Exhibit A - Resolution Certifying EIR — Fresno City Council, October 30, 2025 (part 1 of 3)

E
xhibit A

Exhibit A -1

July 2025

PUBLIC REVIEW DRAFT

E N V I R O N M E N T A L I M P A C T R E P O R T

FRESNO VMT REDUCTION PROGRAM

FRESNO, CALIFORNIA
STATE CLEARINGHOUSE NUMBER: 2024091129

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July 2025

PUBLIC REVIEW DRAFT

E N V I R O N M E N T A L I M P A C T R E P O R T

FRESNO VMT REDUCTION PROGRAM

FRESNO, CALIFORNIA
STATE CLEARINGHOUSE NUMBER: 2024091129

Submitted to:

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

Prepared by:

LSA
2565 Alluvial Avenue, Suite 112
Clovis, California 93611
559.490.1210

Project No. 20241626

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TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................... i FIGURES AND TABLES ............................................................................................................................. v

1.0 EXECUTIVE SUMMARY ...................................................................................... 1-1

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

1.2 Project Summary ............................................................................................................... 1-1

1.2.1 Project Location ..................................................................................................................... 1-1

1.2.2 Project Description ................................................................................................................ 1-1

1.2.3 Project Objectives .................................................................................................................. 1-2

1.2.4 Significant Unavoidable Adverse Impacts .............................................................................. 1-2

1.2.5 Lead Agency, Responsible and Trustee Agencies ................................................................... 1-2

1.3 Summary of Project Alternatives ...................................................................................... 1-3

1.3.1 No Project Alternative ........................................................................................................... 1-3

1.3.2 All Applicable Fee Alternative ................................................................................................ 1-3

1.4 Areas of Controversy ......................................................................................................... 1-3

1.5 Public Review of the Draft EIR ........................................................................................... 1-4

1.6 Executive Summary Matrix................................................................................................ 1-5

2.0 INTRODUCTION ................................................................................................ 2-1

2.1 Purpose of this EIR ............................................................................................................ 2-1

2.2 Environmental Review Process ......................................................................................... 2-1

2.3 Intended Uses of This EIR .................................................................................................. 2-2

2.4 Proposed Project ............................................................................................................... 2-3

2.5 EIR Scope ........................................................................................................................... 2-4

2.6 Report Organization .......................................................................................................... 2-4

2.7 Public Participation ........................................................................................................... 2-5

3.0 PROJECT DESCRIPTION ..................................................................................... 3-1

3.1 Project Location and Setting.............................................................................................. 3-1

3.1.1 Project Location ..................................................................................................................... 3-1

3.1.2 Project Setting ....................................................................................................................... 3-1

3.2 Background and History .................................................................................................... 3-2

3.3 Proposed Project ............................................................................................................... 3-3

3.4 Project Objectives ............................................................................................................. 3-8

3.5 Discretionary Approvals .................................................................................................... 3-9

3.5.1 City of Fresno ......................................................................................................................... 3-9

3.5.2 California Department of Transportation (Caltrans) .............................................................. 3-9

3.5.3 Other Responsible/Trustee Agencies ..................................................................................... 3-9

4.0 EVALUATION OF ENVIRONMENTAL IMPACTS ..................................................... 4-1 Determination of Significance .................................................................................................... 4-1 Issues Addressed in the Draft EIR ............................................................................................... 4-1 Environmental Setting ................................................................................................................ 4-1 Cumulative Analysis Context ...................................................................................................... 4-2 Format of Issue Section .............................................................................................................. 4-2

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Environmental Issues .................................................................................................................. 4-3

4.1 Aesthetics ....................................................................................................................... 4.1-1

4.1.1 Existing Environment Setting .............................................................................................. 4.1-1

4.1.2 Regulatory Setting .............................................................................................................. 4.1-2

4.1.3 Impacts and Mitigation Measures ...................................................................................... 4.1-3

4.2 Agriculture and Forestry Resources ............................................................................... 4.2-1

4.2.1 Existing Environment Setting .............................................................................................. 4.2-1

4.2.2 Methodology ...................................................................................................................... 4.2-1

4.2.3 Regulatory Setting .............................................................................................................. 4.2-1

4.2.4 Impacts and Mitigation Measures ...................................................................................... 4.2-5

4.3 Air Quality ...................................................................................................................... 4.3-1

4.3.1 Existing Environment Setting .............................................................................................. 4.3-1

4.3.2 Regulatory Setting ............................................................................................................ 4.3-13

4.3.3 Impacts and Mitigation Measures .................................................................................... 4.3-28

4.4 Biological Resources ....................................................................................................... 4.4-1

4.4.1 Existing Environment Setting .............................................................................................. 4.4-1

4.4.2 Regulatory Setting ............................................................................................................ 4.4-13

4.4.3 Impacts and Mitigation Measures .................................................................................... 4.4-21

4.5 Cultrual Resources and Tribal Cultural Resources .......................................................... 4.5-1

4.5.1 Existing Environment Setting .............................................................................................. 4.5-1

4.5.2 Regulatory Setting ............................................................................................................ 4.5-12

4.5.3 Impacts and Mitigation Measures .................................................................................... 4.5-18

4.6 Energy ............................................................................................................................. 4.6-1

4.6.1 Existing Environment Setting .............................................................................................. 4.6-1

4.6.2 Regulatory Setting .............................................................................................................. 4.6-3

4.6.3 Impacts and Mitigation Measures ...................................................................................... 4.6-6

4.7 Geology and Soils ........................................................................................................... 4.7-1

4.7.1 Existing Environment Setting .............................................................................................. 4.7-1

4.7.2 Regulatory Setting .............................................................................................................. 4.7-9

4.7.3 Impacts and Mitigation Measures .................................................................................... 4.7-17

4.8 Greenhouse Gas Emissions ............................................................................................ 4.8-1

4.8.1 Existing Environment Setting .............................................................................................. 4.8-1

4.8.2 Regulatory Setting .............................................................................................................. 4.8-5

4.8.3 Impacts and Mitigation Measures .................................................................................... 4.8-16

4.9 Hazards and Hazardous Materials .................................................................................. 4.9-1

4.9.1 Existing Environment Setting .............................................................................................. 4.9-1

4.9.2 Regulatory Setting .............................................................................................................. 4.9-9

4.9.3 Impacts and Mitigation Measures .................................................................................... 4.9-16

4.10 Hydrology and Water Quality ....................................................................................... 4.10-1

4.10.1 Existing Environment Setting ......................................................................................... 4.10-1

4.10.2 Regulatory Setting .......................................................................................................... 4.10-5

4.10.3 Impacts and Mitigation Measures ............................................................................... 4.10-11

4.11 Land Use and Planning ................................................................................................. 4.11-1

4.11.1 Environmental Setting ................................................................................................... 4.11-1

4.11.2 Regulatory Setting .......................................................................................................... 4.11-2

4.11.3 Impacts and Mitigation Measures ............................................................................... 4.11-10

4.12 Mineral Resources ........................................................................................................ 4.12-1

4.12.1 Existing Environmental Setting ...................................................................................... 4.12-1 iii

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4.12.2 Regulatory Setting .......................................................................................................... 4.12-1

4.12.3 Impacts and Mitigation Measures ................................................................................. 4.12-2

4.13 Noise............................................................................................................................. 4.13-1

4.13.1 Methodology ................................................................................................................. 4.13-1

4.13.2 Existing Environmental Setting ...................................................................................... 4.13-6

4.13.3 Regulatory Setting .......................................................................................................... 4.13-8

4.13.4 Impacts and Mitigation Measures ............................................................................... 4.13-15

4.14 Population and Housing ............................................................................................... 4.14-1

4.14.1 Existing Environmental Setting ...................................................................................... 4.14-1

4.14.2 Methodology ................................................................................................................. 4.14-3

4.14.3 Regulatory Setting .......................................................................................................... 4.14-4

4.14.4 Impacts and Mitigation Measures ................................................................................. 4.14-6

4.15 Public Services and Recreation ..................................................................................... 4.15-1

4.15.1 Existing Environmental Setting ...................................................................................... 4.15-1

4.15.2 Regulatory Setting ........................................................................................................ 4.15-10

4.15.3 Impacts and Mitigation Measures ............................................................................... 4.15-16

4.16 Transportation .............................................................................................................. 4.16-1

4.16.1 Existing Environmental Setting ...................................................................................... 4.16-1

4.16.2 Regulatory Setting .......................................................................................................... 4.16-6

4.16.3 Impacts and Mitigation Measures ............................................................................... 4.16-10

4.17 Utilities and Service Systems ........................................................................................ 4.17-1

4.17.1 Existing Environmental Setting ...................................................................................... 4.17-1

4.17.2 Regulatory Setting .......................................................................................................... 4.17-9

4.17.3 Impacts and Mitigation Measures ............................................................................... 4.17-12

4.18 Wildfire ......................................................................................................................... 4.18-1

4.18.1 Existing Environmental Setting ...................................................................................... 4.18-1

4.18.2 Regulatory Setting .......................................................................................................... 4.18-1

4.18.3 Impacts and Mitigation Measures ................................................................................. 4.18-3

5.0 CEQA-REQUIRED ASSESSMENT CONCLUSIONS .................................................. 5-1

5.1 Growth Inducement .......................................................................................................... 5-1

5.1.1 Elimination of Obstacles to Population Growth .................................................................... 5-2

5.1.2 Promotion of Economic Growth ............................................................................................ 5-3

5.2 Significant Irreversible Changes ........................................................................................ 5-3

5.3 Significant Unavoidable Impacts ....................................................................................... 5-4

6.0 ALTERNATIVES TO THE PROPOSED PROJECT ...................................................... 6-1

6.1 Introduction ....................................................................................................................... 6-1

6.2 Selection of Alternatives ................................................................................................... 6-2

6.2.1 Alternatives Considered but Rejected ................................................................................... 6-2

6.3 Proposed Project ............................................................................................................... 6-3

6.3.1 Project Characteristics ........................................................................................................... 6-3

6.3.2 Project Objectives .................................................................................................................. 6-3

6.3.3 Significant Unavoidable Impacts of the Proposed Project ..................................................... 6-4

6.4 Alternative 1: No Project Alternative ................................................................................ 6-4

6.4.1 Description ............................................................................................................................ 6-4

6.4.2 Environmental Analysis ......................................................................................................... 6-4

6.4.3 Overview of Potential Impact/Comparison to Proposed Project .......................................... 6-5

6.4.4 Project Objectives .................................................................................................................. 6-5

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6.5 Alternative 2: All Applicable Fee Alternative ..................................................................... 6-5

6.5.1 Description ............................................................................................................................ 6-5

6.5.2 Environmental Analysis ......................................................................................................... 6-6

6.5.3 Overview of Potential Impact/Comparison to Proposed Project .......................................... 6-6

6.5.4 Project Objectives .................................................................................................................. 6-6

6.6 Environmentally Superior Alternative ............................................................................... 6-6

7.0 REPORT PREPARATION ..................................................................................... 7-1

7.1 Report Preparers ............................................................................................................... 7-1

7.1.1 City of Fresno ......................................................................................................................... 7-1

7.1.2 LSA Associates, Inc. ................................................................................................................ 7-1

7.2 References ......................................................................................................................... 7-1

APPENDICES:

A: NOTICE OF PREPARATION
B: PUBLIC SCOPING COMMENTS
C: VMT REDUCING PROJECTS
D: NATIVE AMERICAN CONSULTATION

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FIGURES AND TABLES

FIGURES
Figure 3-1: VMT Reduction Program Fee Projects ............................................................................... 3-6 Figure 4.3-1: California Population, Gross State Product (GSP), Diesel Cancer Risk, and Diesel Vehicle Miles Traveled (VMT) Regulatory Context............................................... 4.3-13

TABLES
Table 1.A: Executive Summary Matrix ................................................................................................. 1-6 Table 3.A: Potential VMT-Reducing Improvements ............................................................................. 3-4 Table 4.2-1: Existing Farmland Acreages Within the Planning Area ................................................. 4.2-3 Table 4.2-2: Existing Farmland under Williamson Act Contracts Within the Planning Area ............ 4.2-4 Table 4.3.A: Sources and Health Effects of Air Pollutants ................................................................. 4.3-2 Table 4.3.B: Federal and State Ambient Air Quality Standards ........................................................ 4.3-6 Table 4.3.C: San Joaquin Valley Air Basin Air Quality Attainment Status ........................................ 4.3-10 Table 4.3.D: Ambient Air Quality in the Project Vicinity ................................................................. 4.3-11 Table 4.3.E: Screening Levels for Potential Odor Sources .............................................................. 4.3-20 Table 4.3.F: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year) ..... 4.3-28 Table 4.4.A: Special-Status Plant Species Recorded in the Project Vicinity ...................................... 4.4-6 Table 4.4.B: Special-Status Wildlife Species within the Project Vicinity ........................................... 4.4-7 Table 4.8.A: Global Warming Potential of Greenhouse Gases ......................................................... 4.8-2 Table 4.8.B: Senate Bill 375 Regional Greenhouse Gas Emissions Reduction Targets ...................... 4.8-9 Table 4.9.A: Facilities Listed on the US EPA CERCLIS Database ......................................................... 4.9-3 Table 4.9.B: Facilities Listed on the DTSC EnviroStor Database ........................................................ 4.9-4 Table 4.9.C: Waste Management Units ............................................................................................ 4.9-5 Table 4.9.D: Facilities Listed on the Water Board List of “Active” CDO and CAOs ............................ 4.9-5 Table 4.11.A: General Plan Consistency Analysis ............................................................................ 4.11-3 Table 4.11.B: Fresno COG 2022 RTP Consistency Analysis ........................................................... 4.11-12 Table 4.13.A: Definitions of Acoustical Terms................................................................................. 4.13-3 Table 4.13.B: Typical A-Weighted Sound Levels ............................................................................. 4.13-4 Table 4.13.C: Human Response to Different Levels of Ground-Borne Noise and Vibration ........... 4.13-5 Table 4.13.D: Measured Existing Noise Levels from Approved General Plan ................................. 4.13-7 Table 4.13.E: Summary of USEPA Noise Levels ............................................................................... 4.13-9 Table 4.13.F: Summary of Human Effects in Areas Exposed to 55 dBA CNEL ................................. 4.13-9 Table 4.13.G: Interpretation of Vibration Criteria for Detailed Analysis ....................................... 4.13-10 Table 4.13.H: Construction Vibration Damage Criteria ................................................................ 4.13-10 Table 4.13.I: Transportation (Non-Aircraft) Noise Sources ........................................................... 4.13-13 Table 4.13.J: Stationary Noise Sources ......................................................................................... 4.13-13 Table 4.13.K : Ambient Noise Standards in Decibels .................................................................... 4.13-14 Table 4.14.A: Population Estimate for City of Fresno Planning Area .............................................. 4.14-2 Table 4.14.B: Employees per Occupied Housing Unit in Fresno County ........................................ 4.14-2 Table 4.14.C: Number of Jobs per Housing Unit in Fresno County ................................................. 4.14-3

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Table 4.15.A: Existing City of Fresno Fire Stations .......................................................................... 4.15-3 Table 4.15.B: Planning Area Planned Open Space .......................................................................... 4.15-7 Table 4.15.C: Libraries in the Planning Area ................................................................................... 4.15-8 Table 4.15.D: Hospitals in the City of Fresno Planning Area ........................................................... 4.15-9 Table 4.15.E: Fire Facilities Fee Program ...................................................................................... 4.15-11 Table 4.15.F: Police Facilities Fee Program ................................................................................... 4.15-12 Table 4.15.G: Park Facilities Fee Program ..................................................................................... 4.15-15 Table 6-1: Comparison of the Environmental Impacts of the Proposed Project and the Project Alternatives ................................................................................................................................ 6-7

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1.0 EXECUTIVE SUMMARY

1.1 PURPOSE
This Draft Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental impacts resulting from implementation of the Fresno Vehicle Miles Travelled (VMT) Reduction Program (herein referred to as the proposed project) for the City of Fresno. This Draft EIR has been prepared in conformance with CEQA (California Public Resources Code, Section 21000, et seq.); the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000, et seq.); and procedures for implementing CEQA as adopted by the City of Fresno.

A program EIR is an EIR that may be prepared on a series of actions that can be characterized as one large project and are related either (1) geographically; (2) as logical parts in the chain of contemplated actions; (3) in connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of continuing a program; or (4) as individual actions carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects that can be mitigated in similar ways. Later activities in the program must be examined in light of the program EIR to determine whether an additional environmental document must be prepared. The purpose of this Draft EIR is to inform public agency decision‐makers, representatives of affected and responsible agencies, the public, and other interested parties of the potential environmental effects that may result from implementation of the proposed project.

1.2 PROJECT SUMMARY
The following provides a summary of the project location, project description, project objectives, potential significant and unavoidable impacts that could result from the proposed project, and a list of the agencies responsible for implementation of the approved VMT Reduction Program and approvals required for subsequent projects.

1.2.1 Project Location
The City of Fresno is located in Fresno County in the central portion of the San Joaquin Valley and covers an area of approximately 113 square miles. The City is located approximately 200 miles north of Los Angeles, and approximately 170 miles south of Sacramento. To the north of Fresno is Madera County, to the northeast and adjacent to Fresno, is the City of Clovis. Unincorporated land is located to the east, south, and west of Fresno. State Route (SR) 99 runs north‐south through the City and provides primary connectivity between Fresno and other regions of California. SR‐41 runs north‐ south through the center of the City and connects Fresno to Yosemite National Park. SR‐168 links the Downtown area to the adjacent City of Clovis. SR‐180 runs east‐west, providing access to outlying rural communities.

1.2.2 Project Description
The proposed project aims to establish a VMT Reduction Program with the intent of reducing citywide VMT by establishing mitigation for future development projects in Fresno. The VMT Reduction Program includes two major components that can be applied, individually or in

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combination, to new development with VMT impacts: an Urban Design Calculator (UDC), which estimates potential VMT reductions for development projects through incorporation of various design elements; and a mitigation fee (supported by a nexus study) and mitigation bank, which would be used to fund VMT‐reducing projects throughout Fresno.

The VMT Reduction Program would identify relevant transportation demand management (TDM) strategies and VMT‐reducing projects within Fresno to be funded by mitigation fees from developments that trigger potentially significant VMT impacts under CEQA. Potential VMT‐reducing measures may include active transportation improvements, multi‐modal transportation programs, and improved street connectivity, including bicycle, pedestrian and transit facilities. The program intends to streamline the Senate Bill 743 compliance process for development projects while funding future VMT improvement projects.

1.2.3 Project Objectives
CEQA Guidelines Section 15124(b) states that an EIR project description must include “[a] statement of objectives sought by the proposed project. The statement of objectives should include the underlying purpose of the project.” The proposed project objectives are outlined below. • Streamline the SB 743 compliance process for development projects by providing feasible mitigation options to reduce potentially significant VMT impacts. • Identify funding for future TDM strategies and VMT‐reducing projects within Fresno to help reduce Citywide total VMT.
• Contribute towards making Fresno a pedestrian‐, bicycle‐, and transit‐oriented community with active, healthy, and livable spaces.

1.2.4 Significant Unavoidable Adverse Impacts
The proposed project would result in the following significant unavoidable impacts:
• Transportation – vehicle miles traveled

1.2.5 Lead Agency, Responsible and Trustee Agencies
The project applicant and lead agency for the proposed project is the City of Fresno. The City is the public agency that has the principal responsibility for certifying the EIR, approving or carrying out the project, or disapproving the project. Although the City is the CEQA Lead Agency for the project, other agencies also have discretionary authority related to components of the project and approvals or serve as a responsible and/or trustee agency in connection to the project. The following lists these agencies.
• California Department of Transportation (Caltrans)
• Federal Aviation Administration
• Fresno County Airport Land Use Commission
• California Department of Fish and Wildlife (CDFW)
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• San Joaquin Valley Air Pollution Control District (SJVAPCD) • Pacific Gas and Electric Company (PG&E)/California Public Utilities Commission, approvals for power line relocations or undergrounding

1.3 SUMMARY OF PROJECT ALTERNATIVES
Below is a summary of the alternatives that were considered and evaluated in Chapter 6.0, Alternatives to the Proposed Project.

1.3.1 No Project Alternative
Under the No Project Alternative, the proposed VMT Reduction Program would not be adopted.

VMT‐reducing transportation improvements currently identified in existing City planning documents as planned but unfunded would continue to be unfunded under this alternative. The identified improvements would not be funded and implemented, and the City would be required to separately identify funding from another source. Additionally, given that the proposed VMT Reduction Program would not be adopted, a mitigation mechanism would not be established to assist future development with reducing potentially significant VMT impacts under CEQA. Similar to existing conditions, future developments that trigger significant VMT impacts under CEQA would be required to prepare Environmental Impact Reports and adopt statements of overriding consideration pursuant to CEQA Guidelines Section 15093.

1.3.2 All Applicable Fee Alternative
All Applicable Fee Alternative would require all future development in Fresno to pay into the proposed VMT Reduction Program. Unlike the proposed project, this alternative would require development projects to pay into the proposed VMT Reduction Program even if the development projects are located in low VMT areas, or areas that would not result in VMT impacts. As a result, this alternative would require all future development projects that generate VMT responsible for addressing Citywide VMT. This alternative would increase funds collected for VMT‐reducing projects and would allow for implementation of more VMT‐reducing projects and TDM measures than the proposed project.

1.4 AREAS OF CONTROVERSY
Pursuant to CEQA Guidelines Section 15123(b), a summary section includes a discussion of areas of controversy known to the lead agency, including issues raised by agencies and the public. The following are the known areas of controversy.
• Air Quality – increases in air emissions and increases in concentrations of toxic air contaminants in Fresno
• Biological Resources – impacts to plant and animal species and habitats • Greenhouse Gases – increases in greenhouse gas emissions

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1.5 PUBLIC REVIEW OF THE DRAFT EIR
Upon completion of this Draft EIR, the City of Fresno prepared and ﬁled a Notice of Completion (NOC) with the California Oﬃce of Planning and Research/State Clearinghouse to begin the public review period (Public Resources Code, Section 21161) on July 2, 2025. Concurrent with the NOC, the City of Fresno distributed a Notice of Availability (NOA) in accordance with Section 15087 of the CEQA Guidelines. The NOA was mailed to the organizations and individuals who previously requested such a notice to comply with Public Resources Code Section 21092(b)(3). This Draft EIR was distributed to the Governor's Oﬃce of Land Use and Climate Innovation/State Clearinghouse in accordance with Section 15206 of the CEQA Guidelines. This Draft EIR was also published in the Fresno Bee newspaper to comply with Section 15087(a) of the State CEQA Guidelines and was distributed to aﬀected agencies, surrounding cities and municipalities, and all interested parties.

During the public review period, this Draft EIR, including the appendices, is available for review at the following locations:

City of Fresno
Planning and Development Department
2600 Fresno Street, Third Floor
Fresno, CA 93721
Monday through Friday: 9:00 a.m. to 4:00 p.m.

Saturday and Sunday: Closed

Fresno County Public Library, Central Branch
2420 Mariposa Street
Fresno, CA 93721
Monday through Thursday: 9:00 a.m. to 6:00 p.m.

Friday and Saturday: 9:00 a.m. to 5:00 p.m.

Sunday: 12:00 p.m. to 5:00 p.m.

In addition, the Draft EIR, including the appendices, is available at the following City of Fresno website:
www.fresno.gov/vmt
Agencies, organizations, individuals, and all other interested parties not previously contacted, or who did not respond to the NOP/IS or attended the scoping meeting, currently have the opportunity to comment on this Draft EIR during the 45-day public review period beginning on July 2, 2025 and ending on August 15, 2025. Written comments on this Draft EIR should be addressed to:

City of Fresno
Planning and Development Department
2600 Fresno Street, Room 3065
Fresno, CA 93721
Attention: Sophia Pagoulatos, Planning Manager
Telephone: (559) 621-8062 Fax: (559) 621-2489
Email: [email protected]
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Upon completion of the public review period, written responses to all substantive environmental issues raised will be prepared and made available for review at least 10 days prior to the public hearing on the project before the City of Fresno City Council, at which the certification of the Final Program EIR will be considered. Comments received and the responses to comments will be included as part of the record for consideration by decision‐makers for the project.

1.6 EXECUTIVE SUMMARY MATRIX
Table 1.A below summarizes the impacts, mitigation measures, and resulting level of significance after mitigation for the relevant environmental issue areas evaluated for the proposed VMT Reduction Program. Table 1.A is intended to provide an overview; narrative discussions for the issue areas are included in the corresponding sections of this Draft EIR. Table 1.A is included in the Draft EIR pursuant to CEQA Guidelines Section 15123(b)(1).

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation

4.1: AESTHETICS
AES-1: The proposed project would not have a
substantial adverse effect on a scenic vista.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AES-2: The proposed project would not substantially
damage scenic resources, including, but not limited
to, trees, rock outcroppings, and historic buildings
within a state scenic highway.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AES-3: The proposed project would not 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), and due to the location of
the project in an urbanized area, the project would
not conflict with applicable zoning and other
regulations governing scenic quality.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AES-4: The proposed project would not create a new
source of substantial light or glare which would
adversely affect day or nighttime views in the area.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AES-5: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would not contribute to a significant cumulative
impact with respect to aesthetics.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.2: AGRICULTURE AND FORESTRY
AG-1: The proposed project would not 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AG-2: The proposed project would not conflict with
existing zoning for agricultural use, or a Williamson
Act contract.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AG-3: The proposed project would not conflict with
existing zoning for, or cause rezoning of, forest land
(as defined in Public Resources Code section
Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact. 1-7

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g)).

AG-4: The proposed project would not result in the
loss of forest land or conversion of forest land to
non‐forest use.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AG-5: The proposed project would not involve other
changes in the existing environment which, due to
their location or nature, could result in conversion of Important Farmland, to non‐agricultural use.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AG-6: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would not result in significant cumulative impacts
with respect to agricultural resources.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.3: AIR QUALITY
AQ-1: The proposed project would not conflict with
or obstruct implementation of the applicable air
quality plan.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AQ-2: The project would not result in a cumulatively
considerable net increase of any criteria pollutant for which the project is nonattainment under an
applicable federal or state ambient air quality
standard.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AQ-3: The project would not expose sensitive
receptors to substantial pollutant concentrations.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AQ-4: The project would not result in other
emissions (such as those leading to odors) adversely
affecting a substantial number of people.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

AQ-5: The proposed project, in combination with
other projects, would not contribute to a significant
cumulative impact related to air quality.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.4: BIOLOGICAL RESOURCES
BIO-1: The proposed project could have a substantial
adverse effect, either directly or through habitat
Potentially significant impact. Mitigation Measure BIO-1: Transportation improvements funded by the proposed Vehicle Miles
Less Than Significant Impact
with Mitigation Incorporated.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
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 U.S.

Fish and Wildlife Service.

Traveled Reduction Program subject to California
Environmental Quality Act (CEQA) review, and with
the potential to reduce or eliminate habitat for native plant and wildlife species or sensitive habitats, shall provide a Biological Resources Assessment prepared
by a qualified biologist for review and approval by
the City of Fresno. The assessment shall include
biological field survey(s) of the project site to
characterize the extent and quality of habitat that
would be impacted by development. Surveys shall be
conducted by qualified biologists and/or botanists in
accordance with California Department of Fish and
Wildlife and/or United States Fish and Wildlife
Services survey protocols for target species. If no
special status/sensitive species, sensitive
habitats/natural communities, or federally protected
wetlands are observed during the field survey, then
no further mitigation will be required. If biological
resources are documented on the project site, the
project proponent shall comply with the applicable
requirements of the regulatory agencies and shall
apply mitigation determined through the agency
permitting process.

BIO-2: The proposed project could 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 Wildlife or US Fish
and Wildlife Service.

Potentially Significant Impact. Refer to Mitigation Measure BIO-1. Less Than Significant Impact with Mitigation Incorporated.

BIO-3: The project would 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.

Potentially Significant Impact. Refer to Mitigation Measure BIO-1. Less Than Significant Impact with Mitigation Incorporated.
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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
BIO-4: The project could 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.

Potentially Significant Impact.

Mitigation Measure BIO-4: A pre‐construction
nesting bird clearance survey shall be conducted by a
qualified biologist no more than fourteen (14) days
prior to the start of any vegetation removal or
ground disturbing activities associated with a
transportation improvement project. The survey shall
be conducted by a qualified biologist and cover all
suitable nesting habitat within the project impact
area, and areas within a biologically defensible buffer zone surrounding the project impact area. Further, if
an active bird nest is found, the qualified biologist
should identify the specific bird species and establish a “no‐disturbance” buffer around the active nest to
avoid potential direct and indirect impacts. It is
further recommended that the qualified biologist
periodically monitor any active bird nests to
determine if project‐related activities disturb the
birds and if the “no disturbance” buffer should be
increased. Once the young have fledged and left the
nest, or the nest otherwise becomes inactive under
natural conditions, project activities within the “no‐
disturbance” buffer may occur following an
additional survey by the qualified biologist to search
for any new nests in the restricted area.

Less Than Significant Impact
with Mitigation Incorporated.

BIO-5: The project would not conflict with any local
policies or ordinances protecting biological
resources, such as a tree preservation policy or
ordinance.

Less Than Significant Impact.

No mitigation measures are required. Less Than Significant Impact.

BIO-6: The project would not conflict with the
provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan.

Less Than Significant Impact.

No mitigation measures are required. Less Than Significant Impact.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
BIO-7: The project, in combination with other
projects, could contribute to a significant cumulative
impact related to biological resources.

Potentially Significant Impact. Refer to Mitigation Measures Bio-1 and Bio-4. Less Than Significant Impact with Mitigation Incorporated.

4.5: CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES
CUL-1: The project could cause a substantial adverse
change in the significance of a historical resource as
defined in Section 15064.5.

Potentially Significant Impact. Mitigation Measure CUL-1: To ensure identification and preservation of potentially historic resources (as
defined by CEQA Guidelines Section 15064.5 as a
resource listed in, eligible for listing in, or listing in the National Register of Historic Places (NRHP),
California Register of Historical Resources (CRHR), or
local register), each transportation improvement
funded by the proposed Vehicle Miles Traveled
Reduction Program subject to California
Environmental Quality Act (CEQA) review (meaning,
subject to discretionary action and non‐exempt from
CEQA) shall be conditioned as follows: prior to any
construction activities that could impact potential or
previously identified historical resources, the project proponent shall provide a historical resources
assessment performed by an architectural historian
or historian who meets the Secretary of the Interior’s
Professional Qualification Standards for architectural
history or history (as defined in 48 Code of Federal
Regulations 44716) to the City of Fresno Planning
and Development Department for review and
approval. The historical resources assessment shall
include a records search at the Southern San Joaquin
Valley Information Center (SSJVIC) and a survey in
accordance with the California Office of Historic
Preservation (OHP) guidelines to identify any
previously unrecorded potential historical resources
that may be potentially affected by the proposed
project. If a historical resource is identified on‐site, the resource shall be avoided to the extent feasible.

Less Than Significant Impact
with Mitigation Incorporated..
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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
If relocation, rehabilitation, or alteration of a
historical resource is required, the project proponent
shall utilize the Secretary of the Interior’s Standards for the Treatment of Historic Properties to the
maximum extent feasible to ensure the historical
significance of the resource is not impaired. If
demolition or significant alteration of a historical
resource is required, the resource shall be evaluated,
and/or designated in the NRHP , CRHR, or local
register, and recordation shall take the form of
Historic American Buildings Survey (HABS), Historic
American Engineering Record (HAER), or Historic
American Landscape Survey (HALS) documentation,
and shall be performed by an architectural historian
or historian who meets the Secretary of the Interior’s
Professional Qualification Standards. Recordation
shall meet the Secretary of the Interior’s Standards
and Guidelines for Architectural and Engineering,
which defines the products acceptable for inclusion
in the HABS/HAER/HALS collection at the Library of
Congress. The specific scope and details of
documentation shall be developed at the project
level in coordination with the City of Fresno Planning
and Development Department and performed prior
to the first issuance of any demolition, building, or
grading permits.

CUL-2: The project could cause a substantial adverse
change in the significance of an archaeological
resource as defined in Section 15064.5 of the CEQA
Guidelines.

Potentially Significant Impact. Mitigation Measure CUL-2.1: To ensure identification and preservation of archaeological resources within
the City of Fresno, each transportation improvement
funded by the proposed Vehicle Miles Traveled
Reduction Program subject to California Environmental
Quality Act (CEQA) review (meaning, subject to
discretionary action and non‐exempt from CEQA) shall
be screened by the City of Fresno Planning and
Development Department to determine whether a
Less Than Significant Impact
with Mitigation Incorporated..

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
Cultural Resources Assessment is required. Screening
shall consider the type of project and whether ground
disturbances will occur. Ground disturbances include
activities such as grading, excavation, trenching,
boring, or demolition that extend below the current
grade. If there will be no ground disturbance, then a
Cultural Resources Assessment shall not be required. If there will be ground disturbances, prior to issuance of any permits required to conduct ground disturbing
activities, the City may require a Cultural Resources
Assessment be conducted under the supervision of an
archaeologist that meets the Secretary of the Interior’s Professionally Qualified Standards in either prehistoric or historic archaeology. The Cultural Resources
Assessment shall include a California Historical
Resources Information System (CHRIS) records search
conducted through the Southern San Joaquin Valley
Information Center (SSJVIC) and Sacred Land Files (SLF) search through the Native American Heritage
Commission (NAHC), review of historical maps, and a
Phase I (intensive) pedestrian survey to assess the
likelihood for buried archaeological resources to occur.

The Cultural Resources Assessment shall meet or
exceed standards in the Office of Historic
Preservation’s Archaeological Resource Management
Reports (ARMR): Recommended Contents and Format
(1990) and Guidelines for Archaeological Research
Designs (1991).

Mitigation Measure CUL-2.2: In the event that cultural
resources are unearthed during excavation and
grading activities of any future transportation
improvement project funded by the proposed
program, the construction contractor shall cease all
earth‐disturbing activities within a 100‐meter radius of 1-13

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
the find and the project proponent shall retain a
qualified archaeologist that meets the Secretary of the Interior’s Professionally Qualified Standards in either prehistoric or historic archaeology to evaluate the
significance of the finding and appropriate course of
action. Salvage operation requirements pursuant to
Section 15064.5 of the CEQA Guidelines shall be
followed. After the find has been appropriately
mitigated, work in the area may resume.

CUL-3: The project would not disturb any human
remains, including those interred outside of
dedicated cemeteries.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

CUL-4: The project would not result in a substantial
adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a
site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope
of the landscape, sacred place, or object with
cultural value to a California Native American tribe,
and that is:
• 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
• A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of PRC Section 5024.1. In applying
the criteria set forth in subdivision (c) of PRC
Section 5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.

Potentially Significant Impact. Refer to Mitigation Measures CUL-1 and CUL-2. Less Than Significant Impact with Mitigation Incorporated.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
CUL-5: The project, in combination with other
projects, could contribute to a significant cumulative
impact related to cultural resources and tribal
cultural resources.

Potentially Significant Impact. Refer to Mitigation Measures CUL-1, CUL-2.1, and CUL-2.2.

Less Than Significant Impact
with Mitigation Incorporated.

4.6: ENERGY
ENG-1: The proposed project would not 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. No mitigation measures are required. Less Than Significant Impact.

ENG-2: The proposed project would not conflict with
or obstruct a state or local plan for renewable energy
or energy efficiency.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

ENG-3: The project, in combination with other
projects, would not contribute to a significant
cumulative impact related to energy.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.7: GEOLOGY AND SOILS
GEO-1: The proposed project would not directly or
indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving
rupture of a known fault, strong seismic ground
shaking, seismic‐related ground failure, or landslides. 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;
iii. Seismic‐related ground failure, including
liquefaction; or
iv. iv. Landslides.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact. 1-15

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
GEO-2: The project would not result in substantial
soil erosion or the loss of topsoil.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

GEO-3: The project would not be located on a
geologic unit or soil that is unstable, or that would
become unstable as a result of the project, and
potentially result in on‐ or off‐site landslide, lateral spreading, subsidence, liquefaction, or collapse.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

GEO-4: The project would not 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. No mitigation measures are required. Less Than Significant Impact.

GEO-5: The project does not contain 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

GEO-6: The proposed project could directly or
indirectly destroy a unique paleontological resource
or site or unique geologic feature.

Potentially Significant Impact. Mitigation Measure GEO-6: Subsequent to a preliminary City review of the project grading plans, if there is evidence that a project will include
excavation or construction activities within previously undisturbed soils, a field survey and literature search for unique paleontological/geological resources shall
be conducted. The following procedures shall be
followed:
• If unique paleontological/geological resources are
not found during either the field survey or
literature search, excavation and/or construction
activities can commence. In the event that unique
paleontological/geological resources are
discovered during excavation and/or construction
activities, construction shall stop in the immediate
vicinity of the find and a qualified paleontologist
shall be consulted to determine whether the
resource requires further study. The qualified
paleontologist shall make recommendations to
Less Than Significant Impact
with Mitigation Incorporated.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
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. If the resources
are determined to be significant, mitigation
measures shall be identified by the monitor and
recommended to the Lead Agency. Appropriate
mitigation 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 resources. Any
paleontological/geological resources 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.
• If unique paleontological/geological resources are
found during the field survey or literature review,
the resources shall be inventoried and evaluated
for significance. If the resources are found to be
significant, mitigation measures shall be identified
by the qualified paleontologist. Similar to above,
appropriate mitigation 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. In addition, appropriate mitigation for
excavation and construction activities in the
vicinity of the resources found during the field
survey or literature review shall include a
paleontological monitor. The monitoring period
shall be determined by the qualified
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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
paleontologist. If additional
paleontological/geological resources are found
during excavation and/or construction activities,
the procedure identified above for the discovery
of unknown resources shall be followed.

GEO-7: The project, in combination with other
projects, could contribute to a significant cumulative
impact related to geology and soils.

Potentially Significant Impact. Refer to Mitigation Measures GEO-6. Less Than Significant Impact with Mitigation Incorporated.

4.8: GREENHOUSE GAS EMISSIONS
GHG-1: The project would not generate greenhouse
gas emissions, either directly or indirectly, that may
have a significant impact on the environment.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

GHG-2: The proposed project would conflict with an
applicable plan, policy or regulation adopted for the
purpose of reducing the emissions of greenhouse
gases.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

GHG-3: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would result in significant cumulative impacts with
respect to greenhouse gas emissions.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.9: HAZARDS AND HAZARDOUS MATERIALS
HAZ-1: The project would not create a significant
hazard to the public or the environment through the
routine transport, use, or disposal of hazardous
materials.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HAZ-2: The project would not create a significant
hazard to the public or the environment through
reasonably foreseeable upset and/or accident
conditions involving the release of hazardous
materials into the environment.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HAZ-3: The project would not 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. No mitigation measures are required. Less Than Significant Impact.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
HAZ-4: The project could 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 create a significant
hazard to the public or the environment.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HAZ-5: The proposed project would not result in a
safety hazard or excessive noise for people residing
or working in the project area.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HAZ-6: The proposed project would not impair
implementation of or physically interfere with an
adopted emergency response plan or emergency
evacuation plan.

Less Than Significant Impact No mitigation measures are required. Less Than Significant Impact.

HAZ-7: The proposed project would not expose
people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving
wildland fires.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HAZ-8: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would not result in significant cumulative impacts
related to hazards and hazardous materials.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.10: HYDROLOGY AND WATER QUALITY
HYD-1: The project would not violate any water
quality standards or waste discharge requirements or
otherwise substantially degrade surface or
groundwater quality.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HYD-2: The project would not 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. No mitigation measures are required. Less Than Significant Impact.

HYD-3: The project would not 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:

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact. 1-19

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
• Result in a substantial erosion or siltation on‐ or
off‐site;
• Substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on‐ or off‐site;
• 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;
nor
• Impede or redirect flood flows.

HYD-4: The project would not risk release of
pollutants due to project inundation in a flood
hazard, tsunami, or seiche zones.

Less Than Significant Impact.

No mitigation measures are required. Less Than Significant Impact.

HYD-5: The project would not conflict with or
obstruct implementation of a water quality control
plan or sustainable groundwater management plan.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

HYD-6: The project, in combination with other
projects, would not contribute to a significant
cumulative impact related to hydrology and water
quality.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.11: LAND USE AND PLANNING
LU-1: The proposed project would not physically
divide an established community.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

LU-2: The proposed project would not 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

LU-3: The project, in combination with other
projects, would not contribute to a significant
cumulative impact related to land use and planning.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation

4.12: MINERAL RESOURCES
MIN-1: The proposed project would not 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

MIN-2: The proposed project would not 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

MIN-3: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would result in less than significant cumulative
impacts with respect to mineral resources.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.13: NOISE
NOI-1: The project could generate 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.

Potentially Significant Impact. Mitigation Measure NOI-1: Each transportation improvement funded by the proposed program
subject to California Environmental Quality Act
(CEQA) review shall ensure through contract
specifications that construction best management
practices (BMPs) are implemented by construction
contractors to reduce construction noise levels.

Contract specifications shall be included in
construction documents, which shall be reviewed
and approved by the City of Fresno Planning and
Development Director prior to issuance of a grading
or building permit (whichever is issued first). BMPs to reduce construction noise levels may include, but are
not limited to, the following:
• Ensure that construction equipment is properly
muffled according to industry standards and is in
good working condition.
• Place noise‐generating construction equipment
and construction staging areas away from
sensitive uses.

Less Than Significant Impact
with Mitigation Incorporated.
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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
• Construction activities shall occur between the
hours of 7:00 a.m. and 10:00 p.m. Monday
through Saturday, pursuant to Section 10‐109 of
the City of Fresno Municipal Code.
• Implement noise attenuation measures, as
needed, which may include, but are not limited to,
temporary noise barriers or noise blankets around
stationary construction noise sources.
• Use electric air compressors and similar power
tools rather than diesel equipment, where
feasible.
• Construction‐related equipment, including heavy‐
duty equipment, motor vehicles, and portable
equipment, shall be turned off when not in use for
more than five minutes.
• The construction contractor shall limit haul truck
deliveries to the same hours specified for
construction equipment (between the hours of
7:00 a.m. and 10:00 p.m. Monday through
Saturday). The haul route exhibit shall design
delivery routes to minimize the exposure of
sensitive land uses or residential dwellings to
delivery truck‐related noise.
• Construction hours, allowable workdays, and the
phone number of the job superintendent shall be
clearly posted at all construction entrances to
allow surrounding owners and residents to
contact the job superintendent. If the City or the
job superintendent receives a complaint, the
superintendent shall investigate, take appropriate
corrective action, and report the action taken to
the reporting party and the Director of
Development.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
NOI-2: The project could generate excessive
groundborne vibration or groundborne noise levels.

Potentially Significant Impact. Mitigation Measure NOI-2: Prior to issuance of a grading permit, each transportation improvement
funded by the proposed program subject to
California Environmental Quality Act (CEQA) review
with construction activities requiring operation of
groundborne vibration generating equipment (i.e.,
vibratory compactor/roller, large bulldozer, caisson
drilling, loaded trucks, and jackhammer) within 25
feet of an existing structure shall be required to
prepare a project‐specific vibration impact analysis to evaluate potential construction vibration impacts
associated with the project, and to determine any
specific vibration control mechanisms that shall be
incorporated into the project’s construction bid
documents to reduce such impacts. Contract
specifications shall be included in construction
documents, which shall be reviewed and approved
by the City prior to issuance of a grading permit.

Less Than Significant Impact
with Mitigation Incorporated.

NOI-3: The proposed would not expose people
residing or working in the project area to excessive
noise levels.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

NOI-4: The project, in combination with other
projects, could contribute to a significant cumulative
impact related to noise.

Potentially Significant Impact. Refer to Mitigation Measures NOI-1 and NOI-2. Less Than Significant Impact with Mitigation Incorporated.

4.14: POPULATION AND HOUSING
POP-1: The proposed project would not 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. No mitigation measures are required. Less Than Significant Impact.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
POP-2: The proposed project would not displace
substantial numbers of existing people or housing,
necessitating the construction of replacement
housing elsewhere.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

POP-3: The proposed project would not contribute to
a significant cumulative impact related to population
and housing.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.15: PUBLIC SERVICES AND RECREATION
PSR-1: The proposed project would not 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.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

PSR-2: The proposed project would not 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 Impact. No mitigation measures are required. Less Than Significant Impact.

PSR-3: The proposed project would not 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 Impact. No mitigation measures are required Less Than Significant Impact.

PSR-4: The project, in combination with other
projects, would not contribute to significant
cumulative impacts related to public services and
recreation.

Less Than Significant Impact No mitigation measures are required. Less Than Significant Impact.

4.16: TRANSPORTATION
TRA-1: The project would not conflict with a
program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

TRA-2: The project would conflict or be inconsistent
with CEQA Guidelines section 15064.3, subdivision
(b).

Potentially Significant Impact. No feasible mitigation measures are available. Significant and Unavoidable Impact.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
TRA-3: The proposed project would not 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. No mitigation measures are required. Less Than Significant Impact.

TRA-4: The proposed project would not result in
inadequate emergency access.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

TRA-5: The project, in combination with other
projects, would contribute to a significant cumulative
impact related to transportation.

Potentially Significant Impact. No feasible mitigation measures are available. Significant and Unavoidable Impact.

4.18: UTILITIES
UTL-1: The project would not require nor 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. No mitigation measures are required. Less Than Significant Impact.

UTL-2: The project would 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. No mitigation measures are required. Less Than Significant Impact.

UTL-3: The project would not result in a
determination by the wastewater treatment provider,
which serves or may serve the project that it has
inadequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

UTL-4: The project would not 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. No mitigation measures are required. Less Than Significant Impact.

UTL-5: The project would comply with federal, state,
and local management and reduction statutes and
regulations related to solid waste.

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Table 1.A: Executive Summary Matrix
Potential Environmental Impact Level of Significance
Before Mitigation Mitigation Measures Level of Significance After Mitigation
UTL-6: The project, in combination with other
projects, would not contribute to a significant
cumulative impact related to utilities and service
systems.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

4.19: WILDFIRE
WF-1: The proposed project would not impair an
adopted emergency response plan or emergency
evacuation plan.

Less Than Significant Impact. No mitigation measures are required. Less Than Significant Impact.

WF-2: The proposed project would not, 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. No mitigation measures are required. Less Than Significant Impact.

WF-3: The proposed project would not 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.

Less Than Significant Impact.

No mitigation measures are required. Less Than Significant Impact.

WF-4: The proposed project would not 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.

No mitigation measures are required. Less Than Significant Impact.

WF-5: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
would result in less than significant cumulative
impacts with respect to wildfire.

Less Than Significant Impact.

No mitigation measures are required. Less Than Significant Impact.

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2.0 INTRODUCTION

2.1 PURPOSE OF THIS EIR
The California Environmental Quality Act (CEQA) requires that all State and local government agencies consider the environmental consequences of programs and projects over which they have discretionary authority before taking action on them. This Environmental Impact Report (EIR) has been prepared in accordance with CEQA to evaluate the potential environmental impacts associated with implementation of the Fresno Vehicle Miles Travelled (VMT) Reduction Program (herein referred to as the proposed project) for the City of Fresno. This EIR has been prepared in conformance with CEQA, California Public Resources Code Section 21000 et seq; the California State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq); and the rules, regulations, and procedures for implementing CEQA as adopted by the City of Fresno (herein referred to as the City).

