LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-18
Policy RC-11-b: Ze ro Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal.
4.4.4 Significance Criteria
The thresholds for greenhouse gas 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 greenhouse gases if it would:
• Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.
Section 15064.4 of the State CEQA Guidelines states “A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project.” In performing that analysis, the lead agency has discretion to determine whether to use a model or methodology to quantify GHG emissions, or to rely on a qualitative analysis or performance-based standards. In making a determination as to the significance of potential impacts, the lead agency then considers the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting, whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
Neither the City of Fresno nor the SJVAPCD has developed or adopted numeric GHG significance thresholds. Therefore, this analysis evaluates the GHG emissions based on the project’s consistency with State GHG reduction goals. The proposed project is evaluated for consistency with the 2022 Scoping Plan, including the proposed project’s compliance with relevant Scoping Plan measures, as well as the FCOG 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). It should be noted that the Scoping Plan is consistent with the AB 1279 GHG reduction targets of achieving carbon neutrality by 2045, and reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. Therefore, consistency with the CARB’s 2022 Scoping Plan would also demonstrate consistency with the carbon neutrality requirements encapsulated by AB 1279.
4.4.5 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to greenhouse gas emissions that could result from implementation of the Specific Plan Update. 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 Specific Plan Update 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.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-19
4.4.5.1 Project Impacts
The following discussion describes the potential impacts related to greenhouse gas emissions that could result from implementation of the Draft Specific Plan.
GHG‐1 T he proposed project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
The proposed project would result in GHG emissions from construction and operational sources.
Construction activities would generate emissions from off-road construction equipment and on roadways as a result of construction-related truck hauling, vendor deliveries, and worker commuting. Operational GHG emissions are typically associated with mobile sources (e.g., vehicle trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). This analysis uses the California Emissions Estimator Model version 2022.1 (CalEEMod) to quantify GHG emissions for both construction and operations associated with buildout of the proposed project. CalEEMod output is contained in Appendix E of this EIR.
Construction Greenhouse Gas Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO
2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.
The City of Fresno does not have an adopted threshold of significance for construction-related GHG emissions. However, emissions that would occur during construction were quantified and are disclosed for informational purposes. Construction emissions for the proposed project were analyzed using CalEEMod. Buildout of the proposed project would occur over a 20-year period beginning with the adoption of the Specific Plan Update, conservatively assumed to being in 2026.
The exact construction schedule is not yet known. Therefore, to provide a conservative estimate of the emissions that could occur due to construction activities, this analysis assumes that project construction will begin in January 2026 and be fully built-out in 2046. Construction phases are expected to occur consecutively; therefore, this analysis evaluates construction emissions as a whole and not per phase. Future site preparation would include removal of rocks, debris, and vegetation. Grading operation is anticipated to be balanced on-site and would not require import or export of materials, which was included in CalEEMod. In addition, this analysis assumes that the proposed project would be constructed using Tier 2 construction equipment, which was included in CalEEMod. Other precise details of construction activities are unknown at this time; therefore, default assumptions (e.g., construction worker and truck trips and construction fleet activities) from CalEEMod were used.
Using CalEEMod, it is estimated that construction of the proposed project would generate a total of 34,876.0 metric tons of CO
2e. As mentioned above, the SJVAPCD has not addressed GHG emissions LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-20
thresholds for construction. However, lead agencies are required to quantify and disclose GHG emissions that would occur during construction. . In order to account for the life cycle emissions during construction and operation, construction GHG emissions were amortized over the life of the project (assumed to be 30 years) and added to the operational emissions. When annualized over the life of the project, amortized construction emissions would be approximately 1,162.5 metric tons of CO
2e per year.
Operation. Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile-source GHG emissions would include project-generated vehicle trips to and from the development site. Area-source emissions would be associated with activities such as landscaping and maintenance within the Specific Plan Area. Energy source emissions would be generated at off-site utility providers because of increased electricity demand generated by the proposed project. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project-generated waste. In addition, water source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.
The proposed project would implement land use changes that would maintain and enhance the character-defining elements associated with the Tower District while allowing for future growth. The majority of the area within the Specific Plan is already developed and not expected to change.
However, implementation of the proposed project would allow for future development projects in the Specific Plan Area that would result in potential increase in planned residential uses and a decrease in commercial land uses when compared to the existing land uses.
CalEEMod was used to calculate the long-term operational emissions associated with implementation of the proposed project. Trip generation rates used in CalEEMod for the proposed project were based on the project’s trip generation as shown in the Transportation Memorandum 16 prepared for the proposed project (Appendix I), which identifies that the proposed project would generate approximately 39,055 average daily traffic (ADT), which was included in CalEEMod. It is not yet known whether the proposed project would utilize natural gas; therefore, this analysis conservatively assumes that natural gas will be included as part of the project operations. In addition, this analysis assumes the proposed project would be operational in 2046, which is included in CalEEMod.
Long-term operational emissions associated with the land uses under the existing conditions were also evaluated in CalEEMod. The existing land use designations in the Tower District include a mix of residential, commercial, public institutions, and pockets of industrial uses. Trip generation rates used in CalEEMod were based on the trip generation described in Appendix I (Tower District Specific Plan Update Transportation Memorandum), which identifies that the buildout of the 1991 Specific Plan and existing uses allowed under the General Plan would generate approximately 36,054 ADT,
16 LSA Associates, Inc. (LSA). 2025e. Tower District Specific Plan Update Trip Generation and Vehicle Miles Traveled Analysis Memorandum.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-21
which was included in CalEEMod. This analysis assumes an operational year of 2025, to represent existing emissions associated with the land uses that are currently existing and operational in the planning area, which is included in CalEEMod. Where project-specific data were not available, default assumptions (e.g., energy usage, water usage, and solid waste generation) from CalEEMod were used to estimate project emissions. CalEEMod output sheets are included in Appendix E.
Table 4.4.C shows the estimated operational emissions associated with the proposed project and the Approved Specific Plan.
Table 4.4.C: Operational Greenhouse Gas Emissions
Emissions Category
Operational Emissions (Metric Tons per Year)
CO2 CH4 N2O CO2e Percentage of Total
Approved Specific Plan – Existing Emissions
Mobile Sources 26,875.0 1.6 1.6 27,427.0 75
Area Sources 1,354.9 2.1 <0.1 1,408.3 4
Energy Sources 6,338.2 0.7 0.1 6,371.1 18
Water Sources 135.6 6.4 0.2 340.8 <1
Waste Sources 224.0 22.4 0.0 783.6 2
Total Existing Emissions 36,330.8 100.0
Proposed Project Emissions
Mobile Sources 21,897.0 0.8 1.2 22,273.0 71
Area Sources 47.0 <0.1 <0.1 47.1 <1
Energy Sources 7,543.2 0.9 0.1 7,582.0 24
Water Sources 156.2 7.4 0.2 393.0 1
Waste Sources 270.2 27.0 0.0 945.5 3
Total Proposed Project Emissions 31,240.6 100.0
Amortized Construction Emissions 1,162.5 -
Total Proposed Project Operational Emissions 32,403.1
Total Net Annual Emissions -3,927.7 -
Source: Compiled by LSA (January 2024).
Note = Some values may not appear to add correctly due to rounding.
CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
N2O = nitrous oxide
As shown in Table 4.4.C, the implementation of the proposed project would result in a net reduction of approximately 3,927.7 metric tons of CO2e per year when compared to the emissions associated with the Approved Specific Plan. As discussed above, the majority of the area within the Specific Plan is already developed and not expected to change. However, the proposed project includes proposed land use changes which would promote more mixed-use development along commercial corridors by creating corridor/center mixed use and neighborhood mixed use areas, specifically on Blackstone Avenue and Shields Avenue. As such, implementation of the proposed project would allow for future development projects in the Specific Plan Area that would result in potential increase in planned residential uses and a decrease in commercial land uses when compared to the Approved Specific Plan. Additionally, policies included in the Specific Plan would reduce vehicle miles traveled by increasing amenities in the Specific Plan Area, as well as by promoting mixed use development and increasing opportunities for multi-modal transit.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-22
Impacts associated with future operation of individual projects that may occur with implementation of the proposed project would be required to prepare project specific technical assessments evaluating operational-related GHG impacts to further reduce emissions to the maximum extent feasible for projects that require environmental evaluation under CEQA. Each discretionary development project is required to be analyzed for conformance with the General Plan, zoning requirements, and other applicable local and State requirements; comply with the requirements of CEQA; and obtain all necessary clearances and permits.
While buildout of the proposed project would not result in an increase in emissions when compared to the buildout of the Approved Specific Plan, individual project emissions that could occur from implementation of the proposed project will contribute to global climate change. As discussed, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds or consistency with a regional GHG reduction plan (such as a Climate Action Plan). Neither the City nor the SJVAPCD has developed or adopted numeric GHG significance thresholds. In the absence of any City or SJVAPCD specific guidelines or thresholds, the proposed project and any future development that could occur from implementation of the proposed project would need to be analyzed for consistency with State goals for the purpose of reducing GHG emissions.
The Bay Area Air District’s Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (Justification Report) 17 established guidance on
how individual projects would be consistent with California’s long-term climate goals and provides substantial evidence in supporting the use of Bay Area Air District thresholds for projects throughout California, because the thresholds are designed to meet the State’s established GHG reduction goals, including the 2022 Scoping Plan goals. According to the Bay Area Air District Justification Report,18 a project would have a less than significant impact related to consistency with the 2022 Scoping Plan if the proposed project achieves a reduction in project-generated VMT below the regional average consistent with the current version of the 2022 Scoping Plan (currently 15 percent) or meets a locally adopted SB 743 VMT target, reflecting the recommendations provided in the OPR's Technical Advisory on Evaluating Transportation Impacts in CEQA.19 Additionally, new projects must not include natural gas appliances or natural gas plumbing and should not result in any wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines. It should be noted that natural gas is currently used in the Tower District, but the use of natural gas would not be expanded under the proposed project. Lastly, a project must achieve compliance with off-street EV requirements in the most recently adopted version of CALGreen Tier 2. If a project is designed and built to incorporate these design elements related to VMT, natural gas, energy, and EVs, then it would contribute its portion of what is necessary to achieve California’s long-term climate goals and
17 Bay Area Air Quality Management District (Bay Area Air District). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. April.
Website: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds- 2022/justification-report-pdf.pdf?la=en (accessed June 2025). 18 Ibid.
19 Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. April.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-23
an agency reviewing the project under CEQA can conclude that the project would be consistent with the State’s 2022 Scoping Plan.
Information regarding operational characteristics of future development projects envisioned under the Specific Plan Update and the associated emissions cannot be determined at the time of this analysis; therefore, implementation of the proposed project could result in potential significant impacts related to GHG. Mitigation Measure GHG-1 would require the preparation of a project-specific assessment of potential GHG impacts and implementation of feasible mitigation measures to reduce GHG emissions. As described above, neither the City of SJVAPCD have developed GHG thresholds. Future project developments can implement the design elements related to VMT, natural gas, energy, and EVs to demonstrate their “fair share” of emissions to meet California’s long-term climate goals and an agency reviewing the project under CEQA can conclude that the project would be consistent with the State’s 2022 Scoping Plan. As such, mitigation Measure GHG-1 would require individual projects to implement these design elements, as necessary, to further ensure that operational-related emissions are reduced to a less than significant level. Therefore, implementation of Mitigation GHG-1 would ensure impact associated with the continued implementation of the proposed project would be less than significant.
Since the 1991 Specific Plan, there has been a shift to mandate clean energy (such as solar, hydroelectric, wind, and nuclear sources), resulting in reductions in GHG emissions in addition to trip reduction and energy conservation measures. The State and the SJVAPCD would continue to adopt additional regulations on most sources of emissions to be implemented during the proposed project buildout period and result in much greater reductions than is predicted with the adopted regulations. In addition, expanded use of renewable fuels, zero emission vehicles, and replacing combustion sources with electrically powered alternatives will also result in reductions in GHG emissions. The proposed project would also be required to adhere to all federal, State, and local requirements for energy efficiency, including current Title 24 and CALGreen Code standards which establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage. The proposed project would also comply with the applicable policies from the General Plan aimed at reducing GHG emissions, including Policies RC-5-c, RC-5-d, and RC-5-e.
