Exhibit M - Environmental Assessment No. T-6432P23-02268 P23-02269 P23-03234 [08-07-2025] — Fresno City Council, October 16, 2025 (part 1 of 4)

Exhibit M
El05 (0000 life

CITY OF FRESNO

NOTICE OF INTENT TO ADOPT A

MITIGATED NEGATIVE DECLARATION
F L ED
APPLICANT:

AUG 07 2025 TIME
2:16Pn

B LRESP
DEPUTYPROJECT LOCATION:

APN(s): 463-140-01,-02,-03, & -04
The full Initial Study is on file in the Planning and Development Department, Fresno City Hall, 3 rd Floor, Room 3043, 2600 Fresno Street, Fresno, CA 93721.

Site Latitude: 360 44’27.08” N
Site Longitude: 119 0 43’06.94” W
Mount Diablo Base & Meridian, Township 14S, Range 21E, Section 6 located on the west side of South Peach Avenue, between East Tulare and East Huntington Avenues in the County of Fresno, California (See Exhibit A - Vicinity Map)
Cameron Graham
Golden State Developers LLC
680 P Street
Fresno, CA 93721
ENVIRONMENTAL ASSESSMENT FOR T-6432/P23-02268/P23-
02269/P23-03234
Filed with the

FRESNO COUNTY
CLERK
2220 Tulare Street,
Fresno, CA 93721
E102S[0000l‘
PROJECT DESCRIPTION:

Pursuant to the California Public Resources Code (PRC) §§ 21093 and 21094 and California Environmental Quality Act (CEQA) Guidelines §§ 15070 to 15075, and 15150, this project has been evaluated with respect to each item on the attached Appendix G/Initial Study Checklist to determine whether this project may cause any additional significant effect on the environment. After conducting a review of the adequacy of the Project Specific Mitigation Measure Checklist and CEQA Guidelines §§ 15151 and 15178(b)(1) and (2), the Planning and Development Department, as lead agency, finds that no substantial changes have occurred, and that no new information has become available.

The City of Fresno has prepared an Initial Study of the above-described project and proposes to adopt a Mitigated Negative Declaration.

Pre-zone Application No. P23-02269 proposes to pre-zone: approximately 4.18 acres of the property from the Fresno County RA-NB (Single Family Residential Agricultural) to the City of Fresno RS-5 (Single-Family Residential, Medium Density) and approximately 4.80 acres of the property from the Fresno County AL20 (Limited Agricultural) zone district to the City of Fresno RS-5/ANX (Single Family Residential, Medium Density/Annexed Rural Residential Overly) zone districts.

Vesting Tentative Tract Map No. 6432 proposes to subdivide approximately 3.97 acres of property into a 44-lot single-family residential development.

Planned Development Permit Application No. P23-03234 proposes to modify the RS-5 zone district development standards to allow for private streets; a reduction in the minimum lot size, and depth; a reduction in the minimum garage, street side yard, and rear yard setbacks, front; and an increase in the maximum lot coverage requirement
Bonique Emerson of Precision Civil Engineering, on behalf of Cameron Graham of Golden State Developers, has filed Annexation Application No. P23-02268, Pre-zone Application No. P23-02269, Vesting Tentative Tract Map No. 6432, and Planned Development Permit Application No. P23- 03234 pertains to ±9.46 acres of property located on the west side of South Peach Avenue, between East Tulare and East Huntington Avenues.

Annexation Application No. P23-02268 proposes to detach the property from the Kings River Conservation District and Fresno County Fire Protection District and annexation to the City of Fresno.

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Based upon the evaluation guided by the Appendix G/Initial Study Checklist, it was determined that there are project specific foreseeable impacts which require project level mitigation measures.

With mitigation imposed under the Project Specific Mitigation Measure Checklist, there is no substantial evidence in the record that this project may have additional significant, direct, indirect or cumulative effects on the environment that are significant. The Planning and Development Department, as lead agency, finds that no substantial changes have occurred, and that no new information has become available.

The completed Appendix G/Initial Study Checklist, its associated narrative, technical studies and mitigation measures reflect applicable comments of responsible and trustee agencies and research, and analyses conducted to examine the interrelationship between the proposed project and the physical environment. The information contained in the project application and its related environmental assessment application, responses to requests for comment, checklist, Initial Study narrative, and any attachments thereto, combine to form a record indicating that an Initial Study has been completed in compliance with the State CEQA Guidelines and the CEQA.

Additional information on the proposed project, including the Project Specific Mitigation Measure Checklist, proposed environmental finding of a Mitigated Negative Declaration and the Initial Study may be obtained from the Planning and Development Department, Fresno City Hall, 2600 Fresno Street, 3rd Floor, Room 3043, Fresno, California 93721 3604. Please contact Juan Lara at (559) 621-8039 or via email at [email protected] for more information.

Public notice has been provided regarding staff’s finding in the manner prescribed by § 15072 of the CEQA Guidelines and by § 21092 of the PRC Code (CEQA provisions).

The Initial Study has concluded that the proposed project will not result in any adverse effects, which fall within the "Mandatory Findings of Significance" contained in § 15065 of the State CEQA Guidelines. The finding is, therefore, made that the proposed project will not have a significant adverse effect on the environment.

ANY INTERESTED PERSON may comment on the proposed environmental finding. Comments must be in writing and must state (1) the commentor’s name and address; (2) the commentor's interest in, or relationship to, the project; (3) the environmental determination being commented upon; and (4) the specific reason(s) why the proposed environmental determination should or should not be made. Any comments may be submitted at any time between the publication date of this notice and close of business on August 28, 2025. Please direct comments to Juan Lara, Planner III, City of Fresno Planning and Development Department, City Hall, 2600 Fresno Street, Room 3043, Fresno, California, 93721-3604; or by email to [email protected].

All new development activity and many non-physical projects contribute directly or indirectly toward cumulative impacts on the physical environment. It has been determined that the incremental effect contributed by this project toward cumulative impacts is not considered substantial or significant in itself and/or that cumulative impacts accruing from this project may be mitigated to less than significant with application of feasible mitigation measures. 202 500004(0
INITIAL STUDY PREPARED BY: SUBMITTED BY:

Juan Lara, Planner III
Juan Lara, Planner III
DATE: 08/07/2025

CITY OF FRESNO
Attachments: Exhibit A - Vicinity Map

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

Environmental Assessment Application No. T-6432/P23-02269/P23-03234/P23- 02268

1. Project title:

Vesting Tentative Tract No. 6432
Annexation Application No. P23-02268
Pre-zone Application No. P23-02269
Planned Development Permit Application No. P23-03234

2. Lead agency name and address:

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

3. Contact person and phone number:

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

4. Project location:

Located on the west side of South Peach Avenue, between East Tulare Avenue and East Huntington Avenue, in the City and County of Fresno, CA Site Latitude: 36º44’27.08” N
Site Longitude: 119º43’06.94” W
Mount Diablo Base & Meridian, Township 14S, Range 21E, Section 6 Assessor’s Parcel Number(s): 463-140-01, -02 and -03. See Figures 1 and 2.

5. Project sponsor's name and address:

Golden State Developers, LLC
680 P Street, Suite 210
Fresno, CA 93721

6. General & Community plan land use designation:

General Plan: Current, Vacant/ Low Density Residential (Fresno County). Proposed, Medium Density Residential (City of Fresno)

7. Zoning:

Current: R1 – Residential Single Family, Extremely Low Density (Fresno County) Proposed: RS-5, Residential Single-Family, Medium Density/ 5-12 d.u./acre (City of Fresno)

8. Description of project:

The proposed Project includes Annexation, Pre -zone, Vesting Tentative Tract Map (VTTM) and Planned Development Applications, all of which were filed by Precision Civil Engineering on behalf of Golden State Developers, LLC, (herein, “Project Applicant”).

Annexation Application No. P23-02268 is required to bring the Project site into the City of Fresno, as the Project is located on the west side of South Peach Avenue, between East Tulare Avenue and East Huntington Avenue immediately outside of the City of Fresno limit within Fresno County.

Pre-zone Application No. P23-02269 is required as the site is currently zoned RA NB – Residential Single Family, Agricultural and AL 20 - Limited Agricultural (Fresno County), and as part of the Project, APNs 463-140-01, 463 -140-02, 463 -140-03, would be prezoned to RS -5 and 463-140-04 would be prezoned to RS -5/ANX, with development proposed on APNs 463-140-01, -02, and -03 (VTTM No. 6432). The project site was previously planned for medium density residential use upon annexation, therefore the pre-zoning would be consistent with existing City plans.

VTTM No. 6432 includes the construction of a 44-lot single-family detached rental unit development, including a private gated entrance, open landscaping and 117 parking spaces (88 in garages, 29 open stalls) on approximately 3.68 acres (Project). The proposed development would include a mix of 3 -bedroom, 2.5 -bathroom and 4 - bedroom, 2.5-bathroom floor plan layouts, with covered outdoor patios and fenced rear yards.

Planned Development Permit Application No. P23-03234 requests modifications to City development standards as follows:

Code Section or
Plan Policy #
Standard
Description
Standard
Requirement
Requested
Modification
15-903-1 Front Setback 13’ 5’
15-903-1 Interior Side
Setback 8’ total, 3’/side 7’ total, 3’/side
15-903-1 Street Side Setback 10’ 5’
15-903-1 Rear Setback 10’ 5’
15-903-1 Garage, from back
of curb or sidewalk 18’ none
15-903-1 Garage from primary
façade 4’ 0’
15-903-1 Maximum lot
coverage 60% 80%
Access to the proposed development will be from one point along South Peach Avenue. All required improvements are proposed and will be installed by the developer as part of the Project.

Construction
The proposed Project includes the construction of a 44-lot single-family detached rental unit development with the associated private roads and utility improvements on an existing parcel , which is currently vacant . Construction will take 12 months with construction starting as early as mid-2025.

It is anticipated that the following pieces of equipment would be used during construction activities:
• Roller;
• Large bulldozer;
• Loaded trucks;
• Excavator;
• Generator;
• Service truck; and
• Air compressor.

9. Surrounding land uses and setting:

Planned Land Use Existing Zoning Existing Land Use
North
Residential -
Medium Density
RS-5
Residential Single Family,
Medium Density (City of
Fresno)
Single-Family
Residential
East Residential –
Medium Density
RA NB
Single Family Residential/
Agricultural (Fresno County)
Single-Family
Residential
South Residential –
Medium Density
AL 20
Limited Agriculture (Fresno
County)
Vacant
West
Residential
Medium Low
Density
RS-4
Residential Single Family,
Medium Low Density (City of
Fresno)
Single-Family
Residential

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

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

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

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

Currently, the Table Mountain Rancheria Tribe and the Dumna Wo Wah Tribe have requested to be notified pursuant to Assembly Bill 52 (AB52). A certified letter was mailed to the above -mentioned tribes on February 7, 2025 . The 30 -day comment period ended on March 9, 2025. Neither tribe has requested consultation.

Figure 1 – Regional Location

Figure 1 – Site Aerial
ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project,

involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Agriculture and Forestry Resources
☐ Air Quality ☐ Biological Resources
☐ Cultural Resources ☐ Energy
☐ Geology/Soils ☐ Greenhouse Gas Emissions
☐ Hazards and Hazardous Materials ☐ Hydrology/Water Quality ☐ Land Use/Planning ☐ Mineral Resources
☐ Noise ☐ Population/Housing
☐ Public Services ☐ Recreation
☐ Transportation ☐ Tribal Cultural Resources
☐ Utilities/Service Systems ☐ Wildfire
☐ Mandatory Findings of Significance
DETERMINATION: (To be completed by the Lead Agency)
On the basis of this initial evaluation:
___ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. _X_
I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
___
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT (EIR) is required.
___ I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An EIR is required, but it must analyze only the effects that remain to be addressed.
___ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Date
___________________________________________August 8,2025______________ Juan Lara, Planner III
City of Fresno, Planning and Development Department
EVALUATION OF ADDITIONAL ENVIRONMENTAL IMPACTS:

1. For purposes of this Initial Study, the following answers have the corresponding meanings:
a. “No Impact” means the specific impact category does not apply to the project, or that the record sufficiently demonstrates that project specific factors or general standards applicable to the project will result in no impact for the threshold under consideration.
b. “Less Than Significant Impact” means there is an impact related to the threshold under consideration, but that impact is less than significant.

c. “Less Than Significant with Mitigation Incorporation” means there is a potentially significant impact related to the threshold under consideration, however, with the mitigation incorporated into the project, the impact is less than significant.

d. “Potentially Significant Impact” means there is substantial evidence that an effect may be significant related to the threshold under consideration.

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

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

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

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

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

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

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

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

8. The explanation of each issue should identify:

a. The significance criteria or threshold, if any, used to evaluate each question; and

b. The mitigation measure identified, if any, to reduce the impact to less than significance.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

I. AESTHETICS – Except as provided in PRC Section 21099, would the project:

a) Have a substantial adverse
effect on a scenic vista?
X

b) Substantially damage scenic
resources, including, but not
limited to, trees, rock out -
croppings, and historic buildings
within a state scenic highway?
X

c) In non -urbanized areas,
substantially degrade the existing
visual character or quality public
views of the site and its
surroundings? (Public views are
those that are experienced from
publicly accessible vantage point).

If the project is in an urbanize d
area, would the project conflict
with applicable zoning and other
regulations governing scenic
quality?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
X

DISCUSSION
a) Have a substantial adverse effect on a scenic vista? No Impact. A scenic vista is a viewpoint that provides a distant view of highly valued natural or man ‐made landscape features for the benefit of the general public.

Typical scenic vistas are locations where views of rivers, hillsides, and open space areas can be obtained as well as locations where valued urban landscape features can be viewed in the distance.

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

According to the City of Fresno General Plan , scenic views are also attributed to public views of buildings in Downtown Fresno that provide a skyline within the Planning Area. Due to relatively flat topography, intervening land uses, and landscaping, views of the skyline are primarily limited to areas within the Downtown Fresno area. Limited views of existing high ‐rise buildings in Downtown Fresno are visible from portions of elevated freeways, including SR 41, SR 99, and SR 180.

The continued implementatio n of the approved General Plan would allow future development in the Downtown area, which could include additional high rises. While views of scenic resources in the Downtown Fresno area may be partially obstructed following future development as allowed b y the approved General Plan, existing development in these areas currently inhibits views of scenic vistas.

The proposed Project site is located in an area designated for residential zoning uses by the County. The site is outside of the San Joaquin River bluffs and Downtown Fresno area. The adjacent parcels consist of single-family residences and areas located further north, south and west have also been developed into residential neighborhoods. The subject site is currently undeveloped. The existing topography of the site is nearly flat, with elevations ranging from 304-307 feet above mean sea level (amsl). There are no significant trees, rock outcroppings, and/or historic buildings located on the subject property that have been identified as important scenic resources.

There would be no impact to scenic vistas.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. The Project site is in a n area dominated by residential development.

There are no scenic vistas or other protected scenic resources on or near the site.

There are no scenic highways near the proposed site. The nearest eligible State Scenic Highway includes a portion of SR 180 (approximately 7 miles east of the City of Fresno) and a portion of SR 168 (approximately 5 miles east of the City of Fresno). The nearest officially ‐designated State Scenic Highway is located more than 30 miles northeast of the City of Fresno within the County of Madera. Miles of intervening land uses separate the Project site from either stretch of eligible State Scenic Highway. As such, there would be no impact.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less Than Significant Impact. The proposed Project is located in an urbanized area immediately adjacent to the City of Fresno. Satellite imagery indicates the Project site was formerly a rural residence. A house and shed, demolished between 2009 and 2012 were present in the southeast quadrant of the Project site. The site is currently periodically disked and was likely last disked in 2018, according to Google imagery. The site is designated by the General Plan for urban development.

The proposed Project would alter the existing visual character of public views of the site from vacant to fully developed with a 44 -lot single-family detached rental unit development. The Project design is subject to the City’s Design Guidelines adopted for the City’s General Plan which apply to site layout, building design, landscaping, interior street design, lighting, parking and signage. Detailed arc hitectural plans, color palettes and building materials as well as landscaping plans will be submitted by the Project developer to the City of Fresno Planning and Development Department. The plans shall be required prior to issuance of any building permits.

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

The site is currently zoned RA NB – Residential Single Family, Agricultural and AL 20 Limited Agricultural (Fresno County), and as part of the Project, APNs 463-140- 01, 463-140-02, 463-140-03, would be prezoned to RS-5 and 463-140-04 would be prezoned to RS-5/ANX, with development proposed on APNs 463-140-01, -02, and -03 (VTTM No. 6432). Once rezoned, the proposed Project will be in compliance with the requirements of the RS-5 Residential Zone.

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

The Project itself is not visually imposing against the scale of the existing landscape and nature of the surrounding area.

Therefore, the Project would have less than significant impacts on the visual character of the area.

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

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

However, most construction work is anticipated to take place during daylight hours, and lighting will be directed away from surrounding homes to minimize disruption.

The construction-related light will cease once Project construction has finished.

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

Mitigation Measures
The proposed Project shall implement and incorporate, as applicable, the aesthetic related mitigation measures as identified in the attached Project Specific Mitigation Monitoring and Reporting Program dated August 7, 2025.

AES-1: Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residents.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an op tional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Departm ent of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted b y the California Air Resources Board. Would the project:

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland,
Unique Farmland, or Farmland of
Statewide Importance (Farm -
land), as shown on the maps
prepared pursuant to the
Farmland Mapping and Monito -
ring Program of the California
Resources Agency, to non -
agricultural use?
X

b) Conflict with existing zoning for
agricultural use, or a Williamson
Act contract?
X
c) Conflict with existing zoning for,
or cause rezoning of, forest land
(as defined in Public Resources
Code section 12220(g)),
timberland (as defined by Public
Resources Code section 4526), or
timberland zoned Timberland
Production (as defined by
Government Code section
51104(g))?
X
d) Result in the loss of forest land
or conversion of forest land to
non-forest use?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

e) Involve other changes in the
existing environment which, due
to their location or nature, could
result in conversion of Farmland,
to non -agricultural use or
conversion of forest land to non -
forest use?
X

DISCUSSION
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

No Impact. Upon annexation, t he site will be within the City limits in an area substantially built up with residential uses. The California Department of Conservation, Important Farmland Finder Program considers the Project site to be Urban and Built- Up Land. This project is contiguous to an existing urbanized area and would a be natural progression that allows orderly and consistent development of residences to meet the growing demand for housing in the City. There is no farmland on-site and as such, there will be no conversion of land to non-agricultural uses. There would be no impact.

b) Conflict with existing zoning for agricultural use or a Williamson Act contract?

No Impact. The site is zoned as Single Family Residential, Agricultural (RA NB) and Limited Agricultural (AL20) by Fresno County. The Applicant proposes annexing and re-zoning the Project site as Single Family Residential, Medium Density (RS-5) and Signel Family Residential, Medium Density /Annexed Rural Residential Transitional Overly (RS-5/ANX), as per the City of Fresno General Plan zoning designations. The site is not subject to a Williamson Act contract and no mitigation is required . There would be no impact.

c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

No Impact. As mentioned in Impact b), above, the site is zoned as Single Family Residential, Agricultural (RA NB) and Limited Agricultural (AL20) by Fresno County.

The Applicant proposes annexing and re -zoning the Project site as Single Family Residential, Medium Density (RS-5) and Signel Family Residential, Medium Density/Annexed Rural Residential Transitional Overly (RS-5/ANX), as per the City of Fresno General Plan zoning designations. The proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production , and no mitigation is necessary . There would be no impact.

d) Result in the loss of forest land or conversion of forest land to non-forest use?

No Impact. As described in Impact c) above, there is no forest land on the Project site. There would be no impact.

e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non -agricultural use or conversion of forest land to non-forest use?

No Impact. As discussed in Impact a) above, there is no agricultural land on-site. The proposed Project will not involve new other changes in the existing environment that could result in conversion of Farmland. There would be no impact.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

a) Conflict with or obstruct
implementation of the applicable
air quality plan ( e.g., by having
potential emissions of regulated
criterion pollutants which exceed
the San Joaquin Valley Air
Pollution Control Districts
(SJVAPCD) adopted thresholds
for these pollutants)?
X

c) Expose sensitive receptors to
substantial pollutant
concentrations?
X

d) Result in other emissions (such
as those leading to odors)
adversely affecting a substantial
number of people?
X

An Air Quality, Greenhouse Gas, and Energy Technical Memorandum ( Memo) was prepared by Johnson Johnson and Miller Air Quality Consulting Services, report date May 15, 2023, Revised November 7, 2024, and is the basis for analysis of this environmental impact section. The Memo is provided in its entirety in Appendix A.

DISCUSSION
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. CEQA requires that certain projects be analyzed for consistency with the applicable air quality plan. An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a non-attainment area. The mai n purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards.

To bring the San Joaquin Valley Air Basin (SJVAB) into attainment, the San Joaquin Valley Air Pollution Control District (SJVAPCD) adopted the 2016 Plan for the 2008 8- Hour Ozone Standard in June 2016 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8-hour ozone standard.

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

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

As discussed below, emissions associated with the construction or operation of the proposed Project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance.

Construction Emissions

Construction is expected to progress over one year. As shown in Table 1, the emissions in each construction year are below the significance thresholds (modeling assumptions are provided in Appendix C). Consequently, the construction emissions for the Project basis are less than significant.

Table 1: Construction Air Pollutant Emissions
Construction
Activity
Emissions (Tons/Year)
ROG NOX CO SOX PM10 PM2.5
Site
Preparation 0.01 0.14 0.09 <0.01 0.05 0.03
Grading 0.02 0.22 0.16 <0.01 0.05 0.02
Paving 0.10 0.91 1.05 <0.01 0.06 0.05
Building
Construction
(2023)

0.09 0.76 0.92 <0.01 0.05 0.04
Building
Construction
(2024)

0.01 0.10 0.15 <0.01 0.01 <0.01
Architectural
Coating 0.29 0.01 0.02 <0.01 <0.01 <0.01
Total
Emissions

0.52 2.14 2.39 0.00 0.22 0.14
Significance
Thresholds 10 10 100 27 15 15
Exceed
Significance
Thresholds?
No No No No No No
Notes:

PM10 and PM 2.5 emissions are from the mitigated output to reflect compliance with Regulation VIII —Fugitive PM 10 Prohibitions.

Source of Emissions: CalEEMod Output (Appendix A).

Source of Thresholds: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT- GAMAQI.PDF. Accessed May 1, 2023.

Operational Emissions

When making important determinations, the SJVAPCD considers building and operating emissions separately; in any case, the annual operating emissions together with the annual building emissions will not exceed the relevant SJVAPCD thresholds.

Operational emissions occur during the project's lifespan and come from two major sources: Region sources and motor vehicles or mobile sources.

Please note that these findings include the benefits of compliance with required regulations not yet implemented in the California Emissions Estimator Model (CalEEMod) and the design and location of projects using the mitigation portion of CalEEMod. Such s teps and regulations are considered part of the project baseline; however, the results are presented in the mitigated model performance of CalEEMod and are not considered mitigation appropriate for compliance with CEQA.

Reductions from land use and transportation measures relating to the location, site design and proximity of the project to alternative modes of transport are measured by CalEEMod and are based on the methodology provided in the 2010 report of the California Air Pollution Control Officers Association (CAPCOA), Quantifying Gas Mitigation Measures. As shown in Table 2, the emissions are below the San Joaquin Valley Air Pollution Control District (SJVAPCD) significance thresholds, and therefore, would result in a less than significant impact.

Table 2: Operational Air Pollutant Emissions
Source
Emissions (tons/year)
ROG NOX CO SOX PM10 PM2.5
Area 0.39 0.02 0.33 <0.01 <0.01 <0.01
Energy 0.01 0.05 0.02 <0.01 <0.01 <0.01
Mobile (Vehicle Trips) 0.13 0.25 1.57 <0.01 0.45 0.12
Annual Total 0.53 0.32 1.92 <0.01 0.45 0.12
Significance
Thresholds 10 10 100 27 15 15
Exceed Significance
Thresholds? No No No No No No
Notes:

Emissions were quantified using the earliest operational year for the proposed project to provide a conservative estimate of emissions.

Source: CalEEMod Output (Appendix A).

Localized Pollutant Analysis

Emissions occurring at or near the Project have the potential to create a localized impact also referred to as an air pollutant hotspot. Localized emissions are considered significant if , when combined with background emissions, they would result in exceedance of any health-based air quality standard. In locations that already exceed standards for these pollutants, significance is based on a significant impact level (SIL) that represents the amount that is considered a cumulatively considerable contribution to an existing violation of an air quality standard. The pollutants of concern for localized impact in the SJVAB are NO2, SOx, and CO.

The SJVAPCD has provided guidance for screening localized impacts in the GAMAQI that establishes a screening threshold of 100 pounds per day of any criteria pollutant.

If a project exceeds 100 pounds per day of any criteria pollutant, then ambient air quality modeling would be necessary. If the project does not exceed 100 pounds per day of any criteria pollutant, it can be assumed that the emission would not cause a violation of an ambient air quality standard. Local construction impacts would be short- term in nature lasting only during the duration of construction.

Construction

As shown in Table 3, on-site construction emissions would be less than 100 pounds per day for each of the criteria pollutants. To present a conservative estimate, on-site emissions for on -road construction vehicles were included in the localized analysis.

Based on the SJVAPCD’s guidance, the construction emissions would not cause an ambient air quality standard violation.

Table 3: Localized Concentrations of NOX, CO, PM10, and PM2.5 for Construction
Source
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Maximum On-site Daily (2023) 27.56 18.37 10.12 5.71
Maximum On-site Daily (2024) 13.63 16.46 0.63 0.58
Maximum Daily On-site
Emissions 27.56 18.37 10.12 5.71
Significance Thresholds 100 100 100 100
Exceed Significance Thresholds? No No No No
Note: Assumptions regarding dates of construction activities are based on the construction schedule shown in Error! Reference s ource not found..

Source of Emissions: CalEEMod Output and Additional Supporting Information (Appendixt A).

Accessed May 1, 2023.

As shown in Table 3, the proposed Project will not surpass SJVAPCD screening requirements that require additional analysis of the ambient air quality. As such, the proposed Project will not conflict with or obstruct implementation of the applicable air quality plan. Impacts would be less than significant.

Operation

Localized impacts could occur in areas with a single large source of emissions such as a power plant or with multiple sources concentrated in a small area such as a distribution center.

As shown in Table 4 below, operational modeling of on -site emissions for the proposed Project indicate that the Project would not exceed 100 pounds per day for each of the criteria pollutants. Therefore, based on the SJVAPCD’s guidance, the operational emissions would not cause an ambient air quality standard violation. As such, impacts would be less than significant.

Table 4: Localized Concentrations of NOX, CO, PM10, and PM2.5 for Construction

Source
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Area 0.44 3.78 0.05 0.05
Energy 0.27 0.11 0.02 0.02
Mobile (On-site +
Localized Vehicle
Emissions) 0.49 3.14 0.16 0.05
Daily Total 1.20 7.03 0.24 0.12
Significance
Thresholds 100 100 100 100
Exceed Significance
Thresholds? No No No No
Source of Emissions: CalEEMod Output and Additional Supporting Information (Attachment A).

Maximum daily emissions of NOX, CO, PM10, and PM2.5 were highest in the Winter scenario.

Accessed May 1, 2023.

As shown in Table 1 and 2 above, the Project’s construction and operational regional emissions would not exceed SJVAPCD’s regional criteria pollutant emissions quantitative thresholds. Therefore, the proposed project would not be considered in conflict with or obstruct implementation of the ap plicable air quality plan. Potential impacts would be less than significant.

b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant Impact. To result in a less than significant impact, emissions of nonattainment pollutants must be below the SJVAPCD’s regional significance thresholds. This is an approach recommended by the SJVAPCD’s in its GAMAQI.

The primary pollutants of concern during project construction and operation are ROG, NOX, PM10, and PM2.5. The SJVAPCD GAMAQI adopted in 2015 contains thresholds for CO, NOX, ROG, SOX, PM10, and PM2.5.

Air pollutant emissions have both regional and localized effects. As shown in Table 3 and Table 4, the Project’s regional emissions would not exceed the applicable regional criteria pollutant emissions quantitative thresholds. Potential impacts would be less than significant.
c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact with Mitigation Incorporated. Emissions occurring at or near the project have the potential to create a localized impact that could expose sensitive receptors to substantial pollutant concentrations. The SJVAPCD considers a sensitive receptor to be a location that houses or attracts children, the elderly, people with illnesses, or others who are especially sensitive to the effects of air pollutants.

Examples of sensitive receptors include hospitals, residences, convalescent facilities, and schools. The image below shows a 1,000 foot rad ius around the center point of the proposed Project site. While the site is vacant and is largely surrounded by open space and single family residences, other sensitive receptors within 1,000 feet of the

Project boundary include:
• Trolley Creek Park (372 feet to the southwest)
• Huntington Palace luxury apartments (417 feet to the east) • Kings Canyon Middle School (740 feet to the north)
• Easterby Elementary School (744 feet to the north)
• Evergreen Care Center (758 feet to the southeast)
• Southeast Fresno Child Development Daycare Center (760 feet to the north) • Huntington Pond Park (770 feet to the southwest)
• Vintage Gardens Assisted Living Community (995 feet to the south)

The SJVAPCD’s GAMAQI includes screening thresholds for identifying projects that need detailed analysis for localized impacts. Projects with on-site emission increases from construction activities or operational activities that exceed the 100 pounds per day screening level of any criteria pollutant after implementation of all enforceable mitigation measures would require additional analysis to determine if the preparation of an ambient air quality analysis is needed. The criteria pollutants of concern for localized impact in the Air Basin are PM10, PM2.5, NOX, and CO. There is no localized emission standard for ROG.

As shown in Table 3, the Project would not exceed the emission screening thresholds during project construction. Therefore, the Project’s localized criteria pollutant impacts from construction of the Project would be less than significant.

As shown in Table 4, the Project would not exceed SJVAPCD screening thresholds for localized criteria pollutant impacts; therefore, the Project’s localized criteria pollutant impacts from long-term operations would be less than significant.

Toxic Air Contaminants
Construction
As discussed above, criteria pollutant emissions during construction would not exceed the SJVAPCD’s significance thresholds and would not be expected to result in concentrations that would exceed ambient standards or contribute substantially to an existing exceedance of an ambient air quality standard. Therefore, construction of the proposed Project would not result in localized emissions that, if when combined with background emissions, would result in exceedance of any health -based air quality standard fo r any criteria pollutant. As such, health risk impacts related to criteria pollutants emitted during the construction period of the proposed Project would be less than significant.

Construction-related activities would result in temporary, short-term project-generated emissions of diesel particulate matter (DPM) from the exhaust of off-road, heavy-duty diesel equipment for site preparation (e.g., clearing, grading); soil hauling truck traffic; paving; home construction; application of architectural coatings; and other miscellaneous activities. For construction activity, DPM is the primary air toxic of concern. Particulate exhaust emissions from diesel -fueled engines (i.e., DPM) were identified as a toxic air contaminant (TAC) by the California Air Resources Board (CARB) in 1998.1 Due to proposed Project’s proximity to existing sensitive receptors,

1 California Air Resources Board (CARB). 1998. The Toxic Air Contaminant Identification Process: Toxic Air Contaminant Emissions from Diesel -fueled Engines. Website:
www.arb.ca.gov/toxics/dieseltac/factsht1.pdf.
a health risk assessment was performed to assess impacts from DPM emissions resulting from construction of the project. The results of the health risk assessment are summarized below, while the calculations used for the health risk assessment are provided as Attachment B of Appendix A.

The construction HRA evaluated DPM (represent as exhaust PM 10) emissions generated during construction of the proposed Project and the related health risk impacts for sensitive receptors located within 1,000 feet of the project boundary. A project would result in a significant impact if it would individually expose sensitive receptors to TACs resulting in an increased cancer risk greater than 20 in one million or an increased non-cancer risk of greater than 1.0 on the hazard index. It should be noted that the SJVAPCD’s latest threshold of significance for TAC emissions is an increase in cancer risk for the maximally exposed individual of 20 in one million (formerly 10 in one million).

To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including DPM), a dispersion model2 (AERMOD) was used to translate an emission rate from the source location to concentrations at the receptor locations of interest (i.e., receptors at nearby residences). AERMOD provides a refined methodology for estimating localized impacts by utilizing lo ng-term, measured representative meteorological data for the project site and a representative construction schedule. A graphical representation of AERMOD inputs, including the locations of modeled sensitive receptor locations, is included as part of Attachment B of Appendix A.

Construction-related activities would result in temporary, short-term project-generated emissions of diesel particulate matter (DPM) from the exhaust of off-road, heavy-duty diesel equipment for site preparation (e.g., clearing, grading); soil hauling truck traffic; paving; home construction; application of architectural coatings; and other miscellaneous activities. For construction activity, DPM is the primary air toxic of concern. Particulate exhaust emissions from diesel -fueled engines (i.e., DPM) were identified as a toxic air contaminant (TAC) by the California Air Resources Board (CARB) in 1998. Due to the proposed Project’s proximity to existing sensitive receptors, a health risk assessment was performed to assess impacts from DPM emissions resulting from construction of the Project. The results of the health risk

2 An air dispersion model is a mathematical formulation used to estimate air quality impacts at specific locations (receptors) surrounding a source of emissions given the rate of emissions and prevailing meteorological conditions. The air dispersion model applied in this assessment was the EPA American Meteorological Society Regulatory Model (AERMOD), Version 21112, which is approved by the SJVAPCD for air dispersion assessments.
assessment are summarized below, while the calculations used for the health risk assessment are provided as Attachment B in Appendix A.

A project would result in a significant impact if it would individually expose sensitive receptors to TACs resulting in an increased cancer risk greater than 20 in one million or an increased non-cancer risk of greater than 1.0 on the hazard index. It shou ld be noted that the SJVAPCD’s latest threshold of significance for TAC emissions is an increase in cancer risk for the maximally exposed individual of 20 in one million (formerly 10 in one million).

To estimate the potential cancer risk associated with construction of the proposed Project from equipment exhaust (including DPM), a dispersion model (AERMOD) was used to translate an emission rate from the source location to concentrations at the receptor locations of interest (i.e., receptors at nearby residences). AERMOD provides a ref ined methodology for estimating localized impacts by utilizing long -term, measured representative meteorological data for the project site and a representative construction schedule. A graphical representation of AERMOD inputs, including the locations of modeled sensitive receptor locations, is included as part of Attachment B in Appendix A.

