (see Chapter 4).

District New and Modified Stationary Source Review
Beyond District rules that apply to specific categories of stationary sources, District Rule 2201 (New and Modified Stationary Sources Review) applies to all new stationary sources and all modifications to existing stationary sources that are subject to District permit requirements. District Rule 2201, and the associated permitting process, ensure that new or modified stationary sources of air pollution are subject to the most effective emissions controls feasible for implementation; that emissions from the project do not create a public health risk (including a modeled analysis of cancer risks resulting from the project and possible health hazard risks resulting from both acute and chronic exposure to emissions for nearby residences and worksites); and that the project does not increase the potential for a violation of State or National Ambient Air Quality Standards. More information about the District’s rigorous permitting process is available at http://www.valleyair.org/busind/pto/ptoprocess.htm, and is also summarized below.

Under Rule 2201, new facilities or facilities modifying equipment must obtain an Authority to Construct (ATC) permit prior to construction, and are subject to stringent requirements, including:
 Best Available Control Technology (BACT)
 Risk Management Review (RMR)
 Toxic Best Available Control Technology (T-BACT)
 Ambient Air Quality Analysis (AAQA)
Best Available Control Technology (BACT): For each emissions unit (specific piece of equipment) that has the potential to emit over the 2 lb/day BACT threshold, the South Central Fresno Community Emissions Reduction Program September 19, 2019 40 | P a g e
District requires the use of the best available air pollution control technology commonly used to control emissions from similar type of equipment. The District also conducts an analysis to determine if, based on specific criteria, cleaner technologies that are not commonly used for these type of equipment could be used to further reduce emissions from the proposed equipment. This very stringent requirement ensures that the most effective air pollution control technique is utilized resulting in reduced public exposure to air pollutants and toxic air contaminants.

As a part of the District’s BACT Policy (publicly available at https://www.valleyair.org/busind/pto/bact/bactidx.htm), District staff maintain a BACT Clearinghouse, updated and published quarterly, that includes available control technologies and methods that meet one of the following conditions:

A. The control technologies or methods have been achieved in practice for an emissions unit and class of source; or
B. Are contained in any SIP approved by the EPA for an emissions unit category and class of source; or
C. Are any other emission limitation or control technique, including process and equipment changes of basic or control equipment, found to be technologically feasible for such class or category of sources or for a specific source.

AB 617 legislation requires that CARB develop and maintain a state-wide Technology Clearinghouse for BACT and T-BACT. Once available, District staff will review the Technology Clearinghouse as an additional resource when updating the District’s BACT Clearinghouse.

Risk Management Reviews: The District conducts Risk Management Reviews to ensure that the public exposure to toxic air contaminants from projects required to obtain an ATC is less than significant. Very complex computer models and the most conservative assumptions are used to assess the project’s maximum impact on resident’s health. Projects resulting in estimated significant health risk for the public are not approved.

Toxic Best Available Control Technology (T-BACT): When T-BACT is triggered under a Risk Management Review analysis, the District conducts a T-BACT analysis to ensure the most stringent control technique is utilized resulting in reduced public exposure to toxic air contaminants. T-BACT is required for units emitting air toxic emissions that result in a cancer risk of greater than one-in-a-million, and projects that would pose significant impacts to nearby residences or businesses. Projects resulting in estimated significant health risk for the public are not approved.

Ambient Air Quality Analysis (AAQA): The U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) have established National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS), respectively, for numerous pollutants. Under Rule 2201, the District conducts AAQAs to ensure that project related emissions would not cause or make worse a violation of the State or National ambient air quality standard. This South Central Fresno Community Emissions Reduction Program September 19, 2019 41 | P a g e
analysis ensures that the public exposure to certain criteria air pollutants is less than the maximum allowed concentration in outdoor air without harm to public.

AB 2588 (Air Toxics Hot Spots Information and Assessment Act) The District’s implementation of AB 2588, California’s Air Toxics “Hot Spots” Information and Assessment Act, has resulted in dramatic reductions in emissions of air toxics from existing sources in the San Joaquin Valley. Under this right-to-know law, the District has worked with 5,700 Valley facilities to quantify emissions of air toxics, determine the health risk caused by those emissions, report emissions and any significant risks through written public reports and neighborhood public meetings, and take steps to reduce such risks. As a result of these efforts, and the subsequent reductions in air toxics, since 2007 there have been no Valley facilities that pose a significant risk to any Valley resident under the “Hot Spots” program. A detailed discussion of AB 2588 and facility risk reduction audits conducted to date in the community is included in Section IV.

Implementation of State Airborne Toxic Control Measures The District’s integrated air toxics program incorporates Airborne Toxic Control Measure (ATCM) regulations promulgated by the Air Resources Board. State-issued ATCMs are designed to reduce toxic air emissions from various types or categories of equipment by imposing prescribed air pollution control measures. Implementing ATCMs result in reductions of toxics exposure from targeted type or category that could cause significant risks at a regional level. These ATCMs are implemented primarily through the District’s permitting process. Examples of emissions sources that have drastically reduced toxic air contaminant emissions in the San Joaquin Valley because of such rules and regulations include dry cleaners, chrome platers, gas stations, and diesel internal combustion engines.

Implementation of Federal National Emissions Standards for Hazardous Air Pollutants (NESHAPS) and Maximum Achievable Control Technology (MACT) Standards
The District’s integrated air toxics program fulfills federal mandates under Title III of the federal Clean Air Act, which requires specific types of sources of air toxic emissions to directly reduce emissions through NESHAPS and MACT standards. These standards apply to a variety of source categories, ranging from diesel internal combustion engines to chrome platers, and from refineries to power plants.

Implementation of Federal New Source Performance Standards (NSPS) The District also fulfills federal mandates under Title I of the federal Clean Air Act, which requires specific types of new, modified, and reconstructed facilities subject to NSPS to directly reduce emissions of criteria air pollutants. These standards apply to a variety of source categories, ranging from hot mix asphalt facilities to sewage treatment plants, and from landfills to boilers.

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District Indirect Source Requirements
District Rule 9510 is the only rule of its kind in the State of California and throughout the nation which applies to new residential and commercial development projects. The District’s rule is recognized as the benchmark, or best available control, for regulating these indirect sources of emissions, such as from construction equipment and mobile sources associated with new developments. This rule requires mitigation of the growth in emissions from mobile and area sources associated with construction and operation of new development projects in the Valley.

District Air Quality Assistance and Guidance to Public Agencies The District provides assistance and guidance to other public agencies, including cities and counties in the San Joaquin Valley, to help them assess, minimize, and mitigate air quality impacts of projects undergoing their land-use approval processes, over which the District has no statutory authority. For instance, the District provides comments under the California Environmental Quality Act (CEQA) to public agencies on hundreds of proposed projects each year, designed to minimize air quality impacts. In addition, the District maintains and makes available an extensive suite of guidance documents and tools for assessing and mitigating air quality impacts, including criteria and air toxic emissions, from stationary source projects and other development projects.

Mobile Source Regulations
Mobile source emissions make up over 85% of the Valley’s NOx emissions, the primary driver in the formation of particulate and ozone pollution, and therefore reductions in mobile source emissions have become an ever-increasingly important part of the Valley’s attainment strategy of federal air quality standards. States and the federal government, unlike the District, have the authority to directly regulate tailpipe emissions from mobile sources. CARB has adopted tough regulations for heavy-duty trucks, offroad equipment, and other mobile sources. Additionally, the District has adopted innovative regulations such as the Indirect Source Review and Employer-based Trip Reduction rules to reduce emissions from mobile sources within the District’s limited jurisdiction over these sources. Local air districts do not have the authority to implement regulations requiring ultra-low tailpipe emissions standards on mobile sources.

With authority to regulate mobile source emissions, CARB has adopted and amended a number of regulations aimed at reducing exposure to diesel PM and NOx from fuel sources, freight transport sources like heavy-duty diesel trucks, transportation sources like passenger cars and buses, and off-road sources like large construction equipment.

Phased implementation of these regulations will produce emission reduction benefits in the coming years as the regulated fleets are retrofitted, and as older and dirtier fleet units are replaced with newer and cleaner models at an accelerated pace. CARB’s ongoing comprehensive measures to reduce emissions from mobile sources throughout the state are detailed in Chapter 4 in the “Statewide Strategies” section.

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In partnership with community members and other agencies, District staff have developed a suite of targeted measures to reduce emissions from community identified sources of concern. In addition to the emission reductions achieved through expedited implementation of BARCT in community facilities, the adoption or amendment of rules that further reduce PM2.5 and toxics in the Valley, and enhanced enforcement in the community, these local measures provide accelerated emissions reductions in the community.

AB 617 legislation requires that community emission reduction programs identify costeffective measures to achieve emission reduction targets in the community. During Steering Committee discussions to review potential strategies for implementation in the community, Committee members consistently supported and prioritized measures that would reduce emissions from residential sources of emissions while also providing tangible benefits to residents in the community. To that end, in addition to measures to reduce emissions from stationary, area, and mobile sources that are large contributors to the community emissions inventory, many of the measures supported by the Steering Committee and proposed for implementation in the South Central CERP include targeted incentive programs and interagency partnerships that provide co-benefits in the community, in addition to air quality improvements. The measures described in this chapter encompass a range of strategies to reduce community level exposure burden, including regulatory, enforcement, outreach and education, and voluntary incentivebased programs, as well as partnerships with other agencies to address issues outside of the District’s direct jurisdiction.

It should be noted that the identified funding amounts for each measure are designed assuming that future-year state budget appropriations and funding allocations are similar to those approved by the legislature and CARB for current use in the AB 617 program, and are available in future District budget appropriations.

Incentive program guidelines also generally contain strict requirements that include specific project types and funding amounts. To maximize emission reductions in the AB 617-selected community of South Central Fresno, the CERP includes measures that also leverage existing District incentive funding allocations, above and beyond funding amounts available through AB 617-related funding allocations.

Some of the incentive measures included in the CERP are proposed to operate under existing authority and approved program guidelines, while other measures will require the development of new program guidelines and associated approval by the District Governing Board and CARB. As the CARB Blueprint states, CARB and the District will continue developing regulatory and incentive actions through separate public processes. Subsequent implementation of proposed CERP measures will be conditional on the successful completion of applicable public processes, necessary financing approvals, technical feasibility analyses, economic competitiveness, safety, and environmental reviews.

The District will continue to work with the Steering Committee to receive community input as program guidelines are developed and projects are implemented within the South Central Fresno Community Emissions Reduction Program September 19, 2019 48 | P a g e
community. As experience is gained in implementing the measures contained in the CERP, it may become evident that certain measures are more successful than others in reducing emissions and/or exposure, and are more popular with the community.

Committee input on these considerations, and discussions about funding availability and cost-effectiveness of projects, may lead to adjustments to strategy goals and/or funding amounts to achieve overall emission reduction targets of the CERP.

The sections that follow provide detailed information about emission and exposure reduction strategies developed for each source category of concern to the community.

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HEAVY DUTY MOBILE SOURCES

HEAVY DUTY MOBILE SOURCES IN SOUTH CENTRAL FRESNO
There are a variety of heavy-duty mobile sources operating in and around the City of South Central Fresno. These can range from on-road trucks, school and transit buses, off-road equipment including agricultural and construction equipment, line-haul, shorthaul and switcher locomotives. This equipment is primarily powered by diesel engines and, depending on the specific category, is regulated by one or more statewide regulation.

Emissions from this source category include oxides of nitrogen (NOx) and combustion PM from the internal combustion engines. Mobile sources account for more than 85% of the NOx inventory throughout the Valley. In the South Central Fresno community, 595 tons per year of NOx and 15 tons per year of PM2.5 are attributed to on-road heavy-duty equipment. In addition, 300 tons per year of NOx and 7.4 tons of PM2.5 are attributed to off-road heavy-duty equipment referenced in this measure.

Figure 4-1: Examples of Heavy Duty Mobile Sources

COMMUNITY CONCERNS AND COMMENTS
During the committee discussions regarding heavy-duty mobile sources, a majority of the committee ranked this source as a high priority to address. Committee member comments and suggestions included providing incentives to replace older trucks, CNG fueling infrastructure development, clean fleet requirements, shifting trucking routes away from residents, and adjusting work schedules.

CURRENT CONTROL PROGRAMS
The District does not have regulatory authority of emissions from mobile sources, including heavy-duty vehicles and equipment, locomotives, school and transit buses.

Diesel powered on-road heavy-duty vehicles are subject to statewide CARB Truck and Bus Regulation which requires all equipment to get progressively cleaner over time.

Off-road heavy-duty equipment is similarly controlled through the CARB Off-Road Regulation, which requires all fleets to be upgraded to newer, cleaner technologies over time. However, at this time, there are no regulatory requirements in place at the state or federal level controlling emissions from locomotives or heavy-duty agricultural South Central Fresno Community Emissions Reduction Program September 19, 2019 50 | P a g e
equipment including tractors, harvesting equipment and other heavy-duty equipment used in agriculture.

Due to the large amount of pollution that can be attributed to mobile sources, the District has implemented a broad suite of voluntary incentive programs, targeted at reducing emissions from heavy-duty engines operating throughout the Valley.

Heavy-Duty Trucks/Buses:

The District currently offers a variety of programs targeted at replacing or upgrading older, high-polluting trucks and buses with cleaner technology.  The Heavy Duty Truck Replacement Program http://valleyair.org/grants/truckreplacement.htm This program provides incentives for the replacement of existing heavy-duty diesel trucks with new, zero or near-zero-emission technology.  The District is currently developing a Heavy-Duty Truck Repair Pilot Program to provide financial assistance to small fleet truck owners and operators to provide durable repairs for broken emissions components or systems in summer 2019.  The District is currently developing new program for Heavy-Duty Alternative Fuel Infrastructure which will provide local businesses and agencies incentive funding to install alternative fueling infrastructure (electric, natural gas, hydrogen, etc.) to support the increased deployment of heavy-duty advanced clean technology vehicles.
 Electric School Bus Incentive Program - http://valleyair.org/grants/electric-schoolbus.htm This program is operated by the District and provides incentives for the replacement of existing older, higher-polluting school buses with new, electric school buses.
 Volkswagen Mitigation Trust – http://vwbusmoney.valleyair.org/ The VW Mitigation Trust has $130 million in funds to replace older, high-polluting transit, school, and shuttle buses with new battery-electric or fuel-cell buses.

Replacing an older bus with a zero-emission bus eliminates particulate matter and other pollutants that impact children and residents riding the buses, as well as residents throughout California communities. This statewide program is being administered by the District.