This EIR is intended to serve as an informational document for the public agency decision‐makers and the public regarding the potential environmental impacts associated with the construction and long-term buildout of the proposed project. In addition to identifying potential environmental impacts, this EIR also identifies potential mitigation measures and alternatives to reduce potential environmental impacts.

Environmental impacts cannot always be mitigated to a level that is considered less than significant.

In accordance with Section 15093(b) of the State CEQA Guidelines, if a lead agency, such as the City of Fresno, approves a project that has significant impacts that are not substantially mitigated (i.e., significant unavoidable impacts), the lead agency shall state in writing the specific reasons for approving the project, based on the final CEQA documents and any other information in the public record for the project. This is identified in Section 15093 of the State CEQA Guidelines, “a statement of overriding considerations.” These potential impacts are discussed in more detail throughout Chapter 4.0 of this EIR.

2.2 ENVIRONMENTAL REVIEW PROCESS
The City of Fresno, serving as Lead Agency responsible for administering the environmental review for the proposed project, determined that preparation of an EIR was required for the Fresno VMT Reduction Program.

CEQA requires that, before a decision can be made to approve a project that could result in adverse physical effects, an EIR must be prepared that fully describes the environmental effects of the project. The EIR is a public information document for use by governmental agencies and the public to identify and evaluate potential environmental impacts of a project, to recommend mitigation measures to lessen or eliminate significant adverse impacts, and to examine feasible alternatives to the project. The information contained in the EIR must be reviewed and considered by the City of Fresno Planning Commission, City Council, and other approving bodies prior to a decision to approve, disapprove, or modify the project.

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As part of the consideration of the proposed project, an agency must prepare findings that identifies that all environmental effects of the project are supported by substantial evidence in the record.

CEQA requires that agencies shall neither approve nor implement a project unless the project’s significant environmental effects have been reduced to a less-than-significant level, essentially “eliminating, avoiding, or substantially lessening” the potentially significant impacts, except when certain findings are made. If an agency approves a project that will result in the occurrence of significant adverse impacts that cannot be mitigated to less-than-significant levels, the agency must state the reasons for its action in writing, demonstrate that its action is based on the EIR or other information in the record, and adopt a Statement of Overriding Considerations.

2.3 INTENDED USES OF THIS EIR
As noted above and described in the State CEQA Guidelines, public agencies are charged with the duty to avoid or substantially lessen significant environmental effects, where feasible. In undertaking this duty, a public agency has an obligation to balance a project’s significant effects on the environment with its benefits, including economic, social, technological, legal, and other non- environmental characteristics.

This EIR is intended as an informational document to: evaluate the proposed project and the potential for significant impacts on the environment; examine methods of reducing adverse environmental impacts; identify any significant and unavoidable adverse impacts that cannot be mitigated; and identify reasonable and feasible alternatives to the proposed project that would eliminate any significant adverse environmental effects or reduce the impacts to a less-than- significant level. The Lead Agency is required to consider the information in the EIR, along with any other relevant information, in making its decisions on the proposed project. This analysis, in and of itself, does not determine whether a project will be approved, but aids the planning and decision- making process by disclosing the potential for significant and adverse impacts.

In conformance with CEQA and the State CEQA Guidelines, this EIR provides objective information addressing the environmental consequences of the project and identifies possible means of reducing or avoiding significant impacts, either through mitigation measures or feasible project alternatives. The City must certify the Final EIR prior to project approval and implementation. Under State CEQA Guidelines Section 15168, this is a program-level EIR. This type of EIR examines implementation of a plan over an extended period of time but considers potential construction and operational impacts of implementing the plan. This type of EIR would also allow for later activities that would occur under the proposed Integrated Master Plan to be evaluated to the extent feasible based on the level of detail provided at the time the program EIR is prepared. Later activities and discretionary actions occurring under the proposed Integrated Master Plan would be subject to additional environmental review and documentation.

The State CEQA Guidelines help define the role and standards of this EIR, as follows:
• Information Document. An EIR is an informational document which will inform public agency decision-makers and the public generally of the significant environmental effect(s) of a project, identify possible ways to minimize significant effects, and describe reasonable alternatives to 2-3

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the project. The public agency shall consider the information in the EIR along with other information which may be presented to the agency (State CEQA Guidelines Section 15121(a)). • Degree of Specificity. The degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying activity which is described in the EIR. An EIR on a development project will necessarily be more detailed in its discussion of specific effects of the project than will be an EIR on the adoption of a local general plan or comprehensive zoning ordinance because the effects of the construction can be predicted with greater accuracy (State CEQA Guidelines Section 15146(a)).
• Standards for Adequacy of an EIR. An EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information, which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure (State CEQA Guidelines Section 15151).

Section 15382 of the State CEQA Guidelines defines a significant effect on the environment as “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project…” Therefore, in identifying the significant impacts of the project, this EIR focuses on the substantial physical effects and mitigation measures to avoid, reduce, or otherwise alleviate those effects.

2.4 PROPOSED PROJECT
The proposed project, called the VMT Reduction Program, aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank and an Urban Design Calculator (UDC) which could be applied individually or in combination. The mitigation bank would be used to fund VMT-reducing projects throughout Fresno and an UDC would recommend potential VMT reductions for development projects through incorporation of various design elements.

The fee program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank. These projects, which may include active transportation improvements, multi-modal transportation programs, and improved street connectivity, including bicycle, pedestrian and transit facilities, would be subject to future CEQA analysis on a project‐by‐project basis as they are proposed and as the extent of impacts become known through the design process.

The proposed mitigation fee would be determined through the development of a Nexus Study, which would include technical details on the estimation of various cost components for the proposed mitigation measures for the project and their efficacy on VMT reductions. The Nexus Study would provide justification and nexus between anticipated VMT growth and proposed mitigation measures, costs, and fees.

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Additionally, the proposed project would include updating the City’s existing UDC for use by individual projects. Projects that would have a significant VMT impact can reduce the project’s impact by applying VMT reducing project design features at the project site. The extent of VMT reduction could be calculated using the UDC as a first step of the VMT Reduction Program prior to participating in the VMT mitigation bank. After applying VMT reductions using UDC, the remaining excess VMT from the project would be used to calculate the project’s contribution into the mitigation bank.

2.5 EIR SCOPE
A Notice of Preparation (NOP) of the EIR was circulated for 30 days on September 27, 2024, to help identify the types of impacts that could result from implementation of the proposed project, as well as potential areas of controversy. The NOP was mailed to public agencies, organizations, and individuals likely to be interested in the project and its potential impacts. Additionally, a public scoping meeting to inform interested parties and the public about the proposed project was held on October 21, 2024. A total of five comment letters regarding the NOP were received within the review period. Copies of the NOP and the comment letters are included in Appendix B.

The following environmental topics are addressed in this EIR:
• Aesthetics
• Agriculture and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources and Tribal Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services and Recreation
• Transportation
• Utilities and Service Systems
• Wildfire

2.6 REPORT ORGANIZATION
This EIR is organized into the following chapters:
• Chapter 1.0 – Executive Summary: This chapter provides a summary of the impacts that would result from implementation of the proposed project, describes mitigation measures recommended to reduce or avoid significant impacts, and describes the alternatives to the proposed project.
• Chapter 2.0 - Introduction: This chapter discusses the overall EIR purpose, provides a summary of the proposed project, describes the EIR scope, and summarizes the organization of the EIR. • Chapter 3.0 - Project Description: This chapter provides a description of the project site, the project objectives, the proposed project, and intended uses of this EIR. 2-5

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• Chapter 4.0 – Evaluation of Environmental Impacts: This chapter describes the following for each environmental technical topic: existing conditions (setting), potential environmental impacts and their level of significance, and mitigation measures recommended to mitigate identified impacts. Potential adverse impacts are identified by levels of significance, as follows:
less-than-significant impact (LTS), significant impact (S), and significant and unavoidable impact (SU). The significance of each impact is categorized before and after implementation of any recommended mitigation measures(s). Cumulative impacts are also addressed. • Chapter 5.0 - Alternatives: This chapter provides an evaluation of the alternatives to the proposed project in addition to the CEQA-required No Project alternative. • Chapter 6.0 – CEQA-Required Assessment Conclusions: This chapter provides an analysis of effects found not to be significant, growth-inducing impacts, unavoidable significant environ- mental impacts, and significant irreversible changes.
• Chapter 7.0 - Report Preparation: This chapter identifies preparers of the EIR, references used, and the persons and organizations contacted.
• Appendices: The appendices contain the NOP and comment letters on the NOP (Appendix B), technical calculations, and other documentation prepared in conjunction with this EIR.

2.7 PUBLIC PARTICIPATION
The State CEQA Guidelines encourage public participation in the planning and environmental review processes. The City will provide opportunities for the public to present comments and concerns regarding the CEQA and planning processes. These opportunities will occur during the Draft EIR public review and comment period and public hearings before the City of Fresno Planning Commission and City Council.

This Draft EIR, in compliance with Section 15105 of the State CEQA Guidelines, has been distributed to responsible and trustee agencies, and other interested organizations, agencies and individuals for review and comment on the adequacy of the environmental analysis. The public review and comment period for the Draft EIR would be 45 days.

Written public comments may be submitted to the Planning and Development Department during the specified public review and comment period, and oral comments may be presented at the Draft EIR public hearing before the City of Fresno Planning Commission and City Council. Written comments should be delivered in person or by courier service, or be sent by mail or email to:

Sophia Pagoulatos
Planning Manager
City of Fresno – Planning and Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
(559) 621-8062
[email protected]

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3.0 PROJECT DESCRIPTION
This chapter describes the proposed Fresno Vehicle Miles Traveled (VMT) Reduction Program evaluated in this Draft Environmental Impact Report (EIR). This chapter includes a description of the project location and setting, background and history, a list of project objectives, a description of proposed project components, and a list of required approvals and entitlements. The City of Fresno (City) is the CEQA lead agency and has final authority to approve the proposed project. Information presented in this chapter was derived from the Fresno VMT Reduction Program and other information provided by City staff, and serves as the basis for the environmental analysis contained in this Draft EIR.

3.1 PROJECT LOCATION AND SETTING

3.1.1 Project Location
The City of Fresno is located in Fresno County in the central portion of the San Joaquin Valley and covers an area of approximately 113 square miles. The City is located approximately 200 miles north of Los Angeles, and approximately 170 miles south of Sacramento. To the north of Fresno is Madera County, to the northeast and adjacent to Fresno, is the City of Clovis. Unincorporated land is located to the east, south, and west of Fresno. State Route (SR) 99 runs north-south through the City and provides primary connectivity between Fresno and other regions of California. SR-41 runs north- south through the center of the City and connects Fresno to Yosemite National Park. SR-168 links the Downtown area to the adjacent City of Clovis. SR-180 runs east-west, providing access to outlying rural communities.

3.1.2 Project Setting
The City of Fresno’s General Plan was adopted in December 2014 and governs future development throughout Fresno. The General Plan contains policies, plans and programs that form a blueprint for the physical development of the City, prioritizing infill development, Downtown, and neighborhood revitalization; transit-oriented development along major streets; mixed-uses; and the building of Complete Neighborhoods. Policy direction for development according to the General Plan is further refined by community and specific plans that were called for in the General Plan, such as the Fulton Corridor Specific Plan, the Downtown Neighborhoods Community Plan, and the Southwest Fresno Specific Plan. These plans were adopted in order to address specific issues and to identify future investment needs. Central to these plans is the transformation of these areas into walkable complete neighborhoods and communities through well-designed infill development, in combination with a multi-modal transportation system.

As described in the Fresno General Plan and the Fresno Municipal Code (Municipal Code), a variety of land use designations and zoning districts encompass the City. Land use designations that make up the City include the following: Low Density Residential, Medium Low Density Residential, Medium Density Residential, Medium High Density Residential, Urban Neighborhood Residential, High Density Residential, Main Street Commercial, Community Commercial, Recreation Commercial, General Commercial, Highway and Auto Commercial, Regional Commercial, Employment - Office, Employment - Business Park, Employment - Regional Business Park, Employment - Light Industrial,

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Employment - Heavy Industrial, Neighborhood Mixed Use, Corridor/Center Mixed Use, Regional Mixed Use, Downtown Core, Downtown General, Downtown Neighborhood, Open Space, and Public Facilities.

Further, the following zoning districts encompass the City : Buffer (B), RE (Residential Estate), RS-1 (Residential Single-Family, Extremely Low Density) RS-2 (Residential Single-Family, Very Low Density), RS-3 (Residential Single-Family, Low Density), RS-4 (Residential Single-Family, Medium Low Density), RS-5 (Residential Single-Family, Medium Density), RM-MH (Mobile Home Park), RM-1 (Residential Multi-Family, Medium High Density), RM-2 (Residential Multi-Family, Urban Neighborhood), RM-3 (Residential Multi-Family, High Density), NMX (Neighborhood Mixed-Use), CMX ( Corridor/Center Mixed-Use), RMX (Regional Mixed-Use), CMS (Commercial - Main Street), CC (Commercial - Community), CR (Commercial - Regional), CG (Commercial - General), CH (Commercial - Highway and Auto), CRC (Commercial - Recreation), DTN (Downtown Neighborhood), DTG (Downtown General), DTC (Downtown Core), O (Office), BP (Business Park), RBP (Regional Business Park), IL (Light Industrial), IH (Heavy Industrial), OS (Open Space), PR (Parks and Recreation), and PI (Public and Institutional).

3.2 BACKGROUND AND HISTORY
In September 2013, the Governor’s Office of Planning and Research (OPR) signed Senate Bill (SB) 743 into law, starting a process that fundamentally changed the way transportation impact analysis is conducted under the California Environmental Quality Act (CEQA). SB 743 identifies vehicle miles traveled (VMT) as the most appropriate CEQA transportation metric and eliminates auto delay, or level of service (LOS), and similar measurements of vehicular roadway capacity and traffic congestion as the basis for determining significant impacts. In December 2018, the California Natural Resource Agency certified and adopted the CEQA statute (14 California Code of Regulations Section 15064.3). Per the CEQA statute, the VMT guidelines became effective on July 1, 2020.

In accordance with SB 743, the Fresno City Council adopted the City’s VMT Guidelines on June 25, 2020 to address the shift from delay‐based LOS CEQA traffic analyses to VMT CEQA traffic analyses.

The City’s VMT Guidelines include standardized project screening criteria for projects, recommendations for appropriate VMT significance thresholds for development projects, transportation projects, and plans, and feasible VMT mitigation strategies for projects.

The implementation of SB 743 and the City’s recently adopted VMT Guidelines have created challenges for development projects in Fresno. Specifically, development projects located in some parts of Fresno or requiring General Plan Amendment (GPA)/Zone Change (ZC) have been triggering potentially significant VMT impacts under CEQA with no established feasible mitigation to offset such impacts. Thus, the City is proposing to create a VMT Reduction Program to streamline the SB 743 compliance process for development within Fresno.

As part of this effort, the City retained LSA to prepare the proposed VMT Reduction Program. LSA conducted thorough research of local planning documents such as the City’s Active Transportation Plan and Fresno Area Express’ (FAX) short‐range transit plan and long-range transit plan, Fresno Council of Governments’ (Fresno COG’s) Regional Transportation Plan (RTP), consulted available literature providing VMT mitigation strategies, and reviewed the City’s VMT Guidelines to assess 3-3

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existing types of VMT mitigation that could serve as potential active transportation and transit‐ related infrastructure and capital improvement projects funded by the program. Planning-level cost estimates and Nexus calculations were prepared for the identified VMT-reducing projects to estimate the cost of identified improvements and the net VMT benefits.

As presented to City Council in June of 2020, the VMT Reduction Program includes an Urban Design Calculator (UDC) and a mitigation fee program. The UDC would help projects that have a significant VMT impact reduce the project’s VMT by implementing VMT-reducing project design features at the project site. The mitigation impact fee would allow new development to mitigate VMT impacts by making “fair share” payments into a mitigation bank to cover the cost of the identified VMT- reducing projects in the proposed VMT Reduction Program. The fee contribution would be calculated by analyzing the relationship between the excess VMT generated by the project compared to the City’s VMT threshold. The future project would then be required to pay the calculated fee based on the excess VMT generated by the future project. It is possible that by utilizing the UDC and implementing the design features and reducing the future project’s VMT, future projects may be able to reduce the assessed fee contribution. By virtue of collecting this fee as part of the mitigation bank, the City would be able to implement the proposed mitigation projects as identified in the mitigation bank. A nexus study, prepared as part of the VMT Reduction Program, was prepared to provide a framework for the City to confirm that the fees collected have a relationship to the VMT-reducing projects.

The fee collected as part of the mitigation bank would be applicable to new residential and non- residential developments in Fresno subject to VMT analysis under CEQA that would generate VMT over the significance thresholds established in the City’s VMT Guidelines. Therefore, if a project screens out of VMT analysis based on City’s VMT Guidelines, the impact fee would not be applicable.

The impact fee would only apply for projects that result in potentially significant VMT impacts under CEQA.

3.3 PROPOSED PROJECT
The proposed VMT Reduction Program (from herein referred to as the “program” or “project”) aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank. The program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank.

As described above under Section 3.2, Background and History, mitigation measures and VMT- reducing projects for the proposed VMT Reduction Program were determined through thorough research of local planning documents, consultation of available literature providing VMT mitigation strategies, and review of the City’s VMT Guidelines to assess existing types of VMT mitigation measures identified herein.

The following existing City planning documents were reviewed to identify unfunded, planned infrastructure improvement projects within Fresno that contribute towards reducing Citywide VMT and could be funded by the proposed program:

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• FAX Short Range Transit Plan
• FAX Long Range Transit Plan
• Fresno Council of Governments (COG) Regional Transportation Plan (RTP) • Fresno Safe Routes to School Action Plan
• Fresno Active Transportation Plan
• Fresno County Regional Trails Plan
• Southern Blackstone Avenue Smart Mobility Plan
• Highway 41+ North Corridor Complete Streets Plan
Table 3.A below provides a summary of VMT-reducing improvements that were identified for the proposed program. Refer to Appendix C, VMT-reducing projects, for additional detail related to these TDM strategies, VMT-reducing projects and associated VMT reduction scores. Additionally, Figure 3-1 illustrates the approximate locations of the identified VMT-reducing improvements within Fresno.

Table 3.A: Potential VMT-Reducing Improvements
Improvement Locations Improvement Descriptions
Transportation Demand Management Projects

1. Citywide Mobile Ticketing Trip Planning App

2. Citywide Marketing for Transit, Active Transportation, TDM, and Multi-Modal Travel

3. Citywide Transportation Demand Management Coordinator

4. Citywide Bike/Pedestrian Trip Trackers

5. Citywide Intermodal Signage to connect transit and
bicycle/pedestrian networks.

Transit Projects

6. Clinton Avenue Three new buses for 15-minute frequency on Route 39

7. Southern Industrial Area 52 new ADA compliant stops for Southern Industrial service expansion on Route 34

8. Bullard Avenue Four new buses and 72 new stops for Bullard Avenue Crosstown Route

9. Church Avenue Four new buses and 68 new stops for Church Avenue Crosstown Service

10. Willow Avenue Four new buses and 68 new stops for service on Willow Avenue from Shields and Clovis Community College

11. Ashlan Avenue Two new buses and 10 new stops to increase service on Route 45

12. Cedar Avenue Cedar Avenue Transit Signal Priority - Adaptive Signal Control on Cedar from Herndon to Jensen

13. Fresno Street/First Street Six new buses to increase service on Route 32 Bicycle/Pedestrian Projects

14. Along Herndon No 39 Canal (section on East Shields
Avenue) to Mill No 36 Canal (section along East McKinley Avenue) to North Clovis Avenue
Priority Bikeway Network/Pedestrian Network/Midtown
Trail

15. Southern Blackstone from SR 180 to Dakota Ave. Class IV Bikeway

16. First Street from Dakota Avenue to Ventura Avenue Pedestrian Safety Enhancement Corridor

17. Downtown Fresno - South of Divisadero Street and
Northeast of Highway 99, Northwest of Highway 41
Pedestrian Improvements in Pedestrian Activity Areas

18. North Avenue Neighborhood Pedestrian Improvements in Underserved Neighborhoods 3-5

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Table 3.A: Potential VMT-Reducing Improvements
Improvement Locations Improvement Descriptions

19. Kings Canyon Road/Cesar Chavez Blvd – Cedar Avenue
to Clovis Avenue
Pedestrian Improvements in Pedestrian Safety
Enhancement Corridor

20. Florence Avenue adjacent to Balderas Elementary
School
Pedestrian Improvements in Underserved Neighborhoods

21. Tower District-Olive Avenue from Palm Avenue to Van Ness Avenue
Pedestrian Improvements in Pedestrian Activity Areas

22. Yosemite Middle School Neighborhood Pedestrian Improvements in Underserved Neighborhoods

23. Blackstone Avenue/Abby Street from Divisadero to
Shaw Ave
Pedestrian Improvements in Pedestrian Activity Areas

24. Scandinavian Middle School Neighborhood Pedestrian Improvements in Underserved Neighborhoods Source: Compiled by LSA (2025)
TDM = Transportation demand management
ADA = Americans with Disabilities Act

The VMT-reducing improvements identified above could potentially be constructed utilizing funds collected under the proposed VMT Reduction Program. These projects would be subject to future CEQA analysis on a project-by-project basis as they are planned and as the extent of impacts become known through the design process. However, these facilities may result in impacts to the environment. Additionally, it is expected that the VMT-reducing projects identified above may be completed, and the City expects to review and update the project list over time.

The proposed mitigation fee is determined through the development of a Nexus Study, as required by Government Code §§ 66000 – 66025 (also referred to as the “Mitigation Fee Act”). The Nexus Study includes technical details on the estimation of various cost components for the proposed mitigation measures for the project and their efficacy on VMT reductions. The development of the Nexus Study must comply and be consistent with the requisite statutory findings contained in § 66001 of the Mitigation Fee Act by identifying the purpose of the fee, how the fee is being utilized, and a determination that there is a reasonable relationship between the fee and the types of projects that will be subject to the fee, and that there is a reasonable relationship between the need for an infrastructure improvement and the type of project that will be subject to the fee. The Nexus Study provides justification and nexus between anticipated VMT growth and proposed mitigation measures, costs, and fees. The findings of the Nexus Study will be used to establish a mitigation fee for excess VMT (compared to the City’s VMT threshold) generated by the proposed development in Fresno, which would be used to offset and mitigate project-level VMT impacts through funding of active transportation and transit improvement projects identified in the proposed VMT Reduction Program.

As part of the VMT Reduction Program, the City’s existing UDC was created for use by individual projects. Projects that would have a significant VMT impact can reduce the project’s impact by applying VMT reducing project design features at the project site. The extent of VMT reduction could be calculated using the UDC as a first step of the VMT Reduction Program prior to

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Whites Bridge
Maple
Brawley
Herndon
Bullard
Shaw
Clovis
Fowler
Temperance
West
Palm
Clovis
Fowler
Temperance
De Wolf
Highland
McCall
Shields
McKinley
Belmont
Chestnut
Peach
American
Cedar
Grantland
Haye
s
Elm
East
M
arks
W
est
Walnut
Cornelia
North
California
Jensen
Ashlan
Grantland
Hayes
Cornelia
Brawley
Marks
Shaw
Bullard
Herndon
Nees
McCall
Highland
De Wolf
Shields
McKinley
Belmont
California
Jensen
North
Kings Canyon
Ashlan
Peach
Behymer
Copper
Shepherd
Nees
Blackst
one
First
Cedar
Chestnut
Garfield
Bryan
Polk
Blythe
Valentine
Van Ness
Fruit
Maroa
Fresno
Millbrook
Maple
Willow
Dakota
Clinton
Olive
Gettysburg
Barstow
Sierra
Alluvial
Nielsen
Kearney
Muscat
Annadale
Church
W
illow
Minnewawa
Malaga
Orange
Bryan
Sunnys
ide
Arm
strong
Locan
Leonard
Thompson
Fig
Cherry
Hughes
Fruit
Polk
Valentine
Blythe
Alluvial
Sierra
Barstow
Perrin
Sunnyside
Armstrong
Locan
Thompson
Leonard
Clinton
Olive
Tulare
Butler
Church
Annadale
Dakota
Minnewawa
International
Teague
Gould Canal / Redbank Creek
California
State
University
Fresno
Fresno
International
Airport
Fresno-Clovis Regional Wastewater
Reclamation Facility
§¨¦99
§¨¦41
§¨¦41
E
0 31.5 Miles
")6
Document Path: K:\GIS 2025\VMT\VMT 2025.mxd
VMT Reduction Program Fee Projects
Active Transportation
§¨¦180
§¨¦168
§¨¦99
Route Enhancements Route Extensions

1.Mobile ticketing and trip planning app

2.Transit marketing program

3.TDM coordinator

4.Bike/Ped trip trackers

5.Intermodal signage
§¨¦180
Priority Bikeway Improvements
High Pedestrian Activity Area
Underserved Neighborhoods with Missing Sidewalks
New Routes
Transit
Transportation Demand Management Projects
UV45
UV38
UV34
UV32
UV32
UV39
Sphere of Influence
Fresno City Limits
UV34
UV45

6.Frequency enhancement, Route 39

7.Accessibility improvements, Route 34

8.New route- Bullard Ave

9.New route- Church Ave

10.New route- Willow Ave

11.Route extension, Route 45

12.Route enhancement, Route 38

13.Service improvement, Route 32

14.Priority Bikeway/Pedestrian Network

15.Southern Blackstone Smart Mobility Corridor

16.Pedestrian Safety Enhancement Corridor

17.Downtown High Pedestrian Activity Area

18.North Avenue Neighborhood

19.Pedestrian Safety Enhancement Corridor

20.Underserved Neighborhood

21.High Pedestrian Activity Area

22.Yosemite Middle School Neighborhood

23.High Pedestrian Activity Area

24.Scandinavian Middle School Neighborhood
UV38
UV32
UV39
UV45
")7
")8
")9
")11
")10
")13
")14")15
")16
")22
")12
")18
")24
")20
")21
")17
")23
")19
Transit Projects:

Bicycle/Pedestrian Projects:
(not shown on map)
Southern Blackstone Smart Mobility Strategy
Pedestrian Safety Enhancement Corridor
I:\2024\20241626\G\VMT_Mitigation_Program.ai (6/30/2025) FIGURE 3-1
Fresno VMT Mitigation Program EIR
VMT Reduction Program Fee Projects
SOURCE: City of Fresno, 2025
MILES

31.50 Whites Bridge
Maple
Brawley
Herndon
Bullard
Shaw
Clovis
Fowler
Temperance
West
Palm
Clovis
Fowler
Temperance
De Wolf
Highland
McCall
Shields
McKinley
Belmont
Chestnut
Peach
American
Cedar
Grantland
Haye
s
Elm
East
M
arks
W
est
Walnut
Cornelia
North
California
Jensen
Ashlan
Grantland
Hayes
Cornelia
Brawley
Marks
Shaw
Bullard
Herndon
Nees
McCall
Highland
De Wolf
Shields
McKinley
Belmont
California
Jensen
North
Kings Canyon
Ashlan
Peach
Behymer
Copper
Shepherd
Nees
Blackst
one
First
Cedar
Chestnut
Garfield
Bryan
Polk
Blythe
Valentine
Van Ness
Fruit
Maroa
Fresno
Millbrook
Maple
Willow
Dakota
Clinton
Olive
Gettysburg
Barstow
Sierra
Alluvial
Nielsen
Kearney
Muscat
Annadale
Church
W
illow
Minnewawa
Malaga
Orange
Bryan
Sunnys
ide
Arm
strong
Locan
Leonard
Thompson
Fig
Cherry
Hughes
Fruit
Polk
Valentine
Blythe
Alluvial
Sierra
Barstow
Perrin
Sunnyside
Armstrong
Locan
Thompson
Leonard
Clinton
Olive
Tulare
Butler
Church
Annadale
Dakota
Minnewawa
International
Teague
Gould Canal / Redbank Creek
California
State
University
Fresno
Fresno
International
Airport
Fresno-Clovis Regional Wastewater
Reclamation Facility
§¨¦99
§¨¦41
§¨¦41
E
0 31.5 Miles
")6
Document Path: K:\GIS 2025\VMT\VMT 2025.mxd
VMT Reduction Program Fee Projects
Active Transportation
§¨¦180
§¨¦168
§¨¦99
Route Enhancements Route Extensions

1.Mobile ticketing and trip planning app

2.Transit marketing program

3.TDM coordinator

4.Bike/Ped trip trackers

6.Frequency enhancement, Route 39

7.Accessibility improvements, Route 34

8.New route- Bullard Ave

9.New route- Church Ave

10.New route- Willow Ave

11.Route extension, Route 45

12.Route enhancement, Route 38

13.Service improvement, Route 32

14.Priority Bikeway/Pedestrian Network

15.Southern Blackstone Smart Mobility Corridor

16.Pedestrian Safety Enhancement Corridor

17.Downtown High Pedestrian Activity Area

18.North Avenue Neighborhood

19.Pedestrian Safety Enhancement Corridor

20.Underserved Neighborhood

21.High Pedestrian Activity Area

22.Yosemite Middle School Neighborhood

23.High Pedestrian Activity Area

24.Scandinavian Middle School Neighborhood
UV38
UV32
UV39
UV45
")7
")8
")9
")11
")10
")13
")14")15
")16
")22
")12
")18
")24
")20
")21
")17
")23
")19
Transit Projects:

Bicycle/Pedestrian Projects:
(not shown on map)
Southern Blackstone Smart Mobility Strategy
Pedestrian Safety Enhancement Corridor

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participating in the VMT mitigation bank. After applying VMT reductions using the UDC, the remaining excess VMT from the project would be used to calculate the project’s contribution into the mitigation bank.

Existing VMT estimation tools for land use development projects, such as the Fresno COG Activity Based Model (ABM) do not adequately capture the benefits of various project design elements such as pedestrian and bike improvements at the project site level. The City developed its UDC to apply to development projects that have a significant VMT impact to appropriately account for the benefits of various design features in reducing VMT that improve the multimodal design aspects of developments in Fresno.

The UDC estimates the potential reductions in development projects’ VMT due to various design elements of the project. The UDC includes various strategies related to projects’ land use characteristics, urban design elements, and parking pricing/management policies. The UDC has been updated to estimate VMT reductions for various design elements based on the most recent version of California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reduction, Assessing Climate Vulnerabilities, and Advancing Health and Equity (December 2021). While the VMT reduction strategies and methodologies are based on the CAPCOA handbook, the methodologies/variables have been adjusted to the City’s regional characteristics using data from Fresno COG ABM. The UDC helps the user to assess various VMT reduction strategies and select those that are best suited to the type of project, its location, and their efficacies. The UDC is intended to reduce VMT impacts at the project level and related mitigation fees by improving the multimodal design aspects of the City’s development projects.

It is recommended that the UDC be reviewed and updated in the future to incorporate data from existing and approved developments in Fresno that include VMT-reducing design elements, so that elasticities specifically applicable to the City can be refined for the tool. Basing VMT reduction quantifications for specific design elements on data collected within Fresno would provide substantial evidence on the efficacy of specific design features and measures for reducing VMT.

3.4 PROJECT OBJECTIVES
CEQA Guidelines Section 15124(b) states that an EIR project description must include “[a] statement of objectives sought by the proposed project. The statement of objectives should include the underlying purpose of the project.” The proposed project objectives are outlined below. • Streamline the SB 743 compliance process for development projects by providing feasible mitigation options to reduce potentially significant VMT impacts. • Identify funding for future TDM strategies and VMT-reducing projects within Fresno to help reduce Citywide total VMT.
• Contribute towards making Fresno a pedestrian‐, bicycle‐, and transit‐oriented community with active, healthy, and livable spaces.

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3.5 DISCRETIONARY APPROVALS
Although the City is the CEQA Lead Agency for the project, other agencies also have discretionary authority related to the project and approvals or serve as a responsible and/or trustee agency in connection to the project. The following lists these agencies and potential permits and approvals that may be required.

3.5.1 City of Fresno
• Certification of the EIR
• Adoption of the VMT Reduction Program and Nexus Study and the associated Capital Improvement Plan
• Adoption of ordinance amending the Fresno Municipal Code to codify the VMT Mitigation Fee • Amendment of the Master Fee Schedule to include a VMT Mitigation Fee Additionally, TDM strategies and VMT-reducing improvements implemented in accordance with the VMT Reduction Program and constructed as part of future developments or by the City would require separate future discretionary approvals, such as:
• Site Development Permits
• Street Vacations/Dedications
• Encroachment Permits
• Building and Construction Permits

3.5.2 California Department of Transportation (Caltrans) • Encroachment Permits

3.5.3 Other Responsible/Trustee Agencies
• Federal Aviation Administration
• Fresno County Airport Land Use Commission
• California Department of Fish and Wildlife (CDFW)
• San Joaquin Valley Air Pollution Control District (SJVAPCD) • Pacific Gas and Electric Company (PG&E)/California Public Utilities Commission, approvals for power line relocations or undergrounding

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4.0 EVALUATION OF ENVIRONMENTAL IMPACTS
This chapter contains an analysis of each potentially significant environmental issue that has been identified for the Fresno Vehicle Miles Travelled (VMT) Reduction Program (proposed project). The following: (1) identifies how a determination of significance is made; (2) identifies the environmental issues addressed in this chapter; (3) describes the context for the evaluation of cumulative effects; (4) lists the format of the topical issue section; and (5) provides an evaluation of each potentially significant issue in Sections 4.1 through 4.18.

DETERMINATION OF SIGNIFICANCE
Under the California Environmental Quality Act (CEQA), a significant effect is defined as a substantial, or potentially substantial, adverse change in the environment. The State CEQA Guidelines direct that this determination be based on scientific and factual data. The impact evaluation in this chapter is prefaced by criteria of significance, which are the thresholds for determining whether an impact is significant. These criteria of significance are based on the State CEQA Guidelines and applicable City policies.

ISSUES ADDRESSED IN THE DRAFT EIR
Sections 4.1 through 4.18 in this chapter describe the environmental setting of the project as evaluated in this Environmental Impact Report (EIR) and the impacts that are expected to result from implementation of the proposed project. Mitigation measures are proposed to reduce potential impacts, where appropriate.

4.1 Aesthetics

4.2 Agriculture and Forestry Resources

4.3 Air Quality

4.4 Biological Resources

4.5 Cultural Resources and Tribal Cultural Resources

4.6 Energy

4.7 Geology and Soils

4.8 Greenhouse Gas Emissions

4.9 Hazards and Hazardous Materials

4.10 Hydrology and Water Quality

4.11 Land Use and Planning

4.12 Mineral Resources

4.13 Noise

4.14 Population and Housing

4.15 Public Services and Recreation

4.16 Transportation

4.17 Utilities and Service Systems

4.18 Wildfire

ENVIRONMENTAL SETTING
This chapter has been prepared in accordance with State CEQA Guidelines Section 15125, which states: “An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. The environmental setting will normally constitute the baseline physical

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conditions by which a Lead Agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to provide an understanding of the physical effects of the proposed project and its alternatives.” The Notice of Preparation (NOP) of an EIR for the proposed project was published on September 27, 2024. Thus, each of the environmental topical sections in this chapter includes a discussion of physical conditions in the vicinity of the project site on or around September 27, 2024.

CUMULATIVE ANALYSIS CONTEXT
CEQA defines cumulative impacts as “two or more individual effects which, when considered together, are considerable, or which can compound to increase other environmental impacts.” Section 15130 of the State CEQA Guidelines requires that an EIR evaluate potential environmental impacts when the project’s incremental effect is cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of “reasonably foreseeable probable future” projects, per CEQA Section 15355. Cumulative impacts can result from a combination of the proposed project together with other closely related projects that cause an adverse change in the environment. Cumulative impacts can result from individually minor but collectively significant projects taking place over time.

The methodology used for assessing cumulative impacts typically varies depending on the specific topic being analyzed. CEQA requires that cumulative impacts be discussed using either a list of past, present, and probable future projects producing related or cumulative impacts, or a summary of projections contained in an adopted local, regional, or Statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect. This EIR uses both approaches to evaluate cumulative impacts, and the particular approach used depends on the topical area under consideration. Refer to the cumulative discussion in the individual topic sections for further discussion and the identification of the cumulative study are for each topic.

FORMAT OF ISSUE SECTION
The environmental topical sections comprise two primary parts: (1) Environmental Setting, and (2) Impacts and Mitigation Measures. An overview of the general organization and the information provided in the two parts is provided below:
• Existing Environmental Setting. The Environmental Setting section for the environmental topic generally provides a description of the applicable physical setting (e.g., existing land uses, existing traffic conditions) for the project site. An overview of regulatory considerations that are applicable to each specific environmental topic is also provided. • Regulatory Setting. The Regulatory Setting section for the environmental topic provides a description of the applicable regulatory considerations that are applicable to the specific environmental topic discussed.
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• Impacts and Mitigation Measures. The Impacts and Mitigation Measures section for the environmental topic presents a discussion of the impacts that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine whether an impact is significant. The latter part of this section presents the impacts from the proposed project and mitigation measures, as appropriate. Cumulative impacts are also addressed.

Impacts are numbered and shown in bold type, and the corresponding mitigation measures are numbered and indented. Impacts and mitigation measures are numbered consecutively and begin with an acronymic or abbreviated reference to the impact section (e.g., TRA for Transportation). The following symbols are used for individual topics:

AES Aesthetics
AG Agriculture and Forestry Resources
AIR Air Quality
BIO Biological Resources
CUL Cultural Resources and Tribal Cultural Resources
EN Energy
GEO Geology and Soils
GHG Greenhouse Gas Emissions
HAZ Hazards and Hazardous Materials
HYD Hydrology and Water Quality
LU Land Use and Planning
MIN Mineral Resources
NOI Noise
POP Population and Housing
PSR Public Services and Recreation
TRA Transportation
UTL Utilities and Service Systems
WF Wildfire

Impacts are also categorized by type of impact, as follows: No Impact, Less Than Significant, Less Than Significant with Mitigation Incorporated, and Potentially Significant.

ENVIRONMENTAL ISSUES
Sections 4.1 through 4.18 of this chapter describe the environmental setting of the project as it relates to each specific environmental topic evaluated in the EIR and the impacts that are expected to result from implementation of the proposed project. Mitigation measures are proposed to reduce potential impacts, where appropriate.

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4.1 AESTHETICS
This section describes the existing aesthetic character of the project area and evaluates the potential impacts to visual resources associated with implementation of the proposed VMT Reduction Program.

4.1.1 Existing Environment Setting
• Scenic Resources: Scenic resources are defined as natural or man‐made elements that contribute to an area’s scenic value and are visually pleasing. Scenic resources include landforms, vegetation, water, or adjacent scenery and may include a cultural modification to the natural environment. The degree to which these resources are present in a community is clearly subject to personal and cultural interpretation. Scenic resources within the city of Fresno include landscaped open space areas including parks and golf courses; areas along the San Joaquin River due to varying topography; and the river bluffs, which provide a unique geological feature in the San Joaquin Valley. Man‐made scenic resources include historic buildings in Downtown Fresno, which provide a unique skyline.
• Light and Glare: Lighting effects are associated with the use of artificial light during the evening and nighttime hours. There are two primary sources of light: light emanating from building interiors passing through windows, and light from exterior sources (i.e., street lighting, building illumination, security lighting, parking lot lighting, and landscape lighting). Light introduction can be a nuisance to adjacent residential areas, diminish the view of the clear night sky, and if uncontrolled, can cause disturbances. Uses such as residences are considered light sensitive since occupants have expectations of privacy during evening hours and may be subject to disturbance by bright light sources.

Glare is primarily a daytime occurrence caused by the reflection of sunlight or artificial light by highly polished surfaces such as window glass or reflective materials and, to a lesser degree, from broad expanses of light‐colored surfaces. Perceived glare is the unwanted and potentially objectionable sensation as observed by a person as they look directly into the light source of a luminaire. Daytime glare generation is common in urban areas and is typically associated with buildings with exterior facades largely or entirely comprised of highly reflective glass. Glare can also be produced during evening and nighttime hours by the reflection of artificial light sources such as automobile headlights. Glare‐sensitive uses include residences, transportation corridors, and aircraft landing corridors.

The majority of the area within the existing city limits is urbanized and is characterized by significant sources of light and glare, including streetlights, lighting within parking lots, interior lights from Downtown buildings, lighting associated with recreational facilities, and light emitted from residential and non‐residential buildings throughout the city. Rural residential and agricultural areas that are located within the southeastern and western portions of the city are not characterized by significant sources of light and glare.

The analysis of visual impacts focuses on changes in the visual character of the city that may result subsequent to the approval of the proposed project. This would include the visual

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compatibility of land uses, changes in scenic vistas and viewsheds where visual changes would be evident, changes to scenic resources along designated scenic corridors, and the introduction of new sources of light and glare. Impacts to the existing environment in and around the city are identified by the contrast between the visual setting of the city before and after implementation of the proposed project.

4.1.2 Regulatory Setting

4.1.2.1 Federal Policies and Regulations
No federal policies or regulations pertaining to aesthetics are applicable to the proposed project.

4.1.2.2 State Policies and Regulations
Caltrans Scenic Highway Program. The Caltrans Scenic Highway Program protects the natural scenic beauty of the State’s highways and corridors through its designated scenic highways throughout the State. Caltrans defines a scenic highway as any freeway, highway, road, or other public right‐of‐way that traverses an area of exceptional scenic quality. Other considerations given to a scenic highway designation include how much of the natural landscape a traveler may see and the extent to which visual intrusions degrade the scenic corridor. As stated previously, there are no eligible or officially designated State Scenic Highways within the city of Fresno.

California Building Energy Efficiency Standards. Title 24, Part 6 of the California Code of Regulations outlines mandatory provisions for lighting control devices and luminaires for all new developments.

This code encourages buildings (both residential and nonresidential) to be constructed and operated utilizing energy‐efficient development strategies.

4.1.2.3 Local Policies and Regulations
The following is a summary of the applicable policies included in the City’s Zoning Ordinance and General Plan that are related to aesthetic resources and applicable to the proposed project.

City of Fresno Municipal Code
Zoning Ordinance. The City’s Zoning Ordinance (Chapter 15 of the Municipal Code) is intended to provide a guide for the physical development of the city in order to achieve the arrangement of land uses depicted in the City’s General Plan, as well as implement goals, objectives, and policies of the City’s General Plan. Among the aspects of development regulated by the Municipal Code are types of allowable land uses, setback and height requirements, landscaping, walls, fencing, signage, access, parking requirements, storage areas, and trash enclosures. Article 25, Performance Standards, of the Zoning Ordinance includes standards related to lighting and glare.

City of Fresno General Plan. The City of Fresno’s General Plan Urban Form, Land Use, and Design Element includes objectives and policies that work to establish a comprehensive Citywide land use planning strategy to meet economic development objectives, achieve efficient and equitable use of

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resources and infrastructure, and create an attractive living environment. The following policies related to aesthetics are applicable to the proposed project.

Policy LU‐5‐g: Scale and Character of New Development. Allow new development in or adjacent to established neighborhoods that is compatible in scale and character with the surrounding area by promoting a transition in scale and architectural character between new buildings and established neighborhoods, as well as integrating pedestrian circulation and vehicular routes.

Policy D‐4‐f: Design Compatibility with Residential Uses. Strive to ensure that all new nonresidential land uses are developed and maintained in a manner complementary to and compatible with adjacent residential land uses, to minimize interface problems with the surrounding environment and to be compatible with public facilities and services.

Policy MT‐3‐a: Scenic Corridors. Implement measures to preserve and enhance scenic qualities along scenic corridors or boulevards, including:
• Van Ness Boulevard ‐ Weldon to Shaw Avenues
• Van Ness Extension ‐ Shaw Avenue to the San Joaquin River Bluff • Kearney Boulevard ‐ Fresno Street to Polk Avenue
• Van Ness/Fulton couplet ‐ Weldon Avenue to Divisadero • Butler Avenue ‐ Peach to Fowler Avenues
• Minnewawa Avenue ‐ Belmont Avenue to Central Canal
• Huntington Boulevard ‐ First Street to Cedar Avenue
• Shepherd Avenue ‐ Friant Road to Willow Avenue
• Audubon Drive ‐ Blackstone to Herndon Avenues
• Friant Road ‐ Audubon to Millerton Roads
• Tulare Avenue ‐ Sunnyside to Armstrong Avenues
• Ashlan Avenue‐ Palm to Maroa Avenues

4.1.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to aesthetics that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less‐than‐significant level. Cumulative impacts are also addressed.

4.1.3.1 Significance Criteria
The thresholds for aesthetics impacts used in this analysis are consistent with Appendix G of the State CEQA Guidelines. The proposed project may be deemed to have a significant impact with respect to aesthetics if it would:

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a. Have a substantial adverse effect on a scenic vista. b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
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? d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

4.1.3.2 Project Impacts
The following discussion describes the potential impacts related to aesthetics that could result from implementation of the proposed project.

AES‐1 The proposed project would not have a substantial adverse effect on a scenic vista.

A scenic vista is generally defined as a view of undisturbed natural lands exhibiting a unique or unusual feature that comprises an important or dominant portion of the viewshed. Scenic vistas may also be represented by a particular distant view that provides visual relief from less attractive views of nearby features. Other designated Federal and State lands, as well as local open space or recreational areas, may also offer scenic vistas if they represent a valued aesthetic view within the surrounding landscape of nearby features.

The city is almost entirely developed and is characterized by an urban and suburban landscape consisting of low, medium, and high density residential, commercial, office, mixed use, industrial, institutional, and open space uses. The visual setting of the proposed project is primarily characterized by areas of low‐ to moderate‐scale buildings and structures; however, the Downtown Fresno area is characterized by high‐rise buildings that are greater in height, density, and scale than other surrounding areas. Views from the project area include highly valued features such as the San Joaquin River, Sierra Nevada Mountain foothills, and buildings in Downtown Fresno. Public views of the San Joaquin River from the project are limited due to the prevalence of privately‐owned property located adjacent to the river. From the eastern portion of the city, public views of the Sierra Nevada Mountain foothills are prevalent from existing public roadways. It should be noted that views of the foothills are typically impeded due to the poor air quality within the city.

The City’s 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 City’s General Plan are similar to current land uses. As such, implementation of the VMT Reduction Program would result in a less than significant impact on existing designated vista points.

Public views of buildings in Downtown Fresno provide a skyline view with the city of Fresno. Due to relatively flat topography, intervening land uses, and landscaping, views of the skyline are primarily

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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.