Since implementation of the proposed project would result in a net reduction of GHG emissions when compared to the Approved Specific Plan, the proposed project would not result in a significant impact. In addition, with implementation of Mitigation Measure GHG-1, impacts associated with the implementation of the proposed project would be less than significant. Therefore, with implementation of Mitigation Measure GHG-1, the proposed project would not generate GHG emissions, either directly or indirectly, that may have a significant effect on the environment and impacts would be less than significant.
Level of Significance Without Mitigation: Potentially Significant Impact.
Impact GHG-1: The proposed project would result in a potentially significant impact related to GHG emissions.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-24
Mitigation Measure GHG-1 Prior to discretionary approval by the City of Fresno (City) for development projects subject to California Environmental Quality Act (CEQA) review (i.e., nonexempt projects), Project applicants shall prepare and submit a technical assessment evaluating potential project-related greenhouse gas (GHG) impacts to the City for review and approval. The evaluation shall be prepared in conformance with San Joaquin Valley Air Pollution Control District (SJVAPCD) methodology. While neither the City nor the SJVAPCD currently have established threshold of significance for evaluating the GHG emissions impact of a proposed project, if either the City or the SJVAPCD develop GHG thresholds in the future (i.e. CEQA qualified Greenhouse Gas Reduction Plan/Climate Action Plan or SJVAPCD project-specific GHG thresholds), the evaluation of project- related GHG emissions shall demonstrate consistency with those thresholds of significance. In the absence of project-specific GHG thresholds established by the City or SJVAPCD, projects shall demonstrate compliance with the 2022 Scoping Plan GHG
requirements, consistent with State GHG emissions reduction and equity prioritization goals, by implementing the following design elements, where feasible:
• Projects shall not include natural gas appliances or natural gas plumbing.
• Projects shall achieve a reduction in project- generated VMT below the regional average consistent with the current version of the 2022 Scoping Plan (currently 15 percent) or meets the City’s locally adopted target reduction (13 percent reduction). • Projects shall not result in any wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.
• Projects must achieve compliance with EV requirements in the most recently adopted version of CALGreen Tier 2.
Should a proposed project exceed established thresholds of significance, the City shall require that the proposed project implement GHG emission reduction measures to reduce emissions below applicable thresholds or to a level commensurate with implementing the recommended project-design features outlined above. Such mitigation measures could include, but are not limited to, energy efficiency measures, water conservation and efficiency measures, solid waste measures, and transportation and motor LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-25
vehicles measures. The identified measures shall be included as part of the conditions of approval.
Level of Significance with Mitigation: Less than Significant Impact Implementation of Mitigation Measures GHG-1 would serve to ensure that the potential impacts of the proposed project are assessed to determine if they would have a significant impact on GHG.
Therefore, compliance with Mitigation Measures GHG-1 would ensure the potential GHG impacts associated with the continued implementation of the proposed project would be less than significant.
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.
This s
ection includes analysis of the proposed project’s consistency with State and local plans, policies, and regulations that have been adopted for the purpose of reducing GHGs. As discussed above, the SJVAPCD has adopted a CCAP, which includes suggested best performance standards for proposed development projects. However, the SJVAPCD’s CCAP was adopted in 2009 and was prepared based on the State’s 2020 GHG targets, which are now superseded by State policies (i.e., the 2022 California Green Building Code) and the 2030 GHG targets, established in SB 32, as well as State goals for carbon neutrality, as included in Executive Orders and codified in AB 1279. Therefore, in this section, the proposed project is analyzed for consistency with the goals of EO B-30-15, SB 32, AB 197, and the 2022 Scoping Plan and the FCOG RTP.
2022 Scoping Plan. The following discussion evaluates the proposed project according to the goals of the 2022 Scoping Plan, EO B-30-15, SB 32, and AB 197.
EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, 20 to reflect the
2030 target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels.
The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.
In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.
20 California Air Resources Board (CARB). 2017a. California’s 2017 Climate Change Scoping Plan. November.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-26
The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California will be zero-emission by 2035, and all other fleets will have transitioned to zero-emission as fully possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.
Appendix D of the 2022 Scoping Plan includes local action recommendations that align with the state’s climate strategies.
21 Land use development projects that are consistent with these, either through on-site project design features or mitigation strategies, would support state-level measures to contain the growth of GHG emissions associated with the transportation system and built environment. The 2022 Scoping Plan categorizes the priority areas into Transportation Electrification, VMT Reduction, and Building Decarbonization and provides project attributes associated with each that are intended as a guide to help local jurisdictions qualitatively identify projects that are consistent with the state’s climate goals. The following sections provide an analysis of the proposed project’s consistency with the overarching, long-term GHG reduction goals from the Scoping Plan related to Transportation Electrification, VMT Reduction, and Building Decarbonization.
Energy Efficiency and Building Decarbonization. Energy efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. The proposed project would comply with the CALGreen Code, regarding energy conservation and green building standards, which will ensure highly energy efficient development. Additionally, the Pacific Gas & Electric Company (PG&E) is the private utility that would supply the proposed project’s electricity. In 2021, a total of 50 percent of PG&E’s delivered electricity came from renewable sources, including solar, wind, geothermal, small hydroelectric, and various forms of bioenergy. 22 PG&E reached California’s
2020 renewable energy goal in 2017 and is positioned to meet the State’s 60 percent by 2030 renewable energy mandate set forth in SB 100. In addition, PG&E plans to continue to provide reliable service to its customers and upgrade its distribution systems as necessary to meet future demand, consistent with the State’s renewable portfolio.
21 California Air Resources Board (CARB). 2022. Appendix D Local Actions – Draft 2022 Scoping Plan. May.
Website: https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp-appendix-d-local- actions_0.pdf (accessed July 2025)
22 Pacific Gas & Electric Company (PG&E). 2021. Exploring Clean Energy Solutions. Website:
https://www.pge.com/en_US/about-pge/environment/what-we-are-doing/clean-energy-solutions/clean- energy-solutions.page?WT.mc_id=Vanity_cleanenergy (accessed June 2024).
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-27
The elimination of natural gas in new development would help projects implement their “fair share” of GHG emission reductions necessary to achieve carbon neutrality by 2045. As such, if a project does utilize natural gas, a lead agency can conclude that it would not be consistent with achieving the 2045 neutrality goal and will have a cumulative considerable impact on climate change.23 It is not yet known whether the proposed project would include natural gas. To be conservative, this analysis assumes that natural gas may be required. However, the proposed project would support development standards that increase electrification and building decarbonization for future land uses. The elimination of natural gas from the building sector is a key action identified by CARB to reduce statewide emissions. CARB provides a target year of 2035 to initiate decarbonizing of industrial processes with the understanding that the industrial sector is a more challenging GHG sector to electrify; however, decarbonizing new commercial and residential development is considered a feasible requirement for projects proposed now. With Mitigation Measure GHG-1, the proposed project would require future development to eliminate the use of natural appliances or natural gas plumbing. As technology continues to advance towards cleaner energy, future development projects would be able to reduce the use of natural gas and align with building decarbonization goals. Furthermore, the proposed project will be constructed with the latest Title 24 building design and will meet all required energy efficiency measures. Therefore, the proposed project would comply with applicable energy measures.
Additionally, and as noted above, the proposed project would comply with the CALGreen Code, which also includes a variety of different measures for water conservation and efficiency, including the reduction of wastewater and water use. Therefore, the proposed project would also promote the reduction of GHG emissions through water efficiency measures.
Transportation Electrification and VMT. The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction targets for passenger vehicles. The proposed project would promote more mixed-use development along commercial corridors by creating corridor/center mixed use and neighborhood mixed use areas. This would continue to promote the walkability of the Tower District while allowing for greater residential development. Additionally, medium low density residential uses would be allowed at Terrace Gardens, Porter Tract, and Wilson Island. As such, implementation of the proposed project would promote alternative forms of transportation (e.g., walking and cycling) and would reduce vehicle miles traveled. Overall, the nearby transit facilities and proposed improvements to the pedestrian network would support public transit use and walking and bicycling. Furthermore, with Mitigation Measure GHG-1, development of the land uses under the proposed project would meet the mandatory EV charging requirements of the CALGreen Code (Part 11, Title 24, California Code of Regulations), which would promote the widespread use of EVs as well as provide the electrical infrastructure necessary during the development phase of a project that allows for future expansion of electrical EV facilities. As such, the proposed project would be aligned with the State’s long-term EV adoption targets.
Additionally, as described in Section 4.17, Transportation, of the Initial Study (included in Appendix C of this EIR) buildout of the proposed project would result in a less than significant VMT impact. The VMT per capita for the proposed project was estimated to be 11.4, which is below the City’s VMT per capita threshold of 14.0. As such, the proposed project would not generate VMT to the degree
23 Bay Area Air Quality Management District (Bay Area Air District). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans. April.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-28
that the plan would conflict with the City’s locally adopted VMT target and will be consistent with the Governor’s Office of Land Use and Climate Innovation’s (LCI) established targets included in SB 743 (Steinberg, 2013). For this reason, the proposed project would align with the VMT State reduction goals. Therefore, the proposed project would not conflict with the transportation and motor vehicle measures.
Summary. As demonstrated above, with Mitigation Measure GHG-1, the proposed project would not conflict with the plans and policies adopted for the purpose of reducing the emissions of greenhouse gases, including the CARB 2022 Scoping Plan, EO B-30-15, SB 32, and AB 1279.
Fresno Council of Governments’ 2022 Regional Transportation Plan. The Fresno Council of Governments (FCOG) Regional Transportation Plan (RTP) reflects transportation planning for Fresno County through 2046. The vision, goals, and policies in the 2022 RTP are intended to serve as the foundation for both short and long-term planning and guide implementation activities. The core vision in the 2022 RTP is to create a region of diverse, safe, resilient, and accessible transportation options that improve the quality of life for all residents by fostering sustainability, equity, a vibrant economy, clean air, and healthy communities. The 2022 RTP contains transportation projects to help more efficiently distribute population, housing, and employment growth, and forecast development that is generally consistent with regional-level general plan data. The actions in the 2022 RTP address all transportation modes (highways, local streets and roads, mass transportation, rail, bicycle, aviation facilities and services) and consist of short- and long-term activities that address regional transportation needs. While the actions are organized by the five key policy areas, many of them are cross-cutting and support multiple goals and policies. Some actions are intended to support the Sustainable Communities Strategy (SCS) and reduce greenhouse gas emissions directly, while others are focused on the RTP’s broader goals. The 2022 RTP does not require that local General Plans, Specific Plans, or zoning be consistent with the 2022 RTP, but provides incentives for consistency for governments and developers.
The proposed project would not interfere with the FCOG’s ability to achieve the region’s GHG reductions. The proposed project includes proposed land use changes which would promote more mixed-use development along commercial corridors by creating corridor/center mixed use and neighborhood mixed use areas. Although implementation of the proposed project could result in an increase in planned residential units, all land use changes would be consistent with the Fresno 6 th
Cycle Housing Element and would accommodate much needed housing within the City. The proposed project would result in 537 new dwelling units and a reduction in 18,000 square feet of retail/commercial spaces. Therefore, it is anticipated that implementation of the proposed project would not exceed growth assumptions in the 2022 RTP/SCS. Therefore, the proposed project would not interfere with FCOG’s ability to implement the regional strategies outlined in the 2022 RTP.
Conclusion. The proposed project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in the 2022 RTP and would be consistent with applicable State plans and programs designed to reduce GHG emissions. Therefore, the proposed project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs, and impacts would be less than significant.
Level of Significance Without Mitigation: Potentially Significant Impact LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25)
4.4-29
Impact GHG-2: The proposed project would result in a potentially significant impact related to building decarbonization and transportation electrification.
Mitigation Measures: Refer to Mitigation Measure GHG-1.