Cancer Risk
The Office of Environmental Health Hazard Assessment (OEHHA) has developed guidance for estimating cancer risks that considers the increased sensitivity of infants and adults to TAC emissions, different breathing rates, and time spent at home. This guidance was applied in estimating cancer risks from the construction and operation of the proposed Project.

The recommend method for the estimation of cancer risk is shown in the equations.

Cancer Risk = CDPM x Inhalation Exposure Factor (EQ-1)
Where:

Cancer Risk = Total individual excess cancer risk defined as the cancer risk a hypothetical individual faces if exposed to carcinogenic emissions from a particular source for specified exposure durations; this risk is defined as an excess risk because it i s above and beyond the background cancer risk to the population; cancer risk is expressed in terms of risk per million exposed individuals.

CDPM = Period average DPM air concentration calculated from the air dispersion model in µg/m3
Inhalation is the most important exposure pathway to impact human health from DPM and the inhalation exposure factor is defined as follows:

Inhalation Exposure Factor=CPF x EF x ED x DBR x AAF/AT (EQ-2) Where:

Chronic Non-Cancer Hazard
Non-cancer chronic impacts are calculated by dividing the annual average concentration by the Reference Exposure Level (REL) for that substance. The REL is defined as the concentration at which no adverse non -cancer health effects are anticipated. The following equation was used to determine the non-cancer risk:

Hazard Quotient = Ci/RELi
Where:

Ci = Concentration in the air of substance i (annual average concentration in μg/m3) RELi = Chronic noncancer Reference Exposure Level for substance i (μg/m3)

Construction Health Risk Assessment Results
The results of the HRA prepared for Project construction for cancer risk and long-term chronic cancer risk are summarized below. Construction emissions were estimated assuming adherence to all applicable rules, regulations, and Project design features.

The construction emissions were assumed to be distributed over the Project Area with a working schedule of eight hours per day and five days per week. Emissions were adjusted by a factor of 4.2 to convert for use with a 24-hour-per-day, 365 day-per-year averaging period. Detailed parameters and complete calculations are included in Attachment B of Appendix A.

The estimated health and hazard impacts at the Maximally Exposed Receptor (MER) from the Project’s construction emissions are provided in Table 5.

Table 5: Summary of the Health Impacts from Unmitigated Construction of the Proposed Project

As shown in Table 5, estimated health risks from elevated DPM concentrations during construction of the proposed Project would exceed the applicable cancer risk significance threshold at the MER. This represents a potentially significant construction TAC exposure impact. Therefore, mitigation is required to reduce the impact during the construction period to below a level of significance.

MM AIR-1 requires the Project applicant, Project sponsor, or construction contractor to provide documentation to the City of Fresno that the construction fleet meets CARB Tier 4 Interim off-road emissions standards. Table 6 shows the health risks and non- cancer hazard index for construction with implementation of MM AIR-1.

Table 6: Summary of the Health Impacts from Mitigated Construction of the Proposed Project

As noted in Table 6, calculated health metrics from the proposed Project’s construction DPM emissions would not exceed the cancer risk significance threshold or non-cancer hazard index significance threshold at the MER with incorporation of MM AIR-1. Therefore, the impact on nearby sensitive receptors from TACs during construction would be less than significant with the incorporation of mitigation.

Operations
PM10 and PM2.5 are commonly used as proxies for Diesel Particulate Matter (DPM), which would be the toxic air containment of concern emitted by the Project. Estimated localized emissions generated by the proposed Project would not reach levels high enough to necessitate further analysis. As such, it is not expected that any TAC concentrations would reach levels that would cause an exceedance of the SJVAPCD’s health risk thresholds.

Unlike warehouses or distribution centers, the daily vehicle trips generated by the proposed residential Project would be primarily generated by passenger vehicles.

Passenger vehicles typically use gasoline engines rather than the diesel engines that are found in heavy-duty trucks. Gasoline-powered vehicles do emit TACs in the form of toxic organic gases, some of which are carcinogenic. Compared to the combustion of diesel, the combustion of gasoline had relatively low emissions of TACs. Thus, residential users produce limited amounts of TAC emissions during operation.

Nonetheless, it is anticipated that there would be some heavy-duty trucks visiting the project site during operations. Consistent with SJVAPCD guidance, an operational prioritization screening analysis was completed for the proposed Project.

Operational DPM emissions from diesel trucks were estimated using emission factors from CARB’s EMFAC and estimated truck travel and idling at the Project site based

on average daily trips and the SJVAPCD -approved residential fleet mix. The emissions were entered into the SJVAPCD Prioritization Screening Tool to determine the risk scores, with complete calculations and assumptions included as part of Attachment A in Appendix A . The results of the screening analysis are provided in Table 7.

Table 7: Prioritization Tool Health Risk Screening Results

As shown in Table 7, the Project would not exceed the cancer risk or chronic hazard threshold levels. The primary source of the emissions responsible for chronic risk are from diesel trucks. DPM does not have an acute risk factor. Since the Project does not exceed the applicable SJVAPCD screening thresholds for cancer risk, acute risk, or chronic risk, this impact would be less than significant.

Valley Fever
Valley fever, or coccidioidomycosis, is an infection caused by inhalation of the spores of the fungus, Coccidioides immitis (C. immitis). The spores live in soil and can live for an extended time in harsh environmental conditions. Activities or conditions that increase the amount of fugitive dust contribute to greater exposure, and they include dust storms, grading, and recreational off-road activities.

The San Joaquin Valley is considered an endemic area for Valley fever. During 2000– 2018, a total of 65,438 coccidioidomycosis cases were reported in California; median statewide annual incidence was 7.9 per 100,000 population and varied by region from

1.1 in Northern and Eastern California to 90.6 in the Southern San Joaquin Valley, with the largest increase (15 ‐fold) occurring in the Northern San Joaquin Valley.

Incidence has been consistently high in six counties in the Southern San Joaquin Valley (Fresno, Kern, Kings, Madera, Tulare, and Merced counties) and Central Coast (San Luis Obispo County) regions. California experienced 7,392 new probable or confirmed cases of Valley fever in 2020. A total of 466 Valley fever cases were reported in Fresno County in 2020.

The distribution of C. immitis within endemic areas is not uniform and growth sites are commonly small (a few tens of meters) and widely scattered. Known sites appear to have some ecological factors in common suggesting that certain physical, chemical, and biological conditions are mor e favorable for C. immitis growth. Avoidance, when possible, of sites favorable for the occurrence of C. immitis is a prudent risk management strategy. Listed below are ecological factors and sites favorable for the occurrence of C. immitis:
1) Rodent burrows (often a favorable site for C. immitis , perhaps because temperatures are more moderate and humidity higher than on the ground surface) 2) Old (prehistoric) Indian campsites near fire pits
3) Areas with sparse vegetation and alkaline soils
4) Areas with high salinity soils
5) Areas adjacent to arroyos (where residual moisture may be available) 6) Packrat middens
7) Upper 30 centimeters of the soil horizon, especially in virgin undisturbed soils 8) Sandy, well-aerated soil with relatively high water-holding capacities Sites within endemic areas less favorable for the occurrence of C. immitis include:
1) Cultivated fields
2) Heavily vegetated areas (e.g., grassy lawns)
3) Higher elevations (above 7,000 feet)
4) Areas where commercial fertilizers (e.g., ammonium sulfate) have been applied 5) Areas that are continually wet
6) Paved (asphalt or concrete) or oiled areas
7) Soils containing abundant microorganisms
8) Heavily urbanized areas where there is little undisturbed virgin soil The current Project site is primarily vacant, with sparse shrubbery; however, the site has been previously graded or tilled. In addition, the Project site is surrounded by other parcels that are built -up or have been previously disturbed. The Project site is not cultivated, heavily vegetated, at a high elevation, fertilized, paved, continually wet, or heavily urbanized. Therefore, construction activities could generate fugitive dust that contain C. immitis spores. The Project will minimize the generation of fugitive dust during construction activities by complying with SJVAPCD’s Regulation VIII (Fugitive Dust/PM-10 Control), which is included in Mitigation Measure AIR -2. Regulation VIII is a series of rules designed to reduce fugitive dust from construction sites, parking and staging areas, open areas, material storage areas, etc. In addition, common dust control measures used to comply with SJVAPCD’s Regulation VIII (such as applying water or chemical dust suppressants) would further reduce the favorability of the site conditions for C. immitis to occur. Therefore, compliance with the SJVAPCD’s Regulation VIII and Mitigation Measure AIR -2 would reduce Valley fever impacts during construction to less than significant.

During operations, dust emissions are anticipated to be relatively small, because most of the project area where operational activities would occur would be occupied by the proposed residential homes and pavement. This condition would substantially lessen the possibility of the Project from providing habitat suitable for C. immitis spores and for generating fugitive dust that may contribute to Valley fever exposure. Impacts would be less than significant.

Naturally Occurring Asbestos
Review of the map of areas where naturally occurring asbestos in California are likely to occur found no such areas in the Project Area. Therefore, development of the Project is not anticipated to expose receptors to naturally occurring asbestos. Impacts would be less than significant.

Operations—The Project’s Potential to Locate Sensitive Receptor Near Existing Sources of TACs
As a residential project, the Project would locate sensitive receptors – future residents – where they could be subject to existing sources of TACs. However, the California Supreme Court concluded in California Building Industry Association (CBIA) v. Bay Area Air Quality Management District (BAAQMD) (2015) 62 Cal.4th 369, that agencies subject to CEQA are not required to analyze the impact of existing environmental conditions on a project’s future users or residents. Therefore, this potential impact will not be further addressed in this document.

Conclusion
In summary, the Project would not exceed SJVAPCD localized emission daily screening levels for any criteria pollutant. The Project would not be a significant source of TAC emissions during operations and would be a less than significant source of TAC emissions during construction with implementation of mitigation. The Project is not in an area with suitable habitat for Valley fever spores and is not in an area known to have naturally occurring asbestos. Therefore, the Project would not result in significant impacts to sensitive receptors. MM AIR-1 and AIR-2 are required to reduce the Project’s potential impacts during construction to less than significant with mitigation incorporated.

d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact. Two situations are recognized to create a potential for odor impact. The first occurs when a new odor source is located near an existing sensitive receptor. The second occurs when a new sensitive receptor locates near an existing source of odor. to the decision in CBIA v. BAAQMD suggests that impacts of existing sources of odors on future residents at the Project site are not subject to CEQA review.

Odor impacts from the Project on residential areas and other sensitive receptors, such as hospitals, day -care centers, schools, etc. warrant the closest scrutiny, but consideration should also be given to other land uses where people may congregate, such as recreational facilities, wor ksites, and commercial areas. The SJVAPCD recommends that the analysis should be based on a review of odor complaints for similar facilities. In assessing potential odor impacts, consideration also should be given to local mete orological conditions, particularly the intensity and direction of prevailing winds.

Lead Agencies can also make a determination of significance based on a review of SJVAPCD complaint records. For a project locating near an existing source of odors, the impact is potentially significant when the project site is at least as close as any other site that has already experienced significant odor problems related to the odor source.

Significant odor problems are defined by the SJVAPCD as:
• More than one confirmed complaint per year averaged over a three-year period, or • Three unconfirmed complaints per year averaged over a three-year period.

An unconfirmed complaint means that either the odor/air contaminant release could not be detected, or the source/facility cannot be determined. Because of the subjective nature of odor impacts and the lack of quantitative or formulaic methodologies, the significance determination of potential odor impacts should be considered on a case- by-case basis.

Although the Project is less than one mile from the nearest sensitive receptor, the Project is not expected to be a significant source of odors. The screening levels for these land use types are shown in Table 8.

Table 8: Screening Levels for Potential Odor Sources
Odor Generator Screening Distance
Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Composting Facility 1 mile
Petroleum Refinery 2 miles
Asphalt Batch Plant 1 mile
Chemical Manufacturing 1 mile
Fiberglass Manufacturing 1 mile
Painting/Coating Operations (e.g., auto body shop) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Source of Thresholds: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF.

Accessed May 1, 2023.

Construction
During construction, various diesel -powered vehicles and equipment in use on -site would create localized odors. These odors would be temporary and intermittent, which would decrease the likelihood of the odors concentrating in a single area or lingering for any notable period of time. As such, these odors would likely not be noticeable for extended periods of time beyond the Project’s site boundaries. The potential for odor impacts from construction of the Project would, therefore, be less than significant.

Operations
Project as a Generator
The occurrence and severity of odor impacts depend on numerous factors, including the nature, frequency, and intensity of the source; wind speed and direction; and the presence of sensitive receptors. Although offensive odors rarely cause any physical harm, they still can be very unpleasant, leading to considerable distress and often generating citizen complaints to local governments and regulatory agencies. The Project is residential in nature, and operations would not be anticipated to produce odorous emi ssions. Therefore, Project operations would not create objectionable odors affecting a substantial number of people; the impact would be less than significant.

Mitigation Measures
The Project shall implement and incorporate, as applicable, the air quality related mitigation measures as identified in the attached Project Specific Mitigation Monitoring and Reporting Program dated August 7, 2025.

MM AIR-1
Before a construction permit is issued for the proposed Project, the Project applicant, Project sponsor, or construction contractor shall submit reasonably detailed proof of compliance with the following requirements to the City of Fresno.

Where portable diesel engines are used during construction, all off -road equipment with engines greater than 75 horsepower shall have engines that meet California Air Resources Board (CARB) Tier 4 Interim off -road emission standards. except as otherwise specified herein. If engines that comply with Tier 4 Interim or Tier 4 Final off -road emission standards are not commercially available, then the construction contractor shall use the next cleanest piece of off-road equipment (e.g., Tier 3) that is commercially available. For purposes of this project design feature, “commercially available” shall mean the equipment at issue is available taking into consideration factors such as (i) critical-path timing of construction; and (ii) geographic proximity of equipment to the project site . If the relevant equipment is determined by the project applicant to not be commercially available, the contractor must confirm this conclusion by providing to the City letters from at least two rental companies for each piece of unavailable off-road equipment that is required for the Project.

MM AIR-2
Consistent with the SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions), the following controls are required to be included as specifications for the proposed Project and implemented at the construction site:
• All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, covered with a tarp or other suitable cover or vegetative ground cover.
• All on -site unpaved roads and off -site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.
• All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking. • When materials are transported off -site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least six inches of freeboard space from the top of the container shall be maintained. • All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. (The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.)
• Following the addition of materials to, or the removal of materials from, the surface of out-door storage piles, said piles shall be effectively stabilized of fugitive dust emission utilizing sufficient water or chemical stabilizer/suppressant.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

IV. BIOLOGICAL RESOURCES – Would the project:

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

a) Have a substantial adverse
effect, either directly or through
habitat modifications, on any
species identified as a candidate,
sensitive, or special status
species in local or regional plans,
policies, or regulations, or by the
California Department of Fish and
Game or U.S. Fish and Wildlife
Service?
X

b) Have a substantial adverse
effect on any riparian habitat or
other sensitive natural community
identified in local or regional
plans, policies, regulations or by
the California Department of Fish
and Game or US Fish and Wildlife
Service?
X

c) Have a substantial adverse
effect on federally protected
wetlands as defined by Section
404 of the Clean Water Act
(including, but not limited to,
marsh, vernal pool, coastal, etc.)
through direct removal, filling,
hydrological interruption, or other
means?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

e) Conflict with any local policies
or ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
X

f) Conflict with the provisions of an
adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan?
X

DISCUSSION
The biological resources evaluation is based upon a review of available literature, databases, and existing site conditions evaluated during a reconnaissance survey.

These studies evaluated the potential for sensitive biological resources to occur on and in the vicinity of the Project, and any impacts that could potentially occur. A copy of the biological resource evaluation, included as Appendix B of this document, is the basis for analysis of the discussion below.

As a framework for the evaluation and reconnaissance survey, an official USFWS species list was obtained for the Project (USFWS 2023a). In addition, the California Natural Diversity Database (CNDDB, CDFW 2023) and the CNPS Inventory of Rare and Endangered Plants (CNPS 2023) were searched for records of special -status plant and animal species from the vicinity of the Project site. Regional lists of special- status species were compiled using CNDDB and CNPS database searches confined to the Malaga 7.5 -minute United States Geological Survey (USGS) topographic quadrangle, which encompasses the Project site, and the eight surrounding quadrangles (Caruthers, Clovi s, Conejo, Fresno North, Fresno South, Round Mountain, Sanger, and Selma). A local list of special -status species was compiled using CNDDB records from within five miles of the Project site. Species that lacked a CEQA-recognized special status designation by state or federal regulatory agencies or public interest groups were omitted from the final list. Species for which the Project site does not provide habitat were eliminated from further consideration. Aerial imagery was reviewed from Google Earth and other sources, USGS topographic maps, the Web Soil Survey, the National Wetlands Inventory , and relevant literature.

The results of the database inquiries were reviewed to evaluate the potential for the occurrence of special-status species and other sensitive biological resources known to occur on or near the Project site prior to conducting the biological reconnaissance survey.

A field reconnaissance survey of the Project site was conducted on January 18, 2023.

The Project site and a 50-foot buffer surrounding the Project site (Survey Area) were walked and thoroughly inspected to evaluate and document the potential for the area to support state or federally protected resources. All plants except those under cultivation or planted in residential areas and all vertebrate wildlife species obser ved within the survey area were identified and documented. The survey area was evaluated for the presence of regulated habitats, including lakes, streams, and other waters using methods described in the Wetlands Delineation Manual and regional supplement and as defined by the California Department of Fish and Wildlife (CDFW) or under the Porter -Cologne Water Quality Control Act. An additional buffer of 0.5 miles around the Project site was inspected for potential nesting habitat for special - status raptors. The 0.5 -mile buffer was surveyed by driving public roads and identifying the presence of la rge trees or other potentially suitable substrates for nesting raptors as well as open areas that could provide foraging habitat.

The purpose of the survey was to determine the presence and extent of existing plant communities and any sensitive habitats, the presence and potential for occurrence of special-status plant and animal species, and to identify any other sensitive biologica l resources within the Survey Area Plant and wildlife species and current site conditions were recorded while conducting the survey.

General Site Conditions
The Project site support s ruderal vegetation dominated by nonnative grasses and forbs. It is bordered by rural residential development in all directions. Unmaintained ornamental trees and shrubs are sparsely distributed throughout the eastern half and around the perimeter of the Project site . Trash and debris are scattered throughout the entire Project site. Satellite imagery indicates the Project site was formerly a rural residence which was demolished between 2009 and 2012. The site is periodically disked and was last disked in 2018, according to Google imagery.

The Project site is underlain by Atwater loamy sand, 0 to 3 percent slopes and Greenfield sandy loam, 0 to 3 percent slope s.. The Project site is at an elevation of 316–318 feet above mean sea level.

A total of 19 plant species (four native and 15 nonnative) and 14 bird species were observed during the survey (see Table 2, Appendix B).

Search Results
Searching the CNDDB for records of special -status species from the Malaga 7.5 - minute USGS topographic quadrangle and the eight surrounding quadrangles produced 131 records of 42 species (See Table 1, Appendix B). Of those 42 species, 11 were not considered further because they are not CEQA -recognized as special - status species by state or federal regulatory agencies or public interest groups or are considered extirpated in California. Of the re maining 31 species, 17 are known from within 5 miles of the Proje ct site. Of those species only two, pallid bat ( Antrozous pallidus – SSSC) and western mastiff bat (Eumops perotis californicus – SSSC), could occur on or near the Project site (Table 1, Appendix B).

Searching the CNPS inventory of rare and endangered plants of California yielded 12 species (CNPS 2023) which have a CRPR of 1 or 2 (Table 1 , Appendix B). None of these species are expected to occur on or near the Project site due to either (1) lack of habitat, (2) the Project site being outside the current range of the species, or (3) lack of detection during the January 18, 2023 field survey.

Impact Analysis
This section describes the results of the database searches and, using conditions present on the Project site as determined by the reconnaissance survey, provides an analysis of Project impacts on each of six biological evaluation criteria. Each of the biological evaluation criteria were determined to be in one of three categories: less - than-significant impacts with mitigation incorporated, less than significant impacts, and no impacts. Each of the evaluation criteria are discussed below and mitigation measures are provided as needed which, when implemented, reduce impacts to less than significant levels.
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? Less than Significant Impact with Mitigation Incorporated. The Project could adversely affect t hree special-status animal species , burrowing owl, the western mastiff bat and the pallid bat, that could occur on or near the Project site. Construction activities such as excavating, trenching, or using other heavy equipment that disturbs or harms a special -status species could constitute a significant impact. Mitigation Measures BIO-1 and BIO-2, which include preconstruction surveys, are included in the conditions of approval to reduce the potential impacts to less than significant with mitigation incorporated.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
No Impact. There are no riparian habitats or other sensitive natural communities identified in local or regional plans, policies, or regulation or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service in the subject site. Additionally, there are no natural waterways or sensitive natural communities on the subject site or in the immediate vicinity. As such, there is no impact.

c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. There are no state or federally protected wetlands on the subject site. As such, there is no impact.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than Significant Impact with Mitigation Incorporated. The Project could impede the use of nursery sites for native birds protected under the MBTA and CFGC.

Migratory birds are expected to nest on and near the Project site. Construction disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings or otherwise lead to nest abandonment. Disturbance that causes nest abandonment or loss of reproductive effort can be considered “take” under the MBTA and CFGC. Loss of fertile eggs or nesting birds, or any activities resulting in nest abandonment, could constitute a significant effect if the species is particularly rare in the region. Construction activities such as excavating, trenching , and grading that disturb a nesting bird on the Project site or immediately adjacent to the construction zone could constitute a significant impact. Mitigation Measure BIO -3 (below) shall be included in the conditions of approval to reduce the potential effect to less than significant with mitigation incorporated.
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less Than Significant Impact. The City’s General Plan Parks, Open Space , and Schools Element contains several objectives and policies pertaining to the protection of biological resources. Most of the policies pertain to general long-term protection and preservation of biological resources including providing buffers for natural areas (Policy POSS-5-c), implementing habitat restoration where applicable (Policy POSS- 5-f), protection/enhancement of the San Joaquin River area (Policy POSS-6-a, 6-b, 7- a through 7-g). The Project is not located in the vicinity of the San Joaquin River and is surrounded by urban development. The biological resource evaluation prepared for the proposed Project (see Appendix B) determined that no critical habitat occurs on site and the site is lacking habitat for the majority of sensitive species. Mitigation measures BIO-1 through BIO-3 are included to protect species that may have on-site habitat. Ornamental trees associated with previously removed residences are on-site and will be removed as a part of the proposed Project. The removal of these trees are subject to provisions of the City’s Municipal Code regarding trees on public property (Article 3 of Section 13-305 of the City of Fresno Municipal Code) which requires the City to utilize whatever technique, methods and procedures necessary to preserve all trees in the city, when feasible. Through the City of Fresno entitlement process, City staff will ensure that the City’s Municipal Code is being adhered to. There is a less than significant impact.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The PG&E San Joaquin Valley Operation and Maintenance (O&M) Habitat Conservation Plan (HCP) was approved in 2007 and covers portions of nine counties, including Fresno County. This HCP covers PG&E activities which occur as a result of ongoing O&M that would have an adverse impact on any of the 65 covered species and provides incidental take coverage from the US Fish and Wildlife Service and the California Department of Fish and Wildlife. As the proposed Project is not a PG&E activity, the Project is not subject to the provisions of the HCP. There is no other HCP, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan that regulates the Project area. Therefore, there is no impact.

Mitigation Measures
The proposed Project shall implement and incorporate the biological resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated August 7, 2025.

BIO-1 Protect roosting pallid bat and western mastiff bat:

A pre-construction clearance survey shall be conducted by a qualified biologist to ensure that no roosting pallid bats or western mastiff bats will be disturbed during the implementation of the Project. A pre -construction clearance survey shall be conducted no more than 14 days prior to the initiation of construction activities.

During this survey, the qualified biologist shall inspect all potential roosting habitat in and immediately adjacent to the impact areas. If an active roost is found close enough to the construction area to be disturbed by these activities, the qualified biologist shall determine the extent of a construction -free buffer to be established around the roost. If work cannot proceed without disturbing the roosting bats, work will be halted or redirected to other areas until the roost is no longer in use.

BIO-2 Protect burrowing owl
Conduct focused burrowing owl surveys to assess the presence/absence of burrowing owl in accordance with the Staff Report on Burrowing Owl Mitigation and the Burrowing Owl Survey Protocol and Mitigation Guidelines. These involve conducting four pre-construction survey visits.

If a burrowing owl or sign of burrowing owl use (e.g., feathers, guano, pellets) is detected on or within 500 feet of the Project site, and the qualified biologist determines that Project activities would disrupt the owl(s), a construction -free buffer, lim ited operating period, or passive relocation shall be implemented in consultation with the CDFW.

BIO-3 Protect nesting birds:

To the extent practicable, construction shall be scheduled to avoid the nesting season, which extends from February through August. If it is not possible to schedule construction between September and January, pre-construction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no active nests will be disturbed during the implementation of the Project. A pre-construction survey shall be conducted no more than 14 days prior to the initiation of construction activities. During this survey, the qualified biologist shall inspect all potential nest substrates in and immediately adjacent to the impact areas. If an active nest is found close enough to the construction area to be disturbed by these activities, the qualified biologist shall determine the extent of a construction -free buffer to be established around the nest. If work cannot proceed without disturbing the nesting birds, work will be halted or redirected to other areas until nesting and fledging are completed or the nest has otherwise failed for non-construction related reasons.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

V. CULTURAL RESOURCES – Would the project:

a) Cause a substantial adverse
change in the significance of a
historical resource as defined in
Section 15064.5?
X

b) Cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to Section 15064.5?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

c) Disturb any human remains,
including those interred outside of
formal cemeteries?
X

DISCUSSION
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
Less Than Significant Impact with Mitigation. A prehistoric and historic site records and literature search was conducted for the Project area through the Southern San Joaquin Valley Information Center of the California Historical Resources Information System on January 30, 2023 (File RS#23-023). Records indicated that there have been no previous cultural resources studies conducted within the Project area. There has been one previous cultural resource study completed that intersects with the eastern border of the Project area, FR -01800. It should be noted this report was completed approximately 21 years ago and should be considered out of date for current studies. Additionally, there have been seven cultural resource studies conducted within the one-half mile radius: FR00257, 00296, 020 (See Appendix C). A review of the Sacred Lands Inventory by the Native American Heritage Commission (NAHC) was also performed and the results were negative.

There are no previously recorded cultural resources within the Project area.

Furthermore, it is not known if any currently exist there. There have been 11 recorded resources within the one -half mile radius: P -10- 004312, 004762, 004763, 004764, 004765, 004766, 004767, 004769, 004770, 004772, & 005121. These resources consist of historic era single family properties.

Although no cultural or archaeological resources, paleontological resources or human remains have been identified in the Project area to date, the possibility exists that such resources or remains may be discovered during Project site preparation, excavation and/or grading activities. As such, Mitigation Measure CUL-1 shall be implemented to protect undiscovered resources. Adherence to this mitigation measure will result in a less than significant impact with mitigation incorporated.

b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less Than Significant Impact with Mitigation. As discussed in Impact a) above, no surface or recorded evidence of sensitive cultural resources have been recorded .

However, the possibility exists that such resources or remains may be discovered during Project site preparation, excavation and/or grading activities. Mitigation Measure CUL – 1 shall be implemented to ensure that Project will result in less than significant impact with mitigation incorporated.

c) Disturb any human remains, including those interred outside of formal cemeteries?
Less Than Significant Impact with Mitigation . Although no cultural or archaeological resources, paleontological resources or human remains have been identified in the Project area yet, the possibility exists that such resources or remains may be discovered during Project site preparation, excavation a nd/or grading activities.

The discovery of human remains is regulated by California Health and Safety Code Section 7050.5, which states, in part, that:
“(b) In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the humans remains are discovered has determined in accordance with Chapter 10 (commencing with Section 27460) of Part 3 of Division 2 of Title 3 of the Government Code, that the remains are not subject to provisions of law concerning investigation of the circumstances, manner and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. The coroner shall make his or her determination within two working days from the time the person responsible for the excavation, or his or her authorized representative, no tifies the coroner of the discovery or recognition of the human remains.
(c) If the coroner determines that the remains are not subject to his or her authority and the coroner recognizes the human remains to be those of a Native American, or has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.” Incorporation of Mitigation Measure CUL -2 will ensure compliance with California Health and Safety Code Section 7050.5, which would protect buried remains and reduce potential impacts to human remains to less than significant with mitigation incorporated.

Mitigation Measures
The proposed Project shall implement and incorporate the cultural resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated August 7, 2025.

CUL-1 If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study. The qualified historical resources specialist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines and the City’s Historic Preservation Ordinance. If the resources are determined to be unique historical resources as defined under Section 15064.5 of the CEQA Guidelines, measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No furth er grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any historical artifacts recovered as a result of mitigation shall be provided to a City ‐approved institution or person who is capable of providing long ‐term preservation to allow future scientific study.

CUL-2 In the event that human remains are unearthed during excavation and grading activities of any future development Project, all activity shall cease immediately. Pursuant to Health and Safety Code (HSC) Section 7050.5, no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to PRC Section 5097.98(a). If the remains are determined to be of Native American descent, the coroner shall within 24 hours notify the Native American Herit age Commission (NAHC). The NAHC shall then contact the most likely descendent of the deceased Native American, who shall then serve as the consultant on how to proceed with the remains. Pursuant to PRC Section 5097.98(b), upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity , according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the mo st likely descendants regarding their recommendations, if applicable, taking into account the possibility of multiple human remains. The landowner shall discuss and confer with the descendants all reasonable options regarding the descendants' preferences for treatment.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

VI. ENERGY – Would the project:

a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
X

b) Conflict with or obstruct a state
or local plan for renewable energy
or energy efficiency?
X

The energy requirements for the proposed Project were determined using the construction and operational estimates generated from the Modeling Assumptions as noted in the Air Quality, Greenhouse Gas, and Energy Technical Memorandum (Memo) prepared by Johnson Johnson and Miller Air Quality Consulting Services, report date May 15, 2023, revised November 7, 2024, and is the basis for analysis. The Memo is provided in its entirety in Appendix A.

DISCUSSION
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant Impact.

Construction Energy Demand
As summarized in Table 9 and Table 10, the proposed Project would require 15,551 gallons of diesel fuel for construction off-road equipment and 4,956 gallons of gasoline and diesel for on -road vehicles during construction. There are no unusual Project characteristics that would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or other parts of the state. In addition, the overall construction schedule and process is already designed to be efficient in order to avoid excess monetary costs. For example, equipment and fuel are not typically used wastefully due to the added expense associated with renting the equipment, maintaining it, and fueling it. Therefore, it is expected that construction fuel consumption associated with the proposed Project would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the region, and as such, impacts would be less than significant.

Table 9: Construction Off-Road Fuel Consumption
Project Component Construction Activity Fuel Consumption (gallons) Tract No. 6432 Project (On-Site,
Off -road Equipment Use)
Site Preparation 703
Grading 1,100
Building Construction 12,781
Paving 843
Architectural Coating 124
Total 15,551
Note: Totals may not appear to sum correctly due to rounding Source: Energy Consumption Calculations (Attachment C of Appendix A).

Table 10: Construction On-Road Fuel Consumption

Long-Term Energy Demand
Building Energy Demand
Buildings and infrastructure constructed pursuant to the proposed Project would comply with the versions of CCR Titles 20 and 24, including California Green Building Standards (CALGreen), that are applicable at the time that building permits are issued.

The proposed Project is estimated to demand 366,100 kWh of electricity per year (54,915 off-site demand, assuming solar panels will cover approximately 85 percent of the Project’s electricity demand). This would represent an increase in demand for electricity.

It would be expected that building energy consumption associated with the proposed Project would not be any more inefficient, wasteful, or unnecessary than for any other similar buildings in the region. Current state regulatory requirements for new building construction contained in the 2019 CALGreen and Title 24 standards would increase energy efficiency and reduce energy demand in comparison to existing commercial structures, and therefore would reduce actual environmental effects associated with energy use from the proposed Project. Additionally, the CALGreen and Title 24 standards have increased efficiency standards through each update.

Therefore, while the proposed Project would result in increased electricity demand, the electricity and natural gas would be consumed more efficiently and would be typical of existing industrial development.

Based on the above information, the proposed Project would not result in the inefficient or wasteful consumption of electricity, and impacts would be less than significant.

Transportation Energy Demands

The daily vehicular fuel consumption is estimated to be 129.1 gallons of gasoline and diesel fuel combined. Annual consumption is estimated at 47,120 gallons. In addition, the proposed Project would constitute development within an established community and would not be opening a new geographical area for development. As such, the proposed Project would not result in unusually long trip lengths for future residents, visitors, or deliveries to the proposed homes. The Project site is located near other residential land uses and is in close proximity to commercial and public uses. The Project would be well-positioned to accommodate an existing community and provide housing for planned growth. Vehicles accessing the site would be typical of vehicles accessing similar residential uses in the City of Fresno and surrounding areas. For these reasons, it would be expected that vehicular fuel consumption associated with the proposed Project would not be any more inefficient, wasteful, or unnecessary than for any other similar land use activities in the region, and impacts would be less than significant.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact . The Project proposes a tentative tract map that would facilitate the construction and development of 44 new single -family homes, all of which would be built in accordance with all applicable rules and regulations. Compliance with established and applicable regulations would en sure that the Project would not conflict with or obstruct any state or local plan for renewable energy or energy efficiency.

Moreover, compliance with Title 24 standards would ensure that the proposed Project would not conflict with any energy conservation policies related to the proposed Project’s building envelope, mechanical systems, and indoor and outdoor lighting. In addition, the proposed Project would constitute development within an established community. As such, the Project would not be opening a new geographical area for development such that it would not result in unusually long trip lengths for future Project residents.

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

Mitigation Measures
None required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

VII. GEOLOGY AND SOILS – Would the project:

a) Directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:

i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist -Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? Refer
to Division of Mines and Geology
Special Publication 42.

ii) Strong seismic ground
shaking?
X

iii) Seismic-related ground failure,
including liquefaction?
X

iv) Landslides? X

b) Result in substantial soil
erosion or the loss of topsoil?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

d) Be located on expansive soil,
as defined in Table 18 -1-B of the
Uniform Building Code (1994),
creating substantial risks to life or
property?
X

e) Have soils incapable of
adequately supporting the use of
septic tanks or alternative waste
water disposal systems where
sewers are not available for the
disposal of waste water?
X
f) Directly or indirectly destroy a
unique paleontological resource
or site or unique geologic feature?
X

DISCUSSION
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Less Than Significant Impact. According to the Fault Rupture Zones Map prepared by the California Department of Conservation in 2018, the Project site is not located within a Fault ‐Rupture Hazard Area. Moreover, no active faults have been identified within the City of Fresno. The nearest zoned fault to the City is a portion of the Nunez Fault, located approximately 48 miles southwest of the City. Therefore, because no active faults o ccur within the City, impacts associated with fault rupture would be less than significant. ii. Strong seismic ground shaking?