Locomotives:

Freight locomotives are regulated by the U.S. EPA. The current regulation requires that all locomotives purchased in or after 2015 be at least a Tier 4 emission level. Older, lower Tier engines, which comprise the majority of Class 1 fleets, are still permitted to run. Additionally, CARB is planning actions to address freight locomotive emissions South Central Fresno Community Emissions Reduction Program September 19, 2019 51 | P a g e
within the State. More details can be found in the 2019 March CARB Board Meeting Informational Update: https://www.arb.ca.gov/board/books/2019/032119/19-3-2pres.pdf The District offers two incentive programs for locomotive fleets interested in transitioning to newer, clean technology, including:
 Heavy-Duty Program – http://valleyair.org/grants/locomotive.htm. Locomotive replacements can be funded as an eligible project category under the District’s utilizing funding provided to support AB 617. These projects are administered according to Carl Moyer Program guidelines and are subject to additional requirements contained within the approved AB 617 Community Air Protection Guidelines. This program is operated by the District.
 Proposition 1B - http://valleyair.org/grants/locomotives-prop1b.htm This program incentivizes the reduction of emissions and health risks associated with freight movement along California’s trade corridors via upgrading to cleaner technologies or installation of emissions capture and control systems.

Agricultural Equipment:

The District offers the following programs targeted at replacing or repowering agricultural equipment in the Valley:
 Heavy-Duty Program Agricultural Tractors -
http://valleyair.org/grants/documents/tractor/Guidelines.pdf Agricultural tractor replacements can be funded as an eligible project category utilizing funding provided to support AB 617. These projects are administered according to the Carl Moyer Program guidelines and are subject to additional requirements contained within the approved AB 617 Community Air Protection Guidelines. This program is operated by the District.
 FARMER Ag Truck Replacement Program -
http://valleyair.org/grants/documents/FARMER/guidelines.pdf This program provides incentive funds for the replacement of heavy-duty diesel agricultural trucks. Eligible agricultural trucks must be in current compliance with the State of California’s On-Road Truck and Bus Regulation. These projects are administered according to the FARMER Program guidelines and this program is operated by the District.
 Low-Dust Nut Harvester Incentive Program - http://valleyair.org/grants/low-dustnut-harvester.htm This program provides incentives for the replacement of older, conventional harvesters or sweepers with new, low-dust technology equipment. This incentive program helps to reduce dust emissions during harvest time, and can also be South Central Fresno Community Emissions Reduction Program September 19, 2019 52 | P a g e
packaged with the District’s Tractor Replacement funding to upgrade tractors used to pull harvesting equipment.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the priority that community members placed on reducing emissions from this source category and the large amount of emissions, including PM2.5 and toxic air contaminants (particularly diesel PM) that originate from heavy duty mobile sources in and around the community, the following strategies have been developed for implementation in the South Central Fresno community.

The following are proposed measures that are within the Air District’s statutory jurisdiction to implement:

HD.1: INCENTIVE PROGRAM FOR HEAVY DUTY TRUCKS REPLACEMENT WITH

ZERO AND NEAR ZERO EMISSION TECHNOLOGY
Overview: The goal of this strategy is to reduce emissions from heavy duty diesel trucks operating in the South Central Fresno community. The District currently offers incentives up to $200,000 for the replacement of an in use diesel truck with cleaner technology, including battery electric, hybrid and near zero emission trucks. Heavy duty diesel trucks are currently subject to the state on-road truck and bus regulation which will require fleet turnover to 2010 emission standard compliant engines. Advances in engine technology have resulted in cleaner engines or battery electric units in some applications. By reducing or eliminating emissions from heavy duty trucks significant PM2.5, diesel particulate matter, and NOx emissions reductions can be achieved.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: This strategy would provide enhanced outreach and access to incentive funding for zero and near-zero emissions clean truck technologies that operate within the community. This strategy would rely on the Board-approved methodology and funding levels currently available in the District’s truck replacement incentive program. This measure would replace 75 older, heavy duty diesel trucks operating in South Central Fresno with zero or near zero emission technology at an expected cost of $7,500,000. The emission reductions associated with this measure would achieve 0.66 tons of PM2.5 diesel particulate matter, and 246 tons of NOx.

HD.2: INCENTIVE PROGRAM FOR THE DEPLOYMENT OF CLEAN YARD TRUCKS,

TRANSPORT REFRIGERATION UNITS, AND RELATED INFRASTRUCTURE Overview: The goal of this strategy is to provide incentives to reduce emissions from diesel powered yard trucks and transport refrigeration units operating at warehouses, South Central Fresno Community Emissions Reduction Program September 19, 2019 53 | P a g e
distribution centers or other facilities within the community by replacing them with a zero emission technology. Yard trucks are used in moving trailers and containers short distances around freight terminals, port facilities or warehouses. Transport refrigeration units powered by diesel engines are designed to refrigerate or heat perishable goods that are transported in various containers. These types of equipment are in near constant operation at impacted facilities, therefore local communities and equipment operators can be exposed to PM2.5 (consisting of diesel particulate matter, a toxic air contaminant) and NOx emissions. Battery powered, zero emission units are currently available for both of these applications.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2020-2024
Description of Proposed Actions: This strategy would provide incentive funding for operators to replace their diesel powered yard trucks or transport refrigeration units with zero emission technology. This strategy would rely on existing Board-approved methodology and established funding levels. The goal of this measure is to deploy 25 new zero emission yard trucks or transportation refrigeration units along with the associated infrastructure at a cost of $3,500,000. Emission reductions associated with this measure would achieve 0.8 tons of PM2.5 in the form of diesel particulate matter, and 4.5 tons of NOx.

HD.3: INCENTIVE PROGRAM TO REDUCE IDLING OF HEAVY DUTY TRUCKS WITHIN THE COMMUNITY: CHARGING INFRASTRUCTURE
Overview: The goal of this strategy is to reduce the impact of emissions from the idling of heavy duty diesel trucks at distribution centers, warehouses, or other freight facilities where trucks are being loaded or unloaded. Providing incentives for electric infrastructure at these facilities would support the deployment of electric transport refrigeration units and other electric equipment at impacted sources. These facilities are located in the community providing an opportunity to reduce emissions that are directly impacting South Central Fresno residents.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2020-2024
Description of Proposed Actions: This strategy would provide incentive funding to install electric charging infrastructure at distribution centers, warehouse, and other types of freight facilities where heavy duty diesel trucks are being loaded or unloaded using Board-approved methodology, where feasible. This measure would reduce emissions from the idling of these vehicles during this activity by providing $100,000 for the South Central Fresno Community Emissions Reduction Program September 19, 2019 54 | P a g e
installation of 33 plugs with an expected emission reduction of 0.17 tons of PM2.5, and

10.33 tons of NOx.

HD.4: SUPPORT PLANNING AND DEVELOPMENT OF CLEAN FUELING

INFRASTRUCTURE
Overview: To provide support for planning and development of fueling infrastructure for zero and near-zero emission vehicles to support broader deployment of clean vehicles operating throughout the community.

Replacing older heavy-duty vehicles, including trucks, school and transit buses is a prevalent strategy throughout this plan. Reducing emissions from heavy-duty vehicles is an important measure to reduce the public’s exposure to vehicle emissions including NOx and PM2.5. These pollutants negatively impact human health, especially for sensitive populations such as children and the elderly. These new zero and near zeroemission vehicle deployments rely on available and accessible fueling infrastructure to ensure successful deployment and use.

The District is currently developing new program for Heavy-Duty Alternative Fuel Infrastructure which will provide local businesses and agencies incentive funding to install alternative fueling infrastructure (electric, natural gas, hydrogen, etc.) to support the increased deployment of heavy-duty advanced clean technology vehicles Implementing Agency: SJVAPCD
Type of Action: Advocacy/Incentives
Implementation: 2021
Description of Proposed Actions: The goal of this action is to work closely with businesses, public agencies and fueling providers to support and incentivize the development of clean-vehicle fueling infrastructure in the area of the community, utilizing Board-approved methodology and funding levels. In this action, the District will prioritize incentive funding to support the development and construction of new natural gas fueling infrastructure within the community. This includes increased outreach to businesses and public agencies operating vehicles within the community as well as prioritized funding for projects that serve vehicles operating in the community.

Depending on the size, throughput and configuration of the fueling infrastructure, the proposed funding amount of $2,000,000 would incentivize the development of two new natural gas fueling stations at a maximum incentive of up to $1,000,000 each.

HD.6: ENHANCED ENFORCEMENT OF THE STATEWIDE ANTI-IDLING

REGULATION
Overview: The goal of this strategy is to limit the potential for localized PM2.5 and toxic air quality impacts associated with the failure to comply with the state’s heavy duty anti- South Central Fresno Community Emissions Reduction Program September 19, 2019 55 | P a g e
idling regulation. Historically, the District has partnered with CARB to conduct anti-idling enforcement throughout Valley communities.

The state’s anti-idling Airborne Toxic Control Measure limits nonessential (or unnecessary) vehicle idling to specific time limits. It is applicable to all diesel-fueled commercial motor vehicles with a gross vehicular weight rating (GVWR) of greater than 10,000 pounds. The diesel exhaust from excessive idling has the potential to impose significant adverse health and environmental impacts. Therefore, efforts to ensure compliance of the anti-idling regulation, especially near sensitive receptors, is important to limiting the potential for localized impacts within the community.

Implementing Agency: SJVAPCD, CARB
Type of Action: Enforcement
Implementation: 2020
Description of Proposed Actions: The District will partner with CARB to conduct additional targeted anti-idling enforcement efforts in the South Central Fresno community at least once per quarter for the next 5 years. The District and CARB will work with the Community Steering Committee to identify heavy-duty vehicle idling “hot spots,” especially those near schools, to aid in focusing the enforcement efforts.

HD.7: INCENTIVE PROGRAM FOR REPLACING OLDER DIESEL SCHOOL BUSES

WITH ZERO OR NEAR ZERO EMISSION SCHOOL BUSES
Overview: To provide increased outreach and access to incentive funding for the replacement of older, high polluting school buses with new zero or near-zero-emission school buses operating within and surrounding South-Central Fresno.

Replacing older school buses is important to reduce children’s exposure to diesel emissions including NOx and PM2.5 and these pollutants negatively impact human health, especially for sensitive populations such as children. New, zero-emission battery electric and near-zero emission natural gas powered school buses are significantly cleaner than older diesel buses.

Emissions from school buses are regulated by the California Air Resources Board Statewide Truck and Bus Regulation that requires transition to cleaner technology over time. Generally phased in by model year.
https://www.arb.ca.gov/msprog/onrdiesel/onrdiesel.htm
The District administers the following incentive programs targeted at reducing emissions from existing school bus fleets with the Valley:
 Electric School Bus Incentive Program –
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http://valleyair.org/grants/electric-school-bus.htm. This program is operated by the District and provides incentives for the replacement of existing older, higher-polluting school buses with new, electric school buses.
 Volkswagen Mitigation Trust – http://vwbusmoney.valleyair.org/ The VW Mitigation Trust has $130 million in funds to replace older, high-polluting transit, school, and shuttle buses with new battery-electric or fuel-cell buses.

Replacing an older bus with a zero-emission bus eliminates particulate matter and other pollutants that impact children and residents riding the buses, as well as residents throughout California communities. This statewide program is being administered by the District.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: The goal of this action is to replace up to 16 school buses, operated by Fresno Unified School District, Fowler Unified School District and/or Central Unified School District with zero-emission battery-electric school buses that operate within the community, utilizing Board-approved methodology. The proposed funding amount of $6,400,000 would cover up to 100% of the cost of replacing up to 16 diesel school buses with electric buses at $400,000 each. Estimated emissions reductions associated with this measure include 8.32 tons of PM2.5 consisting of diesel particulate matter and 20.8 tons of NOx.

HD.9: INCENTIVE PROGRAM FOR REPLACING OLDER DIESEL LOCOMOTIVES

WITH NEW CLEAN-ENGINE TECHNOLOGY
Overview: To provide incentive funding for the replacement of older, high polluting locomotives with new clean-technology locomotives operating within and surrounding South-Central Fresno.

Replacing older locomotives is important to reduce the public’s exposure to diesel emissions, including PM2.5 in the form of diesel particulate and NOx. These pollutants negatively impact human health, especially for sensitive populations such as children and the elderly. New, clean-technology locomotives generate significantly lower emissions than older, uncontrolled diesel locomotives.

The District offers two incentive programs for locomotive fleets interested in transitioning to newer, clean technology, including:
 Heavy-Duty Program – http://valleyair.org/grants/locomotive.htm. Locomotive replacements can be funded as an eligible project category under the District’s utilizing funding provided to support AB 617. These projects are administered South Central Fresno Community Emissions Reduction Program September 19, 2019 57 | P a g e
according to Carl Moyer Program guidelines and are subject to additional requirements contained within the approved AB 617 Community Air Protection Guidelines. This program is operated by the District.
 Proposition 1B - http://valleyair.org/grants/locomotives-prop1b.htm This program incentivizes the reduction of emissions and health risks associated with freight movement along California’s trade corridors via upgrading to cleaner technologies or installation of emissions capture and control systems.  To date, The District has administered nearly $66million to fund the replacement of old, high-polluting locomotive engines with new, tier 4 and CARB verified locomotive engines.
 South Coast APCD is administering the Volkswagen Environmental Mitigation Trust Funding on behalf of the State of California to replace high-polluting locomotive engines throughout California with newer, low-polluting Tier 4, CARB verified locomotive engines. This program will be launching in the fall of 2019. http://www.aqmd.gov/vw/
Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2021
Description of Proposed Actions: The goal of this action is to replace up to two (2) older, high-polluting locomotives operating within the community. The proposed funding amount of $5,200,000 would cover up to 95% of the cost of replacing up to two (2) diesel locomotives at $2,600,000 each utilizing Board-approved methodology. This measure is estimated to achieve 2.8 tons of PM2.5 diesel particulate matter, and 126 tons of NOx emissions reductions.

HD.10: INCENTIVE PROGRAM FOR REPLACING OLDER DIESEL RAILCAR

MOVERS AND SWITCHER LOCOMOTIVES WITH NEW CLEAN-ENGINE

TECHNOLOGY
Overview: To provide incentive funding for the replacement of older, high polluting railcar movers and/or switcher locomotives with new clean-technology railcar movers and/or switcher locomotives operating within and surrounding South-Central Fresno.

Replacing older railcar movers and/or switcher locomotives is important to reduce the public’s exposure to diesel emissions including NOx and PM2.5. These pollutants negatively impact human health, especially for sensitive populations such as children and the elderly. New, clean-technology railcar movers and/or switcher locomotives are significantly cleaner than older uncontrolled diesel railcar movers and/or switcher locomotives.