Implementation of the VMT Reduction Program would not affect future development in the Downtown area. Therefore, potential impacts of the proposed project on scenic vistas would be less than significant, and no mitigation would be required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AES‐2 The proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

According to the Caltrans State Scenic Highway Mapping System, there are no eligible or officially designated State Scenic Highways within Fresno. However, Fresno County has three eligible State Scenic Highways; the nearest eligible highways include a portion of SR 180 (approximately 7 miles east of the City’s Planning Area) and a portion of SR 168 (approximately 5 miles east of the Planning Area). The nearest officially designated State Scenic Highway is located more than 30 miles northeast of Fresno within the county of Madera. Due to intervening land uses and distance, implementation of the VMT Reduction Program would not impact scenic resources from these eligible and officially designated State Scenic Highways nearest to Fresno. Therefore, since there are no eligible or officially designated State Scenic Highways within or in close proximity to the City of Fresno Planning Area, future projects implemented under the VMT Reduction Program would not impact scenic resources within a designated state scenic highway.

Although there are no eligible or officially designated State Scenic Highways located in the Planning Area, the City’s General Plan designates the following local scenic corridors:
• Van Ness Boulevard – Weldon to Shaw Avenues
• Van Ness Extension – Shaw Avenue to the San Joaquin River Bluff • Kearney Boulevard – Fresno Street to Polk Avenue
• Van Ness‐Fulton couplet – Weldon Avenue to Divisadero • Butler Avenue – Peach to Fowler Avenues
• Minnewawa Avenue – Belmont Avenue to Central Canal
• Huntington Boulevard – First Street to Cedar Avenue
• Shepherd Avenue – Friant Road to Willow Avenue
• Audubon Drive – Blackstone to Herndon Avenues
• Friant Road – Audubon to Millerton Roads
• Tulare Avenue – Sunnyside to Armstrong Avenues
• Ashlan Avenue – Palm to Maroa Avenues.

Although implementation of the VMT Reduction Program would facilitate new projects in the city, future projects would not affect scenic qualities along these scenic corridors. Therefore, the proposed project would not result in impacts related to the substantial damage of scenic resources within a State‐designated highway or local scenic corridors.

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Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AES‐3 The proposed project would not 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), and due to the location of the project in an urbanized area, the project would not conflict with applicable zoning and other regulations governing scenic quality.

The City includes both urbanized and non‐urbanized areas. For the purposes of this threshold and given the nature of the proposed program and location of most VMT‐reducing improvements within the City, the project’s potential to conflict with applicable zoning and other regulations governing scenic quality is evaluated below.

As stated, the proposed program would fund VMT‐reducing transportation improvements as City‐ initiated projects. As a result, future improvements would be required to comply with existing City standards related to street improvements. Additionally, future transportation improvements implemented as part of development projects would be required to comply with zoning‐specific development standards governing scenic quality, including setbacks, landscaping, outdoor lighting, and signage per Municipal Code Chapter 15, Citywide Development Code. Future improvements may also be located in Specific Plan areas of the City and thus, would be required to comply with development standards and design guidelines governing scenic quality as they relate to roadway design within those areas. All future transportation improvements would also be required to undergo separate environmental review under CEQA and implement project‐level mitigation measures, as needed.

Overall, future transportation improvements would be required to comply with existing zoning regulations governing scenic quality and would be ensured as part of the City’s plan review process.

Thus, future improvements constructed as part of the proposed project would be consistent with the Municipal Code and impacts in this regard would be less than significant.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AES‐4 The proposed project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

A significant impact may occur if lighting, as part of a proposed project exceeds adopted thresholds for light and glare, including exterior lighting or light spillover, or if a proposed project creates a substantial new source of light or glare. Light‐sensitive uses in Fresno are predominantly associated with residential development.

Future construction activities associated with implementation of the VMT Reduction Program could involve temporary glare impacts as a result of construction equipment and materials. However, the

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majority of projects identified by the VMT Reduction Program would occur within existing rights‐of‐ way. Therefore, glare generated from construction activities would not be substantial when compared to other existing sources of glare along City roadways (e.g., buildings, structures, and vehicles).

Additionally, construction activities within Fresno are generally limited to the hours of 7:00 a.m. to 10:00 p.m. from Monday through Saturday per Municipal Code Section 10‐109. Thus, as no construction activities would be permitted after 10:00 p.m. from Monday through Saturday, or on Sundays, short‐term construction‐related impacts pertaining to nighttime lighting are not anticipated.

It should also be noted that all future projects implemented as part of the VMT Reduction Program would be required to undergo separate environmental review under CEQA and would be evaluated on a project‐specific level with regards to light and glare construction impacts.

Most of the anticipated transportation improvements funded by the VMT Reduction Program would have no operational impacts with regards to light and glare. However, some improvements, including those implemented as part of future development projects, could include additional roadway or pathway lighting within or along existing rights‐of‐way or at new bus stop shelters. Outdoor lighting requirements are detailed in Municipal Code Title 15, Outdoor Lighting and Illumination. For example, Municipal Code Section 15‐2015, Outdoor Lighting and Illumination, regulates outdoor lighting and requires lighting to be directed away from adjacent properties and designed and located in a manner that prevents glare onto adjacent properties. As stated, future transportation improvements and those implemented as part of future development projects would be required to undergo separate environmental review under CEQA to evaluate project‐level impacts with regards to operational light and glare and implement mitigation, as needed. Thus, impacts would be less than significant in this regard.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

4.1.3.3 Cumulative Impacts
CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with future buildout of the General Plan.

Scenic Vistas. Future cumulative projects developed in accordance with the General Plan could result in adverse impacts to scenic vistas in Fresno. However, similar to future transportation improvements associated with the VMT Mitigation Program, cumulative projects would be required to undergo project‐specific environmental review under CEQA to evaluate project‐level impacts to scenic vistas and to determine any required mitigation. As analyzed above, transportation improvements implemented in accordance with the proposed program are not anticipated to contribute to a cumulative impact with regards to scenic vistas, as these improvements would

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predominantly be located within or along existing rights‐of‐way and would not be large enough in scale and height to block or obstruct views compared to existing surrounding structures. Further, future transportation improvements would also be required to undergo separate environmental review under CEQA. Thus, the proposed program would not significantly contribute to cumulative impacts in this regard and impacts would be less than significant.

Scenic Highways. There are no designated State Scenic Highways within the city of Fresno. As result, implementation of the VMT Reduction Program would not impact eligible or officially designated State Scenic Highways. The nearest State Scenic Highway in the county of Madera is located more than 30 miles northeast of the Planning Area. Further, due to distance, cumulative development located outside of the city of Fresno would not impact local scenic corridors as designated in the City’s General Plan. Therefore, future projects implementation of the VMT Reduction Program would result in no cumulative impact on scenic vistas, State Scenic Highways, local scenic corridors.

Visual Quality. Under this threshold, future cumulative projects developed in accordance with the General Plan would be evaluated based on whether the project is located in an urbanized or nonurbanized area. If a cumulative project is proposed in an urbanized area, the project would be evaluated based on whether it could conflict with applicable zoning and other regulations governing scenic quality. If a cumulative project is proposed in a non‐urbanized area (e.g., rural), it would be evaluated based on whether it could substantially degrade the existing visual character or quality of public views of the site and its surrounding. Regardless, cumulative projects would be required to undergo project‐specific environmental review under CEQA to evaluate project‐level impacts and to determine any required mitigation. As part of the City’s plan review process, the City would review each cumulative project for consistency with applicable General Plan policies and site development standards included in the Municipal Code that aid in governing scenic quality.

As stated, future transportation improvements funded by the proposed program would be required to comply with existing City standards related to street improvements and zoning‐specific land use development standards under Municipal Code Chapter 15. Further, should future improvements be located in a Specific Plan area, the improvements would be required to comply with development standards and design guidelines governing scenic quality as they relate to roadway design within those areas. Thus, the proposed project would not significantly contribute to cumulative impacts to scenic quality regulations and impacts in this regard would be less than significant.

Light and Glare. Development of cumulative projects could result in increased light and glare in the City during construction and operational activities. However, all cumulative development would be required to undergo separate environmental review under CEQA to evaluate project‐level impacts associated with light and glare. Additionally, similar to the proposed project, cumulative projects would be required to comply with outdoor lighting requirements specific to each zoning district as detailed in Municipal Code Chapter 15, Citywide Development Code.

As stated, short‐term and long‐term light and glare impacts associated with the project’s transportation improvements would be reduced to less than significant levels following conformance with outdoor lighting standards under the Municipal Code. Further, the majority of transportation improvements would occur within or adjacent to existing rights‐of‐way and would not result in substantial new sources of light and glare compared to existing conditions. Thus, the project would

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not cumulatively contribute to the creation of substantial new lighting or glare and impacts would be less than significant.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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4.2 AGRICULTURE AND FORESTRY RESOURCES
This section provides a discussion of the existing agricultural and forestry resources in the project area and in the surrounding area, and evaluates the potential for conversion of agriculture and forestry land uses that could result from implementation of the proposed Fresno VMT Reduction Program.

4.2.1 Existing Environment Setting
The study area for project impacts regarding agricultural resources is the Fresno Planning Area because, as shown in Figure 3-2 in Chapter 3.0, Project Description, potential development under the proposed project would be limited to areas within the Planning Area. The Planning Area includes all areas within the City’s current city limits, including the Fresno‐Clovis Regional Wastewater Reclamation Facility (RWRF), the areas within the current Sphere of Influence (SOI). The Planning Area is characterized as a mature agricultural area due to the prevalence and diversity of farming activities. Agricultural operations are comprised of relatively stable crops such as orchards and vineyards. Fruits and nuts, livestock and poultry, vegetable crops, and field crops are prevalent in Fresno and Madera counties.

4.2.2 Methodology
The potential project-related impacts to agricultural and forestry resources were evaluated on a qualitative and quantitative basis. Quantitative impacts were assessed based on existing farmland data from the California Department of Conservation (California DOC) Farmland Mapping and Monitoring Program (FMMP), as well as farmland data received from the Fresno County Assessor’s Office Land Use Codes provided by City staff. Qualitative impacts were assessed by evaluating the project’s potential for impacting agricultural activities within the Planning Area.

4.2.3 Regulatory Setting

4.2.3.1 Federal Policies and Regulations
Farmland Protection Policy Act. The Farmland Protection Policy Act (FPPA) was enacted to minimize the impact of federal programs on the conversion of farmland to non-agricultural uses. To the extent possible, the FPPA ensures that federal programs are administered to be compatible with state and local regulations to protect farmland. This act does not authorize the federal government to regulate the use of private or non-federal land. For the purposes of the FPPA, farmland includes prime farmland, unique farmland, and land of statewide or local importance.

4.2.3.2 State Policies and Regulations
Farmland Mapping and Monitoring Program.In 1982, the California DOC began coordinating with the United Stated Department of Agriculture (USDA) Soil Conservation Service in the preparation and completion of mapping of important farmland throughout the State. The FMMP created a greater level of mapping compared to the USDA Soil Conservation Service by modifying the federal criteria for use in the State and incorporating irrigation criteria for farmland significance. The primary purpose of the FMMP is to monitor the conversion of the State’s agricultural lands. The DOC Division of Land Resource Protection works with landowners, local governments, and researchers to

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conserve California’s farmland and open space resources based on information provided in the FMMP.

The DOC FMMP produces maps and statistical data used for analyzing impacts on agricultural resources. Agricultural land is categorized according to soil quality and irrigation status. The maps are updated every 2 years through review of aerial photographs, a computer mapping system, public review, and field reconnaissance. The FMMP categories are defined as follows:
• Prime Farmland (P): This land category has the best combination of physical and chemical features for sustaining long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce crops with sustained high yields. The land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date.
• Farmland of Statewide Importance (S): This category is similar to Prime Farmland but with minor shortcomings (e.g., greater slopes or less ability to store soil moisture). The land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date.
• Unique Farmland (U): This category consists of lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated, but may include non-irrigated orchards or vineyards. The land must have been cropped at some time during the 4 years prior to the mapping date.
• Farmland of Local Importance (L): This land category is important to the local agricultural economy as determined by each county’s Board of Supervisors and a local advisory committee. • Grazing Land (G): This type of land is occupied with vegetation suited to grazing livestock. This category was developed in cooperation with the California Cattleman’s Association, University of California Cooperative Extension, and other groups interested in the extent of grazing activities. The minimum mapping unit is 40 acres.
• Urban and Built-Up Land (D): This type of land is occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. Common examples include residential, industrial, commercial, institutional facilities, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, and water control structures. • Other Land (X): This type of land is not included in any other mapping category. Common examples include low-density rural developments, brush, timber wetland, riparian area not suitable for livestock grazing, and water bodies smaller than 40 acres. Vacant and non- agricultural land surrounded on all sides by urban development that is greater than 40 acres is mapped as Other Land.
• Water (W): This classification includes perennial water bodies with an extent of at least 40 acres.

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• Optional Designation – Land Committed to Non-Agricultural Use: This type of land is defined as existing farmland, grazing land, and vacant areas, which have a permanent commitment for development.

The DOC FMMP considers Prime Farmland, Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance collectively as Important Farmland.

Based on the farmland mapping categories identified above, Table 4.2-1 depicts the acreages of each category within the Planning Area.

Table 4.2-1: Existing Farmland Acreages Within the
Planning Area
Designation Acreage
Prime Farmland 9,134
Farmland of Statewide Importance 2,269
Unique Farmland 3,224
Farmland of Local Importance 7,896
Urban and Built Up 71,963
Rural Residential 6,434
Nonagricultural or Natural Vegetation 1,869
Confined Animal Agriculture 136
Grazing 1
Vacant or Disturbed 2,327
Water 57
Semi-Agricultural and Rural Commercial 729
Source: USDA FMMP (2016).

As shown in Table 4.2-1, the Planning Area includes approximately 9,134 acres of Prime Farmland, approximately 2,269 acres of Farmland of Statewide Importance, and approximately 3,224 acres of Unique Farmland. In total, the Planning Area includes approximately 14,627 acres of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland. This represents approximately

13.8 percent of the Planning Area.1
Land Conservation Act of 1965 (Williamson Act). The California Land Conservation Act, better known as the Williamson Act, has acted as the State’s agricultural land protection program since its enactment in 1965. Fundamentally, the Williamson Act is a State policy administered by local governments, who enter into agreements with local landowners. In return, the landowners receive property tax assessments based on farming and open space uses, as opposed to full market value, thus resulting in a lower tax burden. Local governments are not mandated to administer the Act, but those that do have some latitude to tailor the program to suit local goals and objectives. The purpose of the Williamson Act is to preserve agricultural and open space lands by discouraging premature and unnecessary conversion to urban uses. In general, the minimum preserve size is 100 acres, and the minimum standard contract size for the county of Fresno is 20 acres on Prime

1 Calculation: 14,627 acres of farmland / 106,000 acres in Planning Area = 13.8 percent

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Farmland and 40 acres on non‐prime farmland within a preserve. The Williamson Act has a minimum contract size of 10 acres.

Williamson Act contracts have a minimum term of 10 years, with renewal occurring automatically each year (local governments can establish initial contract terms for longer periods of time). The Williamson Act contracts run with the land and are binding on all successors in interest of the landowner. Only land located within an agricultural preserve is eligible for Williamson Act contracts.

An agricultural preserve defines the boundary of an area within which a city or county would enter into contracts with landowners. The boundary is designated by resolution of the board of supervisors or city council having jurisdiction. The rules of each agricultural preserve specify the uses allowed. Generally, any commercial agricultural uses would be permitted within any agricultural preserve. In addition, local governments may identify compatible uses allowed with a use permit.

The landowner can petition to cancel a contract, although the presiding jurisdiction must make a finding based on substantial evidence that supports the cancellation of the contract. Upon approval, the landowner must pay a fee of 12.5 percent of the current fair market valuation of the property.

Table 4.2-2 shows the acreages of land under a Williamson Act contract within the Planning Area.

Table 4.2-2: Existing Farmland under Williamson
Act Contracts Within the Planning Area
Designation Acreage
Prime Farmland 1,012
Farmland of Statewide Importance 343
Unique Farmland 431
Farmland of Local Importance 157
Other Lands 603
Total 2,546
Source: USDA FMMP (2016).

As shown in Table 4.2-2, the Planning Area contains approximately 1,012 acres of prime agricultural land that are under a Williamson Act contract as well as approximately 931 acres of non‐prime agricultural land (i.e., Statewide Importance, Unique, or Local Importance).

Public Resources Code 12220 (g) – Forest Land. “Forest land” is land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.Public Resources Code 4526 - Timberland. “Timberland” means land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees. Commercial species shall be determined by the board on a district basis.Public Resources Code 51104 (g) – Timberland Production Zone. “Timberland production zone” or “TPZ” means an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses.Local Policies and Regulations

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City of Fresno General Plan. The General Plan is a set of goals, objectives, and policies that form a blueprint for the physical development of the city. The following objective and policies related to agricultural resources are applicable to the proposed project.

Objective RC-9. Preserve agricultural land outside of the area planned for urbanization under this General Plan.

Policy RC-9-b: Unincorporated Land in the Planning Area. Express opposition to residential and commercial development proposals in unincorporated areas within or adjacent to the Planning Area when these proposals would do any of the following:
• Make it difficult or infeasible to implement the General Plan; • Contribute to the premature conversion of agricultural, open space, or grazing lands; or • Constitute a detriment to the management of resources and/or facilities important to the region (such as air quality, water quantity and quality, traffic circulation, and riparian habitat).

Policy RC-9-c: Farmland Preservation Program. In coordination with regional partners or independently, establish a Farmland Preservation Program. When Prime Farmland, Unique Farmland, or Farmland of Statewide Importance is converted to urban uses outside City limits, this program would require that the developer of such a project permanently protect an equal amount of similar farmland elsewhere through easement to mitigate the loss of such farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall provide several mitigation options that may include, but are not limited to the following: Restrictive Covenants or Deeds, In Lieu Fees, Mitigation Banks, Fee Title Acquisition, Conservation Easements, Land Use Regulation, or any other mitigation method that is in compliance with the requirements of CEQA. The Farmland Preservation Program may be modeled after some or all of the programs described by the California Council of Land Trusts.

4.2.4 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to agriculture and forestry resources that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant.

The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less than significant level. Cumulative impacts are also addressed.

4.2.4.1 Significance Criteria
Based on State CEQA Guidelines Appendix G, the proposed project would have a significant impact on agricultural resources if it would:

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

4.2.4.2 Project Impacts
The following discussion describes the potential impacts related to agriculture and forestry resources that could result from implementation of the proposed project.

AG-1 The proposed project would not 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.

The project area is located within Fresno and which includes areas that have been designated as Prime Farmland, Unique Farmland, and Farmland of Statewide Importance through the FMMP of the California DOC. However, it should be noted that existing agricultural operations are not necessarily occurring on all of the land designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance by the FMMP. In addition, there may be agricultural operations that occur within the Fresno that are not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.

The project is proposing to adopt a VMT Reduction Program which aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank and urban design calculator (UDC). The program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank. The project would not result in any physical improvements or change the distribution or intensity of the land uses within the project area. The adoption of the proposed VMT Reduction Program would support future design improvements at the project level through the UDC and multi-modal or transportation improvements citywide in accordance with the program. These improvements would not involve converting important farmland to non-agricultural uses. Although the program identifies VMT-reducing improvements for the program, these improvements are associated with VMT-reducing measures through the implementation of multi-modal improvements within Fresno and would not require the conversion of agricultural land. Therefore, the proposed

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project would not result in impacts to agricultural resources within the project area and no mitigation is necessary.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AG-2 The proposed project would not conflict with existing zoning for agricultural use, or a Williamson Act contract.

The project description does suggest identified improvements in areas within the project area that allow for multimodal improvements or are associated with existing transportation uses. These improvements would not result in impacts that conflict with existing zoning for agricultural use or Williamson Act contracts as the improvements are located in areas with existing transportation land uses. Additionally, adoption of the VMT Reduction Program would not result in a conflict with existing zoning for agricultural use or a Williamson Act contract. Therefore, the project would not conflict with the existing zoning for agricultural use or Williamson Act contracts and no mitigation is necessary.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AG-3 The proposed project would not 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)).

The project area is not used for forestry purposes, and no properties within the project area are designated or zoned for forestry uses. Therefore, the project would not conflict with existing zoning for, or cause rezoning of, forest land timberland, or timberland zoned Timberland Production.

Therefore, the project would not impact forestry resources, and no mitigation is required.

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Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AG-4 The proposed project would not result in the loss of forest land or conversion of forest land to non-forest use.

The project is proposing to implement a VMT Reduction Program which aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank. The program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT- reducing projects within Fresno to be funded by the proposed mitigation bank. The adoption of the proposed VMT Reduction Program would support future transportation improvements in accordance with the program and would likely be located within or adjacent to areas associated with existing transportation uses.

As stated above, the planning area is not used for forestry purposes, and no properties within the project area are designated or zoned for forestry uses. Therefore, the project would not result in the loss of forest land or conversion of forest land to non-forest use and no mitigation is required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AG-5 The proposed project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Important Farmland, to non- agricultural use.

The project is proposing to adopt a VMT Reduction Program which aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank. The program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank. The adoption of the proposed VMT Reduction Program would support future multi-modal or transportation improvements in accordance with the proposed project. The proposed project includes the adoption of the proposed VMT Reduction Program, which would not result in any physical improvements or change the distribution or intensity of the land uses within the project area. As such, the proposed project would result in a less-than-significant impact related to conversion of Important Farmland to a non- agricultural use, and no mitigation is necessary.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

4.2.4.3 Cumulative Impacts
The project is proposing to adopt a VMT Reduction Program which aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank. The program would identify, quantify, and prioritize applicable mitigation measures, and relevant VMT-reducing

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projects within Fresno to be funded by the proposed mitigation bank. The adoption of the proposed VMT Reduction Program would support future multi-modal or transportation improvements in accordance with the program. The project description does suggest identified improvements in areas within the project area that allow for multimodal improvements or are associated with existing transportation uses. Based on the analysis above, the adoption of the proposed VMT Reduction Program along with the project description’s identified improvements, would not result in any physical improvements or change the distribution or intensity of the land uses within the project area, and, therefore, would not result in cumulative impacts to agricultural resources.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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4.3 AIR QUALITY
This section describes the existing air quality setting in the project area and has been prepared using the methodologies and assumptions contained in the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI).1 In keeping with these guidelines, this section describes existing air quality and the regulatory framework for air quality. The section also describes the potential effects of the proposed project on air quality, including the effects of construction and operation of the proposed project on regional pollutant levels and health risks.

4.3.1 Existing Environment Setting
The city of Fresno is located in the county of Fresno in the San Joaquin Valley Air Basin (SJVAB). The Air Basin consists of Kings, Madera, San Joaquin, Merced, Stanislaus, and Fresno counties, as well as a portion of Kern county. The local agency with jurisdiction over air quality in the Basin is the San Joaquin Valley Air Pollution Control District (SJVAPCD). Regional and local air quality is impacted by topography, dominant airflows, atmospheric inversions, location, and season.

4.3.1.1 Study Area for Project Impacts
The study area for project impacts regarding air quality is the City of Fresno Planning Area and proximate sensitive receptors potentially impacted by a project within the Planning Area because the proposed project is limited to areas within the Planning Area.

4.3.1.2 Air Pollutants and Health Effects
Both State and federal governments have established health-based Ambient Air Quality Standards for six criteria air pollutants: carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter. In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Two criteria pollutants, O3 and NO2, are considered regional pollutants because they (or their precursors) affect air quality on a regional scale. Pollutants such as CO, SO2, and Pb are considered local pollutants that tend to accumulate in the air locally.

Occupants of facilities such as schools, daycare centers, parks and playgrounds, hospitals, and nursing and convalescent homes are considered to be more sensitive than the general public to air pollutants because these population groups have increased susceptibility to respiratory disease.

Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality.

Residential areas are considered more sensitive to air quality conditions, compared to commercial and industrial areas, because people generally spend longer periods of time at their residences, with greater associated exposure to ambient air quality conditions. Recreational uses are also considered

1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Final Draft - Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf (accessed May 2025).

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sensitive compared to commercial and industrial uses due to greater exposure to ambient air quality conditions associated with exercise.

Air pollutants and their health effects, and other air pollution-related considerations are summarized in Table 4.3.A and are described in more detail below.

Table 4.3.A: Sources and Health Effects of Air Pollutants Pollutants Sources Primary Effects
Ozone (O3) Precursor sources:1 motor vehicles,
industrial emissions, and consumer
products.

Respiratory symptoms.

Worsening of lung disease leading to premature
death.

Damage to lung tissue.

Crop, forest, and ecosystem damage.

Damage to a variety of materials, including rubber,
plastics, fabrics, paints, and metals.

Particulate Matter Less
than 2.5 Microns in
Diameter (PM2.5)
Cars and trucks (especially diesels).

Fireplaces, woodstoves.

Windblown dust from roadways,
agriculture, and construction.

Premature death.

Hospitalization for worsening of cardiovascular
disease.

Hospitalization for respiratory disease.

Asthma-related emergency room visits.

Increased symptoms, increased inhaler usage.

Particulate Matter Less
than 10 Microns in
Diameter (PM10)
Cars and trucks (especially diesels).

Fireplaces, woodstoves.

Windblown dust from roadways,
agriculture, and construction.

Premature death and hospitalization, primarily for
worsening of respiratory disease.

Reduced visibility and material soiling.

Nitrogen Oxides (NOX) Any source that burns fuels such as cars, trucks, construction and farming
equipment, and residential heaters and
stoves.

Lung irritation.

Enhanced allergic responses.

Carbon Monoxide (CO) Any source that burns fuels such as cars, trucks, construction and farming
equipment, and residential heaters and
stoves.

Chest pain in patients with heart disease.

Headache.

Light-headedness.

Reduced mental alertness.

Sulfur Oxides (SOX) Combustion of sulfur-containing fossil fuels.

Smelting of sulfur-bearing metal ores.

Industrial processes.

Worsening of asthma: increased symptoms,
increased medication usage, and emergency room
visits.

Lead (Pb) Contaminated soil. Impaired mental functioning in children.

Learning disabilities in children.

Brain and kidney damage.

Toxic Air Contaminants
(TACs)
Cars and trucks (especially diesels).

Industrial sources, such as chrome
platers.

Neighborhood businesses, such as dry
cleaners and service stations.

Building materials and products.

Cancer.

Reproductive and developmental effects.

Neurological effects.

Source: California Air Resources Board (2018).
1 Ozone is not generated directly by these sources. Rather, chemicals emitted by these precursor sources react with sunlight to form ozone in the atmosphere.

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Ozone. Ozone is a secondary air pollutant produced in the atmosphere through a complex series of photochemical reactions involving ROG and NOX. The main sources of ROG and NOX, often referred to as ozone precursors, are combustion processes (including combustion in motor vehicle engines) and the evaporation of solvents, paints, and fuels. Automobiles are the single largest source of ozone precursors. Ozone is referred to as a regional air pollutant because its precursors are transported and diffused by wind concurrently with ozone production through the photochemical reaction process. Ozone causes eye irritation, airway constriction, and shortness of breath and can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema.Carbon Monoxide. CO is an odorless, colorless gas usually formed as the result of the incomplete combustion of fuels. The single largest source of CO is motor vehicles. CO transport is limited - it disperses with distance from the source under normal meteorological conditions. However, under certain extreme meteorological conditions, CO concentrations near congested roadways or intersections may reach unhealthful levels that adversely affect local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients). Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service (LOS) or with extremely high traffic volumes. Exposure to high concentrations of CO reduces the oxygen-carrying capacity of the blood and can cause headaches, nausea, dizziness, and fatigue, impair central nervous system function, and induce angina (chest pain) in persons with serious heart disease.

Extremely high levels of CO, such as those generated when a vehicle is running in an unventilated garage, can be fatal.Particulate Matter. Particulate matter is a class of air pollutants that consists of heterogeneous solid and liquid airborne particles from human-made and natural sources.

Particulate matter is categorized in two size ranges: PM10, for particles less than 10 microns in diameter, and PM2.5, for particles less than 2.5 microns in diameter. Motor vehicles are the primary generators of particulates, through tailpipe emissions as well as brake pad, tire wear, and entrained road dust. Wood burning in fireplaces and stoves, industrial facilities, and ground-disturbing activities such as construction are other sources of such fine particulates. These fine particulates are small enough to be inhaled into the deepest parts of the human lung and can cause adverse health effects. According to the California Air Resources Board (CARB), studies in the United States and elsewhere have demonstrated a strong link between elevated particulate levels and premature deaths, hospital admissions, emergency room visits, and asthma attacks, and studies of children’s health in California have demonstrated that particle pollution may significantly reduce lung function growth in children.2 Statewide attainment of particulate matter standards could reduce premature deaths, hospital admissions for cardiovascular and respiratory disease, asthma-related emergency room visits, and episodes of respiratory illness in California.

Nitrogen Dioxide. NO2 is a reddish brown gas that is a byproduct of combustion processes.

Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to ozone formation, NO2 also contributes to other pollution problems, including a high concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases lung function and may reduce resistance to infection.

2 California Air Resources Board (CARB). 2025. Inhalable Particulate Matter and Health (PM2.5 and PM10).

Website: ww2.arb.ca.gov/resources/inhalable-particulate-matter-and-health (accessed May 2025).

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Sulfur Dioxide. SO2 is a colorless acidic gas with a strong odor. It is produced by the combustion of sulfur-containing fuels such as oil, coal, and diesel. SO2 has the potential to damage materials and can cause health effects at high concentrations. It can irritate lung tissue and increase the risk of acute and chronic respiratory disease. SO2 also reduces visibility and the level of sunlight at the ground surface.

Lead. Lead is a metal found naturally in the environment as well as in manufactured products. The major sources of lead emissions have historically been mobile and industrial sources. As a result of the phase-out of leaded gasoline, metal processing is currently the primary source of lead emissions.

The highest levels of lead in air are generally found near lead smelters. Other stationary sources are waste incinerators, utilities, and lead-acid battery factories.

Twenty years ago, mobile sources were the main contributor to ambient lead concentrations in the air. In the early 1970s, the United States Environmental Protection Agency (EPA) established national regulations to gradually reduce the lead content in gasoline. In 1975, unleaded gasoline was introduced for motor vehicles equipped with catalytic converters. The EPA banned the use of leaded gasoline in highway vehicles in December 1995. As a result of EPA regulatory efforts to remove lead from gasoline, emissions of lead from the transportation sector and levels of lead in the air decreased dramatically.

Toxic Air Contaminants. In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of pollutants of concern. Some examples of TACs include:
benzene, butadiene, formaldehyde, and hydrogen sulfide. Potential human health effects of TACs include birth defects, neurological damage, cancer, and death. There are hundreds of different types of TACs with varying degrees of toxicity. Individual TACs vary greatly in the health risk they present; at a given level of exposure, one TAC may pose a hazard that is many times greater than another.

TACs do not have ambient air quality standards, but are regulated by the EPA, CARB, and the SJVAPCD. In 1998, the CARB identified particulate matter from diesel-fueled engines as a TAC. The CARB has completed a risk management process that identified potential cancer risks for a range of activities and land uses that are characterized by use of diesel-fueled engines.3 High volume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic (distribution centers, truck stops) were identified as posing the highest risk to adjacent receptors.

Other facilities associated with increased risk include warehouse distribution centers, large retail or industrial facilities, high volume transit centers, and schools with a high volume of bus traffic. Health risks from TACs are a function of both concentration and duration of exposure.

Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate matter is emitted from mobile sources—primarily “off-road” sources such as construction and mining equipment, agricultural equipment, and truck-mounted refrigeration units, as well as trucks and buses traveling on freeways and local roadways.

The CARB Diesel Risk Reduction Plan is intended to substantially reduce diesel particulate matter emissions and associated health risks through introduction of ultra-low-sulfur diesel fuel—a step

3 California Air Resources Board (CARB). 2000. Diesel Risk Reduction Plan. September. Website:
https://ww2.arb.ca.gov/our-work/programs/diesel-risk-reduction-plan (accessed May 2025).

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already implemented—and cleaner-burning diesel engines.4 The technology for reducing diesel particulate matter emissions from heavy-duty trucks is well established, and both State and federal agencies are moving aggressively to regulate engines and emission control systems to reduce and remediate diesel emissions.

High Volume Roadways. Air pollutant exposures and their associated health burdens vary considerably within places in relation to sources of air pollution. Motor vehicle traffic is perhaps the most important source of intra-urban spatial variation in air pollution concentrations. Air quality research consistently demonstrates that pollutant levels are substantially higher near freeways and busy roadways, and human health studies have consistently demonstrated that children living within 100 to 200 meters (328 to 656 feet) of freeways or busy roadways have reduced lung function and higher rates of respiratory disease. At present, it is not possible to attribute the effects of roadway proximity on non-cancer health effects to one or more specific vehicle types or vehicle pollutants. Engine exhaust, from diesel, gasoline, and other combustion engines, is a complex mixture of particles and gases, with collective and individual toxicological characteristics.

Valley Fever. Valley fever is a fungal infection caused by coccidioides organisms. It can cause fever, chest pain and coughing, among other signs and symptoms. The coccidioides species of fungi that cause valley fever are commonly found in the soil in certain areas. These fungi can be stirred into the air by anything that disrupts the soil, such as farming, construction and wind. The fungi can then be breathed into the lungs and cause valley fever, also known as acute coccidioidomycosis. A mild case of valley fever usually goes away on its own. In more severe cases of valley fever, doctors prescribe antifungal medications that can treat the underlying infection. Valley Fever is not contagious and therefore does not spread from person to person. Most cases (approximately 60 percent) have no symptoms or only very mild flu-like symptoms and do not see a doctor. When symptoms are present, the most common are fatigue, cough, fever, profuse sweating at night, loss of appetite, chest pain, generalized muscle and joint aches particularly of the ankles and knees.

There may also be a rash that resembles measles or hives but develops more often as tender red bumps on the shins or forearms.

4.3.1.3 National and State Ambient Air Quality Standards Both State and federal governments have established health-based ambient air quality standards for criteria air pollutants. Criteria pollutants are defined as those pollutants for which the federal and State governments have established ambient air quality standards, or criteria, for outdoor concentrations in order to protect public health.

Both the EPA and the CARB have established ambient air quality standards for the following com- mon pollutants: CO, O3, NO2, SO2, Pb, and suspended particulate matter. In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin

4 California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October. Prepared by the Stationary Source Division and Mobile Source Control Division. Website: https://ww2.arb.ca.gov/sites/default/files/classic/diesel/documents/ rrpfinal.pdf (accessed May 2025).

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of safety. These ambient air quality standards are levels of contaminants that avoid specific adverse health effects associated with each pollutant.

Federal standards include both primary and secondary standards. Primary standards establish limits to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, and damage to animals, crops, vegetation, and buildings.5 State and federal standards for the criteria air pollutants are listed in Table 4.3.B.

4.3.1.4 Existing Climate and Air Quality
The following provides a discussion of the local and regional air quality and climate in the project area.

Regional and Local Air Quality. Air quality is a function of both local climate and local sources of air pollution. The amount of a given pollutant in the atmosphere is determined by the amount of the pollutant released and the atmosphere's ability to transport and dilute the pollutant. The major determinants of transport and dilution are wind, atmospheric stability, terrain, and for photochemical pollutants, sunshine.The project site is within the SJVAB and is under the jurisdiction of the SJVAPCD. A region’s topographic features have a direct correlation with air pollution flow and therefore are used to determine the boundary of air basins. The SJVAB is composed of approximately 25,000 square miles and covers eight counties including Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, Tulare, and the western portion of Kern. The SJVAB is defined by the Sierra Nevada in the east (8,000 to more than 14,000 feet in elevation), the Coast Ranges in the west (averaging 3,000 feet in elevation), and the Tehachapis in the south (6,000 to 8,000 feet in elevation). The valley is basically flat with a slight downward gradient to the northwest. The valley opens to the sea at the Carquinez Strait, where the Sacramento-San Joaquin River Delta empties into San Francisco Bay. An aerial view of the SJVAB would simulate a “bowl” opening only to the north. These topographic features restrict air movement through and out of the SJVAB.

Although marine air generally flows into the SJVAB from the Sacramento-San Joaquin River Delta, the Coast Range hinders wind access into the SJVAB from the west, the Tehachapis prevent southern passage of air flow, and the high Sierra Nevada range is a significant barrier to the east.

These topographic features result in weak air flow, which becomes blocked vertically by high barometric pressure over the SJVAB. As a result, the SJVAB is highly susceptible to pollutant accumulation over time. Most of the surrounding mountains are above the normal height of summer inversion layers (1,500 to 3,000 feet).

5 United States Environmental Protection Agency (EPA). 2017. Criteria Air Pollutants. October. Website:
www.epa.gov/criteria-air-pollutants (accessed May 2025).

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Table 4.3.B: Federal and State Ambient Air Quality Standards Pollutant Averaging
Time
California Standards 1 Federal Standards 2
Concentration 3 Method 4 Primary 3,5 Secondary 3,6 Method 7 Ozone
(O3)8
1-Hour 0.09 ppm
(180 μg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8-Hour 0.07 ppm
(137 μg/m3)

0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)9
24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μg/m3 Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 μg/m3 –
Fine
Particulate
Matter
(PM2.5)9
24-Hour – 35 μg/m3 Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 μg/m3 Gravimetric or Beta
Attenuation 12.0 μg/m3
Carbon
Monoxide
(CO)
8-Hour 9.0 ppm
(10 mg/m3) Non-Dispersive
Infrared
Photometry
(NDIR)
9 ppm
(10 mg/m3) – Non-Dispersive
Infrared
Photometry
(NDIR)
1-Hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8-Hour
(Lake Tahoe)
6 ppm
(7 mg/m3) – –
Nitrogen
Dioxide
(NO2)10
Annual
Arithmetic
Mean

0.03 ppm
(57 μg/m3) Gas Phase
Chemi-
luminescence
53 ppb
(100 μg/m3)
Same as
Primary
Standard
Gas Phase
Chemi-
luminescence 1-Hour 0.18 ppm
(339 μg/m3)
100 ppb
(188 μg/m3) –
Lead
(Pb)12,13
30-Day
Average 1.5 μg/m3
Atomic
Absorption
– – High-Volume
Sampler and
Atomic
Absorption
Calendar
Quarter – 1.5 μg/m3
(for certain areas)l Same as
Primary
Standard Rolling 3-Month
Average i – 0.15 μg/m3
Sulfur
Dioxide
(SO2)11
24-Hour 0.04 ppm
(105 μg/m3)
Ultraviolet
Fluorescence

0.14 ppm
(for certain areas) –
Ultraviolet
Fluorescence;
Spectro-
photometry
(Pararosaniline
Method)
3-Hour – – 0.5 ppm
(1300 μg/m3)
1-Hour 0.25 ppm
(655 μg/m3)
75 ppb
(196 μg/m3)11 –
Annual
Arithmetic
Mean
–

0.030 ppm
(for certain
areas)11
–
Visibility-
Reducing
Particles 12
8-Hour See footnote 14
Beta Attenuation
and Transmittance
through Filter Tape No

Federal

Standards

Sulfates 24-Hour 25 μg/m3 Ion
Chromatography
Hydrogen
Sulfide 1-Hour 0.03 ppm
(42 μg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride 10 24-Hour 0.01 ppm
(26 μg/m3)
Gas
Chromatography
Source: Ambient Air Quality Standards (California Air Resources Board 2016).

Table notes continued on the following page

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1 California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2 National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded m ore than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the st andard.

Contact EPA for further clarification and current national policies. 3 Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a re ference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of polluta nt per mole of gas.
4 Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near th e level of the air quality standard may be used.
5 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public heal th. 6 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
7 Reference method as described by the EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the EPA. 8 On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. 9 On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing national 24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. 10 To attain the 1-hour national standard, the three-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb).

California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 pp m. 11 On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the three-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm).

To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
12 The CARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for adverse h ealth effects determined. These actions allow for the implementation of control measures at levels below the ambient concentration s specified for these pollutants.
13 The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
14 In 1989, the CARB converted both the general Statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the Statewide and Lake Tahoe Air Basin standards, respectively.
C = degrees Celsius
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
ppb = parts per billion
ppm = parts per million
EPA = United States Environmental Protection Agency

Local climatological effects, including wind speed and direction, temperature, inversion layers, precipitation and fog, can exacerbate the air quality in the SJVAB. Wind speed and direction play an important role in dispersion and transport of air pollutants. Wind at the surface and aloft can

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disperse pollution by mixing vertically and by transporting it to other locations. For example, in the summer, wind usually originates at the north end of the SJVAB and flows in a south-southeastern direction through the SJVAB, through Tehachapi Pass, into the Southeast Desert Air Basin. In the winter, the wind direction reverses and flows in a north-northwestern direction. In addition to the seasonal wind flow, a sea breeze flows into SJVAB during the day and a land breeze flowing out of the SJVAB at night. The diversified wind flow enhances the pollutant transport capability within SJVAB.

The annual average temperature varies throughout the SJVAB, ranging from the low 40s to high 90s, measured in degrees Fahrenheit (F). With a more pronounced valley influence, inland areas show more variability in annual minimum and maximum temperatures than coastal areas. Temperature data from the Fresno Yosemite International Airport Station (043257), a climatological station within the project area, was assessed to find representative temperature levels for the project area. The monthly average maximum temperature recorded at this station from January 1948 to June 2016 ranged from 54.6F in January to 98.3F in July, with an annual average maximum of 76.5F. The monthly average minimum temperature recorded at this station ranged from 35.3F in December to

65.7F in July, with an annual average minimum of 50.4F.6 January and December are typically the coldest months and July is typically the warmest month in this area of the SJVAB.

The majority of annual rainfall in the SJVAB occurs between November and March. Summer rainfall is minimal and is generally limited to scattered thundershowers in desert regions and slightly heavier showers near the lower portion of the SJVAB and along the Sierra Nevada to the east.

Average monthly rainfall during that period varied from 0.01 inch in July and August to 2.09 inches in January, with an annual total of 10.89 inches.7 Patterns in monthly and yearly rainfall totals are predictable due to the recognizable differences in seasons within the valley.

The vertical dispersion of air pollutants in the SJVAB is limited by the presence of persistent temperature inversions. Because of cooling of the atmosphere, air temperature usually decreases with altitude. A reversal of this atmospheric state, where the air temperature increases with height, is termed an inversion. Inversions can exist at the surface, or at any height above the ground. The height of the base of the inversion is known as the “mixing height”. This is the level within which pollutants can mix vertically. Air above and below the inversion base does not mix because of the differences in air density. Semi-permanent systems of high barometric pressure fronts frequently establish themselves over the SJVAB, preventing low-pressure systems that might otherwise bring rain and winds that clean the air.

Inversion layers are significant in determining ozone formation and CO and PM10 concentrations.

Ozone and its precursors will mix and react to produce higher ozone concentrations under an inversion. The inversion will also simultaneously trap and hold directly emitted pollutants such as

6 Western Regional Climate Center. n.d. Fresno Yosemite International Airport (043257), Period of Record Monthly Climate Summary. Website: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca3257 (accessed May 2025).
7 Western Regional Climate Center. n.d. Fresno Yosemite International Airport (043257), Period of Record Monthly Climate Summary. Website: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca3257 (accessed May 2025).

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carbon monoxide. PM10 is both directly emitted and created in the atmosphere as a chemical reaction. Concentration levels of pollutants are directly related to inversion layers due to the limitation of mixing space.

Surface or radiation inversions form when the ground surface becomes cooler than the air above it during the night. The Earth’s surface goes through a radiative process on clear nights, where heat energy transfers from the ground to a cooler night sky. As the Earth’s surface cools during the evening hours, the air directly above it also cools, while air higher up remains relatively warm. The inversion is destroyed when heat from the sun warms the ground, which in turn heats the lower layers of air; this heating stimulates the ground level air to float up through the inversion layer.

The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are lowest. Periods of low inversions and low wind speeds are conditions favorable to high concentrations of CO and PM10. In the winter, the greatest pollution problems are CO and NOX because of extremely low inversions and air stagnation during the night and early morning hours. In the summer, the longer daylight hours and the brighter sunshine combine to cause a reaction between hydrocarbons and oxides of nitrogen to form photochemical smog.

Attainment Status. The EPA and the CARB designate air basins where ambient air quality standards are exceeded as “nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data to make a definitive attainment designation, they are considered “unclassified.”National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards. Each standard has a different definition, or “form” of what constitutes attainment, based on specific air quality statistics. For example, the federal 8-hour CO standard is not to be exceeded more than once per year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air monitoring value exceeds the threshold per year. In contrast, the federal annual PM2.5 standard is met if the 3-year average of the annual average PM2.5 concentration is less than or equal to the standard. Table 4.3.C shows the current attainment designations for the SJVAB.

Table 4.3.C: San Joaquin Valley Air Basin Air Quality Attainment Status Pollutant State Federal
Ozone (1-hour) Severe/Nonattainment Not Applicable
Ozone (8-hour) Nonattainment Extreme Nonattainment
PM10 Nonattainment Attainment (Maintenance)
PM2.5 Nonattainment Nonattainment
Carbon Monoxide Attainment Attainment (Maintenance)
Nitrogen Dioxide Attainment Unclassified/Attainment
Lead Attainment Unclassified/Attainment
Sulfur Dioxide Attainment Unclassified
Sulfates Attainment No Federal Standard
Hydrogen Sulfide Unclassified No Federal Standard
Source: Ambient Air Quality Standards & Attainment Status - San Joaquin Valley Attainment Status.(San Joaquin Valley Air Pollution Control District, n.d.).

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Air Quality Monitoring Results. Air quality monitoring stations are located throughout the nation and maintained by the local air pollution control district and state air quality regulating agencies.

Ambient air data collected at permanent monitoring stations are used by the EPA to identify regions as attainment or nonattainment depending on whether the regions met the requirements stated in the primary National Ambient Air Quality Standards (NAAQS). Attainment areas are required to maintain their status through moderate, yet effective air quality maintenance plans. Nonattainment areas are imposed with additional restrictions as required by the EPA. In addition, different classifications of attainment such as marginal, moderate, serious, severe, and extreme are used to classify each air basin in the state on a pollutant-by-pollutant basis. Different classifications have different mandated attainment dates and are used as guidelines to create air quality management strategies to improve air quality and comply with the NAAQS by the attainment date. A region is determined to be unclassified when the data collected from the air quality monitoring stations do not support a designation of attainment or nonattainment, due to lack of information, or a conclusion cannot be made with the available data.

The SJVAPCD, together with CARB, maintains ambient air quality monitoring stations in the SJVAB.

The air quality monitoring stations closest to the project site are the stations at 4706 East Drummond Street in Fresno, 2482 Foundry Park Avenue in Fresno, and 3727 North First Street in Fresno.

Pollutant monitoring results for years 2020 to 2022 at the Fresno monitoring stations, shown in Table 4.3.D, indicate that air quality in Fresno has generally been moderate. As indicated in the monitoring results, the federal PM10 standard was exceeded once in 2020 and an unknown number of times in 2021 and 2022. The State PM10 standard was exceeded 25 times in 2020, 20 times in 2021, and 133 times in 2022. The federal PM2.5 standard had 48 exceedances in 2020, 36 exceedances in 2021, and 21 exceedances in 2022. The State 1-hour ozone standards were exceeded 11 times in 2020, 9 times in 2021, and 3 times in 2022. The State 8-hour ozone standards were exceeded 27 times in 2020, 41 times in 2021, and 8 times in 2022. The federal 8-hour standards were exceeded 27 times in 2020, 39 times in 2021, and 8 times in 2022. The CO, SO2, and NO2 standards were not exceeded in this area during the 3-year period.