Level of Significance with Mitigation: Less than Significant Impact Implementation of Mitigation Measure GHG-1 would serve to ensure that the impacts of the continued implementation of the proposed project would meet the building decarbonization, transportation electrification, and VMT goals. Therefore, compliance with Mitigation Measure GHG- 1 would ensure the potential GHG impacts associated with the continued implementation of the proposed project would be less than significant.
4.4.5.2 Cumulative Impacts
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 GHG emissions. However, unlike the cumulative analysis for many topics that address the combined impacts of a proposed project in addition to related projects in a project study area, the analysis of impacts related to GHG emissions is inherently cumulative.
GHG‐3
Implementation of the proposed project in combination with past, present, and reasonably foreseeable projects, would result in significant cumulative impacts with respect to GHG emissions.
AB 32 req
uired CARB to reduce statewide GHG emissions to 1990 level by 2020. As part of this legislation, CARB was required to prepare a “Scoping Plan” that demonstrates how the State will achieve this goal. The Scoping Plan was first adopted in 2011 and in it, local governments were described as “essential partners” in meeting the statewide goal, recommending a GHG reduction level of 15 percent below 2005 to 2008 levels by 2020. In addition, CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the 2030 GHG emissions reductions target of at least 40 percent below 1990 levels by 2030. CARB recently adopted the 2022 Scoping Plan,24 which assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan Update focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.
In order to achieve these goals, CARB is in the process of establishing and implementing regulations to reduce statewide GHG emissions. However, there are currently no applicable significance thresholds, specific reduction targets, and/or approved policy or guidance to assist in determining
24 California Air Resources Board (CARB). 2022a. 2022 Scoping Plan Update. May 10. Website:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan- documents (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25)
4.4-30
significance at the cumulative level. Additionally, there is currently no generally accepted methodology to determine whether GHG emissions associated with a specific project represent new emissions or existing, displaced emissions.
GHG impacts are by their nature cumulative impacts. Localized impacts of climate change are the result of the cumulative impact of global emissions. The combined benefits of reductions achieved by all levels of government help to slow or reverse the growth in greenhouse gas emissions. In the absence of comprehensive international agreements on appropriate levels of reductions achieved by each country, another measure of cumulative contribution is required. This serves to define the State’s share of the reductions regardless of the activities or lack of activities of other areas of the United States or the world. Therefore, a cumulative threshold based on consistency with State targets and actions to reduce GHGs is an appropriate standard of comparison for significance determinations.
As previously stated, GHG emissions associated with the buildout under the proposed project would result in a net reduction of GHG emissions when compared to the existing land uses. Since GHG is a global issue, it is unlikely that the proposed project would generate enough GHG emissions to influence GHG emissions on its own. Implementation of Mitigation Measure GHG-1 would serve to ensure that the impacts of the continued implementation of the proposed project are assessed to determine if they would have a significant impact on GHG. Mitigation Measure GHG-1 would ensure that future development projects that would occur from implementation of the proposed project would comply with State goals related to the reduction of GHG emissions. Therefore, compliance with Mitigation Measures GHG-1 would ensure the potential GHG impacts associated with the continued implementation of the proposed project would be less than significant. Therefore, the proposed project would not have a significant contribution to cumulatively considerable GHG emission impacts. In addition, as demonstrated above, with Mitigation Measure GHG-1 the proposed project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals, including the CARB 2022 Scoping Plan, Executive Order B-30-15, SB 32, and AB 1279. As such, cumulative impacts would be considered less than significant.
Level of Significance Without Mitigation: Potentially Significant Impact Impact GHG-2: The proposed project would result in a potentially significant impact related to GHG emissions and State goals related to building decarbonization and transportation electrification.
Mitigation Measures: Refer to Mitigation Measure GHG-1.
Level of Significance with Mitigation: Less than Significant Impact Implementation of Mitigation Measure GHG-1 would serve to ensure that the impacts of the continued implementation of the proposed project are assessed to determine if they would have a significant impact on GHG and ensure that future development projects would comply with State goals related to the reduction of GHG emissions. Therefore, compliance with Mitigation Measure GHG-1 would ensure the potential GHG impacts associated with the continued implementation of the proposed project would be less than significant.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-1
4.5 NOISE
4.5.1 Introduction
This section discusses noise impacts resulting from implementation of the Tower District Specific Plan Update (proposed project or Specific Plan Update) for the City of Fresno (City) and evaluates the potential for changes in noise that could result from the proposed project. This section discusses the fundamentals of sound and vibration; describes the existing noise and vibration settings/ conditions; examines federal, State, and local noise guidelines, policies, and standards; reviews noise levels at existing receptor locations; evaluates potential noise impacts associated with the Specific Plan Update; and provides mitigation to reduce noise impacts.
4.5.2 Existing Environmental Setting
The study area for project impacts regarding noise is the Tower District Specific Plan Area (Specific Plan Area) and the immediate surrounding areas because potential development under the proposed project could affect areas inside the Specific Plan Area. For the proposed project, the Specific Plan Area encompasses the Tower District, which is centrally located within Fresno and is generally bound by Shields Avenue to the north, Blackstone Avenue to the east, State Route (SR) 180 to the south, and Fruit Avenue and the Union Pacific Railroad (UPRR) tracks to the west.
4.5.2.1 Characteristics of Sound
Sound is increasing in the environment and can affect quality of life. Noise is usually defined as unwanted sound. Noise consists of any sound that may produce physiological or psychological damage and/or interfere with communication, work, rest, recreation, and sleep.
To the human ear, sound has two significant characteristics: pitch and loudness. Pitch is generally an annoyance, while loudness can affect the ability to hear. Pitch is the number of complete vibrations (or cycles per second) of a wave, resulting in the tone’s range from high to low. Loudness is the strength of a sound, describes a noisy or quiet environment, and is measured by the amplitude of the sound wave. Loudness is determined by the intensity of the sound waves combined with the reception characteristics of the human ear. Sound intensity is the average rate of sound energy transmitted through a unit area perpendicular to the direction in which the sound waves are traveling. This characteristic of sound can be precisely measured with instruments. In the analysis of a project, the noise environment of the Specific Plan Area is defined in terms of sound intensity and its effect on adjacent sensitive land uses.
4.5.2.2 Measurement of Sound
Sound intensity is measured through the A-weighted scale to correct for the relative frequency response of the human ear. That is, an A-weighted noise level de-emphasizes low and very high frequencies of sound similar to the human ear’s de-emphasis of these frequencies. Decibels (dB), unlike the linear scale (e.g., inches or pounds), is a scale based on powers of 10.
For example, 10 dB is 10 times more intense than 0 dB, 20 dB is 100 times more intense than 0 dB, and 30 dB is 1,000 times more intense than 0 dB. Thirty decibels (30 dB) represents 1,000 times as much acoustic energy as 0 dB. The decibel scale increases as the square of the change, representing the sound pressure energy. A sound as soft as human breathing is about 10 times greater than 0 dB.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-2
The decibel system of measuring sound gives a rough connection between the physical intensity of sound and its perceived loudness to the human ear. A 10 dB increase in sound level is perceived by the human ear as only a doubling of the loudness of the sound. Ambient sounds generally range from 30 A-weighted decibels (dBA) (very quiet) to 100 dBA (very loud).
Sound levels generate from a source, and their decibel level decreases as the distance from that source increases. Sound dissipates exponentially with distance from the noise source. For a single point source, sound levels decrease approximately 6 dB for each doubling of distance from the source. This drop-off rate is appropriate for noise generated by stationary equipment. If noise is produced by a line source, such as highway traffic or railroad operations, the sound decreases 3 dB for each doubling of distance in a hard site environment. Line source noise in a relatively flat environment with absorptive vegetation decreases 4.5 dB for each doubling of distance. See Table 4.5.A, below, for definitions of acoustical terms.
Table 4.5.A: Definitions of Acoustical Terms
Term Definitions
Decibel, dB A unit of level that denotes the ratio between two quantities proportional to power; the number of decibels is 10 times the logarithm (to the base 10) of this ratio.
Frequency, Hz Of a function periodic in time, the number of times that the quantity repeats itself in one second (i.e., number of cycles per second).
A-Weighted Sound Level, dBA The sound level obtained by use of A-weighting. The A-weighting filter de- emphasizes the very low and very high frequency components of the sound in a manner similar to the frequency response of the human ear and correlates well with subjective reactions to noise. All sound levels in this report are A-weighted, unless reported otherwise.
L01, L10, L50, L90 The fast A-weighted noise levels equaled or exceeded by a fluctuating sound level for 1 percent, 10 percent, 50 percent, and 90 percent of a stated time period.
Equivalent Continuous Noise Level, Leq The level of a steady sound that, in a stated time period and at a stated location, has the same A-weighted sound energy as the time varying sound.
Community Noise Equivalent Level, CNEL The 24-hour A-weighted average sound level from midnight to midnight, obtained after the addition of five decibels to sound levels occurring in the evening from 7:00 p.m. to 10:00 p.m. and after the addition of 10 decibels to sound levels occurring in the night between 10:00 p.m. and 7:00 a.m.
Day/Night Noise Level, Ldn The 24-hour A-weighted average sound level from midnight to midnight, obtained after the addition of 10 decibels to sound levels occurring in the night between 10:00 p.m. and 7:00 a.m.
Lmax, Lmin The maximum and minimum A-weighted sound levels measured on a sound level meter, during a designated time interval, using fast time averaging.
Ambient Noise Level The all-encompassing noise associated with a given environment at a specified time, usually a composite of sound from many sources at many directions, near and far; no particular sound is dominant.
Intrusive The noise that intrudes over and above the existing ambient noise at a given location. The relative intrusiveness of a sound depends upon its amplitude, duration, frequency, and time of occurrence and tonal or informational content as well as the prevailing ambient noise level.
Source: Handbook of Acoustical Measurements and Noise Control (Cyril Harris, ed., 1998).
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-3
There are many ways to rate noise for various time periods, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. The equivalent continuous sound level (L
eq) is the total sound energy of time-weighted average noise over a sample period.
However, the predominant rating scales for human communities in California are Leq and the Community Noise Equivalent Level (CNEL) or the day-night average noise level (Ldn) based on dBA.
CNEL is the time-varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours) and a 10 dBA weighting factor applied to noises occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale but without the adjustment for events occurring during the relaxation hours. CNEL and Ldn are within 1 dBA of each other and are normally interchangeable. The noise adjustments are added to the noise events occurring during the more sensitive hours. Typical A-weighted sound levels from various sources are described in Figure 4.5-1.
Figure 4.5-1: Typical A-Weighted Sound Levels
Source: Compiled by LSA (2016).
Other noise rating scales of importance, when assessing the annoyance factor, include the maximum instantaneous noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a stated time period. The noise environments discussed in this analysis are specified in terms of Lmax for short-term noise impacts. Lmax reflects peak operating conditions and LSA
Noise Level
Common Outdoor Sound Levels dBIAl Common Indoor Sound Levels Rock Band
Commercial Jet Flyover at 1000 Feet
Gas Lawn Mower at 3 Feet Inside Subway Train (New York) Diesel Truck at 50 Feet
Food Blender at 3 Feet
Concrete Mixer at 50 Feet
Garbage Disposal at 3 Feet
Air Compressor at 50 Feet Shouting at 3 Feet
Vacuum Cleaner at 10 Feet
Lawn Tiller at 50 Feet Normal Speech at 3 Feet
50 Large Business Office
Quiet Urban Daytime
Dishwasher Next Room
Quiet Urban Nighttime 40 Small Theater, Large Conference Room Quiet Suburban Nighttime (Background)
30 Library
Quiet Rural Nighttime 20 Bedroom at Night
Concert Hall (Background)
10 Broadcast and Recording Studio
0 Threshold of Hearing
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-4
addresses the annoying aspects of intermittent noise. Another noise scale often used together with Lmax in noise ordinances for enforcement purposes is noise standards in terms of percentile noise levels. For example, the L10 noise level represents the noise level exceeded 10 percent of the time during a stated period. The L50 noise level represents the median noise level; half the time the noise level exceeds this level and half the time it is less. The L90 noise level represents the noise level exceeded 90 percent of the time and is considered the background noise level during a monitoring period. For a relatively constant noise source, Leq and L50 are approximately the same.