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The District offers two incentive programs for locomotive fleets interested in transitioning to newer, clean technology, including:
 Heavy-Duty Program – http://valleyair.org/grants/locomotive.htm. Locomotive replacements, including switcher locomotives and railcar movers can be funded as an eligible project category under the District’s utilizing funding provided to support AB 617. These projects are administered according to Carl Moyer Program guidelines and are subject to additional requirements contained within the approved AB 617 Community Air Protection Guidelines. This program is operated by the District.
 Proposition 1B - http://valleyair.org/grants/locomotives-prop1b.htm This program incentivizes the reduction of emissions and health risks associated with freight movement along California’s trade corridors via upgrading to cleaner technologies or installation of emissions capture and control systems.  To date, the District has administered nearly $66 million to fund the replacement of old, high-polluting locomotive engines with new, Tier 4 and CARB verified locomotive engines.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2020-2024
Description of Proposed Actions: The goal of this action is to replace up to three (3) older, high-polluting railcar movers and/or switcher locomotives operating within and surrounding the community. The proposed funding amount of $4,100,000 would cover up to 95% of the cost of replacing up to three (3) diesel railcar movers and/or switcher locomotives at $1,340,875 each, utilizing Board-approved methodology. Estimated emissions reductions associated with this measure include 1.75 tons of PM2.5 consisting of diesel particulate matter and 66.5 tons of NOx.

The following are additional suggested measures not within the Air District’s jurisdiction to directly implement:

HD.11: HEAVY DUTY TRUCK REROUTING
Overview: Some Steering Committee members have suggested that heavy duty trucks be rerouted off of Jensen Avenue to other streets to reduce emissions exposure of South Central Fresno community residents.

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Jurisdictional Issues: It should be noted that the District has no authority over how agencies allow land under their jurisdiction to be used. These so-called “land-use” decisions, such as truck rerouting, are historically the responsibility, under state law, of cities and counties, or, in some cases, state and federal agencies responsible for transportation corridors, state and federal parks, and other properties. AB 617 does not provide the District with new land-use regulatory authority, so land-use authority remains with cities, counties, and state and federal land-use agencies, as discussed in CARB’s Blueprint (see “Who Has the Authority to Implement Actions?”, page 26 of the Blueprint). However, the District has made available to the responsible agencies the various land-use strategies that have been presented by the Committee for potential inclusion into the CERP for responsible agency’s input and response in the South Central Fresno Community Emissions Reduction Program.

Implementing Agency: City, County, Caltrans
Type of Action: Partnership
Timing: Unknown
Description of Proposed Actions: The District will work with the City, County, Caltrans, and all other appropriate land-use and transportation agencies to communicate this Steering Committee suggestion and receive agency feedback and response about this measure for potential inclusion in the CERP. The District has received the following response from the City:
“City will support a detailed study of vehicular trips within the AB617 geographic footprint, to include but not limited to number and type of each vehicle, destination/origin of each vehicular trip, time of day/week analysis, vehicle miles traveled and emissions.

This would then be used to assess current truck routes, evaluate alternatives and calculate the increase/decrease in VMT, GHG, and Air Quality per CEQA. The City would be willing to lead the study if funding is identified. Estimated cost: $500,000+” The District will work with the City of Fresno and other appropriate agencies to seek funding to support this study.

HD.12: PROMOTE THE USE OF BIODIESEL/RENEWABLE DIESEL FUELS Overview: The reduction of emissions from diesel engines has been one of the primary elements in obtaining air quality and greenhouse gas reduction goals within California and throughout the nation. A key element of CARB’s efforts in reducing greenhouse gases has been the Low Carbon Fuel Standard (LCFS), the goal of which is to reduce the carbon intensity of transportation fuels by 20% by 2030. Since the LCFS was implemented in 2011, reductions have predominantly been achieved by introducing more lower-carbon fuels to partially replace conventional fuels for transportation South Central Fresno Community Emissions Reduction Program September 19, 2019 60 | P a g e
applications. In 2018, biodiesel and renewable diesel met 15% of diesel fuel demand in California.2
Biodiesel and renewable diesel have been shown to reduce life-cycle GHG emissions by 40% - 80% as compared to traditional fossil-fuels.3 Both alternative fuels have been shown to reduce PM2.5 emissions, as compared to petroleum diesel. According to CARB, biodiesel and renewable diesel tend to have no impact on NOx emissions when used in newer on-road engines, while in older or off-road engines biodiesel tends to increase NOx and renewable diesel tends to decrease NOx. Biodiesel can be produced from vegetable oils, used cooking oils, and/or rendered animal fats, and is often combined with ultra-low sulfur diesel to be used in fuel blends up to B20 if increased NOx emissions can be mitigated, and up to B5 otherwise. Renewable diesel can be made from the same resources as biodiesel, but uses a different production process that results in a fuel that can be used as a drop-in replacement for petroleum diesel.

One Steering Committee member commented that the use of these alternative fuels can help reduce emissions in the community.

Jurisdictional Issues: It should be noted that oversight of fuel standards is the jurisdiction of the U.S. EPA and CARB. AB 617 does not provide the District with new regulatory authority over fuels programs, as discussed in CARB’s Blueprint (see page 26, “Who Has the Authority to Implement Actions?”). Therefore, the District relies on CARB to research, test, and certify that such fuels achieve the intended emissions reductions.

Implementing Agency: SJVAPCD, CARB
Type of Action: Partnership/Outreach
Implementation: 2020
Description of Proposed Actions: To the extent that biodiesel and renewable diesel fuels are certified by CARB to reduce NOx/PM2.5/GHG emissions, the District will work with local suppliers to promote the use of biodiesel and renewable diesel in the community.

2 Low Carbon Fuel Standard Data Dashboard. “Alternative Fuel Volumes and Credit Generation” https://ww3.arb.ca.gov/fuels/lcfs/dashboard/figure2 053019.xlsx.. 3 Low Carbon Fuel Standard Data Dashboard. “2018 Volume-weighted Average Carbon Intensity by Fuel Type” https://ww3.arb.ca.gov/fuels/lcfs/dashboard/dashboard.htm South Central Fresno Community Emissions Reduction Program September 19, 2019 61 | P a g e

OLDER/HIGH POLLUTING PASSENGER CARS

OLDER/HIGH POLLUTING PASSENGER CARS IN SOUTH CENTRAL FRESNO Mobile source emissions account for over 85% of the overall NOx inventory in the San Joaquin Valley. With no regulatory authority over these sources, the District has relied on voluntary incentive programs to transition older, higher emitting vehicles to newer, cleaner and more fuel efficient models. With limited public transportation options available to residents driving is more prevalent in the Valley than in other areas of the state. Vehicles registered in the Valley are typically older and have higher mileage than statewide averages.

Emissions from light duty vehicles in South Central Fresno total 80.22 tons per year (TPY) of NOx, 94.75 TPY of VOC, and 7.57 TPY PM2.5. These total emissions contribute 10.8% of the NOx inventory, 25.7% of the VOC inventory, and 3.4% of the PM2.5 inventory.

Figure 4-2: The District's Drive Clean in the San Joaquin Repair and Replacement program helps Valley residents purchase new or used clean-air vehicles

COMMUNITY CONCERNS AND COMMENTS
Steering Committee comments regarding passenger vehicles included concerns about the impact of freeways, local arterial roads, and idling vehicles on community residents.

Committee member suggestions to address this source category included increased outreach and incentives for low income residents, modifying program guidelines to allow increased participation, and increasing charging infrastructure in the community.

CURRENT CONTROL PROGRAMS
The District does not have regulatory authority of emissions from mobiles sources, however, due to the large amount of pollution that originates from passenger vehicles the District has implemented a suite of programs to reduce pollution from mobile sources. These programs include the following measures:

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 Tune In Tune Up vehicle repair program which provides incentive funds to repair high emitting vehicles.
http://valleyair.org/drivecleaninthesanjoaquin/repair/
 Vehicle replacement program which provides funding to replace older, high emitting vehicles with newer, cleaner and more fuel efficient models. https://www.valleyair.org/drivecleaninthesanjoaquin/replace/  The vehicle rebate program provides rebates for the purchase or lease of a new clean air vehicle including battery electric, fuel cell, plug in hybrid, zero emission motorcycles, and advanced technology natural gas vehicles. https://www.valleyair.org/drivecleaninthesanjoaquin/rebate/  Incentives are available for publically accessible charging infrastructure through the District’s Charge Up! program
http://valleyair.org/grants/chargeup.htm
 The District’s Healthy Air Living school program promotes no idling while picking up children at school and provides no idling signs to schools to encourage drivers to turn off their engines.
 District Indirect Source Rule (9510) accounts for mobile source emissions from construction and new development projects and ensures that emissions from these activities are mitigated.
 District Employer based Trip Reduction Rule (9410) requires large employers to implement measures to encourage employees to take alternative transportation to work in order to reduce single occupancy vehicle trips.  CARB mobile source strategy calls for increasing the deployment of plug in hybrid, battery electric, and fuel cell vehicles in order to attain federal ozone standards, reduce greenhouse gas emissions, minimize health risks, reduce petroleum usage and increase energy efficiency.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the high priority that community members placed on reducing criteria pollutant and toxic air contaminant emissions that originate from passenger vehicles operating in and around the community, District staff and the Steering Committee have developed targeted strategies for implementation in the South Central Fresno community. As detailed below, measures developed include additional incentive measures intended to increase the deployment of electric vehicles through the replacement of gas powered vehicles currently in use; providing additional charging infrastructure throughout the community; providing for electric vehicle maintenance training to increase available repair facilities and job skills in the community; and repairing high polluting passenger vehicles.

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The following are proposed measures that are within the Air District’s statutory jurisdiction to implement:

C.1: INCENTIVE PROGRAM TO HOST A LOCAL TUNE IN TUNE UP EVENT TO

REDUCE EMISSIONS FROM OLDER, HIGH POLLUTING CARS
Overview: The goal of this strategy is to reduce emissions of high emitting passenger vehicles that may be in need of repair. Reducing emissions from passenger vehicles is important due to their contribution to the formation of ozone in the Valley. Through the District’s Tune In Tune Up Program, financial incentives up to $850 are available for emissions related repairs of high emitting vehicles. Through the program weekend testing events are held to determine if vehicles are in need of emissions related repairs.

Approved participants are provided vouchers which can be utilized for the necessary smog tests, diagnostic work and emissions related repairs at participating STAR certified smog shops.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2020
Description of Proposed Actions: This strategy would provide funding for a Tune In Tune Up event in the community of South Central Fresno and funding for vehicle repairs. This measure would provide up to $850 in vehicle emissions related repairs.

The overall cost of this measure is $1,000,000 which would provide funding for the event related expenses as well as 1,250 vehicle repairs. This measure is expected to achieve 11.6 tons of NOx.

C.2: INCENTIVE PROGRAM FOR THE REPLACEMENT OF PASSENGER VEHICLES

WITH BATTERY ELECTRIC OR PLUG IN HYBRID VEHICLES
Overview: The goal of this strategy is to reduce emissions associated with passenger vehicles operating in the South Central Fresno community. The District’s Drive Clean in the San Joaquin Replacement program provides incentives up to $9,500 to low to moderate income residents of disadvantaged communities to replace their older, high polluting vehicle with a newer, cleaner, model. Emission reductions from passenger vehicles provide benefits to area residents as well as assist in reducing ozone formation in the Valley.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019
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Description of Proposed Actions: This strategy would provide incentive funding to South Central Fresno residents to replace their older vehicles with newer, cleaner and more fuel efficient vehicles including conventional gas powered vehicles, hybrid, plug in hybrid and battery electric vehicles, utilizing Board-approved methodologies for program eligibility and funding. Enhanced outreach would be conducted in the South Central Fresno community to ensure that residents are fully aware of available incentive options and community residents would be provided priority access through the program in order to complete projects as quickly as possible. This measure would provide $1,600,000 for the replacement of 220 vehicles. This measure is expected to achieve

1.98 tons of NOX and 0.07 tons of PM2.5.

C.5: INCENTIVE PROGRAM FOR EDUCATIONAL TRAINING FOR ELECTRIC

VEHICLE MECHANICS
Overview: The goal of this strategy is to provide incentive funding to develop and advance the education of personnel on the mechanics, safe operation and maintenance of alternative fuel vehicles and infrastructure. The District currently offers an alternative fuel mechanic training incentive program that would be utilized for this measure. With a deployment of electric vehicles in the South Central Fresno community it will be necessary to have qualified, trained personnel available to provide service as needed to these vehicles.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2021
Description of Proposed Actions: This strategy would provide up to $75,000 for 5 alternative fuel mechanic training course provided by an appropriate entity. Additional outreach will be conducted to identify projects that would provide a benefit to the South Central Fresno community. There are no direct emission reductions associated with this measure, however, this measure supports the emission reductions associated with electric vehicle deployment.

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RESIDENTIAL BURNING

BACKGROUND
The wood burning fireplaces and wood burning heaters source category includes emissions from wood burning fireplaces, wood burning heaters, and outdoor wood burning devices. This source category contributes 17.6 tons per year of PM2.5 towards area sources of emissions in the community of South Central Fresno, representing

7.8% of the total PM2.5 inventory. During winter, residential wood burning is one of the largest sources of particulate pollution. Given the significant localized health impacts associated with residential wood smoke, reducing emissions from residential wood burning is a high priority for South Central Fresno. Many scientific studies have found that prolonged inhalation of wood smoke contributes to adverse impacts on human health, especially among children, elderly, and people with certain medical conditions, and individuals who are sensitive to the impacts of air pollution. A number of environmental justice communities experience a disproportionately high level of directly emitted PM2.5 emissions from residential wood burning.

COMMUNITY CONCERNS AND COMMENTS
The community of South Central Fresno has provided recommendations to implement the District’s recently adopted amendments to Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) requirements as committed in the 2018 PM2.5 Plan.

Additionally, implementation of enhanced financial incentives for residents to replace existing wood burning devices and pellet stoves with natural gas or electric technologies would reduce the smoke impacts associated with residential wood burning for downwind communities. The South Central Fresno community made recommendations to also have schools and community-based organizations conduct outreach and education in support of this measure.