Table 4.3.D: Ambient Air Quality in the Project Vicinity Pollutant Standard 2020 2021 2022
Carbon Monoxide (CO)1
Maximum 1-hour concentration (ppm) 2.3 2.6 3.4
Number of days exceeded: State: > 20 ppm 0 0 0
Federal: > 35 ppm 0 0 0
Maximum 8-hour concentration (ppm) 2.0 2.2 2.5
Number of days exceeded: State: > 9 ppm 0 0 0
Federal: > 9 ppm 0 0 0
Ozone (O3)2
Maximum 1-hour concentration (ppm) 0.123 0.125 0.111
Number of days exceeded: State: > 0.09 ppm 11 9 3
Maximum 8-hour concentration (ppm) 0.092 0.100 0.089
Number of days exceeded: State: > 0.07 ppm 27 41 8
Federal: > 0.07 ppm 27 39 8

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Table 4.3.D: Ambient Air Quality in the Project Vicinity Pollutant Standard 2020 2021 2022
Coarse Particulates (PM10)2
Maximum 24-hour concentration (µg/m3) 350.4 151.8 166.4 Number of days exceeded: State: > 50 µg/m3 25 20 133
Federal: > 150 µg/m3 1 ND ND
Annual arithmetic average concentration (µg/m3) 59.9 43.8 31.2 Exceeded for the year: State: > 20 µg/m3 Yes Yes Yes
Federal: > 50 µg/m3 Yes No No
Fine Particulates (PM2.5)1
Maximum 24-hour concentration (µg/m3) 157.2 85.2 54.6
Number of days exceeded: Federal: > 35 µg/m3 48 36 21
Annual arithmetic average concentration (µg/m3) 20.3 17.2 14.8 Exceeded for the year: State: > 12 µg/m3 Yes Yes Yes
Federal: > 9 µg/m3 Yes Yes Yes
Nitrogen Dioxide (NO2)2
Maximum 1-hour concentration (ppm) 0.067 0.065 0.058
Number of days exceeded: State: > 0.250 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.013 0.011 0.012 Exceeded for the year: Federal: > 0.053 ppm No No No
Sulfur Dioxide (SO2)3
Maximum 1-hour concentration (ppm) 0.0162 0.0075 0.0034 Number of days exceeded: State: > 0.25 ppm 0 0 0
Maximum 24-hour concentration (ppm) 0.0022 0.0027 0.0012 Number of days exceeded: State: > 0.04 ppm 0 0 0
Federal: > 0.14 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.00046 0.00043 0.00034 Exceeded for the year: Federal: > 0.030 ppm No No No
Sources: CARB (2023) and EPA (2024).
1 Data taken from the 4706 East Drummond Street Monitoring Station. 2 Data taken form the 2482 Foundry Park Avenue Monitoring Station. 2 Data taken form the 3727 North First Street Monitoring Station. µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value. ppm = parts per million
EPA = United States Environmental Protection Agency

Toxic Air Contaminant Trends. In 1984, the CARB adopted regulations to reduce TAC emissions from mobile and stationary sources, as well as consumer products. A CARB study showed that ambient concentrations and emissions of the seven TACs responsible for the most cancer risk from airborne exposure declined by 76 percent between 1990 and 2012.8 Concentrations of DPM, a key TAC, declined by 68 percent between 1990 and 2012, despite a 31 percent increase in State population and an 81 percent increase in diesel vehicle miles traveled (VMT), as shown on Figure 4.3-1, below.

8 Propper, Ralph, Patrick Wong, Son Bui, Jeff Austin, William Vance, Álvaro Alvarado, Bart Croes, and Dongmin Luo. 2015. Ambient and Emission Trends of Toxic Air Contaminants in California. American Chemical Society: Environmental Science & Technology. Website: https://pubs.acs.org/doi/epdf/10.1021/ acs.est.5b02766?ref=article_openPDF (accessed May 2025).

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The study also found that the significant reductions in cancer risk to California residents from the implementation of air toxics controls are likely to continue.

Source: Ambient and Emission Trends of Toxic Air Contaminants in California (Propper, Ralph, et al. 2015).

Figure 4.3-1: California Population, Gross State Product (GSP), Diesel Cancer Risk, and Diesel Vehicle Miles Traveled (VMT) Regulatory Context

4.3.2 Regulatory Setting
The EPA and the CARB regulate direct emissions from motor vehicles. The SJVAPCD is the regional agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as monitoring ambient pollutant concentrations.

The following discusses the applicable federal, State, regional, and local regulatory framework.

4.3.2.1 Federal Policies and Regulations
Federal Clean Air Act.At the federal level, the EPA has been charged with implementing national air quality programs. The EPA air quality mandates are drawn primarily from the federal Clean Air Act (FCAA), which was enacted in 1963. The FCAA was amended in 1970, 1977, and 1990.

The FCAA required the EPA to establish primary and secondary NAAQS and required each state to prepare an air quality control plan referred to as a State Implementation Plan (SIP). The FCAA Amendments of 1990 added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins as reported by their jurisdictional agencies. The EPA has responsibility to review all state SIPs to determine conformity with the mandates of the FCAA and determine if implementation will

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achieve air quality goals. If the EPA determines a SIP to be inadequate, a Federal Implementation Plan (FIP) may be prepared for the nonattainment area, which imposes additional control measures.

Failure to submit an approvable SIP or to implement the plan within the mandated timeframe may result in sanctions on transportation funding and stationary air pollution sources in the air basin.

The EPA is also required to develop National Emission Standards for Hazardous Air Pollutants, which are defined as those which may reasonably be anticipated to result in increased deaths or serious illness, and which are not already regulated. An independent science advisory board reviews the health and exposure analyses conducted by the EPA on suspected hazardous pollutants prior to regulatory development.

4.3.2.2 State Policies and Regulations
The CARB is the lead agency for implementing air quality regulations in the State. Key efforts by the State are described below.

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

The CARB has been given authority to regulate many sources that would normally be pre-empted by federal regulations through the issuance of waivers.

Pursuant to these authorities, CARB has adopted the world’s most stringent standards for passenger cars, light-duty trucks, and medium-duty vehicles. CARB has also adopted regulations establishing standards for heavy-duty vehicles, offroad vehicles and engines, offroad recreational vehicles, off-road diesel engines and equipment, offroad gasoline and liquefied petroleum gas engines and equipment, and marine pleasure craft. Descriptions of these regulations are provided below.

Low-Emission Vehicle Program.The CARB first adopted low‐emission vehicle (LEV) program standards in 1990. These first LEV standards ran from 1994 through 2003. LEV II regulations, running from 2004 through 2010, represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 State Implementation Plan (SIP). In 2012, CARB adopted the LEV III amendments to California’s LEV regulations. These amendments include more stringent emission standards for both criteria pollutants and greenhouse gases for new passenger vehicles.On-Road Heavy-Duty Vehicle Program. The CARB has adopted standards for emissions from various types of new on‐road heavy‐

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duty vehicles. Section 1956.8, Title 13, California Code of Regulations contains California’s emission standards for on‐road heavy‐duty engines and vehicles, and test procedures.9 CARB has also adopted programs to reduce emissions from in‐use heavy‐duty vehicles including the Heavy‐Duty Diesel Vehicle Idling Reduction Program, the Heavy‐Duty Diesel In‐Use Compliance Program, the Public Bus Fleet Rule and Engine Standards, and the School Bus Program and others.In addition, the CARB’s Truck and Bus regulation was established to meet federal attainment standards. This regulation requires heavy-duty diesel vehicles that operate in California to reduce TAC emissions from their exhaust. Diesel exhaust is responsible for 70 percent of the cancer risk from airborne toxics. Therefore, by January 1, 2023, nearly all trucks and buses were required to have 2010 or newer model year engines to reduce PM and NOx emissions. To help ensure that the benefits of this regulation are achieved, starting in 2020, only vehicles compliant with this regulation will be registered by the California Department of Motor Vehicles.10 Air Quality Land Use Handbook.The CARB has developed an Air Quality and Land Use Handbook11 (CARB Handbook), which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision- making process. According to the CARB Handbook, recent air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies strongly consider proximity to these sources when finding new locations for “sensitive” land uses such as homes, medical facilities, daycare centers, schools and playgrounds. Land use designations with air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome-plating facilities, dry cleaners, and large gasoline service stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000 vehicles/day
• Within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week)
• Within 1,000 feet of a major service and maintenance rail yard • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries

9 California Air Resources Board. 2021. On-Road Heavy-Duty Current Standards, Test Procedures and Regulatory Documents. Website: https://ww2.arb.ca.gov/resources/documents/road-heavy-duty-current- standards-test-procedures-and-regulatory-documents (accessed May 2025). 10 California Air Resources Board. 2023. Truck and Bus Regulation. Website: https://ww2.arb.ca.gov/our- work/programs/truck-and-bus-regulation (accessed May 2025). 11 California Air Resources Board. 2005. Air Quality and Land Use Handbook: A Community Health Perspective.

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• Within 300 feet of any dry-cleaning operation (for operations with two or more machines, provide 500 feet)
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater)
The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues.

4.3.2.3 Regional Policies and Regulations
San Joaquin Valley Air Pollution Control District. The SJVAPCD is responsible for controlling emissions primarily from stationary sources. The SJVAPCD maintains air quality monitoring stations throughout the basin. The SJVAPCD, in coordination with the eight county transportation agencies, is also responsible for developing, updating, and implementing air quality attainment plans for the Air Basin. The SJVAPCD also has roles under CEQA.

Guide for Assessing and Mitigating Air Quality Impacts. The SJVAPCD provides guidance and thresholds for CEQA air quality and greenhouse gas analyses. The result of this guidance as well as State regulations to control air pollution is an overall improvement in the Basin. In particular, the SJVAPCD’s GAMAQI states:

The SJVAPCD’s Air Quality Attainment Plans include measures to promote air quality elements in county and city general plans as one of the primary means of reducing indirect emissions such as those from land use development projects. The approved General Plan is the primary long range planning document used by cities and counties to direct development. Since air districts have no authority over land use decisions, it is up to cities and counties to ensure that their general plans help achieve air quality goals. Section 65302.1 of the California Government Code requires cities and counties in the San Joaquin Valley to amend appropriate elements of their general plans to include data, analysis, comprehensive goals, policies, and feasible implementation strategies to improve air quality in their next housing element revisions. This was completed for Fresno County with the adoption of the Fresno County General Plan Policy Document, General Plan Update adopted October 3, 2020, which includes an air quality policy section. The City of Fresno’s General Plan includes a Resource Conservation and Resilience Element that addresses air quality and greenhouse gas emissions.

The SJVAB is classified nonattainment for ozone, PM10, and PM2.5. The SJVAPCD had adopted project level thresholds based on a cumulative contribution of ozone precursors ROG and NOx of 10 tons per year and thresholds for PM10 and PM2.5 of 15 tons per year. Although these thresholds are project-specific, a conservative interpretation of this threshold would apply the annual emission thresholds to annual emissions generated during implementation of the approved General Plan. As such, the combined annual emissions of projects during construction and operation would then be compared to the annual threshold. As mentioned, this would provide a conservative approach to assessing project-level impacts through cumulative contributions.

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Current Air Quality Plans. The SJVAPCD is responsible for formulating and implementing the Air Quality Management Plan (AQMP) for the Basin. The main purpose of an AQMP is to bring the area into compliance with federal and State air quality standards. The SJVAPCD does not have one single AQMP for criteria pollutants, rather the SJVAPCD address each criteria pollutant with its own Plan. The SJVAPCD has the following AQMPs:
• 2024 Plan for the Annual PM2.5 Standard
• 2022 Plan for the 2015 8-Hour Ozone Standard
• 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards • 2016 Moderate Area Plan for the 2012 PM2.5 standard
• 2016 Plan for the 2008 8-Hour Ozone Standard
• 2013 Plan for the Revoked 1-Hour Ozone Standard
• 2007 PM10 Maintenance Plan
• 2004 Revision to the California State Implementation Plan for Carbon Monoxide The SJVAPCD’s AQMPs incorporate the latest scientific and technological information and planning assumptions, including updated emission inventory methodologies for various source categories. The SJVAPCD’s AQMPs included the integrated strategies and measures needed to meet the NAAQS, implementation of new technology measures, and demonstrations of attainment of the 1-hour and 8-hour ozone NAAQS as well as the latest 24-hour and annual PM2.5 standards.

The SJVAPCD’s current air quality plans are discussed blow.

Ozone Plans. The SJVAPCD’s Governing Board approved the 2016 Plan for the 2008 8-Hour Ozone Standard on June 16, 2016. The comprehensive strategy in this plan will reduce NOx emissions by more than 60 percent between 2012 and 2031 and will bring the San Joaquin Valley into attainment of EPA’s 2008 8-hour ozone standard as expeditiously as practicable, no later than December 31, 2031. The SJVAPCD adopted the 2022 Plan for the 2015 8-Hour Ozone Standard on December 15, 2022 to satisfy Clean Air Act requirements and ensures expeditious attainment of the 70 parts per billion 8-hour ozone standard.

Particulate Matter Plans. The SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007 to assure the SJVAB’s continued attainment of the EPA’s PM10 standard.

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

The 2008 PM2.5 Plan builds upon the comprehensive strategy adopted in the 2007 Ozone Plan to bring the Basin into attainment of the 1997 national standards for PM2.5. The EPA has identified NOx and SO2 as precursors that must be addressed in air quality plans for the 1997 PM2.5 standards. The 2008 PM2.5 Plan is a continuation of the SJVACPD’s strategy to improve the air quality in the SJVAB.

The SJVAPCD prepared the 2012 PM2.5 Plan to bring the San Joaquin Valley into attainment of the EPA’s most recent 24‐hour PM2.5 standard of 35 μg/m³. The CARB approved the SJVAPCD’s 2012 PM2.5 Plan at a public hearing on January 24, 2013. The plan, approved by

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the SJVAPCD Governing Board on December 20, 2012, intended to bring the Valley into attainment of EPA’s 1997 PM2.5 standard as expeditiously as practicable, but no later than, December 31, 2020. On January 28, 2022, the EPA determined that the Valley attained the 1997 24-hour PM2.5 standard by the attainment date of December 31, 2020.

On November 15, 2018, the SJVAPCD the adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. This plan addressed the EPA federal 1997 annual PM2.5 standard of 15 μg/m³ and 24-hour PM2.5 standard of 65 μg/m³; the 2006 24-hour PM2.5 standard of 35 μg/m³; and the 2012 annual PM2.5 standard of 12 μg/m³. The 2018 plan demonstrates attainment of the federal PM2.5 standards as expeditiously as practicable. Additionally, the SJVAPCD adopted the 2024 Plan for the 2012 Annual PM2.5 Standard on June 20, 2024. This Plan addresses the EPA federal 2012 annual PM2.5 standard of 12 μg/m³.

Rules and Regulations. The SJVAPCD rules and regulations that may apply to projects that will occur during implementation of the proposed project include but are not limited to:
• Rule 2260—Registration Requirements for Equipment Subject to California’s Oil and Gas Regulation. The purpose of this rule is to provide a registration mechanism that satisfies the requirements of and will ensure compliance with California’s Oil and Gas Regulation.
• Rule 2280—Portable Equipment Registration. Portable equipment used at project sites for less than six consecutive months must be registered with the SJVAPCD. The SJVAPCD will issue the registrations 30 days after receipt of the application. • Rule 2303-Mobile Source Emission Reduction Credits. A project may qualify for SJVAPCD vehicle emission reduction credits if it meets the specific requirements of Rule 2303 for any of the following categories:
○ Low-Emission Transit Buses
○ Zero-Emission Vehicles
○ Retrofit Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles ○ Retrofit Heavy-Duty Vehicles
• Rule 3156 – Fees for Equipment Subject to Rule 2260 Registration Requirements for Equipment Subject to California’s Oil and Gas Regulation. The purpose of this rule is to recover the District’s costs of developing and maintaining an effective registration program, as required by Rule 2260 (Registration Requirements for Equipment Subject to California’s Oil and Gas Regulation).
• Rule 4102 – Nuisance. The purpose of this rule is to protect the health and safety of the public, and applies to any source operation that emits or may emit air contaminants or other materials.

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• Rule 4601 – Architectural Coatings. The purpose of this rule is to limit volatile organic compound (VOC) emissions from architectural coatings. Emissions are reduced by limits on VOC content and providing requirements on coatings storage, cleanup, and labeling. • Rule 4641 – Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations. The purpose of this rule is to limit VOC emissions from asphalt paving and maintenance operations. The paving operations for new development and existing paved surfaces will be subject to Rule 4641.
• Rule 8011—General Requirements: Fugitive Dust Emission Sources. Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, including construction operations, must control fugitive dust emissions in accordance with SJVAPCD Regulation VIII. According to Rule 8011, the SJVAPCD requires the implementation of control measures for fugitive dust emission sources. For projects in which construction-related activities would disturb equal to or greater than 1 acre of surface area, the SJVAPCD recommends that demonstration of receipt of an SJVAPCD- approved Dust Control Plan or Construction Notification Form, before issuance of the first grading permit, be made a condition of approval.
• Regulation VIII – Fugitive PM10 Prohibitions. Rules 8011‐8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk material storage, paved and unpaved roads, carryout and track out, etc. All development projects that involve soil disturbance are subject to at least one provision of the Regulation VIII series of rules.
• Rule 9410 – Employer Based Trip Reduction. The purpose of this rule is to reduce VMT from private vehicles used by employees to commute to and from their worksites to reduce emissions of NOx, VOC, and PM. The rule requires larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes. The rule uses a menu- based Employer Trip Reduction Implementation Plan and periodic reporting requirements to evaluate performance on a phased‐in compliance schedule. • Rule 9510 – Indirect Source Review. This rule reduces the impact of NOx and PM10 emissions from new development projects. The rule places application and emission reduction requirements on development projects meeting applicability criteria to reduce emissions through onsite mitigation, offsite SJVAPCD administered projects, or a combination of the two. Compliance with SJVAPCD Rule 9510 reduces emissions impacts through incorporation of onsite measures as well as payment of an offsite fee that funds emission reduction projects in the Air Basin. The emissions analysis for Rule 9510 is detailed and is dependent on the exact project design that is expected to be constructed or installed. Compliance with Rule 9510 is separate from the CEQA process, although the control measures used to comply with Rule 9510 may be used to mitigate significant air quality impacts.

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Odor impacts on residential areas and other sensitive receptors, such as hospitals, day-care centers, schools, etc., warrant the closest scrutiny, but consideration could also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas. Although offensive odors rarely cause any physical harm, they can be very unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and the SJVAPCD.

Two situations create a potential for odor impact. The first occurs when a new odor source is near an existing sensitive receptor. The second occurs when a new sensitive receptor locates near an existing source of odor. The SJVAPCD has determined the common land use types that are known to produce odors in the Basin. These types are shown in Table 4.3.E.

Table 4.3.E: Screening Levels for Potential Odor Sources Odor Generator 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: San Joaquin Valley Air Pollution Control District 2015.

Community Emissions Reductions Program: Assembly Bill 617. AB 617 requires the CARB and air districts to develop and implement a Community Emission Reduction Plan (CERP) with additional emissions reporting, monitoring, and reduction plans and measures in an effort to reduce air pollution exposure in disadvantaged communities. Given that 20 of the 30 most disadvantaged communities in California are in the San Joaquin Valley, this process is expected to bring additional clean air resources and strategies to many Valley communities.

South Central Fresno and the City of Shafter are the first Valley communities selected by the California Air Resources Board for investment of additional resources under AB 617. The SJVAPCD has established a steering committee for each of these communities comprising community residents, businesses, community advocates, and government representatives to assist in the development and implementation of community air monitoring and emission reduction programs.

Fresno’s CERP was adopted by CARB and is now in the implementation phase.

The South Central Fresno CERP identifies sources of pollution that are of particular concern to the community and possible strategies for reducing pollution impacts from these sources, including incentive funding measures, public engagement strategies, enforcement strategies, regulatory strategies, and strategies that will be completed in partnership with other agencies and local

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organizations. The CERP anticipates investing $44.3 million in emission reduction incentives for cleaner cars and trucks, and a variety of other clean air projects in the South Central Fresno area.

Additional measures have been developed as part of the CERP to reduce exposure to air pollution for sensitive receptors, including schools and residences. These efforts are projected to achieve approximately 278 tons of PM2.5 reductions and 1,662 tons of NOx reductions as well as significant reductions in air toxics emissions in the community, particularly with respect to diesel particulate matter from mobile sources, the main contributor to community air toxics health risk.

Fresno Council of Governments. Fresno Council of Governments (FCOG) is responsible for regional transportation planning in Fresno county and participates in developing mobile source emission inventories used in air quality attainment plans.

Regional Transportation Plan/Sustainable Communities Strategy. Regional Transportation Plans (RTPs) are State-mandated plans that identify long-term transportation needs for a region’s transportation network. Fresno Council of Governments’ (Fresno COG) 2022 RTP charts the long‐range vision of regional transportation in Fresno county through the year 2046. The RTP identifies existing and future transportation related needs, while considering all modes of travel, analyzing alternative solutions, and identifying priorities for the anticipated available funding for the 1,100 projects and multiple programs included within it. Senate Bill 375 (SB 375), which went into effect in 2009, added statutes to the California Government Code to encourage planning practices that create sustainable communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every four years. The SCS is intended to show how integrated land use and transportation planning can lead to lower greenhouse gas (GHG) emissions from autos and light trucks. Fresno COG has included the SCS in its 2022 RTP.

Transportation Conformity. FCOG must ensure that transportation plans and projects comply with Federal Transportation Conformity. Transportation conformity is a way to ensure that Federal funding and approval are given to those transportation activities that are consistent with air quality goals. It ensures that these transportation activities do not worsen air quality or interfere with the "purpose" of the State Implementation Plan, which is to meet the NAAQS.

Meeting the NAAQS often requires emissions reductions from mobile sources. According to the Clean Air Act, transportation plans, programs, and projects cannot:
• Create new NAAQS violations;
• Increase the frequency or severity of existing NAAQS violations; or • Delay attainment of the NAAQS.

In practice, air quality plans include criteria pollutant emission budgets required for attainment of air quality standards by mandated deadlines. The budgets must not be exceeded considering projected growth in mobile source activity. The FCOG 2019 Conformity Analysis determined that the conformity tests for ozone, PM10 and PM2.5 revealed that all years are projected to be less than the approved emissions budgets and, as such, the conformity tests are satisfied.

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4.3.2.4 Local Policies and Regulations
City of Fresno General Plan. The City of Fresno’s General Plan Resources Conservation and Resilience Element includes objectives and policies that work to achieve and maintain compliance with State and federal air quality standards for criteria pollutants. Several additional General Plan elements include objectives and policies that foster reduction in vehicle miles traveled and commensurate reductions in criteria pollutants as well as greenhouse gas emissions. The following General Plan goals and policies would be applicable to the proposed project:

Urban Form, Land Use, and Design Element
Policy UF-12-e: Access to Activity Centers. Promote adoption and implementation of standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers.

Objective UF‐14: Create an urban form that facilitates multi-modal connectivity.

Commentary: Multi-modal connectivity creates the opportunity for people to travel through a variety of modes of transportation, including biking, walking, driving, and using public transit.

Policy UF‐14‐a: Design Guidelines for Walkability. Develop and use design guidelines and standards for a walkable and pedestrian-scaled environment with a network of streets and connections for pedestrians and bicyclists, as well as transit and autos.

Commentary: These guidelines will highlight how to achieve these design ideas and avoid barriers to access, such as:
• Walls and fences that separate related uses or isolate neighborhoods; • Over reliance on cul-de-sacs and dead end streets that cut off access within neighborhoods;
• Disconnected bike and pedestrian paths;
• Wide streets that lack pedestrian support, such as sidewalks, median strips, and a landscaped strip that separates pedestrians from the street; • Street front parking lots that separate pedestrian from commercial operations; • Retail centers that are exclusively auto-oriented;
• Transit stops that are not easily accessible from an individual’s starting point and destination; and
• Long blocks that discourage walking.

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Objective LU‐2: Plan for infill development that includes a range of housing types, building forms, and land uses to meet the needs of both current and future residents.

Policy LU-2-a: Infill Development and Redevelopment. Promote development of vacant, underdeveloped, and re-developable land within the City Limits where urban services are available by considering the establishment and implementation of supportive regulations and programs.

Policy LU‐8‐b: Access to Public Facilities. Ensure that major public facilities and institutions have adequate multi-modal access and can be easily reached by public transit.

Resource Conservation and Resilience Element
Policy RC-4-b: Conditions of Approval. Develop and incorporate air quality maintenance requirements, compatible with Air Quality Attainment and Maintenance Plans, as conditions of approval for General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals.

Policy RC-4-c: Evaluate Impacts with Models. Continue to require the use of computer models used by SJVAPCD to evaluate the air quality impacts of plans and projects that require such environmental review by the City.

Policy RC-4-f: Municipal Operations and Fleet Actions. Continue to control and reduce air pollution emissions from vehicles owned by the City and municipal operations and facilities by undertaking the following:
• Expand the use of alternative fuel, electric, and hybrid vehicles in City fleets. • Create preventive maintenance schedules that will ensure efficient engine operation. • Include air conditioning recycling and charging stations in the City vehicle maintenance facilities, to reduce Freon gases being released into the atmosphere and electrostatic filtering systems in City maintenance shops, when feasible or when required by health regulations.
• Use satellite corporation yards for decentralized storage and vehicle maintenance. • Convert City-owned emergency backup generators to natural gas fuels whenever possible, and create an advanced energy storage system.

Policy RC-4-g: FAX Actions. Continue to improve Fresno Area Express (FAX) bus transit system technical performance, reduce emission levels, streamline system operations, and implement BRT where supportive land uses are proposed by Figure LU-1: Land Use Diagram.

Objective RC‐8: Reduce the consumption of non-renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources.

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Policy RC-8-c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by fifteen percent.

Mobility and Transportation Element.

Objective MT‐1: Create and maintain a transportation system that is safe, efficient, provides access in an equitable manner, and optimizes travel by all modes.

Policy MT‐1-a: Transportation Planning Consistent with the General Plan. Continue to review local, regional and inter-regional transportation plans and capital improvement plans, and advocate for the approval and funding of State highway and rail projects, consistent with the General Plan and discourage projects inconsistent with the General Plan.

Policy MT-1-g: Complete Streets Concept Implementation. Provide transportation facilities based upon a Complete Streets concept that facilitates the balanced use of all viable travel modes (pedestrians, bicyclists, motor vehicle and transit users), meeting the transportation needs of all ages, income groups, and abilities and providing mobility for a variety of trip purposes, while also supporting other City goals.

Implementation actions will include:
• Meeting the needs of all users within the street system as a whole; each individual street does not need to provide all modes of travel, but travel by all modes must be accommodated throughout the Planning Area;
• Continuing to adopt refined street cross-section standards as appropriate in response to needs identified;
• Encouraging conversion of one-way streets to two-way streets to improve location circulation, access, and safety;
• Considering the impact of streets on public health by addressing storm water runoff quality, air quality, and water conservation among other factors; and • Adhering to the water efficient landscape standards adopted by the City for median and streetscape plantings and irrigation methods.

Policy MT-1-j: Transportation Improvements Consistent with Community Character.

Prioritize transportation improvements that are consistent with the character of surrounding neighborhoods and supportive of safe, functional and Complete Neighborhoods; minimize negative impacts upon sensitive land uses such as residences, hospitals, schools, natural habitats, open space areas, and historic and cultural resources. • In implementing this policy, the City will design improvements to:

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• Facilitate provision of multi-modal transportation opportunities; • Provide added safety, including appropriate traffic calming measures; • Promote achievement of air quality standards;
• Provide capacity in a cost effective manner; and
• Create improved and equitable access with increased efficiency and connectivity.

Objective MT‐4: Establish and maintain a continuous, safe, and easily accessible bikeways system throughout the metropolitan area to reduce vehicle use, improve air quality and the quality of life, and provide public health benefits.

Policy MT-4-b: Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right- of-way and that necessary improvements are constructed to implement the planned bikeway system shown on Figure MT-2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right-of-way is available.

Policy MT-4-c: Bikeway Linkages. Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible.

Policy MT-4-d: Prioritization of Bikeway Improvements. Prioritize bikeway components that link existing separated sections of the system, or that are likely to serve the highest concentration of existing or potential cyclists, particularly in those neighborhoods with low vehicle ownership rates, or that are likely to serve destination areas with the highest demand such as schools, shopping areas, recreational and park areas, and employment centers.

Policy MT-4-e: Minimum Bike Lane Widths. Provide not less than 10 feet of street width (five feet for each travel direction) to implement bike lanes for designated Class II bikeways along roadways. Strive for 14 feet of street width (seven feet for each travel direction) for curbside bike lanes where right-of-way is available.

Policy MT-4-i: Bicycling and Public Transportation. Promote the integration of bicycling with other forms of transportation, including public transit. Continue to provide bike racks or space for bicycles on FAX buses.

Objective MT‐5: Establish a well-integrated network of pedestrian facilities to accommodate safe, convenient, practical, and inviting travel by walking, including for those with physical mobility and vision impairments.

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Policy MT-5-a: Sidewalk Development. Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in established neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes.

Policy MT-5-b: Sidewalk Requirements. Assure adequate access for pedestrians and people with disabilities in new residential developments per adopted City policies, consistent with the California Building Code and the Americans with Disabilities Act.

Policy MT-5-d: Pedestrian Safety. Minimize vehicular and pedestrian conflicts on both major and non-roadways through implementation of traffic access design and control standards addressing street intersections, median island openings and access driveways to facilitate accessibility while reducing congestion and increasing safety. Increase safety and accessibility for pedestrians with vision disabilities through the installation of Accessible Pedestrian Signals at signalized intersections.

Objective MT-6: Establish a network of multi-purpose pedestrian and bicycle paths, as well as limited access trails, to link residential areas to local and regional open spaces and recreation areas and urban Activity Centers in order to enhance Fresno's recreational amenities and alternative transportation options.

Policy MT-6-g: Path and Trail Development. Require all projects to incorporate planned multi-purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case-by-case determinations as a condition of project approval.

Commentary: This should be done pursuant to Figure MT-2: Paths and Trails, and the adopted ATP, as may amended.

Policy MT-6-i: Path and Trail Design Standards. Designate and design paths and trails in accordance with design standards established by the City that give consideration to all path and trail users (consistent with design, terrain and habitat limitations) and provide for appropriate widths, surfacing, drainage, design speed, barriers, fences, signage, visibility, intersections, bridges, and street cleaning.

Commentary: Trail improvements and characteristics (e.g. accessibility, continuity, width and location, and surface treatment) within the Fancher Creek water conveyance and riparian corridor, and other alignments immediately adjacent to existing or planned residential land, will be determined by the City Council after providing for appropriate public participation.

Policy MT-6-j: Variety in Path and Trail Design. Provide for different levels and types of usable pedestrian and bicycle corridors, including broad, shaded sidewalks; jogging paths; paved and all terrain bicycle paths; through-block passageways; and hiking trails. Where a designated multi-purpose path route is adjacent to a public right-of-way which

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accommodates bike lane, allow for flexibility in path design, so that bike lanes may be substituted for the bicycle component of the multi-purpose path where it is safe and appropriate to do so.

Commentary: This should be done pursuant to Figure MT-2: Paths and Trails, and the adopted ATP, as may amended.

Policy MT-6-l: Environmentally Sensitive Path and Trail Design. Develop paths and trails with minimum environmental impact by taking the following actions:
• Surface paths and trails with materials that are conducive to maintenance and safe travel, choosing materials that blend in with the surrounding area; • Design paths and trails to follow contour lines where the least amount of grading (fewest cuts and fills) and least disturbance of the surrounding habitat will occur; • Beautify path and trail rights-of-way in a manner consistent with intended use, safety, and maintenance;
• Use landscaping to stabilize slopes, create physical or visual barriers, and provide shaded areas; and
• Preserve and incorporate native plant species into the landscaping.

Objective MT‐8: Provide public transit options that serve existing and future concentrations of residences, employment, recreation and civic uses and are feasible, efficient, safe, and minimize environmental impacts.

Commentary: Public transit services must meet accessibility standards for individuals with disabilities as required by applicable state and federal regulations.

Policy MT‐8-a: Street Design Coordinated with Transit. Coordinate the planning, design, and construction of the major roadway network with transit operators to facilitate efficient direct transit routing throughout the Planning Area.

Commentary: Neighborhoods with circuitous and discontinuous streets are more difficult for public transit to serve efficiently than those with consistently spaced linear or semi- grid patterns.

Policy MT-8-d: Coordination of Transportation Modes. Plan, design, and implement transportation system improvements promoting coordination and continuity of transportation modes and facilities, such as shared parking or park and ride facilities at Activity Centers.

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4.3.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to air quality that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less-than-significant level. Cumulative impacts are also addressed.

4.3.3.1 Significance Criteria
Based on CEQA Guidelines Appendix G, the proposed project would have a significant impact on air quality if it would:
a. 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 is nonattainment under an applicable federal or state ambient air quality standard; c. Expose sensitive receptors to substantial pollutant concentrations; or d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Regional Emissions Thresholds. A threshold of significance is defined by the SJVAPCD in its GAMAQI12 as an identifiable quantitative, qualitative, or performance level of a particular environmental effect. Non-compliance with a threshold of significance means the effect will normally be determined to be significant. Compliance with a threshold of significance means the effect normally will be determined to be less than significant. The SJVAPCD has established thresholds of significance for criteria pollutant emissions generated during construction and operation of projects as shown in Table 4.3.F.

Table 4.3.F: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year)
CO NOX ROG SOX PM10 PM2.5
Construction Thresholds 100 10 10 27 15 15
Operation Thresholds 100 10 10 27 15 15
Source: Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD, March 19, 2015).

The emissions thresholds in the SJVAPCD GAMAQI were established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of

12 San Joaquin Valley Air Pollution Control District, 2015, op. cit.

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safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks.

Health Risk Thresholds. Both the State and federal governments have established health-based ambient air quality standards (AAQS) for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level.

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the Basin:
• MICR: MICR is the estimated probability of a maximum exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 30 years for adults and 9 years for children in residential locations, 350 days per year. The SJVAPCD’s Update to the District’s Risk Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 20 in 1 million.
• Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multi- pathway consideration when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location.
• Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

4.3.3.2 Project Impacts
The following discussion describes the potential impacts related to air quality that could result from implementation of the proposed project.

AIR-1 The project would not conflict with or obstruct implementation of the applicable air quality plan.

The proposed project was assessed to determine if the impacts from future transportation improvement projects included under the proposed VMT Reduction Program would conflict with or obstruct the implementation of the applicable attainment plan. The VMT Reduction Program includes a broad range of VMT-reducing transportation improvements that could be funded through the proposed program. The pace of development within Fresno and timing for development of VMT- reducing improvements cannot be determined at this time. Therefore, construction-related

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emissions associated with future transportation improvements that may occur at any one time are speculative and cannot be accurately determined at this stage of the planning process.

Therefore, it is necessary to assess the project’s consistency with the SJVAPCD’s Air Quality Attainment Plans as well as the General Plan and growth forecasts. The purpose of the consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans, and thus, if it would interfere with the region’s ability to comply with federal and State air quality standards. It is important to note that even if a project is found consistent it could still have a significant impact on air quality under CEQA. Consistency with plans means that a project is consistent with the goals, objectives, and assumptions in the respective plan to achieve the Federal and State air quality standards.

The proposed VMT Reduction Program would be consistent with the General Plan as it would preserve acceptable air quality and would improve a transportation network that is sensitive to environmental issues, such as air quality. The proposed project would not affect Fresno’s growth projections because the proposed project does not include any development that would introduce population or substantial employment in Fresno. As such, the proposed project would not exceed the housing and population growth forecasts for Fresno.

The project’s short-term construction and long-term operational emissions impacts would be less than significant, and the proposed project, and future projects implemented under the proposed project would be required to comply with all SJVAPCD rules and regulations to improve air quality.

Therefore, the proposed project would not conflict with or obstruct implementation of the applicable air quality plan. A less than significant impact would occur.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AIR-2 The project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project is nonattainment under an applicable federal or state ambient air quality standard.

The intent of the proposed project is to streamline the SB 743 compliance process for development projects while funding future VMT improvement projects to reduce VMT throughout Fresno. As identified in Table 3.A, Potential VMT-Reducing Improvements, future transportation improvements would include, but are not limited to new buses, increased bus service, pedestrian improvements, and bikeways.

The SJVAPCD has adopted project level quantitative thresholds for ozone precursors reactive organic gases ROG and NOx of 10 tons per year and recommends quantitative thresholds for PM10 and PM2.5 of 15 tons per year. Although these thresholds are intended for use on individual development projects, no other quantitative plan level threshold has been adopted.

Construction-related emissions are described as short-term or temporary in duration and have the potential to represent a significant impact with respect to air quality. The proposed improvements

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would likely be small-scale transportation improvement projects in Fresno. The future construction- related activities associated with the proposed VMT Reduction Program in Fresno would result in emissions of criteria air pollutants and precursors from site preparation (e.g., excavation, grading, and clearing); exhaust from off-road equipment, material delivery trucks, and worker commute vehicles; vehicle travel on roads; and other miscellaneous activities (e.g., asphalt paving).

The proposed VMT Reduction Program would provide a broad range of VMT-reducing transportation improvements that could be funded through the program. The pace of development within Fresno and timing for development of VMT-reducing improvements cannot be determined at this time. Therefore, construction-related emissions associated with future transportation improvements that may occur at any one time are speculative and cannot be accurately determined at this stage of the planning process. The construction activities would occur throughout Fresno as funding becomes available. Although the rate of VMT-reducing improvement projects cannot be determined, each individual improvement project would be small-scale with a limited construction duration, and it is not anticipated that such improvements would have the capacity to exceed SJVAPCD project level thresholds. Furthermore, all future individual VMT-reducing improvement projects within Fresno, including those implemented as part of development projects, would require separate environmental review under CEQA (e.g., preparation of a Categorical Exemption, Mitigated Negative Declaration, or Environmental Impact Report) and be analyzed at a project-specific level.

Construction activities associated with these individual VMT-reducing improvement projects result in an increase in criteria pollutants. However, these construction-related emissions would be analyzed on a case-by-case basis. All transportation improvements, including those implemented as part of development projects, would be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and any required mitigation. As a result, a less-than- significant impact related to criteria pollutants would occur.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AIR-3 The project would not expose sensitive receptors to substantial pollutant concentrations.

The analysis below addresses exposure to sensitive receptors from both stationary sources and mobile sources. Proposed projects associated with the proposed VMT Reduction Program that emit TACs would require review under SJVAPCD rules and regulations or review under CEQA, especially if located near sensitive receptors. Projects with sensitive receptors proposed near localized sources of TAC emissions (e.g., residents to be located near major roadways or stationary sources) could expose new sensitive populations to TACs and other air pollutants. According to the CARB and SJVAPCD, exposure to elevated levels of TACs contribute to elevated health risks. The ARB recommends that buffers should be included to avoid exposure of sensitive receptors to TAC sources. Risk levels drop dramatically beyond 500 feet from a source due to dispersion of emissions with distance.

It is important to note that CEQA generally does not require analysis or mitigation of the impact of existing environmental conditions on a project, including a project's future users or residents.

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However, as with other laws and regulations enforced by other agencies that protect public health and safety, the City, as the lead agency, has authority other than CEQA to institute policies that aim to protect public health and safety.

Implementation of the proposed VMT Reduction Program would not directly generate operational emissions as the transportation improvements funded by the proposed program would result in a net decrease in VMT throughout and Fresno associated mobile source operational emissions. In alignment with SB 743, the project would allow implementation of TDM strategies and VMT- reducing improvements that contribute towards reducing Citywide VMT, resulting in beneficial operational air quality impacts. Additionally, the proposed program itself would not involve any building construction or land uses that may generate stationary or mobile source emissions. As a result, in a less-than-significant impact related to exposing sensitive receptors to substantial operation-related pollutant concentrations.

Stationary sources of TACs within Fresno include the stationary sources permitted by the SJVAPCD.

Emissions of TACs would be controlled through permits issued by SJVAPCD and would be subject to further study and health risk assessment prior to the issuance of any necessary air quality permits.

Since it is not possible to determine the amount of TAC concentrations at the time of this analysis, it is not possible to calculate the risks for a particular health effect within the Planning Area. The proposed project is a programmatic project and until specific future projects are proposed, the associated TAC emissions cannot be determined or modeled at this time. Future development projects subject to environmental review under CEQA would be required to analyze potential TAC emissions and include mitigation as appropriate.

As noted above, implementation of the propose VMT Reduction Program would not result in long- term operation of any stationary sources of TACs and would have a decrease in mobile source emissions as the project would cause a decrease in Citywide VMT. However, construction of the various potential transportation improvements may result in temporary increases in emissions of diesel particulate matter (DPM) associated with the use of off-road diesel equipment. However, potential increase in pollution concentrations would be analyzed on a case-by-case basis. All transportation improvements, including those implemented as part of development projects, would be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and any required mitigation. As a result, a less-than-significant impact related to substantial pollution concentrations would occur.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

AIR-4 The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The city of Fresno has many sources with the potential to generate odors including wastewater treatment facilities, landfills, transfer stations, recycling centers, manufacturing plants, food processors, painting operations, and rendering plants.

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The proposed VMT Reduction Program does not propose any demolition or development activities within Fresno. Individual transportation improvements within the Fresno would occur in incremental phases over time, based largely on available funding. Transportation improvements may also occur as part of development projects (e.g., improvements along a project frontage). The phasing and exact details of each improvement would be evaluated by the City on a case-by-case basis as the funding becomes available. Construction activities associated with these improvements may generate detectable odors from heavy-duty equipment exhaust and paving. However, these construction-related odors would be analyzed on a case-by-case basis. All transportation improvements, including those implemented as part of development projects, would be required to undergo separate environmental review under CEQA to evaluate project-specific impacts and any required mitigation. In addition, the improvements within Fresno would be required to comply with the California Code of Regulations, Title 13, Sections 2449(d)(3) and 2485, which minimizes the idling time of construction equipment either by shutting it off when not in use or by reducing the time of idling to no more than five minutes. This would further reduce the detectable odors from heavy-duty equipment exhaust. As a result, a less-than-significant impact related to odors would occur.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

4.3.3.3 Cumulative Impacts
AIR-5 The project, in combination with other projects, would not contribute to a significant cumulative impact related to air quality.

As defined in Section 15130 of the State CEQA Guidelines, cumulative impacts are the incremental effects of an individual project when viewed in connection with the effects of past, current, and probable future projects within the cumulative impact area for air quality. The cumulative study area analyzed for potential air quality impacts is the Basin. Each project in the Basin is required to comply with SJVAPCD rules and regulations and is subject to independent review.

The Basin is currently designated as a nonattainment area for the federal ozone standard and PM2.5 standard and as a nonattainment area for the State ozone, PM10, and PM2.5 standard. Thus, the Basin has not met the federal and State standards for these air pollutants. Future development that may occur under the approved General Plan would contribute criteria pollutants to the area during project construction and operation. However, future development under the proposed VMT Reduction Program project would be required to comply with CARB motor vehicle standards, SJVAPCD regulations from stationary sources and architectural coatings, Title 24 energy efficiency standards, and the approved General Plan and policies. While the approved General Plan policies and regulations are intended to reduce impacts associated with air quality violations, specific standard conditions for future project developments that implement these policies and regulations are identified as mitigation measures to ensure that the intended environmental protections are achieved. Implementation of the approved General Plan could contribute to an increase in frequency or severity of air quality violations. However, compared to existing conditions, implementation of the proposed VMT Reduction Program would result in a decrease in Citywide

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VMT and associated mobile source operational emissions. Therefore, cumulative construction and operational impacts associated with implementation of the proposed VMT Reduction Program would be considered less than significant.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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4.4 BIOLOGICAL RESOURCES
This section describes the existing biological resources of the project area and evaluates the potential impacts associated with the proposed project on biological resources, including vegetation communities, special-status plant and wildlife species and their associated habitats, and special- status natural communities, including riparian communities and wetlands.

4.4.1 Existing Environment Setting
The study area for project impacts is the Planning Area for the City of Fresno.

4.4.1.1 Existing Conditions
Vegetation Communities. The following discussion of vegetation communities known to occur in the Planning Area is based on a review of information in the California Natural Diversity Database (CNDDB) in 2025.
• Annual Grassland • Riverine
• Barren • Urban
• Deciduous Orchard • Valley Foothill Riparian
• Irrigated Row and Field Crops • Valley Oak Woodland
• Lacustrine • Northern Claypan Vernal Pool
• Pasture

The majority of the Planning Area consists of previously disturbed urban/developed areas containing residential, commercial and industrial development and associated roads and infrastructure.

For the purposes of this evaluation, vegetation communities are classified according to the CDFW’s Natural Communities List and cross-referenced to descriptions provided in Holland’s Preliminary Descriptions of the Terrestrial Natural Communities of California and Oberbauer’s update to those descriptions.
1 The CDFW does not maintain narrative description of these vegetation communities, so the descriptions provided below have been adapted from Holland and Oberbauer.

The vegetation maps produced for this evaluation do not imply regulatory jurisdictional determinations under Section 404 of the Federal Clean Water Act, Section 10 of the Rivers and Harbors Act, or Section 1600 of the California Fish and Game Code (Lake and Streambed Alteration Program), or the lack thereof. Such determinations usually require a site visit to assess the current conditions on the ground and to map boundaries. Similarly, terms such as “riparian” and “wetland” in the vegetation keys and type descriptions may inform, but do not imply or assert, regulatory jurisdiction or the lack thereof.

Annual Grassland. The Planning Area contains annual grassland, located primarily along the northern and western borders of the Planning Area boundary. Annual grassland in the Planning Area includes a mix of native and non-native, annual grasses, which often occur in association

1 Holland, R.F. 1986 (updated 1996). Preliminary Descriptions of the Terrestrial Natural Communities of California. Non-game Heritage Program. California Department of Fish and Game. Sacramento, California.

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with ruderal herbs and occasional native annual forbs. The dominant plant species within the annual grassland vegetation community typically include black needlegrass (Nasella sp.), fescue (Vulpia sp.), brome (Bromus sp.), and wild oats (Avena spp.), with mustard (Brassica nigra), dove weed (Eremocarpus setigerus), and poppy (Eschscholzia sp.). These grasses germinate with the fall rains, grow during the winter and spring, and wither in the early summer.