Less Than Significant Impact. It is anticipated that the proposed Project site would be subject to some ground acceleration and ground shaking associated with seismic activity during its design life. The Project site would be engineered and constructed in strict accordance with the ea rthquake resistant design requirements contained in the latest edition of the California Building Code (CBC) for seismic zone III, as well as Title 24 of the California Administrative Code, and therefore would avoid potential s eismically induced hazards on planned structures. Additionally, construction and daily activities of operation will not cause or contribute to strong seismic shaking. The impact of strong seismic ground shaking on the Project would be less than significant.

iii. Seismic-related ground failure, including liquefaction?

Less Than Significant Impact. The potential for soil liquefaction within the City of Fresno ranges from very low to moderate due to the variable density of the subsurface soils and the presence of shallow groundwater . Construction in California is regulated by the California Building Code (CBC) which requires site- specific geotechnical studies which must consider the potential for liquefaction and soil strength loss. The CBC also mandates foundation design that addresses liquefaction impacts and may require ground improvement techniques. The proposed Project will be subject to the requirements set forth in the California Building Code (Fresno Municipal Code Section 11 -101) which would ensure that potential settlement and lateral spread impacts would be less than significant.

iv. Landslides?
Less Than Significant Impact. Landslides are the release of rock, soil, or other debris and its subsequent movement down a slope or hillside. Landslides occur during earthquakes, triggered by the strain induced in soil and rock by ground shaking vibrations, and during non -earthquake conditions, most frequently during the rainy season. Any slope of 15 degrees or greater is susceptible to mud or landslides. The Project area is generally flat in nature, with slopes nearly at zero degrees. As such, the Project site is not susceptible to mud or landslides during non-earthquake conditions during the dry or rainy season.

Additionally, the proposed Project site is not located in an earthquake fault zone as delineated by the 1972 Alquist-Priolo Earthquake Fault Zoning Map Act. No active faults have been mapped within the Project boundaries, so there is no potential for fault rupture. It is anticipated that the proposed Project site would be subject to some ground acceleration and ground shaking associated with seismic activity during its design life. The Project site would be engineered and constructed in strict accordance wi th the earthquake resistant design requirements contained in the latest edition of the California Building Code (CBC) for seismic zone III, as well as Title 24 of the California Administrative Code, and therefore would avoid potential seismically induced h azards on planned structures. The impact of the Project on and from landslides would be less than significant.

b) Result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Construction activities associated with the Project involve ground preparation work for the new residential development, streets, and the associated improvements. These activities could expose barren soils to sources of wind or water, resulting in the potential for erosion and sedimentation on and off the Project site. During construction, nuisance flow caused by minor rain could flow off - site. The City and/or contractor would be required to employ appropriate sediment and erosion control BMPs as part of a Stormwater Pollution Prevention Plan (SWPPP) that would be required in the California National Pollution Discharge Elimination System (NPDES). In addition, soil erosion and loss of topsoil would be minimized through implementation of the SVJAPCD fugitive dust control measures (See Section III).

Once construction is complete , the site will be covered with streets, buildings and landscaping and , the Project would not result in soil erosion or loss of topsoil.

Adherence to local and state requirements will ensure that any impacts are less than significant.

c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off -site landslide, lateral spreading, subsidence, liquefaction, or collapse? Less Than Significant Impac t. As discussed in Impact a) above, the site is not at significant risk from earthquakes, ground shaking, liquefaction, or landslide and is otherwise considered geologically stable. Subsidence is typically related to over - extraction of groundwater from certai n types of geologic formations where the water is partly responsible for supporting the ground surface. However, the City of Fresno is not recognized by the U.S. Geological Service as being in an area of subsidence. 3 Impacts would be less than significant.

d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated), creating substantial direct or indirect risks to life or property?
Less Than Significant Impact. Surface and near-surface soils throughout the city of Fresno consist of varying combinations of clays, silts, sands, gravels, and cobbles.

The Project site is underlain by Atwater loamy sand, 0 to 3 percent slopes and Greenfield sandy loam, 0 to 3 percent slopes (NCRS 2023 ). These soil types are considered well drained with a low ability for water storage, which means they are unlikely to expand.4 Any impacts would be less than significant.

e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. Under the approved City of Fresno General Plan, all development within the City limits is required to install public sewage collection and disposal systems.

Should the site contain a septic system from the previous use, it will be removed in compliance with the Fresno County Public Works and Planning Department regulation, including obtaining a demolition permit. The Project will be required to tie into existing sewer services (See Utilities section for more details). Therefore, there would be no impact.

3 U.S. Geological Service. Areas of Land Subsidence in California. https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html.

Accessed February 2023.
4 USDA Natural Resources Conservation Service. Custom Soil Resource Report for Eastern Fresno Area, California.

f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant Impact with Mitigation . There are no unique geological features on site or in the area. As discussed previously in this document, there are no known cultural or historical resources on or near the site. (See Section V. for more details). Mitigation Measure CUL -1 is included to reduce potential impacts to undiscovered resources. Therefore, there would be a less than significant impact with mitigation.

Mitigation Measures
See CUL-1 in Section V.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

VIII. GREENHOUSE GAS EMISSIONS – Would the project:

a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
X

b) Conflict with an applicable plan,
policy or regulation adopted for
the purpose of reducing the
emissions of greenhouse gases?
X

DISCUSSION
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact. The analysis in the Greenhouse Gas section is based on the Air Quality, Greenhouse Gas, and Energy Technical Memorandum (Memo) prepared by Johnson Johnson and Miller Air Quality Consulting Services, report date May 15, 2023. The Memo is provided in its entirety in Appendix A.

To determine significance, the analysis first quantifies Project-related GHG emissions under a business-as-usual scenario, and then compare s these emissions with those emissions that would occur when all Project-related design features are accounted for, and when compliance with applicable regulatory measures is assumed. The standards and methodology are explained in further detail, below.

Construction
GHG emissions generated during all phases of construction were combined and are shown in Table 11. Neither the City of Fresno nor the SJVAPCD have adopted thresholds of significance for construction related emissions. In addition, GHG emission reduction measures for construction equipment are relatively limited.

Therefore, a standard practice is to amortize construction emissions over the anticipated lifetime of a project, so that GHG reduction measur es will address construction GHG emissions as part of the operational GHG reduction strategies. To evaluate construction-related GHG emissions, the total emissions generated during construction were amortized based on the life of the development (30 years for residential development) and added to the operational emissions to determine the total emissions from the Project, as shown below.

Table 11: Summary of Construction-Generated Greenhouse Gas Emissions Emissions Source MT CO2e per Year
Site Preparation (2023) 18
Grading (2023) 46
Building Construction (2024) 170
Building Construction (2024) 150
Paving (2024) 22
Architectural Coating (2024) 3
Total Construction Duration (2023-2024)
Total Construction MTCO2e 409
Emissions Amortized Over 30 Years1 13.6
Notes:

MT CO2e = metric tons of carbon dioxide equivalent
1 Construction GHG emissions are amortized over the 30-year lifetime of the project.

Source: CalEEMod Output and Additional Supporting Information (Attachment A of Appendix A).

Operations
Operational or long -term emissions occur over the life of the Project. Sources of emissions may include motor vehicles and trucks, energy usage, water usage, waste generation, and area sources, such as landscaping activities and residential woodburning. Operational GHG emissions associated with the proposed Project were estimated using CalEEMod 2020.4.0. Please see the “Assumptions” sections of Attachment A in Appendix A for details regarding assumptions and methodology used to estimate emissions. Complete CalEEMod output files and additional supporting information are also included in Attachment A.

Business-as-Usual Operational Emissions
Operational emissions under the business -as-usual scenario were modeled using CalEEMod 2020.4.0. Modeling assumptions for the year 2005 were used to represent business as usual conditions (without the benefit of regulations adopted to reduce GHG emissions) . CARB and SJVAPCD guidance recommend using regulatory conditions in 2002 -2004 in the baseline scenario to represent conditions as if regulations had not been adopted to allow the effect of projected growth on achieving reduction targets to be clearly defi ned. CalEEMod defaults were used for Project energy usage, water usage, waste generation, and area sources (architectural coating, consumer products, and landscaping). The vehicle fleet mixes were revised to reflect the appropriate residential Project fleet mix for each scenario modeled.

Buildout Year Operational Emissions
Operational emissions for full Project buildout were modeled for the 2023 operational year (full buildout scenario in the earliest operational year) and 2030 operational year scenarios using CalEEMod. CalEEMod assumes compliance with some, but not all, applicable rules and regulations re garding energy efficiency, vehicle fuel efficiency, renewable energy usage, and other GHG reduction policies, as described in the CalEEMod User’s Guide.

The reductions obtained from each regulation and the source of the reduction amount used in the analysis are described below.

The following regulations are incorporated into the CalEEMod emission factors:
• Pavley I and Pavley II (LEV III) motor vehicle emission standards • CARB Medium and Heavy-Duty Vehicle Regulation
• 2005, 2008, 2013, 2016, and 2019 Title 24 Energy Efficiency Standards The following regulations have not been incorporated into the CalEEMod emission factors and require alternative methods to account for emission reductions provided by the regulations:
• Renewables Portfolio Standard (RPS) requirements for year 2030 • Green Building Code Standards (indoor water use)
• California Model Water Efficient Landscape Ordinance (outdoor water) • CalRecycle 75 Percent Initiative (solid waste)
• 2022 Title 24 Energy Efficiency Standards
Title 24 reductions for 2013 and 2016 updates were added to CalEEMod 2016.3.2 and were carried into CalEEMod 2020.4.0. Title 24 reductions for 2019 were added to CalEEMod 2020.4.0; however, the additions do not account for on -site renewable energy that would be included as part of single-family residential projects. Therefore, the CalEEMod mitigation component was used to account for rooftop solar included as part of the proposed Project.

RPS is not accounted for in CalEEMod 2020.4.0. Reductions from RPS for operational years 2030 and beyond are addressed by revising the electricity emission intensity factor in CalEEMod to account for the utility RPS rate forecast for 2030. The utilities will be required by SB 100 to increase the use of renewable energy sources to 60 percent by 2030. Data for PG&E was used to estimate a revised CO2 intensity factor for use in the modeling.

Reductions in emissions from solid waste are based on the County of Fresno achieving the CalRecycle 75 Percent Initiative by 2020 compared with a 50 percent baseline for 2005. No additional reductions were accounted for in the emission estimates prepared for the Project.

Energy savings from water conservation resulting from the Green Building Code Standards for indoor water use and California Model Water Efficient Landscape Ordinance for outdoor water use are not included in CalEEMod. The Water Conservation Act of 2009 mandates a 20 percent reduction in urban water use that is implemented with these regulations. Benefits of the water conservation regulations are applied in the CalEEMod mitigation component.

GHG reductions from some design features and compliance with regulations that are not otherwise accounted for can be quantified in CalEEMod. Note that CalEEMod nominally treats these design elements and conditions as “mitigation measures,” despite their inclusion in the project description. Therefore, reported operational emissions are considered to represent unmitigated project conditions.

Operational GHG emissions by source are shown in Table 1 2 for the buildout year scenarios. Full buildout of the Project was modeled in the 2023 operational year, as earliest occupancy is anticipated to occur as early as 2023.

Table 12: Unmitigated Project Operational GHG Emissions (Buildout Year Scenario) Emission Source
Emissions (MT CO2e per year)
Business as Usual
Total Emissions (MT
CO2e per year)
Buildout Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 19.73 19.72
Energy 194 62
Mobile (On-Road Vehicles) 566 408
Waste 23 17
Water 10 5
Amortized Construction Emissions 14 14
Total (MT CO2e per year) 827 526
Reduction from BAU (MT CO2e per year) 301
Percent Reduction 36.4%
Significance Threshold 29%
Exceeds Either Significance Threshold? No
MT CO2e = metric tons of carbon dioxide equivalent.

Totals were calculated using unrounded emissions; totals may not appear to sum exactly due to rounding.

Source of Significance Threshold: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Website:
https://www.valleyair.org/transportation/GAMAQI2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 1, 2023.

Source of Business-as-Usual Emissions: CalEEMod output for the 2023 BAU scenario (see Attachment A of Appendix A).

Source of Buildout Year Emissions: CalEEMod output for project buildout in 2023 (Attachment A of Appendix A).

As shown in Table 12, the proposed Project’s total GHG annual emissions would not exceed applicable thresholds of significance in either scenario analyzed.

The 2030 operational year scenarios are summarized in Table 1 3. As previously noted, the 2030 operational year was used to assess the Project’s consistency with the SB 32 2030 target. The 2017 Scoping Plan addresses a future GHG goal and remains relevant to assess potential impacts from the proposed Project, which is expected to be built and operational prior to 2030.

Table 13: Unmitigated Project Operational GHG Emissions (Year 2030 Scenario) Emission Source
Emissions (MT CO2e per year)
Business as Usual
Total Emissions (MT
CO2e per year)
Buildout Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 19.73 19.72
Energy 194 62
Mobile (On-Road Vehicles) 562 333
Waste 23 17
Water 10 5
Amortized Construction Emissions 14 14
Total (MT CO2e per year) 823 451
Reduction from BAU (MT CO2e per year) 372
Percent Reduction 45.2%
Significance Threshold1 29%
Exceeds Either Significance Threshold? No
MT CO2e = metric tons of carbon dioxide equivalent.

Totals were calculated using unrounded emissions; totals may not appear to sum exactly due to rounding. 1 Adjusted threshold to account for 2017 Scoping Plan Update 40 percent reduction goal by 2030.

Source of Business-as-Usual Emissions: CalEEMod output for the 2030 BAU scenario (see Attachment A of Appendix A).

Source of 2030 Emissions: CalEEMod output for the year 2030 (Attachment A of Appendix A).

As shown in Table 1 2 and Table 1 3, the Project would achieve a 36.4 percent reduction from BAU at Project buildout (2023) and a 45.2 percent reduction from BAU by the year 2030 with adopted regulations and design features incorporated. These amounts both exceed the 29 percent reduction required by the SJVAPCD threshold, and go beyond the required 21.7 percent average reduction from all GHG emission sources to meet the AB 32 targets. CARB originally identified a reduction of 29 percent from business as usual as needed to achieve AB 32 targets. The 2008 recession and slower growth in the years since 2008 have reduced the growth forecasted for 2020 and the amount needed to be reduced to achieve 1990 levels as required by AB 32 , so the target was revised to 21.7 percent.

The 36.4 percent reduction from BAU is 14.7 percent beyond the average reduction required by the state from all sources to achieve the AB 32 2020 target (and 7.4 percent beyond the SJVAPCD’s threshold). This surplus addresses the Supreme Court’s concern in the Newhall case that new development must exceed average reductions to meet its fair share of emission reductions.

By 2030, the proposed Poject would achieve a 45.2 percent reduction from BAU or

23.5 percent above the 16.2 percent reduction necessary to meet the AB 32 reduction target.

The Project’s occupancy is anticipated to begin as early as 202 5; thus, additional analysis is provided to show consistency with post-2020 state legislative GHG goals.

The SB 32 goal of 40 percent below 1990 emission levels by 2030 is the target established by the 2017 Scoping Plan Update.

The 2017 Scoping Plan includes strategies that are not incorporated in the analysis above. Many measures that are likely to proceed include zero net energy buildings in future updates to Title 24 and enhanced motor vehicle fuel efficiency standards beyond 2025. The 2017 Scoping Plan identified an emission limit of 260 million metric tons of carbon dioxide equivalents (MMTCO2e). The 2030 BAU Inventory is estimated to be 392 MMTCO2e. The 2017 Scoping Plan identified that the bulk of its reductions would come from electric power, industrial fuel combustion, and transportation. The continuance of Cap and Trade would provide additional reductions. Although the 2017 Scoping Plan largely relies on state actions to achieve the GHG emissions limit, CARB considers local government partners in achieving the state’s goals for reducing GHG emissions. The 2017 Scoping Plan suggests that all new land use development implement feasible measures to reduce GHG emissions, however, it does not define feasible measures nor assign a required reduction amount to new development. A fair share quantitative threshold based on the 2017 Scoping Plan is not presently feasible as the nexus between a project’s contribution and its fair share mitigation is not well defined.

Based on the 36.4 percent reduction from BAU for Project buildout in the earliest operational year (2025), the proposed Project would not have a significant impact on GHG emissions as it would meet the SJVAPCD’s threshold of 29 percent and exceed the CARB’s 21.7 percent reduction necessary from all sources to meet the AB 32 emissions limit.

For the year 2030, the Project achieves a 45.2 percent reduction from BAU, which demonstrates substantial progress towards achieving the 2030 target.

Regarding the years 2045 and 2050, there have been Executive Orders issued to address carbon neutrality and GHG reduction targets, respectively for those years, however, there are no existing GHG reduction plans that specifically address those Orders. Historically, the state would take the lead in developing regulatory and market measures to achieve the required reductions. The proposed Project would participate in the reductions through adherence with regulations and continued improvements to the motor vehicle efficiencies accessing the Project site. Studies have shown that in order to meet the 2050 targets, aggressive pursuit of technologies in the transportation and energy sectors, including electrification and the decarbonization of fuel, will be required. Because of the technological shifts required and the unknown parameter s of the regulatory framework in 2050, quantitatively analyzing the proposed Project’s impacts further relative to the 2050 goals is speculative for purposes of CEQA.

Conclusion
In summary, the proposed Project meets the required 29 percent below BAU guidance provided by the SJVAPCD. Furthermore, analysis of the proposed Project shows substantial reductions in the year 2030 , which is evidence that it would not inhibit the state’s progress in achieving the 2030 GHG emissions target or emissions targets beyond 2030. The GHG emissions impact would be less than significant with respect to Consideration #1 and #2.

b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less Than Significant Impact . The following analysis assesses the proposed Project’s compliance with Consideration No. 3 regarding consistency with adopted plans to reduce GHG emissions. The proposed Project is also assessed for its consistency with CARB’s adopted Scoping Plans, which include the 2008, 2017, and 2022 Scoping Plans.

The combined effect of this successful effort is that the State projects that it will achieve continued progress toward meeting post -2020 targets. Governor Brown, in the introduction to Executive Order B-30-15, stated “California is on track to meet or exceed the current target of reducing greenhouse gas emissions to 1990 levels by 2020, as established in the California Global Warming Solutions Act of 2006 (AB 32).”

Consistency with SB 32 and the 2017 Scoping Plan
The 2017 Climate Change Scoping Plan Update (2017 Scoping Plan) includes the strategy that the State intends to pursue to achieve the 2030 targets of Executive Order S ‐3‐05 and SB 32. Although CARB adopted the 2022 Scoping Plan in December 2022 that addresses long -term GHG goals set forth by AB 1279,17 the 2017 Scoping Plan addresses a future GHG goal and remains relevant to the proposed Project. The 2017 Scoping Plan includes the following summary of its overall strategy for reaching the 2030 target:
• SB 350
o Achieve 50 percent Renewables Portfolio Standard (RPS) by 2030. o Doubling of energy efficiency savings by 2030.
• Low Carbon Fuel Standard (LCFS)
o Increased stringency (reducing carbon intensity 18 percent by 2030, up from 10 percent in 2020).
• Mobile Source Strategy (Cleaner Technology and Fuels Scenario) o Maintaining existing GHG standards for light‐ and heavy‐duty vehicles. o Put 4.2 million zero‐emission vehicles (ZEVs) on the roads. o Increase ZEV buses, delivery and other trucks.
• Sustainable Freight Action Plan to Improve freight system efficiency. o Maximize use of near ‐zero emission vehicles and equipment powered by renewable energy.
o Deploy over 100,000 zero‐emission trucks and equipment by 2030. • Short‐Lived Climate Pollutant (SLCP) Reduction Strategy o Reduce emissions of methane and hydrofluorocarbons 40 percent below 2013 levels by 2030.
o Reduce emissions of black carbon 50 percent below 2013 levels by 2030. • SB 375 Sustainable Communities Strategies
o Increased stringency of 2035 targets.
• Post‐2020 Cap‐and‐Trade Program
o Declining caps, continued linkage with Québec, and linkage to Ontario, Canada. o CARB will look for opportunities to strengthen the program to support more air quality co -benefits, including specific program design elements. In Fall 2016, CARB staff described potential future amendments including reducing the offset usage limit, redesigning the allocation strategy to reduce free allocation to support increased technology an d energy investment at covered entities and reducing allocation if the covered entity increases criteria or toxics emissions over some baseline.
• By 2018, develop Integrated Natural and Working Lands Action Plan to secure California’s land base as a net carbon sink.

Table 14 provides an analysis of the Project’s consistency with the 2017 Scoping Plan Update measures.

Table 14: Consistency with SB 32 2017 Scoping Plan Update Scoping Plan Measure Project Consistency
SB 350 50% Renewable Mandate. Utilities subject
to the legislation will be required to increase their
renewable energy mix from 33% in 2020 to 50% in
2030. (The requirement is now 60% in 2030 per SB
100.)
Consistent: The Project will purchase electricity from a utility subject to the SB 350 Renewable Mandate.

SB 350 Double Building Energy Efficiency by
2030. This is equivalent to a 20 percent reduction
from 2014 building energy usage compared to
current projected 2030 levels.

Not Applicable . This measure applies to existing
buildings. New structures, including new single -family homes, are required to comply with Title 24 Energy
Efficiency Standards that are expected to increase in
stringency until residential housing achieves zero net
energy. The Project consists of the construction of 44 new single-family homes and does not include renovations to existing structures.

Low Carbon Fuel Standard. This measure requires
fuel providers to meet an 18 percent reduction in
carbon content by 2030.

Consistent. Vehicles accessing the Project site will use fuel containing lower carbon content as the fuel standard is implemented.

Mobile Source Strategy (Cleaner Technology and
Fuels Scenario). Vehicle manufacturers will be
required to meet existing regulations mandated by
the LEV III and Heavy ‐Duty Vehicle programs. The
strategy includes a goal of having 4.2 million ZEVs
on the road by 2030 and increasing numbers of ZEV
trucks and buses.

Consistent. Project residents can be expected to
purchase increasing numbers of more fuel efficient and
zero emission cars and trucks each year. The CALGreen
Code requires electrical service in new single -family
housing to be EV charger -ready. In addition, home
deliveries will be made by increasing numbers of ZEV
delivery trucks.

Sustainable Freight Action Plan. The plan’s target
is to improve freight system efficiency 25 percent by
increasing the value of goods and services produced
from the freight sector, relative to the amount of
carbon that it produces by 2030. This would be
achieved by deploying over 100,000 freight vehicles
and equipment capable of zero emission operation
and maximize near ‐zero emission freight vehicles
and equipment powered by renewable energy by
2030.

Not Applicable . The measure applies to owners and
operators of trucks and freight operations. The Project is residential in nature and would not support freight
operations. However, home deliveries are expected to be made by increasing number of ZEV delivery trucks.

Scoping Plan Measure Project Consistency
Short‐Lived Climate Pollutant (SLCP) Reduction
Strategy. The strategy requires the reduction of
SLCPs by 40 percent from 2013 levels by 2030 and
the reduction of black carbon by 50 percent from
2013 levels by 2030.

Consistent. The Project will only include natural gas
hearths that produce very little black carbon compared
with wood burning fireplaces and heaters in -line with the SJVAPCD’s Guidance for Assessing and Mitigating Air
Quality Impacts mitigation measures.1
SB 375 Sustainable Communities Strategies.

Requires Regional Transportation Plans to include a
sustainable communities strategy for reduction of per
capita vehicle miles traveled.

Not applicable. The Project is for tentative tract map to allow for the construction and development of 44 single - family homes and does not include the development of a
regional transportation plan. However, the Project will provide residential development to increase development densities, which facilitates reductions to VMT.

Post‐2020 Cap‐and‐Trade Program. The Post 2020
Cap‐and‐Trade Program continues the existing
program for another 10 years. The Cap ‐and‐Trade
Program applies to large industrial sources such as
power plants, refineries, and cement manufacturers.

Consistent. The post ‐2020 Cap ‐and‐Trade Program
indirectly affects people who use the products and
services produced by the regulated industrial sources
when increased cost of products or services (such as
electricity and fuel) are transferred to the consumers. The Cap‐and‐Trade Program covers the GHG emissions
associated with electricity consumed in California, whether generated in ‐state or imported. Accordingly, GHG
emissions associated with CEQA projects’ electricity
usage are covered by the Cap -and‐Trade Program. The
Cap‐and‐Trade Progr am also covers fuel suppliers
(natural gas and propane fuel providers and transportation fuel providers) to address emissions from such fuels and from combustion of other fossil fuels not directly covered at large sources in the program’s first compliance period.

Natural and Working Lands Action Plan. CARB is
working in coordination with several other agencies
at the federal, state, and local levels, stakeholders,
and with the public, to develop measures as outlined
in the Scoping Plan Update and the governor’s
Executive Order B ‐30‐15 to reduce GHG emissions
and to cultivate net carbon sequestration potential for California’s natural and working land.

Not Applicable . The Project is residential development and will not be considered natural or working lands.

Source: California Air Resources Board (CARB). 2017. The 2017 Climate Change Scoping Plan Update. January 20.

Website: https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf. August 1, 2022. 1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMA. Accessed May 1, 2023.

Consistency Regarding GHG Reduction Goals for 2050 under Executive Order S‐3‐ 05 and GHG Reduction Goals for 2045 under the 2022 Scoping Plan CARB adopted the 2022 Scoping Plan in December 2022 that addresses long-term GHG goals set forth by AB 1279.18 The 2022 Scoping Plan outlines the State’s pathway to achieve carbon neutrality and an 85 percent reduction in 1990 emissions goal by 2045.

In the 2022 Scoping Plan, CARB advocates for compliance with a local GHG reduction strategy consistent with CEQA Guidelines section 15183.5.

To achieve carbon neutrality by 2045, the 2022 Scoping Plan contains GHG reductions, technology, and clean energy mandated by statutes, reduction of short -lived climate pollutants, and mechanical carbon dioxide capture and sequestration actions. Table 15 contains a list of key GHG emission reduction actions and strategies from the 2022 Scoping Plan and assesses the Project’s consistency with these actions and strategies.

Table 15: Project Consistency with 2022 Scoping Plan
2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
Transportation Technology
• Achieve 100 percent ZEV sales of light duty
vehicles by 2035 and medium heavy-duty vehicles
by 2040.
• Achieve 20 percent zero-emission target for the
aviation sector.
• Develop a rapid and robust network of ZEV
refueling infrastructure to support needed
transition to ZEVs.
• Ensure that the transition of ZEV technology is
affordable for low-income households and
communities of color and meets the needs of
communities and small business.
• Prioritize incentive funding for heavy-duty ZEV
technology deployment in regions of the state with
the highest concentrations of harmful criteria and
toxic air contaminant emissions.
• Promote private investment in the transition to
ZEV technology, undergirded by regulatory
certainty such as infrastructure credits in the Low
Carbon Fuel Standard for hydrogen and electricity
and hydrogen station grants from the CEC’s
Clean Transportation Program pursuant to
Executive Order B-48-18.
• Evaluate and continue to offer incentives similar to
those through FARMER, Carl Moyer, the Clean
Fuel Reward Program, the Community Air
Protection Program, the Low Carbon
Transportation, including CORE. Where feasible,
prioritize and increase funding for clean
transportation equity programs.
• Continue and accelerate funding support for zero
emission vehicles and refueling infrastructure
through 2030 to ensure the rapid transformation of
the transportation sector.

State
agencies and
local
agencies
No Conflict: Vehicles must transition to zero-emission
technology to decarbonize the transportation sector.

Executive Order N -79-20 reflects the urgency of
transitioning to zero emission vehicles (ZEVs) by
establishing target dates for reaching 100 percent ZEV
sales or fleet transitions to ZEV technology. EO N-79-
20 calls for 100 percent ZEV sales of new light -duty
vehicles by 2035. The Advanced Clean Cars II
regulation fulfills this goal and serves as the primary mechanism to help deploy ZEVs. A number of existing
incentive programs also support this transition,
including the Clean Cars 4 All Program. EO N -79-20
also sets targets for transitioning the medium - and
heavy-duty fleet to zero emissions: by 2035 for
drayage trucks and by 2045 for buses and heavy-duty
long-haul trucks where feasible. Replacing heavy-duty
vehicles with ZEV technology will substantially reduce
GHG emissions and diesel PM emissions in
communities adjacent to ports, distribution centers,
and highways.

EO N -79-20 sets an off -road equipment target of
transitioning the entire fleet to ZEV technology by
2035, where feasible. There are a number of funding
sources available to support this transition, including FARMER, Carl Moyer, and Community Air Protection
Incentives; as well as Low Carbon Transportation
Incentives, including the Clean Off -Road Equipment
program.

Refueling infrastructure is a crucial component of
transforming transportation technology. Electric
vehicle chargers and hydrogen refueling stations must
become easily accessible for all drivers to support a
wholesale transition to ZEV technology. Deployme nt
of ZEV refueling infrastructure is currently supported
by a number of existing State public funding
mechanisms.

Intrastate aviation relies on internal combustion engine technology today, but battery -electric and hydrogen
fuel cell aviation applications are in development,
along with sustainable aviation fuel.
2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
The proposed Project consists of the construction and
operations of 44-lot single family detached residential rental unit development on approximately 3.68 net
acres. GHG emissions generated by Project-related
vehicle travel would benefit from the above regulations and programs, and mobile source emissions
generated by the proposed Project would be reduced
as automobiles and truck fleets are transitioned to ZEV technology. Additionally, the Project would include EV
charging infrastructure in accordance with regulations
which would support the transition to EV technology.

Thus, the Project would not conflict with actions under the transportation technology sector.

Transportation Fuels
• Accelerate the reduction and replacement of fossil
fuel production and consumption in California.
• Incentivize private investment in new zero-carbon
fuel production in California.
• Incentivize the transition of existing fuel
production and distribution assets to support
deployment of low- and zero-carbon fuels while
protecting public health and the environment.
• Invest in the infrastructure to support reliable
refueling for transportation such as electricity and
hydrogen refueling.
• Evaluate and propose, as needed, changes to
strengthen the Cap-and-Trade Program.
• Initiate a public process focused on options to
increase the stringency and scope of the LCFS:
- Evaluate and propose accelerated carbon
intensity targets pre-2030 for LCFS.
- Evaluate and propose further declines in
LCFS post-2030 carbon intensity targets to
align with this 2022 Scoping Plan.
- Consider integrating opt-in sectors into the
program.
- Provide capacity credits for hydrogen and
electricity for heavy-duty fueling.
• Monitor for and ensure that raw materials used to
produce low-carbon fuels or technologies do not
result in unintended consequences.

State
agencies
and local
agencies
No Conflict: Mobile source emissions generated by
the proposed residential Project would be reduced
with implementation of the wider use of zero-carbon
fuels consistent with reduction of GHG emissions
under AB 1279. Additionally, the Project would utilize
energy efficiency appliances and equipment and will
meet the applicable energy standards in the Title 24
Building Energy Efficiency Standards and CALGreen
Code, which will limit the amount of fossil fuel use
and GHG emissions. During operations the Project
will provide improvements to the pedestrian network
by complying with local building codes and
incorporating paved areas and landscaping.

Considering the actions and strategies require action
by the state and local agencies, Project consistency
is determined by assessing whether the Project
would conflict with the actions needed in the
transportation fuels sector. As supported by the
information provided above, the Project would not
conflict with actions in the transportation fuels sector.

Vehicles Miles Traveled
• Achieve a per capita VMT reduction of at least 25
percent below 2019 levels by 2030 and 30
percent below 2019 levels by 2045.
• Reimagine new roadway projects that decrease
VMT in a way that meets community needs and
reduces the need to drive.
• Invest in making public transit a viable alternative
to driving by increasing affordability, reliability,
coverage, service frequency, and consumer
experience.
• Implement equitable roadway pricing strategies
based on local context and need, reallocating
revenues to improve transit, bicycling, and other
sustainable transportation choices.
• Expand and complete planned networks of high-
quality active transportation infrastructure.

State
agencies and
local
agencies
No Conflict: VMT reductions will play a crucial role in reducing overall transportation energy demand and
achieving California’s climate, air quality, and equity goals. CARB did not set regulatory limits on VMT in the 2022 Scoping Plan because the authority to reduce
VMT largely lies with state, regional, and local
transportation, land use, and housing agencies, along
with the Legislature and its budgeting choices.

The Project-specific VMT impacts were addressed
under the transportation section of the CEQA
document. The VMT analysis demonstrates that the
Project-generated trip estimates fall below the
thresholds for analysis of VMT or for requiring the
preparation of a traffic impact study. As such, impacts 2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
• Channel the deployment of autonomous vehicles,
ride-hailing services, and other new mobility
options toward high passenger-occupancy and
low VMT-impact service models that complement
transit and ensure equitable access or priority
populations.
• Streamline access to public transportation through
programs such as the California Integrated Travel
Project.
• Ensure alignment of land use, housing,
transportation, and conservation planning in
adopted regional plans and local plans (e.g.,
general plans, zoning, and local transportation
plans), and develop tools to support
implementation of these plans.
• Accelerate infill development and housing
production at all affordability levels in
transportation-efficient places, with a focus on
housing for lower income residents.
related to VMT were found to be less than significant .

As such, the Project would not conflict with actions in the vehicle miles traveled sector.

Clean Electricity Grid
• Per SB 350, double statewide energy efficiency
savings in electricity and fossil gas end uses by
2030, through a combination of energy efficiency
and fuel substitution actions.
• Use long-term planning processes to support grid
reliability and expansion of renewable and zero-
carbon resource and infrastructure deployment.
• Complete systemwide and local reliability
assessments. Such assessments should be
completed before state agencies update their
electricity sector GHG targets.
• Prioritize actions to mitigate impacts to electricity reliability and affordability and provide sufficient
flexibility in the state’s decarbonization roadmap
for adjustments as may be needed.
• Facilitate long lead-time resource development.
• Continue coordination between energy agencies
and energy proceedings to maximize
opportunities for demand response.
• Continue to explore the benefits of regional
markets to enhance decarbonization, reliability,
and affordability.
• Address resource build-out challenges, including
permitting, interconnection, and transmission
network upgrades.
• Explore new financing mechanisms and rate
designs to address affordability.
• Per SB 100 and SB 1020, achieve 90 percent, 95
percent, and 100 percent renewable and zero-
carbon retail sales by 2035, 2040, and 2045,
respectively.
• Evaluate and propose, as needed, changes to
strengthen the Cap-and-Trade Program.
• Target programs and incentives to support and
improve access to renewable and zero-carbon
energy projects (e.g., rooftop solar, community
owned or controlled solar or wind, battery storage,
and microgrids) for communities most at need,
State
agencies and
local
agencies
No Conflict: Decarbonizing the electricity sector
depends on both using energy more efficiently and
replacing fossil-fueled generation with renewable and
zero carbon resources, including solar, wind, energy
storage, geothermal, biomass, and hydroelectric
power. The RPS Program and the Cap-and-Trade
Program continue to incentivize dispatch of
renewables over fossil generation to serve state
demand.