CURRENT CONTROL PROGRAMS
The District’s comprehensive strategy to reduce emissions from residential wood burning includes implementation of stringent curtailment requirements through Rule 4901, strong outreach and education to establish the necessary public support, and deployment of financial incentives to transition away from wood burning to cleaner alternatives. This approach that combines regulatory and incentive based strategies is designed to improve the public health by reducing toxic wood smoke emissions in Valley neighborhoods during the peak PM2.5 winter season (November through February). The District has continually enhanced the strategy since adopting the first regulation in 1993. Today, the District has the toughest and most effective residential wood burning strategy in the nation as it reduces emissions when and where most needed, such as during multi-day periods of stagnation and in the evening hours, and in neighborhoods where residents live and play.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the high priority that the Steering Committee and members of the public placed on reducing PM2.5 and toxic air contaminant emissions that originate from residential burning in and around the community, targeted measures have been developed to South Central Fresno Community Emissions Reduction Program September 19, 2019 66 | P a g e
reduce emissions from this source category. Building upon the effective implementation of the District’s wood burning emission reduction strategy, the District commits to provide enhanced incentives to replace wood burning devices, increased efforts to educate public about harmful impacts of wood smoke, enhanced enforcement of wood burning curtailments, focused outreach to reduce illegal activity, and enhanced enforcement to reduce illegal burning of residential waste.

The following are proposed measures that are within the Air District’s statutory jurisdiction to implement:

RB.1: INCENTIVE PROGRAM FOR THE REPLACEMENT OF EXISTING WOOD

BURNING DEVICES AND PELLET STOVES WITH NATURAL GAS OR ELECTRIC

TECHNOLOGIES
Overview: The goal of this strategy is to reduce the impact of PM2.5 pollution associated with residential wood burning. During the winter months, one of the largest sources of particulate pollution comes from residential wood burning. Emissions are the result of incomplete combustion and are emitted into Valley neighborhoods where residents live and play. Multiple scientific studies show that prolonged inhalation of wood smoke has adverse impacts on human health. Inhalation of wood smoke contribute to lung disease, and pulmonary arterial hypertension, which can eventually lead to heart failure. Through the District’s Burn Cleaner program, incentives are currently offered to encourage Valley residents to switch to cleaner burning options.

The program currently offers up to $3,000 depending on the income of the resident and the type of device they are purchasing
Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2019-2024
Description of Proposed Actions: This strategy would provide enhanced financial incentives to replace existing wood burning devices and pellet stoves with natural gas or electric technologies utilizing existing Board-approved methodology. Incentives available to South Central Fresno residents would include $3,000 for natural gas devices and $4,000 for an eligible electric heating device. The goal of this measure is to replace 500 wood burning devices in South Central Fresno with natural gas or electric alternatives at an expected cost of $1,500,000. This measure is expected to achieve a total of 246 tons of PM2.5 emissions reductions.

RB.3: ENHANCED ENFORCEMENT OF WOOD-BURNING CURTAILMENTS UNDER DISTRICT RULE 4901
Overview: The goal of this strategy is to limit the potential for localized PM2.5 impacts associated with the failure to comply with mandatory episodic wood burning South Central Fresno Community Emissions Reduction Program September 19, 2019 67 | P a g e
curtailments under District Rule 4901. Currently, to optimize rule effectiveness and reduce the public health impact of wood smoke, the District dedicates extensive staffing resources to operate a robust Rule 4901 enforcement program covering all aspects of the rule. The District’s strategy focuses on both compliance assistance and enforcement activities. On all curtailment days, the District dedicates significant staffing resources to conducting surveillance in neighborhoods and responding to complaints from members of the public to ensure compliance with the rule. The District treats fireplace surveillance and complaint response as the highest priority enforcement activity. On each curtailment day, a substantial number of the District’s inspection staff are assigned to perform surveillance with a focus on areas where non-compliance with the rule has been historically high and/or where public complaints regarding burning have been common. Notwithstanding this focus, the District works to ensure that surveillance is conducted regularly in all areas subject to regulatory curtailments. In addition to the surveillance and complaint response conducted during normal business hours, the District also conducts surveillance and complaint response on weekends, holidays, and during nighttime hours.

Implementing Agency: SJVAPCD
Type of Action: Enforcement
Implementation: 2019-2024
Description of Proposed Actions: Upon implementation of this strategy, District staff will allocate additional resources toward the enforcement of District Rule 4901 episodic curtailment requirements in the South Central Fresno community. Specifically, District staff will conduct at least four (4) hours of surveillance within the South Central Fresno community on each declared curtailment day for the next five (5) winter seasons to enhance the enforcement of District Rule 4901. The District will work with the Community Steering Committee to focus surveillance efforts in areas where wood burning is more prevalent.

RB.4: REDUCE ILLEGAL BURNING THROUGH RESIDENTIAL OPEN BURNING

EDUCATION
Overview: The goal of this strategy is to reduce illegal burning of residential waste through outreach and education. It is important for residents to understand both the unlawfulness of burning garbage and its negative health impacts on all. Smoke from burning trash, yard waste, or burn barrels may contain toxic air contaminants and other pollutants that are especially harmful to human health. Education is critical to effectively reducing this dangerous practice.

Implementing Agency: SJVAPCD
Type of Action: Outreach
Implementation: 2020-2024
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Description of Proposed Actions: This strategy would establish a series of five (5) public workshops to educate South Central Fresno residents about the illegality and health impacts of burning waste, and to address questions and concerns interactively and accessibly within a forum setting. Workshops would take place in locations commonly available to the public such as libraries, schools, and community, health, or recreation centers. This strategy would also invest funds into geo-targeted outdoor ads in areas with frequent violations, including four (4) billboards, three (3) pieces of street furniture (such as bus shelters or kiosks), and two (2) buses routed through relevant locations. Additionally, two (2) postcard mailers would be sent to county residents in rural areas.

RB.5: ENHANCED ENFORCEMENT TO REDUCE ILLEGAL BURNING OF

RESIDENTIAL WASTE
Overview: The goal of this strategy is to limit the potential for localized PM2.5 and toxic impacts associated with the illegal open burning of residential waste.

Pursuant to District rules and state law, the burning of residential waste is illegal in the San Joaquin Valley. Recognizing both the potential for localized exposure and regional air quality impacts associated with the burning of residential waste, the District promptly responds to all complaints regarding illegal burning, conducts regular area surveillance for the purpose of enforcing open burn prohibitions, and works closely with local fire agencies to encourage interdepartmental cooperation and cross-reporting of incidents.

Implementing Agency: SJVAPCD
Type of Action: Enforcement
Implementation: 2020-2024
Description of Proposed Actions: Building on the District’s existing surveillance and complaint response efforts, the District will conduct additional targeted surveillance efforts in the South Central Fresno community at least once per quarter for the next five (5) years. The District will work with the Community Steering Committee to focus surveillance efforts in areas where illegal residential open burning has historically occurred.

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AGRICULTURAL OPERATIONS

AGRICULTURAL OPERATIONS IN SOUTH CENTRAL FRESNO
The San Joaquin Valley’s natural environment supports one of the most productive agricultural regions in the country; the Sierra Nevada provides the necessary water for growing the abundance of crops, and a temperate climate provides a long growing season. While the community of South Central Fresno is primarily an urban area, portions of the community are located at the edge of the urban-rural boundary. The southern portion of the community is currently used for agricultural purposes, but is zoned for development into an industrial area under the City of Fresno’s General Plan.

Agricultural source categories include fuel combustion, industrial processes for the purpose of food and agriculture, farming processes (including dust from harvest and tilling operations, and emissions from off-road mobile sources), pesticides/fertilizers, and managed open burning. While the South Central Fresno community experiences the majority of air pollution emissions from mobile and industrial sources, agricultural sources in the surrounding area contribute a small percentage of the overall emission inventory in this community. Agricultural emissions that originate in and around the community of South Central Fresno include 12 tons per year of NOx, 72 tons per year of VOCs, and 4.81 tons per year of PM2.5. Emissions from agricultural operations represent 0.77% of the total NOx inventory, 2.77% of total VOCs, and 2.13% of the total PM2.5 emitted in the community.

COMMUNITY CONCERNS AND COMMENTS
Community members expressed concerns regarding the adverse health effects resulting from emissions generated from open burning of agricultural waste in the surrounding area, as well as concerns related to dust generated during nut harvesting that may affect community neighborhoods and roads located near orchards.

CURRENT CONTROL PROGRAMS
Current District rules regulating open burning, internal combustion engines, and dust from orchards, vineyards, and row crops are as follows:
 4101 Visible Emissions
 4103 Open Burning
 4550 Conservation Management Practices
 4702 Internal Combustion Engines
Additionally, a variety of incentive programs are available for alternatives to open burning, the replacement of agricultural tractors, trucks, pumps, and nut harvesters or sweepers, as further detailed below.

Open Burning
Through Rule 4103, the District no longer allows the burning of field crops (with the exception of a certain percentage of rice), prunings (with the exception of pome fruit prunings, and a limited amount of surface harvested pruning acreage), and orchard removals (with the exception of small acreage removals, vineyard removals, pome South Central Fresno Community Emissions Reduction Program September 19, 2019 70 | P a g e
fruit removals, and citrus removals). A limited amount of additional burning is allowed for disease prevention, noxious weeds, ditch banks and canals, ponding and levee banks, and diseased beehives, provided rule requirements are met and meteorological conditions are appropriate.

Rule 4103 also contains requirements for collecting, sorting, drying, and igniting agricultural materials; the timing, monitoring, and maintenance of burns; and specific requirements for field crop burning, ditch bank and levee maintenance, contraband materials, Russian thistle (tumbleweeds), and diseased materials. Additionally, the rule details a set of conditions that must be met for a burn permit to be issued.

The District uses a comprehensive Smoke Management System (SMS) to manage the Valley’s remaining open burning of agricultural crops and materials. On a daily basis, the District analyzes projected local meteorology, the air quality conditions, the atmospheric holding capacity, the amount of burning already approved in a given area, and the potential impacts on downwind populations. Through the results of this daily analysis, the District uses the SMS to manage 97 Valley burn zones and allocates daily burning allowances if appropriate. This approach ensures the District limits the distribution of air pollutant emissions from open burning temporally and spatially, providing flexibility of burn days for growers while minimizing the impact on the public.

Properly managed burning allocations under the SMS ensures that air quality impacts, health impacts, and public nuisance from open burning of agricultural materials are minimized to the fullest extent feasible.

Furthermore, the District’s Alternative to Open Ag Burning Incentive Pilot Program provided incentives for chipping or shredding agricultural material, with the materials being required to be used for soil incorporation or land application on agricultural land.

From the program’s launch in late 2018, the program was oversubscribed with a total of $1,644,320 offered to fund chipping and soil incorporation projects. This pilot program resulted in approximately 200 tons of NOx, 241 tons of VOC, and 337 tons of PM emission reductions.

Pesticides
The Department of Pesticide Regulation (DPR) regulates pesticides under a comprehensive program that encompasses enforcement of pesticide use in agricultural and urban environments. DPR oversees a multi-tiered enforcement infrastructure and is vested by the EPA with primary responsibility to enforce federal pesticide laws in California. DPR directs and oversees County Agricultural Commissioner enforcement of pesticide and environmental laws and regulations locally, including enforcement for the Department of Consumer Affairs' Structural Pest Control Board. DPR requires farmers to notify the department before they apply any form of pesticide. Additionally, agricultural operators are subject to strict rules that limit overspray and drift from the approved site of application, and may be subject to fines for violations. Schools near a pesticide application must be notified by DPR to allow the school to take precautions to prevent exposure.

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Agricultural Tractors
Agricultural tractors are not controlled by regulation. However, the District’s Ag Tractor Replacement Program provides incentive funds for the replacement of in-use, off-road mobile equipment that are engaged in agricultural operations as defined by the California Air Resources Board. Funds are provided on a first-come, first-served basis.

Eligible tractor/equipment includes but is not limited to wheel loaders, balers, combines, graders or tractors.

Agricultural Pump Replacement Program
This program provides incentives for engine replacement (repower) of engines/motors used to power agricultural irrigation pumps. The Agricultural Pump Incentive Program provides monetary incentives for the replacement of Tier 3 internal combustion engines (IC engines) to Tier 4f IC engines and Tier 3 or Tier 4f IC engines to electric motors.

Funds are provided on a first-come, first-served basis. District Rule 4702 – Internal Combustion Engines limits the emissions of NOx, CO, VOC, and SOx from IC engines.

Agricultural Trucks
Agricultural trucks are controlled by the California Air Resources Board Statewide Truck and Bus Regulation that requires transition to cleaner technology over time. This regulatory transition is generally phased in by model year.

The Funding Agricultural Replacement Measures (FARMER) Ag Truck Replacement Program provides incentive funds for the replacement of heavy-duty diesel agricultural trucks. Eligible agricultural trucks must be in current compliance with the State of California’s On-Road Truck and Bus Regulation under the following compliance options:
 Agricultural Vehicle Extension
 Low-Use Exemption
 Specialty Agricultural Vehicle Extension
 Model Year Schedule and the truck must operate as an “agricultural vehicle” as defined in the truck and bus regulation.

Dust from Orchards, Vineyards, and Row Crops
The District requires that growers implement conservation management practices to reduce air pollution from agricultural operations. Growers must submit a conservation management plan to the District for approval, as required by District Rule 4550 - Conservation Management Practices. Within this plan, farmers detail specific measures they will be implementing to reduce dust emissions from their facility. District staff regularly conducts site inspections of Valley farms to ensure compliance with rule requirements.

The District has worked closely with representatives from the agricultural community to evaluate new harvesting equipment and practices that can effectively reduce dust from harvest activities. Based on the significant dust emission reductions that low-dust harvesting equipment can provide, the District is offering funding for the replacement of older, conventional nut harvesters or sweepers with new, low-dust technology South Central Fresno Community Emissions Reduction Program September 19, 2019 72 | P a g e
equipment for use in nut harvesting operations. This incentive funding can also be packaged with the Ag Tractor Replacement Program funding to upgrade the tractor used to pull harvesting equipment. This incentive program is currently available to agricultural operations throughout the Valley, including in agricultural areas that may impact community neighborhoods or arterial roads.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
The above Valley-wide control measures continue to reduce emissions from agricultural operations throughout the Valley, including in and around the community of South Central Fresno. Due to the proximity of the South Central Fresno community to areas that are currently used for agricultural operations but that are zoned for future industrial development under the City of Fresno General Plan, members of the Steering Committee expressed concerns about the impacts of emissions from removing orchards and vineyards and disposing of the resulting agricultural biomass. To address these concerns and help to reduce agricultural burning in the area, the following strategy has been developed for implementation as a part of the South Central Fresno CERP.