Special-status species with a potential to occur in the Planning Area and associated with annual grassland habitats include:
• American Badger • Western mastiff bat
• Burrowing owl • Western spadefoot
• California horned lark • Hartweg’s golden sunburst
• California linderiella • Caper-fruited tropidocarpum
• California tiger salamander • California jewel-flower • Fresno kangaroo rat • Dwarf downingia
• Pallid bat • Spiny-sepaled button-celery
• San Joaquin kit fox • Succulent owl’s clover
• San Joaquin pocket mouse • Greene’s tuctoria
• Swainson’s hawk

Barren. Barren lands include areas in which the vegetative cover comprises less than 10 percent of the surface area (disregarding natural rock outcrops) and where there is evidence of soil surface disturbance and compaction from previous legal human activity, and/or areas in which the vegetative cover is greater than 10 percent, soils surface compaction is evident, and building foundations and debris are present (e.g., irrigation piping, fencing, old wells, abandoned farming or mining equipment) from legal activities (as opposed to illegal dumping). Barren land occurs in the northwest corner of the Planning Area, adjacent to the San Joaquin River corridor.

Vegetation within barren land has a high predominance of non‐native or weedy species that are indicators of soil disturbance, including Russian thistle (Salsola tragus), telegraph weed (Heterotheca grandiflora), horehound (Marrubium vulgare), and sow thistle (Sonchus oleraceus), and a sub‐dominance of non‐native grasses. Barren land only provides moderately suitable habitat for one special‐status species, California horned lark.

Deciduous Orchard. Deciduous orchard communities are located along the western, southern and eastern margins of the Planning Area, where there are flat alluvial soils on valley floors, rolling foothills and relatively steep slopes. Orchard communities are typically comprised of artificially irrigated habitat dominated by one, sometimes several, tree or shrub species planted for cultivation. Trees are typically low and bushy, and the understory is open, with little groundcover. In the Planning Area, deciduous orchards include a variety of fruit trees (e.g., apples, apricots, cherries, citrus, kiwi, peaches, nectarines, pears, persimmons, plums, pluots, pomegranates, etc.) and/or nut trees and shrubs (e.g., almonds, olives, pistachios, walnuts, etc.). Understory species generally consist of short native and non‐native grasses and other herbaceous species.

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Deciduous orchard is a relatively disturbed vegetation community and contains very little groundcover and planted trees that provide moderately suitable habitat for only one special‐ status species, California horned lark.

Irrigated Row and Field Crops. This vegetation community frequently occurs in floodplains or upland areas with high soil quality. Irrigated row and field crows include annual and perennial crops, grown in rows, with open space between the rows. Row and field crops are artificially irrigated and feature a moderate disturbance rate by vehicle and pedestrian encroachment typically associated with farming activities. Species composition changes frequently, both by season and by year.

Since irrigated row and field crops contain active agriculture, and are therefore significantly disturbed with altered substrates, this vegetation community does not provide suitable habitat for any special-status plant species and limited habitat for special-status wildlife species. Special- status wildlife species with a potential to occur within this vegetation community include:
• burrowing owl
• California horned lark
• Swainson’s hawk
Lacustrine. Lacustrine communities consist of standing/open waters in topographic depressions (i.e., lakes) or dammed river channels. Lacustrine communities lack persistent emergent vegetation, but may have submerged or floating‐leaved aquatic vegetation. Generally, lacustrine systems are surrounded by hydrophytic plants, grasses, and trees. Lacustrine systems are located near the San Joaquin River, within the isolated southwestern most portion of the Planning Area, and within the isolated basins and ponds that are interspersed throughout the city. Special‐status species with a potential to occur within a lacustrine community include:
• western spadefoot
• tricolored blackbird
• hoary bat
• spotted bat
• western pond turtle
• dwarf downingia
• Sanford’s arrowhead
Pasture. Pasture lands occur along the northwest corner of the Planning Area, near deciduous orchards and other irrigated row and field crops. Pasture lands form a dense habitat with nearly 100 percent cover; usually monoculture crops are planted in these areas, which are irrigated, artificially seeded, and frequently maintained. Characteristic species include non-native grasses such as oat (Avena sp.), bermuda grass (Cynodon sp.), barley (Hordeum sp.), Sorghum grass, as well as clover (Medicago sp.). Often times, this land contains significant areas of bare ground due to livestock grazing and movement across acres of this vegetation community. Special- status species with a potential to occur within this vegetation community include:

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• burrowing owl
• California horned lark
• San Joaquin kit fox
• Swainson’s hawk
Riverine. Riverine systems consist of linear aquatic communities of flowing, non-tidal waters with a distinct channel and little to no persistent emergent vegetation. Riverine systems may also include areas with abundant submerged or floating-leaved aquatic vegetation. Vegetation communities abutting riverine systems tend to be dominated by trees, shrubs, persistent emergent vegetation, and/or emergent mosses and lichens. This vegetation community occurs near or depends upon a nearby freshwater source or areas with fresh water flow during all or part of the year. Riverine communities are predominately located along the northern boundary, within the San Joaquin River system. Special-status species that are known to occur in riverine habitat include:
• western yellow-billed cuckoo
• tricolored blackbird
• hardhead
• hoary bat
• spotted bat
• western pond turtle
• California satintail
Urban. Urban (or developed) lands have been constructed upon or otherwise covered with a permanent, unnatural surface (e.g., concrete, asphalt, buildings, homes, etc.) or large amount of debris or other materials. The Planning Area consists predominately of urban areas, which are concentrated in the central portion of the Planning Area, within the Fresno city limits. Urban land is less common within the rural and agricultural portions of the Planning Area. Urban land provides poor quality habitat for any special‐status species. Special‐status species are unlikely to occur within this vegetation community.

Valley Foothill Riparian. Valley foothill riparian communities occur primarily within mature riparian forests along the San Joaquin River corridor. Valley foothill riparian communities typically have a 20 to 80 percent canopy cover with trees that are winter deciduous. Wild grape (Vitis californica) often provides 30 to 50 percent ground cover. There is very little herbaceous understory with the exception of disturbed openings in the canopy cover. The understory typically consists of leaf‐litter, fallen limbs, and is often impenetrable for smaller herbaceous plants. Tree canopy species within this community typically includes cottonwood (Populus fremontii), California sycamore (Platanus racemosa), and valley oak (Quercus lobata). Subcanopy species often includes white alder (Alnus rhombifolia), boxelder (Acer negundo), and Oregon ash (Fraxinus latifolia). Typical understory shrub layer plants include wild grape, California blackberry (Rubus ursinus), blue elderberry (Sambucus caerulea), poison oak (Toxicodendron diversilobum), and willows (Salix sp.). Special‐status species with a potential to occur within valley foothill riparian habitat includes:

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• western spadefoot
• western yellow-billed cuckoo
• California horned lark
• hoary bat
• spotted bat
• pallid bat
• western mastiff bat
• valley elderberry longhorn beetle
• California satintail
Valley Oak Woodland. The Valley Oak Woodland is a special-status natural community. The Planning Area includes valley oak woodland located primarily within the San Joaquin River corridor. Valley oak woodland communities vary from open-canopy savanna-like woodlands to partially closed canopy woodlands but mostly consist of winter-deciduous, broad-leaved species. Valley oak (Quercus lobata), a winter-deciduous species and California’s largest broad- leaved tree, is usually the only tree species present, although blue oak (Q. douglasii) may also be present. Mature valley oaks can reach heights of 50 to 100 feet (about 15 to 35 meters). Valley oak woodlands typically occur on deep, well-drained alluvial soils in valley bottoms that have a higher summer moisture content. This community intergrades with valley oak riparian near rivers and with blue oak woodlands on drier slopes. Characteristic understory species include creeping wild rye (Elymus triticoides), wild oats (Avena sp.), brome (Bromus sp.), barley (Hordeum zp.), needlegrass (Nassella sp.) and poison oak (Toxicodendron diversilobum). Special- status species known to occur within valley oak woodland habitat includes:
• western spadefoot
• spotted bat
• pallid bat
• western mastiff bat
• San Joaquin pocket mouse
• Hartweg’s golden sunburst
• Madera leptosiphon
Northern Claypan Vernal Pool. The northern claypan vernal pool is a special-status natural community. The Planning Area includes northern claypan vernal pool along the northwest boundary of the Planning Area. Typically, these pools are located within the lower elevations of the main San Joaquin Valley. These areas are typically associated with a series of small mima mounds with interspersed pools. Typically, these pools have highly alkaline and may display whitish salt deposits in non-vegetated centers of dry pools. These vernal pools are dominated by a high percentage of non-native species. Special-status species known to occur within northern claypan vernal pool includes:
• California tiger salamander
• vernal pool fairy shrimp
• California linderiella
• molestan blister beetle

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• midvalley fairy shrimp
• succulent owl’s clover
• Green’s tuctoria
Special‐Status Natural Communities. As described above, the Planning Area contains two special- status natural communities: valley oak woodland and northern claypan vernal pool. Based on a review of the CNDDB, there are three additional special-status natural communities located in the vicinity of the Planning Area. These three special-status natural communities include the northern hardpan vernal pool, great valley mixed riparian forest, and sycamore alluvial woodland. Each of these three special-status natural communities are associated with stream courses, waterways, drainages, wetlands, and seasonal pools; however, these have not been recorded to occur within the Planning Area and are, therefore, not likely to occur.

Special‐Status Species. The Planning Area contains potentially suitable habitat for a total of 40 special-status species (including 8 plant species and 32 wildlife species). Each of the special-status species with potential to occur (or that are known to occur) within the Planning Area is described in more detail below.

Listed Plant Species. Eight listed plant species have the potential to occur within the Planning Area.

Impacts to these species should be avoided to the greatest extent possible. Consultation with state and/or federal agencies would be required in the event that a proposed project had the potential to affect a listed plant species.

Table 4.4.A: Special-Status Plant Species Recorded in the Project Vicinity Common Name Scientific Name Rare Plant Rank1
California jewelflower Caulanthus californicus 1B.1
San Joaquin Valley Orcutt grass Orcuttia inaequalis 1B.1 hairy Orcutt grass Orcuttia pilosa 1B.1
succulent owl’s-clover Castilleja campestris var. succulenta 1B.2 Greene’s tuctoria Tuctoria greenei 1B.1
California satintail Imperata brevifolia 2B.1
Madera leptosiphon Leptosiphon serrulatus 1B.2
Sanford’s arrowhead Sagittaria sanfordii 1B.2
Notes:
1 California Native Plant Society (CNPS) California Rare Plant Rank 1B Plants rare, threatened, or endangered in California and elsewhere. 2B Plants rare, threatened, or endangered in California but more common elsewhere.

Threat Ranks:
.1 Seriously threatened in California (over 80% of occurrences threatened/high degree any immediacy of threat). .2 Moderately threatened in California (20 to 80 percent of occurrences threatened/moderate degree and immediacy of threat).

Source: California Native Plant Society, Inventory of Rare and Endangered Plants of California (online edition, v9.5.1a), http://www.rareplants.cnps.org/, accessed April 2025.

California Jewel‐Flower. California jewel‐flower (Caulanthus californicus) is a state and federally listed endangered species and a CNPS list 1B.1 species. California jewel‐flower occurs within chenopod scrub in valley and foothill grasslands and pinyon‐juniper woodlands. It is historically

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known from various valley habitats in both the Central Valley and Carrizo Plain from 65 to 900 meters. There is one historical known location within the Planning Area, but it is located within an area that appears to have already been converted to urban use.

San Joaquin Valley Orcutt Grass. San Joaquin Valley orcutt grass (Orcuttia inaequalis) is a state endangered species, a federally threatened species, and a CNPS list 1B.1 species. This species is restricted to vernal pools at elevations from 30 to 755 meters above sea level. There is one historic known location within the Planning Area, near the central/western portion, just west of Highway 99.

Hairy Orcutt Grass. Hairy orcutt grass (Orcuttia pilosa) is state and federally endangered species and a CNPS list 1B.1 species. This species is restricted to vernal pools surrounded by annual grasslands. It is specifically known to occur within the northern hardpan vernal pool community, on San Joaquin fine sandy loam. There are no historic/known locations of this species within the Planning Area.

Succulent Owl’s Clover. Succulent owl’s clover (Castilleja campestris ssp. succulenta) is a state endangered species, a federally threatened species, and a CNPS list 1B.2 species. Succulent owl’s clover is isolated to vernal pools in valley and foothill grasslands. Microhabitat requirements include moist places with acidic soils, from 25 to 750 meters. There is one historic/known location in the Planning Area, located within the county of Fresno (and outside of the City of Fresno sphere of influence), just south of the San Joaquin River corridor.

Table 4.4.B: Special-Status Wildlife Species within the Project Vicinity Common Name Scientific Name Federal Status State Status CDFW Status
American badger Taxidea taxus None None SSC
American bumble bee Bombus pensylvanicus None None
Antioch efferian robberfly Efferia antiochi None None
black-crowned night heron Nycticorax nycticorax None None burrowing owl Athene cunicularia None Candidate Endangered SSC California glossy snake Arizona elegans occidentalis None None SSC California horned lark Eremophila alpestris actia None None WL California linderiella Linderiella occidentalis None None California tiger salamander -
central California DPS
Ambystoma californiense
pop. 1
Threatened Threatened WL
coast horned lizard Phrynosoma blainvillii None None SSC Crotch's bumble bee Bombus crotchii None Candidate Endangered double-crested cormorant Nannopterum auritum None None WL Fresno kangaroo rat Dipodomys nitratoides exilis Endangered Endangered great egret Ardea alba None None
hardhead Mylopharodon conocephalus None None SSC
hoary bat Lasiurus cinereus None None
Hurd's metapogon robberfly Metapogon hurdi None None
least Bell's vireo Vireo bellii pusillus Endangered Endangered molestan blister beetle Lytta molesta None None
Northern California legless
lizard
Anniella pulchra None None SSC

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Table 4.4.B: Special-Status Wildlife Species within the Project Vicinity Common Name Scientific Name Federal Status State Status CDFW Status
northwestern pond turtle Actinemys marmorata Proposed
Threatened
None SSC
pallid bat Antrozous pallidus None None SSC
San Joaquin kit fox Vulpes macrotis mutica Endangered Threatened San Joaquin pocket mouse Perognathus inornatus None None snowy egret Egretta thula None None
Swainson's hawk Buteo swainsoni None Threatened
tricolored blackbird Agelaius tricolor None Threatened SSC valley elderberry longhorn
beetle
Desmocerus californicus
dimorphus
Threatened None
vernal pool fairy shrimp Branchinecta lynchi Threatened None western mastiff bat Eumops perotis californicus None None SSC western spadefoot Spea hammondii Proposed
Threatened
None SSC
western yellow-billed
cuckoo
Coccyzus americanus
occidentalis
Threatened Endangered
Notes:

SSC Species of Special Concern – any species, subspecies, or distinct population of fish, amphibian, reptile, bird, or mammal native to California that currently satisfies one or more of the following criteria:
- is extirpated from California or, in the case of birds, in its primary seasonal or breeding role; - is listed as Federally-, but not State-, threatened or endangered; meets the State definition of threatened or endangered but has not formally been listed.
- is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status; or - has naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for State threatened or endangered status.

WL Watch List - taxa that were previously designated as “Species of Special Concern” but no longer merit that status, or which do not yet meet SSC criteria, but for which there is concern and a need for additional information to clarify status.

Greene’s Tuctoria. Greene’s tuctoria (Tuctoria greenei) is a federally endangered species, a California Rare species, and a CNPS list 1B.1 species. This species is known to occur within vernal pools surrounded by valley and foothill grasslands. Specifically this species is located on dry bottoms of vernal pools from an elevation range of 30 to 1,065 meters. There are no historic/known locations of this species within the Planning Area.

Other Special‐Status Plant Species. In addition to the five listed plant species, there are three “other” special-status plant species have the potential to occur in the Planning Area: California satintail (Imperata brevifolia), Madera leptosiphon (Leptosiphon serrulatus), and Sanford’s arrowhead (Sagittaria sanfordii). Direct take of these species should be avoided wherever possible.

Listed Wildlife Species. A total of seven listed wildlife species have the potential to occur or are known to occur within the Planning Area. Project impacts to these species should be avoided to the greatest extent possible.

California Tiger Salamander. The California tiger salamander is federally threatened within the Central Valley in California. The Central Valley species is known to occur within grasslands and oak savannas and along the edges of mixed woodland and lower elevation coniferous forests.

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This species is endemic to California, but most of the historic range is not well known because it has been fragmented. Currently most populations in the Central Valley have been eliminated, and the remainder are found in the surrounding foothills from Tulare county north to Yolo county, and from Santa Barbara county to the Sacramento Valley.

The California tiger salamander is nocturnal and fossorial, spending most of its time underground in animal burrows, especially those of California ground squirrels and valley pocket gophers. Breeding occurs within vernal pools or other seasonal waters. The California tiger salamander emerges at night with the fall rains, sometimes in early November. This species needs both suitable upland terrestrial habitat and temporary breeding ponds in order to survive.

Fresno Kangaroo Rat. Fresno kangaroo rat (Dipodomys nitratoides exilis) is state and federally listed as endangered. This species excavates burrows in gently undulating to level terrain with sandy loam soils that are mildly to moderately alkaline and characterized by herbaceous vegetation with scattered shrubs. Herbaceous vegetation with scattered shrubs is common aboveground cover. Burrow systems cover a surface area from about 7‐feet by 7‐feet to 12‐feet by 12‐feet. Some burrow systems included short dead‐end tunnels, apparently used to escape predators.

San Joaquin Kit Fox. San Joaquin kit fox (Vulpes macrotis mutica) is a state threatened species and a federally endangered species that is in population decline, particularly in California, largely due to widespread habitat loss from agriculture and urbanization. The species occurs from the San Joaquin Valley north to Contra Costa and Alameda counties. This species generally prefers open, level areas with loose-textured soils supporting scattered, shrubby vegetation with little human disturbance.

The San Joaquin kit fox is a small grayish fox about two and one half feet in length and weighing up to five and one half pounds. The kit fox is distinguished from other foxes by its large ears. The fox preys on rodents, rabbits, and lizards, and in turn is preyed upon by larger carnivores, particularly coyote.

Swainson’s Hawk. Swainson’s hawk (Buteo swainsoni) is a state threatened species that breeds regularly from southwestern Canada to northern Mexico. Typical habitat includes open desert, grassland, or croplands near scattered, large trees or small groves. This species nests in open riparian habitat or in scattered trees or small groves in sparsely vegetated flatlands. While it typically roosts in large trees, it will also roost on the ground in areas of suitable habitat, if no large trees are available. The nesting/breeding period for this species is from late March to mid- August, with peak activity in late May to late July. Swainson’s hawks build their nests on a platform of sticks, bark, and fresh leaves in a tree, bush, or utility pole from 1.3 to 30 meters (4- 100 feet) above ground. The Swainson's hawk forages in shrub-steppe habitats and agricultural lands. Swainson’s hawk populations have declined markedly since the 1920s, with steep declines in the 1950s. In some areas there have been losses of 90 to 95 percent of past populations.

Valley Elderberry Longhorn Beetle. Valley elderberry longhorn beetle (Desmocerus californicus dimorphus) is a federally threatened species. The beetle’s current distribution is patchy throughout the remaining riparian forests of the Central Valley, between Redding and

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Bakersfield. The beetle is locally common (i.e., found in population clusters that are not evenly distributed across the Central Valley). The species is nearly always found on or close to its host plant, elderberry (Sambucus sp.). Females lay their eggs on the bark and larvae hatch and burrow into the stems. The larval stage may last 2 years, after which the larvae enter the pupal stage and transform into adults. Adults are active from March to June, feeding and mating. It appears that in order to serve as habitat, the shrubs must have stems that are 1.0 inch or greater in diameter at ground level. Use of the plants by the animal is rarely apparent.

Vernal Pool Fairy Shrimp. Vernal pool fairy shrimp (Branchinecta lynchi) is a federally threatened species. Populations of this species are known to live in ephemeral freshwater habitats, such as vernal pools and swales. None are known to occur in running or marine waters or other permanent bodies of water. This species has a sporadic distribution within vernal pool complexes, wherein the majority of pools in a given complex typically are not inhabited by the species.

Although the vernal pool fairy shrimp has a relatively wide range, the majority of known populations inhabit vernal pools with clear to tea-colored water, most commonly in grass or mud bottomed swales, or basalt flow depression pools in unplowed grasslands, but one population occurs in sandstone rock outcrops and another population in alkaline vernal pools.

They are ecologically dependent on seasonal fluctuations in their habitat, such as absence or presence of water during specific times of the year, duration of inundation, and other environmental factors that include specific salinity, conductivity, dissolved solids, and pH levels.

Water chemistry is one of the most important factors in determining the distribution of fairy shrimp. The vernal pool fairy shrimp occurs at temperatures between 6-20 degrees C, in soft and poorly buffered waters.

Western Yellow‐Billed Cuckoo. Western Yellow-billed cuckoo (Coccyzus americanus occidentalis) is a federally threatened species and a state endangered species. The yellow-billed cuckoo breeds in large blocks of riparian habitat (willow and cottonwood stands in river floodplains). This bird feeds primarily on large insects, including caterpillars and cicadas, and occasionally on small frogs and lizards. Breeding coincides with the emergence of cicadas and tent caterpillar. Historically, yellow-billed cuckoos nested primarily in coastal counties from San Diego county, near the Mexican border, to Sonoma county, to the Central Valley from Kern through Shasta Counties, and along the lower Colorado River. Primary threats to its habitat include conversion of riparian habitat to agriculture, urban development, and flood control, as well as disease, predation and lack of regulatory mechanisms.

Other Special‐Status Wildlife Species. In addition to the seven listed wildlife species, there are nine “other” special-status wildlife species that have the potential to occur or are known to occur within the Planning Area. Direct take of these species should be avoided and significant reductions in suitable habitat and project impacts that result in significant population decline should be avoided to the maximum extent feasible.

American Badger. American badger (Taxidea taxus) is a California Species of Special Concern that is known to occur within a variety of open, arid habitats, most commonly associated with grasslands, savannas, mountain meadows, and open areas of desert scrub. Principle habitat

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requirements include sufficient prey base, friable soils, and relatively open, uncultivated ground.

They typically occur at elevation ranges from below sea level to over 12,000 feet above mean sea level. American badger habitat is threatened by habitat conversion to urban and agricultural uses, farming operations, shooting and trapping, poisoning, and reduction of prey base because of rodent control activities. This species occurs as far north as Canada, and as far south as central Mexico. In the United States, it currently extends east from the Pacific coast to Texas, Oklahoma, Missouri, Illinois, Indiana, and Ohio. In California, American badger is an uncommon, permanent resident throughout most of the state, with the exception of the North Coast area.

Burrowing Owl. Burrowing owl (Athene cunicularia) is designated as a California Species of Special Concern. Burrowing owls require large open expanses of sparsely vegetated areas on gently rolling or level terrain with an abundance of active small mammal burrows. Typical habitat associated with the species includes short-grass prairies, grasslands, lowland scrub, agricultural lands (particularly rangelands), prairies, coastal dunes, desert floors, and some artificial, open areas as a year-round resident. Burrowing owls may also use golf courses, cemeteries, road easements and rights-of-way within cities, airports, vacant lots in residential areas, and irrigation ditches. Burrowing owls often use existing rodent burrows (or other burrows) for roosting and nesting. They may also use pipes and culverts where burrows are scarce. If left undisturbed, a burrowing owl pair will use the same burrow year after year for nesting.

Hardhead. Hardhead (Mylopharodon conocephalus), a fish, is a California Species of Special Concern that occurs in low to mid-elevation streams in the Sacramento-San Joaquin drainage and the Russian River. Microhabitat requirements include clear, deep pools with a mix of sand, gravel and boulder bottoms with slow water velocity. This species is not found where exotic centrarchids (commonly known as sunfish) predominate. Populations of this species are well established in mid-elevation reservoirs used exclusively for hydroelectric power generation, such as the Redinger and Kerkhoff Reservoirs on the San Joaquin River in Fresno county.

Hardhead is a bottom feeder that forages for benthic invertebrates and aquatic plant material in quiet water. They will also occasionally feed on plankton and surface insects. This species is in decline due to predation by smallmouth bass, and damming of large to medium-sized warm water streams with natural flow regimes.

Pallid Bat. The pallid bat (Antrozous pallidus) is a California Species of Special Concern and a High Priority species as designated by the Western Bat Working Group. This species ranges throughout California and occurs within a wide range of habitat types, typically below 6,000 feet above mean sea level. Pallid bats are non-migratory and hibernate during the winter, during which they experience very little activity. Pallid bats occur in a variety of habitats throughout the State and are most abundant in xeric ecosystems. Pallid bats roost alone and in both large and small groups. Day and night roosts include crevices in rocky outcrops and cliffs, caves, mines, trees, and human structures such as bridges, barns, porches, bat boxes, and buildings. This species also has been found roosting on or near the ground under stone piles, rags, and baseboards. Pallid bat is a gregarious species and often roost in colonies of 20 to several hundred individuals. The tendency to roost gregariously, combined with a relative sensitivity to disturbance, makes it vulnerable to mass displacement. Pallid bats are generalists that surface

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glean for arthropods and capture insects on the wing. Breeding occurs from October to February. Pups are born from late April to July and are Volant at 4 to 6 weeks of age. Breeding colonies disperse between August and October.

Spotted Bat. The spotted bat (Euderma maculatum) is a California Species of Special Concern and a High Priority species as designated by the Western Bat Working Group. The spotted bat is easily identifiable by its unique coloration of dorsal black fur with three white spots, white ventral surface and long, pink ears. In addition to being found in California, the species is known to occur in all of the states west of (and including) Montana, Wyoming, Colorado, New Mexico and Texas. The species generally occurs in arid, low desert habitats to high elevation conifer forests. Prominent rock features appear to be a necessary feature for roosting. The winter range and hibernacula are unknown for most of its range, though the species has been captured year- round in the southern part of its range. This species likely breeds in late summer with females giving birth to a single pup in early summer (May or June). They appear to be solitary animals but occasionally roost or hibernate in small groups. Roost sites are cracks, crevices, and caves usually high in fractured rock cliffs. In general, the long-term persistence of this bat, as well as most bats, is threatened by the loss of clean, open water; modification or destruction of roosting and foraging habitat, and disturbance or destruction of hibernacula.

Tricolored Blackbird. The tricolored blackbird (Agelaius tricolor) is a California Species of Special Concern (CSC) that commonly occurs throughout central and coastal California. The species is often found near fresh water, as it prefers emergent wetlands with tall, dense cattails or tules, but it can also be found in thickets of willow, blackberry, wild rose, and other tall herbs.

Tricolored blackbird is known to forage on the ground in croplands, grassy fields, flooded land, and along the edges of ponds. The tricolored blackbird diet generally consists of insects and spiders as a juvenile, and seeds and cultivated grains, such as rice and oats, as an adult. The breeding season for this colonial breeding species generally ranges from mid-April to late July.

Western Mastiff Bat. The western mastiff bat (Eumops perotis) is a California Species of Special Concern and a High Priority species as designated by the Western Bat Working Group. The western mastiff bat occurs throughout California in a wide range of habitat types, typically below 9,000 feet in elevation. Distribution is correlated with suitable rock features required for roosting. Western mastiff bats are non-migratory; however, they may move short distances within their home ranges. This bat species does not hibernate and is active periodically throughout the winter. Western mastiff bat is generally a cliff-dwelling species, but also uses building crevices for day roosts. This species forages most frequently in broad open areas such as flood plains, chaparral, oak woodland, open ponderosa pine forest, grassland, montane meadows, and agricultural areas, and requires large lakes or ponds at least 100 feet long for drinking. Western mastiff bat generally roosts high above the ground, allowing a clear vertical drop of at least 7 feet for flight. Maternity colonies range from 30 to several hundred individuals and generally include adult males. This species has an audible echolocation call and is easily detected while foraging. This bat forages primarily on moths, but also takes crickets and katydids. Breeding occurs from October to March, from which pups are born primarily in July and are Volant at 4 to 6 weeks of age.

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Western Pond Turtle. The western pond turtle (Emys marmorata) is a California Species of Special Concern that inhabits ponds, lakes, rivers, streams, creeks, marshes and irrigation ditches containing abundant vegetation and either rocky or muddy bottoms in woodlands, forests and grasslands. It can be found basking on logs, rocks, cattail mats, and exposed banks within brackish water and seawater. This turtle feeds primarily on aquatic plants, invertebrates, worms, frog and salamander eggs and larvae, crayfish, carrion, and occasionally frogs and fish. It mates in April and May, eggs are laid sometime between April and August, and hatchlings emerge in early fall or overwinter in the nest.

Western Spadefoot. Western spadefoot (Spea hammondii), a California Species of Special Concern, can be found primarily in grassland habitats and valley-foothill hardwood woodlands.

It prefers open areas with sandy or gravelly soils in sandy washes, lowlands, river floodplains, alluvial fans, playas, alkali flats, foothills, and mountains. Vernal pools and rain pools that do not contain bullfrogs, fish or crayfish are necessary for breeding. The species can be found from sea level up to 4,500 feet. Western spadefoot eats a variety of invertebrates, including adult beetles, larval and adult moths, crickets, flies, ants, and earthworms. This species is nocturnal and almost completely terrestrial, entering water only to breed. It can burrow underground to escape hot, arid environments, and will spend most of its life underground. The species is typically active between October and May.

Other Wildlife Species for Consideration. Species that are not state or federally listed, and are not afforded additional state or federal protection include: California horned lark (Eremophila alpestris actia), hoary bat (Lasiurus cinereus), San Joaquin pocket mouse (Perognathus inornatus inornatus), California linderiella (Linderiella occidentalis), Antioch efferian robberfly (Efferia antiochi), molestan blister beetle (Lytta molesta), Hurd’s metapogon robberfly (Metapogon hurdi), and midvalley fairy shrimp (Branchinecta mesovallensis).

4.4.2 Regulatory Setting

4.4.2.1 Federal Policies and Regulations
Federal Endangered Species Act. The United States Fish and Wildlife Service (USFWS) administers the Federal Endangered Species Act (ESA). The ESA provides a process for listing species as either threatened or endangered and methods of protecting listed species. The ESA defines as “endangered” any plant or animal species that is in danger of extinction throughout all or a significant portion of its known geographic range. A “threatened” species is a species that is likely to become endangered. A “proposed” species is one that has been officially proposed by the USFWS for addition to the federal threatened and endangered species list.

Per Section 9 of the ESA, “take” of threatened or endangered species is prohibited. The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in such conduct (codified at 16 U.S.C.A. § 1532(19). “Take” can include disturbance to habitats used by a threatened or endangered species during any portion of its life history. The presence of any federally threatened or endangered species in a project area generally imposes severe constraints on development, particularly if development would result in “take” of the species or its habitat. Under the regulations of the ESA, the USFWS may authorize “take” when it is incidental to, but not the purpose of, an otherwise lawful act.

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Federal Clean Water Act ‐ Section 404. The US Army Corps of Engineers (USACE) administers Section 404 of the federal Clean Water Act (CWA). This section regulates the discharge of dredge and fill material into waters of the United States. “Discharge of fill material” is defined as the addition of fill material into waters of the United States, including, but not limited to, the following:
placement of fill that is necessary for the construction of any structure or impoundment requiring rock, sand, dirt, or other material for the structure’s construction; site development fills for recreational, industrial, commercial, residential, and other uses; causeways or road fills; and fill for intake and outfall pipes and sub-aqueous utility lines (33 C.F.R. §328.2[f]).

The USACE has established a series of nationwide permits that authorize certain activities in waters of the United States, if a proposed activity can demonstrate compliance with standard conditions.

Normally, USACE requires an individual permit for an activity that will affect an area equal to or in excess of 0.5 acre of waters of the United States. Projects that result in impacts to less than 0.5 acre can normally be conducted pursuant to one of the nationwide permits, if consistent with the standard permit conditions. USACE also has discretionary authority to require an Environmental Impact Statement for projects that result in impacts to an area between 0.1 and 0.5 acre. Use of any nationwide permit is contingent on the activities having no impacts to endangered species.

Federal Clean Water Act ‐ Section 401. Per Section 401 of the CWA, “any applicant for a Federal license or permit to conduct any activity including, but not limited to, the construction or operation of facilities, which may result in any discharge into the navigable waters, shall provide the licensing or permitting agency a certification from the State in which the discharge originates or will originate, or, if appropriate, from the interstate water pollution control agency having jurisdiction over the navigable waters at the point where the discharge originates or will originate, that any such discharge will comply with the applicable provisions of sections 1311, 1312, 1313, 1316, and 1317 of this title” (33 U.S.C.A. § 1341(a)(1) ). Therefore, before the USACE will issue a Section 404 permit, applicants must apply for and receive a Section 401 water quality certification from the RWQCB.

Waters of the United States. USACE has primary federal responsibility for administering regulations that concern “waters of the U.S.” The Corps acts under two statutory authorities, the Rivers and Harbors Act (Sections 9 and 10), which governs specified activities in “navigable waters of the U.S.,” and the Clean Water Act (CWA) (Section 404), which governs specified activities in “other waters of the U.S.,” including wetlands. The Corps requires that a permit be obtained if a project proposes placing structures within, over, or under navigable waters or discharging dredged or fill material into “waters of the U.S.” below the ordinary high-water mark in non-tidal waters. The U.S. Environmental Protection Agency (USEPA), USFWS, NMFS, and several other agencies can provide comments on Corps permit applications.

The federal government defines wetlands in CWA Section 404 as “areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support (and do support, under normal circumstances) a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR § 328.3(b) and 40 CFR § 230.3). The federal definition of wetlands requires three wetland identification parameters to be present: wetland hydrology, hydric soils, and hydrophytic vegetation.

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“Other waters of the U.S.” refers to those hydric features that are regulated by the CWA but are not wetlands (33 CFR § 328.4). To be considered jurisdictional, these features must exhibit a defined bed and bank and an ordinary high-water mark. Examples of other waters of the U.S. include rivers, creeks, intermittent and ephemeral channels, ponds, and lakes. Human-made wetland areas that are not regulated under this act include stock watering ponds and created water treatment facilities.

Migratory Bird Treaty Act. The Migratory Bird Treaty Act (MBTA) protects all common wild birds found in the United States (U.S.) except the house sparrow, starling, feral pigeon, and resident game birds such as pheasant, grouse, quail, and wild turkey. Resident game birds are managed separately by each state. Under the MBTA, “it shall be unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture, kill, attempt to take, capture, or kill, possess, offer for sale, sell, offer to barter, barter, offer to purchase, purchase, deliver for shipment, ship, export, import, cause to be shipped, exported, or imported, deliver for transportation, transport or cause to be transported, carry or cause to be carried, or receive for shipment, transportation, carriage, or export, any migratory bird, any part, nest, or egg of any such bird, or any product, whether or not manufactured, which consists, or is composed in whole or part, of any such bird or any part, nest, or egg thereof …” (16 U.S.C.A. § 703(a)).

4.4.2.2 State Policies and Regulations
California Endangered Species Act. The California Department of Fish and Wildlife (CDFW) administers the California Endangered Species Act (CESA). CESA applies to “endangered” or “threatened” birds, mammals, fish, amphibians, reptiles, and plants, but does not apply to insects (see 81 Cal. Op. Att'y Gen. 222 (1998)). The State of California considers an “endangered” species one whose prospects of survival and reproduction are in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease. Any species determined by the commission as “endangered” on or before January 1, 1985, is an “endangered species.” A “threatened” species is one present in such small numbers throughout its range that it is likely to become an endangered species in the foreseeable future in the absence of special protection or management. The California Endangered Species Act of 1970 created the categories of “Endangered” and “Rare.” The California Endangered Species Act of 1984 created the categories of “Endangered” and “Threatened.” On January 1, 1985, all animal species designated as “Rare” were reclassified as “Threatened” (see Fish and Game Code § 2067).

Section 2080 of the Fish and Game Code prohibits “take” of any species that the commission determines to be an endangered species or a threatened species. Take is defined in Section 86 of the Fish and Game Code as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” CESA allows for take incidental to otherwise lawful development projects. CESA emphasizes early consultation to avoid potential impacts to rare, endangered, and threatened species and to develop appropriate mitigation planning to offset project caused losses of listed species populations and their essential habitats.
“Candidate species” means a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for

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which the commission has published a notice of proposed regulation to add the species to either list (Fish and Game Code § 2068).

The CDFW exercises authority over mitigation projects involving State‐listed species, including those resulting from CEQA mitigation requirements. Lead agencies are directed by the CESA to consult with the CDFW on projects or actions that could affect listed species. A “taking” may be authorized by the CDFW if an approved habitat management plan or management agreement that avoids or compensates for possible jeopardy is implemented. In addition, the CDFW requires preparation of mitigation plans in accordance with published guidelines.

California Department of Fish and Wildlife “Species of Special Concern.” A Species of Special Concern (SSC) is a species, subspecies, or distinct population of an animal (i.e., fish, amphibian, reptile, bird and mammal) native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
• is extirpated from the State or, in the case of birds, in its primary seasonal or breeding role; • is listed as Federally-, but not State-, threatened or endangered; • meets the State definition of threatened or endangered but has not formally been listed; • is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status;
• has naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for State threatened or endangered status.

SSCs tend to have a number of factors in common, including that they:
• occur in small, isolated populations or in fragmented habitat, and are threatened by further isolation and population reduction;
• show marked population declines;
• depend on a habitat that has shown substantial historical or recent declines in size and/or quality or integrity;
• have few California records, or which historically occurred in the State but for which there are no recent records; and
• occur largely in areas where current management practices are inconsistent with the animal's persistence.
“Species of Special Concern” is an administrative designation that carries no formal legal status per se, but signifies that the species is recognized as sensitive by the CDFW. Section 15380 of the CEQA

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Guidelines clearly indicates that species of special concern should be included in an analysis of project impacts if they can be shown to meet the criteria of sensitivity outlined therein.

California Native Plant Protection Act. In 1977, the Legislature formally recognized the status of rare or endangered plants with the passage of the Native Plant Protection Act (NPPA) (Fish and Game Code, Section 1900 et seq.). The NPPA directed the CDFW to preserve, protect, and enhance rare and endangered plants in California. The NPPA also authorized the Fish and Game Commission to designate native plants as “rare” or “endangered” and to require permits for collecting, transporting, or selling such plants.

Under Section 1901 of the Fish and Game Code, “native plant” means a plant growing in a wild uncultivated state, which is normally found native to the plant life of this state. A species, subspecies, or variety is considered “endangered” when its prospects of survival and reproduction are in immediate jeopardy from one or more causes. A species, subspecies, or variety is considered “rare” when, although not presently threatened with extinction, it is in such small numbers throughout its range that it may become endangered if its present environment worsens.

Under Section 1913(c) of the NPPA, the owner of land where a rare or endangered native plant is growing is required to notify the department at least 10 days in advance of changing the land use to allow for salvage of plant.

Fish and Wildlife Protection - California Fish and Game Code, Sections 1600 to 1603. The California Fish and Game Code mandates that “it is unlawful for any person to substantially divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake designated by the department, or use any material from the streambeds, without first notifying the department of such activity.” CDFW jurisdiction includes ephemeral, intermittent, and perennial watercourses, including dry washes, characterized by the presence of hydrophytic vegetation, the location of definable bed and banks, and the presence of existing fish or wildlife resources.

Furthermore, CDFW jurisdiction is often extended to habitats adjacent to watercourses, such as oak woodlands in canyon bottoms or willow woodlands that function as part of the riparian system.

Historic court cases have further extended CDFW jurisdiction to include watercourses that seemingly disappear, but re-emerge elsewhere. Under the CDFW definition, a watercourse need not exhibit evidence of an OHWM to be claimed as jurisdiction. However, CDFW does not regulate isolated wetlands; that is, those that are not associated with a river, stream, or lake.

Porter‐Cologne Water Quality Act. The RWQCB regulates actions that would involve “discharging waste, or proposing to discharge waste, within any region that could affect the water of the state” (Water Code Section 13260(a)), pursuant to provisions of the Porter-Cologne Water Quality Act. “Waters of the State” are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state” (Water Code Section 13050 (e)).

Regional Water Quality Control Board Regulated Activities. Under Section 401 of the CWA, the RWQCB regulates all activities that are regulated by the USACE. Additionally, under the Porter- Cologne Water Quality Act, the RWQCB regulates all activities, including dredging, filling, or

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discharge of materials into waters of the state that are not regulated by the USACE due to a lack of connectivity with a navigable water body and/or lack of an OHWM.

California Fish and Game Code ‐ Section 3503 and Section 3511. The CDFW administers the California Fish and Game Code. There are particular sections of the Fish and Game Code that are applicable to natural resource management. For example, Section 3503 of the Fish and Game Code states it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird that is protected under the MBTA. Fish and Game Code Section 3503.5 further protects all birds in the orders Falconiformes and Strigiformes, birds of prey such as hawks and owls, and their eggs and nests, from any form of take. Disturbance that causes nest abandonment and/or loss of reproductive effort is also considered a “taking” by the CDFW. Fish and Game Code Section 3511 lists fully protected bird species where the CDFW is unable to authorize the issuance of permits or licenses to take these species.

Natural Community Conservation Planning Act ‐ Fish and Game Code Sections 2800 et seq. The State of California has adopted the Natural Community Conservation Planning and Habitat Conservation Planning (NCCP/HCP) program to focus on creating a multiple-species, multiple-habitat subregional Reserve System and implementing a long-term “adaptive management” program. To accomplish this, the NCCP/HCP creates a subregional habitat Reserve System and implements a coordinated program to manage biological resources within the habitat reserve. The creating of a defined Reserve System provides certainty to the public and to affected landowners with respect to the location of future development and open space within the subregion. The NCCP/HCP was developed with coordination through the CDFW and the USFWS, in order to account for the CESA and the federal ESA. The City of Fresno does not occur within any NCCP/HCP designated area.

California Native Plant Society. The California Native Plant Society (CNPS) maintains a list of plant species native to California that have low numbers, limited distribution, or are otherwise threatened with extinction. This information is published in the Inventory of Rare and Endangered Plants of California. Potential impacts to populations of CNPS-listed plants require consideration under CEQA.

The following identifies the definitions of the California Rare Plant Ranks (formerly known as the CNPS lists):
• California Rare Plant Rank 1A: Plants believed extirpated in California and either rare or extinct elsewhere.
• California Rare Plant Rank 1B: Plants rare, threatened, or endangered in California and elsewhere.
• California Rare Plant Rank 2A: Plants presumed extirpated in California, but more common elsewhere.
• California Rare Plant Rank 2B: Plants rare threatened or endangered in California but more common elsewhere.

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• California Rare Plant Rank 3: Plants about which more information is needed ‐ a review list. • California Rare Plant Rank 4: Plants of limited distribution – a watch list.

The CNPS Threat Rank is an extension added onto the California Rare Plant Rank, which designates the level of threats by a 1 to 3 ranking, with 1 being the most threatened and 3 being the least threatened. Each threat rank is defined as follows:
• 0.1-Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat).
• 0.2-Moderately threatened in California (20 - 80% occurrences threatened / moderate degree and immediacy of threat).
• 0.3-Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known).

4.4.2.3 Local Policies and Regulations
County of Fresno. The County of Fresno Open Space and Conservation Element of the General Plan is concerned with protecting and preserving natural resources, preserving open space areas, managing the production of commodity resources, protecting and enhancing cultural resources, and providing recreational opportunities.

The Open Space and Conservation Element sets out goals, policies, and implementation measures under three main headings: Productive Resources, Natural Resources, and Recreation and Cultural Resources. Productive Resources encompasses three sections: Water Resources, Forest Resources, and Mineral Resources. Natural Resources encompass four sections: Wetland and Riparian Areas, Fish and Wildlife Habitat, Vegetation and Air Quality. The Recreation and Cultural Resources sections encompass: Parks and Recreation, Recreational Trails, Cultural, Geologic Resources, Scenic Resources, and Scenic Roadways.

City of Fresno Regulations. The guidelines outlined in the City of Fresno General Plan and Municipal Code ensure project level compliance with all applicable state and federal regulations.

General Plan
Parks, Open Space, and Schools Element
Objective POSS-5. Provide for long-term preservation, enhancement, and enjoyment of plant, wildlife, and aquatic habitat.

Policy POSS‐5‐c: Buffers for Natural Areas. Require development projects, where appro- priate and warranted, to incorporate natural features (such as ponds, hedgerows, and wooded strips) to serve as buffers for adjacent natural areas with high ecological value.

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Policy POSS‐5‐d: Guidelines for Habitat Conservation. Establish guidelines for habitat conservation and mitigation programs, including:
• Protocols for the evaluation of a site’s environmental setting and proposed design and operating parameters of proposed mitigation measures.
• Methodology for the analysis depiction of land to be acquired or set aside for mitigation activities.
• Parameters for specification of the types and sources of plant material used for any re- vegetation, irrigation requirements, and post-planting maintenance and other operational measures to ensure successful mitigation.
• Monitoring at an appropriate frequency by qualified personnel and reporting of data collected to permitting agencies.

Objective POSS‐6. Maintain and restore, where feasible, the ecological values of the San Joaquin River corridor.

Policy POSS‐6‐b: Effects of Stormwater Discharge. Support efforts to identify and mitigate cumulative adverse effects on aquatic life from stormwater discharge to the San Joaquin River.
• Avoid discharge of runoff from urban uses to the San Joaquin River or other riparian corridors.
• Approve development on sites having drainage (directly or indirectly) to the San Joaquin River or other riparian areas only upon a finding that adequate measures for preventing pollution of natural bodies of water from their runoff will be implemented. • Periodically monitor water quality and sediments near drainage outfalls to riparian areas. Institute remedial measures promptly if unacceptable levels of contaminant(s) occur.

Objective POSS‐7. Support the San Joaquin River Conservancy in its collaborative, multiagency efforts to develop the San Joaquin River Parkway.

Policy POSS‐7‐d: Buffer Zones near Intensive Uses. Protect natural reserve areas and wildlife corridor areas in the San Joaquin River corridor whenever more intensive human uses exist or are proposed on adjacent lands. Use buffer zones to allow multiple uses on parts of the parkway while still protecting wildlife and native plants. • Require studies of appropriate buffer widths to be approved by State and federal wildlife agencies before variances from standard buffer zone widths are granted.

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• Maintain natural riparian buffer zones with appropriate native plants (seed material and cuttings locally derived).
• Incorporate open space uses such as pasture, low-intensity agricultural activities, and the “rough” or marginal areas of golf courses, into buffer zones when they constitute an improvement in habitat over a previous use or degraded area. Evaluate and address the potential impacts of construction, cultural, and operational practices (such as grading, number of livestock per acre, lighting, and use of pesticides, herbicides, and fertilizers) before these uses are be approved for buffering.
• For nearby areas of the San Joaquin River corridor outside of the exclusive jurisdiction of the City, support efforts to work with other jurisdictions to achieve this policy.

Municipal Code. Chapter 13, Article 3 Street Trees and Parkways. This section of the municipal code provides guidelines and requirements for the preservation and protection existing street trees, as well as guidelines establishing the installation of city-owned trees along streets.

4.4.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to biological resources that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less-than-significant level.

Cumulative impacts are also addressed.

4.4.3.1 Significance Criteria
Based on CEQA Guidelines Appendix G, the proposed project would have a significant impact on biological resources if it would:

1. 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 U.S. Fish and Wildlife Service;

2. 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 Wildlife or US Fish and Wildlife Service;

3. 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;

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4. 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;

5. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance;

6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

4.4.3.2 Project Impacts
The following discussion describes the potential impacts related to biological resources that could result from implementation of the proposed project.

BIO-1 The proposed project could 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 U.S. Fish and Wildlife Service.