Noise impacts can be described in three categories. The first is audible impacts, which refer to increases in noise levels noticeable to humans. Audible increases in noise levels generally refer to a change of 3 dB or greater since this level has been found to be barely perceptible in exterior environments. The second category, potentially audible, refers to a change in the noise level between 1 dB and 3 dB. This range of noise levels has been found to be noticeable only in laboratory environments. The last category is changes in noise levels of less than 1 dB, which are inaudible to the human ear. Only audible changes in existing ambient or background noise levels are considered potentially significant.
4.5.2.3 Physiological Effects of Noise
Physical damage to human hearing begins at prolonged exposure to noise levels higher than 85 dBA.
Exposure to high noise levels affects the entire system, with prolonged noise exposure in excess of 75 dBA increasing body tensions and thereby affecting blood pressure and functions of the heart and the nervous system. In comparison, extended periods of noise exposure above 90 dBA would result in permanent cell damage. When the noise level reaches 120 dBA, a tickling sensation occurs in the human ear, even with short-term exposure. This level of noise is called the threshold of feeling. As the sound reaches 140 dBA, the tickling sensation is replaced by the feeling of pain in the ear. This is called the threshold of pain. Sound levels from 160 to 165 dBA will potentially result in dizziness or loss of equilibrium. The ambient or background noise problem is widespread and generally more concentrated in urban areas than in outlying, less developed areas.
4.5.2.4 Vibration
Vibration refers to ground-borne noise and perceptible motion. Ground-borne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors. The motion may be discernible outdoors, but without the effects associated with the shaking of a building, there is less adverse reaction. Vibration energy propagates from a source through intervening soil and rock layers to the foundations of nearby buildings. The vibration then propagates from the foundation throughout the remainder of the structure. Building vibration may be perceived by occupants as the motion of building surfaces, the rattling of items on shelves or wall hangings, or a low-frequency rumbling noise. The rumbling noise is caused by the vibration of walls, floors, and ceilings radiating sound waves. Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by 10 dB or less, which is an order of magnitude below the damage threshold for normal buildings.
To distinguish vibration levels from noise levels, the unit is written as “vibration velocity decibels” (VdB). Human perception to vibration starts at levels as low as 67 VdB and sometimes lower.
Annoyance due to vibration in residential settings starts at approximately 70 VdB. Ground-borne LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-5
vibrations are almost never annoying to people who are outdoors. Although the motion of the ground may be perceived, without the effects associated with the shaking of the building, the motion does not provoke the same adverse human reaction.
Typical sources of ground-borne vibration are construction activities (e.g., blasting, pile driving and operating heavy-duty earthmoving equipment), steel-wheeled trains, and occasional traffic on rough roads. Problems with ground-borne vibration and noise from these sources are usually localized to areas within approximately 100 feet of the vibration source, although there are examples of ground- borne vibration causing interference out to distances greater than 200 feet. 1 When roadways are
smooth, vibration from traffic, even heavy trucks, is rarely perceptible. Ground-borne noise is not likely to be a problem because noise arriving via the normal airborne path usually will be greater than ground-borne noise.
Ground-borne vibration has the potential to disturb people as well as damage buildings. Although it is very rare for train-induced ground-borne vibration to cause even cosmetic building damage, it is not uncommon for construction processes such as blasting and pile driving to cause vibration of sufficient amplitudes to damage nearby buildings.
2 Ground-borne vibration is usually measured in
terms of vibration velocity, either the root-mean-square (RMS) velocity or peak particle velocity (PPV).
Factors that influence ground-borne vibration and noise include the following:
• Vibration Source: Vehicle suspension, wheel types and condition, track/roadway surface, track support system, speed, transit structure, and depth of vibration source • Vibration Path: Soil type, rock layers, soil layering, depth to water table, and frost depth • Vibration Receiver: Foundation type, building construction, and acoustical absorption Among the factors listed above, there are significant differences in the vibration characteristics when the source is underground compared to at the ground surface. In addition, soil conditions are known to have a strong influence on the levels of ground-borne vibration. Among the most important factors are the stiffness and internal damping of the soil and the depth to bedrock.
Experience with ground-borne vibration indicates that: (1) vibration propagation is more efficient in stiff, clay soils than in loose, sandy soils; and (2) shallow rock seems to concentrate the vibration energy close to the surface and can result in ground-borne vibration problems at large distances from the source. Factors such as layering of the soil and depth to the water table can have significant effects on the propagation of ground-borne vibration. Soft, loose, sandy soils tend to attenuate more vibration energy than hard, rocky materials. Vibration propagation through groundwater is more efficient than through sandy soils.
1 Federal Railroad Administration (FRA). 2012. High-Speed Ground Transportation Noise and Vibration Impact Assessment.
2 Ibid.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-6
In extreme cases, excessive ground-borne vibration has the potential to cause structural damage to buildings. For buildings considered of particular historical significance or that are particularly fragile structures, the damage threshold is approximately 96 VdB; the damage threshold for other structures is 100 VdB.
3 4.5.2.5 Existing Noise Levels
Existing noise levels in the Specific Plan Area as well as the surrounding areas are primarily generated by transportation noise sources. Vehicular traffic noise is the dominant source in most areas, and aircraft and rail activity are sources of noise in the local areas surrounding these operations. In addition, industrial and commercial activity are sources of noise in the area of these land uses.
Land uses within the Tower District (District) include single-family residential uses, which comprise over half of the District’s land area, medium-density residential uses, high-density residential uses, public uses (e.g., schools, parks, and recreation sites), and light industrial uses, which are generally confined to the southwest edge of the District. Also, the District is generally surrounded by urban, built-up areas consisting of similar land uses to those found within the District, including a mix of residential, commercial, public institutions, and pockets of industrial uses. Additionally, Roeding Regional Park is located west of the District, immediately adjacent to the UPRR line and Golden State Boulevard.
Ambient Noise Measurements. Three n
oise meters were placed within public right-of-way to
conduct long-term (24-hour) noise level measurements from June 17 to June 18, 2025, using Larson Davis Spark 706RC dosimeters to document the existing noise environment within the Specific Plan Area. Table 4.5.B, below, summarizes the results of the long-term noise level measurements along with a description of the measurement locations and noise sources that occurred during the measurements. As shown in Table 4.5.B, the calculated CNEL levels at LT-1 through LT-3 range from
58.2 to 72.1 dBA CNEL. The daytime noise levels ranged from 49.4 to 72.3 A-weighted equivalent continuous sound level (dBA Leq), and the nighttime noise levels ranged from 43.3 to 70.1 dBA Leq.
Also, the daytime maximum instantaneous noise levels ranged from 67.1 to 98.2 maximum A- weighted instantaneous noise level (dBA Lmax), and the nighttime maximum instantaneous noise levels ranged from 56.7 to 94.6 dBA Lmax. The long-term noise level measurement survey sheets, along with the hourly Leq and Lmax results, are provided in the Noise and Vibration Impact Analysis (2025)4 (Appendix H) prepared for the proposed project.
3 Harris, C.M., ed. 1998. Handbook of Acoustical Measurements and Noise Control. 4 LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-7
Table 4.5.B: Long-Term Ambient Noise Monitoring Results Monitoring
No. Location
Noise Level
Noise Source dBA Leq dBA Lmax CNEL Daytime Nighttime Daytime Nighttime LT-1 621 North San Pablo Avenue.
On a pole. On the west side of
North San Pablo Avenue.
Approximately 20 ft from
North San Pablo Avenue
centerline.
63.5–66.9
(62.5)1
56.0–64.2
(61.8)2
78.6–93.1 77.1–89.1 69.2 Traffic on SR-180 and
North San Pablo
Avenue.
LT-2 1599 North Calaveras Street.
On a pole in the alleyway.
Approximately 85 ft from the
East McKinley Avenue
centerline.
62.2–72.3
(65.6)1
58.7–70.1
(64.8)2
77.2–98.2 81.6–94.6 72.1 Traffic on East
McKinley Avenue and
North Blackstone
Avenue. Occasional
train pass-by and
crossing noise.
Occasional aircraft
noise.
LT-3 244 West Princeton Avenue.
On a tree. Approximately 20 ft
away from North Arthur
Avenue centerline. At the
northeast corner of North
Arthur Avenue and West
Princeton Avenue.
49.4–55.5
(51.2)1
43.3–56.7
(51.4)2
67.1–84.0 56.7–77.4 58.2 Very light traffic on
West Princeton
Avenue and North
Arthur Avenue.
Occasional aircraft
noise.
Source: Compiled by LSA (2025).
Note: The long-term (24-hour) noise level measurements were conducted from June 17 to June 18, 2025. 1 Average daytime noise level.
2 Average nighttime noise level.
CNEL = Community Noise Equivalent Levell
dBA = A-weighted decibels
ft = foot/feet
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
SR-180 = State Route 180
Existing Aircraft Noise. The closest airports to the Specific Plan Area are the Fresno Chandler Executive Airport (1 mile southeast of the project site), Fresno Yosemite International Airport (3.3 miles east of the project site), and Sierra Sky Park Airport (4.8 miles northwest of the project site).
The Specific Plan Area is outside the 60 dBA CNEL noise contour of airports based on the Fresno County Airport Land Use Compatibility Plan.5 There are also no private airstrips within 2 miles of the project site. In addition, the aviation-related noise exposure to people residing or working in the Specific Plan Area under the proposed project would remain the same as the 1991 Specific Plan and existing conditions.
Therefore, the proposed project would not expose people residing or working in the Specific Plan Area to aviation-related excessive noise levels.
5 Fresno County Airport Land Use Commission (Fresno County ALUC). 2023. Fresno County Airport Land Use Compatibility Plan. October. Website: https://www.fresnocog.org/wp-content/uploads/2025/06/2023- ALUCP.pdf (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-8
4.5.3 Regulatory Setting
The Specific Plan Area encompasses the City of Fresno and its sphere of influence (SOI). Noise regulations are addressed through the efforts of various federal, State, and local government agencies. The agencies responsible for regulating noise are discussed below.
4.5.3.1 Federal Policies and Regulations
United States Environmental Protection Agency. In 1972, Congress enacted the United States Noise Control Act. This act authorized the United States Environmental Protection Agency (USEPA) to publish descriptive data on the effects of noise and establish levels of sound “requisite to protect the public welfare with an adequate margin of safety.” These levels are separated into health (hearing loss levels) and welfare (annoyance levels), as shown in Table 4.5.C. The USEPA cautions that these identified levels are not standards because they do not take into account the cost or feasibility of the levels.
Table 4.5.C: Summary of USEPA Noise Levels
Effect Level Area
Hearing loss Leq(24) < 70 dB All areas.
Outdoor activity
interference and annoyance
Ldn < 55 dB
Outdoors in residential areas and farms and other outdoor areas where people spend widely varying amounts of time and other places in which quiet is a basis for use.
Leq(24) < 55 dB Outdoor areas where people spend limited amounts of time, such as school yards, playgrounds, etc.
Indoor activity interference
and annoyance
Leq < 45 dB Indoor residential areas.
Leq(24) < 45 dB Other indoor areas with human activities such as schools, etc.
Source: Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety (USEPA, March 1974).
dB = decibels
Leq = equivalent continuous sound level
USEPA = United States Environmental Protection Agency
For protection against hearing loss, 96 percent of the population would be protected if sound levels were less than or equal to an Leq(24) of 70 dBA. The “(24)” signifies an Leq duration of 24 hours. The USEPA activity and interference guidelines are designed to ensure reliable speech communication at about 5 feet in the outdoor environment. For outdoor and indoor environments, interference with activity and annoyance should not occur if levels are below 55 dBA and 45 dBA, respectively.
Table 4.5.D summarizes the noise effects associated with an outdoor L dn of 55 dBA. At 55 dBA Ldn,
95 percent sentence clarity (intelligibility) may be expected at 11 feet, with no community reaction.