SB 100 increased RPS stringency to require 60
percent renewables by 2030 and for California to
provide 100 percent of its retail sales of electricity
from renewable and zero-carbon resources by 2045.

Furthermore, SB 1020 has added interim targets to
SB 100’s policy framework to require renewable and
zero-carbon resources to supply 90 percent of all
retail electricity sales by 2035 and 95 percent of all
electricity retail sales by 2040; establish a planning
goal of at least 20 GW of offshore wind by 2045; and
that state agencies plan for an energy transition that
avoids the need for new fossil gas capacity to meet
California’s long-term energy goals.

California also continues to advance its appliance
and building energy efficiency standards to reduce
growth in electricity consumption and meet the SB
350 goal to double statewide energy efficiency
savings in electricity and fossil gas end uses by 2030.

Increased transportation and building electrification
and continued policy commitment to behind-the-
meter solar and storage will continue to drive growth
of microgrids and other distributed energy resources.

Continued transition to renewable and zero -carbon
electricity resources will enable electricity to become a zero-carbon substitute for fossil fuels. This
transformation will drive investments in a large fleet of generation and storage resources but will also require
significant transmission to accommodate these new
2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
including frontline, low-income, rural, and
indigenous communities.
• Prioritize public investments in zero-carbon
energy projects to first benefit the most overly
burdened communities affected by pollution,
climate impacts, and poverty.
capacity additions. Resources such as storage and
demand-side management are essential to maintain
reliability with high concentrations of renewables.

Hydrogen produced from renewable resources and
renewable feedstocks can serve a dual role as a low -
carbon fuel for existing combustion turbines or fuel
cells, and as energy storage for later use.

The proposed Project would utilize energy efficiency
appliances and equipment and will meet the applicable
energy standards in the Title 24 Building Energy
Efficiency Standards and CALGreen Code. In addition,
the Project would include on-site renewable energy in
the form of solar panels and would not have a
significant impact due to wasteful, inefficient, or
unnecessary consumption of energy resources during
Project construction or operations (see Energy
analysis). As such, the Project would not conflict wi th actions under the clean electricity grid sector
Sustainable Manufacturing and Buildings
• Maximize air quality benefits using the best
available control technologies for stationary
sources in communities most in need.
• Implement SB 905, which requires CARB to
create the Carbon Capture, Removal, Utilization,
and Storage Program to evaluate, demonstrate,
and regulate carbon capture, utilization, and
sequestration and carbon dioxide removal
projects and technology.
• End fossil gas infrastructure expansion for newly
constructed buildings.
• Develop a net-zero cement strategy to meet SB
956 targets for the GHG intensity of cement use.
• Leverage energy efficiency and low carbon
hydrogen programs.
• Prioritize most vulnerable residents with the
majority of funds in the new $922 million Equitable
Building Decarbonization program.
• Achieve three million all-electric and electric-ready homes by 2030 and seven million by 2035 with six
million heat pumps installed by 2030.
• Adopt a zero-emission standard for new space
and water heaters sold in California beginning in
2030.
• Implement biomethane procurement targets for
investor-owned utilities as specified in SB 1440.

State
agencies and
local
agencies
No Conflict : The 2022 Scoping Plan reduces
dependence on fossil gas in the industrial and building sectors by transitioning substantial energy demand to
alternative fuels. Combustion of fossil gas, other
gaseous fossil fuels, and solid fossil fuels provide
energy to meet three broad industry needs: electricity, steam, and process heat. Non -combustion emissions
result from fugitive emissions and from the chemical
transformations inherent to some manufacturing
processes. Decarbonizing industrial facilities depends
upon displacing fossil fuel use with a mix of
electrification, solar thermal heat, biomethane, low- or zero-carbon hydrogen, and other low -carbon fuels to
provide energy for heat and reduce combustion
emissions. Emissions also can be reduced by
implementing ene rgy efficiency measures and using
substitute raw materials that can reduce energy
demand and some process emissions. Some
remaining combustion emissions and some non -
combustion CO 2 emissions can be captured and
sequestered. This sector has a continuing demand for
fossil gas due to lack of non -combustion
technologically feasible or cost -effective alternatives for certain industrial sectors. Microgrids powered by
renewable resources and with battery storage are
emerging as a key enabler of electrification and
decarbonization at industrial facilities.

The Project is residential in nature and would not
include industrial uses. The Project would utilize
energy-efficient appliances in the proposed
residences. The Project would also meet the
applicable energy standards in the Title 24 Building
Energy Efficiency Standards and CALGreen Code.

During operations, the Project will provide
improvements to the pedestrian network. As such, the
2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
Project would not conflict with sustainable
manufacturing buildings industry sector.

Carbon Dioxide Removal and Capture Sector
• Implement SB 905.
• Achieve the 85 percent reduction in anthropogenic
sources below 1990 levels per AB 1279 by
incorporating Carbon Capture and Storage (CCS)
into sectors and programs beyond transportation.
• Evaluate and propose the role for CCS in cement
decarbonization and as part of hydrogen peroxide
pathways.
• Explore carbon capture application for zero-
carbon power for reliability needs per SB 100.

State
agencies and
local
agencies
No Conflict : CARB has acknowledged that the
deployment of carbon dioxide removal to
counterbalance hard -to-abate residual emissions is
needed to achieve net zero GHG emissions. Modeling
shows that emissions from the AB 32 GHG Inventory
sources will continue to persist even if all fossil related combustion emissions are phased out. Carbon dioxide
removal includes both sequestration in natural and
working lands and mechanical approaches such as:
direct air capture, CCS (which is carbon capture from
anthropogenic point sources involves capturing
carbon from a smokestack of an emitting facility), or
direct air capture (which captures carbon directly from the atmosphere).

The Project would not conflict with measures to
increase carbon dioxide removal and capture. As
such, the Project would not conflict with action under
the carbon dioxide removal and capture sector.

Short-Lived Climate Pollutants (Non - Combustion
Gases)
• Install anaerobic digesters to maximize air and
water quality protection, maximize biomethane
capture, and direct biomethane to specific sectors.
• Increase alternative manure management
projects.
• Expand markets for products made from organic
waste.
• Pursuant to SB 1137, develop leak detection and
repair plans for facilities in health protection
zones, implement emission detection system
standards, and provide public access to emissions
data.
• Convert large HFC emitters to the lowest practical
global warming potential (GWP) technologies.

State
agencies and
local
agencies
No Conflict: SLCPs include black carbon, methane,
and fluorinated gases. Dairy and livestock are the
largest source of methane emissions followed by
landfills. Black Carbon (soot) comes primarily from
transportation, specifically heavy -duty vehicles
followed by fuel combustion for residential,
commercial, and industrial uses.

The Project would not conflict with SLCP dairy and
livestock methane sector actions in the 2022 Scoping
Plan. The proposed Project consists of the
construction and operations of 44-lot single family
detached residential rental unit development on
approximately 3.68 net acre s and does not include
dairy or livestock. Furthermore, the Project does not
include a new landfill or any oil or gas production,
processing, or storage facilities. The Project would
comply with the 2022 CalGreen Code for energy
efficiency and use of high-GWP refrigerants and would
not conflict with these policies or actions. Considering the information presented above, the Project would not
conflict with SLCP sector actions in the 2022 Scoping
Plan.

Natural and Working Lands
• Implement AB 1757 and SB 27.
• Implement the Climate Smart Strategy.
• Accelerate the pace and scale of climate smart
forest management to at least 2.3 million acres
annually by 2025.

State
agencies
and local
agencies
No Conflict: AB 1757 requires state agencies to set
targets for natural carbon removal and emissions
reductions on natural and working lands. AB 1757 is
expected to catalyze natural carbon sequestration in
California by: requiring California Natural Resources
Agency and CARB to establish targets for
sequestration on natural and working lands for 2030,
2038, and 2045; ensuring that natural sequestration
2022 Scoping Plan Actions and Strategies
Responsible
Party(ies) Project Consistency
• Accelerate the pace and scale of healthy soils
practices to 80,000 acres annually by 2025,
conserve at least 8,000 acres of annual crops
annually, and increase organic agriculture to 20
percent of all cultivated acres by 2045.
• Restore 60,000 acres of Delta wetlands annually
by 2045.
• Increase urban forestry investment annually by
200 percent, relative to business as usual.
projects have rigorous measurement and verification;
and establishing an expert committee to advise state
agencies on modeling and implementation.

SB 27 is designed to accelerate the removal of carbon
from the atmosphere by expanding California’s carbon
removal capability (i.e. sequestration) and improve the carbon retention of the state’s natural and working
lands.

The Project is residential in nature and would not
include natural working lands. As such, the Project
would not conflict with natural and working strategies
under the 2022 Scoping Plan.

Source: California Air Resources Board (CARB). 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. November 16. Website:
https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp_1.pdf. Accessed November 3, 2024.

As shown above in Table 15, the Project would not conflict with relevant 2022 Scoping Plan actions or strategies that aim to achieve the State’s climate target of reducing anthropogenic emissions to 85 percent below 1990 levels and achieving carbon neutrality by 2045.

Conclusion
Taking into account the proposed Project’s emissions, Project design features detailed in Table 15, and the progress being made by the State towards reducing emissions in key sectors such as transportation, industry, and electricity, the Project would be consistent with State GHG Plans and would further the State’s goals of reducing GHG emissions to 1990 levels by 2020, 40 percent below 1990 levels by 2030 and carbon neutral by 2045, and does not obstruct their attainment. The proposed Project’s GHG impacts would be less than significant.

Mitigation Measures
None Required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

IX. HAZARDS AND HAZARDOUS MATERIAL – Would the project:

a) Create a significant hazard to
the public or the environment
through the routine transport, use,
or disposal of hazardous
materials?
X

b) Create a significant hazard to
the public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of hazardous
materials into the environment?
X

c) Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile of
an existing or proposed school?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) For a project located within an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project result in a safety hazard for
people residing or working in the
project area?
X

f) Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
X

g) Expose people or structures,
either directly or indirectly, to a
significant risk of loss, injury or
death involving wildland fires?
X

DISCUSSION
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less Than Significant Impact. Construction of the Project would require the use and transport of hazardous materials, including fuels, oils, and other chemicals (e.g., paints, lead, adhesives, etc.) typically used during construction. It is likely that these hazardous materials and vehicles would be stored by the contractor(s) on-site during construction activities. Improper use and transportation of hazardous materials could result in accidental releases or spills, potentially posing health risks to workers, the public, and the environment. However, all materi als used during construction would be contained, stored, and handled in compliance with applicable standards and regulations established by the Department of Toxic Substances Control (DTSC), the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). In addition, as discussed previously, a Storm Water Pollution Prevention Plan (SWPPP) is required for the Project and shall include emergency procedures for incidental hazardous materials releases. The SWPPP also includes Best Management Practices which includes requirements for hazardous materials storage.

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

Residential land uses do not typically routinely transport, use, or dispose of hazardous materials, or dispose of hazardous materials, or present a reasonably foreseeable release of hazardous materials, with the exception of common residential hazardous materials such as cleaners, paint, petroleum products, etc. However, the potential for a significant hazard occurring from the use of everyday household products is low.

The use of hazardous materials would mostly be confined to the Project construction period. Any impacts are less than significant.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant. The proposed Project includes the development of a 44-lot single-family detached rental unit development, including a private gated entrance, open landscaping, 117 parking spaces and other associated improvements . As discussed in Impact a) above, the use of hazardous materials would be primarily confined to the Project construction period and those materials would be contained, stored, and handled in compliance with applicable standards and regulations. As such, there are less than significant impacts regarding the release of hazardous materials into the environment.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school?
Less Than Significant Impact. Easterby Elementary School is located approximately

0.2 miles northeast of the Project site , located at 5211 E. Tulare Avenue. Kings Canyon Middle School is also located just over one-quarter of mile northwest of the Project site, located at 5117 E. Tulare Avenue. Any hazardous materials contained, stored, or handled on site would be in compliance with applicable standards and regulations established by the Department of Toxic Substances Control (DTSC), the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). The immediate area surrounding the Project site is primarily comprised of residential purposes. Any impacts would be less than significant.

d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. The proposed Project site is not located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 (Geotracker5 and Envirostor6 databases – accessed in May 2025). Therefore, there is no impact.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
Less than Significant Impact. The Project site is located within the Airport Influence Area (AIA) of Fresno-Yosemite International Airport , which lies approximately two miles to the north. The Project site is located within the Traffic Pattern Zone (TPZ) 6 per the Airport Land Use Compatibility Plan (ALUCP).7 Aircraft accident risk level is considered to be low within the TPZ. The Project will be required to follow Safety Criteria Matrix (Table 3A, ALUCP) for construction within the TPZ which includes but is not limited to:
• Airport disclosure notice required
• Airspace review required for objects >100 feet tall
• New structures are prohibited on existing terrain that penetrates 14 CFR Part 77 surfaces

5 California State Water Resources Control Board, GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Fresno. Accessed May 2025. 6 Department of Toxic Substances Control, EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/. Accessed May 2025.
7 Fresno County Airport Land Use Compatibility Plan, December 2018, Part Two. Exhibit D1, Fresno-Yosemite INTL. Airport Influence Area and Safety Zones. https://fresnocog.wpenginepowered.com/wp-content/uploads/2019/01/fresno-final-alucp- 113018-r_part2.pdf. Accessed May 2023.
• New structures require additional airspace analysis required within the 50 ‐foot terrain penetration buffer.

As the Project will be in compliance with the required Safety Criteria Matrix of the Fresno-Yosemite International Airport, any impacts would be less than significant.

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant. The City’s design and environmental review procedures shall ensure compliance with emergency response and evacuation plans. Additionally, the site plan will be reviewed by the Fire Department per standard City procedure to ensure consistency with emergenc y response and evacuation needs. Fresno’s Emergency Operations Plan is located within the City’s General Plan Emergency Response Section. The proposed Project complies with the following policies included in the Emergency Response section of the City of Fresno’s General Plan:

Policy NS-6-b – Disaster Response Coordination. Maintain coordination with other local, State and Federal agencies to provide coordinated disaster response.

Policy NS -6-f. Emergency Vehicle Access. Require adequate access for emergency vehicles in all new developments, including adequate widths, turning radii, hard standing areas, and vertical clearance.

Therefore, the proposed Project would have a less than significant impact on emergency evacuation.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Less Than Significant Impact. The Project site is located in an area mapped as Local Responsibility Area and is not located within a Very High Fire Hazard Severity Zone,8 indicating that the area is urbanized and not susceptible to wildland fires .

Therefore, the proposed Project would not expose people or structures to a significant loss, injury or death involving wildland fires and the impact would be less than significant.

Mitigation Measures

8 California Department of Forestry and Fire Protection. Fire Hazard Severity Zone Viewer. https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/#data_s=id%3AdataSource_1-18ea091fea0-layer- 6%3A10. Accessed May 2025.

None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

X. HYDROLOGY AND WATER QUALITY – Would the project:

a) Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface or
ground water quality?
X

b) Substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the project
may impede sustainable
groundwater management of the
basin?
X

i) Result in a substantial erosion or
siltation on- or off-site;
X

ii) Substantially increase the rate
or amount of surface runoff in a
manner which would result in
flooding on- or off-site:

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

iii) create or contribute runoff
water which would exceed the
capacity of existing or planned
stormwater drainage systems or
provide substantial additional
sources of polluted runoff; or
X

iv) impede or redirect flood flows? X

d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
X

e) Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
X

DISCUSSION
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less Than Significant Impact. The Project has the potential to impact water quality standards and/or waste discharge requirements during construction (temporary impacts) and operation, whichare discussed below.

Grading, excavation and loading activities associated with construction activities could temporarily increase runoff, erosion, and sedimentation. Construction activities also could result in soil compaction and wind erosion effects that could adversely affe ct soils and reduce the revegetation potential at construction sites and staging areas.

The proposed Project site is 3.96 acres in size. In compliance with the General Plan, any development project disturbing one or more acres of soil must obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit Order 2009-0009-DWQ). Construction activities subject to the Construction General Permit include clearing, grading and other ground- disturbing activities such as stockpiling or excavation. The Construction General Permit r equires development and implementation of a Storm Water Pollution Prevention Plan (SWPPP).

A SWPPP includes features designed to eliminate contact of rainfall and stormwater runoff with sources of pollution that occur on construction sites, the main source being soil erosion resulting from unstabilized soils coming in contact with water and wind .

These features are known as Best Management Practices (BMPs). Common BMPs to limit pollution in stormwater runoff from construction sites include maintaining or creating drainages to convey and direct surface runoff away from bare areas and installing ph ysical barriers such as berms, silt fencing, waddles, straw bales, and gabions. Regulatory compliance with eh National Pollutant Discharge Elimination System (NPDES) Construction General Permit will ensure the Project’s construction activities will not significantly impact water quality. This permit requires the Project to prepare and implement a SWPPP and BMPs to effectively minimize potential water quality impacts.

Long-term operation impacts associated with the proposed Project would be reduced to less than significant levels with implementation of the City’s Storm Drainage and Flood Control Master Plan, which manages the City’s stormwater drainage systems, and the City’s participation in the Phase 1 NPDES Permit for Stormwater Discharges from Municipal Separate Storm Sewer Systems (Phase 1 MS4), which requires the City to implement water quality and watershed protection measures for all development projects. Therefore, impacts associated with the proposed Project would be less than significant.

b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact The proposed Project includes a 44-lot single-family detached rental unit development. Each home will be equipped with typical restroom facilities. The proposed Project consists of 44 dwelling units, and the average household size in Fresno is 3.09, therefore the Project will house approximately 135 people. Per the City’s 2020 Urban Water Management Plan, the City’s water use averaged 198 gallons per person per day. 10 Therefore, the proposed Project would result in estimated water demand of 26,730 gallons per day ( 135 people x 198 gallons/day = 26,730 gallons/day).

Water service would be provided to the Project by the City of Fresno. Based on the assumptions in the City’s Urban Water Management Plan ( UWMP),11 the Project would not negatively impact water supplies or otherwise deplete groundwater supplies. Moreover, the proposed Project is not anticipated to interfere with groundwater recharge efforts being implemented by the City. The City’s UWMP contains a detailed evaluation of existing sources of water supply, anticipated future water demand, extensive conservation measures, and the development of new water supplies (recycled water, increased recharge, surface water treatment, etc.).

Measures contained in the UWMP as well as the City’s General Plan are intended to reduce demands on groundwater resources by augmenting supply and introducing conservation measures and other mitigation strategies. Additionally, stormwater flows would be directed through the curb and gutter system in the roadway, which would be directed to a FMFCD retention basin and would enhance groundwater recharge in the area. As such, the Project would result in a less than significant e to sustainable groundwater management.

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? Less Than Significant Impact. The Project site is comprised of vacant disturbed land and is surrounded by urban development. The Project includes changes to the existing stormwater drainage pattern of the area through site construction activities, the installation of a 44-lot single-family residential development.

The Project requires a Soils Report (i.e., Geotechnical Investigation) prior to granting of a grading permit . Because the Project would disturb more than one acre of land, a National Pollution Discharge Elimination System (NPDES) permit

9 U.S. Census Bureau. QuickFacts. Fresno City. 2017-2017. https://www.census.gov/quickfacts/fact/table/fresnocitycalifornia,fresnocountycalifornia/PST045222. Accessed November 2024. 10 City of Fresno. 2020 Urban Water Management Plan. July 2021. Page ES -4. chrome - extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-2020- UWMP_Final_2021-07-21-1.pdf. Accessed May 2025.
11 Ibid.
and preparation of a Stormwater Pollution Prevention Plan (SWPPP) would also be required prior to granting a grading permit . Preparation of the Soils Report as well as implementation of standard best management practices (e.g., silt fences, fiber rolls, rumble grate, etc.) which would be identified in the SWPPP would be effective in avoiding erosion and siltation impacts on or off -site to less than significant levels. Therefore, impacts with regard to substantial erosion or siltation on or off-site would be less than significant.
ii. Substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site?

Less Than Significant Impact. A majority of t he Project site is within Zone X, or area having 0.2% Annual Chance of Flood Hazard, areas of 1% Annual Chance Flood with average depth of less than one foot or with drainage areas of less than one square mile and is not considered a flood prone area , as identified by the Federal Emergency Management Agency, Flood Map 06019C2130H, effective 2/18/2009.12 Project site development would result in the addition of impervious surfaces in the form of 44 residential buildings, internal driveways and a roadway.

This would result in an increase in storm water runoff as well as the potential for contaminated runoff to enter FMFCD drainage basins. The Project site is surrounded by existing storm drainage infrastructure which was sized to accommodate future development/buildout of the General Plan . The proposed Project site is designated for urban development. Accordingly, infrastructure has designed to accomodate this level of development. Therefore, the Project would result in a less than significant impact regarding on- or off-site flooding.

iii. Create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

Less Than Significant Impact. Site runoff from precipitation currently either percolates into the ground where there are no impervious surfaces or drains into the City’s stormwater system and eventually into drainage basins that serve the area. Site re -development will result in the ad dition of impervious surfaces in the form of additional foundations, buildings, streets, and other paved surfaces. This would result in an increase in storm water runoff from the site and would increase the potential for contaminated runoff to enter FMFCD drainage basins or for

12 U.S. Department of Homeland Security. FEMA National Flood Hazard Layer Viewer. https://hazards- fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd. Accessed May 2025.

drainage basins to overflow and cause flooding. However, the proposed Project would be designed to FMFCD and City of Fresno standards to prevent drainage overflow and flooding and the potential for contaminated runoff. The Project site has been desinated for residential urban use by the City of Fresno General Plan.

As with all developments, existing policies and standards apply, which are assessed during review of entitlement applications by the City and FMFCD to ensure that none of the water quality stand ards would be violated and that waste discharge requirements would be adhered to during construction and operation of the Project.

The proposed Project would connect to the City of Fresno’s existing storm -drain system and pay drainage fees pursuant to the Drainage Fee Ordinance. Impacts resulting from polluted runoff would be less than significant.

iv. Impede or redirect flood flows?

Less Than Significant Impact. As discussed above, a majority of the Project site is within Zone X, or area having 0.2% Annual Chance of Flood Hazard, areas of 1% Annual Chance Flood with average depth of less than one foot or with drainage areas of less than one square mile. As discussed in Impacts ii, the Project site would connect to stormwater infrastructure that has been sized to accommodate urban development. The Project would not impede or redirect flood flows as it has been designed with on -site storm drainage infrastructure that would connect with the City’s system. The impact would be less than significant.

d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less Than Significant Impact. A majority of t he Project site is within Zone X, or area having 0.2% Annual Chance of Flood Hazard, areas of 1% Annual Chance Flood with average depth of less than one foot or with drainage areas of less than one square mile, as identified by the Federal Emergency Management Agency, Flood Map 06019C 2130H, effective 2/18/2009. There are no bodies of water near the site that would create a potential risk of hazards from seiche, tsunami or mudflow.

As mentioned in Impact c) above, all new development within the City of Fresn o Planning Area must conform to standards and plans detailed by the FMFCD. By conforming to all standards and policies as outlined, any impacts would be less than significant.

e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant Impact. The City of Fresno is part of the North Kings Groundwater Sustainability Agency (GSA) which is one of the seven GSA’s within the Kings Groundwater Subbasin. The North Kings GSA submitted the Groundwater Sustainability Plan to the CA Department of Water Resources in January 2020. The City of Fresno relies on natural groundwater recharge, subsurface inflow, and intentional recharge to replenish groundwater. As the City of Fresno would provide water to the proposed Project (upon a pproval), and the City is subject to the requirements of the GSA, the proposed Project would not conflict with any adopted water quality or sustainable groundwater management plan.

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

Mitigation Measures
None required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XI. LAND USE AND PLANNING – Would the project:

a) Physically divide an established
community?
X

b) Cause a significant
environmental impact due to a
conflict with any land use plan,
policy, or regulation adopted for
the purpose of avoiding or
mitigating an environmental
effect?
X

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

The site is currently vacant and does not include an established community . The proposed Project land use designation allows for densities between 5 to 12 units per acre, intended to provide for single -family detached housing. The proposed Project would include 44 units on approximately 3.68 acres of currently undeveloped land, for a density of approximately 1 2 dwelling units per ac re. Pursuant to Fresno Municipal Code Section 15-303, fractions of one-half (0.5) or greater shall be rounded up to the nearest whole number and fractions of less than one-half (0.5) shall be rounded down to the nearest whole number. Specific to residentia l density rounding, fractions only apply to minimum density, but not maximum density. In this case, 11.96 dwelling units per acre would be rounded up to 1 2 dwelling units per acre, which is consistent with the minimum density requirement per the Fresno Gen eral Plan. Within the Project vicinity, there are single -family residential developments, undeveloped land, and a church surrounding the proposed Project. The proposed residential use is allowed within this land use designation, and the Project does not exceed the maximum density, therefore the Project is not dividing an established community. The Project is not being built in a pre -existing community area and would not create any physical barrier between an established community. Any impacts are less than significant.

b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
No Impact. The proposed Project is located in an area that is planned for residential and urban development by the City. The site is currently designated as Medium Density Residential by the City of Fresno and has a zone of RA NB – Single Family Residential, Agricultural and AL 20 Limited Agricultural (Fresno County), and as part of the Project, APNs 463-140-01, 463-140-02, 463-140-03, would be prezoned to RS- 5 and 463-140-04 would be prezoned to RS -5/ANX, with development proposed on APNs 463-140-01, -02, and -03 (VTTM No. 6432).

The proposed subdivision is a standard infill development being proposed in compliance with the City’s planned land use designa tion within the City limits. Infill development contributes to environmental preserva tion by reducing agricultural land conversion, reduce costs to build and maintain infrastructure, and improving air quality by overall reducing travel distances and subsequent greenhouse gas emissions.

Further, through the entitlement process, the Project has been reviewed for compliance with applicable regulations inclusive of those adopted for the purpose of avoiding or mitigating environmental effects. Overall, the entitlement process would ensure that the proposed Project complies with the General Plan, FMC, and any other applicable policies and regulations.

In conclusion, the Project will be consistent with the General Plan and not significantly conflict with applicable land use plans, policies, or regulations of the City of Fresno.

Less than significant impacts will occur.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XII. MINERAL RESOURCES – Would the project:

a) Result in the loss of availability
of a known mineral resource that
would be of value to the region
and the residents of the state?
X

b) Result in the loss of availability
of a locally -important mineral
resource recovery site delineated
on a local general plan, specific
plan or other land use plan?
X

DISCUSSION

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

The proposed Project is not located along the San Joaquin River Corridor, t here are no known mineral resources in the proposed Project area , and none are identified in the City’s General Plan near the Project site. Therefore, there is no impact.

b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. As discussed in Impact a) above, there are no known mineral resources identified in the City’s General Plan in the proposed Project area. There is no impact.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XIII. NOISE – Would the project result in:

a) Generation of a substantial
temporary or permanent increase
in ambient noise levels in the
vicinity of the project in excess of
standards established in the local
general plan or noise ordinance,
or applicable standards of other
agencies?
X

b) Generation of excessive
groundborne vibration or
groundborne noise levels?
X

c) For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project expose people residing or
working in th e project area to
excessive noise levels?
X

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

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

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

Activities involved in construction will generate maximum noise levels, as indicated in Table 16, ranging from 79 to 91 dBA at a distance of 50 feet, without feasible noi se control (e.g., mufflers) and ranging from 75 to 80 dBA at a distance of 50 feet, with feasible noise controls.

Table 16: Typical Construction Noise Levels
Type of Equipment dBA at 50 ft
Without Feasible Noise
Control

With Feasible Noise
Constrol

With Feasible Noise
Control
Dozer or Tractor 80 75
Excavator 88 80
Scraper 88 80
Front End Loader 79 75
Backhoe 85 75
Grader 85 75
Truck 91 75

The distinction between short -term construction noise impacts and long -term operational noise impacts is a typical one in both CEQA documents and local noise ordinances, which generally recognize the reality that short -term noise from construction is inevitable and cannot be mitigated beyond a certain level. Thus, local agencies frequently tolerate short-term noise at levels that they would not accept for permanent noise sources. A more severe approach would be impractical and might preclude the kind of construction activities that are to be expected from time to time in urban environments. Most residents of urban areas recognize this reality and expect to hear construction activities on occasion.

Construction activities would not occur between the hours of 10:00 PM and 7:00 AM, Monday through Saturday, and not at all on Sundays, in accordance with Fresno Municipal Code Section 10-109, which limits work hours “to between the hours of 7 AM and 10 PM on any day except Sunday.”
Long-term (Operational) Noise Impacts
The proposed Project includes future residential uses. The primary source of on-going noise from the Project will be from vehicles traveling to and from the site and from traffic traveling along E. Tulare Avenue and S. Peach Avenue. The immediate vicinity consists of existing and planned residential uses, which produce noise levels that are likely similar to long-term noise levels produced by the proposed Project. Additionally, all surrounding properties are adjacent to collector and arterial streets, which increase the ambient noise of the Project site. The pr oposed Project is not projected to be a long-term noise source due to the Project being a use consistent with neighboring land uses.

The proposed Project will not introduce a new significant source of noise that isn’t already occurring in the area. Therefore, the impact is considered less than significant. b) Generation of excessive groundborne vibration or groundborne noise levels?
Less Than Significant Impact. The dominant sources of man ‐made vibration are sonic booms, blasting, pile driving, pavement breaking, demolition, diesel locomotives, and rail ‐car coupling. None of these activities are anticipated to occur with construction or operation of the proposed Project. Detectable vibration generated from Project operations is not anticipated while v ibration from construction activities could include various types of construction heavy equipment, as detailed in Table 17.

Table 17: Typical Vibration Levels During Construction13

Equipment
Peak Particle Velocity
(PPV) (inches/second) at
25 feet
Approximate Vibration
Level (LV) at 25 feet
Bulldozer (Large) 0.089 87
Bulldozer (Small) 0.003 58
Loaded Truck 0.0176 86

13 US Department of Transportation. Federal Transit Administration. Transit Noise and Vibration Impact Assessment. May 2006. chr ome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/FTA_Noise_and_Vibration_Man ual.pdf. Accessed November 2024.

Equipment
Peak Particle Velocity
(PPV) (inches/second) at
25 feet
Approximate Vibration
Level (LV) at 25 feet
Jackhammer 0.035 79
Vibratory Roller 0.210 94
Caisson Drilling 0.089 87

The primary source of vibration during Project construction would likely be from a large bulldozer (tractor), which would generate 0.089 inch per second PPV at 25 feet with an approximate vibration level of 87 VdB; however, the vibration would be intermittent and not a source of continual vibration. There are no aspects of construction or daily operations that would create excessive groundborne vibration or groundborne noise levels. As such, any impacts would be less than significant.

c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Less Than Significant Impact. The closest airport or airstrip is the Fresno Yosemite International Airport, located approximately 2 miles northeast of the Project site. The site is within the Fresno County Airport Land Use Compatibility Plan (ALUCP) Zone 6- Traffic Pattern Zone. Zone 6 encompasses the areas falling within the regular aircraft traffic patterns determined in accordance with the 14 CFR Part 77 Conical Surface. Additionally, it’s important to note that, as per the Handbook and the California Code of Regulations, residential uses are not considered suitable in areas with noise levels exceeding 65 dB.

The proposed Project is inside the noise level contour identified in the ALUCP (Figure D2, Fresno Council of Governments, 2018) and forecast at 60 dB CNEL. In conclusion, the proposed Project would not expose people residing or working in the Project site to excessive noise levels associated with such airport facilities, and there would be less than significant impact.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XIV. POPULATION AND HOUSING – Would the project:

a) Induce substantial unplanned
population growth in an area,
either directly (for example, by
proposing new homes and
businesses) or indirectly (for
example, through extension of
roads or other infrastructure)?
X

b) Displace substantial numbers
of existing people or housing,
necessitating the construction of
replacement housing elsewhere?
X

DISCUSSION
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant Impact. As of 2022, t he population in Fresno is 54 5,567 people with an average household size of 3.07. 14 The Project will construct housing with 44 dwelling units, which will house approximately 135 persons. The City’s General Plan encourages residential developments to meet the future population growth needs. This Project accommodates this anticipated increase in City’s population by providing 44 new residences for existing and future residents.

The Project site has a proposed designation of Medium Density Residential as per the City’s General Plan upon annexation and a proposed rezoning of RS -5 (Medium Density Residential). Upon approval, the Project will be consistent with both the

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

General Plan and zoning ordinance. Therefore, the Project would not induce substantial population growth in an area, either directly or indirectly. Impacts would be less than significant.

b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The Project site is undeveloped and surrounded primarily by residential development. As proposed, the Project will not displace existing housing or people either directly or indirectly. There are currently no residential units on -site, thus no people or existing housing will be displaced. There is no impact.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XV. PUBLIC SERVICES – Would the project:

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

a) Result in substantial adverse
physical impacts associated with
the provision of new or physically
altered governmental facilities,
need for new or physically altered
governmental facilities, the
construction of which could cause
significant environmental impacts,
in order to maintain acceptable
service ratios, response times or
other performance objectives for
any of the public services:

Fire protection?
X

Police protection?
X

Schools? X

Parks?
X

Other public facilities? X

DISCUSSION
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause si gnificant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

a) Fire protection?
Less Than Significant. The Project includes construction of a 44-lot single-family detached rental unit development, including a private gated entrance, open landscaping, 117 parking spaces and other associated improvements.

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

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

The proposed Project would be served by the current Fire Station 8, which is located at 1428 S. Cedar Avenue , approximately 2.1 miles southwest of the Project site. After reviewing the Project, the Fire Department has determined that the Project can be adequately serviced by the current local Fire Facilities and Personnel, consistent with National Fire Protection Association 1710 Objectives.