As stated above, several special-status plant and wildlife species have been recorded within Fresno.

The proposed program would establish a VMT mitigation mechanism for future development projects that exceed the City’s VMT thresholds in the form of a mitigation fee. As such, the program would fund VMT-reducing transportation improvements within the City. Potential improvements would primarily occur within existing rights-of-way or within the development footprint of future development projects and thus, would likely avoid adverse impacts to sensitive special-status species. While future transportation improvement projects funded by the program would be largely focused within developed areas, the proposed improvements could still adversely impact sensitive special-status species. Future transportation improvements would be City-initiated projects or implemented as part of future development projects and would require environmental review under CEQA (e.g., preparation of a Categorical Exemption, Mitigated Negative Declaration, or Environmental Impact Report). Additionally, per Mitigation Measure BIO-1, a Biological Resources Assessment may be required, as determined by the City, to evaluate potential impacts to on-site biological resources, including sensitive or special-status species. As such, future VMT-reducing improvements would be evaluated on a project-specific level with site-specific analysis and mitigation measures would be identified, as needed. Thus, the proposed program would not result in significant impacts to sensitive special-status species.

Mitigation Measure BIO-1 Transportation improvements funded by the proposed Vehicle Miles Traveled Reduction Program subject to California
Environmental Quality Act (CEQA) review, and with the potential to reduce or eliminate habitat for native plant and wildlife species or sensitive habitats, shall provide a Biological Resources Assessment prepared by a qualified biologist for review and approval by the City of Fresno. The assessment shall include biological field survey(s) of the project site to characterize the extent and quality of habitat that

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would be impacted by development. Surveys shall be conducted by qualified biologists and/or botanists in accordance with California Department of Fish and Wildlife and/or United States Fish and Wildlife Services survey protocols for target species. If no special status/sensitive species, sensitive habitats/natural communities, or federally protected wetlands are observed during the field survey, then no further mitigation will be required. If biological resources are documented on the project site, the project proponent shall comply with the applicable requirements of the regulatory agencies and shall apply mitigation determined through the agency permitting process.

Level of Significance: Less Than Significant Impact with Mitigation Incorporated.

BIO-2 The proposed project could 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 Wildlife or US Fish and Wildlife Service.

Several locations within the Planning Area support riparian or wetland vegetation. As stated, the majority of future transportation improvements funded by the proposed program would occur within existing disturbed rights-of-way and thus, avoid impacts to riparian habitat or other sensitive natural communities within Fresno. While future transportation improvement projects funded by the program would be largely focused within developed areas, the proposed improvements could still have the potential to adversely impact riparian habitat or other sensitive natural communities.

All future transportation improvements, including those implemented as part of future development projects, would be required to undergo environmental review under CEQA. Additionally, as stated, a Biological Resources Assessment may be required, as determined by the City, to evaluate potential impacts to on-site biological resources, including riparian habitat or other sensitive natural communities; refer to Mitigation Measure BIO-1. Thus, future improvements funded by the proposed mitigation program would be evaluated on a project-specific level with site-specific analysis and implement mitigation measures, as needed. Impacts to riparian habitat or other sensitive natural communities associated with the proposed program would be less than significant.

Mitigation Measures: Refer to Mitigation Measure BIO-1.

Level of Significance: Less Than Significant Impact with Mitigation Incorporated.

BIO-3 The project would 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.

As stated, several locations within the project area support riparian or wetland vegetation. The majority of future transportation improvements funded by the proposed program would occur within existing rights-of-way in developed areas of the City and not impact Federally protected

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wetlands. Nevertheless, all future transportation improvements, including those implemented as part of future development projects, would be required to undergo project-level environmental review under CEQA and be evaluated on a project-specific level with site-specific analysis and implement mitigation measures, as needed. A Biological Resources Assessment may be required, as determined by the City, to evaluate potential impacts to on-site biological resources, including Federally protected wetlands; refer to Mitigation Measure BIO-1. Impacts to wetland habitat are regulated by the USACE pursuant to Section 404 of the CWA, RWQCB in accordance with Section 401 of the CWA, and CDFW under Section 1600 of California Fish and Game Code. Thus, future transportation improvements would be required to comply with existing regulatory requirements in this regard. Overall, impacts to Federally protected wetlands from the proposed VMT Reduction Program would be less than significant.

Mitigation Measures: Refer to Mitigation Measure BIO-1.

Level of Significance: Less Than Significant Impact with Mitigation Incorporated.

BIO-4 The project could 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.

Wildlife corridors are key features for wildlife movement between habitat patches and are generally defined as those areas that provide opportunities for individuals or local populations to conduct seasonal migrations, permanent dispersals, or daily commutes. Wildlife corridors are typically larger expanses of undeveloped areas. The majority of future transportation improvements funded by the proposed program would occur within existing rights-of-way in developed areas of the City and thus, would not adversely impact wildlife corridors or nursery sites. However, future transportation improvements implemented as part of future development projects may occur on sites with trees or be located adjacent to trees that could serve as nesting habitat for migratory birds. Therefore, there is potential to impact nesting birds if construction occurs during the avian nesting season (generally from February 1 through August 31). The MBTA, enforced by the USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. Thus, compliance with existing regulatory requirements would reduce impacts in this regard. Additionally, Mitigation Measure BIO-2 would require a pre- construction nesting bird clearance survey be conducted prior to ground disturbing activities associated with future transportation improvements. As stated, all future transportation improvements would also be required to undergo project-level environmental review under CEQA, be evaluated on a site-specific basis, and implement mitigation, as needed.

Mitigation Measure BIO-4 A pre-construction nesting bird clearance survey shall be conducted by a qualified biologist no more than fourteen (14) days prior to the start of any vegetation removal or ground disturbing activities associated with a transportation improvement project. The survey shall be conducted by a qualified biologist and cover all suitable nesting habitat within the project impact area, and areas within a biologically defensible buffer zone surrounding the project impact area. Further, if an active bird nest is found, the qualified biologist

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should identify the specific bird species and establish a “no- disturbance” buffer around the active nest to avoid potential direct and indirect impacts. It is further recommended that the qualified biologist periodically monitor any active bird nests to determine if project-related activities disturb the birds and if the “no disturbance” buffer should be increased. Once the young have fledged and left the nest, or the nest otherwise becomes inactive under natural conditions, project activities within the “no- disturbance” buffer may occur following an additional survey by the qualified biologist to search for any new nests in the restricted area.

Level of Significance: Less Than Significant Impact With Mitigation Incorporated.

BIO-5 The project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Several local policies and ordinances protect biological resources within the project area, including the General Plan and Municipal Code. The majority of future transportation improvements funded by the proposed program would occur within existing rights-of-way in developed areas of the City.

Future transportation improvements, including those implemented as part of future development projects, would be required to undergo separate environmental review under CEQA with project- specific analysis and mitigation measures, as needed. Thus, compliance with existing regulatory requirements related to the protection of biological resources would reduce impacts to less than significant levels.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

BIO-6 The project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

The Planning Area is not located within the boundaries of any approved or draft Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other adopted local, regional or state HCP. Therefore, development within the Planning Area would not result in any impacts to an adopted HCP or NCCP.

The Pacific Gas & Electric (PG&E) San Joaquin Valley Operation and Maintenance (O&M) Habitat Conservation Plan (HCP)
2 was approved in 2007 and covers portions of nine counties, including Fresno county and the city of Fresno. This HCP covers PG&E activities which occur as a result of ongoing O&M that would have an adverse impact on any species covered by the HCP. The HCP also

2 Pacific Gas & Electric. 2007. PG&E San Joaquin Valley Operation & Maintenance Habitat Conservation Plan. November.

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provides incidental take coverage from the USFWS and CDFW. The project site is not located within the covered area of any other HCP, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Mitigation Measures recommended in this EIR are largely consistent with the PG&E HCP in that site- specific analysis would be required to avoid and/or minimize potential impacts resulting from implementation of the proposed VMT Reduction Program and the PG&E HCP. 3 Because project specific analysis would be required for future transportation improvements, site- specific analysis is required under the small-scale temporary effects required for operation and maintenance activities under the PG&E HCP. Therefore, the proposed VMT Reduction Program would not conflict with the provisions of the PG&E HCP and the proposed project and would have a less-than-significant impact.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

4.4.3.3 Cumulative Impacts
CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with future buildout of the General Plan; refer to Table 4- 1, General Plan 2030 – GPCAC Preferred Land Use Plan Alternative Buildout.

BIO-7 The project, in combination with other projects, could contribute to a significant cumulative impact related to biological resources.

Cumulatively Considerable Impacts to Candidate, Sensitive, or Special Status Species or Riparian Habitat in Local or Regional Plans, Policies, or Regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Additionally, per Mitigation Measure BIO-1, a Biological Resources Assessment may be required, as determined by the City, to evaluate potential impacts to on-site biological resources, including sensitive or special-status species, riparian habitat and sensitive natural communities.

3 Ibid.

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As a result, the proposed VMT Reduction Program itself would not result in cumulatively considerable impacts to sensitive special-status species. Impacts in this regard would be less than significant.

Cumulatively Considerable Impacts to Federally Protected Wetlands.

Future cumulative development projects developed in accordance with the General Plan would be required to undergo project-specific environmental review under CEQA and the City’s discretionary review process to determine potential impacts to Federally protected wetlands and any required mitigation. Similar to the proposed project, cumulative projects would also be required to comply with existing regulatory requirements governed by the USACE under Section 404 of the CWA, RWQCB under Section 401 of the CWA, and CDFW under Section 1600 of California Fish and Game Code. As stated, all future transportation improvements funded by the proposed program would be required to undergo separate environmental review under CEQA. Additionally, a Biological Resources Assessment may be required, as determined by the City, to evaluate potential impacts to on-site biological resources, including Federally protected wetlands; refer to Mitigation Measure BIO-1. Thus, the proposed program would not result in cumulatively considerable impacts to Federally protected wetlands and impacts in this regard would be less than significant.

Cumulatively Considerable Impacts to the Movement of Native Resident or Migratory Fish Or Wildlife Species.

Future cumulative development projects developed in accordance with the General Plan would be required to undergo project-specific environmental review under CEQA and the City’s discretionary review process to determine potential impacts to the movement of native resident or migratory fish or wildlife species and any required mitigation. Future projects would also be required to comply with existing regulation requirements, including the MBTA. As stated, all future transportation improvements funded by the proposed program would be required to undergo separate environmental review under CEQA. Mitigation Measure BIO-2 would require a pre-construction nesting bird clearance survey be conducted prior to construction activities associated with future transportation improvements. Thus, upon compliance with existing regulations and Mitigation Measure BIO-2, future transportation improvements, in conjunction with cumulative projects, would result in less than significant cumulative impacts.

Conflict with Local Policies or Ordinances Protecting Biological Resources Future cumulative development projects developed in accordance with the General Plan would be required to undergo project-specific environmental review under CEQA and the City’s discretionary review process to determine potential impacts to local policies or ordinances protecting biological resources and any required mitigation. Similar to future transportation improvements implemented in accordance with the proposed program, cumulative project would also be required to comply with existing local policies protecting biological resources. As stated, all future transportation improvements funded by the proposed program would be required to undergo separate environmental review under CEQA and comply with existing local policies protecting biological resources. Thus, cumulative impacts in this regard would be less than significant.

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Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

As discussed in under BIO-6, cumulative development resulting from continued implementation of the approved General Plan within the PG&E HCP would not result in any impacts to the HCP.

Therefore, the proposed project would result in no cumulative impacts regarding HCPs.

Mitigation Measures: Refer to Mitigation Measure BIO-1 and Mitigation Measure BIO-2.

Level of Significance: Less Than Significant Impact with Mitigation Incorporated.

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4.5 CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES
This section describes the baseline conditions for cultural resources in the project area, identiﬁes potentially signiﬁcant impacts to cultural resources that may result from project implementation, and recommends mitigation measures to reduce the severity of potentially signiﬁcant impacts.

4.5.1 Existing Environment Setting
The study area for cultural resources for the proposed project is the City of Fresno Planning Area, given that implementation of the proposed project would be limited to areas within the Planning Area.

Cultural resources include prehistoric-era archaeological sites, historic-era archaeological sites, Native American traditional cultural properties, sites of religious and cultural signiﬁcance, and historical buildings, structures, objects, and sites. The importance of any single cultural resource is deﬁned by the context in which it was ﬁrst created, current public opinion and modern yet evolving analysis. From the analytical perspective, temporal and geographic considerations help to deﬁne the historical context of the Planning Area. The importance or signiﬁcance of a cultural resource is in part described by the context in which it originated or developed. National Park Service Bulletin 16a 1 describes a historic context as “information about historic trends and properties grouped by an important theme in prehistory or history of a community, state, or the nation during a particular period of time.” A context links an existing property to important historic trends and this allows a framework for determining the signiﬁcance of a property. Given this, a major goal of the historian is to determine accurate themes of analysis, a task that can only be undertaken by a thorough review of previous researchers’ thoughts and ideas, as well as reviewing the literature of the resources.

In California, historians have divided the past into broad categories based on climate models, archaeological dating and written histories. Paleontologists divide time into much larger segments, with deﬁned and named periods of time shortening in timespan as the modern era is reached. For the purposes of this analysis, these periods in history have been summarized below.

4.5.1.1 Prehistoric Era
To better understand the past, archaeologists develop models of prehistoric resource chronologies and description of lifestyles based on data collected at the archaeological sites they investigate.

Models of prehistoric lifeways were developed from archaeological research and ethnographic information. As more archaeological data is brought forth, the models are reﬁned and reinterpreted.

1 National Park Service. 1997. Bulletin 16a. Available online at: www.nps.gov/subjects/nationalregister/ upload/NRB16A-Complete.pdf (accessed December 10, 2024).

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Unfortunately, prehistoric archaeological investigations are very limited in the Fresno area. Indeed, the San Joaquin River section of the middle and lower San Joaquin Valley is identiﬁed by many researchers to be one of the least understood areas of the State. 2 For this reason, the prehistoric
background review in this section is derived from several regional reports of recent publication.

General information associated with Fresno County and San Joaquin Valley regional archaeology has been derived from several sources.
3,4,5 Prehistoric background information regarding near-city cultural resource projects has been derived several sources, as well.6,7,8 Bennyhoﬀ and Fredrickson’s Central California Taxonomic System9 has in the past been used to form descriptions of the temporal background for certain projects in Fresno County. A more generalized systemic description is provided here because many of the archaeological elements supporting the CCTS have not been uncovered in the Planning Area. Part of the challenge associated with archaeological research in this area is that the eastern side of the San Joaquin Valley has been farmed for generations and farming tends to destroy the surface signatures of most prehistoric sites.

Terminal Pleistocene (13,500 to 11,000 BP [Before Present]). About 14,000 years ago, California was a much wetter and cooler place, but with the retreat of continental Pleistocene glaciers, the whole of California except the northwest coast saw a warming and drying trend. Large shallow lakes ﬁlled with glacial meltwater were located in the Central Valley and used by populations of large game animals, most of which are now extinct. The waters in these pluvial lakes rose and fell with the season, but were unlikely to have dried completely. A few prehistoric sites have been discovered near the southwestern shore of Tulare Lake, but none in or near the Planning Area and none in the middle San Joaquin Valley. Native American populations were probably widely dispersed hunter- gatherers, and their archaeological assemblages would have consisted of large projectile points with distinctive “ﬂuted” styles and deeply buried features with animal fragments. Such sites would likely be discovered on Late Pleistocene-dated ground surfaces. Within the city, these surfaces are not exposed at the ground surface and would quite probably be deeply buried.

Early and Middle Holocene (11,000 to 7,000 BP - 7,000 to 3,800 BP). Historical analysis set forth the argument that land located between the ﬂoodplain of the middle and lower San Joaquin Valley and the lower foothills is covered with a recent and thick blanket (30 feet or more) of alluvium derived

2 Rosenthal, Jeﬀrey S., et al. 2007. The Central Valley: A View from the Catbird’s Seat. In California Prehistory: Colonization, Cultural, and Complexity.
3 Moratto, Michael J. 1984. California Archaeology.
4 Fagan, Brian. 2003. Before California. Landham, MD: Rowman & Littleﬁeld. 5 Arnold, et al. 2004. The Archaeology of California. Journal of Archaeological Research 12:1-73. 6 Rosenthal, Jeﬀrey S., et al. 2007. The Central Valley: A View from the Catbird’s Seat. In California Prehistory: Colonization, Cultural, and Complexity.
7 San Joaquin River Restoration Program (SJRRP). 2011. San Joaquin River Restoration Program Draft Program Environmental Impact Statement/Environmental Impact Report. Available online at:
www.usbr.gov/mp/nepa/includes/documentShow.php?Doc_ID=7557 (accessed December 10, 2024). 8 California High Speed Rail Authority. 2012. California High-Speed Train Project EIR/EIS Merced to Fresno Section.
9 Hughes, Richard E. 1994. Toward a New Taxonomic Framework for Central California Archaeology: Essays by James A. Bennyhoﬀ and David A. Frederickson. Contributions of the University of California Archaeological Research Facility, No. 52. Berkeley.

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from a post-Pleistocene erosion of the western Sierras. Thus, while a few sites from the early Holocene periods are found in upland environments, there are no such dated sites in or very near the Planning Area.

Sites in the nearby foothills exhibit groundstone assemblages suggesting that acorns and pine nuts were harvested when ripe by bands of mobile groups. Comparative ethnographic data suggests that mobile peoples with a seasonal round may have created a home base (village) in winter during these periods, then travelled to exploit pockets of certain resources in temporary encampments. This type of lifeway was likely common for most California peoples except those on the North Coast, and probably continued in a like fashion throughout the Early and Middle Holocene. Diﬀerences in lowland and upland sites emerged about 4,500 BP giving the regional populations distinct patterns.

Lowland groups may have predominated in the Fresno area during the late Middle Holocene and archaeological sites dated to this time would likely exhibit foodstuﬀ and processing tools more focused on lakeshore resources than grinding implements seen in upland sites. Soil strata found in the northwestern portion of the city has been deﬁned as a Late Pleistocene non-marine alluvial fan covered with a veneer of late Holocene soil. In general, early and Middle Holocene alluvial deposits with cultural resources in them would typically be exposed only after several feet of soil has been removed. Soils near active stream channels are younger and are less likely to exhibit sites from this period except on intact dunes and at some depth. Thus, sites from this period are likely located in the Planning Area, but are more likely to be found at depth after a disturbed topsoil horizon has been removed.

Late Holocene (3,800 to 1,500 BP). This period saw an increase in the number of sites and evidence for an increased sophistication in the toolkit of the local prehistoric groups. Archaeologists often interpret increases in the number of sites dated to a certain period as reﬂecting an increase in population. Populations existing on ﬂatter areas between braided stream channels near the city and those along the major riverine systems in the middle San Joaquin Valley probably concentrated their lifeways on marsh-based resources. Evidence for trading networks between nearby groups is robust.

The quantity of sites near the south bank of the San Joaquin River (in and near the city limits) is large and several have been investigated.
10 Archaeologists seldom excavate buried sites exhibiting data that might allow a determination of whether or not a prehistoric site “belongs” to one ethnographic group or another, but at the end of this period cultural groups possessing Great Basin-style toolkits began to arrive in California and appear to have begun inﬂuencing and/or merging with the existing populations. Local sites saw changes in the toolkit with an overall reduction of projectile point size suggestive of bow and arrow technologies. Previous studies suggest that at about 2,300 years ago, large villages were clustered along the banks of the San Joaquin River and other watersheds (winter villages).
11 Structured social hierarchies are inferred in the archaeological data. Evidence for Late Holocene deposits in and very near the city limits is likely. These would lie upon buried alluvial fans and riverine deposits at shallow depths, and possibly near the exposed surface of vacant properties.

10 Rosenthal, Jeﬀrey S., et al. 2007. The Central Valley: A View from the Catbird’s Seat. In California Prehistory: Colonization, Cultural, and Complexity.
11 Ibid.

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Late Prehistoric (1,500 BP to Contact with the Spanish). With the introduction of Great Basin populations into the Eastern Sierras of California at the beginning of the Late Prehistoric, many of the ancestral California tribes were inﬂuenced by their toolkits and lifestyles. Part of this interpretation is derived from linguistic studies. The Yokuts were Penutian speakers, which appear to have arrived earlier, and many of the tribes to the east and southeast were newly arrived Takic or Uto-Aztecan speakers.
12 The Takic speakers exhibited toolkits and lifeways adapted to desert climates. Bow and arrow technologies and the use of pottery are found in sites dating to this period.

This period was the zenith of prehistoric California life, with an increase in sophisticated lifestyles, extensive trade networks, and a burgeoning population. The end of the period saw the introduction of Europeans and their diseases of which the local tribes had little defense or resistance. For more information on the Yokuts, see the ethnographic section below.

4.5.1.2 Ethnographic Overview
At the time of European contact, most of the San Joaquin Valley and the foothills of the western slope of the Sierra Nevada were occupied by 40 or so groups classiﬁed together as the Yokuts with a Foothills division and a Valley division of language dialects. 13 The Yokuts were recognized as having
three major subgroups: the Northern Valley, the Foothill, and the Southern Valley. Each of these ethnolinguistic groups was composed of autonomous, culturally and linguistically related tribes or tribelets. Ethnographic evidence suggests the city is located in part of the Southern Valley Yokuts territory.

Alfred Kroeber divided a Yokuts classiﬁcation system into Valley Divisions and Foothill Divisions based on ethnographic lines, geographic habitat, and dialect. 14 Here, the Foothill Division’s worldview and
economy were inﬂuenced more by their Shoshonean neighbors than the Valley Division Yokuts.

Later, William Wallace divided the Yokuts into three subgroups, Southern Valley, Northern Valley, and Foothill, and shifted the known tribelets among these divisions. 15 The following is a review of
ethnographic information associated with the Southern Valley Yokuts.

The Southern Valley Yokuts occupied a rich environment with abundant water resources from the nearby sloughs, lake basins, and river systems. Swamps and tule marshes surrounded the waterways and teemed with wildlife, including aquatic mammals, ﬁsh, and waterfowl. Adjacent grasslands provided food for herds of elk, antelope, and (in the winter) deer. The regional ﬂora was equally, if not more, diverse and was used as a main staple of the Yokuts diet. The Southern Valley Yokuts dietary base relied on a mixed strategy of ﬁshing, waterfowl hunting, shellﬁsh, and plant collecting, with less emphasis on large-game hunting. Important vegetal resources included cattail roots,

12 Kroeber. A. L. 1925. Handbook of the Indians of California (1976 Diver Edition). Bureau of American Ethnology Bulletin 76, Smithsonian Institution, Washington D.C. 13 Wallace, William J. 1978. Southern Valley Yokuts. In Handbook of North American Indians, Vol 8, California.

Smithsonian Institution, Washington D.C.
14 Kroeber. A. L. 1925. Handbook of the Indians of California (1976 Diver Edition). Bureau of American Ethnology Bulletin 76, Smithsonian Institution, Washington D.C. 15 Wallace, William J. 1978. Southern Valley Yokuts. In Handbook of North American Indians, Vol 8, California.

Smithsonian Institution, Washington D.C.

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grasses, nuts, seeds, tule, and bulbs. The resource-rich environment allowed for permanent village sites, which typically were occupied throughout the year.

Resources not found in the local environment were obtained through an extensive trade network, which had begun to develop during the Late Holocene. Quality stone and wood were lacking in the Valley environment and were often acquired through trade with nearby tribes. Imported items included acorns, salt, obsidian, and seashells, which were exchanged for locally available asphaltum, steatite, and animal skins. The material culture of the Southern Valley Yokuts included structures, watercraft, basketry, weapons, and tools fashioned primarily from local resources. The ubiquitous tule was the primary component used for house construction and other ﬁber crafts such as basketry, mats, and cradles. Rafts were central to the economy base because of the abundance of waterways, which made watercraft the preferred mode of transportation. Wood, stone, and bone were commonly used to manufacture a variety of tools and weapons. Sweathouses were common to every settlement and, in the case of the Southern Valley Yokuts, were used exclusively by men on a daily basis.

The Southern Valley Yokuts were divided into true tribes, with individual tribelets having their own name, dialect, and territory. Typically, a tribelet was ruled by a central chief who inherited the position, was assisted by one or more aides, and lived in the largest village. The chief’s duties included decisions that aﬀected the well-being of the entire tribelet, sanctioning trade, entertaining guests, and arbitration of intra-tribal disputes. Marriage was typically informal, and patrilocality was the accepted practice following marriage. Thus, if a family had numerous sons, a circle of extended family members would inhabit the area immediately adjacent to the patriarch’s home. Polygamy was not objected to, but it was practiced solely by men. There is scant evidence that the Southern Valley Yokuts participated in a large number of organized religious ceremonies.

4.5.1.3 Historic Era
Gabriel Moraga was one of the ﬁrst Europeans to see and explore the Central Valley of California. In 1805, he was ordered by the Spanish Governor to send his cavalry into the Modesto area and Calaveras Rivers, naming both.
16 In 1806, he travelled past the Kings, Merced and Stanislaus watersheds, naming each river. In 1808, he was ordered into the Central Valley once again in search of potential new Mission sites and runaway neophytes. He named a tributary of the San Joaquin during this trip (San Joaquin Creek). It was later discovered that the creek fed into a larger river, which was named San Joaquin River. As Spanish California passed to Mexican control, American trappers increasing began to exploit the region’s resources and once gold was discovered, the population rush into California began, with mineral exploration in the mountains and foothills east of the Planning Area. During the latter half of the 19th century, the size of all Yokuts populations dwindled dramatically, due to the spread of European settlements and the diseases the Europeans brought with them.

Mexican Period. With the declaration of Mexican independence in 1821, Spanish control of Alta California ended, although little change actually occurred. Political change did not take place until

16 Bancroft, Hubert Howe. 1884-1890. History of California, 7 vols. The History Company, San Francisco, California.

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mission secularization in 1834, when Native Americans were released from missionary control and the mission lands were granted to private individuals. Researchers hypothesize that mission secularization removed the social protection and support on which Native Americans had come to rely. It exposed them to further exploitation by outside interests, often forcing them into a marginal existence as laborers for large ranchos. Following mission secularization, the Mexican population grew as the native population continued to decline. Anglo-American settlers began to arrive in Alta California during this period and often married into Mexican families, becoming Mexican citizens, which made them eligible to receive land grants. In 1846, on the eve of the Mexican-American War (1846 to 1848), the estimated population of Alta California was 8,000 non-natives and 10,000 natives. However, these estimates have been debated.
17 It is estimated that the Native American
population was 100,000 in 1850; the U.S. Census of 1880 reports the Native American population as 20,385.

American Expansion. In 1848, California became a United States territory as a result of the Treaty of Guadalupe Hidalgo. Also in 1848, John Marshall found gold at Sutter’s Mill, which marked the start of the Gold Rush. The inﬂux of miners and entrepreneurs increased the non-native population of California from 14,000 to 224,000 in just four years. In 1854, gold was discovered in the upper reaches of the Kern River, which brought a tremendous inﬂux of miners into eastern Kern County.

This, in turn, stimulated commercial growth in the central and lower San Joaquin Valley as eager entrepreneurs set up business to support the miners and mining operations. Gold and silver were mined along the San Joaquin but the deposits were not large. When the Gold Rush was over, many of the miners settled in the Central Valley communities and established farms, ranches, and lumber mills.

Local History. Mining opportunities allowed the development of very small communities along rivers and streams in the foothills and mountains east and northeast of the city. In 1856, Fresno County was created and the ﬁrst county seat was located in the foothill community of Millerton. In 1867, the San Joaquin River ﬂooded Millerton and several other small towns along its banks, causing locals to look for a safer place to build a trade center that could serve the whole of the foothills. Named for the Spanish word for “ash tree,” Fresno has its roots in the form of a large farm established in 1867 by A.Y . Easterby in an area of what is now central downtown. Moses Church, his partner, began building a water delivery system for this farm and others and began diverting water from the Kings River into the region via a series of ditches. By 1871, Easterby’s 5,000-acre ranch featured plots of wheat irrigated by these river-fed “Church ditches.” When Central Paciﬁc Railroad Company oﬃcials, including Leland J. Stanford, saw the Easterby farm in 1871, legend has it that Stanford declared the area the site of a stop for the new Central California Railroad (Southern Paciﬁc) line. This line was later referred to as the Southern Paciﬁc line, as the Central Paciﬁc Railroad Company became the Southern Paciﬁc Railroad Company in 1884.

Because the railroad followed a northwest-southeast track, the ﬁrst town site of Fresno Station was built on the Easterby farm paralleling the tracks in 1872, with the upslope portions (east) preferred for development. After locals realized Fresno Station would become the trading center for the area, development spread beyond the original Easterby plat, and began to be oriented toward roadways

17 Cook, S.F. 1976. The Population of the California Indians 1769-1970. University of California Press.

Berkeley, California.

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put in along Section lines in cardinal directions. The need for water to irrigate the arid San Joaquin Valley became a priority for the economic development of Central Valley towns such as Fresno.

Agriculture’s dominance over ranching was exhibited in 1873 when the California State Legislature passed the “No Fence Law.” Under this law, farmers were no longer obligated to put up fences to keep roaming livestock out of their crops; furthermore, any crop destruction became the responsibility of the rancher who owned the oﬀending livestock. Irrigation companies, colonies, and districts were formed in the vicinity of various small towns including Fresno to promote agriculture.

In 1875 the Central California Colony was established south of Fresno, which set the model for a system of development that was used throughout the San Joaquin Valley. Tracts of land were subdivided into 20-40 acre parcels, irrigated from a system of canals and often landscaped with boulevards of palms, eucalyptus or other drought-resistant trees. By 1903, there were 48 separate colonies or tracts in Fresno County which drew farmers and their families from Scandinavia and from across the United States.

Church’s Fresno Canal and Irrigation Company, a predecessor of the Fresno Irrigation District, began expanding in 1876 in response to locals moving into the area near the railroad stop; this became the ﬁrst extensive irrigation system in the Central Valley. Agricultural colonies were developed and water rights for those colonies established. The expanding irrigation system led to a shift in both the types of crops grown and the size of a typical farm. Pioneers initially grew wheat and other grain crops or raised cattle. As irrigation water became more readily available, individual farmers realized that premium crops like grapes, citrus, and tree fruit could be proﬁtably grown on lots as small as 20 acres.
18 Fresno incorporated in 1885, with a population of over 3,000. Development was restricted to a six- block area beginning at and northeast from the Southern Paciﬁc Railroad Depot; development was concentrated at Mariposa and H Street. Development of the infrastructure needed to support increases in agricultural and commercial industry soon followed and once diversity of industry began, immigrant populations also began to increase. Chinese, Japanese, Armenian and Volga Germans began to arrive and settle. By 1900, Fresno held 12,000 people.

Fresno County’s ﬁrst lumber mill was constructed in 1852, with 23 new mills following soon after.

Wood ﬂumes, some measuring more than 50 miles in length, were built by large lumber companies to transfer logs from the mills in the mountains to Fresno for rail transport. In 1921, the Sugar Pine Lumber Company (Sugar Pine) was incorporated: the goal was to harvest the vast sugar pine strands of the Sierra Nevada east of Fresno. Sugar Pine located its mill on a 574-acre tract overlooking the San Joaquin River north of Fresno. Fresno County historian Charles Clough called Pinedale “the largest [lumber mill] in the world at that time” with the capacity to cut 600,000-board feet and send out forty boxcars of lumber per day (Clough 1963, 1986).

As Fresno grew from its founding as a regional agricultural center, municipal infrastructure and amenities also increased. One of the ﬁrst projects to build Fresno’s infrastructure was the electric intra-urban railway. By 1905, Fresno Traction Company had laid 15.5 miles of track on Fresno streets before being purchased in 1910 by Southern Paciﬁc Railroad. In addition, the Fresno Traction

18 The Planning Center. 2010. Fresno El Paseo Environmental Impact Report. Prepared for the City of Fresno.

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Company built an amusement park on eight acres of San Joaquin River bottomland eleven miles from downtown Fresno named Fresno Beach. They extended the tracks to the beach in 1913. The Fresno Beach route was terminated at Herndon Avenue in 1930 due to increasing automobile use.

Fresno Traction Company continued to cut back all of its routes and in 1939 streetcar service in Fresno ended.

The founding and expansion of Fresno in the late 19th Century plus the extensive developments before World War I has left its mark on the setting of the city, its cultural and physical enclaves, the names of streets, and how the suburban areas of the city expanded and changed. Numerous project- level historical studies have taken place in the city during the last ten years (Bungalow Courts 2004; Chinatown Survey 2006; Germantown Historical Context 2006; Arts and Culture District 2006-7; Pinedale 2007; Mid-Century Modern Historic Context 2008; North Park 2008; South Stadium 2008; Wilson Island 2009; Downtown Fresno (Fulton Corridor) Historic Resources Survey 2011, amended 2014; Huntington Boulevard 2015; South Van Ness Industrial District Historic Survey 2015; Re-survey of Potential L Street Historic District 2018), and each have focused on the background history of speciﬁc areas in the city. Future historical research is likely to occur at neighborhood analytical levels because of the City’s status as a NPS-SHPO Certiﬁed Local Government.

The ﬁrst three decades of the 20th Century were a period of steady growth and increasing prosperity for Fresno during which the city established itself as the primary city of the San Joaquin Valley. The city’s ﬁrst electric streetcar was in use in 1902. By 1909, the ﬁrst double-track streetcar line was installed along J Street (now Fulton Street). By the early 1920s, streetcar lines would radiate out from the central business district to the north, east, south, and west where farmland was being subdivided for suburban development. The expanding transit infrastructure, along with exponentially increasing private automobile ownership, made living further from the city center possible. Land within the central city increasingly became used for commercial and civic purposes.

By the end of the 1920s, Fresno had transformed into a thriving city at the center of the United States most productive agricultural region. The downtown was fully established as the San Joaquin Valley’s primary marketplace oﬀering oﬃce, retail, lodging, dining, and entertainment facilities.

Adjacent industrial activity enabled agricultural goods to be processed and shipped to distant consumers. The central city’s residential areas had largely been developed. Residential properties were increasingly redeveloped for commercial uses as the city’s wide-ranging streetcar system and increased private automobile ownership allowed more of Fresno’s citizens to live outside of the city center. Fresno, along with the nation, appeared increasingly prosperous. Then on November 24, 1929, the New York Stock Exchange crashed and millions of dollars in stock value vanished. The stock market crash exposed structural weaknesses in the banking and ﬁnance systems, key industries, and the economy as a whole, ushering in the Great Depression.

The Great Depression had a profound eﬀect on the San Joaquin Valley. Farmers were forced to cut costs in the face of reduced demand for their products; many were forced into foreclosure. Along with the rest of the country, unemployment skyrocketed. The Valley’s problems were exacerbated by the inﬂux of migrant refugees or “Dust Bowl” migrants. It is believed that 2.5 million people migrated from the Midwestern Plains states between 1930 and 1940, with over 300,000 relocating to California just between 1930 and 1934. Thousands more would continue to arrive throughout the 1930s and many ended up in the Central Valley as migrant farm workers earning very low wages.

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On December 7, 1941, the Japanese attacked Pearl Harbor and the United States oﬃcially entered World War II. The United States’ entrance into the War eﬀectively ended the Depression in California as all aspects of the national economy mobilized to serve the war eﬀort. California received almost 12% of the government war contracts and produced 17% of all war supplies. California also acquired more military installations than any other state by a wide margin, and military bases were opened throughout the state. Aircraft, shipbuilding, and numerous other industries were booming due to the war eﬀort, and unemployment was virtually eliminated.

Approximately 60,000 service members were stationed in and around Fresno during the War.

Military activity was concentrated at two locations. One, the Hammer Field bomber base, was constructed in 1941 just beyond what was then the eastern boundary of the city. Today it is the site of Fresno Yosemite International Airport. The second, Camp Pinedale, was located six miles north of Downtown Fresno in the (then) unincorporated community of Pinedale on the site of the defunct Sugar Pine Lumber Company. The Army had acquired the site in March of 1942 for use as an Army Signal Training School.

Following World War II, the passage of the G.I. Bill enabled returning veterans to purchase homes and establish businesses, prompting another period of rapid expansion. The Mayfair subdivision, completed in 1947 northeast of the Project Area, included Fresno’s ﬁrst suburban shopping mall and ushered in an era of development at the suburban fringe. Between 1940 and 1950, the city’s population grew by 30,000, with much of the growth accommodated in new auto-oriented suburbs.

The Interstate Highway Act of 1956 served to spur development of suburbs, and ultimately led to the economic decline of many inner cities.

By the mid-1950s, however, the results of rapid suburbanization were becoming evident in Downtown Fresno as major retailers such as Sears & Roebuck relocated to newly developed suburban shopping centers such as Manchester Center (1955) and Fig Garden Village (1956). The downtown core was continually being bypassed as a place to locate new businesses. With Downtown unable to compete with burgeoning suburban development, construction of new buildings in Downtown Fresno came to a virtual halt.

Historic-Era Architectural Styles in Fresno. Fresno is home to a diversity of architectural styles that include Victorian, Period Revival (Colonial, Italian, Renaissance, Mission, Mediterranean, Spanish, and Tudor), Neoclassical, Craftsman Bungalow, Streamline Moderne, Beaux-Arts, Art Deco, International, Mid-Century Modern, and Ranch among others. While styles focus upon a collection of speciﬁc decorative features; types are based on form. Considered a distinctly American type, the Prairie Box—also known as the American Foursquare— was popular in Fresno in the early 20th Century.

Beginning in the early 20th century the city’s downtown was completely transformed: the elegant “Victorian” style blocks and hotels were demolished or in the case of smaller buildings were eventually refaced with a “modern” storefront. What emerged was a more “rational” Classical Revival city, one inﬂuenced by the latest trends in architectural design emanating from American cities such as New York, Chicago, and San Francisco, as well as Paris, France. One of the ﬁrst “high- rise” Neoclassical oﬃce buildings in Fresno was the Griﬃth-McKenzie Building, also known as the Helm Building, a 10-story steel frame structure constructed in 1914 and designed by the San

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Francisco architect George Kelham. Other buildings of note include two buildings constructed in 1912: the Hotel Fresno, which is included on the National Register, and is a 7-story Neoclassical building; and the Rowell Building, a 6-story Renaissance Revival building.

Numerous oﬃce buildings followed suit, many of them designed and constructed by the R.F. Felchlin Company. The building boom in downtown was halted in mid-1930 as the Depression began to sink in. Many of the downtown buildings that survived relatively intact are listed on Fresno’s Local Register of Historic Resources.19 There are also 26 National Register-listed structures in the downtown core.

Although farming and ranching remain at the economic forefront, its place in central California means that Fresno is an excellent location for industrial complexes and distribution centers. In addition, its central location and less expensive housing prices oﬀer opportunities for expansion.

4.5.1.4 Known Prehistoric Resources
Review of documents at the SSJVIC and from on-line sources show that no previous prehistoric site or artifact has been recorded within the Planning Area, which covers approximately 106,027 acres.

Since prehistoric deposits are typically detected by surveying archaeologists during the planning stages of a project, the lack of recorded deposits is not surprising. Additional reviews of various historic newspaper archive websites shows that no references to a Native American discovery within the city limits has been noted in an archived newspaper, such as the Fresno Bee. This is somewhat unusual for a California city, but not unique. Review of studies prepared for development projects located within the city show that little information is provided regarding the possibility that prehistoric resources might be uncovered during construction-related earthmoving.

As shown above in the historical and geological setting of the city, except near the San Joaquin River, most parts of the City are clearly not conducive to deposition or preservation of surface prehistoric resources at the modern ground surface. Slawson and Kay identiﬁed that the City is located in areas that might have had good potential for archaeological deposits, and that such deposits may have been damaged by development and farming practices. Citywide, an accurate assessment of resource sensitivity for prehistoric resources cannot be established at the present time. Based on existing data, the sensitivity for prehistoric cultural resources to be uncovered within the Planning Area is not certain because there has been a limited amount (approximately 0.3 percent) of land in the Planning Area surveyed. Upstream and downstream of the Planning Area, the banks of the San Joaquin River are known to contain prehistoric archaeological sites. This is because the river channel has carved a 50-70 foot deep cut into the surrounding alluvium since the end of the Pleistocene, and the banks of permanent rivers in the Central Valley of California have a much greater chance to contain buried or otherwise undiscovered prehistoric resources compared to areas subject to regular ﬂooding.

The portion of the Planning Area that extends from the south bank of the San Joaquin River to approximately one-mile south of the River is identiﬁed as having a high sensitivity for buried prehistoric resources. Because most lands in the remainder of the Planning Area have been built

19 City of Fresno. Planning and Development, Historic Preservation. Website: https://www.fresno.gov/ planning/historic-preservation/#database (accessed December 10, 2024).

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upon or disturbed by farming, it is diﬃcult to predict when prehistoric resources will be uncovered as a result of new development. Researchers have shown that when reliable water is available, prehistoric people may have lived nearby and exploited local resources. They could have built permanent villages. Based on the geological study provided in Appendix F, it may be possible to detect certain types of Pleistocene and Holocene ground surfaces once the disturbed horizons have been removed by earthmoving equipment during development activities. Finally, the Native American Heritage Commission characterized the city of Fresno as being “very sensitive” for potential impacts to Native American sacred sites and prehistoric deposits.

4.5.1.5 Known Historical Resources
The city of Fresno has experienced extensive growth since the 1800s when the railroad arrived and the broad plain between the Kings and San Joaquin Rivers was hand-cleared of brush and native grasses. As agricultural commerce strengthened, most of the downtown area was transformed from little farms and railroad-supply businesses, to a burgeoning agricultural center, then to the development of Victorian style blocks with grand hotels, to more modern styles evidenced in many Classical Revival buildings.

The City of Fresno retains many of its historically signiﬁcant buildings and structures through listings on various registers; local and national. Within the Planning Area there are 33 historical resources listed on the National Register of Historic Places,
20 and 277 existing structures21 that are designated
by the City on the Local Register of Historic Resources. Additionally, there are 29 Heritage Properties, which are not Historic Resources for the purposes of the City's Historic Preservation Ordinance but could potentially be treated as historical resources for the purposes of CEQA at the City's discretion.22 The City identiﬁes four historic districts: the Porter Tract (near Fresno City College), the Wilson Island (located within the Tower District), Huntington Boulevard (near Roosevelt High School), and the Chandler Airﬁeld/Fresno Municipal Airport.
23 Unlike the analysis of prehistoric resources, a process for establishing the signiﬁcance of individual buildings and historic districts was mandated by the City in 1979 in the form of a Historic Preservation Ordinance, which was updated in 1999. The Ordinance has resulted in the identiﬁcation of over 2,000 older structures within the city limits, and as the city ages more historic era properties are added to the databases each year.

20 National Register, 2024.
21 City of Fresno. Planning and Development, Historic Preservation. Website: https://www.fresno.gov/ planning/historic-preservation/#database (accessed December 10, 2024). 22 Historic Fresno. 2019. A Guide to Historic Architecture in Fresno, California. Website:
www.historicfresno.org/heritage/index.htm (accessed December 10, 2024). 23 City of Fresno. Planning and Development, Historic Preservation. Website: https://www.fresno.gov/ planning/historic-preservation/#database (accessed December 10, 2024).

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4.5.1.6 Native American Consultation
On June 16, 2025, the City sent notiﬁcation letters to 12 tribes, including 2 tribes that have requested to be notiﬁed of projects in accordance with Assembly Bill (AB) 52. Appendix D includes the Native American consultation information.

4.5.2 Regulatory Setting

4.5.2.1 Federal Policies and Regulations
National Historic Preservation Act. The National Historic Preservation Act of 1966 (NHPA) is the most concise and eﬀective federal law dealing with historic preservation. Federal preservation law does not apply to the purpose of this analysis but a short review of the legislation is needed because the State and Local requirements have been derived from this legislation. The NHPA established guidelines to “preserve important historic, cultural, and natural aspects of our cultural heritage, and to maintain, wherever possible, an environment that supports diversity and a variety of individual choice.” The NHPA includes regulations speciﬁcally for federal land-holding agencies, but also includes regulations (known as Section 106) which pertain to all projects that are funded, permitted, or approved by any federal agency and which have the potential to aﬀect cultural resources. In addition, the NHPA authorizes the Secretary of the Interior to establish a National Register of Historic Places (The National Register). The Register is an inventory of districts, sites, buildings, structures and objects signiﬁcant at a national, State, or local level in American history, architecture, archaeology, engineering, and culture. The National Register is wholly maintained by the National Park Service, the Advisory Council on Historic Preservation, and the State Oﬃce of Historic Preservation (SHPO) and grants-in-aid programs.

According to the National Park Service (NPS) and the State Historic Preservation Oﬃce (SHPO), the City is a Certiﬁed Local Government (CLG). The CLG program is a preservation partnership between local, state and national governments focused on promoting historic preservation at the grass roots level. The program is jointly administered by NPS and SHPO, with each local community working through a certiﬁcation process to become recognized as a CLG. CLG’s become an active partner in the Federal Historic Preservation Program and the opportunities (and funding) it provides.

4.5.2.2 State Policies and Regulations
California Register of Historical Resources. The California Register of Historical Resources (California Register or CRHR) is an inventory of signiﬁcant architectural, archaeological, and historical resources in the State of California. Important cultural resources can be listed in the California Register through a number of methods, and listing requires approval from the State Historical Resources Commission.

Properties can be nominated to the California Register by local governments, private organizations, or citizens. State Historical Landmarks and National Register-listed properties gain automatic listing in the California Register. The evaluative criteria used by the California Register for determining eligibility are closely based on those developed by the National Park Service for the National Register of Historic Places. In order for a cultural resource to be signiﬁcant, or in other words eligible, for listing in the California Register, it must reﬂect one or more of the following criteria (PRC 5024.1c):

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• Criterion 1 (Events): Resources that are associated with events that have made a signiﬁcant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.
• Criterion 2 (Persons): Resources that are associated with the lives of persons important to local, California, or national history.
• Criterion 3 (Architecture): Resources that embody the distinctive characteristics of a type, period, region, or method of construction, or represent the work of a master, or possess high artistic values.
• Criterion 4 (Information Potential): Resources or sites that have yielded or have the potential to yield information important to the prehistory or history of the local area, California, or the nation.

California Environmental Quality Act. CEQA requires that public agencies assess the eﬀects on historical resources of public or private projects that the agencies ﬁnance or approve. Historical resources are deﬁned as buildings, sites, structures, objects, areas, places, records, or manuscripts that the lead agency determines to have historical signiﬁcance, including architectural, archaeological, cultural, or scientiﬁc signiﬁcance. CEQA requires that if a project results in an eﬀect that may cause a substantial adverse change in the signiﬁcance of a historical resource, alternative plans or mitigation measures must be considered.

However, only signiﬁcant historical resources need to be addressed. Therefore, before the assessment of eﬀects or development of mitigation measures, the signiﬁcance of cultural resources must be determined. The steps that are normally taken in a cultural resources investigation for CEQA compliance are as follows:

1. Identify potential historical resources.

2. Evaluate the eligibility of historical resources.

3. Evaluate the eﬀects of the project on all eligible historical resources.

In addition, properties that are listed in or eligible for listing in the NRHP are considered eligible for listing in the CRHR and thus are signiﬁcant historical resources for the purposes of CEQA (PRC Section 5024.1[d][1]).