However, 1 percent of the population may complain about noise at this level, and 17 percent may indicate annoyance.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-9
Table 4.5.D: Summary of Human Effects in Areas Exposed to 55 dBA CNEL Type of Effect Magnitude of Effect
Speech – Indoors 100 percent sentence intelligibility (average) with a 5 dB margin of safety.
Speech – Outdoors
100 percent sentence intelligibility (average) at 0.35 meter (1.14 feet). 99 percent sentence intelligibility (average) at 1.0 meter (3.28 feet). 95 percent sentence intelligibility (average) at 3.5 meters (11.5 feet).
Average Community Reaction None evident; 7 dB below level of significant complaints and threats of legal action and at least 16 dB below “vigorous action.”
Complaints 1 percent dependent on attitude and other non-level related factors.
Annoyance 17 percent dependent on attitude and other non-level related factors.
Attitude Towards Area Noise essentially the least important of various factors.
Source: Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety (USEPA, March 1974).
CNEL = Community Noise Equivalent Level
dB = decibels
dBA = A-weighted decibels
USEPA = United States Environmental Protection Agency
Federal Transit Administration. The construction noise criteria included in the Federal Transit Administration’s (FTA) Transit Noise and Vibration Impact Assessment Manual6 (FTA Manual) were used to evaluate potential construction noise impacts because the City does not have construction noise level limits. Table 4.5.E shows the FTA’s Detailed Assessment Daytime Construction Noise Criteria based on the composite noise levels for each construction phase.
Table 4.5.E: Detailed Assessment Daytime Construction Noise Criteria Land Use Daytime 8-hour Leq (dBA)
Residential 80
Commercial 85
Industrial 90
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). dBA = A-weighted decibels
FTA = Federal Transit Administration
Leq = equivalent continuous sound level
Vibration standards included in the FTA Manual are used in this analysis for ground-borne vibration impacts on human annoyance, as shown in Table 4.5.F. The criteria presented in Table 4.5.F account for the variations in project types, which differ widely among projects.
6 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual .
September 2018. FTA Report No. 012.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-10
Table 4.5.F: Interpretation of Vibration Criteria for Detailed Analysis Land Use Max Lv
(VdB)1 Description of Use
Workshop 90 Vibration that is distinctly felt. Appropriate for workshops and similar areas not as sensitive to vibration.
Office 84 Vibration that can be felt. Appropriate for offices and similar areas not as sensitive to vibration.
Residential Day 78 Vibration that is barely felt. Adequate for computer equipment and low-power optical microscopes (up to 20×).
Residential Night and
Operating Rooms
72 Vibration is not felt, but ground-borne noise may be audible inside quiet rooms. Suitable for medium-power microscopes (100×) and other equipment of low sensitivity.
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 As measured in 1/3-octave bands of frequency over the frequency range 8 to 80 hertz.
FTA = Federal Transit Administration
LV = velocity in decibels
Max = maximum
VdB = vibration velocity decibels
The criteria for environmental impact from ground-borne vibration and noise are based on the maximum levels for a single event. Table 4.5.G lists the potential vibration building damage criteria associated with construction activities, as suggested in the FTA Manual.
Table 4.5.G: Construction Vibration Damage Criteria
Building Category PPV (in/sec) Approximate LV
(VdB)1
Reinforced concrete, steel, or timber (no plaster) 0.50 102 Engineered concrete and masonry (no plaster) 0.30 98
Non-engineered timber and masonry buildings 0.20 94
Buildings extremely susceptible to vibration damage 0.12 90 Source: Transit Noise and Vibration Impact Assessment (FTA 2018). 1 RMS vibration velocity in decibels (VdB) re 1 µin/sec. µin/sec = microinches per second
FTA = Federal Transit Administration
in/sec = inch/inches per second
LV = velocity in decibels
PPV = peak particle velocity
RMS = root-mean-square
VdB = vibration velocity decibels
FTA Manual guidelines show that a vibration level of up to 0.5 inches per second (in/sec) in PPV is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster), and would not result in any construction vibration damage. For a non-engineered (those not designed by an engineer or architect) timber and masonry building, the construction building vibration damage criterion is 0.2 in/sec in PPV.
4.5.3.2 State Regulations and Policies
The State of California has established regulations that help prevent adverse impacts to occupants of buildings near noise sources. Referred to as the State Noise Insulation Standard, it requires noise- sensitive land uses to meet performance standards through design and/or building materials that would offset any noise source in the vicinity of the building. Chapter 5, Section 5.507 of the California Green Building Standards Code includes nonresidential mandatory measures, which LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-11
require that buildings exposed to a noise level of 65 dB Leq-1-hour during any hour of operation shall have building, addition, or alteration exterior wall and roof-ceiling assemblies exposed to the noise source meeting a composite Sound Transmission Class (STC) rating of at least 45 (or Outdoor/Indoor Transmission Class [OITC] 35) with exterior windows of a minimum STC of 40 (or OITC 30).
The State has also established land use compatibility guidelines for determining acceptable noise levels for specified land uses, as shown in Table 4.5.G.
California Department of Transportation. Vibration standards included in the 2020 California Department of Transportation (Caltrans) Transportation and Construction Vibration Guidance Manual
7 (Caltrans Manual) are used in this analysis for ground-borne vibration impacts on human annoyance and building damage. The criteria for environmental impact from ground-borne vibration are based on the maximum levels for a single event and the RMS vibration level. Table 4.5.H provides the criteria for assessing the potential for interference or annoyance from vibration levels in a building. Table 4.5.I lists the potential vibration building damage criteria associated with construction activities, as suggested in the Caltrans Manual.
Table 4.5.H: Interpretation of Vibration Criteria for Detailed Analysis Human Response Vibration Level (RMS in/sec)
Barely perceptible 0.01
Distinctly perceptible 0.04
Strongly perceptible 0.10
Severe 0.40
Source: Transportation and Construction Vibration Guidance Manual (Caltrans 2020).
Caltrans = California Department of Transportation
in/sec = inch/inches per second
RMS = root-mean-square
Table 4.5.I: Construction Vibration Damage Criteria
Structure / Condition PPV (in/sec)
Extremely fragile historic buildings, ruins, ancient monuments 0.08 Fragile buildings 0.10
Historic and some old buildings 0.25
Older residential structures 0.30
New residential structures 0.50
Modern industrial / commercial buildings 0.50
Source: Transportation and Construction Vibration Guidance Manual, Table 19 (Caltrans 2020).
Caltrans = California Department of Transportation
in/sec = inch/inches per second
PPV = peak particle velocity
7 California Department of Transportation (Caltrans). 2020. Transportation and Construction Vibration Guidance Manual. April 2020. Division of Environmental Analysis Environmental Engineering Hazardous Waste, Air, Noise, Paleontology Office.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-12
4.5.3.3 Local Regulations and Policies
The following is a summary of the applicable policies included in the City’s General Plan and Municipal Code that are related to noise and applicable to the proposed project.
City of Fresno General Plan. The City General Plan Noise and Safety Element (2014) has established interior and exterior noise standards from transportation (non-aircraft) noise sources for various land uses shown in Table 4.5.J and exterior noise standards from stationary noise sources shown in Table 4.5.K. In addition, the City General Plan Noise and Safety Element has established policies to meet the City’s noise-related objective. The applicable General Plan Noise and Safety Element noise- related objective and policies for the proposed project are listed below.
Table 4.5.J: Transportation (Non-Aircraft) Noise Sources Noise-Sensitive Land Use1 Outdoor Activity Areas2 Interior Spaces Ldn/CNEL, dB Ldn/CNEL, dB Leq dB2
Residential 65 45 -
Transient Lodging 65 45 -
Hospitals, Nursing Homes 65 45 -
Theaters, Auditoriums, Music Halls - - 35
Churches, Meeting Halls 65 - 45
Office Buildings - - 45
Schools, Libraries, Museums - - 45
Source: City of Fresno General Plan (2014).
1 Where the location of outdoor activity areas is unknown or is not applicable, the exterior noise level standard shall be applied to the property line of the receiving land use.
2 As determined for a typical worst-case hour during periods of use.
CNEL = Community Noise Equivalent Level
dBA = A-weighted decibels
Ldn = day-night average noise level
Leq = equivalent continuous sound level
Table 4.5.K: Stationary Noise Sources
Daytime
(7:00 a.m. – 10:00 p.m.)
Nighttime
(10:00 p.m. to 7:00 a.m.)
Hourly Equivalent Sound Level (Leq), dBA 50 45
Maximum Sound Level (Lmax), dBA 70 60
Source: City of Fresno General Plan (2014).
1 The Department of Development and Resource Management Director, on a case-by-case basis, may designate land uses other than those shown in this table to be noise-sensitive, and may require appropriate noise mitigation measures. 2 As determined at outdoor activity areas. Where the location of outdoor activity areas is unknown or not applicable, the noise exposure standard shall be applied at the property line of the receiving land use. When ambient noise levels exceed or equal the levels in this table, mitigation shall only be required to limit noise to the ambient plus 5 dB. dBA = A-weighted decibels
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-13
General Plan Noise-Related Objective and Policies.
Objective NS-1: Protect the citizens of the City from the harmful and annoying effects of exposure to excessive noise.
Policy NS-1-a: Desirable and Generally Acceptable Exterior Noise Environment. Establish 65 dBA Ldn or CNEL as the standard for the desirable maximum average exterior noise levels for defined usable exterior areas of residential and noise-sensitive uses for noise, but designate 60 dBA Ldn or CNEL (measured at the property line) for noise generated by stationary sources impinging upon residential and noise-sensitive uses. Maintain 65 dBA Ldn or CNEL as the maximum average exterior noise levels for non-sensitive commercial land uses, and maintain 70 dBA Ldn or CNEL as maximum average exterior noise level for industrial land uses, both to be measured at the property line of parcels where noise is generated which may impinge on neighboring properties.
Policy NS-1-b: Conditionally Acceptable Exterior Noise Exposure Range. Establish the conditionally acceptable noise exposure level range for residential and other noise sensitive uses to be 65 dB Ldn or require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the desirable and conditionally acceptable exterior noise level and the required interior noise level standards set in Table 9-2 (of the Fresno General Plan) [Table 4.5.E of this EIR].
Policy NS-1-c: Generally Unacceptable Exterior Noise Exposure Range. Establish the exterior noise exposure of greater than 65 dB L
dn or CNEL to be generally unacceptable for
residential and other noise sensitive uses for noise generated by sources in Policy NS-1-a, and study alternative less noise-sensitive uses for these areas if otherwise appropriate.
Require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the generally desirable or generally acceptable exterior noise level and the required 45 dB interior noise level standards set in Table 9-2 [Table 4.5.E] as conditions of permit approval.
Policy NS-1-g: Noise mitigation measures which help achieve the noise level targets of this plan include, but are not limited to, the following:
• Façades with substantial weight and insulation;
• Installation of sound-rated windows for primary sleeping and activity areas; • Installation of sound-rated doors for all exterior entries at primary sleeping and activity areas;
• Greater building setbacks and exterior barriers;
• Acoustic baffling of vents for chimneys, attic and gable ends; • Installation of mechanical ventilation systems that provide fresh air under closed window conditions.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-14
The aforementioned measures are not exhaustive and alternative designs may be approved by the City, provided that a qualified Acoustical Consultant submits information demonstrating that the alternative design(s) will achieve and maintain the specific targets for outdoor activity areas and interior spaces.
Policy NS-1-h: Interior Noise Level Requirement. Comply with the State Code requirement that any new multifamily residential, hotel, or dorm buildings must be designed to incorporate noise reduction measures to meet the 45 dB L dn interior noise criterion, and
apply this standard as well to all new single-family residential and noise sensitive uses.
Policy NS-1-i: Mitigation by New Development. Require an acoustical analysis where new development of industrial, commercial or other noise generating land uses (including transportation facilities such as roadways, railroads, and airports) may result in noise levels that exceed the noise level exposure criteria established by Table 9-2 [Table 4.5.E] and Table 9-3 [Table 4.5.F] to determine impacts, and require developers to mitigate these impacts in conformance with Table 9-2 [Table 4.5.E] and Table 9-3 [Table 4.5.F] as a condition of permit approval through appropriate means.