Additionally, the Project will also be subject to Fire Facilities Fees. Project implementation will result in less than significant impacts. b) Police protection?
Less Than Significant. The Project includes construction of a 44-lot single-family detached rental unit development, including a private gated entrance, open landscaping, 117 parking spaces and other associated improvements. The surrounding area is currently protected by the existing Southeast Police District, approximately 1.4 miles to the east at 224 S Argyle Avenue . The Fresno Police Department provides a full range of police services including uniformed patrol response to calls for service, crime prevention, tactical crime an d enforcement (including gang and violent crime suppression), and traffic enforcement/accident prevention. The proposed Project would also be protected by the Southeast Police District and would be subject to pay development impact fees to offset any potential impacts to police protection. Additionally, the Fresno Police Department reviewed the Project and had no comments. Any impacts are considered less than significant.
c) Schools?
Less Than Significant. According to the Fresno Unified School District School Boundary Maps, the schools that will serve the proposed Project are Easterby Elementary School, approximately 0. 2 miles northeast of the Project, Kings Canyon Middle School approximately 0.2 miles north west of the Project, and Sunnyside High School approximately 0.5 miles southeast of the Project.

The proposed residential uses result in the generation of students, which would impact the District’s student classroom capacity. Any future development occurring as a result of the proposed Project may have an effect on the Clovis Unified School District’s student housing capacity. The District, through local funding, is in a position to mitigate its shortage of classrooms to accommodate planned population growth for the foreseeable future. Ho wever, the District recognizes that the legislature, as a matter of law, has deemed under Government Code Section 65996 that all school facilities impacts are mitigated as a consequence of SB 50 Level 1, 2, and 3 developer fee legislative provisions.

The developer will pay appropriate impact fees at time of building pe rmits. The proposed Project does not result in the construction of new school facilities.

Impacts would be less than significant.
d) Parks?
Less Than Significant. The Project includes construction of a 44-lot single-family detached rental unit development, including a private gated entrance, open landscaping, 117 parking spaces and other associated improvements. The nearest park is Trolley Creek Park, approximately 0. 2 miles south west of the Project. The City of Fresno maintains a park goal to provide five acres of city park space per 1,000 residents. To meet this park goal, pursuant to FMC Section 12-

4.705 a.i – for residential subdivisions with tentative maps containing fifty parcels or less, such as the proposed Project, the subdivider shall pay in-lieu fees only in order to finance park facilities and to pay for the development’s fair share of the construction and acquisition costs of these improvements.

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

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

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

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XVI. RECREATION–- Would the project:

a) Increase the use of existing
neighborhood and regional parks
or other recreational facilities such
that substantial physical
deterioration of the facility would
occur or be accelerated?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

b) Does the project include
recreational facilities or require
the construction or expansion of
recreational facilities which might
have an adverse physical effect
on the environment?
X

DISCUSSION
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less Than Significant. The Project does not include common activity areas ; thus, the proposed Project may result in the physical deterioration of existing parks or recreational facilities.

Trolley Creek Park lies approximately 0.2 miles to the southwest of the Project and Willow Park Tennis Courts are 0.4 miles to the northwest of the Project. There are also four schools with sports fields and other outdoor areas located within a half -mile of the Project; two to the north and two to the south.

As noted in Impact XV( c), the Project would be required to pay in-lieu fees pursuant to FMC Section 12 -4.705(a)(i) in order to finance park facilities and to pay for the development’s fair share of the construction and acquisition costs of these improvements. Park and recreation fees, per the Quimby Act, are collected for new residential developments. The Project review and approval process will ensure that all park related fees are paid by the applicant. These requirements will ensure that the proposed Project does not significantly affect park and recreation f acilities. Impacts would be less than significant.
b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
Less Than Significant. As discussed above, the Project includes construction of a 44-lot single -family detached rental unit development, including a private gated entrance, open landscaping, 117 parking spaces and other associated improvements; however, no parks are included in Project development . Therefore, through the standard City building process for the future park and payment of the required development fees, the Project will not significantly affect park and recreation facilities.

The Project would not result in any new recreational facilities that might have an adverse physical effect on environmental impacts and are considered to be less than significant.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle and
pedestrian facilities?
X

b) Conflict or be inconsistent with
CEQA Guidelines § 15064.3,
subdivision (b)?
X

c) Substantially increase hazards
due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment)?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

d) Result in inadequate
emergency access?
X

DISCUSSION
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less Than Significant . Within proximity to the Project , there are several transportation facilities, including transit, roadway, bicycle, and pedestrian facilities.

Transit Services
Fresno Area Express (FAX) is the transit operator in the City of Fresno. The closest bus stop is for FAX Routes 22 and 26, less than one-quarter mile north of the proposed Project site at Peach and Kings Canyon Road . Route 22 operates at 30 -minute intervals on weekdays and weekends , and Route 26 operates at 30 -minute intervals on weekdays and 60-minute intervals on the weekends . The Project is not expected to disrupt or impede existing transit facilities because few people will use the transit system. The construction of 44 units with an additional 135 people is not anticipated to create delays in bus service in the area.

Bicycle and Pedestrian Facilities
The 2017 City of Fresno Active Transportation Plan (ATP) refers to the Caltrans Highway Design Manual for classification of bicycle facilities as follows:
• Class I Bikeway (Bike Path): Off -street facilities that provide exclusive use for nonmotorized travel, including bicyclists and pedestrians. • Class II Bikeway (Bike Lane): On -street facilities that use striping, stencils, and signage to denote preferential or exclusive use by bicyclists. • Class III Bikeway (Bike Route): On -street pavement markings or signage that connect the bicycle roadway network along corridors that do not provide enough space for dedicated lanes on low-speed and low-volume streets. • Class IV Bikeway (Separated Bikeways): Physically separated bicycle facilities that are distinct from the sidewalk and designed for exclusive use by bicyclists. Commonly known as “cycle tracks,” they are located within the street right -of-way but provide similar comfort when compared to Class I Bikeways.

The Project is not expected to disrupt or impede existing or planned bicycle facilities.

The proposed Project will not require any changes to existing transportation systems and will have no impact on any plans, ordinances, or policies related to the effectiveness or performance of transit, pedestrian and bicycle facilities. The Project will comply with all applicable City development standards. Any impacts would be less than significant.

b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less Than Significant Impact . Senate Bill (SB) 743 requires that relevant CEQA analysis of transportation impacts be conducted using a metric known as vehicle miles traveled (VMT) instead of Level of Service (LOS). VMT measures how much actual auto travel (additional miles driven) a pr oposed project would create on California roads. If the Project adds excessive car travel onto our roads, the Project may cause a significant transportation impact.

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

CEQA Guidelines Section 15064.3(b)(4) states that “[a] lead agency has discretion to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revision to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.”
On June 25, 2020, the City of Fresno adopted CEQA Guidelines for Vehicle Miles Traveled Thresholds, dated June 25, 2020, pursuant to Senate Bill 743 to be effective of July 1, 2020. The thresholds described therein are referred to herein as the City of Fresno VMT Thresholds. The City of Fresno VMT Thresholds document was prepared and adopted consistent with the requirements of CEQA Guidelines Sections 15064.3 and 15064.7. The December 2018 Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory) published by the Governor’s Office of Planning and Research (OPR), was utilized as a reference and guidance document in the preparation of the Fresno VMT Thresholds.

The City of Fresno VMT Thresholds adopted a screening standard and criteria that can be used to screen out qualified projects that meet the adopted criteria from needing to prepare a detailed VMT analysis.

The City of Fresno VMT Thresholds Section 3.0 regarding Project Screening discusses a variety of projects that may be screened out of a VMT analysis including specific development and transportation projects. For development projects, conditions may exist that would presume that a development project has a less than significant impact. These may be size, location, proximity to transit, or trip ‐making potential. For transportation projects, the primary attribute to consider with transportation projects is the potential to increase vehicle travel, sometimes referred to as “induced travel.”
One of the eligible screening criteria is whether a residential project is located within an area with low VMT, as designated in the screening map for residential uses (Figure 6) in the City of Fresno’s CEQA Guidelines for VMT Thresholds Technical Advisory .

These low VMT areas were calculated using Fresno County as the region. The Fresno County average VMT per capita is 16.10. Figure 6 indicates that the Project area maintains less than 14.0 VMT per capita, which is less than the County average of

16.10. Additionally, in evaluating traffic generation for the Project, using the 10th Edition of the ITE Trip Generation Manual, the proposed Project in this area will generate 10.0 trips per unit, with 0.96 peak morning trips per unit and 0.99 peak afternoon trips. This indicates the Project will generate 450 total trips per day, 43 peak morning trips and 45 peak afternoon trips. These levels are below the 500 Average Dailly Trip thresholds within the City’s Guidelines for VMT analysis or for requiring the preparation of a traffic impact study. This results in a less than significant impact. c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less Than Significant Impact. The Project will be designed to current standards and safety regulations. All intersections will be constructed to comply with the City and Caltrans regulations, and design and safety standards of Chapter 33 of the California Building Codes (CBC) and the guidelines of Title 24 in order to create safe and accessible roadways.

Vehicles exiting the subdivision will be provided with a clear view of the roadway without obstructions. Landscaping associated with the entry driveways could impede such views, if improperly installed. Specific circulation patterns and roadway designs will incorporate all applicable safety measures to ensure that hazardous design features or inadequate emergency access to the site or other areas surrounding the Project area would not occur. Therefore, with the incorporated design features and all applicabl e rules and regulations, the Project will have a less-than-significant impact.

d) Result in inadequate emergency access?
Less Than Significant Impact. State and City Fire Codes establishes standards by which emergency access may be determined. The proposed Project would have to provide adequate unobstructed space for fire trucks to turn around. The Fresno City Fire Department reviered the proposed Project plans and determined access is acceptable as proposed. The proposed Project site would have adequate internal circulation capacity including entrance and exit routes to provide adequate unobstructed space for fire trucks and other emergency vehicles to gain access and to turn around. The proposed Project would not inhibit the ability of local roadways to continue to accommodate emergency response and evacuation activities. Impacts would be less than significant.

Mitigation Measures:

None are required.

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

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse
change in the significance of a
tribal cultural resource, defined in
PRC section 21074 as either a
site, feature, place, cultural
landscape that is geographically
defined in terms of the size and
scope of the landscape, sacre d
place, or object with cultural value
to a California Native American
tribe, and that is:

i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
PRC section 5020.1(k), or,
X
ii) A resource determined by the
lead agency, in its discretion and
supported by substantial evi -
dence, to be significant pursuant
to criteria set forth in subdivisionI)
of PRC section 5024.1. In
applying the criteria set forth in
subdivisI (c) of PRC section
5024.1, the lead agency shall
consider the significance of the
resource to a California Native
American tribe.

DISCUSSION

a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
Less Than Significant Impact with Mitigation. A Tribal Cultural Resource (TCR) is defined under Public Resources Code section 21074 as a site, feature, place, cultural landscape that is geographically defined in terms of size and scope, sacred place, and object with cultural value to a California Nati ve American tribe that are either included and that is listed or eligible for inclusion in the California Register of Historic Resources or in a local register of historical resources, or if the City of Fresno, acting as the Lead Agency, supported by substantial evidence, chooses at its discretion to treat the resource as a TCR.

The proposed Project site is currently undeveloped and surrounded by residential land uses. A prehistoric and historic site records and literature search was conducted for the Project area through the Southern San Joaquin Valley Information Center of the California Historical Resources Information System on January 30, 2023 (File RS#23-023). Records indicated that there have been no previous cultural resources studies conducted within the Project area. There has been one previous cultural resource study com pleted that intersects with the eastern boarder of the Project area, FR -01800. It should be noted this report was completed approximately 21 years ago and should be considered out of date for current studies. Additionally, there have been seven cultural resource studies conducted within the one -half mile radius: FR00257, 00296, 020 (See Appendix C). A review of the Sacred Lands Inventory by the Native American Heritage Commission (NAHC) was also performed and the results were negative.

There are no previously recorded cultural resources within the Project area.

Furthermore, it is not known if any currently exist there. There have been 11 recorded resources within the one -half mile radius: P -10- 004312, 004762, 004763, 004764, 004765, 004 766, 004767, 004769, 004770, 004772, & 005121. These resources consist of historic era single family properties.

Pursuant to Assembly Bill 52 (AB 52), the Table Mountain Rancheria Tribe and the Dumna Wo Wah were invited to consult under AB 52. The City of Fresno mailed notices of the proposed Project to each of these tribes on February 7, 2025, which included the required 30-day time period for tribes to request consultation. Following the close of the 30-day comment period, City staff confirmed that no comments were received.

It has been determined that there are no known Tribal Cultural Resources on the proposed Project site. Because the Tribes did not request consultation, because of compliance with California Health and Safety Code Section 7050.5 as discussed in Section V, and because of the implementation of CUL-1 which will protect any unknown resources, any impacts to TCR’s are less than significant with mitigation incorporated.

ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdiIion (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in suIvision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

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

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

Pursuant to AB 32, Native American tribes traditionally and culturally affiliated with the Project area were invited to consult regarding the project based on a list of contacts provided by the Native American Heritage Commission (NAHC). The City of Fresno mailed notices of the proposed project to each of these tribes on February 7, 2025, which included the required 30-day time period for tribes to request consultation, which ended on March 9, 202 5. A ll tribes which were contacted declined consultation.

Additionally, and as described in Impact XVIII (a)(i), above, the proposed Project site is currently undeveloped and surrounded by residential land uses. A CHRIS search was conducted and it was determined that there are no known cultural resources on the site.

As such, it is determined that the residence on -site does not have any elements that would make it eligible for nomination to the California Register of Historic Places or in a local register of historical resources. Therefore, there is a less than significant impact.

Mitigation Measures
The proposed Project shall implement and incorporate the tribal cultural resource related mitigation measures as identified in the attached Project Specific Mitigation Monitoring Checklist dated August 7, 2025.

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

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

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:

a) Require or result in the
relocation or construction of new
or expanded water, wastewater
treatment or storm water
drainage, electric power, natural
gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effect?
X

b) Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry
and multiple dry years?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

c) Result in a determination by the
waste water treatment provider,
which serves or may serve the
project that it has adequate
capacity to serve the project’s
projected demand in addition to
the provider’s existing
commitments?
X

d) Generate solid waste in excess
of state or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?
X

e) Comply with federal, state, and
local management and reduction
statutes and regulations related to
solid waste?
X

DISCUSSION
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less Than Significant Impact. The proposed Project will require construction of new infrastructure to connect to the existing utility infrastructure. This will include water, wastewater, and storm water drainage connections. Additionally, the Project will include connections for electr ic power, natural gas, and telecommunications facilities. The installation of this infrastructure will not require any major upsizing or other offsite construction activities that would cause a significant impact. The new infrastructure would be connected to the existing infrastructure that is adjacent to the Project site.

Impacts to storm drainage facilities have been previously discussed under the Hydrology and Water Quality section included within this analysis herein above. As described in Section VII, Geology and Soils, and in compliance with NPDES General Construction Permit requirements, the proposed Project would design and submit a site -specific SWPPP to minimize the discharge of wastewater during construction and a Water Quality Management Plan that includes best management practices (BMPs) for runoff control as req uired. Therefore, the proposed Project would not require new stormwater drainage facilities to manage stormwater runoff during construction or operation.

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

Sanitary sewer and water service under City of Fresno jurisdiction delivery is also subject to payment of applicable connection charges and/or fees. Compliance with the Department of Public Utilities standards, specifications, and policies; the rules and regulations of the California Public Utilities Commission and California Health Services; and, implementation of the City -wide program for the completi on of incremental expansions to facilities for planned water supply, treatment, and storage ensures that impacts would be less than significant.

b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less Than Significant Impact. As discussed under the Section VII Hydrology and Water Quality section of this Initial Study, the Fresno General Plan recognizes regional water resource planning efforts, such as, the Kings Basin’s Integrated Regional Water Management Plan, the Fresno -Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resource Management Plan and cites the findings of the City of Fresno 2020 UWMP. The purpose of these management plans is to provide safe, adequate, and dependable water supplies in order to adequately meet existing and future needs of the Kings Basin regions and the Fresno-Clovis metropolitan area in an economical manner; protect groundwater quality from further degradation and overdraft; and provide a plan of reasonably implementable measures and facilities. Through routing to the applicable departments and agencies, the City has determined that adequate water supply exists to serve the proposed Project. Additionally, the applicant will be required to comply with all requirements of the City of Fresno Department of Public Utilities to reduce the Project’s water impacts to less than significant.

c. Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant Impact. See Impact (b) above. The City of Fresno acts as the Regional Sewer Agency and is responsible for operating the Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF) and the North Fresno Wastewater Treatment Facility (NFWTF). The Regional Facility provides wastewater treatment for a service area that includes most of the Cities of Fresno and Clovis, and some unincorporated areas of Fresno County. The City is currently evaluating upgrades and modifications to the existin g Regional Facility that may result in a capacity rating increase of 15.0 MGD. The City of Clovis owns 9.3 MGD of wastewater treatment capacity at the Regional Facility, and the City of Fresno owns the remaining capacity.

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

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

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

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

The conditions of approval include payment of the applicable sanitary sewer fees, which would eventually be used to provide funding for the improvements at the RWRF and NFWTF in order to expand. The proposed Project will not result in a determination by the wastewater treatment provider that it has inadequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments. Impacts would be less than significant.

d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant Impact. The City of Fresno Department of Public Utilities, Solid Waste Division has reviewed the Project for compliance with any federal, State, and local management and reduction statutes and regulations related to solid waste.

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

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

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

In the operational phase, typical household refuse would be generated by residences. According to CalRecycle, residential units average 12.23 lbs. 15 of household refuse per day. The proposed 30 units would generate approximately 538.12 lbs. per day, or approximately 98 tons per year. Given the available capacity at the American Avenue Landfill, the additional solid waste generated by the proposed Project is not anticipated to cause the facility to exceed its daily permitted capacity. Furthermore, the site is designated by the General Plan for residential uses and as such, site development has been accounted for in the City’s infrastructure planning documents, including waste management. Additionally, the Project would be required t o comply provisions of AB 939, which calls for a 50% reduction in the waste sent to landfill.

The Project will comply with any statutes and regulations related to solid waste and as such, the proposed Project would not result in any waste related environmental impacts, and impacts would be less than significant.

e. Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
No Impact. The proposed Project will comply with all applicable federal, state, and

15 CalRecycle. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed November 2024.
local regulations pertaining to the disposal of solid waste, including recycling.

Therefore, the proposed Project would have no impact on solid waste regulations.

Furthermore, Project construction and operational activities that generate solid waste would be handled, transported, and disposed of in accordance with AB 939 and CALGreen regulations related to solid waste.

In compliance with CALGreen Section 4.408, the Project will undertake construction waste management practices, which include recycling and salvaging a minimum of 65 percent of nonhazardous construction and demolition waste. Exceptions are made for excavated soil and landclearing debris. The enforcing agency may identify alternate waste reduction requirements in cases where diversion facilities necessary for compliance are not reasonably available near the job site. To adhere to these requirements, the Project will submit a construction waste management plan signed by the owner, which will identify the materials to be diverted from disposal through recycling, reuse, or salvage, and specify whether materials will be source -separated or bulk mixed. Documentatio n will be maintained to demonstrate compliance with these regulations. Therefore, the proposed Project would have no impact on solid waste regulations.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

a) Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

b) Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks, and thereby expose
project occupants to pollutant
concentrations from a wildfire or
the uncontrolled spread of a
wildfire?
X

c) Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water
sources, power lines or other
utilities) that may exacerbate fire
risk or that may result in temporary
or ongoing impacts to the
environment?
X

d) Expose people or structures to
significant risks, including
downslope or downstream
flooding or landslides, as a result
of runoff, post-fire slope instability,
or drainage changes?
X

Setting
There are no State Responsibility Areas (SRAs) within the vicinity of the Project site. The Project site is not categorized as a "Very High" Fire Hazard Severity Zone (FHSZ) by CalFire. Although this CEQA topic only applies to areas within an SRA or Very H igh FHSZ, out of an abundance of caution, these checklist questions are analyzed below.

DISCUSSION
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
No Impact. The City of Fresno does have an adopted Emergency Operations Plan (EOP); however the EOP does not designate evacuation routes, which may not be necessary since Fresno does not face any expected natural hazards from likely sources or locations. 16 The Project site will connect to an existing network of City streets. The Project site is located in an area with several alternative access roads allowing access in the event of an emergency. Access to the alternative access roads would be maintained thro ughout construction, and appropriate detours would be provided in the event of potential road closures. The City of Fresno Fire Department oversees emergency response and preparedness.

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

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

No Impact. The Project includes development of infrastructure (water, sewer, and storm drainage) required to support the proposed residential uses. The Project site is surrounded by existing and future urban development. The infrastructure required by the Project is not expected to exacerbate fire risk. The Project would not require the installation or maintenance of infrastructure that may exacerbate fire risk.

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

Upon development of the site, stormwater would flow to the existing storm drains in the adjacent roadways. Any further storm drain requirements will be processed by the Fresno Metropolitan Flood Control District and constructed per the District’s standards. Additionally, the majority of t he Project site is within Zone X, or area having 0.2% Annual Chance of Flood Hazard, areas of 1% Annual Chance Flood with average depth of less than one foot or with drainage areas of less than one square mile. Further, because the site is essentially flat and located in an existing urbanized area of the City, downstream landslides would not occur.

Landslides include rockfalls, deep slope failure, and shallow slope failure. Factors such as the geological conditions, drainage, slope, vegetation, and others directly affect the potential for landslides. One of the most common causes of landslides is construction activity that is associated with road building (i.e., cut and fill). The Project site is relatively flat; therefore, the potential for a landslide in the Project site is essentially non-existent. Impacts would be less than significant.

Mitigation Measures
None are required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

XIX. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the
potential to degrade the quality of
the environment, substantially
reduce the habitat of a fish or
wildlife species, cause a fish or
wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or ani mal
community, reduce the number or
restrict the range of a rare or
endangered plant or animal or
eliminate important examples of
the major periods of California
history or prehistory?
X

b) Does the project have impacts
that are individually limited, but
cumulatively co “siderable?
("Cumulatively”considerable"
means that the incremental
effects of a project are
considerable when viewed in
connection with the effects of past
projects, the effects of other
current projects, and the effects of
probable future projects)?
X

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

c) Does the project have
environmental effects which will
cause substantial adverse effects
on human beings, either directly
or indirectly?
X

DISCUSSION

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a p lant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory?

Less than Significant Impact. The proposed Project site is currently undeveloped and surrounded by residential land uses. The Project includes the development of 44 residential units As evaluated in this IS/MND, the proposed Project would not substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self - sustaining levels; threaten to eliminate a plant or animal communi ty; reduce the number or restr ict the range of an endangered, rare, or threatened species; or eliminate important examples of the major periods of California history or prehistory.

Mitigation measures have been included to lessen the significance of potential impacts. Similar mitigatio n measures would be expected of other projects in the surrounding area, most of which share a similar cultural paleontological and biological resources. Consequently, the incremental effects of the proposed Project, after mitigation, would not contribute t o an adverse cumulative impact on these resources. Therefore, the Project would have a less than significant impact.

b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)

Less than Significant Impact. CEQA Guidelines Section 15064(i) states that a Lead Agency shall consider whether the cumulative impact of a project is significant and whether the effects of the project are cumulatively considerable. The assessment of the significance of the cumulative effects of a project must, therefore, be conducted in connection with the effects of past projects, other current projects, and probable future projects. Due to the nature of the Project and consistency with environmental policies, incremental contributions to impacts are considered less than cumulatively considerable. All Project - related impacts were determined to be either less than significant, or less than significant after mitigation. The proposed Project would not contribute substantially to adverse cumulative conditions, or create any substantial indirect impacts (i.e., increase in population could lead to an increase need for housing, increase in traffic, air pollutants, etc.). Due to buildout of the area and existing land constraints, it is not anticipated that further unplanned substantial residential development will occur in the area in the foreseeable future. As such, Project impacts are not considered to be cumulatively considerable given the lack of proposed new development in the area and the insignificance of Project -induced impacts. The impact is therefore less than significant.

c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Less than Significant Impact. The analyses of environmental issues contained in this Initial Study indicate that the Project is not expected to have substantial impact on human beings, either directly or indirectly. Project-specific mitigation measures have been incorporated as described in each specific impact area which will reduce all potentially significant impacts to less than significant.

References
California Air Resources Board (CARB). 1998. The Toxic Air Contaminant Identification Process: Toxic Air Contaminant Emissions from Diesel -fueled Engines. Website:
www.arb.ca.gov/toxics/dieseltac/factsht1.pdf.

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

California Department of Forestry and Fire Protection. Fire Hazard Severity Zone Viewer. https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/#data _s=id%3AdataSource_1-18ea091fea0-layer-6%3A10. Accessed May 2025.

California Department of Toxic Substances Control, EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/. Accessed May 2023.

California State Water Resources Control Board, GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Fresno.

Accessed February 2023.

Fresno County Airport Land Use Compatibility Plan, December 2018, Part Two. Exhibit D1City of Fresno. 2020 Urban Water Management Plan. July 2021. Page ES-4. chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.fresno.gov/wp- content/uploads/2023/03/Fresno-2020-UWMP_Final_2021-07-21-1.pdf. Accessed May 2025.

Fresno-Yosemite INTL. Airport Influence Area and Safety Zones. https://fresnocog.wpenginepowered.com/wp-content/uploads/2019/01/fresno-final- alucp-113018-r_part2.pdf. Accessed May 2023.

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

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

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

U.S. Department of Homeland Security. FEMA National Flood Hazard Layer Viewer. https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b 5529aa9cd. Accessed May 2025.

U.S. Department of Transportation. Federal Transit Administration. Transit Noise and Vibration Impact Assessment. May 2006. chrome -
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.transit.dot.gov/sites/fta.dot.g ov/files/docs/FTA_Noise_and_Vibration_Manual.pdf. Accessed November 2024.

U.S. Geological Service. Areas of Land Subsidence in California. https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html. Accessed February 2023.

MITIGATION MONITORING AND REPORTING
PROGRAM – August 7, 2025

This Mitigation Monitoring and Reporting Program (MMRP) has been formulated based upon the findings of the Initial Study/Mitigated Nega tive Declaration (IS/MND) for the City of Fresno’s T- 6432/P23-02269/P23-03234/P23-02268 Residential Project (proposed Project). The MMRP lists mitigation measures recommended in the IS/MND for the proposed Project and identifies monitoring and reporting requirements as well as conditions recommended by responsible agencies who commented on the project.

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

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
AES-1: Lighting systems for street and parking areas
shall include shields to direct light to the roadway
surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from
adjacent light sensitive land uses such as residents.

Project
Applicant
Prior to issuance of
construction permit
City of
Fresno,
Planning and
Development
Department

AIR-1: Before a construction permit is issued for the
proposed Project, the Project applicant, Project
sponsor, or construction contractor shall provide
reasonably detailed proof of compliance with the
following requirements to the City of Fresno:

WheWhere portable diesel engines are used during
construction, all off -road equipment with engines
greater than 75 horsepower shall have engines that
meet California Air Resources Board (CARB) Tier 4
Interim off -road emission standards. except as
otherwise specified herein. If engines that comply with Tier 4 Interim or Tier 4 Final off -road emission
standards are not commercially available, then the
construction contractor shall use the next cleanest
piece of off -road equipment (e.g., Tier 3) that is
commercially a vailable. For purposes of this project
design feature, “commercially available” shall mean the equipment at issue is available taking into
consideration factors such as (i) critical -path timing of construction; and (ii) geographic proximity of
equipment to the project site. If the relevant equipment is determined by the project applicant to not be
commercially available, the contractor can must
Project
Applicant
Prior to issuance of
construction permit
City of
Fresno,
Planning and
Development
Department

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
confirm this conclusion by providing to the City letters from at least two rental companies for each piece of
unavailable off-road equipment that is at issue required for the Project.

AIR-2: Consistent with the SJVAPCD Regulation VIII
(Fugitive PM10 Prohibitions), the following controls
are required to be included as specifications for the
proposed Project and implemented at the construction
site:
• All disturbed areas, including storage piles,
which are not being actively utilized for
construction purposes, shall be effectively
stabilized of dust emissions using water,
chemical stabilizer/suppressant, covered with a
tarp or other suitable cover or ve getative
ground cover.
• All on-site unpaved roads and off-site unpaved
access roads shall be effectively stabilized of
dust emissions using water or chemical
stabilizer/suppressant.
• All land clearing, grubbing, scraping,
excavation, land leveling, grading, cut and fill,
and demolition activities shall be effectively
controlled of fugitive dust emissions utilizing
application of water or by presoaking.
• When materials are transported off -site, all
material shall be covered, or effectively wetted
to limit visible dust emissions, and at least six
Project
Applicant
Prior to issuance of
construction permit
City of
Fresno,
Planning and
Development
Department

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
inches of freeboard space from the top of the
container shall be maintained.
• All operations shall limit or expeditiously
remove the accumulation of mud or dirt from
adjacent public streets at the end of each
workday. (The use of dry rotary brushes is
expressly prohibited except where preceded or
accompanied by sufficient wetting to limit the
visible dust emissions. Use of blower devices is
expressly forbidden.)
• Following the addition of materials to, or the
removal of materials from, the surface of out -
door storage piles, said piles shall be effectively
stabilized of fugitive dust emission utilizing
sufficient water or chemical
stabilizer/suppressant.

BIO-1: A pre-construction clearance survey shall be
conducted by a qualified biologist to ensure that no
roosting pallid bats or western mastiff bats will be
disturbed during the implementation of the Project. A
pre-construction clearance survey shall be conducted
no more than 14 days prior to the initiation of
construction activities. During this survey, the
qualified biologist shall inspect all potential roosting habitat in and immediately adjacent to the impact
areas. If an active roost is found close enough t o the construction area to be disturbed by these activities,
the qualified biologist shall determine the extent of a construction-free buffer to be established around the
Project
Applicant and
Qualified
Biologist
Prior to initiation of any
site
preparation/construction
City of
Fresno,
Planning and
Development
Department

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
roost. If work cannot proceed without disturbing the
roosting bats, work may need to be halted or
redirected to other areas until the roost is no longer in use.

BIO-2: Conduct focused burrowing owl surveys to
assess the presence/absence of burrowing owl in
accordance with the Staff Report on Burrowing Owl
Mitigation and the Burrowing Owl Survey Protocol and
Mitigation Guidelines. These involve conducting four
pre-construction survey visits.

If a burrowing owl or sign of burrowing owl use (e.g.,
feathers, guano, pellets) is detected on or within 500
feet of the Project site, and the qualified biologist
determines that Project activities would disrupt the
owl(s), a construction -free buffer, lim ited operating period, or passive relocation shall be implemented in
consultation with the CDFW.

Project
Applicant and
Qualified
Biologist
Prior to initiation of any
site
preparation/construction
City of
Fresno,
Planning and
Development
Department

BIO-3: To the extent practicable, construction shall be scheduled to avoid the nesting season, which extends
from February through August. If it is not possible to
schedule construction between September and
January, pre -construction surveys for nesting birds
shall be conducted by a qualified biologist to ensure
that no active nests will be disturbed during the
implementation of the Project. A pre -construction
survey shall be conducted no more than 14 days prior
Project
Applicant and
Qualified
Biologist
Prior to initiation of any
site
preparation/construction
City of
Fresno,
Planning and
Development
Department

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
to the initiation of construction activities. During this survey, the qualified biologist shall inspect all potential nest substrates in and immediately adjacent to the
impact areas. If an active nest is found close enough
to the construction area to be di sturbed by these
activities, the qualified biologist shall determine the extent of a construction -free buffer to be established around the nest. If work cannot proceed without
disturbing the nesting birds, work will be halted or
redirected to other areas until nesting and fledging are completed or the nest has otherwise failed for non -
construction related reasons.

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

City of
Fresno,
Planning and
Development
Department

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

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

CUL-2: In the event that human remains are
unearthed during excavation and grading activities of
any future development project, all activity shall cease immediately. Pursuant to Health and Safety Code
(HSC) Section 7050.5, no further disturbance shall
occur unti l the County Coroner has made the
necessary findings as to origin and disposition
pursuant to PRC Section 5097.98(a). If the remains
are determined to be of Native American descent, the
coroner shall within 24 hours notify the Native
American Heritage Commission (NAHC). The NAHC
shall then contact the most likely descendent of the
deceased Native American, who shall then serve as
the consultant on how to proceed with the remains.

Pursuant to PRC Section 5097.98(b), upon the
discovery of Native American remains, the landowner
shall ensure that the immediate vicinity, according to
generally accepted cultural or archaeological
standards or practices, where the Native American
human remains are located is not damaged or
Project
Applicant and
qualified
historical
resources
specialist
Planning and
Development
Department to review
construction
specifications to ensure
inclusion of provisions
included in mitigation
measure.

City of
Fresno,
Planning and
Development
Department

Mitigation Measure
Party
responsible
for
Implementing
Mitigation
Implementation
Timing
Party
responsible
for
Monitoring
Verification
(name/date)
disturbed by further development activity until the
landowner has discussed and conferred with the most
likely descendants regarding their recommendations,
if applicable, taking into account the possibility of
multiple human remains. The landowner shall discuss
and confer with the descendants all reasonable
options regarding the descendants' preferences for
treatment.

Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

To: Emily Bowen, LEED AP, Principal
Environmental Planner
Crawford & Bowen Planning, Inc.
113 N. Church Street, Suite 310
Visalia, CA 93291
[email protected]
From: Johnson Johnson and Miller Air Quality
Consulting Services
Richard Miller, Managing Air Quality and
Climate Change Specialist
[email protected]

Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project in the City of Fresno, California
Date: May 15, 2023
Subject: Air Quality, Greenhouse Gas, and Energy Technical Memorandum This Air Quality, Greenhouse Gas Emissions, and Energy Analysis Report was prepared to evaluate the estimated criteria air pollutant, ozone precursor, toxic air contaminant (TAC), and greenhouse gas (GHG) emissions generated from construction and operation of the Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project (proposed project or project). The respective analyses were conducted within the context of the California Environmental Quality Act (CEQA) (California Public Resources Code [PRC] § 21000, et seq.). The methodology follows the Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI) prepared by the San Joaquin Valley Air Pollution Control District ( SJVAPCD) for the quantification of emissions and evaluation of potential impacts to air resources.1 The GHG Analysis follows and the SJVAPCD’s Guidance for Valley Land-Use Agencies in Addressing GHG Emission Impacts for New Projects under the California Environmental Quality Act (CEQA) 2 and the City of Fresno Greenhouse Gas Reduction Plan Update to determine significance.

Project Location and Description
Golden State Developers, LLC (Applicant) proposes a Vesting Tentative Tract Map to facilitate a residential development in the City of Fresno, herein referred to throughout this memorandum as “project” or “proposed project”.

The proposed Project would consist of a 44-lot single family detached residential rental unit development on approximately 3.68 net acres at a density of approximately 11.96 du/acre, which is within the density range of the existing land use. The units would be a mix of 3-bedroom, 2.5 bathroom and 4-bedroom, 2.5- bathroom floor plan layouts.