According to CEQA, a project with an eﬀect that may cause a substantial adverse change in the signiﬁcance of a historical resource may have a signiﬁcant impact on the environment (State CEQA Guidelines 15064.5[b]). CEQA also states that a substantial adverse change in the signiﬁcance of a resource means the physical demolition, destruction, relocation, or alteration of an historical resource or its immediate surroundings such that the signiﬁcance of the resource would be materially impaired. Actions that would materially impair the signiﬁcance of a historical resource are any actions that would demolish or materially and adversely alter the physical characteristics of a historical resource that convey its historical signiﬁcance and qualify or justify its eligibility for inclusion in the CRHR or in a local register or survey that meet the requirements of PRC Sections 5020.1(k) and 5024.1(g).

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Signiﬁcant Historical Resources under CEQA Guidelines. In completing an analysis of a project under CEQA, it must ﬁrst be determined if the project site possesses a historical resource. A site may qualify as a historical resource if it falls within at least one of four categories listed in CEQA Guidelines Section 15064.5(a). The four categories are:

1. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code Section 5024.1, Title 14 CCR, Section 4850 et seq.).

2. A resource included in a local register of historical resources, as deﬁned in Section 5020.1(k) of the Public Resources Code or identiﬁed as signiﬁcant in an historical resource survey meeting the requirements of section 5024.1 (g) of the Public Resources Code, shall be presumed to be historically or culturally signiﬁcant. Public agencies must treat any such resource as signiﬁcant unless the preponderance of evidence demonstrates that it is not historically or culturally signiﬁcant.

3. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically signiﬁcant or signiﬁcant in the architectural, engineering, scientiﬁc, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically signiﬁcant” if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code SS5024.1, Title 14 CCR, Section 4852).

These conditions are related to the eligibility criteria for inclusion in the CRHR (PRC Sections 5020.1[k], 5024.1, 5024.1[g]). A cultural resource may be eligible for inclusion in the CRHR if it:
• Is associated with events that have made a signiﬁcant contribution to the broad patterns of California’s history and cultural heritage;
• Is associated with the lives of persons important in our past; • Embodies the distinctive characteristics of a type, period, region, or method of construction; represents the work of an important creative individual; or possesses high artistic values; or • Has yielded, or may be likely to yield, information important in prehistory or history.

The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Pub. Resources Code), or identiﬁed in an historical resources survey (meeting the criteria in section 5024.1(g) of the Pub. Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as deﬁned in Pub.

Resources Code sections 5020.1(j) or 5024.1.

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A lead agency must consider a resource that has been listed in, or determined to be eligible for listing in the California Register (Category 1) as an historical resource for CEQA purposes. In general, a resource that meets any of the other three criteria listed in CEQA Guidelines Section 15064.5(a) is also considered to be a historical resource unless “the preponderance of evidence demonstrates” that the resource is not historically or culturally signiﬁcant.” State Health and Safety Code. The discovery of human remains is regulated according to California Health and Safety Code Section 7050.5, which states that if human remains are encountered, no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98. The County Coroner must be notiﬁed of the ﬁnd immediately. If the remains are determined to be precontact, the Coroner will notify the NAHC, which will determine and notify the Most Likely Descendant (MLD). With the permission of the landowner or his or her authorized representative, the MLD may inspect the site of the discovery.

The MLD shall complete the inspection within 24 hours of notiﬁcation by the NAHC. The MLD may recommend scientiﬁc removal and nondestructive analysis of human remains and items associated with Native American burials.

California Government Code 65352.3-5: Local Government-Tribal Consultation. California Government Code Sections 65092, 65351, 65352, 65352.3, and 65352.4, formally known as Senate Bill (SB) 18, regulate the consultation with California Native American tribes having traditional lands located within the jurisdiction of applicable cities and counties. The intent of the underlying legislation was to provide all California Native American tribes that are on the contact list maintained by the NAHC, an opportunity to consult with speciﬁc local governments for the purpose of preserving and protecting their sacred places. Such consultations apply to the preparation, adoption, and amendment of general plans.

Senate Bill 18. SB 18, signed into law in September 2004, requires local (city and county) governments to consult with California Native American tribes to aid in the protection of traditional tribal cultural places through local land use planning. The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage for the purpose of protecting or mitigating impacts to cultural places. The consultation and notice requirements apply to adoption and amendment of both general plans (Government Code Section 65300 et seq.) and speciﬁc plans (Government Code Section 65450 et seq.). Speciﬁcally, Government Code Section 65352.3 requires local governments, prior to making a decision to adopt or amend a general plan, to consult with California Native American tribes identiﬁed by the NAHC for the purpose of protecting or mitigating impacts to cultural places. As previously discussed, the NAHC is the State agency responsible for the protection of Native American burial and sacred sites.

Assembly Bill 52. Assembly Bill (AB) 52, the Native American Historic Resource Protection Act, sets forth a proactive approach intended to reduce the potential for delay and conﬂicts between Native American and development interests. Projects subject to AB 52 are those that ﬁle a Notice of Preparation (NOP) for an EIR or Notice of Intent (NOI) to adopt a Negative or Mitigated Negative Declaration on or after July 1, 2015. AB 52 adds tribal cultural resources (TCRs) to the speciﬁc cultural resources protected under CEQA. Under AB 52, a TCR is deﬁned as a site, feature, place, cultural landscape (must be geographically deﬁned in terms of size and scope), sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for

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inclusion in the California Register, or included in a local register of historical resources. A Native American tribe or the Lead Agency, supported by substantial evidence, may choose at its discretion to treat a resource as a TCR. AB 52 also mandates Lead Agencies to consult with Native American tribes, if requested by the tribe, and sets the principles for conducting and concluding consultation.

4.5.2.3 Local Policies and Regulations
City of Fresno General Plan. The City of Fresno’s General Plan Historic and Cultural Resources Element includes objectives and policies that work to identify and preserve Fresno’s historic and cultural resources that reﬂect important cultural, social, economic, and architectural features. The following policies related to biological resources are applicable to the proposed project:

Objective HCR-1: Maintain a comprehensive, citywide preservation program to identify, protect and assist in the preservation of Fresno’s historic and cultural resources.

Policy HCR-1-c: Historic Preservation Ordinance. Maintain the provisions of the City’s Historic Preservation Ordinance, as may be amended, and enforce the provisions as appropriate.

Objective HCR-2: Identify and preserve Fresno’s historic and cultural resources that reﬂect important cultural, social, economic, and architectural features so that residents will have a foundation upon which to measure and direct physical change.

Policy HCR-2-a: Identiﬁcation and Designation of Historic Properties. Work to identify and evaluate potential historic resources and districts and prepare nomination forms for Fresno’s Local Register of Historic Resources and California and National registries, as appropriate.

Policy HCR-2-b: Historic Surveys. Prepare historic surveys according to California Oﬃce of Historic Preservation protocols and City priorities as funding is available.

Policy HCR-2-c: Project Development. Prior to project approval, continue to require a project site and its Area of Potential Eﬀects (APE), without beneﬁt of a prior historic survey, to be evaluated and reviewed for the potential for historic and/or cultural resources by a professional who meets the Secretary of Interior’s Qualiﬁcations. Survey costs shall be the responsibility of the project developer. Council may, but is not required, to adopt an ordinance to implement this policy.

Policy HCR-2-d: Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, as required by State law, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.

Policy HCR-2-f: Archaeological Resources. Consider State Oﬃce of Historic Preservation guidelines when establishing CEQA mitigation measures for archaeological resources.

Policy HCR-2-n: Property Database and Informational System. Identify all historic resources within the city designated on the Local, State, or National register, and potential signiﬁcant

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resources (building, structure, object or site) in existence for at least 45 years, and provide this information on the City’s website.

Objective HCR-3: Promote a “New City Beautiful” ethos by linking historic preservation, public art, and planning principles for Complete Neighborhoods with green building and technology.

Policy HCR-3-c: Context Sensitive Design. Work with architects, developers, business owners, local residents and the historic preservation community to ensure that inﬁll development is context-sensitive in its design, massing, setbacks, color, and architectural detailing.

Municipal Code
Historic Preservation Ordinance. The City of Fresno has established a Historic Preservation Commission and a Local Register of Historic Resources (Fresno Municipal Code, Chapter 12, Article 16). The Ordinance is used to provide local levels of control over the historical aesthetics of cultural resources within the city, and to ensure that the potential impact to locally signiﬁcant historical resources that may be the subject of redevelopment are given reasonable consideration. The purpose of the Ordinance is to:
[…] continue to preserve, promote and improve the historic resources and districts of the City of Fresno for educational, cultural, economic and general welfare of the public; to continue to protect and review changes to these resources and districts which have a distinctive character or a special historic, architectural, aesthetic or cultural value to this city, state and nation; to continue to safeguard the heritage of this city by preserving and regulating its historic buildings, structures, objects, sites and districts which reﬂect elements of the city’s historic, cultural, social, economic, political and architectural history; to continue to preserve and enhance the environmental quality and safety of these landmarks and districts; to continue to establish, stabilize and improve property values and to foster economic development. (Article 16 Section 12-1602(a).)
The Ordinance provides legislative mechanisms to protect certain historical resources. Local registers of identiﬁed historical resources are known, including:

1. Heritage Properties. These are deﬁned as a resource which is worthy of preservation because of its historical, architectural or aesthetic merit but which is not proposed for and is not designated as an Historic Resource under the ordinance.

2. Historic Resources. These are deﬁned as any building, structure, object or site that has been in existence more than ﬁfty years and possesses integrity of location, design, setting, materials, workmanship, feeling and association, and is associated with events that have made a signiﬁcant contribution to the broad patterns of city history, or is associated with the lives of persons signiﬁcant in our past, or embodies the distinctive characteristics of a type, period or method of construction, or represents the work of a master or possesses high artistic values; or has yielded, or may be likely to yield, important information in prehistory

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or history; and has been designated as such by the Council pursuant to the provisions of the Ordinance.

3. Local Historic Districts. These are deﬁned as any ﬁnite group of resources related to one another in a clearly distinguishable way or any geographically deﬁnable area which possesses a signiﬁcant concentration, linkage or continuity of sites, buildings, structures or objects united historically or aesthetically by plan or physical development. The Local Historic District must be signiﬁcant as well as identiﬁable and it must meet Local Register Criteria for listing on that Register. Contributors to Historic Districts are deﬁned as any Historic Resource that contributes to the signiﬁcance of the speciﬁc Local Historic District or a proposed National Register Historic District under the criteria set forth in the Ordinance.

4. National Register Historic Districts, which shall mean any ﬁnite group of resources related to one another in a clearly distinguishable way or any geographically deﬁnable area which possesses a signiﬁcant concentration, linkage or continuity of sites, buildings, structures or objects united historically or aesthetically by plan or physical development. A National Register Historic District must be signiﬁcant as well as identiﬁable and it must meet National Register Criteria for listing on that Register. Contributors to a National Register Historic District are deﬁned as any individual Historic Resource which contributes to the signiﬁcance of a National Register Historic District under the criteria set forth in the Ordinance.

4.5.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to cultural and tribal cultural resources that could result from implementation of the proposed project. The section begins with the criteria of signiﬁcance, which establish the thresholds to determine if an impact is signiﬁcant.

The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures. Mitigation measures are recommended, as appropriate, for signiﬁcant impacts to eliminate or reduce them to a less than signiﬁcant level.

Cumulative impacts are also addressed.

4.5.3.1 Signiﬁcance Criteria
Based on State CEQA Guidelines Appendix G, the proposed project would have a signiﬁcant impact on cultural resources and tribal cultural resources if it would:
a. Cause a substantial adverse change in the signiﬁcance of a historical resource pursuant to Section 15064.5;
b. Cause a substantial adverse change in the signiﬁcance of an archaeological resource pursuant to Section 15064.5;
c. Disturb any human remains, including those interred outside of dedicated cemeteries; d. Result in a substantial adverse change in the signiﬁcance of a TCR, deﬁned in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically deﬁned in terms of the

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size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
• Listed or eligible for listing in the California Register or in a local register of historical resources as deﬁned in PRC Section 5020.1(k), or
• A resource determined by the Lead Agency, in its discretion and supported by substantial evidence, to be signiﬁcant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the Lead Agency shall consider the signiﬁcance of the resource to a California Native American tribe.

4.5.3.2 Project Impacts
The following discussion describes the potential impacts related to cultural resources that could result from implementation of the proposed project.

CUL-1 The project could cause a substantial adverse change in the signiﬁcance of a historical resource as deﬁned in Section 15064.5.

Known historical resources are located primarily in Downtown Fresno because this is the area where development of the city began in the mid-1800s. These known resources meet the deﬁnition of historical resource under CEQA Section 15064.5(a). As discussed previously, there are 33 historical resources listed on the National Register of Historic Places, 31 historical resources listed on the California Register of Historic Resources, and 277 existing structures that are on the Local Register of Historic Places. There are also 29 Heritage Properties, which are not Historic Resources for the purposes of the City's Historic Preservation Ordinance but could potentially be treated as historical resources for the purposes of CEQA at the City's discretion. In addition to the individual resources, there are four designated Local Historic Districts within the Planning Area. As additional surveys for potential historical resources are prepared, such as the surveys that were prepared for the Fulton Corridor Speciﬁc Plan in Downtown Fresno, additional resources may be added to the various lists.

Many areas of Downtown, as well as other locations within the Planning Area, have not been surveyed. As a result, only a portion of the resources in the Planning Area are known.

As land uses are built out in accordance with the approved General Plan, the growth that would occur within the Planning Area would include inﬁll development and buildout of rural, agricultural, and undeveloped areas. As the density and intensity increases in the existing urban areas, there is a possibility that the new development could result in demolition or substantial alterations of historical or potentially historical buildings and structures. In addition to land use development, infrastructure and other public works improvements could result in demolition or substantial alterations of historical resources.

To reduce the potential impacts on historical resources, there are federal, State, and local regulations. These regulations are discussed above in Section 4.5.2. The City of Fresno Historic Preservation Ordinance provides a process to preserve, promote, and improve the Historic Resources and Historic Districts within its jurisdiction. In addition to the Historic Preservation Ordinance, the approved General Plan includes the following objective HCR-1 and Policy HCR-1-c,

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Objective HCR-2 and Policies HCR-2-a through HCR-2-d, HCR-2-f, HCR-2-g, Objective HCR-3, and Policy HCR-3-c to preserve historic resources.

Future transportation improvements funded by the proposed program would be City-initiated or implemented as part of future development projects. All future improvements would be required to undergo separate environmental review under CEQA (e.g., preparation of a Categorical Exemption, Mitigated Negative Declaration, or Environmental Impact Report). Thus, cultural resource assessments, including historical assessments, may be required to analyze project-speciﬁc impacts on historical resources as deﬁned under CEQA Guidelines Section 15064.5; refer to Mitigation Measure CUL-1. Implementation of Mitigation Measure CUL-1 would ensure a historical resources assessment is conducted by a qualiﬁed architectural historian or historian to evaluate the site for any previously unrecorded potential historical resources that could be impacted by the transportation improvement. Thus, upon implementation of Mitigation Measure CUL-1, the proposed program would not result in signiﬁcant impacts to historical resources.

Mitigation Measure CUL-1 To ensure identiﬁcation and preservation of potentially historic resources (as deﬁned by CEQA Guidelines Section 15064.5 as a resource listed in, eligible for listing in, or listing in the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), or local register), each transportation improvement funded by the proposed Vehicle Miles Traveled Reduction Program subject to California Environmental Quality Act (CEQA) review (meaning, subject to discretionary action and non- exempt from CEQA) shall be conditioned as follows: prior to any construction activities that could impact potential or previously identiﬁed historical resources, the project proponent shall provide a historical resources assessment performed by an architectural historian or historian who meets the Secretary of the Interior’s Professional Qualiﬁcation Standards for architectural history or history (as deﬁned in 48 Code of Federal Regulations 44716) to the City of Fresno Planning and Development Department for review and approval. The historical resources assessment shall include a records search at the Southern San Joaquin Valley Information Center (SSJVIC) and a survey in accordance with the California Oﬃce of Historic Preservation (OHP) guidelines to identify any previously unrecorded potential historical resources that may be potentially aﬀected by the proposed project. If a historical resource is identiﬁed on-site, the resource shall be avoided to the extent feasible.

If relocation, rehabilitation, or alteration of a historical resource is required, the project proponent shall utilize the Secretary of the Interior’s Standards for the Treatment of Historic Properties to the maximum extent feasible to ensure the historical signiﬁcance of the resource is not impaired.

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If demolition or signiﬁcant alteration of a historical resource is required, the resource shall be evaluated, and/or designated in the NRHP , CRHR, or local register, and recordation shall take the form of Historic American Buildings Survey (HABS), Historic American Engineering Record (HAER), or Historic American Landscape Survey (HALS) documentation, and shall be performed by an architectural historian or historian who meets the Secretary of the Interior’s Professional Qualiﬁcation Standards. Recordation shall meet the Secretary of the Interior’s Standards and Guidelines for Architectural and Engineering, which deﬁnes the products acceptable for inclusion in the HABS/HAER/HALS collection at the Library of Congress. The speciﬁc scope and details of documentation shall be developed at the project level in coordination with the City of Fresno Planning and Development Department and performed prior to the ﬁrst issuance of any demolition, building, or grading permits.

Level of Signiﬁcance With Mitigation: Less Than Signiﬁcant Impact with Mitigation Incorporated.

CUL-2 The project could cause a substantial adverse change in the signiﬁcance of an archaeological resource as deﬁned in Section 15064.5 of the CEQA Guidelines.

As stated, several locations within the City and surrounding area have known archaeological resources. Based on previously completed cultural resource surveys historical/archaeological sites have been discovered within the General Plan Planning Area. While future transportation improvement projects funded by the VMT Reduction Program would be largely focused within developed areas and within or adjacent to existing rights-of-way, the proposed improvements could still adversely impact previously unknown archaeological resources. For example, resources may be preserved within native soils below disturbances associated with existing commercial, residential, or other developments.

Future transportation improvements funded by the proposed project would be required to undergo separate environmental review under CEQA. Depending on the nature of future improvements, the City may require preparation of a cultural resources assessment to evaluate project- and site-speciﬁc impacts on potential archaeological resources. Implementation of Mitigation Measure CUL-2.1 would ensure a cultural resources assessment is prepared, if required by the City, and that the potential impacts to unknown archaeological resources are reduced to the greatest extent feasible.

Additionally, if a resource is unearthed during any excavation and grading activities, Mitigation Measure CUL-2.2 would require earth-disturbing activities to halt within a 100-meter radius of the ﬁnd and the project proponent shall retain a qualiﬁed archaeologist to evaluate the signiﬁcance of the ﬁnd and appropriate course of action. As such, the proposed program would not result in signiﬁcant impacts to archaeological resources. Impacts in this regard would be less than signiﬁcant.

Mitigation Measure CUL-2.1 To ensure identiﬁcation and preservation of archaeological resources within the City of Fresno, each transportation improvement funded by the proposed Vehicle Miles Traveled Reduction Program subject to California Environmental Quality Act

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(CEQA) review (meaning, subject to discretionary action and non- exempt from CEQA) shall be screened by the City of Fresno Planning and Development Department to determine whether a Cultural Resources Assessment is required. Screening shall consider the type of project and whether ground disturbances will occur. Ground disturbances include activities such as grading, excavation, trenching, boring, or demolition that extend below the current grade. If there will be no ground disturbance, then a Cultural Resources Assessment shall not be required. If there will be ground disturbances, prior to issuance of any permits required to conduct ground disturbing activities, the City may require a Cultural Resources Assessment be conducted under the supervision of an archaeologist that meets the Secretary of the Interior’s Professionally Qualiﬁed Standards in either prehistoric or historic archaeology.

The Cultural Resources Assessment shall include a California Historical Resources Information System (CHRIS) records search conducted through the Southern San Joaquin Valley Information Center (SSJVIC) and Sacred Land Files (SLF) search through the Native American Heritage Commission (NAHC), review of historical maps, and a Phase I (intensive) pedestrian survey to assess the likelihood for buried archaeological resources to occur. The Cultural Resources Assessment shall meet or exceed standards in the Oﬃce of Historic Preservation’s Archaeological Resource Management Reports (ARMR): Recommended Contents and Format (1990) and Guidelines for Archaeological Research Designs (1991).

Mitigation Measure CUL-2.2 In the event that cultural resources are unearthed during excavation and grading activities of any future transportation improvement project funded by the proposed program, the construction contractor shall cease all earth-disturbing activities within a 100- meter radius of the ﬁnd and the project proponent shall retain a qualiﬁed archaeologist that meets the Secretary of the Interior’s Professionally Qualiﬁed Standards in either prehistoric or historic archaeology to evaluate the signiﬁcance of the ﬁnding and appropriate course of action. Salvage operation requirements pursuant to Section 15064.5 of the CEQA Guidelines shall be followed. After the ﬁnd has been appropriately mitigated, work in the area may resume.

Level of Signiﬁcance With Mitigation: Less Than Signiﬁcant Impact with Mitigation Incorporated.

CUL-3 The project would not disturb any human remains, including those interred outside of dedicated cemeteries.

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The majority of future transportation improvements funded by the proposed program would occur within existing rights-of-way in developed areas of the City. As such, it is not anticipated that human remains, including those interred outside of formal cemeteries, would be encountered during earth removal or ground-disturbing activities. Nonetheless, if human remains are found, those remains would require proper treatment, in accordance with applicable laws. State of California Public Resources Health and Safety Code Section 7050.5 through 7055 describe the general provisions for human remains. Speciﬁcally, Health and Safety Code Section 7050.5 describes the requirements if any human remains are accidentally discovered during excavation of a site. As required by State law, the requirements and procedures set forth in Section 5097.98 of the California Public Resources Code would be implemented, including notiﬁcation of the County Coroner, notiﬁcation of the Native American Heritage Commission, and consultation with the individual identiﬁed by the Native American Heritage Commission to be the most likely descendant. If human remains are found during excavation, excavation must stop near the ﬁnd and any area that is reasonably suspected to overlay adjacent remains until the County Coroner has been called out, the remains have been investigated, and appropriate recommendations have been made for the treatment and disposition of the remains. Following compliance with the aforementioned regulations, impacts related to the disturbance of human remains are less than signiﬁcant.

Mitigation Measures: No mitigation measures are required.

Level of Signiﬁcance: Less Than Signiﬁcant Impact.

CUL-4 The project would not result in a substantial adverse change in the signiﬁcance of a tribal cultural resource, deﬁned in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically deﬁned in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
• 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 • A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be signiﬁcant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the signiﬁcance of the resource to a California Native American tribe.

As previously described in Section 4.5.2.2, a TCR is deﬁned as a site, feature, place, cultural landscape (must be geographically deﬁned in terms of size and scope), sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register, or included 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 resources as a TCR.

On June 16, 2025, compliant with AB 52 the City provided formal notiﬁcation to interested Native American tribes that may be culturally or traditionally aﬃliated with the project area and vicinity to

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conduct consultation. The City sent formal notiﬁcation to 12 tribes, including 2 tribes that have requested to be notiﬁed of projects in accordance with AB 52. None of the 12 tribes contacted responded via letter or telephone prior to publication of the Draft EIR. Consultation letters are included in Appendix D of this EIR.

As discussed under impact discussions CUL-1, CUL-2, and CUL-4, impacts from future development within Fresno could impact unknown archaeological resources including Native American artifacts and human remains. Impacts would be reduced to a less-than-signiﬁcant level with implementation of Mitigation Measures CUL-1, CUL-2.1 and CUL-2.2.

While the proposed VMT Reduction Program does not involve any development, future transportation improvements implemented in accordance with the program could impact tribal cultural resources during ground-disturbing activities. All future transportation improvements funded by the proposed program would similarly require separate environmental review under CEQA (e.g., preparation of a Categorical Exemption, Mitigated Negative Declaration, or Environmental Impact Report). Should future projects require compliance with AB 52, consultation with Native American tribes would occur at a later date and project speciﬁc information (e.g., site plans and grading plans) would be available to more accurately determine whether the project could result in potentially signiﬁcant impacts to tribal cultural resources and help identify appropriate mitigation measures. As such, impacts to tribal cultural resources associated with the adoption of the VMT Reduction Program itself would be less than signiﬁcant.

Mitigation Measures: Refer to Mitigation Measure CUL-1 and Mitigation Measure CUL-2.

Level of Signiﬁcance: Less Than Signiﬁcant Impact with Mitigation Incorporated.

4.5.3.3 Cumulative Impacts
Future cumulative development projects developed in accordance with the General Plan would be required to undergo project-speciﬁc environmental review under CEQA and the City’s discretionary review process to determine potential impacts to historical resources, archaeological resources, and tribal cultural resources and identify any required mitigation.

As stated, all future transportation improvements funded by the proposed program would similarly require separate environmental review under CEQA to evaluate project-level potential impacts to historical resources and to identify any required mitigation. Implementation of Mitigation Measure CUL-1, CUL-2.1, and CUL-2.2 would ensure a historical resources assessment is prepared to identify any previously unrecorded historic resources and evaluate impacts of future transportation improvements on such resources. Thus, the proposed program would not cumulatively contribute towards potentially signiﬁcant impacts with other development in accordance with the General Plan, and less-than-signiﬁcant cumulative impacts related to cultural resources and tribal cultural resources would occur.

Mitigation Measure: Refer to Mitigation Measures CUL-1, CUL-2.1, and CUL-2.2.

Level of Signiﬁcance With Mitigation: Less Than Signiﬁcant Impact with Mitigation Incorporated.

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

4.6.1 Existing Environment Setting

4.6.1.1 Study Area for Project Impacts
The study area for project impacts regarding energy is the City of Fresno Planning Area.

4.6.1.2 Study Area for Cumulative Impacts
The study area for the analysis of cumulative energy impacts is the Pacific Gas and Electric’s (PG&E) service area that spans approximately 70,000 square miles from Eureka in the north to Bakersfield in the south and from the Pacific Ocean in the west to the Sierra Nevada in the east.

4.6.1.3 Energy Resources
Electricity. Electricity is a manmade resource. The production of electricity requires the consumption or conversion of energy resources (including water, wind, oil, gas, coal, solar, geothermal, or nuclear resources) into energy. Electricity is used for a variety of purposes (e.g., lighting, heating, cooling, and refrigeration, and for operating appliances, computers, electronics, machinery, public transportation systems and electric vehicles).1
According to the most recent data available, in 2023, California’s electricity was generated primarily by natural gas (43.68 percent), coal (0.1 percent), large hydroelectric (12.6 percent), nuclear (8.2 percent), and renewable sources (56.1 percent). Total electric generation in California in 2023 was 215,623 gigawatt-hours (GWh).2
Total system electric generation is the sum of all utility-scale in-state generation plus net electricity imports. In 2023, total generation for California was 281,140 gigawatt-hours (GWh), down 2.1 percent (6,080 GWh) from 2022. California's non-CO2 emitting electric generation categories (nuclear, large hydroelectric, and renewables) accounted for 58 percent of total generation, compared to 54 percent in 2022. California’s wide variety of climate and weather systems play a large role in how the various generation resources shape the annual power mix.3 The project site receives its electricity from PG&E. According to the California Energy Commission (CEC), total electricity consumption in the PG&E service area in 2022 was 104,695.0 GWh (35,245.7

1 United States Energy Information Administration. 2023. Electricity Explained. Website:
https://www.eia.gov/energyexplained/electricity/ (accessed April 2025). 2 California Energy Commission (CEC). 2023. 2023 Total System Electric Generation. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2022-total-system- electric-generation (accessed April 2025).
3 Ibid.

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GWh for the residential sector and 69,449.3 GWh for the nonresidential sector).4 Total electricity consumption in Fresno County in 2022 was 8,384.4 GWh (3,170.5 GWh for the residential sector and 5,213.9 for the nonresidential sector).5
Natural Gas. Natural gas is a non-renewable fossil fuel. Fossil fuels are formed when layers of decomposing plant and animal matter are exposed to intense heat and pressure under the surface of the Earth over many years. Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas is found in naturally occurring reservoirs in deep underground rock formations. Natural gas is used for a variety of uses (e.g., heating buildings, generating electricity, and powering appliances such as stoves, washing machines and dryers, gas fireplaces, hot water heaters and gas grills).6 According to the United States Energy Information Administration, in 2023, natural gas consumed in California was used for electricity generation (30.4 percent), residential uses (22.1 percent), industrial uses (30.6 percent), commercial uses (12.3 percent), and transportation uses (1.5 percent).7
PG&E is the natural gas service provider for the project site. According to the CEC, total natural gas consumption in the PG&E service area in 2022 was 4,421.6 million therms (1,856.1 million therms for the residential sector and 2,565.5 million therms for the nonresidential sector).8 Total natural gas consumption in Fresno County in 2022 was 319.4 million therms (108.4 million therms for the residential sector and 211.0 million therms for the nonresidential sector).9 Fuel. Petroleum is also a non-renewable fossil fuel. Petroleum is a thick, flammable, yellow-to-black mixture of gaseous, liquid, and solid hydrocarbons that occurs naturally beneath the earth's surface.

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

Gasoline is the most used transportation fuel in California, with 97 percent of all gasoline being consumed by light-duty cars, pickup trucks, and sport utility vehicles. According to the most recent data available, total gasoline consumption in California was 314,160 thousand barrels (13.9 billion gallons) or 1,586.1 trillion British thermal units (BTU) in 2023.10 Of the total gasoline consumption,

4 California Energy Commission (CEC). 2021b. Electricity Consumption by Entity. Website:
http://www.ecdms.energy.ca.gov/elecbyutil.aspx (accessed April 2025). 5 California Energy Commission (CEC). 2021c. Electricity Consumption by County. Website:
http://www.ecdms.energy.ca.gov/elecbycounty.aspx (accessed April 2025). 6 United States Energy Information Administration. 2022b. Natural Gas Explained, Use of Natural Gas.

Website: https://www.eia.gov/energyexplained/natural-gas/use-of-natural-gas.php (accessed April 2025). 7 United States Energy Information Administration. 2025. Natural Gas Consumption by End Use (Million Cubic Feet). Website: https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm (accessed June 2025). 8 California Energy Commission (CEC). 2022. Gas Consumption by Entity. Website:
http://www.ecdms.energy.ca.gov/gasbyutil.aspx (accessed April 2025). 9 California Energy Commission (CEC). 2022. Gas Consumption by County. Website:
http://www.ecdms.energy.ca.gov/gasbycounty.aspx (accessed April 2025). 10 A British Thermal Unit (BTU) is defined as the amount of heat required to raise the temperature of one pound of water by one degree Fahrenheit.

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296,948 thousand barrels (12.5 billion gallons) or 1,499.3 trillion BTU were consumed for transportation.11

4.6.2 Regulatory Setting

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

Safer Affordable Fuel-Efficient Vehicles Rule. On March 21, 2020, the USEPA and National Highway Traffic Safety Administration (NHTSA) finalized the SAFE Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule). The SAFE Vehicles Rule amends certain existing corporate average fuel economy (CAFE) and tailpipe CO2 emissions standards for passenger cars and light trucks and establishes new standards, all covering model years 2021 through 2026. More specifically, the NHTSA set new CAFE standards for model years 2022 through 2026 and amended its 2021 model year CAFE standards, and the USEPA amended its CO2 emissions standards for model years 2021 and later.

The current administration withdrew portions of the SAFE Rule, concluding that the SAFE Rule overstepped the agency’s legal authority and finalized updated CAFE Standards for model years 2024 through 2026. The final rule establishes standards that would require an industry-wide fleet average of approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024 and 2025, and 10 percent annually for model years 2026. The agency projects the final standards will save consumers nearly $1,400 in total fuel expenses over the lifetimes of vehicles produced in these model years and avoid the consumption of about 234 billion gallons of gas between model years 2030 to 2050. The NHTSA also projects that the standards will cut greenhouse gases from the atmosphere, reduce air pollution, and reduce the country’s dependence on oil.

4.6.2.2 State Policies and Regulations
Assembly Bill 1575, Warren-Alquist Act. In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted Assembly Bill (AB) 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of the CEC is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger; develop energy technologies and renewable energy resources; plan for and direct State responses to energy emergencies; and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code (PRC) Section

11 United States Energy Information Administration. 2023. California State Profile and Energy Estimates, Table F10: Motor gasoline consumption, price, and expenditure estimates, 2023. Website:
eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_mg.html&sid=CA (accessed April 2025).

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21100(b)(3) and State CEQA Guidelines Section 15126.4 to require Environmental Impact Reports (EIRs) to include, where relevant, mitigation measures proposed to minimize the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created Appendix F to the State CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy and the means of achieving this goal, including (1) decreasing overall per capita energy consumption; (2) decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3) increasing reliance on renewable energy sources.

Senate Bill 1389, Energy: Planning and Forecasting. In 2002, the State Legislature passed Senate Bill (SB) 1389, which required the CEC to develop an integrated energy plan every 2 years for electricity, natural gas, and transportation fuels for the California Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for zero emission vehicles (ZEVs) and their infrastructure needs, and encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate pedestrian and bicycle access.

In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report every 2 years and an update every other year. The most recently adopted reports include the 2023 Integrated Energy Policy Report12 and the 2024 Integrated Energy Policy Report Update.13 The Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecast, and the California Energy Demand Forecast.

The Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs.

Renewable Portfolio Standards. SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially required that 20 percent of electricity retail sales be served by renewable resources by 2017; however, this standard has become more stringent over time. In 2006, SB 107 accelerated the standard by requiring that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that 33 percent of electricity retail sales be served by renewable resources by 2020. In 2015, SB 350 established tiered increases to the Renewable Portfolio Standards of 40 percent by 2024, 45 percent by 2027, and 50 percent by 2030. In 2018, SB 100 increased the

12 California Energy Commission (CEC). 2023. 2023 Integrated Energy Policy Report. Docket Number: 23- IEPR-01.
13 California Energy Commission (CEC). 2024. 2024 Integrated Energy Policy Report Update. Docket Number:
24-IEPR-01.

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requirement to 60 percent by 2030 and required that all State's electricity to come from carbon-free resources by 2045. SB 100 took effect on January 1, 2019.14 Title 24, California Building Code. Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards, embodied in Title 24 of the California Code of Regulations (CCR), known as the California Building Code (CBC). The CEC first adopted the Building Energy Efficiency Standards for Residential and Nonresidential Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The CBC is updated every 3 years, and the current 2022 CBC went into effect on January 1, 2023. The efficiency standards apply to both new construction and rehabilitation of both residential and non-residential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting. The building efficiency standards are enforced through the local building permit process. Local government agencies may adopt and enforce energy standards for new buildings, provided these standards meet or exceed those provided in CCR Title 24. Title 24 standards are updated every 3 years and was most recently updated in 2022 to include new mandatory measures for residential as well as non-residential uses; the new measures took effect on January 1, 2023. The measures include both solar photovoltaic system and solar ready requirements that apply to new low-rise residential buildings. Requirements include energy storage systems and electric vehicle charging systems.

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

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

14 California Public Utilities Commission (CPUC). 2020. Renewables Portfolio Standard (RPS) Program.

Website: https://www.cpuc.ca.gov/rps/ (accessed April 2025).

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• 50 percent of new major renovations of State buildings will be ZNE by 2025.

In 2011, the Energy Efficiency Strategic Plan was updated to include the Lighting Chapter that requires that its strategies be incorporated into energy efficiency program planning and implementation starting in 2011.

4.6.2.3 Local Policies and Regulations
City of Fresno General Plan. The City of Fresno’s General Plan Resource and Conservation Element includes objectives and policies that work to reduce the consumption of non-renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources. The following policies related to energy are applicable to the proposed project:Policy RC8-b:

Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 KWh per year and non-residential electricity use to 2,700 KWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost-effective savings.

Policy RC-8-c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by fifteen percent.

Policy RC8-i: Renewable Target. Adopt and implement a program to increase the use of renewable energy to meet a given percentage of the city’s peak electrical load within a given time frame.

Policy RC8-j: Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

4.6.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to energy that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less-than-significant level. Cumulative impacts are also addressed.

4.6.3.1 Significance Criteria
Based on State CEQA Guidelines Appendix G, the proposed project would have a significant impact related to energy if it would:
a. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or b. Conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

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4.6.3.2 Project Impacts
The following discussion describes the potential impacts related to energy resources that could result from implementation of the proposed project.

EN-1 The project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

The proposed VMT Reduction Program would not include funding for development of any habitable structures or other uses that would result in building energy consumption, and therefore would not cause changes to the City’s or County’s electricity or natural gas consumption.

In addition, implementation of the proposed VMT Reduction Program would result in construction activities associated with VMT-reducing transportation improvements funded by the program, which would result in construction fuel consumption. However, construction details of these projects are unknown at this stage of the planning process and therefore, the associated construction fuel consumption cannot be quantified at this time. Each individual transportation improvement is expected to be small in scale (in the context of Citywide and Countywide energy consumption) with a limited construction duration, and would not significantly increase the City’s or County’s construction fuel consumption. Additionally, all future transportation improvements, including those implemented as part of development projects, would require separate environmental review under CEQA (e.g., preparation of a Categorical Exemption, Mitigated Negative Declaration, or Environmental Impact Report) to evaluate project-specific energy consumption impacts and identify any required mitigation.

Further, the intent of the proposed program is to reduce Citywide VMT, which would proportionally reduce Citywide operational fuel consumption. Since the details of the potential transportation improvements are unknown at this stage of the planning process, total operational fuel consumption reduction associated with the future transportation improvements cannot be quantified at this time. (CEQA Appendix F - Criterion 1).

Construction-Related Energy. During construction, the transportation improvements would consume energy in two general forms: (1) the fuel energy consumed by construction vehicles and equipment; and (2) bound energy in construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass. However, as stated, construction details of these improvements are unknown at this stage of the planning process, and these improvements could be built at any time in the future as funding provided by the proposed program becomes available. Therefore, construction-related energy consumption that may occur at any one time is speculative and cannot be accurately determined at this time. Additionally, as stated above, future transportation improvements, including those implemented as part of development projects would be subject to environmental review on a project-by- project basis, and specific mitigation measures would be implemented to reduce construction-related energy consumption impacts during construction, as needed.

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Some incidental energy conservation would occur during construction through compliance with State requirements that equipment not in use for more than five minutes be turned off. Construction equipment would also be required to comply with the latest U.S. Environmental Protection Agency (EPA) and California Air Resources Board (CARB) engine emissions standards. These emissions standards require highly efficient combustion systems that maximize fuel efficiency and reduce unnecessary fuel consumption. In addition, because the cost of fuel and transportation is a significant aspect of construction budgets, contractors have a strong financial incentive to avoid wasteful, inefficient, and unnecessary consumption of energy during construction (CEQA Appendix F - Criterion 4).

Significant reductions in energy inputs for construction materials can be achieved by selecting construction materials composed of recycled materials that require less energy to produce than nonrecycled materials. The integration of resource-efficient construction materials can help reduce environmental impacts associated with the extraction, transport, processing, fabrication, installation, reuse, recycling, and disposal of these construction materials.15 It is noted that construction fuel use is temporary and would cease upon completion of construction activities. There are no unusual characteristics associated with future transportation improvements funded by the proposed program that would necessitate the use of construction equipment, materials, or methods that would be less energy efficient than at comparable construction sites in the region or State.

Therefore, fuel energy and construction materials consumed during construction would not represent a significant demand on energy resources (CEQA Appendix F - Criterion 5).

Overall, construction energy use associated with future VMT-reducing projects funded by the proposed program would not be any more inefficient, wasteful, or unnecessary than other similar development projects of this nature. As a result, a less-than-significant impact would occur related to construction energy.

Operational Energy. Future transportation improvement projects funded by the proposed program may include new buses, increase in bus service, pedestrian improvements in underserved neighborhoods, among several improvements; refer to Table 3.A, Potential VMT-Reducing Improvements. Such improvements would require operational energy use. However, implementation of future transportation improvements funded by the proposed program, as a whole, would reduce Citywide VMT and associated fuel consumption, and therefore would not result in excessive long- term operational fuel consumption (CEQA Appendix F - Criterion 2). The lighting and other electric element required by the improvements would be minimal and would not cause additional peak and base period demands for electricity (CEQA Appendix F - Criterion 3). The key drivers of transportation-related fuel consumption are job locations/commuting distance and many personal choices on when and where to drive for various purposes. The increase in bus service, through new buses, efficient transportation demand management and increase in number of buses would encourage residents, workers, and visitors to use alternative transportation methods, including walking, biking, and transit, and contribute towards improving the overall traffic flow throughout Fresno. Therefore, implementation of the proposed program would contribute towards reducing Citywide fuel consumption (CEQA Appendix F - Criterion 4 and Criterion 6). Overall, fuel

15 California Department of Resources Recycling and Recovery, Green Building, https://www.calrecycle.ca.gov/greenbuilding/ (accessed April 2025).

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consumption associated with the proposed program would not be considered inefficient, wasteful, or unnecessary in comparison to other developments in the region. As a result, a less-than- significant impact would occur.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

EN-2 The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Future transportation improvement projects funded by the proposed program would be required to comply with objectives and policies included in the approved General Plan that are aimed at reducing energy consumption in the Planning Area. In addition, where applicable, Future transportation improvement projects funded by the proposed program that require construction would be required to comply with the CALGreen Code (CCR Title 24, Part 11) and the California Energy Code (CCR Title 24, Part 6), which includes provisions related to insulation and design aimed at minimizing energy consumption.

Future projects facilitated by the proposed VMT Reduction Program would be required to comply with federal, State, and local regulations aimed at reducing energy consumption. Implementation of the proposed program is intended to reduce fuel consumption by reducing vehicle miles traveled. In addition, the City’s General Plan includes several objectives and policies aimed at reducing energy consumption specifically within the Planning Area. These objectives and policies have been developed in accordance with federal and State energy regulations, such as the California Energy Code Building Energy Efficiency Standards (CCR Title 24, Part 6), the CALGreen Code (CCR Title 24, Part 11), and SB 743, which are also aimed at reducing energy consumption. Therefore, the implementation of the proposed project would be consistent with applicable State and local plans related to renewable energy and energy efficiency, and no mitigation would be required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

4.6.3.3 Cumulative Impacts
CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.” The cumulative analysis below considers the proposed project’s impacts in conjunction with future buildout of the General Plan.

EN-3 The project, in combination with other projects, would not contribute to a significant cumulative impact related to energy.

Development of cumulative projects within the PG&E service area which encompasses 70,000 square miles would result in a substantial increase in electricity and natural gas demand as well as an increase in the consumption of fuel for vehicles. The jurisdictions throughout the PG&E service area

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are working with the state to reduce the consumption of energy. Given that development within the Planning Area would be required to adhere to the policies identified in the approved General Plan, implementation of the proposed VMT Reduction Program would not contribute to potential cumulative impacts associated with the potential inefficient, wasteful and unnecessary consumption of energy within other parts of the PG&E service area. In addition, compliance with the objectives and policies identified above would not result in the inefficient, wasteful and unnecessary consumption of energy. The City’s General Plan includes several policies to reduce the demand for electricity and natural gas. Furthermore, implementation of the approved General Plan includes intensive land uses and transit opportunities to reduce fuel consumption. Implementation of the proposed VMT Reduction Program would complement buildout of the approved General Plan by implementing several transportation improvements that would reduce energy use. As a result, implementation of the proposed project, in conjunction with the implementation of the approved General Plan would result in a less-than-significant cumulative impact related to the inefficient, wasteful and unnecessary consumption of energy.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

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4.7 GEOLOGY AND SOILS
This section describes the regulatory framework and existing conditions in the project area related to geology and soils, and the potential impacts resulting from implementation of the proposed project.

4.7.1 Existing Environment Setting
The study area for project impacts regarding geology and soils is the City of Fresno Planning Area. given that implementation of the proposed project would be limited to areas within the Planning Area.

4.7.1.1 Regional Setting
The City of Fresno Planning Area is located along the eastern margin of the southern San Joaquin Valley portion of the Great Valley Geomorphic Province of California. The San Joaquin Valley is bordered to the north by the Sacramento Valley portion of the Great Valley, to the east by the Sierra Nevada, to the west by the Coast Ranges, and to the south by the Transverse Ranges. The San Joaquin sedimentary basin is separated from the Sacramento basin to the north by the buried Stockton arch and associated Stockton Fault. The 450-mile long Great Valley is an asymmetric structural trough that has been filled with a prism of Mesozoic and Cenozoic sediments up to 5 miles thick.

The Sierra Nevada, located east of the San Joaquin Valley, is a gently southwesterly tilted fault block comprised of igneous and metamorphic rocks of pre-Tertiary age that comprise the basement beneath the San Joaquin Valley. The Coast Ranges, located west of the San Joaquin Valley, are comprised of folded and faulted sedimentary and metasedimentary rocks of Mesozoic and Cenozoic age.

The San Joaquin River and the Kings River are the principal rivers in the Planning Area, with the alluvial fans formed by these rivers serving as the predominant geomorphic features in the area. The Planning Area is generally characterized by low alluvial fans and plains, which constitute a belt of coalescing alluvial fans of low relief between the dissected uplands, adjacent to the Sierra Nevada and the valley trough. Recent alluvial fan deposits from streams emerging from highlands surrounding the Great Valley and Pleistocene non-marine sedimentary deposits (Riverbank Formation) composed of older alluvium and dissected fan deposits underlain the subject site area.

Lithology. The thick accumulation of deposits within the San Joaquin Valley range in age from Jurassic to Holocene and include both marine and continental rocks and deposits. The 1965 Geologic Map of California, Fresno Sheet, indicates that the near-surface deposits in the City of Fresno Planning Area consist of Quaternary recent fan deposits and Quaternary Older alluvium (Pleistocene Nonmarine Sedimentary deposits).

The subsurface information available for the Planning Area indicates that the surface and near- surface deposits generally consist of sandy silts, silty sands, sands, clayey sands, sandy clays, and clayey silts. These observed deposits are consistent with those mapped in the Planning Area.

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Structures and Faults. The City of Fresno Planning Area is underlain by a homoclinal series of Cenozoic deposits dipping four to six degrees to the southwest toward the center of the San Joaquin Valley. The contact between the Cenozoic and basement rocks dips nearly eight degrees southwest, or at a slightly greater inclination than does the on-lapping homoclinal Cenozoic sequence. No active faults are mapped within the Planning Area.

Adjacent to the San Joaquin Valley, the Sierra Nevada and Coast Ranges are geologically young mountain ranges that possess active and potentially active fault zones. Major active faults and fault zones occur at some distance to the east, west, and south of the Planning Area.

Numerous active faults are present within the central Coast Ranges west of the Planning Area including the San Andreas Fault located approximately 61 miles west of the area. The fault is considered active and serves as a primary concern in evaluating seismic hazards throughout western Fresno county. The 684-mile-long San Andreas Fault Zone is the principal element of the San Andreas Fault system, a network of faults with predominately dextral strike-slip displacement that collectively accommodates the majority of relative north-south motion between the North America and Pacific plates. The creeping section of the San Andreas Fault is approximately 61 miles from the Planning Area at its closest point. The San Andreas Fault Zone is considered to be the Holocene and historically active dextral strike-slip fault that extends along most of coastal California from its complex junction with the Mendocino Fault Zone to the north, southwest to the northern Transverse Range, and inland to the Salton Sea, where a well-defined zone of seismicity transfers the slip to the Imperial Fault along a right-releasing step.