Noise mitigation measures may include:
• The screening of noise sources such as parking and loading facilities, outdoor activities, and mechanical equipment;
• Providing increased setbacks for noise sources from adjacent dwellings; • Installation of walls and landscaping that serve as noise buffers; • Installation of soundproofing materials and double-glazed windows; and • Regulating operations, such as hours of operation, including deliveries and trash pickup.
Alternative acoustical designs that achieve the prescribed noise level reduction may be approved by the City, provided a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces. As a last resort, developers may propose to construct noise walls along roadways when compatible with aesthetic concerns and neighborhood character. This would be a developer responsibility, with no City funding.
Policy NS-1-j: Significance Threshold. Establish, as a threshold of significance for the City's environmental review process, that a significant increase in ambient noise levels is assumed if the project would increase noise levels in the immediate vicinity by 3 dB L dn or CNEL or
more above the ambient noise limits established in this General Plan Update.
City of Fresno Municipal Code. Chapter 10, Article 1 (Noise Regulations), of the Fresno Municipal Code establishes excessive noise guidelines and exemptions. The following portions of the Municipal Code are applicable to the proposed project:
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-15
SEC. 10-102. Definitions. (b ) Ambient Noise. “Ambient noise” is the all-enc ompassing noise associated with a given environment, being usually a composite of sounds from many sources near and far. For the purpose of this ordinance, ambient noise level is the level obtained when the noise level is averaged over a period of fifteen minutes, without inclusion of the offending noise, at the location and time of day at which a comparison with the offending noise is to be made. Where the ambient noise level is less than that designated in this section, however, the noise level specified herein shall be deemed to be the ambient noise level for that location.
District Time Sound Level Decibels
Residential 10:00 p.m. to 7:00 a.m. 50
Residential 7:00 p.m. to 10:00 p.m. 55
Residential 7:00 a.m. to 7:00 p.m. 60
Commercial 10:00 p.m. to 7:00 a.m. 60
Commercial 7:00 a.m. to 10:00 p.m. 65
Industrial anytime 70
SEC. 10-105. Excessive Noise Prohibited. N o person shall make, cause, or suffer or permit to be made or caused upon any premises or upon any public street, alley, or place within the city, any sound or noise which causes discomfort or annoyance to any reasonable person of normal sensitiveness residing or working in the area, unless such noise or sound is specifically authorized by or in accordance with this article. The provisions of this section shall apply to, but shall be limited to, the control, use, and operation of the following noise sources:
(a) Rad
ios, musical instruments, phonographs, television sets, or other machines or devices used for the amplification, production, or reproduction of sound or the human voice. (b) Animals or fowl creating, generating, or emitting any cry or behavioral sound. (c) Machinery or equipment, such as fans, pumps, air conditioning units, engines, turbines, compressors, generators, motors or similar devices, equipment, or apparatus. (d) Construction equipment or work, including the operation, use or employment of pile drivers, hammers, saws, drills, derricks, hoists, or similar construction equipment or tools.
SEC
. 10-107
. School, Hospitals, and Churches. No person shall create any noise on any street, sidewalk, or public place adjacent to any school, institution of learning, or church while the same is in use, or adjacent to any hospital, which noise unreasonably interferes with the workings of such institution or which disturbs or unduly annoys patients in the hospital, provided conspicuous signs are displayed in such street, sidewalk, or public place indicating the presence of a school, church, or hospital.
SEC.
10-109
. Exceptions. The provisions of this article shall not apply to:
(a) Co
nstruction, repair or remodeling work accomplished pursuant to a building, electrical, plumbing, mechanical, or other construction permit issued by the city or other governmental agency, or to site preparation and grading, provided such work takes place between the hours of 7:00 a.m. and 10:00 p.m. on any day except Sunday.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-16
(b) Emergency work.
(c) Any act or acts which are prohibited by any law of the State of California or the United States.
4.5.4 Significance Criteria
The thresholds for impacts to noise used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Implementation of the proposed project would result in a significant impact with respect to noise if it would:
• 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 in other applicable local, state, or federal standards; • Generate excessive groundborne vibration or groundborne noise levels; or • For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels.
4.5.5 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to noise that could result from implementation of the Specific Plan Update. 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 Specific Plan Update 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.
4.5.5.1 Project Impacts
The following discussion describes the potential impacts related to noise that could result from implementation of the Specific Plan Update.
NOI-1 Implementation of the proposed 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 in other applicable local, State, or Federal standards.
Implementation of the Specific Plan Update would have a significant impact if it would expose new and existing receptors to incompatible levels of noise from both the construction and operations resulting from future development facilitated by the Specific Plan Update.
Sho
rt-Ter
m Construction Noise Impacts. Two types of short-term noise impacts could occur during implementation of the Specific Plan Update. First, construction crew commutes and the transport of construction equipment and materials to future development facilitated by the Specific Plan Area LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-17
would incrementally increase noise levels on roads leading to the site. The pieces of heavy equipment for construction activities will be moved on site, will remain for the duration of each construction phase, and will not add to the daily traffic volume in the project vicinity. Although there would be a relatively high single-event noise exposure potential causing intermittent noise nuisance (passing trucks at 50 feet would generate up to a maximum of 84 dBA), the effect on longer-term (daily) ambient noise levels would be small because the daily construction-related vehicle trips are small compared to the existing daily traffic volumes on roadways leading in the Specific Plan Area.
The results of the California Emissions Estimator Model (CalEEMod) (version 2022.1), contained in the Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report ((Specific Plan Air Quality, GHG, and Energy Analysis) (LSA 2025a)8 provided in Appendix E of this Draft EIR, indicate that the building construction phase would generate the most trips out of all of the construction phases (up to 2,887 vehicle trips) and that they would be distributed throughout the Specific Plan Area over 11 years. Although the proposed project would generate higher vehicle trips than estimated with the existing conditions, construction-related vehicle trips are not expected to double the existing traffic volume on roadways within the Specific Plan Area. A doubling of traffic would result in a noise increase of a maximum of 3 dBA. A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, short-term, construction-related noise impacts associated with worker commute and equipment transport to future project sites within the Specific Plan Area would be less than significant. No mitigation measures are required.
Construction Activities. The second type of short-term noise impact is related to noise generated from construction activities. Construction is performed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. The proposed project anticipates phases of construction including site preparation, grading, building construction, paving, and architectural coating. These various sequential phases change the character of the noise generated on a project site. Therefore, the noise levels vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table 4.5.L lists the maximum noise levels (L
max) recommended for noise impact assessments for typical construction equipment included in the FHWA Highway Construction Noise Handbook (2006),9 based on a distance of 50 feet between the equipment and a noise receptor.
8 LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
9 Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook. Roadway Construction Noise Model, FHWA HEP-06-015. DOT-VNTSC-FHWA-06-02. NTIS No. PB2006-109012.
August.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-18
Table 4.5.L: Typical Construction Equipment Noise Levels Equipment Description Acoustical Use Factor1
(Percent) Maximum Noise Level (Lmax) at 50 ft2
Backhoe 40 80
Compactor (ground) 20 80
Compressor (air) 40 80
Crane 16 85
Dozer 40 85
Dump Truck 40 84
Excavator 40 85
Flatbed Truck 40 84
Forklift 20 85
Front-End Loader 40 80
Generator 50 82
Grader 40 85
Impact Pile Driver 20 95
Jackhammer 20 85
Pavement Scarifier 20 85
Paver 50 85
Pickup Truck 40 55
Pneumatic Tools 50 85
Pump 50 77
Rock Drill 20 85
Roller 20 85
Scraper 40 85
Tractor 40 84
Welder/Torch 40 73
Source: FHWA Highway Construction Noise Handbook, Table 9.1 (FHWA 2006).
Note: The noise levels reported in this table are rounded to the nearest whole number. 1 Acoustical Use factor is the percentage of time during a construction noise operation that a piece of construction equipment is operating at full power.
2 Maximum noise levels were developed based on Spec 721.560 from the CA/T program to be consistent with the City of Boston, Massachusetts, Noise Code for the “Big Dig” project.
CA/T = Central Artery/Tunnel
FHWA = Federal Highway Administration
ft = foot/feet
Lmax = maximum instantaneous noise level
Table 4.5.M lists the anticipated construction equipment for each construction phase based on the CalEEMod (Version 2022.1) results contained in Appendix E, the Tower District Specific Plan Air Quality, GHG, and Energy Analysis (LSA 2025a)10 for the proposed project. Table 4.5.M shows the combined noise level at 50 feet from all of the equipment in each phase and the Leq noise level for each equipment at 50 feet based on the quantity, reference Lmax noise level at 50 feet, and the acoustical use factor. As shown in Table 4.5.M, construction noise levels would reach up to 89.2 dBA Leq at a distance of 50 feet.
10 LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-19
Table 4.5.M: Summary of Construction Phase, Equipment, and Noise Levels Construction
Phase
Construction
Equipment Quantity
Reference
Noise Level at
50 ft
(dBA Lmax)
Acoustical
Use Factor1
(%)
Noise Level
at 50 ft
(dBA Leq)
Combined Noise
Level at 50 ft
(dBA Leq)
Site Preparation Dozers 3 85 40 85.8 87.3 Front-End Loader 4 80 40 82.0 Grading
Graders 1 85 40 81.0
89.2 Excavator 2 85 40 84.0
Front-End Loader 2 80 40 79.0
Scraper 2 85 40 84.0
Dozer 1 85 40 81.0
Building
Construction
Forklift 3 85 20 82.8
86.5 Generator 1 82 50 79.0
Crane 1 85 16 77.0
Welder/Torch 1 73 40 69.0
Front-End Loader 3 80 40 80.8
Paving
Paver 2 85 50 85.0
87.6 Pavement Scarifier 2 85 20 81.0
Roller 2 85 20 81.0
Architectural
Coating Air Compressors 1 80 40 76.0 76.0
Source: Compiled by LSA (2025).
1 The acoustical use factor is the percentage of time during a construction noise operation that a piece of construction equipment operates at full power.
dBA = A-weighted decibels
ft = foot/feet
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
Construction noise levels for the proposed project would be relatively similar to those approved in the 1991 Specific Plan because construction would be localized to the future specific project sites located throughout the Specific Plan Area and would be constructed over many years. There would, however, be more construction under the proposed Specific Plan Update compared to the existing Specific Plan.
Future projects facilitated by the Specific Plan Update would be required to comply with existing regulatory compliance measures, including limiting construction activities to certain hours and days to regulate noise levels. Although noise generated by project construction activities would be higher than the ambient noise levels and may result in a temporary increase in the ambient noise levels, construction noise would stop once project construction is completed. However, construction noise levels have the potential to exceed the FTA daytime construction noise standards of 80 dBA L eq for
residences and 85 dBA Leq for commercial properties. Therefore, this impact is potentially significant.
Long-Ter
m Project Impacts. The proposed project would generate approximately 39,055 daily trips, and the existing conditions would generate approximately 36,054 daily trips based on the information above and in the Tower District Specific Plan Update Trip Generation and Vehicle Miles Traveled Analysis Memorandum (LSA 2025d),11 the proposed project would increase daily trips by 3,001 compared to the existing conditions. Although the proposed project would increase daily trips by 3,001, the project-related traffic noise increase would either be similar or slightly higher than the
11 LSA Associates, Inc. (LSA). 2025d. Tower District Specific Plan Update Trip Generation and Vehicle Miles Traveled Analysis Memorandum.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-20
existing conditions because the daily trips are distributed throughout the Specific Plan Area. Given this, daily trips associated with the proposed project are not expected to double the existing traffic volume on roadways within the Specific Plan Area. A doubling of traffic would result in a noise increase of 3 dBA. A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, traffic noise from project-related traffic on off-site sensitive receptors would be less than significant, similar to the existing Specific Plan.
Stationary Sources. Similar to the 1991 Specific Plan, the proposed project would include new stationary noise sources generated from proposed residential, commercial, and industrial uses, which could include heating, ventilation, and air conditioning (HVAC) equipment, swimming pool equipment, generators, drive-thru menu board speakerphones, truck loading docks, parking activities, car wash operations, and like uses. These long-term stationary noise sources could exceed the City’s stationary noise standards if they were to occur in areas adjacent to noise-sensitive land uses. Noise impacts from long-term stationary noise sources would be considered significant.