The following proposed measure is within the Air District’s statutory jurisdiction to implement:

AG.1: INCENTIVE PROGRAM FOR DEPLOYING ON-FIELD ALTERNATIVES TO THE

OPEN BURNING OF AGRICULTURAL MATERIALS
Overview: The goal of this strategy is to limit the potential for localized PM2.5 impacts associated with open agricultural burning by providing enhanced access to funding for the District’s Alternative to Agricultural Open Burning Incentive Program for growers within South Central Fresno and the surrounding areas.

The San Joaquin Valley, in adherence with applicable state laws instituted under SB705 (2003 Florez), has the toughest restrictions on agricultural burning in the state. District regulations no longer allow the burning of all field crops (with the exception of rice), almost all prunings, and almost all orchard removals. The District also operates a comprehensive Smoke Management System which only allows the limited amount of burning that is still permissible to take place on days with favorable meteorology and in amounts that will not cause a significant impact on air quality.

Until 2014, the restrictions imposed by the District resulted in an 80% reduction in the open burning of agricultural waste. The exceptional drought conditions that the Valley recently experienced and the demise of the biomass power industry has resulted in an increase in the open burning of wood waste and threatens the District’s ability to continue to maintain broad restrictions on open burning of agricultural waste into the future.

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mandates, the District is committed to implementing strategies to reduce localized PM2.5 community impacts.

In January of 2019, the District commenced one such strategy, a pilot incentive program to help fund the implementation of on-field practices, such as soil incorporation, that may provide alternatives to open burning of agricultural material from orchard removals.

The purpose of the program was to demonstrate the feasibility of utilizing chipped agricultural material for soil incorporation or as a surface application as alternatives to burning. The cost of these practices can be prohibitive and questions remain regarding the ability to adapt these practices across all agricultural applications, but where feasible analysis shows that on-field soil incorporation of woody biomass has the potential to result in significant emission reductions when compared to open burning of agricultural material. To date, the District’s program has been well subscribed with applications received totaling over $2 million in funding valley-wide.

Implementing Agency: SJVAPCD
Type of Action: Incentives
Implementation: 2020-2024
Description of Proposed Actions: This strategy would provide enhanced access to District’s Alternative to Agricultural Open Burning Incentive Program for growers within South Central Fresno and the surrounding area by providing access to $375,000 in dedicated funding. This strategy would fund up to 700 acres of alternative practices.

The following are additional suggested measures not within the Air District’s statutory jurisdiction to implement:

AG.2: REDUCING EXPOSURE TO PESTICIDES IN THE COMMUNITY
Overview: Specific measures were suggested by Committee members regarding reducing community exposure to pesticides, including banning untarped applications of 1,3-D, reducing the 1,3-D township cap, implementing a notification system to alert residents prior to pesticide applications, banning aerial application of pesticides, and establishing buffer zones where pesticide application is banned near sensitive receptor locations.

Jurisdictional Issue: Under state law, the District has no regulatory authority over pesticides in their pesticidal use. Some advocates have pointed out that a 1996 court case (Harbor Fumigation Inc v. County of San Diego Air Pollution Control District) clarified that air districts do have jurisdiction over emissions of pesticides released into the air after their pesticidal use:
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use of a pesticide is completed and its waste gas emitted into the ambient air from the Facility, then APCD's regulatory jurisdiction … begins.” The District agrees, and has, for decades, regulated facilities that perform fumigation where the pesticide is applied in a room or fumigation chamber, and then released into the air from that chamber. The District does require air pollution control equipment or techniques to reduce pesticide emissions in such situations. Air Districts are allowed to do so by state law because the emissions of pesticides are occurring after their pesticidal use is completed. However, the District does not have jurisdiction in the case of open air application, such as on-field pesticide application, because all potential control of emissions in such situations is also a regulation of the pesticide in its pesticidal use. For instance, pesticide reformulation and limiting pesticide use (whether by amount or by location) is regulating a pesticide in its pesticidal use, and the state’s position is that the District is prohibited by state law from doing so.

Implementing Agency: DPR, CARB
Type of Action: Partnership
Timing: Unknown
Description of Proposed Actions: Through discussions with the District and the Committee, DPR and CARB are committed to including in the CERP actions to address pesticides. DPR submitted a summary of strategies that will reduce exposure to pesticides in the South Central Fresno community, as follows:
“The Department of Pesticide Regulation (DPR) is the public agency responsible for protecting California and its residents from adverse human health and environmental effects caused by the use of pesticides. Its mission is to protect human health and the environment by regulating pesticide sales and use and by fostering reduced-risk pest management. Protecting the air we breathe is one of DPR's highest priorities, focusing not only on preventing health problems that can be caused by pesticide air toxins, but also on reducing pesticide emissions that contribute to air pollution.

The following are some of the statewide emission reduction efforts currently being developed by DPR:

Emission Reductions:
 DPR is currently developing a regulation to reduce exposures to 1,3-D in ambient air.
 DPR is currently working through the legal Pesticide Toxic Air Contaminant (TAC) process with its partner agencies including Office of Environmental Health Hazards Assessment (OEHHA), CARB, Air Districts, and CACs during the development of the regulations.

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Additional Efforts:
 DPR routinely works with local partners to identify and promote use of alternative agricultural practices.
 DPR promotes the adoption and implementation of effective integrated pest management (IPM) systems and practices that reduce risks from pesticide use to human health and the environment in agricultural and non-agricultural settings. To aid in this effort, DPR makes Pest Management Alliance Grants available on a yearly basis in an effort to support the development of methods or practices to reduce pesticide associated risk. DPR is committed to promote and encourage local groups to apply for the Pest Management Alliance Grants.” South Central Fresno Community Emissions Reduction Program September 19, 2019 76 | P a g e

INDUSTRIAL SOURCES

INDUSTRIAL SOURCES IN SOUTH CENTRAL FRESNO
There are a variety of industrial sources located in and around the South Central Fresno Community. These sources range from smaller operations like gasoline dispensing operations (GDOs) and auto body coating operations, to medium sized operations like chrome plating operations, to larger operations like a biomass power facility, a gasoline pipeline terminal facility, and a glass manufacturing plant; which includes equipment like internal combustion (IC) engines, boilers/steam generators, and many others.

Criteria pollutant emissions from this source category include NOx, SOx, PM10/PM2.5, CO, and VOC, and toxic air contaminants (TACs) like benzene, toluene, xylene, arsenic, and dioxins. Within the SC Fresno community, 597.74 tons per year of NOx, 148.48 tons per year of VOC and 72.78 tons per year of PM2.5 are attributed to stationary sources.

COMMUNITY CONCERNS AND COMMENTS
During committee discussions regarding industrial sources, committee members identified chrome plating operations, the biomass facility, and the glass manufacturing plant as a sources to address, with suggestions ranging from providing “incentives” to replace older, higher polluting equipment, to having chrome platers switch from using hexavalent chromium to trivalent chromium, or to install advanced controls that go beyond current regulations.

CURRENT CONTROL PROGRAMS
For more than 25 years, the District has implemented several generations of emissions control regulations for stationary and area sources under its regulatory jurisdiction.

These control measures represent the nation’s toughest air pollution regulations and have greatly contributed to reducing ozone and particulate matter concentrations in the Valley. Stringent and innovative rules, such as those for indirect source review, residential wood burning, glass manufacturing, and agricultural burning, have set benchmarks for California and the nation. While there has been significant progress in reducing air pollution with these regulations, which have been greatly aided by the pollution reduction efforts and financial investments of Valley businesses and residents, the District continues to adopt and modify rules to achieve ongoing emissions reductions and advance our progress toward clean air.

Gasoline Dispensing Operations (GDOs):

Gasoline dispensing operations in the San Joaquin Valley are subject to District Rule 4621 – Gasoline Transfer Into Stationary Storage Containers, Delivery Vessels, and Bulk Plants and Rule 4622 – Gasoline Transfer Into Motor Vehicle Fuel Tanks.

The purpose of Rule 4621 is to limit VOC emissions from stationary storage containers, delivery vessels, and bulk plants. This rule applies to gasoline storage containers with capacities greater than 250 gallons and has requirements to install CARB certified Phase I vapor control systems. The purpose of Rule 4622 is to limit emissions of South Central Fresno Community Emissions Reduction Program September 19, 2019 77 | P a g e
gasoline vapors from the transfer of gasoline into motor vehicle fuel tanks. This rule applies to any gasoline storage and dispensing operation or mobile fueler from which gasoline is transferred into motor vehicle fuel tanks. This rule also requires the installation of CARB certified Phase II vapor control systems. GDOs are subject to stringent enforcement provisions, including ongoing monitoring of equipment and annual inspections.

Auto Body Coating Operations:

Auto body coating operations in the San Joaquin Valley are subject to District Rule 4612 – Motor Vehicle and Mobile Equipment Coating Operations and Rule 4101 – Visible Emissions.

The purpose of Rule 4612 is to limit VOC emissions from coatings of motor vehicles, mobile equipment, and associated parts and components, and associated organic solvent cleaning, storage, and disposal. This rule applies to any person who supplies, sells, offers for sale, manufacturers, or distributes any automotive coating for use within the District, as well as any person who uses, applies, or solicits the use or application of any automotive coating within the District. This rule requires the sale and use of low VOC coatings and solvents, in addition to stringent requirements for the application of these coatings. Auto body coating operations are subject to stringent enforcement provisions, including ongoing recordkeeping of coatings/solvents used and annual inspections. Auto body coating operations must demonstrate continued compliance with additional visible emissions requirements as described in Rule 4101.

Chrome Plating Operations:

Chrome Plating operations in the San Joaquin Valley are subject to District Rule 7011 – Chromium Plating and Chromic Acid Anodizing Facilities and the Air Toxic Control Measure (ATCM) 17 CCR 93102 – Airborne Toxic Control Measure for Chromium Plating and Chromic Acid Anodizing Facilities.

The purpose of Rule 7011 and the ATCM is to limit chromium emissions from chromium plating and chromic acid anodizing facilities. This rule applies to any owner or operator of any facility performing hard chromium electroplating, decorative chromium electroplating, or chromic acid anodizing and any person who sells, supplies, offers for sale, uses, or manufactures for sale in California a chromium electroplating or chromic acid anodizing kit. This rule prohibits the manufacturing, sale, and use of chromium electroplating or chromic acid anodizing kits unless used at a permitted facility that is in compliance with the ATCM. For these permitted facilities, stringent requirements such as the use of add-on controls and/or chemical fume suppressants are required to minimize chromium emissions. Chrome plating operations are subject to stringent enforcement provisions, including inspection and maintenance (I&M) programs, source testing requirements, ongoing recordkeeping and annual inspections.

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Biomass Power Facilities:

Biomass power facilities in the San Joaquin Valley are subject to District Rule 4352 – Solid Fuel Fired Boilers, Steam Generators, and Process Heaters and Rule 4101 – Visible Emissions.

The purpose of Rule 4352 is to limit emissions of NOx and CO from solid fuel fired boilers, steam generators and process heaters. This rule applies to any boiler, steam generator or process heater fired on solid fuel. This rule has very stringent emission limits, periodic monitoring, and source testing requirements. Biomass power facilities are subject to stringent enforcement provisions, including ongoing recordkeeping of materials burned and annual inspections. These facilities must demonstrate continued compliance with additional visible emissions requirements as described in Rule 4101.

Gasoline Pipeline Terminal Facilities:

Gasoline pipeline terminal facilities in the San Joaquin Valley are subject to District Rule 4623 – Storage of Organic Liquids and Rule 4624 – Organic Liquid Loading.

The purpose of Rule 4623 is to limit VOC emissions from the storage of organic liquids.

This rule applies to any tank with a capacity of 1,100 gallons or greater in which any organic liquid is placed, held, or stored. The purpose of Rule 4624 is to limit VOC emissions from the transfer of organic liquids. This rule applies to organic liquid transfer facilities. Facilities that store or transfer organic liquids, such as gasoline pipeline terminals are subject to stringent enforcement provisions, including quarterly leak inspection requirements and annual inspections.

Glass Manufacturing Plants:

Glass manufacturing plants in the San Joaquin Valley are subject to District Rule 4354 – Glass Melting Furnaces.

Rule 4354 is among the most stringent rules in the nation for glass melting furnaces.

The purpose of this rule is to limit NOx, SOx, VOC, CO, and PM emissions from glass melting furnaces. The NOx emission limits contained within Rule 4354 require the installation of the best available NOx technology (such as oxy-fuel firing or SCR systems). Facilities with glass melting furnaces are subject to stringent enforcement provisions, including the installation of continuous emissions monitoring equipment, periodic source testing requirements, ongoing recordkeeping of facility and annual inspections.

The purpose of Rule 4306/4320 is to limit emissions of NOx, CO, oxides of sulfur (SOx), and PM10 from boilers, steam generators, and process heaters. This rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, or process heater with a total rated heat input greater than 5 million Btu per hour. The purpose of Rule 4702 is to limit the emissions of NOx, CO, VOC, and SOx from internal combustion engines.

This rule applies to any internal combustion engine rated at 25 brake horsepower or greater. Both these rules have very stringent emission limits, periodic monitoring, and source testing requirements.

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STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the priority that community members placed on reducing PM2.5 and toxic air contaminant emissions that originate from industrial sources in and around the community, the following strategies have been developed for implementation in the South Central Fresno community.

IS.1: PROVIDE INCENTIVES, WITH REGULATORY BACKSTOP, TO PLATING

OPERATIONS TO FURTHER REDUCE CHROME EMISSIONS
Overview: The goal of this strategy is to provide incentives to Chrome Plating operations to further reduce emissions of chromium, using new state funding guidelines for chrome plating facilities switching to trivalent chrome or controlling emissions beyond existing rule requirement levels, and beyond applicable BACT and BARCT requirements. District Rule 7011 already contains stringent requirements for chrome plating operations. The state identified hexavalent chromium as a Toxic Air Contaminant (TAC) in 1986, and has developed an Air Toxic Control Measure (ATCM) to reduce hexavalent chrome emissions from chrome platers. San Joaquin Valley chrome platers must comply with this ATCM and District Rule 7011, and so have already significantly reduced chrome emissions. However, hexavalent chromium is currently known to be the second most potent carcinogen identified by the state, and so the state is in the process of identifying potential updates to the chrome plating ATCM, which the District will implement upon adoption.

The California Air Resources Board has also identified chrome platers specifically as a category of stationary source that is eligible for incentive funding under AB 617, to achieve reductions in toxic emissions beyond those already required by rules and regulations. This measure takes advantage of that available funding, and seeks to achieve emission reductions even in advance of regulatory updates.