Two major surface-rupturing earthquakes have occurred on the San Andreas Fault in historic time:
the 1857 Fort Tejon and 1906 San Francisco earthquakes. Additional historic surface rupturing earthquakes include the unnamed 1812 earthquake along the Mojave section and the northern part of the San Bernardino Mountains section, and a large earthquake in the San Francisco Bay area that occurred in 1838 that was probably on the Peninsula section. Historic fault creep rates are as high as 32 millimeters per year for the 82-mile-long creeping section in central California, with creep rates gradually tapering to zero at the northwestern and southeastern ends of the section.

One of the nearest seismotectonic sources is the Great Valley Fault Zone (Coast Ranges-Central Valley boundary zone), located approximately 34 miles west of the Planning Area. The Great Valley Fault Zone is the geomorphic boundary of the Coast Ranges and the Central Valley and is underlain by a 300-mile long seismically active fold and thrust belt that has been the source of recent earthquakes, such as the 1983 magnitude 6.5 Coalinga and the 1985 magnitude 6.1 Kettleman Hills earthquakes. Nearly the entire thrust system is concealed or “blind.” The basal detachment of this thrust system dips at a shallow angle to the west. East-directed thrusting over ramps in the detachment and west-directed thrusting on backthrusts are responsible for the uplift along the eastern range front of the Coast Ranges. Based on earthquake focal mechanisms, movement on the thrust zone is generally perpendicular to the strike of the geomorphic boundary and trend of the San Andreas Fault system. Shortening along the geomorphic boundary is driven by a component of the Pacific-North American Plate motion that is normal to the plate boundary. The Great Valley Fault Zone is considered the dominant seismic feature with potential for affecting the Planning Area.

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The Ortigalita Fault Zone is a major Holocene dextral strike-slip fault in the central Coast Ranges that is an eastern part of the larger San Andreas Fault system. The Ortigalita Fault Zone is approximately 54 miles west of the Planning Area. The Ortigalita Fault Zone extends from roughly 12.4 miles northwest of San Luis Reservoir southeast to the vicinity of Panoche Valley. The Ortigalita Fault Zone is characterized by echelon fault traces separated by pull-apart basins. The fault zone is divided into four sections. The Little Panoche Valley section is the southernmost section and is closest to the Planning Area. The Little Panoche Valley section is late Holocene active. Late Quaternary slip rates and recurrence intervals are unknown, although the recurrence interval for the entire Ortigalita Fault Zone is about 2,000 to 5,000 years.

Regional structure within the western Sierra Nevada north of the Planning Area is complex and generally consists of blocks separated by steeply eastward-dipping, north, and northwest striking reverse faults of the Foothills Fault system. The Foothills Fault system is located within approximately 32 miles north of the Planning Area. Based on mapping and historical seismicity, the seismicity of the Sierra Nevada foothills has been generally considered low by the scientific community. However, on August 1, 1975, a 5.7 Richter magnitude earthquake occurred near Oroville within the northern Sierra Nevada. Surface rupture along the Cleveland Hill Fault (part of the Foothills Fault System) was associated with the 1975 Oroville earthquake. As a result of this event, numerous studies were undertaken to evaluate further the seismicity of the Sierra Nevada foothills. Of particular note are the geologic and seismicity studies conducted by Woodward-Clyde Consultants (WCC) to evaluate the proposed Auburn Dam site. Based on these studies, WCC concluded that seismic events in the Sierra Nevada foothills are associated with very small, geologically infrequent, incremental displacements having minor geomorphic surface expression.

In addition, the eastern border of the southern San Joaquin Valley is cut by a series of en-eschelon range-front faults. These faults are mainly northwest trending normal faults, down dropped to the west and with a near vertical dip. One of the range-front faults, the Clovis Fault, is mapped extending from an area just south of the San Joaquin River to a few miles south of Francher Creek approximately six miles northeast of the Planning Area. No evidence has been found of historic ground movement along this feature. These range-front faults have generally been considered inactive, with no recognized Quaternary displacement. However, a September 1973 magnitude 4.4 earthquake that occurred approximately 4.3 miles north of the Planning Area may be related to this fault system.

The Nunez Fault is located approximately six to seven miles northwest of Coalinga and is roughly 48 miles southwest of the Planning Area. The fault is about 2.6 miles long and is considered active based on surface rupture associated with the 1983 Coalinga earthquake. The fault is divided into two north and south trending segments. Approximately 2.1 miles of right-reverse surface rupture occurred on the segments. Total displacement and timing of past fault movements are poorly constrained.

Tensional forces resulting in normal faults are reported to be related to crustal stress relief in the southeast portion of the San Joaquin Valley. Numerous relatively short, normal faults traverse this region. Creep activity is the prominent mode of slip on those faults in this region that are active.

These movements have continued on an intermittent basis from the early Miocene to recent times.

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This faulting is directly related to and controls the accumulation of oil in several oil fields within the westerly portion of the valley. Most authors agree that current creep movements can be ascribed to subsidence promoted by extensive withdrawal of petroleum, and in some cases, groundwater.

Those faults considered to be active in the southern valley are Kern Front and Pond Faults located at least 70 miles south of the Planning Area.

The Sierra Nevada and Owens Valley Fault Zones bound the eastern edge of the Sierra Nevada block more than 90 miles east of the Planning Area. The Owens Valley Fault Zone branches to the east of the Sierra Nevada Fault Zone approximately 2 miles south of the Alabama Hills. The Owens Valley Fault Zone is roughly 75 miles long and extends to the west side of Owens Lake to a few miles north of Big Pine. The maximum width of the fault zone is about 2 miles. The Owens Valley Fault generated one of California's greatest historical earthquakes (Owens Valley Earthquake of 1872) and poses a significant hazard to the communities on the eastern side of the Sierra Nevada Mountains.

The White Wolf Fault, responsible for a 1952 earthquake that caused extensive damage in the greater Bakersfield area, is located in the tectonically active Tehachapi Mountains at the southerly terminus of the valley, over 100 miles south of the Planning Area.

4.7.1.2 Planning Area Setting
General Setting and Surface Features. The City of Fresno Planning Area encompasses an approximate 166 square miles, just south of the San Joaquin River, in the central portion of Fresno county, California. The natural topography within the Planning Area generally trends from the northeast towards the southwest. The historically natural, agricultural, and manmade flow for drainage channels predominately follows the northeast to southwest trend. However, because the Planning Area was historically developed for agricultural use, there are also many subchannels designed to transport water in a northwest-southeast direction.

Surface faulting is absent within the Planning Area and the majority of the area is relatively flat.

However, slopes associated with the San Joaquin River bluff are on the order five feet to greater than 100 feet high. The bluff slopes in the vicinity of existing developments were generally well maintained and appeared to be relatively stable. However, the bluff slopes in predominately undeveloped and/or agricultural areas are in relatively good to poor condition with varying degrees of instability and disrepair.

Subsurface Conditions. Subsurface soil conditions in the Planning Area have been previously explored by drilling hundreds of geotechnical borings to depths ranging from approximately 5 to 150 feet below existing site grade, using a truck-mounted drill rig. Over time, penetration tests were performed throughout the Planning Area to evaluate soil consistency and to obtain information regarding the engineering properties of the subsoils, and soil samples were retained for laboratory testing. The soils encountered were continuously examined and visually classified in accordance with the Unified Soil Classification System.

The subsurface conditions encountered appear typical of those found in the geologic region of the Planning Area. Generally, the upper soils consisted of approximately 6 to 12 inches of very loose silty sand, silty sand with trace clay, sandy silt, clayey sand, or clayey gravel. These soils are disturbed, have low strength characteristics, and are highly compressible when saturated.

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Below the loose surface soils, approximately two to four feet of loose/soft to very dense/hard clays, silts, sands, and gravels are typically encountered. Previous field and laboratory tests associated with various projects throughout the Planning Area suggest that these soils are typically moderately strong and slightly to moderately compressible. The clayey soils had a low to high expansion potential. Penetration resistance ranged from less than 5 to greater than 100 blows per foot. Dry densities ranged from 80 to 120 per cubic foot (pcf). Representative soil samples typically consolidate approximately 0.5 to 12 percent under 2 kilos per square foot (ksf) load when saturated.

Representative soil samples had angles of internal friction ranging from 11 to 40 degrees.

Representative samples of the clayey soils had expansion indices ranging from 0 to 100+.

Below 3 to 5 feet, predominately clays, silts, sands, and gravels are usually encountered. Previous field and laboratory tests associated with various project throughout the Planning Area suggest that these soils are typically moderately strong and slightly compressible. Penetration resistance ranges from 10 to greater than 100+ blows per foot. Dry densities ranged from 90 to 140 pcf. Representa- tive soil samples typically consolidate approximately two to three percent under a 2 ksf load when saturated. These soils usually have slightly stronger strength characteristics than the upper soils and extend to the termination depth of the borings.

Test boring locations for various projects throughout the Planning Area were checked for the presence of groundwater during and immediately following the drilling operations. Groundwater was encountered near the surface in the vicinity of existing ponds, lakes, ditches, and canals, to depths greater than 100 feet below site grade during the field investigations. Review of groundwater elevation data provided by the California Department of Water Resources dating from the 1950’s to 2019 indicates that depth to free groundwater in the vicinity of the Planning Area ranged from 0 feet to greater than 100 feet below the existing grade within the Planning Area. 1 Geological Subgrade. The general soil profile within the City of Fresno Planning Area consists predominately of silty sands, sandy silts, clayey sands, sandy clayey silts, and sands. With the exception of a limited occurrence of near-surface loose soils, penetration resistance and laboratory testing indicate that these materials are typically at least medium dense. Based on the soil properties of specific sites, each site will be classified as a Site Class. The Site Class, per Section 1613.2.2 of the 2019 California Building Code, is assigned to a site based upon the types of soils present and their engineering properties. Site Class D, characterized as stiff soil, is most consistent with the soil conditions in the Planning Area. However, within isolated locations through the Planning Area, and in close proximity to water features, Site Class E conditions (soft soil profile) may be encountered.

Liquefaction. Liquefaction is a seismic phenomenon in which loose, saturated, fine-grained granular soils behave similarly to a fluid when subjected to high-intensity ground shaking. Liquefaction occurs when shallow groundwater; low density, fine, clean sandy soils; and high intensity motion occurs.

Effects of liquefaction can include sand boils, settlement, and bearing capacity failures below foundations.

1 California Department of Water Resources. Water Data Library. Website:
https://wdl.water.ca.gov/waterdatalibrary/Map.aspx (accessed January 2025).

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The predominant soils anticipated to be encountered within the Planning Area consist of varying combinations of very loose/very soft to very dense/hard silts, clays, sands, and gravels. Moderate cohesion strength is associated with the clayey soils. Groundwater has been encountered near the surface during exploratory drilling, in close proximity to water filled features such as canals, ditches, ponds, and lakes. Historically, groundwater in the Planning Area has been encountered at depths as shallow as 0 feet to greater than 100 feet below the ground surface.

Seismic Settlement and Lateral Spreading. Subsidence of the land surface can be induced by both natural and human phenomena. Natural phenomena that can cause subsidence can result from tectonic deformations and seismically induced settlements; from consolidation, hydrocompaction, or rapid sedimentation; from oxidation or dewatering of organic-rich soils; and from subsurface cavities. Subsidence related to human activity can result from withdrawal of subsurface fluids or sediment, such as pumping of groundwater.

Lateral spreading is the horizontal movement or spreading of soil toward an open face, such as a stream bank, the open side of fill embankments, or the sides of levees. The potential for failure from subsidence and lateral spreading is highest in areas where the groundwater table is high, where relatively soft and recent alluvial deposits exist, and where creek banks are relatively high. One of the most common phenomena during seismic shaking accompanying any earthquake is the induced settlement of loose unconsolidated soils. Due to the subsurface conditions within the Planning Area, and the relatively low to moderate seismicity of the region, the City of Fresno Planning Area is not located in an area within a seismic settlement or lateral spread hazard area.

Land Subsidence. Portions of the San Joaquin Valley have been subject to land subsidence due to fluid withdrawal (groundwater and petroleum). Land subsidence affects 3,500 square miles of productive farm land in the San Joaquin Valley as intense pumping of groundwater continues. Over 20 feet of subsidence has occurred in western Fresno county. Subsidence was first recognized in the valley in 1935, when surveys discovered differential settlements in areas of intensive pumping. With the accelerated use of groundwater for agriculture, subsidence has continued to the present. Today, one-third of the entire San Joaquin Valley is subsiding and damage costs and remedial expenditures represent many millions of dollars. Damage caused by subsidence has been restricted principally to significant changes in gradients of canals, aqueducts, and drainage systems, and breakage of deep water-well casings.

Within the San Joaquin Valley, subsidence is concentrated in the southern part and west side of the valley where rainfall is sparse and groundwater recharge is minimal. The subsidence has been greatest in three areas: an elongated trough close to the mountains west of Fresno, where more than 20 feet of subsidence occurred between 1920 and 1963 and total subsidence is approximately 28 feet; a location 30 miles south of Tulare, where more than 12 feet of subsidence has occurred; and an area located south of Bakersfield, where more than 8 feet of subsidence has occurred. These three areas are not located within the Planning Area. Subsidence rates vary greatly from year to year, and subsidence continues in all areas except south of Tulare where surface water imports have reversed the downward trends of water levels.

Expansive Soils. Expansive soils are composed largely of clays, which greatly increase in volume when saturated with water and shrink when dried. Because of this effect, building foundations may

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rise during the rainy season and fall during the dry season. If this expansive movement varies underneath different parts of a single building, foundations may crack, structural portions of the building may be distorted, and doors and windows may become warped so that they no longer function properly. The potential for soil to undergo shrink and swell is greatly enhanced by the presence of a fluctuating, shallow groundwater table. Volume changes of expansive soils can result in the consolidation of soft clays following the lowering of the water table or the placement of fill.

The surface and near-surface soils observed throughout the City of Fresno Planning Area consist of varying combinations of clays, silts, sands, gravels, and cobbles. The clayey soils are considered to be slightly to moderately expansive.

Slope Stability, Slope Failure, and Landslides. Landslides are the release of rock, soil, or other debris and its subsequent movement down a slope or hillside. They are generally caused or controlled by a combination of geology, topography, weather, and hydrology, and can be influenced by develop- ment practices. Landslides vary greatly in size and composition, ranging from a thin mass of soil a few yards wide to deep-seated bedrock slides miles across. The travel rate of a landslide can range from a few inches per month to many feet per second depending on the slope, type of materials, and moisture content.

Any slope of 15 degrees or greater is susceptible to mud or landslides. Landslides and other ground failures 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. Both natural and man-made factors contribute to these slope failures.

Ground failure occurs when stresses in the ground exceed the resistance of earth materials to deformation or rupture. This instability can be triggered by earthquake shaking, which instantane- ously places high stresses on earth materials by loss of soil strength due to saturation or seismic shaking. Ground failure can also be triggered by manmade changes, such as loading a steep slope or unstable soils.

Landslides are perhaps the most common form of ground failure that is not caused by earthquakes.

In areas where a severe slope stability problem exists, landslide damage can best be avoided by not building on the unstable ground. In some landslide-prone areas, landslides can be totally removed or stabilized. Through good planning and careful controlled design, landslide losses can be all but eliminated.

Although slope failures are not expected to produce a regional disaster, there is a persistent risk of damage to public and private property, including individual residences, roads, canals, reservoirs, and other facilities. The two most important factors influencing the performance of slopes are the nature of the bedrock or surficial deposits and the slope angle. However, there are a number of other factors that have a profound effect on the stability of a particular hillside. These include the presence or absence of deep-rooted vegetation; surface and subsurface drainage conditions; thickness and engineering characteristics of soils and underlying weathered, partially decomposed rock; orientation of bedding; or locally high rainfall can exert a controlling effect on the intensity of natural processes occurring on a particular hillside.

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City and County General Plans historically have recognized that major slope areas in excess of 26 percent are "not readily available" and "undevelopable," recognizing the cost and engineering difficulties of grading steep slopes as well as their inherent unsuitability. This development limit generally agrees with customary limits throughout the State, and varies only slightly from the 30 percent standard reference developed by the State Division of Mines and Geology as the maximum developable slope. This is a statewide reference that does not reflect special conditions such as clayey soils.

Whether a landslide will or will not occur at any specific, presently stable slope usually cannot be predicted under "natural conditions" because of the range of natural conditions and changes which occur with time. However, land that has experienced land sliding in the past is believed to be generally more slide-prone and is also more sensitive to man-induced changes, such as grading, watering, removing or changing the type of vegetation, and changing drainage patterns, among many possible factors.

Paleontologic/Geologic Context. The general structure of the central San Joaquin Basin had begun to take shape in the Late Cretaceous (65 to 75 million years ago [MYA]) as the effects of subductive North American and Pacific Plates collision lifted once extremely deep ocean sediments above sea level. During the Paleocene (65 to 53 MYA) and Eocene (53 to 35 MYA) Epochs, regional changes in the structure of the Earth’s crust caused the Basin to rise and fall below sea level numerous times.

During periods when the area was above sea level, large deltas brought sediment out of the Sierras to the east with smaller amounts out of the Diablos to the west. During periods when the Basin was below sea level, sedimentation within a shallow sea environment at maximum several hundred feet deep would occur. The deeper rocks and strata in the Basin, as encountered by petroleum geologists, reflect the fresh and saltwater layer-cake nature of geological time, and many of the deeper petroleum and natural gas deposits trapped by oceanic sedimentation are under extremely high pressure.

By the Miocene Epoch, the relationship between the North American and Pacific Plates had changed from subduction to transpression, and the Pacific Plate began sliding northwest. Tremendous volumes of sediment ran into the Basin, filling it by the end of the Pliocene Epoch (5 to 2 MYA) as the seaways were cut off, and raising the land level above the sea. The surrounding mountains were uplifted by tectonic pressure at the same time erosion filled the valleys below. The San Joaquin quickly became a major trap for freshwater and as the water table rose, and the massive Lake Corcoran formed filling the southern and middle San Joaquin Valley with a deltaic outlet to the sea west of Sacramento. Finally, during the Pleistocene Epoch, the deeper areas became individual freshwater lakes that filled and shrank as each season progressed. The low nature of the Valley produced large swamps and meandering stream and river channels. Pleistocene-era and earlier rock strata will exhibit freshwater and marine fossils within slow-moving lithological environments, only to be hidden by the non-fossiliferous Holocene strata that has formed within the last 10,000 years.

Krazan performed a geological analysis of the Planning Area. Based on a review of geological information, the geological subgrade of the Planning Area is entirely alluvial consisting of gravels, sands and clays.

Paleontologic/Geologic Research Results. Based on a review of the University of California Museum paleontology vertebrate paleontology database (Appendix F), geological maps indicate that the

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Planning Area consists of Quaternary alluvium with two primary surficial deposits: 1) Pleistocene non-marine and, 2) Quaternary non-marine fan deposits. The Pleistocene non-marine deposits have been more recently referred to as the Riverbank Formation, and are considered to have high potential sensitivity. The Quaternary non-marine terrace deposits consist of undifferentiated Pleistocene-Holocene alluvial sediments and is also considered to have high potential sensitivity.

Based on a database records search at the University of California Museum of Paleontology (UCMP), three Pleistocene Riverbank Formation localities (#V4401, #V65100, and #V81121) were found in surrounding Fresno county, all of which yielded elements of the Rancholabrean (late Pleistocene) vertebrate fauna. Locality #V81121 is referred to the Riverbank Formation, whereas the other two units are unnamed. Locality #V4401 (Tranquility) accounts for 149 of the 151 specimens listed.

Numerous specimens have been published, several of which are types for their species. The recovered faunal assemblage includes pond turtle (Clemmys marmorata), rattlesnake (Crotalus), loon (Gavia), broad-footed mole (Scapanus latimanus), jackrabbit (Lepus), vole (Microtus), wood rat (Neotoma), pocket gopher (Thomomys), badger (Taxidea), grey fox (Urocyon), true fox (Vulpes), coyote (Canis latrans), horse (Equus), bison (Bison), elk (Cervus), and mule deer (Odocoileus). Among these are type specimens of Clemmys marmorata, Scapanus latimanus, and Canis latrans that have been documented in scientific publication. The UCMP database also records 12 plant localities in Fresno county, in the Pleistocene alluvial deposits of the Modesto, Riverbank, and Turlock Lake formations.

4.7.2 Regulatory Setting

4.7.2.1 Federal Policies and Regulations
Earthquake Hazards Reduction Act. The Earthquake Hazards Reduction Act was enacted in 1997 to “reduce the risks to life and property from future earthquakes in the United States through the establishment and maintenance of an effective earthquake hazards and reduction program.” To accomplish this, the act established the National Earthquake Hazards Reduction Program (NEHRP).

This program was significantly amended in November 1990 by the National Earthquake Hazards Reduction Program Act (NEHRPA), which refined the description of agency responsibilities, program goals, and objectives.

NEHRP’s mission includes improved understanding, characterization, and prediction of hazards and vulnerabilities; improvement of building codes and land use practices; risk reduction through post- earthquake investigations and education; development and improvement of design and construction techniques; improvement of mitigation capacity; and accelerated application of research results. The NEHRPA designates the Federal Emergency Management Agency (FEMA) as the lead agency of the program and assigns it several planning, coordinating, and reporting responsibilities.

4.7.2.2 State Policies and Regulations
Alquist‐Priolo Earthquake Fault Zoning Act. In response to the severe fault rupture damage of structures by the 1971 San Fernando earthquake, the State of California enacted the Alquist-Priolo Earthquake Fault Zoning Act in 1972. This act required the State Geologist to delineate Earthquake Fault Zones (EFZs) along known active faults that have a relatively high potential for ground rupture.

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Faults that are zoned under the Alquist-Priolo Act must meet the strict definition of being “sufficiently active” and “well-defined” for inclusion as an EFZ. The EFZs are revised periodically, and extend 200 to 500 feet on either side of identified fault traces. No structures for human occupancy may be built across an identified active fault trace. An area of 50 feet on either side of an active fault trace is assumed to be underlain by the fault, unless proven otherwise. Proposed construction in an EFZ is permitted only following the completion of a fault location report prepared by a California Registered Geologist. This Act does not apply to areas within the Planning Area because no active faults cross the Planning Area.

California Building Code. Title 24, Part 2, of the California Code of Regulations, also known as the California Building Code (CBC), sets forth minimum requirements for building design and construction. Title 24 is administered by the California Building Standards Commission, which, by law, is responsible for coordinating all building standards. The CBC is reviewed every three years by the California Building Standards Commission. The Commission makes certain State modifications, and adopts the new code edition for use throughout the State. Once the Commission votes to adopt the new code edition, it will become effective on the first of January of the upcoming year, regardless of whether local cities or counties formally adopt it. The current version, the 2019 California Buildings Standard Code, became effective on July 1, 2019.

The California Building Standards Code is a compilation of three types of building standards from three different origins:
• Building standards that have been adopted by state agencies without change from building standards contained in national model codes.
• Building standards that have been adopted and adapted from the national model code standards to meet California conditions.
• Building standards, authorized by the California legislature, that constitute extensive additions not covered by the model codes that have been adopted to address particular California concerns.

In the context of earthquake hazards, the California Building Standards Code’s design standards have a primary objective of assuring public safety and a secondary goal of minimizing property damage and maintaining function during and following a seismic event. Recognizing that the risk of severe seismic ground motion varies from place to place, the California Building Standards Code seismic code provisions will vary depending on location (Seismic Zones 0, 1, 2, 3, and 4; with 0 being the least stringent and 4 being the most stringent). The earthquake design requirements take into account the occupancy category of the structure, Site Class, soil classifications, and various seismic coefficients, which are used to determine a Seismic Design Category (SDC) for a project. The SDC is a classification system that combines the occupancy categories with the level of expected ground motions at the site and ranges from SDC A (very small seismic vulnerability) to SDC E/F (very high seismic vulnerability and near a major fault). Design specifications are then determined according to the SDC.

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Counties and cities may modify their adoption of the California Buildings Standard Code to address local conditions. Most California cities and counties modify the State adopted version of the Building Standards Code to address local circumstances related to the local climate, topography, or geology.

Since modifications cannot be less restrictive, California Building Standards Code provides a minimum standard for protecting public health, safety and welfare that is applicable throughout the Planning Area and study area for cumulative impacts.

4.7.2.3 Regional Policies and Regulations
County of Fresno General Plan. The County of Fresno General Plan contains goals and policies that address geology and soils. The following General Plan goal and policies are applicable to the proposed project, and is currently being updated. The policies listed below are from the existing County of Fresno General Plan, adopted in 2000.

Public Facilities Element
Policy PF‐D.6. The County shall permit individual on-site sewage disposal systems on parcels that have the area, soils, and other characteristics that permit installation of such disposal facilities without threatening surface or groundwater quality or posing any other health hazards and where community sewer service is not available and cannot be provided.

Health and Safety Element
Goal HS‐D. To minimize the loss of life, injury, and property damage due to seismic and geologic hazards.

Policy HS‐D.2. The County shall ensure that the General Plan and/or County Ordinance Code is revised, as necessary, to incorporate geologic hazard areas formally designated by the State Geologist (e.g., Earthquake Fault Zones and Seismic Hazard Zones).

Development in such areas, including public infrastructure projects, shall not be allowed until compliance with the investigation and mitigation requirements established by the State Geologist can be demonstrated.

Policy HS‐D.3. The County shall require that a soils engineering and geologic-seismic analysis be prepared by a California-registered engineer or engineering geologist prior to permitting development, including public infrastructure projects, in areas prone to geologic or seismic hazards (i.e., fault rupture, groundshaking, lateral spreading, lurchcracking, fault creep, liquefaction, subsidence, settlement, landslides, mudslides, unstable slopes, or avalanche).

Policy HS‐D.4. The County shall require all proposed structures, additions to structures, utilities, or public facilities situated within areas subject to geologic-seismic hazards as identified in the soils engineering and geologic-seismic analysis to be sited, designed, and constructed in accordance with applicable provisions of the Uniform Building Code (Title 24 of the California Code of Regulations) and other relevant professional standards to minimize or prevent damage or loss and to minimize the risk to public safety.

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Policy HS‐D.8. The County shall require a soils report by a California-registered engineer or engineering geologist for any proposed development, including public infrastructure projects, that requires a County permit and is located in an area containing soils with high “expansive” or “shrinkswell” properties. Development in such areas shall be prohibited unless suitable design and construction measures are incorporated to reduce the potential risks associated with these conditions.

Policy HS‐D.9. The County shall seek to minimize soil erosion by maintaining compatible land uses, suitable building designs, and appropriate construction techniques. Contour grading, where feasible, and revegetation shall be required to mitigate the appearance of engineered slopes and to control erosion.

Policy HS‐D.11. The County shall not approve a County permit for new development, including public infrastructure projects where slopes are over thirty (30) percent unless it can be demonstrated by a California-registered civil engineer or engineering geologist that hazards to public safety will be reduced to acceptable levels.

Policy HS‐D.12. In known or potential landslide hazard areas, the County shall prohibit avoidable alteration of land in a manner that could increase the hazard, including concentration of water through drainage, irrigation, or septic systems, undercutting the bases of slopes, removal of vegetative cover, and steepening of slopes.

County of Fresno Code of Ordinances
Section 15.28.010. Chapter 18, Chapter 33 and Appendix J of the 2013 California Building Code and Section R300 of the California Residential Code are adopted by reference and except as herein otherwise provided are applicable to and shall cover all grading and excavation within the unincorporated area of the County of Fresno.

4.7.2.4 Local Policies and Regulations
City of Fresno General Plan
Noise and Safety Element
Objective NS‐2: Minimize risks of property damage and personal injury posed by geologic and seismic risks.

Policy NS‐2‐a: Seismic Protection. Ensure seismic protection is incorporated into new and existing construction, consistent with the Fresno Municipal Code.

Policy NS‐2‐b: Soil Analysis Requirement. Identify areas with potential geologic and/or soils hazards, and require development in these areas to conduct a soil analysis and mitigation plan by a registered civil engineer (or engineering geologist specializing in soil geology) prior to allowing on-site drainage or disposal for wastewater, stormwater runoff, or swimming pool/spa water.

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Policy NS‐2‐c: Landfill Areas. Require proposed land uses on or near landfill areas to be designed and maintained to comply with California Code of Regulations, Title 27, Section 21190, Post Closure Land Use.

Policy NS‐2‐d: Bluff Preservation Overlay Zone. Per the requirements of the Bluff Preservation Overlay Zone District and Policy POSS-7-f (Chapter 5, Parks and Open Space), the following standards shall be applicable for property located within the Bluff Preservation zone:
• Require proposed development within 300 feet of the toe of the San Joaquin River bluffs to undertake an engineering soils investigation and evaluation report that demonstrates that the site is sufficiently stable to support the proposed development, or provide mitigations to provide sufficient stability; and • Establish a minimum setback of 30 feet from the San Joaquin River bluff edge for all buildings, structures, decks, pools and spas (which may be above or below grade), fencing, lighting, steps, etc.
○ An applicant may request to reduce the minimum setback to 20 feet from the bluff edge if it can be demonstrated, to the satisfaction of the City’s Building Official and the Planning Director, that the proposed building, structure, deck, pool and/or spas (which may be above or below grade), fencing, steps, etc., will meet the objectives of the Bluff Preservation Overlay Ordinance. In no case shall the setback be reduced to less than 20 feet.

City of Fresno Municipal Code
Section 11‐101. California Building Code. The California Building Code, 2016 Edition, which may be referred to in this Code as the CBC, as promulgated by the California Building Standards Commission, which incorporates the adoption of the 2015 edition of the of the International Building Code as amended with necessary California amendments and the 2015 International Building Code of the International Code Council, with the exception of Appendix B, are adopted and incorporated by reference into the Code and shall be referred to, along with the City's amendments to the CBC provided in Section 11-102, as the Fresno Building Code. One copy of the CBC is on file and available for use by the public in the Development and Resource Management Department, Building and Safety Services Division.

Section 15‐1603. Bluff Protection (BL) Overlay District Purpose. The Bluff Protection (BL) Overlay District is intended to provide special land development standards that will preserve the integrity of the natural landscape of the southerly San Joaquin River Bluffs, adjacent properties, and adjacent open spaces as areas of special quality by reason of the topography, geologic substratum, and environment of the area. Regulations for the BL Overlay District are deemed necessary for the preservation of the special qualities of the southerly San Joaquin River Bluffs, and for the protection of the

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health, safety, and general welfare of owners and users of property within the River Bluff Influence Area.

Applicability. The provisions of this article apply to areas within 300 feet of the toe of the San Joaquin River bluff.

Use Regulations. Those uses permitted in the Base District, subject to the limitations and conditions set forth therein.

Development Standards. Development Standards shall be as required by the Base District, except as follows:
• Bluff Setback: Development, including buildings, structures, decks, pools, spas, and steps, shall be setback a minimum of 20 feet from the bluff edge or as identified as necessary for the preservation of the existing state of the bluffs in the soils report prepared pursuant to Section 15-1603-F, Soils Report, whichever is greater. Buildings, structures, decks, pools, spas, and steps include all objects that may be below grade, at grade, or above grade.
• Lighting and Illumination: Streetlights and all exterior lighting shall be directed away from the river bottom.
• Design and Orientation: The design and orientation of structures, walls and fences shall be in keeping with the natural character of the Bluffs. Fences must be open a minimum of 80 percent (i.e., no more than 20 percent opaque) to allow for the passage of light and air.
• Colors and Materials: Construction shall be permitted only on lots subject to recorded deed restrictions or covenants restricting exterior colors and construction materials to those which are compatible with the natural bluff environment and with surrounding development.

Geologic Impact Standards. To minimize potential geologic and soil hazards, the following provisions shall apply to all subdivisions and development within Bluff Zones I, II, and III of the San Joaquin River Bluffs environs:

General Provisions. General provisions for grading, drainage, and erosion:
• Locations of streets, utilities and other facilities shall be approved by the Director and the City Engineer.
• Requirements for the location, design, construction, and maintenance of surface and subsurface drainage facilities shall be as determined by the Fresno Metropolitan Flood Control District.

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• All development within Bluff Zones I, II, and III shall comply with the applicable provisions of the Building Code as adopted and amended by the City. • Drainage of storm and irrigation water shall be directed away from the Bluff Face to public rights-of-way or to drainage facilities approved by the Fresno Metropolitan Flood Control District. A drainage plan shall be provided and approved by the Director for each separate lot within the Bluff Influence Area, establishing methods for conveying surface water from roofs and landscaping, and drain water from all swimming pools or decorative pools to approved locations away from the Bluff Face. • To minimize erosion, the following shall apply to all graded, altered, or unstable bluff areas:
○ Landscaping with drought-tolerant, low-fuel plants, compatible with the bluff environs, from a list prepared by the City.
○ Landscape irrigation shall utilize drip irrigation or low precipitation systems, and must be approved by the civil engineer prior to installation. ○ Hydroseeding, netting and mulch shall be utilized to re-establish plant life, to control erosion and to discourage rodent burrowing.

Soils Investigation. The following types of soil evaluations shall be performed and reported:
• Bluff Zone I: A civil engineer or soils engineer registered in the State of California shall investigate and report on soil and geologic conditions, utilizing methods consistent with accepted practices. The report shall evaluate soils and geologic conditions for development proposals located outside Bluff Zone II and shall be similar in scope to the soils investigation required under Subparagraph ii, below. The investigation and report shall identify potential surface and subsurface drainage problems that may ultimately affect the stability of the bluffs and any measures to mitigate such effects. • Bluff Zone II: A civil engineer or soils engineer registered in the State of California shall provide a detailed Soils Investigation and Evaluation Report using methods consistent with accepted practice and shall include the following:
○ Evaluation of existing stability;
○ Evaluation of post-development slope stability;
○ Documentation of existing conditions for rock falls, block caving, creep failures, shear failures, excessive erosion and sloughing;
○ Evaluation of slope angles, subsurface drainage, proposed grading, structures, utility trenches, potential rodent population, storm drain disposal, surface irrigation and

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drainage, erosion, traffic vibration, potential seismic hazards, and on-site sewage disposal approximate to the bluffs;
○ Evaluation of the influence of future development and grading along the Bluff Toe for its effect on slope stability;
○ Evaluation of the adverse effect of increased surface and subsurface drainage; ○ Coordination, review, and approval of site grading and drainage plans prepared by the project civil engineer for conformance to soils and geologic reports; ○ Laboratory tests to evaluate the soil parameters to be used in determination of slope stability;
○ Determination and establishment of the location of the Bluff Toe, Bluff Edge and of any building setbacks.
• Bluff Zone III: A civil engineer or soils engineer registered in the State of California shall complete a Soils Investigation and Evaluation Report, involving detailed study of individual lots within the River Bluff Influence Area, as follows:
○ Zone III soils investigations will address the details of the configuration, location, type, and loading of the proposed structures and drainage plan; ○ The report shall provide detailed recommendations for foundations, drainage, and other items critical to bluff stability.

Filing. Filing of Soils Investigation and Evaluation Reports shall be required as follows:
• A Zone I, Zone II or Zone III Soils Investigation and Evaluation Report and a grading plan shall be filed at the time of filing any tentative tract map or parcel map providing for lots or portions of lots within Zone I, Zone II or Zone III, or at the time of filing any application for rezoning or for special permits for parcels of land within Zone I, Zone II or Zone III;
• For parcels of land within Zone I, Zone II or Zone III, that are not the subject of the filing of a tentative map or tentative parcel map, or that are not the subject of any application for rezoning or a special permit, a Zone I, Zone II or Zone III Soils Investigation and Evaluation Report and a grading plan shall be filed with any request for a building permit.

Certification. The Soils Investigation and Evaluation Reports shall be certified as follows:
• The engineer responsible for the soils investigation and evaluation report and for the grading plan shall certify that the proposed project will not cause any significant increase in the risk of damage to the bluff from erosion, slippage, subsidence, or other

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movement when grading, drainage, and other slope protection measures have been done in accordance with the Soils Investigation and Evaluation Report and the grading plan. The certificate may be executed on the face of the subdivision map or parcel map or may be contained in a separate instrument delivered to the Director. • The engineer responsible for the soils investigation and evaluation report and for the grading plan for parcels of land for which certification is not provided above shall file written certification with any request for a building permit that the proposed project will not cause any significant increase in the risk of damage to the bluff from erosion, slippage, subsidence or other movement, when grading, drainage and other slope protection have been done in accordance with the soils investigation and evaluation report and the grading plan.

Completion of Erosion Controls. All erosion control measures shall be completed before the issuance of occupancy permits for residences constructed on lots within or partially within Zone II, and shall be completed before the issuance of building permits for structures constructed on lots within or partially within Zone III.

4.7.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to geology and soils that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less than significant level.

Cumulative impacts are also addressed.

4.7.3.1 Significance Criteria
Based on State CEQA Guidelines Appendix G, the proposed project would have a significant impact on geology and soils if it would:
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;
iii. Seismic-related ground failure, including liquefaction; or iv. Landslides.
b. Result in substantial soil erosion or the loss of topsoil.

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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.
d. Be located on expansive soil, as defined in Table 18-1-B of the UBC (1994), creating substantial risks to life or property.
e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

4.7.3.2 Project Impacts
The following discussion describes the potential impacts related to geology and soils that could result from implementation of the proposed project.

GEO‐1 The proposed project would not directly or indirectly cause potential substantial adverse eﬀects, including the risk of loss, injury, or death involving rupture of a known fault, strong seismic ground shaking, seismic‐related ground failure, or landslides.

The proposed project consists of the adoption of a VMT Reduction Program which aims to establish mitigation for future projects that exceed the City’s VMT thresholds in the form of a mitigation bank.

The program would identify, quantify, and prioritize applicable mitigation measures and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank. The following analysis addresses potential seismic hazards in the project area. 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;
According to the Fault Rupture Zones Map prepared by the California Department of Conservation in 2018, the Planning Area is not located within a Fault-Rupture Hazard Area.

Moreover, no active faults have been identified within the Planning Area. The nearest zoned fault to the Planning Area is a portion of the Nunez Fault, located approximately 48 miles southwest of the Planning Area. Therefore, because no active faults occur within the Planning Area, impacts associated with fault rupture would be less than significant. No mitigation is required.
ii. Strong seismic ground shaking;
As with most areas within the State of California, the Planning Area would be exposed to ground shaking from seismic events on local and regional faults. However, the Fresno area has historically experienced a low to moderate degree of seismicity.

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Although the Planning Area occurs in an area with historically low to moderate level of seismicity, strong ground shaking could occur within the Planning Area during seismic events and occurrences have the possibility to result in significant impacts. Major seismic activity along the nearby Great Valley Fault Zone or the Nunez Fault, or other associated faults, could affect the Planning Area through strong seismic ground shaking. Strong seismic ground shaking could potentially cause structural damage to existing or proposed projects in the Planning Area, possibly resulting in damage to facilities and interruption of service.

The proposed project would not result in any physical improvements, or in changes to the distribution or intensity of the land uses within the Planning Area. However, adoption of the proposed VMT Reduction Program would support future multi-modal or transportation improvements in accordance with the program. These future VMT-reducing projects identified by the VMT Reduction Program would be required to comply with construction and design standards of the California Building Code (CBC), the City’s General Plan and the Municipal Code to reduce risks associated with ground shaking hazards. With the implementation of applicable General Plan policies as well as adherence to Municipal Code and other applicable regulations, potential seismic ground shaking impacts would be less than significant.
iii. Seismic‐related ground failure, including liquefaction; or The predominant soils within the Planning Area consist of varying combinations of loose/very soft to very dense/hard silts, clays, sands, and gravels. Groundwater has been encountered near the ground surface in close proximity to water-filled features such as canals, ditches, ponds, and lakes. Based on these characteristics, the potential for soil liquefaction within the Planning Area ranges from very low to moderate due to the variable density of the subsurface soils and the presence of shallow groundwater.

In addition to liquefaction, the Planning Area could be susceptible to induced settlement of loose unconsolidated soils or lateral spread during seismic shaking events. Based on the nature of the subsurface materials and the relatively low to moderate seismicity of the region, seismic settlement and/or lateral spread are not anticipated to represent a substantial hazard within the Planning Area during seismic events. However, if induced settlement or lateral spread does occur, development projects could experience significant

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impacts. Future VMT-reducing projects identified by the VMT Reduction Program would need to comply with requirements of the CBC, as required by Section 11-101 of the Fresno Municipal Code, which would reduce potential settlement and lateral spread impacts to less-than-significant levels. No mitigation is required. iv. Landslides.

The Planning Area is located within an area that consists of mostly flat topography within the Central Valley. Accordingly, there is no risk of large landslides in the majority of the Planning Area. However, there is the potential for landslides and slumping along the steep banks of rivers, creeks, or drainage basins such as the San Joaquin River bluff and the many unlined basins and canals that trend throughout the Planning Area.

The City of Fresno Municipal Code Section 15-1603 requires a soils investigations and assessments of geologic impact standards to be prepared for every subdivision to be performed in the vicinity of the San Joaquin River bluff prior to any new developments or modifications to the bluff area.

As discussed above, the proposed project would not result in any physical improvements, or in changes to the distribution or intensity of the land uses within the Planning Area.

However, adoption of the proposed VMT Reduction Program would support future multi- modal or transportation improvements in accordance with the program. As required by the City’s Municipal Code, future projects listed under the Fresno VMT Reduction Program would be required to implement CBC requirements into project design, which would reduce potential impacts related to landslides to less-than-significant levels. No mitigation is required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

GEO‐2 The proposed project would not result in substantial soil erosion or the loss of topsoil.

Natural forces, both chemical and physical, are continually at work breaking down soils. Erosion poses two hazards: 1) it removes soils, thereby undermining roads and buildings and producing unstable slopes, and 2) it deposits eroded soil in reservoirs, lakes, and drainage structures, and on roads as mudslides. Natural erosion is frequently accelerated by human activities such as site preparation for construction and alteration of topographic features.

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program. These future VMT-reducing projects identified by the VMT Reduction Program would potentially result in site preparation activities, such as grading and trenching, at future project sites located throughout the Planning Area. Future projects would also result in the addition of impervious surfaces within the Planning Area, and depending on the location of the project, could possibly result in the alteration of topographic features at the project site. The alteration of topographic features could lead to increased erosion by creating unstable rock or soil surfaces, by changing the permeability or runoff characteristics of the soil, or by modifying or creating new pathways for drainage.

The Fresno Municipal Code Section 15-1603 requires the preparation of a preliminary soils report that would identify any potential site-specific soil issues, foundation support and grading parameters would be incorporated into the design as required by the Code. Further, Fresno Municipal Code Section 15-3302 requires every approved map to be conditioned on compliance with the requirements for grading and erosion control, including the prevention of sedimentation or damage to off-site property. Compliance with these policies and with other pertinent regulations will ensure that potential soil erosion impacts, or the potential loss of topsoil, would be less than significant. No mitigation is required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

GEO‐3 The proposed project would not 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.

As previously discussed, impacts associated with liquefaction, lateral spreading, and landslides would be less than significant. Portions of the San Joaquin Valley have been subject to land subsidence or collapse due to groundwater and petroleum extraction. Damage caused by subsidence or collapse has been restricted principally to significant changes in gradients of canals and aqueducts, and breakage of deep-water well casings. Within the San Joaquin Valley, subsidence or collapse is concentrated in the southern part and the west side of the valley where rainfall is sparse and groundwater recharge is minimal. Although subsidence or collapse is a significant concern in western Fresno county, as well as other portions of the San Joaquin Valley, the Planning Area is not known to be subject to such subsidence or collapse hazards.

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Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

GEO‐4 The proposed project would not 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.

The surface and near-surface soils observed throughout the Planning Area consist of varying combinations of clays, silts, sands, gravels, and cobbles. The clayey soils are considered to be slightly to moderately expansive. Previously developed areas within the Planning Area contained expansive clayey soils, and it is anticipated that there are localized areas within the Planning Area that contain expansive soils.

As previously discussed, the proposed project would not result in any physical improvements, or in changes to the distribution or intensity of the land uses within the Planning Area. However, adoption of the proposed VMT Reduction Program would support future multi-modal or transportation improvements in accordance with the program. These future VMT-reducing projects identified by the VMT Reduction Program, at the time they are proposed for development, would be developed according to General Plan requirements and would be required to prepare site-specific geotechnical reports to assess sites for potentially hazardous soil conditions and provide measures to mitigate potential impacts associated with them. Further, grading and erosion control measures are required under Section 15-1603 of the City of Fresno Municipal Code. The implementation of the requirements in the City of Fresno Municipal Code would reduce potential expansive soil impacts to less than significant levels. No mitigation is required.

Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

GEO‐5 The proposed project does not contain 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.

The program would identify, quantify, and prioritize applicable mitigation measures and relevant VMT-reducing projects within Fresno to be funded by the proposed mitigation bank. The proposed project would not result in any physical improvements, or in changes to the distribution or intensity of the land uses within the Planning Area. However, adoption of the proposed VMT Reduction Program would support future multi-modal or transportation improvements in accordance with the program. Future VMT-reducing projects identified by the VMT Reduction Program are not anticipated to generate sewage such that construction of a septic system or connection to the City’s wastewater sewage system would be required to manage it. As such, the proposed project would result in no impacts associated with soils that are incapable of supporting septic tanks. No mitigation is required.

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Mitigation Measures: No mitigation measures are required.

Level of Significance: Less Than Significant Impact.

GEO‐6 The proposed project could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Based on a review of geologic maps of the Planning Area, there are two primary surficial deposits:
(1) Pleistocene non-marine; and (2) Quaternary non-marine fan deposits. The Pleistocene non- marine deposits are considered to have a high potential sensitivity. The Quaternary non-marine deposits consist of Pleistocene-Holocene alluvial sediments. Since these deposits include Pleistocene sediments, they are also considered to have a high potential for sensitivity. Therefore, excavation and/or construction activities within the Planning Area have the potential to impact paleontological/geological resources during excavation and construction activities within previously undisturbed soils.

Mitigation Measure GEO‐6 Subsequent to a preliminary City review of the project grading plans, if there is evidence that a project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for unique paleontological/geological resources shall be conducted. The following procedures shall be followed:
• If unique paleontological/geological resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that unique paleontological/geological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified paleontologist shall be consulted to determine whether the resource requires further study. The qualified paleontologist 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. If the resources are determined to be significant, mitigation measures shall be identified by the

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monitor and recommended to the Lead Agency. Appropriate mitigation 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
resources. Any paleontological/geological resources 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.
• If unique paleontological/geological resources are found during the field survey or literature review, the resources shall be inventoried and evaluated for significance. If the resources are found to be significant, mitigation measures shall be identified by the qualified paleontologist. Similar to above, appropriate mitigation 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.

Fresno City CouncilOctober 30, 2025

Fresno City Council
October 30, 2025