The Tower District provides a desirable setting for special events and entertainment of many forms.
Special events contribute to the economic vitality of the City and attract tourism, however, with residents living in close proximity to these events, ensuring managed frequency and intensity of the noise from these events is a priority for the City. As such, the proposed project includes the potential for a Tower Entertainment District Overlay to be created, which would support the continuation of a variety of entertainment businesses within the District and ensure that commercial uses integrate well with the surrounding residential areas. Implementation of the Tower Entertainment District would require a text amendment to the Development Code to formally establish this new district, which would address potential impacts and include noise mitigation considerations.
Level of Significance Without Mitigation: Potentially Significant Impact Impact NOI-1: Implementation of the proposed Specific Plan Update 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 in other applicable local, State, or federal standards.
Mitigation Measure NOI-1a Prior to the issuance of demolition, grading, and/or construction permits, the construction contractor shall conduct a project-level construction noise analysis to evaluate potential impacts on off-site sensitive land uses adjacent to the project site. The project-level construction noise analysis shall be prepared, reviewed, and approved by the City of Fresno Planning and Development Director.
Measures shall be implemented to reduce construction noise to the FTA construction noise criteria or below if construction noise impacts are identified. Measures may include, but are not limited to the installation of temporary construction barriers.
Mitigation Measure NOI-1b A project-specific noise study shall be prepared by a qualified acoustical consultant to determine the noise levels generated from LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-21
long-term operations of future projects associated with implementation of the Tower District Specific Plan Update, and measures will be included as necessary to reduce noise levels and ensure compliance with the City of Fresno’s stationary noise standards. The project specific noise study will be submitted to the city for review and approval. Noise reduction measures may include, but are not limited to, locating stationary noise sources on the site to be shielded by structures (buildings, enclosures, or soundwalls) or by using equipment that has a quieter rating.
Level of Significance With Mitigation: Less than Significant Impact Implementation of Mitigation Measures NOI-1a and NOI-1b would serve to ensure that the impacts due to the implementation of the Specific Plan would be reduced to a less than significant level.
NOI-2 The proposed project would generate excessive groundborne vibration or groundborne noise levels.
Short-Term Construction Vibration Impacts. This construction vibration impact analysis discusses the level of human annoyance and assesses the potential for building damage using vibration levels in PPV (in/sec). Table 4.5.N shows the reference vibration levels at a distance of 25 feet for each type of standard construction equipment from the Caltrans Manual (2020). Outdoor site preparation and grading for development associated with the proposed project is expected to require the use of large bulldozers and loaded trucks, which would generate ground-borne vibrations of up to
0.089 in/sec maximum PPV and 0.062 in/sec RMS PPV for large bulldozers and 0.076 in/sec maximum PPV and 0.053 in/sec RMS PPV for loaded trucks when measured at 25 feet. Pile drivers, vibratory rollers, and other heavy-tracked construction equipment were not used under the 1991 Specific Plan and would not be used under the proposed project.
Table 4.5.N: Vibration Source Amplitudes for Construction Equipment Equipment Reference PPV/LV at 25 ft
Maximum PPV (in/sec) RMS PPV (in/sec)1
Pile Driver (Impact), Typical 0.644 0.451
Pile Driver (Sonic), Typical 0.170 0.119
Vibratory Roller 0.210 0.147
Hoe Ram 0.089 0.062
Large Bulldozer2 0.089 0.062
Caisson Drilling 0.089 0.062
Loaded Trucks2 0.076 0.053
Jackhammer 0.035 0.025
Small Bulldozer 0.003 0.002
Sources: Transportation and Construction Vibration Guidance Manual (Caltrans 2020). 1 RMS vibration velocity is 70 percent of the maximum PPV. 2 Equipment shown in bold is expected to be used on site.
Caltrans = California Department of Transportation
ft = foot/feet
in/sec = inches per second
LV = velocity in decibels
PPV = peak particle velocity
RMS = root-mean-square
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-22
The greatest vibration levels are anticipated during the site preparation and grading phases. All other phases are expected to result in lower vibration levels. The distance to the nearest buildings for vibration impact analysis is measured between the nearest off-site buildings and the project boundary (assuming the construction equipment would be used at or near the project boundary) because vibration impacts normally occur within the buildings.
The formula for vibration transmission is provided below:
PPV
equip = PPVref x (25/D)1.1
The anticipated large bulldozer located within 38 feet from a building structure would experience vibration levels exceeding 0.04 in/sec (PPV), which is considered distinctly perceptible and would result in annoyance. However, construction is temporary and vibration would stop once construction is complete. In addition, the anticipated large bulldozer located within 10 feet of a historic building, 9 feet of an older residential structure, or 6 feet of a new residential or modern industrial/commercial buildings would experience vibration levels exceeding 0.25 in/sec (PPV),
0.3 in/sec (PPV), and 0.5 in/sec (PPV), respectively, which would have the potential to result in building damage. Therefore, this impact is potentially significant.
Long-Term Ground-Borne Noise and Vibration from Vehicular Traffic. The operations of the proposed project would not generate vibration. In addition, vibration levels generated from project- related traffic on roadways in the Specific Plan Area would be unusual for on-road vehicles because the rubber tires and suspension systems of on-road vehicles provide vibration isolation. Therefore, vibration levels generated from project-related operations would be less than significant. No mitigation measures are required.
Level of Significance Without Mitigation: Potentially Significant Impact Impact NOI-2: Implementation of the proposed project could generate excessive ground-borne vibration or ground-borne noise levels during construction of future development.
Mitigation Measure NOI-2 Future development would require that the construction contractor for the project shall restrict heavy construction (e.g., large bulldozers) or require the use of light construction equipment (e.g., small bulldozers and trucks) within 10 feet of a historic building, 9 feet of an older residential structure, or 6 feet of a new residential or modern industrial/commercial building, to be confirmed by the City of Fresno or lead agency.
Level of Significance With Mitigation: Less than Significant Impact Implementation of Mitigation Measure NOI-2, which restricts heavy construction (e.g., large bulldozers and loaded trucks) or requires the use of light construction equipment (e.g., small bulldozers and trucks) within 10 feet of a historic building, 9 feet of an older residential structure, or 6 feet of a new residential or modern industrial/commercial building, would reduce vibration levels to below the vibration damage threshold for the respective building types. Therefore, vibration LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-23
levels generated from project construction would be less than significant with the implementation of Mitigation Measure NOI-2.
NOI-3 For a proposed project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, the proposed project would not expose people residing or working in the Specific Plan Area to excessive noise levels.
The closest airports to the Specific Plan Area are the Fresno Chandler Executive Airport (1 mile southeast of the Specific Plan Area), Fresno Yosemite International Airport (3.3 miles east of the Specific Plan Area), and Sierra Sky Park Airport (4.8 miles northwest of the Specific Plan Area). The nearest medical center helipads (HP) includes the Community Regional Medical Center HP (0.5 mile southeast of the Specific Plan Area), the Saint Agnes Medical Center HP, (4.2 miles northeast of the Specific Plan Area), and the Clovis Community Hospital HP (8.5 miles northeast of the Specific Plan Area). The Specific Plan Area is outside the 60 dBA CNEL noise contour of airports based on the Fresno County Airport Land Use Compatibility Plan.12 There are also no private airstrips within 2 miles of the project site. In addition, the aviation-related noise exposure to people residing or working in the Specific Plan Area under the proposed project would remain the same as the 1991 Specific Plan.
Therefore, the proposed project would not expose people residing or working in the Specific Plan Area to aviation-related excessive noise levels, impacts would be less than significant.
Level of Significance: Less Than Significant Impact
Mitigation Measures: No mitigation measures are required.
4.5.5.2 Cumulative Impacts
NOI-4 Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, could result in significant cumulative impacts with respect to noise.
Con
struction Noise. Buildout of the Specific Plan Update, along with construction of related projects in the Specific Plan Area, would introduce construction activities to the Specific Plan Area that could potentially result in temporary or periodic increases in ambient noise levels. Construction activities would typically occur intermittently and vary depending upon the nature or phase of construction, although noise ranges are usually similar across all construction phases. Depending on the equipment required and duration of use, average
-hou
rly noise levels associated with
construction activities typically ranges from roughly 65 to 90 dBA Leq at 50 feet. Future construction activities would most likely occur at different locations throughout the Specific Plan Area and the surrounding vicinity. Although scheduling of some of construction activities would likely overlap, development facilitated by the Specific Plan would occur over a number of years. This distribution of individual projects would reduce the potential for compounding of construction noise. Additionally, future development would undergo environmental review under CEQA to evaluate project-specific
12 Fresno County Airport Land Use Commission (Fresno County ALUC). 2023. Fresno County Airport Land Use Compatibility Plan. October. Website: https://www.fresnocog.org/wp-content/uploads/2025/06/2023- ALUCP.pdf (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-24
construction noise impacts and identify any required mitigation. Implementation of Regulatory Compliance Measure NOI-1 and Mitigation Measure NOI-1 would also serve to ensure that the impacts due to the implementation of the Specific Plan would be reduced to a less than significant level
As previously addressed, site preparation, grading, and other construction activity conducted pursuant to a building or other construction permit issued by the City of Fresno or other governmental agency would be exempt for the provisions of Chapter 10, Article 1 – Noise Regulations, of the Fresno Municipal Code, provided such work occurs between 7:00 a.m. and 10:00 p.m., excluding Sunday. Future construction activities associated with cumulative development projects would also be required to comply with the Municipal Code and incorporate mitigation measures on a project-by project basis, as applicable, to reduce construction noise pursuant to CEQA provisions. Therefore, the proposed project contributions to cumulative construction noise would result in a less than significant cumulative impact.
Construction Vibration. As discussed above, project-related construction activities would not generate ground-borne vibration on-site above the significance criteria (i.e., 0.2 in-per-second PPV threshold as established by Caltrans) with implementation of Mitigation Measure NOI-2. Ground- borne vibration generated from cumulative projects in the Specific Plan Area would be required to undergo environmental review under CEQA to determine project-specific impacts and any required mitigation measures on a project-by-project basis. Additionally, implementation of Mitigation Measure NOI-2 would restrict heavy construction (e.g., large bulldozers and loaded trucks) or requires the use of light construction equipment (e.g., small bulldozers and trucks) within 10 feet of a historic building, 9 feet of an older residential structure, or 6 feet of a new residential or modern industrial/commercial building, would reduce vibration levels to below the vibration damage threshold for the respective building types. Therefore, cumulative vibration levels generated from future project construction associated with the Specific Plan Update would result in a less than significant cumulative impact.
Operational Noise – Traffic Sources. Project-related cumulative noise impacts would occur if the proposed Plan’s contribution to cumulative noise increases results in a substantial noise increase in comparison to existing conditions. As discussed above, the Specific Plan Update would not facilitate a substantial noise increase greater than 3 dBA due to traffic noise. Traffic noise generated from cumulative development projects would be required to implement any required mitigation measures on a project-by-project basis, as applicable, pursuant to CEQA provisions. Therefore, the proposed project, in combination with cumulative traffic noise levels, would result in less than significant impacts.
Operational Noise – Stationary Sources. Although cumulative development could occur in proximity to future development facilitated by implementation of the Specific Plan Update, each project would require separate discretionary approval and CEQA analysis, which would address potential noise impacts and identify necessary attenuation measures, where appropriate.
Any new onsite ventilation units and associated equipment associated with future project sites would be acoustically engineered with appropriate procurement specifications, sound enclosures, and parapet walls to minimize noise—all in accordance with City of Fresno stationary noise LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
4.5-25
requirements—to ensure that such equipment does not exceed allowable noise limits. Other stationary sources for residential, office, and commercial uses include landscaping, maintenance, truck deliveries, trash pickup, and parking lot activity, and any other sources of stationary noise at a project site would also be subject to the restrictions of the Municipal Code.