The units will be provided with a covered outdoor patio and fenced rear yards to provide private outdoor recreation space. Ample additional common recreation space is provided through the provision of a community center, swimming pool with arbors and bar-b-que amenities within the pool area, and open landscaping that can be utilized for active recreational activities.

The project will be provided with public access from South Peach Avenue and will be gated for project security. In order to minimize maintenance of the gate operators, the gates will be open during daylight

1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts.

February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 1, 2023.
2 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2009. Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA. December 17. Website: https://www.valleyair.org/Programs/CCAP/12- 17-09/3%20CCAP%20-%20FINAL%20LU%20Guidance%20-%20Dec%2017%202009.pdf. Accessed May 1, 2023. 1 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

hours (generally 7am to 7pm). During evening hours, visitors can access the site through the use of a call box located in a pull-out (to allow for through traffic of residents) connected to the residential units.

Emergency vehicle access will be provided as required by the City of Fresno Fire Department standards.

Parking will include 88 spaces within garages and 29 open stalls providing an overall parking ratio of 2.66 stalls per unit.

To facilitate development as proposed, the Project will be required to submit the following entitlements:
• Annexation
• Prezone
• Tentative Tract Map
• Planned Development Permit
A general plan amendment is not required or proposed, as the proposed Project is consistent with the existing planned land use.

An aerial view of the project site is shown in Figure 1. This figure and the project site plan are included as part of Attachment A.

Figure 1 – Aerial View of the Project Site and Local Vicinity Map

2 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Modeling Parameters and Assumptions
The following modeling parameters and assumptions were used to generate criteria air pollutant and greenhouse gas (GHG) emissions for the proposed project.

Air Pollutants and GHGs Assessed
Criteria Pollutants Assessed
The following criteria air pollutants were assessed in this analysis: reactive organic gases (ROG), oxides of nitrogen (NOX), particulate matter less than 10 microns in diameter (PM 10), and particulate matter less than 2.5 microns in diameter (PM2.5). Note that the proposed project would emit ozone precursors ROG and NOX. However, the proposed project would not directly emit ozone since it is formed in the atmosphere during the photochemical reaction of ozone precursors.

GHGs Assessed
This analysis was restricted to GHGs identified by AB 32, which include carbon dioxide (CO 2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3). The proposed project would generate a variety of GHGs, including several defined by AB 32 such as CO2, CH4, and N2O.

Certain GHGs defined by AB 32 would not be emitted by the proposed project, which is residential in nature. HFCs, PFCs, SF6, and NF3 are typically used in industrial applications, none of which would be used for during operations of typical residential uses. Therefore, it is not anticipated that the proposed project would emit those GHGs.

GHG emissions associated with the proposed project construction as well as future operations were estimated using CO2 equivalent (CO2e) emissions as a proxy for all GHG emissions. In order to obtain the CO2e, an individual GHG is multiplied by its Global Warming Potential (GWP). The GWP designates on a pound for pound basis the potency of the GHG compared to CO 2.

Model Selection
Criteria Pollutants and GHG Emissions
The California Emissions Estimator Model (CalEEMod) is a statewide land use emissions compu ter model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions associated with both construction and operations from a variety of land use projects. CalEEMod quantifies direct emissions from construction and operation activities (including vehicle use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use. Further, CalEEMod identifies mitigation measures to reduce criteria pollutant and GHG emissions along with calculating the benefits achieved from measures chosen by the user.

CalEEMod was developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with the California Air Districts. Default data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California Air Districts to account for local requirements and conditions.

CalEEMod is a comprehensive tool for quantifying air quality impacts from land use projects located throughout California. The model can be used for a variety of situations where an air quality analysis is necessary or desirable such as preparing CEQA or National Environmental Policy Act documents, conducting pre-project planning, and, verifying compliance with local air quality rules and regulations, etc. 3 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

CalEEMod version 2020.4.0 was used to estimate construction and operational impacts of the proposed project. CalEEMod version 2020.4.0 was the most recent version currently adopted version of CalEEMod at the time emissions were estimated (August 2022). The web-based version of CalEEMod (CalEEMod 2022) is currently available; however, SJVAPCD is accepting the use of CalEEMod 2020.4.0 at the time modeling was completed for this technical report (May 2023). Furthermore, the SJVAPCD is currently recommending the use of CalEEMod version 2020.4.0, as the web-based version is awaiting approval from EPA.

Construction DPM emissions (represented as PM10 exhaust) were estimated using CalEEMod Version 2020.4.0. Emissions were estimated for the unmitigated scenario and a scenario with clean construction equipment engines (mitigated scenario 1: Tier 4 mitigated for a portion of the off-road construction equipment; mitigated scenario 2: Level 3 filters for equipment 75 HP or greater). Equipment tiers refer to a generation of emission standards established by the EPA and CARB that apply to diesel engines in off- road equipment. The “tier” of an engine depends on the model year and horsepower rating; generally, the newer a piece of equipment is, the higher the tier level the equipment is likely to have. Excluding e ngines greater than 750 horsepower, Tier 1 engines were manufactured generally between 1996 and 2003.

Since Tier 1 emission standards were established by the EPA in 1994, increasingly more stringent Tier 2, Tier 3, and Tier 4 (interim and final) standards were adopted by the EPA, as well as CARB.

Toxic Air Containments—Model Selection and Parameters
An air dispersion model is a mathematical formulation used to estimate the air quality impacts at specific locations (receptors) surrounding a source of emissions given the rate of emissions and prevailing meteorological conditions. The air dispersion model applied in this assessment was the United States Environmental Protection Agency (EPA) AERMOD (version 22112) air dispersion model. Specifically, the AERMOD model was used to estimate levels of air emissions at sensitive receptor locations from potential sources of project-generated TACs during the construction period. The use of the AERMOD model provides a refined methodology for estimating construction impacts by utilizing long-term, measured representative meteorological data for the project site and a representative construction schedule.

The modeling analysis also considered the spatial distribution and elevation of each emitting s ource in relation to the sensitive receptors. Direction-dependent calculations were obtained by identifying the Universal Transverse Mercator (UTM) coordinates for each source location. Terrain elevations were obtained for the project site using the AERMAP model, the AERMOD terrain data pre-processor. To evaluate the proposed project’s localized impacts at the point of maximum impact, all receptors were placed within the breathing zone at 1.2 meters above ground level to present a conservative estimate of concentration and associated health risks.

For the construction period, construction emissions were assumed to be distributed over the project site with a working schedule of eight hours per day and five days per week. Emissions were adjusted by a factor of 4.2 to convert for use with a 24-hour-per-day, 365 day-per-year averaging period. Project operations were assessed assuming a 24-hour-per-day, and seven day-per-week schedule. Detailed parameters and complete calculations are contained in Attachment B.

Assumptions
Construction Modeling Assumptions
Schedule
The proposed project would require construction activities, including site preparation, grading, paving, building construction (vertical home construction), and architectural coating (painting) for clearing and 4 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

grading of approximately 3.68 acres and the construction of 44 single-family dwelling units. Table 1 shows a summary of the anticipated construction schedule, while a more detailed construction schedule is included in Attachment A. The construction schedule utilized in the analysis represents a “worst-case” analysis scenario since emission factors for construction equipment decrease as the analysis year increases, due to improvements in technology and more stringent regulatory requirements. Therefore, construction emissions would decrease if the construction schedule moved to later years. The duration of construction activity and associated equipment represent a reasonable approximation of the expected construction fleet as required per CEQA guidelines. The site-specific construction fleet may vary due to specific project needs at the time of construction.

Table 1: Project Construction Schedule
Construction Phase Start Date End Date
Construction
Days
Site Preparation 6/1/2023 6/14/2023 10
Grading 6/15/2023 7/12/2023 20
Building Construction 7/13/2023 5/29/2024 230
Paving 5/30/2024 6/26/2024 20
Architectural Coating 6/27/2024 7/24/2024 20
Source: CalEEMod Output and Additional Supporting Information (Attachment A).

Equipment
Construction equipment for each construction activity is shown in Attachment A.

Vehicles Trips
Table 2 provides a summary of the construction-related vehicle trips, while the detailed assumptions are provided in Attachment A.

The fleet mix for worker trips is light-duty passenger vehicles to light-duty trucks. The vendor trips fleet mix is composed of a mixture of medium and heavy-duty diesel trucks. The hauling trips were assumed to be 100 percent heavy-duty diesel truck trips. CalEEMod default trip lengths for a project in Fresno County and an urban setting were used for the construction trips.

Table 2: Construction Vehicle Trips
Construction Task
Maximum Worker Trips
per Day
Maximum Vendor Trips
per Day
Total Haul Truck
Trips
Site Preparation 18 0 14
Grading 15 0 637
Paving 15 4 12
Building Construction 34 12 18
Architectural Coating 7 0 2
Source: CalEEMod Output and Additional Supporting Information (Attachment A).

5 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Operational Modeling Assumptions
Operational emissions are those emissions that occur during long-term operations of the proposed project.

Motor Vehicles
Motor vehicle emissions refer to exhaust and road dust emissions from the automobiles that would travel to and from the proposed project site. Trip generation rates for the project were obtained from the Institute of Transportation Engineers (ITE) Manual, 11th Edition.

Trip Lengths
The CalEEMod default round trip lengths for an urban setting in Fresno County were used in this analysis. Trip lengths are for primary trips. Trip purposes are primary, diverted, and pass -by trips.

Diverted trips take a slightly different path than a primary trip. The CalEEMod default rates for percentages of primary, diverted, and pass-by trips were used.

Vehicle Fleet Mix
The vehicle fleet mix is defined as the mix of motor vehicle classes active during the operation of the proposed project. Emission factors are assigned to the expected vehicle mix as a function of vehicle class, speed, and fuel use (gasoline- and diesel-powered vehicles). The vehicle fleet mix was revised to reflect the residential fleet mix approved by SJVAPCD for each year analyzed.

Area Sources
Hearths
The proposed project would not include woodburning fireplaces in the residences. The residences would be built in compliance with SJVAPCD Rule 4910.

Consumer Products
Consumer products are various solvents used in non-industrial applications, which emit VOCs during their product use. “Consumer Product” means a chemically formulated product used by household and institutional consumers, including but not limited to: detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. It does not include other paint products, furniture coatings, or architectural coatings. CalEEMod includes default consumer product use rates ba sed on building square footage. The default emission factors developed for CalEEMod were used for consumer products associated with parking uses and the general consumer product category.

Architectural Coatings (Painting)
Paints release VOC emissions. The parking lot lines and buildings (residential apartment complex and other project buildings) may be repainted on occasion. The project is required to comply with the SJVAPCD Rule 4601—Architectural Coatings. The rule required flat paints to meet a standard of 50 grams per liter (g/l) and gloss paints 100 g/l by 2012 for an average rate of 65 g/l. Effective January 1, 2022, nonflat gloss and semigloss paints will also be required to meet the 50 g/l standard, providing lower VOC emissions for buildings constructed after that date. Therefore, the analysis uses the 50 g/l emission factor for the analysis.

Landscaping Emissions
6 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

CalEEMod estimates a total of 180 days for which landscaping equipment would be used to estimate potential emissions for the proposed project.

Indirect Emissions
For GHG emissions, CalEEMod contains calculations to estimate indirect GHG emissions. Indirect emissions are emissions where the location of consumption or activity is different from where actual emissions are generated. For example, electricity would be consumed at the proposed project site; however, emissions associated with producing that electricity are typically generated off-site at a power plant. Since the electricity can vary greatly based on locations, the user should override these values if they have more specific information regarding their specific water supply and treatment.

Energy Use
The emissions associated with the building electricity and natural gas usage (non -hearth) were estimated based on the land use type and size. Values for a project served by Pacific Gas and Electric (PG&E) were used in the analysis.

The carbon dioxide intensity factor for Pacific Gas & Electric (from the CEC’s year 2006 data) is as follows:
• Carbon dioxide: 641.35 pounds per megawatt hour (lbs/MWh)

The Renewable Electricity Standards took effect in 2020. The Renewable Electricity Standard requires that electricity providers include a minimum of 33 percent renewable energy in their portfolios starting in the year 2020. Pacific Gas & Electric provides estimates of its emission factor per megawatt hour of electricity delivered to its customers. PG&E provides emission factors for the electricity it provides to customers for its energy portfolio that is used to estimate project emissions. CalEEMod 2020.4.0 includes PG&E emission factor based on actual rates reported by the utility.

The 2020.4.0 CalEEMod default emission factors for PG&E are as follows:
• Carbon dioxide: 203.98 lbs/MWh
• Methane: 0.033 lb/MWh
• Nitrous oxide: 0.004 lb/MWh

The utilities in California will be required to increase the use of renewable energy sources to 60 percent by 2030.

Other Indirect Emissions (Water Use, Wastewater Use, and Solid Waste) CalEEMod includes calculations for indirect GHG emissions for electricity consumption, water consumption, and solid waste disposal. For water consumption, CalEEMod calculates embedded energy (e.g., treatment, conveyance, distribution) associated with providing each gallon of potable water to the project. For solid waste disposal, GHG emissions are associated with the disposal of solid waste generated by the proposed project into landfills. CalEEMod default data were used for inputs associated with solid waste.

Thresholds
Air pollutant emissions have regional effects and localized effects. This analysis assesses the regional effects of the project’s criteria pollutant emissions in comparison to SJVAPCD threshol ds of significance for short-term construction activities and long-term operation of the project. Localized emissions from project construction and operation are also assessed using concentration-based thresholds that 7 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

determine if the project would result in a localized exceedance of any ambient air quality standards or would make a cumulatively considerable contribution to an existing exceedance.

The primary pollutants of concern during project construction and operation are ROG, NO X, PM10, and PM2.5. The SJVAPCD GAMAQI adopted in 2015 contains thresholds for ROG and NO X; SOX, CO, PM10, and PM2.5.

Ozone is a secondary pollutant that can be formed miles away from the source of emissions through reactions of ROG and NOX emissions in the presence of sunlight. Therefore, ROG and NOx are termed ozone precursors. The SJVAB often exceeds the state and national ozone standards. Therefore, if the project emits a substantial quantity of ozone precursors, the project may contribute to an exceedance of the ozone standard. The SJVAB also exceeds air quality standards for PM 10, and PM2.5; therefore, substantial project emissions may contribute to an exceedance for these pollutants.

The SJVAPCD adopted significance thresholds for construction-related and operational ROG, NOX, PM, CO, and SOX, these thresholds are included in Table 3.

Table 3: SJVAPCD Proposed Project-Level Air Quality CEQA Thresholds of Significance Pollutant
Significance Threshold
Construction Emissions
(tons/year) Operational Emission (tons/year)
CO 100 100
NOX 10 10
ROG 10 10
SOX 27 27
PM10 15 15
PM2.5 15 15
Source: SJVAPCD. 2015. Guidance for Assessing and Mitigating Air Quality Impacts. Website:
https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 1, 2023.

Fugitive Dust
Construction
Fugitive dust would be generated from site grading and other earth-moving activities. Most of this fugitive dust would remain localized and would be deposited near the project site. However, the potential for impacts from fugitive dust exists unless control measures are implemented to reduce the emissions from the project site. Therefore, adherence to Regulation VIII would be required during construction of the proposed project. Regulation VIII would require fugitive dust control measures that are consistent with best management practices (BMPs) established by the SJVAPCD to reduce the proposed project’s construction-generated fugitive dust impacts to a less than significant level.

The SJVAPCD (SJVAPCD or District) adopted Regulation VIII in 1993 and its most recent amendments became effective on October 1, 2004.3 This is a basic summary of the regulation’s requirements as they apply to construction sites. These regulations affect all workers at a regulated construction site, including

3 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2022. Current District Rules and Regulations. Website:
https://www.valleyair.org/rules/1ruleslist.htm#reg8. Accessed May 1, 2023. 8 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

everyone from the landowner to the subcontractors. Violations of Regulation VIII are subject to enforcement action including fines.4
Visible Dust Emissions may not exceed 20 percent opacity during periods when soil is being disturbed by equipment or by wind at any time. Visible Dust Emissions opacity of 20 percent means dust that would obstruct an observer’s view of an object by 20 percent. District inspectors are state certified to evaluate visible emissions. Dust control may be achieved by applying water before/during earthwork and onto unpaved traffic areas, phasing work to limit dust, and setting up wind fences to limit windblown dust.

Soil Stabilization is required at regulated construction sites after normal working hours and on weekends and holidays. This requirement also applies to inactive construction areas such as phased projects where disturbed land is left unattended. Applying water to form a visible crust on the soil and restricting vehicle access are often effective for short-term stabilization of disturbed surface areas. Long-term methods including applying dust suppressants and establishing vegetative cover.

Carryout and Trackout occur when materials from emptied or loaded vehicles falls onto a paved surface or shoulder of a public road or when materials adhere to vehicle tires and are deposited onto a paved surface or shoulder of a public road. Should either occur, the material must be cleaned up at least daily, and immediately if it extends more than 50 feet from the exit point onto a paved road. The appropriate clean-up methods require the complete removal and cleanup of mud and dirt from the paved surface and shoulder. Using a blower device or dry sweeping with any mechanical device other than a PM10-efficient street sweeper is a violation. Larger construction sites, or sites with a high amount of traffic on one or more days, must prevent carryout and trackout from occurring by installing gravel pads, grizzlies, wheel washers, paved interior roads, or a combination thereof at each exit point from the site. In many cases, cleaning up trackout with water is also prohibited as it may lead to plugged storm drains. Prevention is the best method.

Unpaved Access and Haul Roads, as well as unpaved vehicle and equipment traffic areas at construction sites must have dust control. Speed limit signs limiting vehicle speed to 15 mph or less at construction sites must be posted every 500 feet on uncontrolled and unpaved roads .

Storage Piles and Bulk Materials have handling, storage, and transportation requirements that include applying water when handling materials, wetting or covering stored materials, and installing wind barriers to limit visible dust emissions. Also, limiting vehicle speeds, loading haul trucks with a freeboard of six inches or greater along with applying water to the top of the load, and covering the cargo compartments are effective measures for reducing visible dust emissions and carryout from vehicles transporting bulk materials.

Dust Control Plans identify the dust sources and describe the dust control measures that will be implemented before, during, and after any dust generating activity for the duration of the project. Owners or operators are required to submit plans to the SJVAPCD at least 30 days prior to commencing the work for the following:
• Residential developments of ten or more acres of disturbed surface area. • Non-residential developments of five or more acres of disturbed surface area. • The relocation of more than 2,500 cubic yards per day of materials on at least three days.

Record Keeping is required to document compliance with the rules and must be kept for each day any dust control measure is used. The SJVAPCD has developed record forms for water application, street sweeping, and “permanent” controls such as applying long term dust palliatives, vegetation, ground cover

4 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2007. Compliance Assistance Bulletin. Website:
http://www.valleyair.org/busind/comply/pm10/forms/RegVIIICAB.pdf. Accessed May 1, 2023. 9 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

materials, paving, or other durable materials. Records must be kept for one year after the end of dust generating activities (Title V sources must keep records for five years).

Exemptions exist for several activities. Those occurring above 3,000 feet in elevation are exempt from all Regulation VIII requirements. Further, Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities exempts the following construction and earthmoving activities:
• Blasting activities permitted by California Division of Industrial Safety. • Maintenance or remodeling of existing buildings provided the addition is less than 50% of the size of the existing building or less than 10,000 square feet (due to asbestos concerns, contact the SJVAPCD at least two weeks ahead of time).
• Additions to single family dwellings.
• The disking of weeds and vegetation for fire prevention on sites smaller than ½ acre. • Spreading of daily landfill cover to preserve public health and safety and to comply with California Integrated Waste Management Board requirements.

Nuisances are prohibited at all times because District Rule 4102 – Nuisance applies to all construction sources of fugitive dust, whether or not they are exempt from Regulation VIII. It is important to monitor dust-generating activities and implement appropriate dust control measures to limit the public’s exposure to fugitive dust.

Criteria Pollutant Emission Estimates
Construction Emissions (Regional)
Construction emissions associated with the project are shown in Table 4. As shown in Table 4, the emissions are below the significance thresholds and, therefore, are less than significant on a project basis.

Table 4: Summary of Construction-Generated Emissions of Criteria Air Pollutants – Unmitigated
Construction
Activity
Emissions (Tons/Year)
ROG NOX CO SOX PM10 PM2.5
Site Preparation 0.01 0.14 0.09 <0.01 0.05 0.03
Grading 0.02 0.22 0.16 <0.01 0.05 0.02
Paving 0.10 0.91 1.05 <0.01 0.06 0.05
Building
Construction (2023) 0.09 0.76 0.92 <0.01 0.05 0.04
Building
Construction (2024) 0.01 0.10 0.15 <0.01 0.01 <0.01
Architectural
Coating 0.29 0.01 0.02 <0.01 <0.01 <0.01
Total Emissions 0.52 2.14 2.39 0.00 0.22 0.14
Significance
Thresholds 10 10 100 27 15 15
Exceed Significance
Thresholds? No No No No No No
10 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Notes:

PM10 and PM2.5 emissions are from the mitigated output to reflect compliance with Regulation VIII—Fugitive PM10 Prohibitions.

Source of Emissions: CalEEMod Output (Attachment A).

Operational Emissions (Regional)
Operational emissions occur over the lifetime of the project. Operational emissions are shown in Table 5.

The SJVAPCD considers construction and operational emissions separately when making significance determinations.

The emissions output for project operation at full buildout assessed in the 2023 operational year are summarized in Table 5. Full buildout is not expected until 2024; however, operations are anticipated to begin as early as 2023. The use of an earlier operational year represents a conservative estimate of emissions, as emissions for the same level of activity for a typical development are expected to decrease in future years due to regulations and advancements and adoption of newer technology. As shown in Table 5, the operational emissions would be less than the thresholds of significance for all criteria air pollutants.

Table 5: Summary of Operational Emissions of Criteria Air Pollutants – Unmitigated Source
Emissions (tons/year)
ROG NOX CO SOX PM10 PM2.5
Area 0.39 0.02 0.33 <0.01 <0.01 <0.01
Energy 0.01 0.05 0.02 <0.01 <0.01 <0.01
Mobile (Vehicle Trips) 0.13 0.25 1.57 <0.01 0.45 0.12
Annual Total 0.53 0.32 1.92 <0.01 0.45 0.12
Significance
Thresholds 10 10 100 27 15 15
Exceed Significance
Thresholds? No No No No No No
Notes:

Emissions were quantified using the earliest operational year for the proposed project to provide a conservative estimate of emissions.

Source: CalEEMod Output (Attachment A).

Localized Impacts
Emissions occurring at or near the project have the potential to create a localized impact also referred to as an air pollutant hotspot. Localized emissions are considered significant if when combined with background emissions, they would result in exceedance of any health-based air quality standard. In locations that already exceed standards for these pollutants, significance is based on a significant impact level (SIL) that represents the amount that is considered a cumulatively considerable contribution to an existing violation of an air quality standard. The pollutants of concern for localized imp act in the SJVAB are NO2, SOx, and CO.

The SJVAPCD has provided guidance for screening localized impacts in the GAMAQI that establishes a screening threshold of 100 pounds per day of any criteria pollutant. If a project exceeds 100 pounds per 11 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

day of any criteria pollutant, then ambient air quality modeling would be necessary. If the project does not exceed 100 pounds per day of any criteria pollutant, then it can be assumed that it would not cause a violation of an ambient air quality standard.

Construction: Localized Concentrations of NOX, CO, PM10, and PM2.5 Local construction impacts would be short-term in nature lasting only during the duration of construction.

As shown in Table 6 below, on-site construction emissions would be less than 100 pounds per day for each of the criteria pollutants. To present a conservative estimate, on-site emissions for on-road construction vehicles were included in the localized analysis. Based on the SJVAPCD’s guidance , the construction emissions would not cause an ambient air quality standard violation.

Table 6: Localized Concentrations of NOX, CO, PM10, and PM2.5 for Construction Source
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Maximum On-site Daily (2023) 27.56 18.37 10.12 5.71
Maximum On-site Daily (2024) 13.63 16.46 0.63 0.58
Maximum Daily On-site
Emissions 27.56 18.37 10.12 5.71
Significance Thresholds 100 100 100 100
Exceed Significance Thresholds? No No No No
Note: Assumptions regarding dates of construction activities are based on the construction schedule shown in Table 1.

Source of Emissions: CalEEMod Output and Additional Supporting Information (Attachment A).

Accessed May 1, 2023.

Operation: Localized Concentrations of NOX, CO, PM10, and PM2.5 Localized impacts could occur in areas with a single large source of emissions such as a power plant or with multiple sources concentrated in a small area such as a distribution center.

As shown in Table 7 below, operational modeling of on-site emissions for the project indicate that the project would not exceed 100 pounds per day for each of the criteria pollutants. Therefore, based on the SJVAPCD’s guidance, the operational emissions would not cause an ambient air quality standard violation. As such, impacts would be less than significant. 12 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 7: Localized Concentrations of NOX, CO, PM10, and PM2.5 for Operations Source
On-site Emissions (pounds per day)
NOX CO PM10 PM2.5
Area 0.44 3.78 0.05 0.05
Energy 0.27 0.11 0.02 0.02
Mobile (On-site +
Localized Vehicle
Emissions) 0.49 3.14 0.16 0.05
Daily Total 1.20 7.03 0.24 0.12
Significance
Thresholds 100 100 100 100
Exceed Significance
Thresholds? No No No No
Source of Emissions: CalEEMod Output and Additional Supporting Information (Attachment A).

Maximum daily emissions of NOX, CO, PM10, and PM2.5 were highest in the Winter scenario.

Accessed May 1, 2023.

Addressing Air Quality CEQA Impact Questions
Table 8: Summary of Air Quality Impact Analysis
Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project: Significance Finding
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard?
Less than Significant Impact
c) Expose sensitive receptors to substantial pollutant concentrations? Less than Significant Impact with Mitigation Incorporated
d) Result in other emissions (such as those leading to odors or) adversely affecting a substantial number of people? Less than Significant Impact

Air Quality Mitigation Measures
MM AIR-C1 is required to reduce the project’s potential impacts during construction to less than significant (see Impact Air C).

either United States Environmental Protection Agency (EPA) or California Air Resources Board (CARB) Tier 4 Interim off-road emission standards except as otherwise specified herein. If engines that comply with Tier 4 Interim or Tier 4 Final off- road emission standards are not commercially available, then the construction contractor shall use the next cleanest piece of off-road equipment (e.g., Tier 3) that is commercially available. For purposes of this project design feature, “commercially available” shall mean the equipment at issue is available taking into consideration factors such as (i) critical-path timing of construction; and (ii) geographic proximity to the project site of equipment. If the relevant equipment is determined by the project applicant to not be commercially available, the contractor can confirm this conclusion by providing letters from at least two rental companies for each piece of off-road equipment that is at issue.
• Option 2) Prior to the issuance of any demolition, grading, or building permits (whichever occurs earliest), the project applicant and/or construction contractor shall prepare a construction operations plan that, during construction activities, requires all off-road equipment with engines greater than 75 horsepower to meet either the particulate matter emissions standards for Tier 4 Interim engines or be equipped with Level 3 diesel particulate filters. Tier 4 Interim engines shall, at a minimum, meet EPA or CARB particulate matter emissions standards for Tier 4 Interim engines.

Alternatively, use of CARB-certified Level 3 diesel particulate filters on off-road equipment with engines greater than 75 horsepower can be used in lieu of Tier 4 Interim engines or in combination with Tier 4 Interim engines. The construction contractor shall maintain records documenting its efforts to comply with this requirement, including equipment lists. Off-road equipment descriptions and information shall include, but are not limited to, equipment type, equipment manufacturer, equipment identification number, engine model year, engine certification (Tier rating), horsepower, and engine serial number. The project applicant and/or construction contractor shall submit the construction operations plan and records of compliance to the City of Fresno.

14 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

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

Air Quality Plans (AQPs) are plans for reaching attainment of air quality standards. The assumptions, inputs, and control measures are analyzed to determine if the Air Basin can reach attainment for the ambient air quality standards. The proposed project site is located within the jurisdictional boundaries of the SJVAPCD. To show attainment of the standards, the SJVAPCD analyzes the growth projections in the Valley, contributing factors in air pollutant emissions and formations, and existing and adopted emissions controls. The SJVAPCD then formulates a control strategy to reach attainment that includes both State and SJVAPCD regulations and other local programs and measures.

The CEQA Guidelines indicate that a significant impact would occur if the project would conflict with or obstruct implementation of the applicable air quality plan. The GAMAQI indicates that projects that do not exceed SJVAPCD regional criteria pollutant emissions quantitative thresholds would not conflict with or obstruct the applicable AQP.

As shown above in Table 4 and Table 5, the project’s construction and operational regional emissions would not exceed SJVAPCD’s regional criteria pollutant emissions quantitative thresholds. Therefore, the proposed project would not be considered in conflict with or obstruct implementation of the applicable air quality plan.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard? Less Than Significant Impact.

To result in a less than significant impact, emissions of nonattainment pollutants must be below the SJVAPCD’s regional significance thresholds. This is an approach recommended by the SJVAPCD’s in its GAMAQI. The primary pollutants of concern during project construction and operation are ROG, NO X, PM10, and PM2.5. The SJVAPCD GAMAQI adopted in 2015 contains thresholds for CO, NO X, ROG, SOX, PM10, and PM2.5.

Air pollutant emissions have both regional and localized effects. As shown in Table 6 and Table 7, the project’s regional emissions would not exceed the applicable regional criteria pollutant emissions quantitative thresholds.
c) Expose sensitive receptors to substantial pollutant concentrations? Less than Significant Impact with Mitigation Incorporated.

Emissions occurring at or near the project have the potential to create a localized impact that could expose sensitive receptors to substantial pollutant concentrations. The SJVAPCD considers a sensitive receptor to be a location that houses or attracts children, the elderly, people with illnesses, or others who are especially sensitive to the effects of air pollutants. Examples of sensitive receptors include hospitals, residences, convalescent facilities, and schools.

As shown in Table 6, the project would not exceed the emission screening thresholds during project construction. Therefore, the project’s localized criteria pollutant impacts from construction of the project would be less than significant.

As shown in Table 7, the project would not exceed SJVAPCD screening thresholds for localized criteria pollutant impacts; therefore, the project’s localized criteria pollutant impacts from long-term operations would be less than significant.

Therefore, construction of the proposed project would not result in localized emissions that, if when combined with background emissions, would result in exceedance of any health -based air quality standard for any criteria pollutant. As such, health risk impacts related to criteria pollutants emitted during the construction period of the proposed project would be less than significant.

Construction-related activities would result in temporary, short-term project-generated emissions of diesel particulate matter (DPM) from the exhaust of off-road, heavy-duty diesel equipment for site preparation (e.g., clearing, grading); soil hauling truck traffic; paving; home construction; application of architectural coatings; and other miscellaneous activities. For construction activity, DPM is the primary air toxic of concern. Particulate exhaust emissions from diesel-fueled engines (i.e., DPM) were identified as a toxic air contaminant (TAC) by the California Air Resources Board (CARB) in 1998. 5 Due to proposed project’s proximity to existing sensitive receptors, a health risk assessment was performed to assess impacts from DPM emissions resulting from construction of the project. The results of the health risk assessment are summarized below, while the calculations used for the health risk assessment are provided as Attachment B.

The construction HRA evaluated DPM (represent as exhaust PM 10) emissions generated during construction of the proposed project and the related health risk impacts for sensitive receptors located within 1,000 feet of the project boundary. A project would result in a significant impact if it would individually expose sensitive receptors to TACs resulting in an increased cancer risk greater than 20 in one million or an increased non-cancer risk of greater than 1.0 on the hazard index. It should be noted that the SJVAPCD’s latest threshold of significance for TAC emissions is an increase in cancer risk for the maximally exposed individual of 20 in one million (formerly 10 in one million).

To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including DPM), a dispersion model6 (AERMOD) was used to translate an emission rate from the source location to concentrations at the receptor locations of interest (i.e., receptors at nearby residences). AERMOD provides a refined methodology for estimating localized impacts by utilizing long - term, measured representative meteorological data for the project site and a representative construction schedule. A graphical representation of AERMOD inputs, including the locations of modeled sensitive receptor locations, is included as part of Attachment B.

5 California Air Resources Board (CARB). 1998. The Toxic Air Contaminant Identification Process: Toxic Air Contaminant Emissions from Diesel-fueled Engines. Website: www.arb.ca.gov/toxics/dieseltac/factsht1.pdf. 6 An air dispersion model is a mathematical formulation used to estimate air quality impacts at specific locations (receptors) surrounding a source of emissions given the rate of emissions and prevailing meteorological conditions. The air dispersion model applied in this assessment was the EPA American Meteorological Society Regulatory Model (AERMOD), Version 21112, which is approved by the SJVAPCD for air dispersion assessments. 16 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

The recommend method for the estimation of cancer risk is shown in the equations.

Cancer Risk = CDPM x Inhalation Exposure Factor (EQ-1)
Where:

Cancer Risk = Total individual excess cancer risk defined as the cancer risk a hypothetical individual faces if exposed to carcinogenic emissions from a particular source for specified exposure durations; this risk is defined as an excess risk because it is above a nd beyond the background cancer risk to the population; cancer risk is expressed in terms of risk per million exposed individuals.

CDPM = Period average DPM air concentration calculated from the air dispersion model in µg/m 3 Inhalation is the most important exposure pathway to impact human health from DPM and the inhalation exposure factor is defined as follows:

Inhalation Exposure Factor=CPF x EF x ED x DBR x AAF/AT (EQ-2) Where:

CPF = Inhalation cancer potency factor for the TAC: 1.1 (mg/kg-day)-1 for DPM EF = Exposure frequency (days/year)
ED = Exposure duration (years of construction)
AAF = set of age-specific adjustment factors that include age sensitivity factors (ASF), daily breathing rates (DBR), and time at home factors (TAH)
AT = Averaging time period over which exposure is averaged (days) Chronic Non-Cancer Hazard
Non-cancer chronic impacts are calculated by dividing the annual average concentration by the Reference Exposure Level (REL) for that substance. The REL is defined as the concentratio n at which no adverse non-cancer health effects are anticipated. The following equation was used to determine the non-cancer risk:

Hazard Quotient = Ci/RELi

Where:

Ci = Concentration in the air of substance i (annual average concentration in μg/m3)
17 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

RELi = Chronic noncancer Reference Exposure Level for substance i (μg/m 3) Construction Health Risk Assessment Results
The results of the HRA prepared for project construction for cancer risk and long-term chronic cancer risk are summarized below. Construction emissions were estimated assuming adherence to all applicable rules, regulations, and project design features. The construction emissions were assumed to be distributed over the project area with a working schedule of eight hours per day and five days per week.