Implementing Agency: SJVAPCD
Type of Action: Incentive, Outreach, and Regulatory
Implementation: 2021
Description of Proposed Actions: The District will discuss the availability of incentives through the CARB Community Air Protection Program guidelines with all chrome plating facilities in the SC Fresno community and fund all willing partners, as feasible. As specified in the CARB funding guidance for this category, facilities willing to convert to the use of trivalent chromium instead of using hexavalent chromium may be funded for up to 90% of eligible costs. Facilities installing advanced control technologies to reduce chromium emissions beyond current rule levels may be funded for up to 80% of eligible costs with a $300,000 cap. This measure will reduce toxic chromium emissions.

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This effort will achieve emission reductions well in advance of any regulatory requirements of the updated state ATCM for chrome platers that CARB is currently developing. However, the District will begin implementing the revised ATCM immediately upon adoption by the state, so that chrome platers that have not taken advantage of the availability of funding will be required to implement the reductions required by the regulation.

IS.4: ENHANCED STATIONARY SOURCE INSPECTION FREQUENCY
Overview: The goal of this strategy is to limit the potential for localized air quality impacts at permitted facilities associated with the failure to comply with emission standards established by District permit, rule, or regulation.

The District conducts inspections and investigations of both permitted sources to determine compliance with a multitude of health-protective local, state, and federal air quality regulations targeting both criteria and toxic pollutants. These include (1) District rules and permit requirements; (2) statewide Airborne Toxic Control Measures; (3) statewide greenhouse gas regulations; and (4) federal New Source Performance Standards, National Emission Standards for Hazardous Air Pollutants, and Maximum Available Control Technology standards. The District closely monitors such sources and strictly enforces applicable requirements. Compliance evaluations are unannounced whenever possible and involve both a physical inspection of the facility and a review of operating and monitoring records. When a violation of a District permit, rule, or regulation is identified, the District takes an appropriate level of enforcement action.

During the review of the enforcement history for the South Central Fresno community and 7-mile buffer area, the District determined that 44 enforcement actions were issued to facilities (not including gas stations) for violations resulting in excess emissions.

These violations occurred at 24 permitted facilities in the area. The District has also issued 18 enforcement actions to gas stations for violations resulting in excess emissions. These violations occurred at 10 gas stations in the area. The District believes that more frequent inspections for these 34 facilities would be prudent to limit the potential for air quality impacts associated with failure to comply with emission standards established by District permit, rule, or regulation.

Implementing Agency: SJVAPCD
Type of Action: Enforcement
Implementation: 2020
Description of Proposed Actions: The District will increase the frequency of inspection at each facility within the South Central Fresno community that has had an emission violation over the past three (3) years. These facilities will be inspected at least twice South Central Fresno Community Emissions Reduction Program September 19, 2019 81 | P a g e
per calendar year for the next five (5) years or until the facility has four (4) consecutive inspections without an emission violation, whichever occurs first.

IS.5: PILOT TRAINING PROGRAM FOR CONDUCTING SELF-INSPECTIONS AT

GAS STATIONS
Overview: The goal of this strategy is to limit the potential for air quality impacts associated with vapor recovery defects at gasoline dispensing stations in the South Central Fresno community.

Gasoline dispensing stations are sources of volatile organic compound (VOC) and toxic emissions such as benzene. Accordingly, District rules require state-certified vapor recovery systems be installed, operated, and maintained in order to achieve at least 95% control of gasoline vapors. District staff inspects gasoline vapor recovery systems on a routine basis to detect equipment defects, such as torn hoses and damaged nozzles, and missing or non-certified parts, to ensure compliance with applicable state and local requirements. Furthermore, District staff routinely witnesses third-party source testing of gasoline vapor recovery systems to verify compliance with applicable leak standards and backpressure requirements. In addition, frequent and thorough selfinspections of vapor recovery systems by the facility operator aids in the identification and timely repair of vapor recovery system defects in the interim between District inspections and reduces the potential for localized impacts from excess emissions associated with equipment defects.

Implementing Agency: SJVAPCD
Type of Action: Compliance Assistance
Implementation: 2020
Description of Proposed Actions: The District will develop a new pilot training program to instruct gas station operators in conducting thorough self-inspections of the vapor recovery systems to aid in the identification and timely repair of vapor recovery system defects. Once developed, the District will provide hands-on training to each of the 52 gas stations in the South Central Fresno community. This training will cover important inspection points such as nozzles, hoses, breakaways, vacuum motors (as applicable), and components associated with storage tanks, and vapor recovery system pressure/vacuum vents. By receiving this training, operators will be better equipped to identify and expeditiously repair any system defects resulting in excess VOC and toxic emissions.

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IS.6: EXPLORE POTENTIAL INCENTIVES TO INSTALL ADVANCED CONTROL

TECHNOLOGY TO ACHIEVE EMISSION REDUCTIONS BEYOND REGULATORY

REQUIREMENTS (BACT AND BARCT)
Overview: The goal of this strategy is to reduce NOx and PM2.5 emissions in the community from stationary source operations through the installation of advanced controls. During the rule development process the District conducts when amending existing rules or adopting new rules; there are times where advanced control technologies are identified that could potentially achieve additional emissions reductions, but are found to be not cost-effective at the time of rule adoption. While the District’s current regulations are some of the most stringent regulations in the nation and have achieved significant emissions reductions, NOx emissions in the Valley must be reduced by an additional 90% in order to attain the latest federal ozone and PM2.5 standards that now encroach on natural background levels, and direct PM2.5 emissions reductions must also be achieved. Therefore, reductions that go beyond these stringent requirements are needed, and the California Air Resources Board is addressing that need by designing an incentive program that can be used to generate additional reductions at stationary sources of pollution. This measure is to work with the Steering Committee to identify stationary sources of concern, and discuss using CARB’s guidance and associated funding to find opportunities to reduce emissions.

Implementing Agency: SJVAPCD, CARB
Type of Action: Incentive, Outreach
Implementation: 2020-2024
Description of Proposed Actions: This strategy would explore potential incentives for stationary sources within the South Central Fresno community to install advanced control technology, beyond existing requirements, including applicable BACT and BARCT requirements that would not otherwise be economically feasible to install. The state is currently developing funding guidance for such projects. The District will work with interested parties, including the Steering Committee, to identify types of facilities and controls not otherwise identified in the CERP and will work with partners to implement these advanced controls. The District will also identify available grant funding to assist implementation (including incentives made available by CARB for such purposes), and will work with the Committee to determine the number and types of projects to be funded, and will quantify emissions reductions as reduction opportunities are finalized.

IS.7: REGULATORY ACTIONS: EVALUATION OF BARCT REQUIREMENTS FOR

RULES THAT APPLY TO CAP AND TRADE FACILITIES
Overview: The goal of this strategy is to evaluate the District’s existing regulations to determine if they meet state requirements for Best Available Retrofit Control Technologies (BARCT), for all rules subject to the state’s greenhouse gas Cap and Trade program, on the expedited schedule approved by the Board in December 2018.

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Further information on the District’s expedited BARCT schedule and rule analyses can be found in the staff report presented to the District Governing Board in December, 2018:
http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2018/December/f inal/13.pdf
IS.8: REGULATORY ACTIONS: EVALUATION OF RULES TO DETERMINE WHETHER ADDITIONAL REDUCTIONS ARE POSSIBLE FOR SOURCES OF NOx and PM2.5
Overview: In addition to the BARCT implementation schedule above, the District will be analyzing and amending eight District rules to pursue additional emission reduction opportunities beyond BARCT. These rule amendments will be reviewed on the schedule included in the District’s 2018 PM2.5 Plan recently adopted by CARB into the State Implementation Plan.

Emissions reductions achieved through the implementation of more stringent limits potentially required through these rule amendments will further contribute to reduced exposure to air pollution in the community. Community Steering Committee members, members of the AB 617-selected community, and the general public are encouraged to be involved in the upcoming rulemaking process for these rules.

Implementing Agency: SJVAPCD
4694 Wine Fermentation and
Storage Tanks Scheduled 2020 2021
4624 Transfer of Organic Liquid Scheduled 2020 2021
4603
Surface Coating of Metal
Parts and Products, Plastic
Parts and Products, and
Pleasure Crafts
Scheduled 2020 2021
4601 Architectural Coatings Scheduled 2020 2021
4401 Steam-Enhanced Crude
Oil Production Wells Scheduled 2021 2022
4566 Organic Material
Composting Operations Scheduled 2021 2022
4625 Wastewater Separators Scheduled 2021 2022
4621
Gasoline Transfer Into
Stationary Storage
Containers, Delivery
Vessels, and Bulk Plant
Scheduled 2021 2022
4402 Crude Oil Production
Sumps Scheduled 2021 2022

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 to determine facility-wide health risks resulting from the emission of toxic air contaminants,
 to notify nearby residents and businesses of significant risk facilities in their vicinity, and
 to require that significant risk facilities reduce their risks to a level that no longer constitutes a significant risk
The District’s implementation of AB 2588, California’s Air Toxics “Hot Spots” Information and Assessment Act, has resulted in major reductions in emissions of air toxics from existing sources in the San Joaquin Valley. Under this right-to-know law, the District has worked with Valley facilities to quantify emissions of air toxics, determine the health risk caused by those emissions, report emissions and any significant risks through written public reports and neighborhood public meetings, and take steps to reduce such risks.

More information about this effort can be found later in this chapter, in the section called, “Additional Regulatory Measures to Reduce Emissions in the Community.” Implementing Agency: SJVAPCD
Type of Action: Regulatory
Implementation: 2019-2021
Description of Proposed Actions: The District has put into effect a plan to expedite the AB 2588 reassessments for facilities located within the AB617 community of South Central Fresno.

Please refer to Appendix E for further details about the District’s Health Risk Assessment Process, and a table identifying the AB 2588 reassessment status of each facility within the community as of September 1, 2019. The District intends to complete this reassessment of facilities within the community by 2021.

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EMISSIONS EXPOSURE AND LAND USE

LAND USE IN THE COMMUNITY
Land use is the characterization of land based on what can be built on it and what the land can be used for. It is important to note that local air districts do not have authority over land use. Land use decisions are directly under the authority of Land use Agencies. The design of development projects in a community significantly influences how people travel. Land use agencies (e.g. City and County government agencies) have jurisdiction over land use, and as such develop land use plans and make decisions about how they grow and expand. Land use agencies typically have principal responsibility for approving development projects within their jurisdictions for a variety of land use types such as residential (single or multi-family, etc.), commercial (fast food, shopping center, retail, etc.), and industrial (warehouse distribution centers, glass manufacturing, etc.). Through the land use approval process, these agencies are responsible for implementing land use strategies that promotes increased walkability, commute alternatives and cleaner transit fleets resulting in air quality benefits within a community.

Land use strategies may result in reduction of number of trips by designing development to be more suitable for walking, bicycling, and transit. These land use strategies are typically outlined as measures and goals within a City or County general plan, which is the primary “long range” planning document used to locate future development and provides the framework within which decisions on how to grow, provide public services and facilities, and protect and enhance the environment are made. For information about the City of Fresno General Plan, please refer to Chapter 3, Understanding the Community. Land use agencies’ decisions are critical in contributing to the improvement in air quality within a community and should be geared towards promoting strategies aimed at reducing VMT by increasing community walkability, implementing commute alternatives and cleaner transit fleets.

The District takes an advisory role working with cities and counties and engages them to use their land use and transportation planning authority to help achieve air quality goals by incorporating as many air quality policies and measures as possible into their general plans, community plans, and specific plans, and to ensure that development occurs in ways that minimize air quality impacts.

COMMUNITY CONCERNS AND COMMENTS
A primary concern expressed by Steering Committee members during meeting discussions was that planned industrial development, specifically distribution centers planned for under the City of Fresno South Industrial Priority Area Specific Plan, will result in increased exposure to emissions for residents that live near heavy duty trucking corridors and major thoroughfares in the community. To address community member concerns, measures included in this section will focus both on strategies to reduce conflicting land uses in the community, as well as transportation strategies that reduce exposure to mobile source emissions resulting from land use decisions.

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For example, a suggestion was to ascertain new truck routes in order to avoid traveling near schools or through the community. Another example is to support the development of charging infrastructure and installing new centralized fueling stations (electric, CNG, clean diesel) for heavy-duty trucks within the industrial areas. Other suggestions included providing low income housing to reduce the need to travel far for work within the community, by providing funds to include sidewalks and bike lanes, cofunding ride-sharing, increasing multi-modal transportation in the community, and strategizing land use planning to minimize or reduce vehicle miles traveled.

As the majority of these suggestions relate to land use issues for which the District does not have land use authority, the District’s approach is to provide support to develop fueling infrastructure for zero and near-zero-emission vehicles, provide incentives for alternative modes of transportation, and support the land use planning process through the California Environmental Quality Act (CEQA). The District is supportive of measures and policies the land use agency can implement toward making the communities more transit-, bicycle-, and pedestrian-friendly, avoid land use conflicts that lead to toxics and nuisance problems, and minimizing the need to and/or mitigate air quality impacts of individual development proposals. In addition, the District has long-standing experience working with the City of Fresno and is already working with the City through providing suggestions and identifying opportunities for minimizing or reducing air quality impacts from proposed projects through the CEQA commenting process. The District plans to further develop its partnership with the City of Fresno and help City’s Planning staff better understand air quality impacts of project proposals and identifying potential measures resulting in air quality benefits in the San Joaquin Valley.

CURRENT CONTROL PROGRAMS
The District has implemented the following rules and programs to reduce emissions from mobile sources and to encourage implementation of measures promoting alternative mode of transportation and increasing walkability within the community.  District Rule 9410 “Employer Based Trip Reduction” requires large employers to implement measures to encourage employees to take alternative transportation to work through the establishment of an Employer Trip Reduction Implementation Plan (eTRIP). An eTRIP is a set of measures that encourages employees to use alternative transportation and ridesharing for their morning and evening commutes. Each measure contributes to a workplace where it is easier for employees to choose to use ridesharing or alternative transportation. Through this rule, single-occupancy vehicle trips are reduced, thus reducing emissions of oxides of nitrogen (NOx), volatile organic compounds (VOC) and particulate matter (PM).
 District Rule 9510 “Indirect Source Review” (ISR) accounts for mobile source emissions from construction and new development projects and ensures that emissions from these activities are mitigated through on site activities or through payment of mitigation fees. The ISR rule reduces NOx and PM10 emissions from mobile and area sources associated with construction and operation of new South Central Fresno Community Emissions Reduction Program September 19, 2019 89 | P a g e
development projects in the Valley. The ISR rule applies to developers of new residential, commercial and industrial projects and to transportation and transit projects whose emissions will exceed certain thresholds contained in the rule.

The ISR rule encourages clean air designs to be incorporated into the development project, or, if insufficient emissions reductions can be achieved through clean air project design features, by paying a fee that will be used to fund off-site emissions reduction projects.
 The District provides incentives up to $50,000 per project for electric vehicle charging infrastructure through the Charge Up Program.
http://valleyair.org/grants/chargeup.htm.
 The District is developing new program for Heavy-Duty Alternative Fuel Infrastructure which will provide local businesses and agencies incentive funding to install alternative fueling infrastructure (electric, natural gas, hydrogen, etc.) to support the increased deployment of heavy-duty advanced clean technology vehicles.
 The District serves as a Commenting Agency under CEQA in providing technical expertise in characterizing project related impacts on air quality when reviewing projects of various land uses (i.e., residential, commercial, and industrial). CEQA is a state statute that requires state and local agencies to identify the significant environmental impacts of their discretionary decisions and to require the avoidance or mitigation of those impacts, if feasible. Typically, the Lead Agency, such as the local city or county, will submit to the District a request for air quality related comments for a specific project. The District then assesses the project’s potential impact on air quality and prepares a letter (commenting letter) that identifies the project, its impact on air quality, recommended feasible mitigation measures to be incorporated, and District rules and regulations that may apply.

The commenting letter is then provided to the Lead Agency.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN THE COMMUNITY Several strategies have been identified under this Land Use and Transportation section that span from advocating issues, providing incentives, collaborating with the local land use agency, i.e. City and County, to providing input through the land use process. Land use and transportation strategies developed to reduce emissions due to conflicting land uses are further detailed below.

The following are proposed measures that are within the Air District’s statutory jurisdiction to implement:

LU.1: SUPPORT PROJECTS THAT REDUCE VEHICLE MILES TRAVELED Overview: The purpose of this strategy is to reduce vehicle miles traveled (VMT) in the community through measures that promote active transport and increase the walkability of community neighborhoods.

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Mobile source emissions make up over 85% of the Valley’s NOx emissions, the primary driver in the formation of ozone and particulate matter pollution, and therefore reductions in mobile source emissions have become an ever-increasingly critical part of the Valley’s attainment strategy of federal air quality standards.

It is important to note that mobile source “tailpipe” emissions are within the responsibility and jurisdiction of the California Air Resources Board, and local air districts do not have the authority to adopt and implement regulations requiring ultra-low tailpipe emissions standards on mobile sources. The State and the federal government, unlike the District, have the authority to directly regulate tailpipe emissions from mobile sources. New state and federal regulations coupled with a robust incentive-based emission reduction strategy are necessary to reduce emission reductions and community residents’ exposure to air pollutants. The California Air Resources Board has adopted tough regulations for heavy-duty trucks, off-road equipment, and other mobile sources.

In the meantime, the District has been innovative in creating rules to reduce air quality impacts from these sources. In particular, the District has adopted regulations such as the Indirect Source Review and Employer based Trip Reduction rules to reduce emissions from mobile sources within the District’s limited jurisdiction over these sources.

The District Rule 9510 “Indirect Source Review” (ISR) is the only rule of its kind in the State of California and throughout the nation, which applies to new development projects. The Districts rule is recognized as a benchmark, or best available control, for regulating indirect source emissions with the purpose of reducing the growth in emissions from mobile and area sources associated with construction and operation of new development project in the Valley. The District encourages emissions to be reduced through project design elements resulting in air quality benefits.

The District Rule 9410 “Employer Based Trip Reduction” requires larger employers to establish trip reduction programs. These programs are designed to encourage employees to reduce single-occupancy vehicle trips, thus reducing emissions associated with work commutes.

Land use decisions are critical in contributing to the improvement in air quality within a community and should be geared towards promoting strategies aimed at reducing VMT by increasing community walkability, implementing commute alternatives and cleaner transit fleets. Examples of such measures are listed below:
 Bicycle infrastructure
 Infrastructure to support alternative modes of transportation (electrical vehicles, near-zero emissions vehicles, etc.)
 Satellite offices/telecommuting centers to reduce the length of employee commute trips or eliminate such trip
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 Implement measures promoting the use of fuels that are less polluting than gasoline or diesel, for example:
o Replacing diesel fleet with alternative fuel engine technology and infrastructure
o Retrofitting existing equipment to reduce emissions using methods such as particulate filters, oxidation catalysts, or other approved technologies o Repowering/Retrofitting heavy-duty diesel fleet with cleaner diesel engine technology and/or diesel particulate filter after-treatment technology o Replacing diesel fleet vehicles with cleaner fueled low emission vehicles (i.e. school buses, buses, on- and off- road heavy duty vehicles, lighter duty trucks and passenger vehicles).

Implementing Agency: SJVAPCD
Type of Action: Partnership
Implementation: 2019-2024
Description of Proposed Actions: Provide District support for projects that reduce VMT, including advocacy for competitive project proposals and potential match funding support to eligible projects, as appropriate, through existing District programs (i.e. bicycle path infrastructure, electric vehicle charging infrastructure, vanpooling and ridesharing). Under this strategy, the District is proposing to partner with City of Fresno to identify opportunities, such as District CEQA commenting process, District’s guidelines for general plans, District’s published Air Quality Mitigation Strategies, committee/public participation in city planning and General Plan development efforts, etc., to expand understanding of air quality impacts of proposals and potential air quality benefits of alternatives.

LU.2: PROVIDE ASSISTANCE DURING THE CALIFORNIA ENVIRONMENTAL

QUALITY ACT PROCESS
Overview: The purpose of this strategy is to provide assistance during the California Environmental Quality Act (CEQA) process with guidance to land use agencies, project proponents, and the public on how the project may impact air quality in the San Joaquin Valley, and information on how air pollution impacts can be reduced.

CEQA is a state statute that requires public agencies such as state and local agencies to identify the significant potential environmental impacts of a proposed project and to avoid or mitigate such impacts, if feasible. A public agency must comply with CEQA when it undertakes an activity defined by CEQA as a "project”. A project is an activity undertaken by a public agency or a private activity which must receive some discretionary approval (meaning that the agency has the authority to deny the requested permit or approval) from a government agency which may cause either a direct physical change in the environment or a reasonably foreseeable indirect change in the environment.

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Land use decisions are critical to improving air quality within the San Joaquin Valley Air Basin because land use patterns greatly influence transportation needs while motor vehicle emissions are the largest source of air pollution in the San Joaquin Valley. It is important to note that local air districts do not have authority over land use. Land use decisions are directly under the authority of Land use Agencies. The design of development projects in a community significantly influences how people travel. Land use agencies (e.g. City and County government agencies) have jurisdiction over land use, and as such develop land use plans and make decisions about how they grow and expand. Even though the District does not have land use authority, however, as a public agency the District takes an active role in the intergovernmental review process under CEQA. Providing District assistance during the CEQA process allows land use agencies and project proponents to enhance project design by identifying feasible mitigation measures in the early stages of the planning process for a better overall project with minimized impact on air quality.

In carrying out its duties under CEQA, the District may act as a Lead Agency, a Responsible Agency, or a Trustee/“Commenting” Agency. The role the District under CEQA is dependent upon the extent of the District’s discretionary approval power over the project. The District is typically not the Lead Agency for proposed new projects because project approval is generally required by other public agencies with broader authority, such as land use agencies. A Lead Agency is the public agency with the broadest authority for approving or carrying out the project and therefore has the principal responsibility for carrying out or approving a project subject to CEQA. Lead Agencies are responsible for complying with CEQA by ensuring that all potential environmental impacts of proposed projects are adequately assessed, and environmental damage is avoided or minimized where feasible.

The District is more often a Responsible Agency or a “Trustee Agency” (more commonly known as a “Commenting Agency”). A Responsible Agency is a public agency, other than the Lead Agency, that has responsibility for carrying out or approving a project subject to CEQA. While a Lead Agency must consider all of the potential impacts of a project, a Responsible Agency may only consider those aspects that are within the agency’s area of expertise or which are required to be carried out or approved by the agency. A “Commenting Agency”, is an agency that has “jurisdiction by law” over a particular natural resource but does not have discretionary approval power over the project. In this role, the District is advising Land use Agencies and provides technical expertise in characterizing project related impacts on air quality when reviewing projects of various land uses (i.e., residential, commercial, and industrial). In addition to reviewing a project’s impact on air quality, the District may review and comment on other sections of the environmental document that relate to air quality impacts, for example traffic and health risks. As such, when serving as a Commenting Agency, the District may provide the Lead Agency with comments on the adequacy of the air quality analysis, identify District rules, which apply to the project, and recommend potential mitigation measures for the Lead Agency’s consideration.

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The air quality considerations that warrant particular attention during early consultation between Lead Agencies and project proponents include consistency with applicable District rules and permit requirements, and incorporation of all feasible measures to reduce a project’s impact on air quality. Addressing issues in relation to land use and project design while a proposed project is still in the planning stages provides project proponents opportunities to incorporate project design features to minimize the impact on air quality.

Implementing Agency: SJVAPCD, City, County
Type of Action: Land use, Partnership
Implementation: 2019
Description of Proposed Actions: The District will work with the City and County on active CEQA coordination with the land use agencies and project proponents for proposed projects within the South Fresno Community. This strategy will result in enhancing project designs in the early stages of the planning process for a better overall project with minimized impact on air quality and early identification of feasible mitigation measures.

City of Fresno has committed to include the Air District in the City’s pre-application process, which may include written comments and/or attendance at Development Review Committee (DRC) meetings for projects that will result in construction within the AB 617 area. Under this partnership, this process will offer an opportunity to the District to discuss the proposed project with the applicant(s) including (if project description has sufficient detail) potential impacts on air quality, on-site clean-air project design elements, and feasible mitigation measures in advance of final decision making and prior to formal application acceptance.

LU.3: PROVIDE EDUCATION AND OUTREACH ON AVAILABLE TOOLS FOR

PUBLIC INFORMATION REGARDING LAND USE PROJECTS
Overview: The purpose of this strategy is to increase awareness about publically available tools and documents through the City of Fresno’s website, and to train community members on how to access and use these tools. FAASTER, for example, is a tool developed by the City of Fresno to provide valuable information about public works project and planning decisions throughout the city including within the South Central Fresno community, and can be found here:
https://lmsaca.fresno.gov/CitizenAccess/.

For land use, FAASTER can provide any public member information on entitlement applications regarding project status, overview and location. Any interested person can search by applicant, project name, parcel number or address to see what is happening in a certain location, and receive notifications as the project review process develops.

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Implementing Agency: SJVAPCD, City of Fresno
Type of Action: Land use, Partnership
Implementation: 2019
Description of Proposed Actions: The District will work with the City to hold a public workshop in the South Central Fresno community to inform the public of the available tools, including FAASTER, and train community members on how to access and use these tools.

The District will continue to look for other opportunities for measures to include in the final CERP to work with the City of Fresno to address community concerns about providing additional transparency to permitting and CEQA processes, including ensuring required air quality mitigation occurs.

LU.4: COLLABORATING TO ENHANCE COMMUNITY PARTICIPATION IN LAND

USE PROCESSES
Overview: While the District and the City of Fresno have committed to extensive interagency cooperation and action in this South Central Fresno Community Emission Reduction Program, additional opportunities may present themselves in future discussions involving the Community Steering Committee, the public, the City, the County, and the District, especially as implementation of the CERP progresses.

This measure is the District’s commitment to continue to assist in facilitating discussions between the community and land-use agencies in the area to identify additional opportunities to address community concerns regarding land-use and air quality.

Implementing Entities: District, City of Fresno, Fresno County Type of Action: Partnership
Implementation: 2019
Description of Proposed Actions: The District will assist in facilitating further discussions with the community and land use agencies (City/County) to identify additional opportunities to address community concerns and questions regarding landuse and air quality. Some areas of future discussion may include, but are not limited to:
 Ensuring more comprehensive opportunities for public input on land-use decisions
 Providing additional public access and education regarding permitting and CEQA processes
 Better communicating and understanding air quality impacts and potential mitigation
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SOLAR DEPLOYMENT IN THE COMMUNITY

BACKGROUND
The State of California has aggressively pursued renewable energy. It is the policy of the state that renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045. The State has also directed state agencies to undertake various studies to identify and assess:
 Barriers to, and opportunities for, solar photovoltaic energy generation.  Barriers to, and opportunities for, access to other renewable energy by lowincome customers.  Barriers to contracting opportunities for local small businesses in disadvantaged communities.

As an outcome of the state’s aggressive renewable and zero-carbon electricity requirements and the state’s desire to make renewable power more accessible to lowincome and disadvantaged communities a number of programs have been developed to make solar photovoltaic systems more accessible in South Central Fresno.

COMMUNITY CONCERNS AND COMMENTS
The South Central Fresno Steering Committee has identified residential solar photovoltaic installation as a strategy to reduce emissions and reduce the cost of energy in the community.

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Based on community interest in residential solar PV systems, the District will be partnering with other entities with solar funding programs to assist the community in accessing those programs. As further detailed below, these programs include the following:
 DAC-Single Family Solar Homes (DAC-SASH) program
 Solar on Multifamily Affordable Housing (SOMAH) program  DAC-Green Tariff (DAC-GT) program
 Community Solar Green Tariff (CSGT) program
The following is a suggested measure not within the Air District’s jurisdiction to directly implement:

SD.1: INCENTIVE PROGRAM FOR INSTALLING SOLAR IN THE COMMUNITY Overview: The goal of this strategy is to increase the amount of solar photovoltaic (PV) systems installed in the community by connecting community members with programs that provide financial incentives for the installation of solar photovoltaic (PV) systems. A variety of programs are available to provide incentives for the installation of PV systems or for preferred rates for green energy in the community.

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Jurisdictional Issues: It should be noted that oversight of energy usage, including implementation of community energy efficiency programs, is the jurisdiction of the California Public Utilities Commission, the public utilities, cities, and counties. AB 617 does not provide the District with new regulatory authority over energy programs, as discussed in CARB’s Blueprint (see “Who Has the Authority to Implement Actions?”, page 26 of the Blueprint). However, the District will make available to the responsible agencies the below strategy, as suggested by the Committee for potential inclusion into the CERP, for input and response in the South Central Fresno Community Emissions Reduction Program.

Implementing Entities: California Public Utilities Commission, Pacific Gas and Electric Company, GRID Alternatives, SOMAH Nonprofit Administrative Partnership (SNAP) Type of Action: Partnership
Implementation: 2019-2024
Description of Proposed Actions: The District will help to coordinate meetings with entities that offer incentives for solar photovoltaic (PV) installation and other green energy programs that have the potential to reduce utility rates in the community. The following is a summary of programs that can benefit the community:

DAC-Single Family Solar Homes (DAC-SASH) program provides assistance in the form of up-front financial incentives for the installation of rooftop solar generating systems for income-qualified owners of single family homes in disadvantaged communities. The program is administered by GRID Alternatives and has an annual budget of $10 million from 2019 through 2030.