Emissions were adjusted by a factor of 4.2 to convert for use with a 24-hour-per-day, 365 day-per-year averaging period. Detailed parameters and complete calculations are included in Attachment B.

The estimated health and hazard impacts at the Maximally Exposed Receptor (MER) from the project’s construction emissions are provided in Table 9.

Table 9: Summary of the Health Impacts from Unmitigated Construction of the Proposed Project
Exposure Scenario
Maximum Cancer
Risk
(Risk per Million)
Chronic
Non-Cancer Hazard
Index1
Risks and Hazards at the MER 31.35 0.0241
Significance Threshold 20 1
Threshold Exceeded in Any Scenario? Yes No
Notes:

MER = maximally exposed receptor
Source: Construction Health Risk Assessment (Attachment B).

As shown in Table 9, estimated health risks from elevated DPM concentrations during construction of the proposed project would exceed the applicable cancer risk significance threshold at the MER. This represents a potentially significant construction TAC exposure impact. Therefore, mitigation is required to reduce the impact during the construction period to below a level of significance.

MM AIR-C1 requires the project applicant, project sponsor, or construction contractor to provide documentation to the City of Fresno that the construction fleet meet one of the following two requirements (1) all off-road diesel-powered construction equipment greater than 75 horsepower meet EPA or CARB Tier 4 Interim off-road emissions standards, or (2) off-road diesel-powered construction equipment greater than 75 horsepower be equipped with Level 3 diesel particulate filters or meet Tier 4 Interim emissions standards. Table 10 shows the health risks and non-cancer hazard index for construction with implementation of MM AIR-C1.
18 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 10: Summary of the Health Impacts from Mitigated Construction of the Proposed Project
Exposure Scenario
Maximum Cancer
Risk
(Risk per Million)
Chronic
Non-Cancer Hazard
Index1
Risks and Hazards at the MER - Mitigated (Tier 4 Option) Risks and Hazards at the MER 3.78 0.0029
Risks and Hazards at the MER - Mitigated (Level 3 Filters Option) Risks and Hazards at the MER 6.36 0.0049
Maximum Risks and Hazards at the MER1 After the Incorporation of Mitigation Measure AIR-2 Highest Risks and Hazards at the MER 6.36 0.0049
Significance Threshold 20 1
Threshold Exceeded in Either Mitigated Scenario? No No Notes:

MER = maximally exposed receptor
Source: Construction Health Risk Assessment (Attachment B).

As noted in Table 10, calculated health metrics from the proposed project’s construction DPM emissions would not exceed the cancer risk significance threshold or non-cancer hazard index significance threshold at the MER with incorporation of MM AIR-C1. Therefore, the proposed project would not result in a significant impact on nearby sensitive receptors from TACs during construction.

Operations
PM10 and PM2.5 are commonly used as proxies for Diesel Particulate Matter (DPM), which would be the toxic air containment of concern emitted by the project. Based on the screening analyzes presented in Table 7, estimated localized emissions generated by the proposed project would not reach levels high enough to necessitate further analysis. As such, it is not expected that any TAC concentrations would reach levels that would cause an exceedance of the SJVAPCD’s health risk thresholds.

Unlike warehouses or distribution centers, the daily vehicle trips generated by the proposed residential project would be primarily generated by passenger vehicles. Passenger vehicles typ ically use gasoline engines rather than the diesel engines that are found in heavy-duty trucks. Gasoline-powered vehicles do emit TACs in the form of toxic organic gases, some of which are carcinogenic. Compared to the combustion of diesel, the combustion of gasoline had relatively low emissions of TACs. Thus, residential and produce limited amounts of TAC emissions during operation. Nonetheless, it is anticipated that there would be some heavy-duty trucks visiting the project site during operations. Consistent with SJVAPCD guidance, an operational prioritization screening analysis was completed for the proposed project.

Operational DPM emissions from diesel trucks were estimated using emission factors from CARB’s EMFAC and estimated truck travel and idling at the project site based on average daily trips and the SJVAPCD-approved residential fleet mix. The emissions were entered into the SJVAPCD Prioritization Screening Tool to determine the risk scores, with complete calculations and assumptions inclu ded as part of Attachment A. The results of the screening analysis are provided in Table 11. 19 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 11: Prioritization Tool Health Risk Screening Results Impact Source Cancer Risk Score Chronic Risk Score Acute Risk Score Diesel Trucks 0.460 0.005 0.000
Total Risk from Project Operations 0.460 0.005 0.000
Screening Risk Score Threshold 10 1 1
Screening Thresholds Exceeded? No No No
Source: Attachment A – Modeling Assumptions, CalEEMod Output files, and Operational Screening Results

As shown in Table 11, the project would not exceed the cancer risk or chronic hazard threshold levels.

The primary source of the emissions responsible for chronic risk are from diesel trucks. DPM does not have an acute risk factor. Since the project does not exceed the applicable SJVAPCD screening thresholds for cancer risk, acute risk, or chronic risk, this impact would be less than significant.

The San Joaquin Valley is considered an endemic area for Valley fever. The San Joaquin Valley is considered an endemic area for Valley fever. During 2000–2018, a total of 65,438 coccidioidomycosis cases were reported in California; median statewide annual incidence was 7.9 per 100,000 population and varied by region from 1.1 in Northern and Eastern California to 90.6 in the Southern San Joaquin Valley, with the largest increase (15‐fold) occurring in the Northern San Joaquin Valley. Incidence has been consistently high in six counties in the Southern San Joaquin Valley (Fresno, Kern, Kings, Madera, Tulare, and Merced counties) and Central Coast (San Luis Obispo County) regions.7 California experienced 7,392 new probable or confirmed cases of Valley fever in 2020. A total of 466 Valley fever cases were reported in Fresno County in 2020.8
The distribution of C. immitis within endemic areas is not uniform and growth sites are commonly small (a few tens of meters) and widely scattered. Known sites appear to have some ecological factors in common suggesting that certain physical, chemical, and biological conditions are more favorable for C. immitis growth. Avoidance, when possible, of sites favorable for the occurrence of C. immitis is a prudent risk management strategy. Listed below are ecologic factors and sites favorable for the occurrence of C. immitis:
1) Rodent burrows (often a favorable site for C. immitis, perhaps because temperatures are more moderate and humidity higher than on the ground surface)

2) Old (prehistoric) Indian campsites near fire pits

7 Centers for Disease Control and Prevention (CDC). 2020. Regional Analysis of Coccidioidomycosis Incidence—California, 2000–2018. Website: https://www.cdc.gov/mmwr/volumes/69/wr/mm6948a4.htm?s_cid=mm6948a4_e. Accessed May 1, 2023.
8 California Department of Public Health (CDPH). 2021. Coccidioidomycosis in California Provisional Monthly Report January 2021. Website: https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciinCA ProvisionalMonthlyReport.pdf. Accessed May 1, 2023.
20 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

3) Areas with sparse vegetation and alkaline soils

4) Areas with high salinity soils

5) Areas adjacent to arroyos (where residual moisture may be available)

6) Packrat middens

7) Upper 30 centimeters of the soil horizon, especially in virgin undisturbed soils

8) Sandy, well-aerated soil with relatively high water-holding capacities

Sites within endemic areas less favorable for the occurrence of C. immitis include:
1) Cultivated fields

2) Heavily vegetated areas (e.g., grassy lawns)

3) Higher elevations (above 7,000 feet)

4) Areas where commercial fertilizers (e.g., ammonium sulfate) have been applied

5) Areas that are continually wet

6) Paved (asphalt or concrete) or oiled areas

7) Soils containing abundant microorganisms

8) Heavily urbanized areas where there is little undisturbed virgin soil.9

The project is situated on a site previously disturbed. The current site is primarily vacant, with sparse shrubbery; however, the site has been previously graded. In addition, the project site is surrounded by other parcels that are built-up or have been previously disturbed. The existing conditions do not provide a suitable habitat for spores. Specifically, the conditions are not favorable for the occurrence of C. immitis because the project site has been previously disturbed from being tilled. Therefore, implementation of the proposed project would have a low probability of the site having C. immitis growth sites and exposure to the spores from disturbed soil.

Although conditions are not favorable, construction activities could generate fugitive dust that contain C. immitis spores. The project will minimize the generation of fugitive dust during construction activities by complying with SJVAPCD’s Regulation VIII. Therefore, this regulation, combined with the relatively low probability of the presence of C. immitis spores would reduce Valley fever impacts to less than significant.

During operations, dust emissions are anticipated to be relatively small, because most of the project area where operational activities would occur would be occupied by the proposed residential homes and pavement. This condition would substantially lessen the possibility of the project from providing habitat suitable for C. immitis spores and for generating fugitive dust that may contribute to Valley fever exposure. Impacts would be less than significant.

Naturally Occurring Asbestos

9 United States Geological Survey (USGS). 2000. Operational Guidelines (Version 1.0) for Geological Fieldwork in Areas Endemic for Coccidioidomycosis (Valley Fever), 2000, Open-File Report 2000-348. Website:
https://pubs.usgs.gov/of/2000/0348/pdf/of00-348.pdf. Accessed May 1, 2023. 21 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Review of the map of areas where naturally occurring asbestos in California are likely to occur foun d no such areas in the project area. Therefore, development of the project is not anticipated to expose receptors to naturally occurring asbestos.10 Impacts would be less than significant.

Operations—The Project’s Potential to Locate Sensitive Receptor Near Existing Sources of TACs
As a residential project, the project would locate sensitive receptors to a site where future project residents could be subject to existing sources of TACs at the project site. However, the California Supreme Court concluded in California Building Industry Association (CBIA) v. Bay Area Air Quality Management District (BAAQMD) that agencies subject to CEQA are not required to analyze the impact of existing environmental conditions on a project’s future users or residents. Therefore, this impact will not be further addressed in this document.

Impact Analysis Summary
In summary, the project would not exceed SJVAPCD localized emission daily screening levels for any criteria pollutant. The project would not be a significant source of TAC emissions during operations and would be a less than significant source of TAC emissions during construction with implementation of mitigation. The project is not in an area with suitable habitat for Valley fever spores and is not in area known to have naturally occurring asbestos. Therefore, the project would not result in significant impacts to sensitive receptors. MM AIR-C1 is required to reduce the project’s potential impacts during construction to less than significant.

MM AIR-C1 Before a construction permit is issued for the proposed project, the project applicant, project sponsor, or construction contractor shall submit provide reasonably detailed compliance with one of the following requirements to the City of Fresno:
• Option 1) Where portable diesel engines are used during construction, all off-road equipment with engines greater than 75 horsepower shall have engines that meet either United States Environmental Protection Agency (EPA) or California Air Resources Board (CARB) Tier 4 Interim off-road emission standards except as otherwise specified herein. If engines that comply with Tier 4 Interim or Tier 4 Final off- road emission standards are not commercially available, then the construction contractor shall use the next cleanest piece of off-road equipment (e.g., Tier 3) that is commercially available. For purposes of this project design feature, “commercially available” shall mean the equipment at issue is available taking into consideration factors such as (i) critical-path timing of construction; and (ii) geographic proximity to the project site of equipment. If the relevant equipment is determined by the project applicant to not be commercially available, the contractor can confirm this conclusion by providing letters from at least two rental companies for each piece of off-road equipment that is at issue.
• Option 2) Prior to the issuance of any demolition, grading, or building permits (whichever occurs earliest), the project applicant and/or construction contractor shall prepare a construction operations plan that, during construction activities, requires all off-road equipment with engines greater than 75 horsepower to meet either the

10 U.S. Geological Survey. 2011. Van Gosen, B.S., and Clinkenbeard, J.P. California Geological Survey Map Sheet 59. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California. Open-File Report 2011-1188 Website: https://pubs.usgs.gov/of/2011/1188/. Accessed May 1, 2023. 22 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

particulate matter emissions standards for Tier 4 Interim engines or be equipped with Level 3 diesel particulate filters. Tier 4 Interim engines shall, at a minimum, meet EPA or CARB particulate matter emissions standards for Tier 4 Interim engines.

Two situations create a potential for odor impact. The first occurs when a new odor source is located near an existing sensitive receptor. The second occurs when a new sensitive receptor locates near an existing source of odor. According to the CBIA v. BAAQMD ruling, impacts of existing sources of odors on the project are not subject to CEQA review. Therefore, the analysis to determine if the project would locate new sensitive receptors near an existing source of odor is provided for informational purposes only.

Odor impacts on residential areas and other sensitive receptors, such as hospitals, day -care centers, schools, etc. warrant the closest scrutiny, but consideration should also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas.

For projects involving new receptors locating near an existing odor source where there is currently no nearby development and for new odor sources locating near existing receptors, the SJVAPCD recommends that the analysis should be based on a review of odor complaints for similar facilities. In assessing potential odor impacts, consideration also should be given to local meteorological conditions, particularly the intensity and direction of prevailing winds.

Although the project is less than one mile from the nearest sensitive receptor, the project is not expected to be a significant source of odors. The screening levels for these land use types are shown in Table 12. 23 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 12: Screening Levels for Potential Odor Sources
Odor Generator Screening Distance
Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Composting Facility 1 mile
Petroleum Refinery 2 miles
Asphalt Batch Plant 1 mile
Chemical Manufacturing 1 mile
Fiberglass Manufacturing 1 mile
Painting/Coating Operations (e.g., auto body shop) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Source of Screening Distances: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT- GAMAQI.PDF. Accessed May 1, 2023.

Impacts from construction and operations of the proposed project are discussed separately below.

Construction
During construction, various diesel-powered vehicles and equipment in use on-site would create localized odors. These odors would be temporary and intermittent, which would decrease the likelihood of the odors concentrating in a single area or lingering for any notable period of time. As such, these odors would likely not be noticeable for extended periods of time beyond the project’s site boundaries. The potential for odor impacts from construction of the proposed project would, therefore, be less than significant.

Although offensive odors rarely cause any physical harm, they still can be very unpleasant, leading to considerable distress and often generating citizen complaints to local governments and regulatory agencies. The project is residential in nature, and project operations would not be anticipated to produce odorous emissions. Therefore, project operations would not create objectionable odors affecting a substantial number of people; the impact would be less than significant.

Project as a Receptor
With the CBIA v. BAAQMD ruling, analysis of odor impacts on receivers is not required for CEQA compliance. Therefore, the following analysis is provided for informational purposes only, while the significance determination for the odor is whether the project would consider an odor generator. As a residential development, the project has the potential to place sensitive receptors near existing and new odor sources.
24 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Potential odor impacts in the City of Fresno were recently reviewed as part of the General Plan Update and related updated Program Environmental Impact Report (PEIR). As detailed in the City’s PEIR, there are no major odor‐generating sources that have received complaints to an extent that would exceed SJVAPCD-recommended thresholds for assessing odor impacts from odor generators. Furthermore, there are existing residential uses located within the screening distances for all the potential sources in the project vicinity. Considering this information, the uses in the vicinity of the project would not result in substantial odor impacts to the project.

25 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Greenhouse Gas Emissions Estimation Summary and Greenhouse Gas Impact Analysis CEQA Guidelines
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial, adverse change in the environment.” To determine if a project would have a significant impact on GHGs, the type, level, and impact of emissions generated by the project must be evaluated.

The following GHG significance thresholds are contained in Appendix G of the CEQA Guidelines:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
b. Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.

Thresholds of Significance
San Joaquin Valley Air Pollution Control District
The SJVAPCD’s Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA presents a tiered approach to analyzing project significance with respect to GHG emissions. Project GHG emissions are considered less than significant if they can me et any of the following conditions:
• Project is exempt from CEQA requirements;
• Project complies with an approved GHG emission reduction plan or GHG mitigation program; • Project implements Best Performance Standards (BPS); or • Project demonstrates that specific GHG emissions would be reduced or mitigated by at least 29 percent compared to Business-as-Usual (BAU), including GHG emission reductions achieved since the 2002-2004 baseline period.

City of Fresno
An updated GHG Reduction Plan was included as part of the recirculated Program Environmental Impact Report in March 2021 and adopted in September of 2021. 11 The following is a description of the Updated GHG Reduction Plan.

Since adoption of the GHG Plan (2014), two significant regulations/decisions have been established.

First, on September 28, 2016, Governor Brown signed SB 32 into law that sets a Statewide goal of reducing GHG emissions to 40 percent below 1990 levels by 2030. Additionally, on November 30, 2015, the California Supreme Court published its decision on the Newhall Ranch Specific Plan invalidating the EIR for a variety of reasons, including the use of a percent reduction below BAU as a threshold to determine significance of GHG emissions under CEQA without any supporting evidence. The GHG Plan Update ensures conformity with the mandates of California Supreme Court in the Newhall Ranch case and the State of California’s latest GHG regulations. The GHG Plan Update re-evaluates the City’s GHG reduction targets and existing reduction strategies from the 2014 GHG Plan. New goals and supporting measures are proposed to reflect and ensure compliance with changes in the local and State policies and regulations such as SB 32 and California’s 2017 Climate Change Scoping Plan.

11 City of Fresno. 2021. Plan and Projects Under Review: Program Environmental Impact Report for the City of Fresno General Plan Amendment No. P19-04226. Accessed May 1, 2023.
26 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

The GHG Reduction Plan Update was designed to be a “Qualified Plan,” according to CEQA Guidelines Section 15183.5.2. As noted in the response to comments for the Recirculated Draft Program EIR (Final Program EIR dated July 2021), the City of Fresno provides substantial evidence that the GHG Reduction Plan meets the requirements provided in CEQA Guidelines Section 15183.5. This demonstrates that the GHG Reduction Plan can be used to evaluate GHG impacts at the project-level for individual development projects within the City.

Newhall Ranch
The California Supreme Court decision in the Center for Biological Diversity et al. vs. California Department of Fish and Wildlife, the Newhall Land and Farming Company (62 Cal.4th 204 [2015], and known as the Newhall Ranch decision), confirmed that the use of BAU analysis (e.g., 29 percent below BAU), a performance-based approach, would be satisfactory. However, for a project-level analysis that uses CARB’s statewide BAU targets, substantial evidence must be presented to support the use of those targets for a particular project at a specific location. The court noted that this may require examination of the data behind the statewide model and adjustment to the levels of reduction from BAU used for project evaluation. To date, neither CARB nor any lead agencies have provided any guidance on how to adjust AB 32’s statewide BAU target for use at the project level.

The regulations in the State’s 2008 Scoping Plan have been adopted and the State is on track to meet the 2020 target and achieve continued progress towards meeting the 2017 Scoping Plan target for 2030 and the 2022 Scoping Plan target for 2045.

In the Newhall case, the Supreme Court was concerned that new development may need to reduce GHG emissions more than existing development to demonstrate it is meeting its fair share of reductions. New development does do more than its fair share through compliance with enhanced regulations, particularly with respect to motor vehicles, energy efficiency, and electricity generatio n. If no additional reductions are required from an individual project beyond that achieved by regulations, then the amount needed to reach the 2020 target is the amount of GHG emissions a project must reduce to comply with Statewide goals.

Project-level Thresholds
Section 15064.4(b) of the CEQA Guidelines’ amendments for GHG emissions states that a lead agency may take into account the following three considerations in assessing the significance of impacts from GHG emissions.
• Consideration #1: The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting.
• Consideration #2: Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
• Consideration #3: The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. Such regulations or requirements must be adopted by the relevant publi c agency through a public review process and must include specific requirements that reduce or mitigate the project’s incremental contribution of GHG emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, an Environmental Impact Report (EIR) must be prepared for the project.

The SJVAPCD’s Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA includes thresholds based on whether the project will reduce or mitigate GHG 27 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

levels by 29 percent from BAU levels compared with 2005 levels by 2020. 12 This level of GHG reduction is based on the target established by CARB’s AB 32 Scoping Plan, approved in 2008. First occupancy at the project site is expected to occur after the AB 32 2020 milestone year. Additional discussion is provided to show progress towards GHG reduction goals identified in CARB’s 2017 Scoping Plan for the year 2030. Although CARB adopted the 2022 Scoping Plan in December 2022 that addresses long -term GHG goals set forth by AB 1279,13 the 2017 Scoping Plan addresses a future GHG goal and remains relevant to the proposed project. Additionally, the goals of reducing GHG emissions 80 percent below 1990 levels by 2050 and the goal to achieve carbon neutrality statewide by 2045 are addressed in the analysis.

12 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2009. “Final Staff Report, Addressing Greenhouse Gas Emissions Impacts under the California Environmental Quality Act.” Website: http://www.valleyair.org/programs/CCAP/11‐05‐ 09/1_CCAP_FINAL_CEQA_GHG_Draft_Staff_Report_Nov_05_2009.pdf. December 2009. Accessed May 1, 2023. 13 The Final 2022 Scoping Plan was released on November 16, 2022 and adopted by CARB on December 15, 2022. 28 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Addressing Greenhouse Gas CEQA Impact Questions
Table 13: Summary of Greenhouse Gas Impact Analysis
Greenhouse Gas Emissions
Would the project: Significance Finding
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant
Impact
b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant
Impact with Mitigation
Incorporated

Greenhouse Gas Mitigation Measures
MM GHG-B1 is required to reduce the project’s potential impacts to conflict with City of Fresno’s Updated GHG Reduction Plan to less than significant (see Impact GHG B).

MM GHG-B1 Before a construction permit is issued for the proposed project, the project applicant, project sponsor, or construction contractor shall provide the City of Fresno with documentation of the following requirement:
• The project shall provide recycling canisters in public areas where trashcans are also provided.
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact.

To determine significance the analysis first quantifies project-related GHG emissions under a business- as-usual scenario, and then compare these emissions with those emissions that would occur when all project-related design features are accounted for, and when compliance with applicable regulatory measures is assumed. The standards and methodology are explained in further detail, below.

The project is assessed for consistency with the City of Fresno’s Updated GHG Reduction Plan under Impact GHG b).

Construction
GHG emissions generated during all phases of construction were combined and are shown in Table 14.

Neither the City of Fresno nor the SJVAPCD have adopted thresholds of significance for construction- related emissions. In addition, GHG emission reduction measures for construction equipment are relatively limited. Therefore, a standard practice is to amortize construction emissions over the anticipated lifetime of a project, so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies. To evaluate construction-related GHG emissions, the total emissions generated during construction were amortized based on the life of the development (30 years for residential development) and added to the operational emissions to determine the total emissions from the project, as shown below.

29 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 14: Summary of Construction-Generated Greenhouse Gas Emissions Construction Activity MT CO2e per Year
Site Preparation (2023) 18
Grading (2023) 46
Building Construction (2023) 170
Building Construction (2024) 150
Paving (2024) 22
Architectural Coating (2024) 3
Total Construction Duration (2023-2024)
Total Construction MTCO2e 409
Emissions Amortized Over 30 Years1 13.6
Notes:

MT CO2e = metric tons of carbon dioxide equivalent
1 Construction GHG emissions are amortized over the 30-year lifetime of the project.

Source: CalEEMod Output and Additional Supporting Information (Attachment A).

Operations
Operational or long-term emissions occur over the life of the project. Sources of emissions may include motor vehicles and trucks, energy usage, water usage, waste generation, and area sources, such as landscaping activities and residential woodburning. Operational GHG emissions associated with the proposed project were estimated using CalEEMod 2020.4.0.

Business-as-Usual Operational Emissions
Operational emissions under the business-as-usual scenario were modeled using CalEEMod 2020.4.0.

Modeling assumptions for the year 2005 were used to represent business as usual conditions (without the benefit of regulations adopted to reduce GHG emissions). CARB and SJVAPCD guidance recommend using regulatory conditions in 2002-2004 in the baseline scenario to represent conditions as if regulations had not been adopted to allow the effect of projected growth on achieving reduction targets to be clearly defined. CalEEMod defaults were used for project energy usage, water usage, waste generation, and area sources (architectural coating, consumer products, and landscaping). The vehicle fleet mixes were revised to reflect the appropriate residential project fleet mix for each scenario modeled.

Buildout Year Operational Emissions
Operational emissions for full project buildout were modeled for the 2023 operational year (full buildout scenario in the earliest operational year) and 2030 operational year scenarios using CalEEMod.

CalEEMod assumes compliance with some, but not all, applicable rules and regulat ions regarding energy efficiency, vehicle fuel efficiency, renewable energy usage, and other GHG reduction policies, as described in the CalEEMod User’s Guide.14
The reductions obtained from each regulation and the source of the reduction amount used in t he analysis are described below.

14 California Air Pollution Control Officers Association (CAPCOA). 2021. California Emission Estimator Model (CalEEMod) Version 2020.4.0 User’s Guide. Website: https://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/01_user-39-s- guide2020-4-0.pdf?sfvrsn=6. Accessed May 1, 2023.
30 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

The following regulations have not been incorporated into the CalEEMod emission factors and require alternative methods to account for emission reductions provided by the regulations:
• Renewables Portfolio Standard (RPS) requirements for year 2030 • Green Building Code Standards (indoor water use)
• California Model Water Efficient Landscape Ordinance (outdoor water) • CalRecycle 75 Percent Initiative (solid waste)
• 2022 Title 24 Energy Efficiency Standards

Title 24 reductions for 2013 and 2016 updates were added to CalEEMod 2016.3.2 and were carried into CalEEMod 2020.4.0. Title 24 reductions for 2019 were added to CalEEMod 2020.4.0; however, the additions do not account for on-site renewable energy that would be included as part of single-family residential projects. Therefore, the CalEEMod mitigation component was used to account for rooftop solar included as part of the proposed project.

Reductions in emissions from solid waste are based on the County of Fresno achieving the CalRecycle 75 Percent Initiative by 2020 compared with a 50 percent baseline for 2005. 15 No additional reductions were accounted for in the emission estimates prepared for the project.

Energy savings from water conservation resulting from the Green Building Code Standar ds for indoor water use and California Model Water Efficient Landscape Ordinance for outdoor water use are not included in CalEEMod. The Water Conservation Act of 2009 mandates a 20 percent reduction in urban water use that is implemented with these regulations.16 Benefits of the water conservation regulations are applied in the CalEEMod mitigation component.

Therefore, reported operational emissions are considered to represent unmitigated project conditions.

Operational GHG emissions by source are shown in Table 15 for the buildout year scenarios. Full buildout of the project was modeled in the 2023 operational year, as earliest occupancy is anticipated to occur as early as 2023.

15 California Department of Resources Recycling and Recovery (CalRecycle). 2023. California’s Short-Lived Climate Pollutant Reduction Strategy. Website: https://calrecycle.ca.gov/organics/slcp/. Accessed May 1, 2023. 16 California Department of Water Resources (CDWR). 2013. California Water Plan Update 2013, Chapter 3 Urban Water Use Efficiency.
31 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 15: Unmitigated Project Operational GHG Emissions (Buildout Year Scenario) Emission Source
Emissions (MT CO2e per year)
Business as Usual
Total Emissions (MT
CO2e per year)
Buildout Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 19.73 19.72
Energy 194 62
Mobile (On-road Vehicles) 566 408
Waste 23 17
Water 10 5
Amortized Construction Emissions 14 14
Total (MT CO2e per year) 827 526
Reduction from BAU (MT CO2e per year) 301
Percent Reduction 36.4%
Significance Threshold 29%
Exceeds Significance Threshold? No
MT CO2e = metric tons of carbon dioxide equivalent.

Totals were calculated using unrounded emissions; totals may not appear to sum exactly due to rounding.

Source of Significance Threshold: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://www.valleyair.org/transportation/GAMAQI- 2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 1, 2023.

Source of Business-as-Usual Emissions: CalEEMod output for the 2023 BAU scenario (see Attachment A).

Source of Buildout Year Emissions: CalEEMod output for project buildout in 2023 (Attachment A).

As shown in Table 15, the proposed project’s total GHG annual emissions would not exceed applicable thresholds of significance in either scenario analyzed.

The 2030 operational year scenarios are summarized in Table 16. As previously noted, the 2030 operational year was used to assess the project’s consistency with the SB 32 2030 target. The 2017 Scoping Plan addresses a future GHG goal and remains relevant to assess poten tial impacts from proposed project, which is expected to be built and operational prior to 2030.

32 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 16: Unmitigated Project Operational GHG Emissions (Year 2030 Scenario) Emission Source
Emissions (MT CO2e per year)
Business as Usual
Total Emissions (MT
CO2e per year)
2030 Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 19.73 19.72
Energy 194 62
Mobile (On-road Vehicles) 562 333
Waste 23 17
Water 10 5
Amortized Construction Emissions 14 14
Total (MT CO2e per year) 823 451
Reduction from BAU (MT CO2e per year) 372
Percent Reduction 45.2%
Significance Threshold 29%
Exceeds Significance Threshold? No
MT CO2e = metric tons of carbon dioxide equivalent.

Totals were calculated using unrounded emissions; totals may not appear to sum exactly due to rounding. 1 Adjusted threshold to account for 2017 Scoping Plan Update 40 percent reduction goal by 2030.

Source of Business-as-Usual Emissions: CalEEMod output for the 2030 BAU scenario (see Attachment A).

Source of 2030 Emissions: CalEEMod output for the year 2030 (Attachment A).

As shown in Table 15 and Table 16, the project would achieve a 36.4 percent reduction from BAU at project buildout (2023) and a 45.2 percent reduction from BAU by the year 2030 with adopted regulations and design features incorporated. These amounts are both exceed the 29 percent reduction required by the SJVAPCD threshold, and above the required 21.7 percent average reduction from all GHG emission sources to meet the AB 32 targets. CARB originally identified a reduction of 29 percent from business as usual as needed to achieve AB 32 targets. The 2008 recession and slower growth in the years since 2008 have reduced the growth forecasted for 2020 and the amount needed to be reduced to achieve 1990 levels as required by AB 32; the target was revised to 21.7 percent.

The 36.4 percent reduction from BAU is 14.7 percent beyond the average reduction required by the State from all sources to achieve the AB 32 2020 target (and 7.4 percent beyond the SJVAPCD’s threshold).

This surplus addresses the Supreme Court’s concern in the Newhall case that new development must do more than average to meet its fair share of emission reductions.

By 2030, the proposed project would achieve a 45.2 percent reduction from BAU or 23.5 percent above the 16.2 percent reduction necessary to meet the AB 32 reduction target.

The project’s occupancy is anticipated begin as early as 2023; thus, an additional analysis is provided to show consistency with post-2020 State legislative GHG goals. The SB 32 goal of 40 percent below 1990 emission levels by 2030 is the target established by the 2017 Scoping Plan Update.

The 2017 Scoping Plan includes strategies that are not incorporated in the analysis above. Many measures that are likely to proceed include zero net energy buildings in future updates to Title 24 and 33 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

enhanced motor vehicle fuel efficiency standards beyond 2025. The 2017 Scoping Plan identified an emission limit of 260 million metric tons of carbon dioxide equivalents (MMTCO 2e). The 2030 BAU Inventory is estimated to be 392 MMTCO2e. The 2017 Scoping Plan identified that the bulk of its reductions would come from the Electric Power, Industrial fuel combustion, and Transportation. The continuance of the Cap and Trade would provide additional reductions. Although the 2017 Scoping Plan largely relies on state actions to achieve the GHG emissions limit, the CARB consid ers local governments partners in achieving the State’s goals for reducing GHG emissions. The 2017 Scoping Plan suggests that all new land use development implement feasible measures to reduce GHG emissions, however, it does not define feasible measures nor assign a required reduction amount to new development. A fair share quantitative threshold based on the 2017 Scoping Plan is not presently feasible as the nexus between a project’s contribution and its fair share mitigation is not well defined.

Based on the 36.4 percent reduction from BAU for project buildout in the earliest operational year (2023), the proposed project would not have a significant impact on GHG emissions as it would meet the SJVAPCD’s threshold of 29 percent and exceed the CARB’s 21.7 percent reduction necessary from all sources to meet the AB 32 emissions limit.

For the year 2030, the project achieves a 45.2 percent reduction from BAU, which demonstrates substantial progress towards achieving the 2030 target.

Regarding the years 2045 and 2050, there have been Executive Orders issued to address carbon neutrality and GHG reduction targets, respectively for those years, however, there are no existing GHG reduction plans that specifically address those Orders. Historically, the State would take the lead in developing regulatory and market measures to achieve the required reductions. The proposed project would participate in the reductions through adherence with regulations and continued improvements to the motor vehicle efficiencies accessing the project site. Studies have shown that in order to meet the 2050 targets, aggressive pursuit of technologies in the transportation and energy sectors, including electrification and the decarbonization of fuel, will be required. Because of the technolo gical shifts required and the unknown parameters of the regulatory framework in 2050, quantitatively analyzing the proposed project’s impacts further relative to the 2050 goals is speculative for purposes of CEQA.

Impact Analysis Summary
In summary, the proposed project meets the required 29 percent below BAU guidance provided by the SJVAPCD. Furthermore, the proposed project shows substantial reductions in the year 2030 to demonstrate that it would not inhibit the State’s progress in achieving the 2030 GHG emissions target or emissions targets beyond 2030. The GHG emissions impact would be less than significant with respect to Consideration #1 and #2.
b) Conflict with any applicable plan, policy or regulation adopted for the purpose of r educing the emissions of greenhouse gases?
Less than Significant Impact with Mitigation Incorporated.

The following analysis assesses the proposed project’s compliance with Consideration No. 3 regarding consistency with adopted plans to reduce GHG emissions. The City of Fresno adopted its most recent GHG Reduction Plan Update as part of the General Plan Update in September 2021. The proposed project’s consistency the GHG Reduction Plan Update is assessed below. The proposed project is also assessed for its consistency with CARB’s adopted Scoping Plans, which include the 2008, 2017, and 2022 Scoping Plans.

34 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Consistency with City of Fresno’s Adopted Greenhouse Gas Reduction Plan The Fresno General Plan includes a GHG Reduction Plan that provides the City’s primary strategy for reducing GHG emissions. The intent of the GHG Reduction Plan is to achieve compliance with State GHG reduction mandates by focusing on feasible actions the City can take to minimize the adverse impacts of growth and development on climate change. The GHG Reduction Plan Update (2021) provides the following guidance to determine project-level impacts when the project does not require a general plan amendment.
(1) Review the GHG Reduction Plan Project Update CEQA Consistency Checklist that lists the local GHG reduction strategies identified in the GHG Reduction Plan Update to determine applicability to the project.
(2) Incorporate design features or mitigation measures into the project as needed to demonstrate consistency.
(3) Implement project design features suitable for the development type and location.