Solar on Multifamily Affordable Housing (SOMAH) program provides financial incentives for installing solar photovoltaic (PV) energy systems on multifamily affordable housing in disadvantaged communities (DAC). The program has $100 million annually and has a goal of installing 300 megawatts of generating capacity by 2030. The program is administered by the SOMAH Nonprofit Administrative Partnership (SNAP).

DAC-Green Tariff (DAC-GT) program procures 100 percent renewable energy on behalf of customers while providing them a 20 percent discount on their otherwise applicable utility rate. The 20 percent discount can be applied as a discount to CARE rates. The DAC-GT program will begin in 2020 and will be run through the utility company (Pacific Gas and Electric).

Community Solar Green Tariff (CSGT) is similar to the DAC-GT program in that it procures 100 percent renewable energy on behalf of the customers while providing a 20 percent rate reductions. However, under this program the projects providing the solar energy must be sited within a top 25 percent DAC and the subscribers must reside within a top 25 percent DAC and live within 5 miles of South Central Fresno Community Emissions Reduction Program September 19, 2019 97 | P a g e
the solar project. The program is approved to serve up to 41 megawatts of power and serve 6,800 customers. In order to enroll in the program communities must contact their utility (Pacific Gas and Electric).

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COMMERCIAL COOKING

COMMERCIAL COOKING OPERATIONS IN FRESNO
Commercial cooking represents emissions from the various methods of cooking at restaurants. This includes charbroiling, deep-fat frying, and other cooking such as clamshell or flat griddles. The emissions are from the cooking process exclusively, such as from fat drippings hitting hot radiant surfaces in a charbroiler, and excludes emissions from the heat sources. The locations of restaurants in the South Central Fresno community are shown in the figure below.

Figure 4-3: Commercial Cooking Operations in South Central Fresno Community In the Valley, the primary pollutant of concern from commercial cooking is PM2.5, but there are also emissions of VOCs and toxics. In this category, 76% of the PM2.5 comes from charbroiling, which is divided between chain-driven charbroilers and underfired charbroilers. Between these two categories, underfired charbroiling represents 89% of PM2.5 emitted.

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Commercial cooking emissions that originate in the community of Fresno include 11 tons per year of VOCs, and 70 tons per year of PM2.5. The commercial cooking category represents 31% of the total PM2.5 emitted in the community, 6% of the formaldehyde, and 2% of the cadmium.

COMMUNITY CONCERNS AND COMMENTS
Although few members indicated this as a priority category, commenters from the Community Steering Committee were concerned that incentives would be insufficient for this category and called for a strong regulatory approach. In combination with the regulatory requirements, further discussed below, that will be developed through a public process as a part of the 2018 PM2.5 Plan implementation, the District included a targeted incentive and outreach program for implementation in the community due to the large percentage of emissions that commercial cooking represent in the community, and the high risk of local exposure to carcinogenic air toxics (including heterocyclic amines and polycyclic aromatic hydrocarbons) from charbroiling operations.

CURRENT CONTROL PROGRAMS
In 2002, the District adopted Rule 4692 (Commercial Charbroiling) requiring emission controls on the most used chain-driven charbroilers in the valley, reducing emissions from those devices 84%. In 2009, the District amended the rule requiring controls on additional chain-driven charbroilers further reducing those emissions by 25%. These stringent controls have reduced the impact of chain-driven charbroilers to only 11% of commercial charbroiling emissions.

The remaining 89% of commercial charbroiling emissions are from underfired charbroilers. The dilution of emissions from these types of charbroilers resulting from the hood and ventilation systems make the types of controls that work for chain-driven units inappropriate for underfired units. To identify potential technologies that could work, and demonstrate them in actual Valley restaurants the District has developed the Restaurant Charbroiler Technology Partnership. Information learned from this program, as well as information from other installations of control equipment throughout the state and country was considered in the District’s 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. That analysis led to a commitment to amend Rule 4692 to achieve additional emission reductions from commercial underfired charbroilers. In addition to the regulatory commitment, the District committed to expanding its incentive program fund the installation of controls for commercial underfired charbroilers within urban boundaries in hot-spot areas of Fresno, Kern, and Madera counties, with a future year regulatory requirements to encourage participation by Valley businesses.

STRATEGY DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
A combination of incentive funding, with enhanced outreach, combined with a future regulatory requirement will seek to install emissions control equipment to reduce PM2.5 emissions from restaurants using underfired charbroilers.

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The following is a proposed measure that is within the Air District’s statutory jurisdiction to implement:

CC.1: INCENTIVE PROGRAM FOR INSTALLING ADVANCED EMISSIONS CONTROL

EQUIPMENT ON UNDERFIRED CHARBROILERS
Overview: The goal of this strategy is reduce PM2.5 emissions from underfired charbroilers. The District has been very successful in reducing emissions from commercial charbroiling by requiring controls on chain-driven charbroilers.

Unfortunately, the same types of controls won’t work for underfired units, and other more expensive technologies must be employed to achieve similar results. These new technologies have not been widely achieved in practice, and many remaining questions regarding their technological feasibility must still be addressed. The District’s Restaurant Charbroiler Technology Partnership program has had some success installing equipment to reduce PM2.5 emissions from underfired charbroilers, and helped identify some technologies that are very promising to address this source category.

Implementing Agency: SJVAPCD
Type of Action: Incentives (with regulatory backstop)
Implementation: 2020-2024
Description of Proposed Actions: This strategy would provide $150,000 in incentive funding per restaurant for the installation of control equipment to reduce particulate emission from underfired charbroilers, and to provide enhanced outreach and education to local restaurants regarding health impacts and availability of funding for installation of controls. Proposed funding amount of $1,200,000 would cover up to 100% of the cost of installing emissions control equipment. Emission reductions will be calculated at a later time.

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DUST IN THE COMMUNITY

BACKGROUND
In the South Central Fresno community, there are 546 miles of roads, including 60 freeway miles, 207 arterial roads, and 279 local roads. Source of emissions from roads include deposits of vehicle exhausts and industrial exhausts, particles from tire and brake wear, dust from paved roads or potholes, and dust from construction, open areas, and other earthmoving activities.

Paved road dust emissions in the community total 34.16 tons per year, or 21% of the total PM2.5 emissions in the community. Construction, demolition and other earthmoving activities emit 12 tons per year of PM2.5, or 7.5% of the total PM2.5 inventory in the community. Unpaved road dust and dust from open areas also have minor PM2.5 emissions in the area, totaling approximately 1% of the community PM2.5 emissions inventory.

COMMUNITY CONCERNS AND COMMENTS
The Community Steering Committee expressed an interest in evaluating air quality impacts and feasibility of increasing frequency of street sweeping along freeways and streets. Community members also wanted to identify opportunities to reduce dust from paved and unpaved roads in the community through road paving improvements.

CURRENT CONTROL PROGRAMS
Regulation VIII (Fugitive PM10 Prohibition) / Dust Control Plan (DCP): The District’s Regulation VIII series (Fugitive PM10 Prohibitions) was adopted in November 2001, and subsequently amended in 2004. This rule series contains a comprehensive suite of rules designed to reduce fugitive PM10 emissions from a range of sources including:
 Specified outdoor fugitive dust sources.
 Construction or demolition related disturbances of soil, including land clearing, grubbing, scraping, excavation, extraction, land leveling, grading, cut and fill operations, travel on the site, travel access roads to and from the site, and demolition activities.
 Outside storage and handling of any unpackaged material, which emits or has the potential to emit dust when stored or handled.
 Prevention and cleanup of mud and dirt whenever it is deposited (carryout and trackout) onto public paved roads
 Open areas 0.5 acres or more within urban areas, or 3.0 acres or more within rural areas that contain at least 1,000 square feet of disturbed surface area.  Any paved, unpaved, or modified public or private road, street highway, freeway, alley way, access drive, access easement, or driveway.
 Unpaved vehicle/equipment areas, including parking, fueling, service, shipping, receiving, and transfer areas.
 “Off-field” agricultural sources including, but not limited to, unpaved roads, unpaved vehicle/equipment traffic areas, and bulk materials.

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The Regulation VIII rules are implemented via the District’s Dust Control Plan (DCP) program: https://www.valleyair.org/busind/comply/PM10/compliance_PM10.htm

STRATEGIES DEVELOPED FOR IMPLEMENTATION IN COMMUNITY
Due to the high priority that the Steering Committee placed on reducing dust in the community, specific measures have been developed to target emissions reductions from fugitive dust sources. The District is proposing increased enforcement of Regulation VIII rules to reduce fugitive dust from construction and earthmoving activities within the community. Additionally, the District will partner with other entities to identify opportunities to increase street sweeping efforts in the community and to increase road paving improvements in the community.

The following proposed measure is within the Air District’s statutory jurisdiction to implement:

FD.1: ENHANCED ENFORCEMENT OF DISTRICT REGULATION VIII FUGITIVE

DUST REQUIREMENTS
Overview: The goal of this strategy is to limit the potential for localized air quality impacts associated with fugitive dust from construction/earthmoving activities and open areas subject to District Regulation VIII.

District rules limit fugitive dust emissions from construction, demolition, and earthmoving; bulk material storage; open areas; and unpaved roads and vehicle/equipment traffic areas. Furthermore, District rules restrict carryout and trackout onto paved public roadways.

In order to facilitate enforcement of fugitive dust prohibitions, a Construction Notification or Dust Control Plan is required for all construction activities in the District involving one or more acre of disturbed surface area. District staff reviews each Construction Notification and Dust Control Plan prior to the start of construction, to ensure that operators have planned to utilize required work practices to mitigate fugitive dust emissions. Furthermore, District staff regularly surveys and inspects such sites, responds to all complaints regarding fugitive dust, and provides training classes for those wishing to submit Dust Control Plans.

In reviewing the compliance history for the South Central Fresno community, it was determined that the District had received 34 complaints regarding fugitive dust related issues, with the majority pertaining to construction/earthmoving activities and open areas. With a number of large projects in the area, the District felt it prudent to add an enforcement strategy to the CERP to ensure continued compliance with fugitive dust regulation in the South Central Fresno community.

Implementing Agency: SJVAPCD
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Type of Action: Enforcement
Implementation: 2020
Description of Proposed Actions: Building on the District’s existing surveillance and complaint response efforts, the District will conduct at least one targeted enforcement effort within the South Central Fresno community during both the 2nd and 3rd quarters for the next five (5) years.

The following suggested measures are not within the Air District’s jurisdiction to directly implement:

FD.2: STREET SWEEPING
Overview: The goal of this strategy is to identify opportunities to reduce dust from paved and unpaved roads in the community through increased frequency of street sweeping.

The District currently regulates fugitive dust emissions from a range of sources with a series of rules known as Regulation VIII. Rule 8061 (Paved and Unpaved Roads) establishes standards for the construction of new and modified paved roads in accordance with published guidelines by the American Association of State Highway and Transportation Officials for road construction and applies to any paved, unpaved, or modified public or private road, street highway, freeway, alley way, access drive, access easement, or driveway. Rule 8061 also establishes thresholds that when exceeded require that roads are treated to reduce visible dust emissions. In addition, Rule 8061 has requirements for PM10 efficient street sweepers to be used at least once per month on streets with paved curbs which have been determined to have the greatest actual or potential for dirt or silt loadings.

In the City of Fresno, the street sweeping schedule is:
 Residential areas are swept once every month.
 Arterial streets are swept once per week and at night.  Major streets are swept once per week during the evenings and weekends.  Downtown is swept three times per week at nights and weekends.

Some areas within the community of South Central Fresno are not within Fresno city limits. These areas are maintained by the County of Fresno.

Jurisdictional Issues: It should be noted that the District has no authority over how agencies allow land under their jurisdiction to be used. These so-called “land-use” decisions, such as whether and how often to require street sweeping, are historically the responsibility, under state law, of cities and counties, or, in some cases, state and federal agencies responsible for transportation corridors, state and federal parks, and other properties. AB 617 does not provide the District with new land-use regulatory authority, so land-use authority remains with cities, counties, and state and federal landuse agencies, as discussed in CARB’s Blueprint (see “Who Has the Authority to South Central Fresno Community Emissions Reduction Program September 19, 2019 104 | P a g e
Implement Actions?”, page 26 of the Blueprint). However, the District has made available to the responsible agencies the various land-use strategies that have been presented by the Committee for potential inclusion into the CERP for responsible agency’s input and response in the South Central Fresno Community Emissions Reduction Program.

Implementing Agency: Cities and Counties
Type of Action: Partnership
Implementation: 2020
Description of Proposed Actions: The District, through partnerships with other entities (including City of Fresno, Fresno County, and Fresno Council of Governments), will work to identify opportunities to identify street sweeping efforts in the community.

FD.3: ROAD PAVING IMPROVEMENTS
Overview: The goal of this strategy is to identify opportunities to reduce dust from paved and unpaved roads in the community through road paving improvements. The District currently regulates fugitive dust emissions from a range of sources with a series of rules known as Regulation VIII. Rule 8061 (Paved and Unpaved Roads) establishes standards for the construction of new and modified paved roads in accordance with published guidelines by the American Association of State Highway and Transportation Officials for road construction and applies to any paved, unpaved, or modified public or private road, street highway, freeway, alley way, access drive, access easement, or driveway. Rule 8061 also establishes thresholds that when exceeded require that roads are treated to reduce visible dust emissions.

Implementing Agency: Cities and Counties
Type of Action: Partnership
Implementation: Immediately upon identifying opportunities for agency coordination Description of Proposed Actions: The District will partner with the City of Fresno and Fresno County to notify them as grant funding opportunities for road paving, road resurfacing, and sidewalk improvements become available. The District will provide support to the City and County in grant applications through letters of support and technical support, as requested.

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LAWN AND GARDEN EQUIPMENT

LAWN AND GARDEN EQUIPMENT IN SOUTH CENTRAL FRESNO
Small off-road engines (SORE) which are typically utilized in gas powered lawn and garden equipment emit oil-based particulates, PM2.5, NOx, and a mixture of hydrocarbons, which combine with other gases to form ozone, carbon monoxide and other toxic air contaminants. This equipment can also cause a significant amount of fugitive dust and can increase fugitive emissions including PM, toxic air contaminants, and ultrafine particles resulting in negative health impacts for the user.