Proposed development projects that are consistent with the GHG Reduction Plan Update , as determined through the use GHG Plan Update CEQA Consistency Checklist, may rely on the GHG Reduction Plan Update for the cumulative impacts analysis of GHG emissions. Projects that are not consistent with the GHG Reduction Plan Update must prepare a comprehensive project-specific analysis of GHG emissions, including quantification of existing and projected GHG emissions and apply appropriate GHG reduction mitigation measures based on the GHG reduction strategies identified in the GHG Reduction Plan Update and listed in the checklist.

Table 17: GHG Reduction Plan Update Checklist Review—Determining Land Use Consistency
Checklist Item Project Consistency

1. Is the proposed project
consistent with the
approved General Plan,
Specific Plan, and
Community Plan planned
land use and zoning
designations?
If the answer is Yes, then
proceed to the GHG Plan
Update Consistency
Checklist.

The proposed project would consist of a 44-lot single family detached residential rental unit development on approximately 3.68 net acres at a density of approximately 11.96 du/acre, which is within the density range of the existing land use.

To facilitate development as proposed, the project will be required to submit the following entitlements:
• Annexation
• Prezone
• Tentative Tract Map
• Planned Development Permit
A general plan amendment is not required or proposed, as the proposed project is consistent with the existing planned land use. Considering this information, the appropriate step is to proceed to the GHG Reduction Plan Update Consistency Checklist.

A review of GHG Reduction Plan Update CEQA Consistency Checklist and an assessment of the project’s consistency with the measures are provided below in Table 18.

35 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Table 18: GHG Reduction Plan Update—CEQA Project Consistency Checklist Checklist Item1 Project Consistency
1: Land Use and Transportation Demand Strategies
a. Does the project include mixed-use, development? For GHG Reduction Plan consistency, mixed-use development
is defined as pedestrian-friendly development that blends two or more residential, commercial, cultural, or institutional, uses, one of which must be residential
Not applicable. The project is residential in
nature and does not include mixed-use
development.
b. Is the project high density? For GHG Reduction Plan
consistency, is the project developed at 12 units per acre or higher?
Not applicable. The project is not high density.

The proposed project would allow for the
construction of a residential subdivision that
consists of a 44-lot single family detached
residential rental unit development on
approximately 3.68 net acres at a density of
approximately 11.96 dwelling units per acre.
c. Is the project infill development, pursuant to the General Plan definition of location within the City limits as of December 31, 2012?
Consistent. The project site is an area that has
been designated for development in the City of
Fresno.
d. Does the project implement pedestrian bicycle, and transit linkages with surrounding land uses and neighborhoods?
For GHG Reduction Plan consistency, the project must
include all sidewalks, paths, trails, and facilities required by the General Plan and Active Transportation Plan, as
implemented through the Fresno Municipal Code and
project conditions of approval.

Consistent. The proposed project would be
designed and would be built in accordance with
all applicable regulations. The project will be
developed in conformance with all requirements
implemented through compliance with the Fresno
Municipal Code and through project conditions of
approval.
e. If the project includes mixed‐use or high density
development, is it located within ½ mile of a High Quality Transit Area as defined in the City’s CEQA Guidelines for Vehicle Miles Traveled? Or, is the project located within 500 feet of an existing or planned transit stop?
Consistent. The project is not mixed‐use or high
density development (as defined as 12 units per
acre or higher). The project would facilitate the
construction and development of a 44-lot single
family detached residential rental unit
development on approximately 3.68 net acres at
a density of approximately 11.96 dwelling units
per acre. There are several existing transit stops
located with ½-mile of the project site, the closet
of which is approximately 330 feet southeast
feet. Therefore, the project located within 500
feet of an existing or planned transit stop.
f. Will the project accommodate a large employer (over 100 employees) and will it implement trip reduction programs such as increasing transit use, carpooling, vanpooling, bicycling, or other measures to reduce vehicle miles traveled pursuant to San Joaquin Valley Air Pollution Control District Rule 9410?
See the SJVAPCD website for details:
https://www.valleyair.org/rules/currntrules/r9410.pdf
Not applicable. As a 44-unit residential
development, the proposed project would not be
considered a large employer once operational.
g. If the modifications to the transportation network project includes, do those improvements meet the requirements of the City of Fresno’s Complete Streets Policy, adopted in October 2019? According to the policy, a complete street is a transportation facility that is planned, designed, operated, and maintained to provide safe mobility for all users - including bicyclists, pedestrians, transit vehicles, trucks, and Not applicable. The project does not include
modifications to the transportation network.
36 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Checklist Item1 Project Consistency
motorists - appropriate to the function and context of the facility while connecting to a larger transportation network.

See City of Fresno website for details:
https://www.fresno.gov/publicworks/wp-
content/uploads/sites/17/2019/10/Complete-Streets-
091119.pdf
h. Does the project have a less than significant VMT impact, either through satisfying screening criteria or mitigating VMT impacts, pursuant to the City’s adopted VMT thresholds? See City of Fresno website for details:
https://www.fresno.gov/darm/wp-
content/uploads/sites/10/2021/01/CEQA-Guidelines-for-
Vehicle-Miles-Traveled-Final-Adopted-Version.pdf
Consistent. See the transportation impact
discussion of the environmental document
prepared for the proposed project for details.
2: Electric Vehicle Strategies
a. For new multi-family dwelling units with parking, does the project provide EV charging spaces capable of supporting future EV supply equipment (EV capable) at 10% of the
parking spaces per 2019 California Green Building
Standards Code (CALGREEN, Title 24, Part 11), Section

4.106.4
Not applicable. The project does not include
new multi-family dwelling units. Specifically, the
proposed project would consist of a 44-lot single
family detached residential rental unit
development on approximately 3.68 net acres at
a density of approximately 11.96 du/acre
b. For new commercial buildings, does project provide EV charging spaces capable of supporting EV capable spaces at 4% to 10% of the parking spaces per 2019 California
Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 5.106.5.3
Not applicable. The project does not include
new commercial buildings.
3: Energy Conservation Strategies
a. Does the project meet or exceed mandatory state building energy codes? If yes, does the project follow any other GreenPoint ratings such as LEED, Energy Star or others? If yes, indicate level of certification-Silver, gold, platinum if applicable?
Consistent. New structures (including new
single-family residential homes) are required to
comply with Title 24 Energy Efficiency Standards
that are expected to increase in stringency over
time. New homes constructed as part of the
proposed project would comply with the
applicable Title 24 Energy Efficiency Standards
in effect at the time building permits are received.

The current Title 24 regulations are the 2022
Title 24 standards, which become effective
January 1, 2023.
b. For commercial projects, does the project achieve net zero emissions electricity?
Mark NA if project will be permitted before 2030. Mark Yes if voluntary. Add source and capacity in explanation.

Not applicable. It is anticipated that the
proposed project would be permitted and
developed before 2030. In addition, the project
is not a commercial project. However, the homes
would be built in accordance with Title 24 Energy
Efficiency Standards. Compliance with Title 24
ensures that the residences will include on-site
renewable energy to power homes.
4: Water Conservation Strategies
a. Does the project meet or exceed the mandatory outdoor water use measures of the 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section

4.304?
Consistent. The project would comply with all
existing regulations.
37 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Checklist Item1 Project Consistency
If the project exceeds CalGreen Code mandatory measures provide methods in excess of requirements in the
explanation.

Examples include outdoor water conservation measures
such as; drought tolerant landscaping plants, compliant irrigation systems, xeriscape, replacing turf etc. Provide the conservation measure that the project will include in the explanation.
b. Does the project meet or exceed the mandatory indoor water use measures of the 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section

4.303?
If the project exceeds CalGreen Code, mandatory measures provide methods in excess of requirements in the
explanation. Examples may include water conserving
devices and systems such as water leak detection system, hot water pipe insulation, pressure reducing valves, energy efficient appliances such as Energy Star Certified
dishwashers, washing machines, dual flush toilets, point of use and/or tankless water heaters.

Consistent. Any new buildings (including new
dwelling units) associated with the proposed
project would be built to code and would meet or
exceed the mandatory indoor use measure of the
applicable California Green Building Standards
Code.
5: Waste Diversion and Recycling Strategies
a. Does the project implement techniques of solid waste segregation, disposal and reduction, such as recycling, composting, waste to energy technology, and/or waste
separation, to reduce the volume of solid wastes that must be sent to landfill facilities?
Consistent. Future residents would be served
by City of Fresno for residential recycling and
sold waste services. The City of Fresno provides
residents with three 96-gallon carts as a basic
level of service. There is one cart for trash (gray),
one for recyclables (blue), and one for green
waste (green). All carts are emptied on the same
day by automated collection trucks.2 As the
project consists of a 44-lot single family detached
residential rental unit development, waste
disposal may be handled by the facility. The
facility would implement techniques of solid
waste segregation.
b. During construction will the project recycle construction and demolition waste?
Consistent. The project would implement
techniques to reduce and recycle waste during
construction activities.
c. Does the project provide recycling canisters in public areas where trashcans are also provided?
Consistent with MM GHG-B1. The project
includes common recreation space that may
include trashcans for public use. The project
description and other project plans do not
indicate that recycling canisters would be
included. If trashcans are provided along
sidewalks or in the pocket park proposed as part
of residential project, implementation of MM
GHG-B1 would ensure that the project would be
consistent with this measure.

Sources:
1 City of Fresno. 2021. Greenhouse Gas Reduction Plan Update. March. 2 City of Fresno. 2022. Trash Disposal & Recycling, Residential Services. Website:
https://www.fresno.gov/publicutilities/trash-disposal-recycling/residential-services/. Accessed May 1, 2023.

38 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

As evaluated above in Table 18, the proposed project would not conflict with the GHG reduction goals identified in the City of Fresno’s adopted GHG Reduction Plan Update after incorporation of MM GHG-B1.

Several of the measures are not applicable to the project. Compliance with regulations enforced by the City of Fresno would ensure the project would not conflict with the City’s efforts to reduce community - generated GHG emissions. MM GHG-B1 is included to ensure the project will provide recycling canisters in any public areas where trashcans are also provided.

Consistency with AB 32 and the 2008 Scoping Plan
The State’s regulatory program implementing the 2008 Scoping Plan is now fully mature. All regulations envisioned in the Scoping Plan have been adopted, and the effectiveness of those regulations has been estimated by the agencies during the adoption process and then tracked to verify their effectiveness after implementation. The combined effect of this successful effort is that the State projects that it will achieve continued progress toward meeting post-2020 targets. Governor Brown, in the introduction to Executive Order B-30-15, stated “California is on track to meet or exceed the current target of reducing greenhouse gas emissions to 1990 levels by 2020, as established in the California Global Warming Solutions Act of 2006 (AB 32).”
Consistency with SB 32 and the 2017 Scoping Plan
The 2017 Climate Change Scoping Plan Update (2017 Scoping Plan) includes the strategy that the State intends to pursue to achieve the 2030 targets of Executive Order S‐3‐05 and SB 32. Although CARB adopted the 2022 Scoping Plan in December 2022 that addresses long-term GHG goals set forth by AB 1279,17 the 2017 Scoping Plan addresses a future GHG goal and remains relevant to the proposed project. The 2017 Scoping Plan includes the following summary of its overall strategy for reaching the 2030 target:
• SB 350
o Achieve 50 percent Renewables Portfolio Standard (RPS) by 2030. o Doubling of energy efficiency savings by 2030.
• Low Carbon Fuel Standard (LCFS)
o Increased stringency (reducing carbon intensity 18 percent by 2030, up from 10 percent in 2020).
• Mobile Source Strategy (Cleaner Technology and Fuels Scenario) o Maintaining existing GHG standards for light‐ and heavy‐duty vehicles. o Put 4.2 million zero‐emission vehicles (ZEVs) on the roads. o Increase ZEV buses, delivery and other trucks.
• Sustainable Freight Action Plan
o Improve freight system efficiency.
o Maximize use of near‐zero emission vehicles and equipment powered by renewable energy.
o Deploy over 100,000 zero‐emission trucks and equipment by 2030. • Short‐Lived Climate Pollutant (SLCP) Reduction Strategy

17 The Final 2022 Scoping Plan was released on November 16, 2022 and adopted by CARB on December 15, 2022. 39 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

o Reduce emissions of methane and hydrofluorocarbons 40 percent below 2013 levels by 2030.
o Reduce emissions of black carbon 50 percent below 2013 levels by 2030. • SB 375 Sustainable Communities Strategies
o Increased stringency of 2035 targets.
• Post‐2020 Cap‐and‐Trade Program
o Declining caps, continued linkage with Québec, and linkage to Ontario, Canada. o CARB will look for opportunities to strengthen the program to support more air quality co- benefits, including specific program design elements. In Fall 2016, CARB staff described potential future amendments including reducing the offset usage limit, redesigning the allocation strategy to reduce free allocation to support increased technology and energy investment at covered entities and reducing allocation if the covered entity increases criteria or toxics emissions over some baseline.
• By 2018, develop Integrated Natural and Working Lands Action Plan to secure California’s land base as a net carbon sink
Table 19 provides an analysis of the project’s consistency with the 2017 Scoping Plan Update measures.

Table 19: Consistency with SB 32 2017 Scoping Plan Update Scoping Plan Measure Project Consistency
SB 350 50% Renewable Mandate. Utilities subject
to the legislation will be required to increase their
renewable energy mix from 33% in 2020 to 50% in
2030. (The requirement is now 60% in 2030 per SB
100.)
Consistent: The project will purchase electricity from a utility subject to the SB 350 Renewable Mandate.

SB 350 Double Building Energy Efficiency by
2030. This is equivalent to a 20 percent reduction
from 2014 building energy usage compared to
current projected 2030 levels.

Not Applicable. This measure applies to existing
buildings. New structures, including new single-family
homes, are required to comply with Title 24 Energy
Efficiency Standards that are expected to increase in
stringency until residential housing achieves zero net
energy. The project consists of the construction of 44
new single-family homes and does not include
renovations to existing structures.

Low Carbon Fuel Standard. This measure requires
fuel providers to meet an 18 percent reduction in
carbon content by 2030.

Consistent. Vehicles accessing the project site will use fuel containing lower carbon content as the fuel standard is implemented.

Mobile Source Strategy (Cleaner Technology
and Fuels Scenario). Vehicle manufacturers will be
required to meet existing regulations mandated by
the LEV III and Heavy‐Duty Vehicle programs. The
strategy includes a goal of having 4.2 million ZEVs
on the road by 2030 and increasing numbers of ZEV
trucks and buses.

Consistent. Project residents can be expected to
purchase increasing numbers of more fuel efficient and
zero emission cars and trucks each year. The CALGreen
Code requires electrical service in new single-family
housing to be EV charger-ready. In addition, home
deliveries will be made by increasing numbers of ZEV
delivery trucks.

Sustainable Freight Action Plan. The plan’s target
is to improve freight system efficiency 25 percent by
increasing the value of goods and services
produced from the freight sector, relative to the
Not Applicable. The measure applies to owners and
operators of trucks and freight operations. The project is residential in nature and would not support freight
40 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Scoping Plan Measure Project Consistency
amount of carbon that it produces by 2030. This
would be achieved by deploying over 100,000
freight vehicles and equipment capable of zero
emission operation and maximize near‐zero
emission freight vehicles and equipment powered
by renewable energy by 2030.
operations. However, home deliveries are expected to
be made by increasing number of ZEV delivery trucks.

Short‐Lived Climate Pollutant (SLCP) Reduction
Strategy. The strategy requires the reduction of
SLCPs by 40 percent from 2013 levels by 2030 and
the reduction of black carbon by 50 percent from
2013 levels by 2030.

Consistent. The project will only include natural gas
hearths that produce very little black carbon compared
with wood burning fireplaces and heaters in-line with the SJVAPCD’s Guidance for Assessing and Mitigating Air
Quality Impacts mitigation measures.1
SB 375 Sustainable Communities Strategies.

Requires Regional Transportation Plans to include a
sustainable communities strategy for reduction of
per capita vehicle miles traveled.

Not applicable. The project is for tentative tract map to allow for the construction and development of 44 single- family homes and does not include the development of a
regional transportation plan. However, the project will provide residential development to increase development densities, which facilitates reductions to VMT.

Post‐2020 Cap‐and‐Trade Program. The Post
2020 Cap‐and‐Trade Program continues the
existing program for another 10 years. The Cap‐
and‐Trade Program applies to large industrial
sources such as power plants, refineries, and
cement manufacturers.

Consistent. The post‐2020 Cap‐and‐Trade Program
indirectly affects people who use the products and
services produced by the regulated industrial sources
when increased cost of products or services (such as
electricity and fuel) are transferred to the consumers. The Cap‐and‐Trade Program covers the GHG emissions
associated with electricity consumed in California,
whether generated in‐state or imported. Accordingly,
GHG emissions associated with CEQA projects’
electricity usage are covered by the Cap-and‐Trade
Program. The Cap‐and‐Trade Program also covers fuel
suppliers (natural gas and propane fuel providers and
transportation fuel providers) to address emissions from such fuels and from combustion of other fossil fuels not directly covered at large sources in the program’s first compliance period.

Natural and Working Lands Action Plan. CARB is
working in coordination with several other agencies
at the federal, state, and local levels, stakeholders,
and with the public, to develop measures as
outlined in the Scoping Plan Update and the
governor’s Executive Order B‐30‐15 to reduce GHG
emissions and to cultivate net carbon sequestration
potential for California’s natural and working land.

Not Applicable. The project is residential development
and will not be considered natural or working lands.

Source: California Air Resources Board (CARB). 2017. The 2017 Climate Change Scoping Plan Update. January 20.

41 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Consistency Regarding GHG Reduction Goals for 2050 under Executive Order S ‐3‐05 and GHG Reduction Goals for 2045 under the 2022 Scoping Plan
CARB adopted the 2022 Scoping Plan in December 2022 that addresses long -term GHG goals set forth by AB 1279.18 The 2022 Scoping Plan outlines the State’s pathway to achieve carbon neutrality and an 85 percent reduction in 1990 emissions goal by 2045. In the 2022 Scoping Plan, CARB advocates for compliance with a local GHG reduction strategy consistent with CEQA Guidelines section 15183.5.

The 2022 Scoping Plan outlines approaches that lead agencies may consider for evaluating the consistency of proposed plans and residential and mixed-use projects with the State’s climate goals. In other words, the 2022 Scoping Plan considers approaches to evaluate whether a project may have a less than significant impact on GHG emissions, though it notes that these approaches are recommendations only and that they do not supplant lead agencies’ discretion to develop their own evidence -based approaches for determining whether a project would result in a potentially significant impact on GHG emissions.

One approach involves assessing the project’s consistency with a GHG reduction plan, such as a CEQA - qualified climate action plan. As previously discussed, the Fresno General Plan includes a GHG Reduction Plan that provides the City’s primary strategy for reducing GHG emissions. The intent of the GHG Reduction Plan is to achieve compliance with State GHG reduction mandates by focusing on feasible actions the City can take to minimize the adverse impacts of growth and development on climate change. The GHG Reduction Plan Update (2021) provides the following guidance to determine project - level impacts when the project does not require a general plan amendment. Based on the proposed project’s consistency with the City of Fresno’s The GHG Reduction Plan Update after incorporation of MM GHG-B1 (see Table 18), the proposed project is considered consistent with the 2022 Scoping Plan and AB 1279’s goal of achieving statewide carbon net neutrality by 2045.

Regarding goals for 2050 under Executive Order S‐3‐05, at this time it is not possible to quantify the emissions savings from future regulatory measures, as they have not yet been developed; nevertheless, it can be anticipated that operation of the project would comply with whatever measures are enacted th at state lawmakers decide would lead to an 80 percent reduction below 1990 levels by 2050. In its 2008 Scoping Plan, CARB acknowledged that the “measures needed to meet the 2050 are too far in the future to define in detail.” In the First Scoping Plan Update; however, CARB generally described the type of activities required to achieve the 2050 target: “energy demand reduction through efficiency and activity changes; large scale electrification of on‐road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and rapid market penetration of efficiency and clean energy technologies that requires significant efforts to deploy and scale markets for the cleanest technologies immediately.” The 2017 Scoping Plan provides an intermediate target that is intended to achieve reasonable progress toward the 2050 target. In addition, the 2022 Scoping Plan outlines objectives, regulations, planning efforts, and investments in clean technologies and infrastructure that outlines how the State can achieve carbon-neutrality by 2045.

Accordingly, taking into account the proposed project’s emissions, project design features, and the progress being made by the State towards reducing emissions in key sectors such as transportation, industry, and electricity, the project would be consistent with State GHG Plans and would further the State’s goals of reducing GHG emissions to 1990 levels by 2020, 40 percent below 1990 levels by 2030,

18 The Final 2022 Scoping Plan was released on November 16, 2022 and adopted by CARB on December 15, 2022. 42 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

carbon neutral by 2045, and 80 percent below 1990 levels by 2050, and does not obstruct their attainment. Impacts would be less than significant.

Impact Analysis Summary
The proposed project would not conflict with the GHG reduction goals identified in the City of Fresno’s adopted GHG Reduction Plan Update after incorporation of MM GHG-B1. MM GHG-B1 is included to ensure the project will provide recycling canisters in any public areas where trashcans are also provided.

In addition, the project would not conflict with CARB’s adopted 2017 Scoping Plan or CARB’s 2022 Scoping Plan. Because the project would be consistent with the City of Fresno’s GHG Reduction Plan Update, it follows that the project would not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs. MM GHG-B1 is required for the project to be consistent with the City of Fresno’s adopted GHG Reduction Plan Update. Therefore, impacts would be less than significant with the incorporation of mitigation.

43 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Energy
Environmental Setting
Pacific Gas and Electric Company (PG&E) provides electricity and natural gas service to the City of Lakeport. Upon buildout of the project site, electricity to the project site would be provided by PG& E. All electricity infrastructure would be located underground and would tie-in to existing infrastructure.

In 2020, approximately 85 percent of the electricity PG&E supplied was from GHG -free sources including nuclear, large hydroelectric, and eligible renewable sources of energy.19 Methodology
The energy requirements for the proposed project were determined using the construction and operational estimates generated from the Air Quality Analysis (refer to Attachment A for related CalEEMod output files). The calculation worksheets for fuel consumption rates for off-road construction equipment and on-road vehicles are provided in Attachment C. Short-term construction energy consumption is discussed below.

Short-Term Construction
Off-Road Equipment
The proposed project is anticipated to begin construction as early as 2023 and conclude in 2024. Table 20 provides estimates of the project’s construction fuel consumption from off-road construction equipment for the entire project, categorized by construction activity.

Table 20: Construction Off-Road Fuel Consumption
Project Component Construction Phase Fuel Consumption (gallons) Tract No. 6432
Project (On-site, Off-
road Equipment Use)
Site Preparation 703
Grading 1,100
Building Construction 12,781
Paving 843
Architectural Coating 124
Total 15,551
Notes:

Totals may not appear to sum correctly due to rounding.

Source: Energy Consumption Calculations (Attachment C).

As shown in Table 20, use of off-road equipment associated with construction of the proposed project is estimated to consume approximately 15,551 gallons of diesel fuel over the entire construction duration.

There are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the City of Fresno or the larger Fresno County region. Therefore, it is expected that construction fuel consumption associated with the proposed project would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the region.

19 Pacific Gas & Electric (PG&E). 2021. Corporate Sustainability Report 2021. Website:
https://www.pgecorp.com/corp_responsibility/reports/2021/pf04_renewable_energy.html. Accessed May 1, 2023. 44 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

On-Road Vehicles
On-road vehicles for construction workers, vendors, and haulers would require fuel for travel to and from the site during construction. Table 21 provides an estimate of the total on-road vehicle fuel usage during construction. There are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sit es in other parts of the state. Therefore, it is expected that construction fuel consumption associated with the proposed project would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the region.

Table 21: Construction On-Road Fuel Consumption
Project
Component Construction Phase
Vehicle Miles Traveled
(miles over the
construction duration)
Total Fuel Consumption
(gallons of fuel over the
construction duration)
Tract No. 6432
Project (On-site,
Off-road
Equipment Use)
Site Preparation 2,224 114
Grading 15,980 2,058
Building Construction 44,216 2,192
Paving 9,456 530
Architectural Coating 1,552 62
Total 73,428 4,956
Notes:

Totals may not appear to sum correctly due to rounding.

Source: Energy Consumption Calculations (Attachment C).

Long-Term Operations
Transportation Energy Demand
Table 22 provides an estimate of the daily and annual fuel consumed by vehicles traveling to and from the proposed project. These estimates were derived using the same assumptions used in the operation al air quality analysis for the proposed project.

Table 22: Long-Term Operational Vehicle Fuel Consumption Vehicle Type
Percent of
Vehicle
Trips Annual VMT
Average Fuel
Economy
(miles/ gallon)
Total Daily Fuel
Consumption
(gallons)
Total Annual Fuel
Consumption
(gallons)
Passenger Cars (LDA) 53.05 636,072 32.59 53.5 19,519
Light Trucks (Pickups)
and Medium Vehicles 42.81 513,294 23.82 59.0 21,545
Light-Heavy to Medium-
Heavy Diesel Trucks 1.05 12,590 11.59 3.0 1,086
Heavy-heavy Trucks 2.18 26,138 7.03 10.2 3,719
Motorcycles 0.25 2,998 37.85 0.2 79
Other 0.66 7,913 6.75 3.2 1,172
Total 100.0 1,199,005 — 129.1 47,120
Notes:

VMT = vehicle miles traveled
Percent of Vehicle Trips and VMT provided by CalEEMod.
“Other” consists of buses and motor homes.
45 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Vehicle Type
Percent of
Vehicle
Trips Annual VMT
Average Fuel
Economy
(miles/ gallon)
Total Daily Fuel
Consumption
(gallons)
Total Annual Fuel
Consumption
(gallons)
Source: Energy Consumption Calculations (Attachment C).

As shown above, annual vehicular fuel consumption is estimated to be 47,120 gallons of gasoline and diesel fuel combined. Using rates calculated for the 2023 operational year, daily consumption is estimated at 129 gallons of fuel (see Attachment C).

Building Energy Demand
As shown in Table 23 and Table 24, the proposed project is estimated to demand 366,100 kilowatt-hours (kWh) of electricity and 1,057,650 1,000-British Thermal Units (kBTU) of natural gas, respectively, on an annual basis. It should be noted that the single-family homes would be built with rooftop solar, consistent with applicable Tile 24 building code requirements.

Table 23: Long-Term Electricity Usage
Land Use
Total Electricity Demand
(kWh/year)
Internal Paved Roads represented as Parking Lot 15,246
Single Family Housing 350,854
Total 366,100
Source: Energy Consumption Calculations (Attachment C).

Table 24: Long-Term Natural Gas Usage
Land Use
Total Natural Gas Demand
(kBTU/year)
Single Family Housing 1,057,650
Total 1,057,650
Source: Energy Consumption Calculations (Attachment C).

Addressing Energy CEQA Impact Questions
This section discusses potential energy impacts associated with the proposed project and provides mitigation measures where necessary.

Table 25: Summary of Energy Impact Analysis
Energy
Would the project: Significance
Finding
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less than
Significant Impact
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less than Significant Impact

46 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less Than Significant Impact.

This impact addresses the energy consumption from both the short-term construction and long-term operations are discussed separately below.

Construction Energy Demand
As summarized in Table 20 and Table 21, the proposed project would require 15,551 gallons of diesel fuel for construction off-road equipment and 4,956 gallons of gasoline and diesel for on-road vehicles during construction. There are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or other parts of the state. In addition, the overall construction schedule and process is already designed to be efficient in order to avoid excess monetary costs. For example, equipment and fuel are not typically used wastefully due to the added expense associated with renting the equipment, maintaining it, and fueling it. Therefore, it is expected that construction fuel consumption associated with the proposed project would not be any more inefficient, wasteful, or unnecessary than at other construction sites in the region, and as such, impacts would be less than significant.

Long-Term Energy Demand
Building Energy Demand
Buildings and infrastructure constructed pursuant to the proposed project would comply with the versions of CCR Titles 20 and 24, including California Green Building Standards (CALGreen ), that are applicable at the time that building permits are issued. The proposed project is estimated to demand 366,100 kWh of electricity per year (54,915 off-site demand, assuming solar panels will cover approximately 85 percent of the project’s electricity demand) and 1,057,650 kBTU of natural gas per year. This would represent an increase in demand for electricity and natural gas.

It would be expected that building energy consumption associated with the proposed project would not be any more inefficient, wasteful, or unnecessary than for any other similar buildings in the region. Current state regulatory requirements for new building construction contained in the 2022 CALGreen and Title 24 standards would increase energy efficiency and reduce energy demand in comparison to existing commercial structures, and therefore would reduce actual environmental effects associated with energy use from the proposed project. Additionally, the CALGreen and Title 24 standards have increased efficiency standards through each update.

Therefore, while the proposed project would result in increased electricity and natural gas demand, the electricity and natural gas would be consumed more efficiently and would be typical of existing industrial development.

Based on the above information, the proposed project would not result in the inefficient or wasteful consumption of electricity or natural gas, and impacts would be less than significant.

Transportation Energy Demands
The daily vehicular fuel consumption is estimated to be 129.1 gallons of gasoline and diesel fuel combined. Annual consumption is estimated at 47,120 gallons. In addition, the proposed project would constitute development within an established community and would not be opening a new geographical area for development. As such, the proposed project would not result in unusually long trip lengths for future residents, visitors, or deliveries to the proposed homes. The project site is located near other 47 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

residential land uses and is in close proximity to commercial and public uses. The proposed project would be well-positioned to accommodate an existing community and provide housing for planned growth.

Vehicles accessing the site would be typical of vehicles accessing similar residential uses in the City of Fresno and surrounding areas. For these reasons, it would be expected that vehicular fuel consumption associated with the proposed project would not be any more inefficient, wasteful, or unnecessary than for any other similar land use activities in the region, and impacts would be less than significant. b) Conflict with or obstruct a state or local plan for renewable energy or energ y efficiency? Less Than Significant Impact.

The project proposes a tentative tract map that would facilitate the construction and development of 44 new single-family homes, all of which would be built in accordance with all applicable rules and regulations. Compliance with established and applicable regulations would ensure that the project and would not conflict with or obstruct any state or local plan for renewable energy or energy eff iciency.

Moreover, compliance with Title 24 standards would ensure that the proposed project would not conflict with any energy conservation policies related to the proposed project’s building envelope, mechanical systems, and indoor and outdoor lighting. In addition, the proposed project would constitute development within an established community. As such, the project would not be opening a new geographical area for development such that it would not result in unusually long trip lengths for future project residents.

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

48 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

Attachments
Attachment A – Modeling Assumptions, CalEEMod Output files, and Operational Screening Results Attachment B – Construction Health Risk Assessment
Attachment C – Energy Consumption Calculations

49 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project—Fresno, California Air Quality, Greenhouse Gas, and Energy Technical Memorandum May 15, 2023

ATTACHMENT A
Modeling Assumptions, CalEEMod Output files, and
Operational Screening Results

50 CalEEMod Output and Additional Supporting Information Table of Contents

Additional Supporting Information
• Tulare & Peach Tract No. 6432 Project Residential Project Construction Assumptions • Project Site Plan
• Project Site Vicinity Map
CalEEMod Output Files
• Unmitigated Construction & Project Buildout Operations in the Earliest Year (2023) • Mitigated Construction – Tier 4 Scenario
• Mitigated Construction – Level 3 Filters Scenario
• Maximum Daily On-site and Localized Construction and Operational Emissions • Business as Usual Scenario – 2023 Buildout Operational Year Scenario • Business as Usual Scenario – 2030 Operational Year Scenario • 2030 Operational Scenario
Operational Health Risk Screening
• Screening Calculations and Prioritization

51 Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432 Project Construction Assumptions
Construction Schedule
Phase Name Start Date End Date
Site Preparation 6/1/2023 6/14/2023 5 10
Grading 6/15/2023 7/12/2023 5 20
Building Construction 7/13/2023 5/29/2024 5 230
Paving 5/30/2024 6/26/2024 5 20
Architectural Coating 6/27/2024 7/24/2024 5 20
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours
Site Preparation Rubber Tired Dozers 3 8 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8 97 0.37
Grading Excavators 1 8 158 0.38
Grading Graders 1 8 187 0.41
Grading Rubber Tired Dozers 1 8 247 0.40
Grading Tractors/Loaders/Backhoes 3 8 97 0.37
Paving Pavers 2 8 130 0.42
Paving Paving Equipment 2 8 132 0.36
Paving Rollers 2 8 80 0.38
Building Construction Cranes 1 7 231 0.29
Building Construction Forklifts 3 8 89 0.20
Building Construction Generator Sets 1 8 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7 97 0.37 Building Construction Welders 1 8 46 0.45
Architectural Coating Air Compressors 1 6 78 0.48
Construction Trips and VMT
Phase Name
Site Preparation 18 0 14 10.8 7.3 20
Grading 15 0 637 10.8 7.3 20
Paving 15 4 12 10.8 7.3 20
Building Construction 34 12 18 10.8 7.3 20
Architectural Coating 7 0 2 10.8 7.3 20
Hauling Trip
Length
Num Days
Load Factor
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Num Days
Week
Horse Power
Worker Trip
Number
52 53
54 TT 6432 Residential Project - Unmitigated Construction & Operations Fresno County, Annual
Project Characteristics - Tulare and Peach Vesting Tentative Tract Map for Tract No. 6432
- Unmitigated Construction & Operations
Full buildout in anticipated earliest year of operations ( 2023
)
Land Use -
44 units analyzed, consistent with project description
Tract
6432
Project Site Gross Acres:

4.18 acres
Added additional one (
1 ) acre to account for off-site improvements (curb, gutter, sidewalk, etc.) Construction Phase - Construction - earlier dates provide a more conservative estimate of emissions Trips and VMT - Additional truck trips were added to each phase for mobilization/demobilization of on-site equipment (two trips per piece of equipment).

Additional vendor trips added to the paving phase to account for delivery of materials.

Grading - Cut/fill anticipated to balance on-site
Included
2,500
cy of import and
2,500
cy of export to provide a conservative estimate of emissions Architectural Coating - Rule 4601 Architectural Coatings Vehicle Trips - ITE 11th Edition Rates for single-family homes (ITE Land Use 210) Woodstoves - SJVAPCD Rule 4901 Woodburning

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Parking Lot

1.00 Acre

1.00 43,560.00
0 Single Family Housing

44.00 Dwelling Unit

4.18 88,000.00
126

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s)
Precipitation Freq (Days)

2.2 45

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
Pacific Gas and Electric Company
2023
Operational Year
CO2 Intensity
(lb/MWhr)
203.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 5/14/2023 7:15 PM

Page 1 of 32 ends

Fresno City CouncilOctober 16, 2025

Fresno City Council
October 16, 2025