Additionally, as noise dissipates as it travels away from its source, noise impacts from stationary sources would be limited to each of the respective sites and their vicinities. Thus, the proposed project and any cumulative development in the Specific Plan Area are not anticipated to result in a significant cumulative impact, and a less than significant impact would occur.
Level of Significance Without Mitigation: Potentially Significant Impact Impact NOI-4: Implementation of the Specific Plan Update could result in cumulative impacts with respect to noise.
Mitigation Measures: Refer to Mitigation Measures NOI-1a, NOI-1b, and NOI-2.
Level of Significance With Mitigation: Less than Significant Impact Implementation of Mitigation Measures NOI-1a, NOI-1b, and NOI-2 would serve to ensure that noise and vibration impacts associated with implementation of the proposed project would not result in a cumulative significant impact.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
4.5-26
This page intentionally left blank
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-1
4.6 RECREATION
4.6.1 Introduction
This section describes how implementation of the Tower District Specific Plan Update (proposed project or Specific Plan Update) for the City of Fresno (City) may affect recreation resources within the Specific Plan Area. This section also addresses local, State, and federal regulations as they pertain to project impacts on recreation.
As discussed in the Initial Study of this Draft Environmental Impact Report (EIR) (Appendix C), the proposed project would result in a potentially significant impact related to parks and recreation. The analysis included in the Initial Study addresses all other potential environmental impacts to public services related to implementation of the proposed project (fire protection, police protection, schools, and other public facilities). Therefore, this section is limited to impact discussions related to parks and recreation.
4.6.2 Existing Environmental Setting
The study area for project impacts regarding recreation is the Tower District Specific Plan Area (Specific Plan Area), as the potential development under the Specific Plan Update is limited to areas within the Specific Plan Area. As defined in Chapter 3.0, Project Description, the Specific Plan Area encompasses the Tower District which is centrally located within Fresno. The Specific Plan Area is generally bound by Shields Avenue to the north, Blackstone Avenue to the east, State Route (SR) 180 to the south, and Fruit Avenue and the Union Pacific Railroad (UPRR) tracks to the west.
4.6.2.1 Parks and Recreation
As identified in the Fresno Parks Master Plan,
1 the City of Fresno owns and operates a park system
that includes more than 100 public parks, trails, regional parks, neighborhood parks, educational facilities, community parks, pocket parks, splash areas, and joint-use storm water detention basins.
Parks are defined as land owned, leased, or provided to the City and used for public recreational purposes. Among these are several Fresno Metropolitan Flood Control District (FMFCD) stormwater detention basins that serve as passive and active parks from April to November. Many of the public parks in the City include additional amenities, such as play structures, sitting areas, walking trails, and skate and dog parks. School facilities supplement the City’s park system by adding acreage and facilities that are available for recreational use through Joint-Use agreements.
The City’s General Plan defines various classes of park space and sets standards for the amount of park acreage that should be provided per thousand population. Table 4.6.A, below, shows the desirable park facility standards within the city.
1 City of Fresno. 2024. Fresno Parks Master Plan with the 2023 Technical Amendment. Website:
https://www.fresno.gov/parks/parksmasterplan/ (accessed June 2025).
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-2
Table 4.6.A: Desirable Park Facility Standards
Park Type Size Range (Acreage) Service Area Radius
Pocket 0.5 to 2 Up to 0.5 mile
Neighborhood 2.01 to 10 Up to 1 mile
Community 10.01 to 40 Up to 4 miles
Regional More than 40 100,000 residents
Trail/Greenway/Parkway Varies Entire City
Source: Fresno General Plan, Chapter 5, Parks and Open Space, Table 5-1 (City of Fresno 2014).
Park types in the General Plan and Parks Master Plan are classified as follows:
• Pocket Park. A Pocket Park is a park up to 0.5 to 2.0 acres in size and is intended to serve the needs of a smaller, specific neighborhood located within a 0.5-mile radius of the pocket park.
Pocket Parks should include amenities to draw neighbors to the park such as a tot lot, picnic bench, or shade structure. New pocket parks developed within new subdivisions are maintained as part of a Home Owners Association (HOA) or Community Facilities District (CFD). • Neighborhood Park. A Neighborhood Park is a park of more than 2.0 acres and up to 10 acres in size, which provides basic recreational activities for neighborhoods located generally within a
0.5-mile radius. There are two types of Neighborhood Parks, active and passive. These parks contribute to neighborhood identity and accommodate a range of facilities, such as play fields and courts, children’s play structures, picnic tables, restrooms, and may include a small center with a multi-purpose room, but also passive recreational features such as walking trails, community gardens, or nature areas.
• Community Park. A Community Park is a park of more than 10 acres and up to 40 acres in size (typically at least 20 acres), which helps define a community or district and is intended to serve the more active recreational needs of persons who live or work up to a 2- to 4-mile radius.
These parks typically include facilities such as lighted sport fields and a community center building with a gym, meeting rooms, and restrooms. Other features may include swimming pools, tennis courts, concession stands, community defining public art, courtyard or plaza. • Regional Park. A Regional Park is a large park of more than 40 acres in size, which is meant to serve a large number of residents across a broad area of the city, or around 100,000 residents.
Regional parks typically include community park features that allow for a variety of sports and active recreation. Some are large enough to enable Fresno to host local and regional tournaments or events that bring revenue to the City and local businesses in the form of additional patrons and tax revenue generated. Regional parks also provide unique public facilities, such as the Shinzen Japanese Garden, the Chaffee Zoological Gardens, or natural areas with hiking trails, fishing opportunities, and access to the San Joaquin River. Parks that provide unique opportunities, such as river access, have been categorized as regional parks, even though they are less than 40 acres in size.
• Trail/Greenway/Parkway. A Trail/Greenway/Parkway is a network of linear open space of varying size, typically intended to accommodate walking and bicycling opportunities for leisure, LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-3
exercise and commuting purposes. These parkways typically include paved surfaces for bicyclists and walkers, and in appropriate locations may include equestrian trails The current citywide standard for parks is a ratio of 3.0 acres per 1,000 residents for Pocket, Neighborhood, and Community parks; this was established under the City’s previous Urban Growth Management Program, General Plan, and the 2024 Parks Master Plan.
There are four parks classified as Pocket, Neighborhood, or Community parks within the Specific Plan Area, as noted by the City of Fresno Parks Locater 2 as shown in Figure 4.6-1, Parks in the
Specific Plan Area, and Table 4.6.B. The Ted C Wills Community Center and San Pablo parks are located in the southeastern corner of the Specific Plan Area, while the Van Ness Greenbelt and Trolley Park are located centrally within the Tower District on Van Ness Boulevard. Additionally, according to the Fresno Parks Master Plan, there is a future pocket park, totaling 0.6 acre, planned for the corner of Broadway and Elizabeth Streets (940 North Broadway Street 3). This future pocket
park would include a playground with musical equipment, Americans with Disabilities Act (ADA) picnic tables, chess tables, and a walking loop.
Table 4.6.B: Existing and Planned Parks within the Specific Plan Area Map ID Facility Name Address Existing
Acreage
Park Type Amenities
A Broadway Parque
(To Open Summer
2025)
940 North
Broadway
0.6 acres Pocket Playground with musical
equipment, ADA picnic
tables, chess tables, and a
walking loop
B San Pablo 511 North San
Pablo
1.4 acres Pocket Outdoor Community
Gathering Space, Children’s
Play Area
C Ted C Wills Park
and Community
Center
770 North San
Pablo
4.3 acres Neighborhood Community Center
D Trolley Park 2004 N. Van Ness
Boulevard
0.4 acres Pocket Playground, Exercise
Stations, Bocce Ball Court,
Shade Trees, Picnic Tables
E Van Ness
Boulevard
Median Island from
Weldon to Shields
1.5 acres Greenbelt N/A
Total Acreage 8.2 acres
Parkland-to-Resident Ratio1, 2 0.33 acres per 1,000 residents.
Source: City of Fresno Parks, Parks and Recreation Facilities Finder (Website: https://cityoffresno.maps.arcgis.com/apps/webapp viewer/index.html?id=53f212b20a0f47efb6681df6c8ad2eaa, accessed July 7, 2025). 1 Assumes population of Specific Plan Area to be 20,200, per Draft Specific Plan Update, Chapter 1. 2 Ratio does not include Van Ness Boulevard Greenbelt, as it is not part of the community, neighborhood, or pocket park goal of providing 3 acres per 1,000 residents. 6.7*(1000/20200) = 0.33.
ADA = Americans with Disabilities Act
2 City of Fresno. n.d. City of Fresno Parks and Recreation Facilities Finder. Website: https://www.fresno. gov/parks/ (accessed July 7, 2025).
3 City of Fresno. 2024. Fresno Parks Master Plan with the 2023 Technical Amendment. Page 101. Website:
https://www.fresno.gov/parks/parksmasterplan/ (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-4
This page intentionally left blank
LSA
LSA
$
775 1550
FEET
SOURCE: Google Maps (2025)
c::J Tower District Boundary
- Parks and Open Space
FIGURE 4.6-1
Tower District Specific Plan Update
Parks and Open Space in the Vicinity of the Plan Area
l:\2024\20241643\GIS\Pro \Tower District Specific Plan Update\Tower District Specific Plan Update.aprx (7/14/2025)
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-6
This page intentionally left blank
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-7
The Specific Plan Area has approximately 6.7 acres of useable parks, not including the Van Ness Greenbelt as it is not a community, neighborhood, or pocket park. As the Tower District is estimated to have a population of 20,200 residents, this equates to 0.33 acre per 1,000 residents. In 2014, the City as a whole provided 1.27 acres of parks (pocket, neighborhood, and community) per 1,000 residents.
4 As discussed in the Park Master Plan, parkland within the City of Fresno needs to increase by 1,095 acres to meet the General Plan overall level of service goals for Fresno’s current population, and by 1,751 acres to meet recreation needs of Fresno’s future population (General Plan Horizon Year 2035).
5 And as shown in the Parks Master Plan, while the ratio for the City is higher than that of the Tower District, the provision of parkland is not even across the City, with the inclusion of open campus schools as parkland increasing the disparity of park space in the neighborhoods north and south of Shaw Avenue, including the Tower District.
While not included in the study area for impacts to parks and recreational facilities, there are fourteen parks and community facilities within a 1-mile vicinity of the Specific Plan Area. Table 4.6.C provides a list of open space in the vicinity of the Specific Plan and their respective acreage. Parks in the vicinity of the Specific Plan Area include the large regional Roeding Park, which features amenities such as the Fresno Chaffe Zoo, Storyland amusement center, Chaffee Zoo Educational Center, a roller-skating ring, tennis courts, a small lake and several ponds, a pergola and several picnic areas, and a redwood grove. Romain Park is located approximately 1.03 miles to the east of the Specific Plan Area and includes a playground, basketball courts, a skate park, community center, soccer fields, and a learner pool. Dicky Playground is located approximately 0.6 mile to the southeast of the Specific Plan Area and features amenities including picnic areas, a baseball field, tennis and basketball courts, a playground, and a splash pad. The Cultural Arts District Park is located approximately 0.7 mile to the south and includes amenities such as a multi-purpose field, performing arts stage, basketball court, playground, outdoor workout stations, picnic areas, community art, and illuminated canopies. Fink-White Park is located approximately 0.7 mile south of the southwestern corner boundary and includes features such as a playground, soccer field, basketball courts, a learner pool, and community center. Additionally, Eaton Plaza and Courthouse Park are located approximately 1 mile south of the Specific Plan Area. Eaton Plaza is adjacent to the Fresno County Library and the B.F. Sisk Courthouse. Fresno City College’s Baseball Park and Ratcliff Stadium are located approximately 0.3 mile northeast of the Specific Plan Area’s northeast corner.
The sports facilities include amenities, such as a football stadium with all-weather track and field facilities, a practice football field and hammer throw facility, a baseball park, and a soccer field with an associated field house. While not accessible for public use, currently enrolled students are able to use the facilities.
4 City of Fresno. 2014. Fresno General Plan. Chapter 5 Parks and Open Space, Table 5-2: City Park Space and Ration Per 1,000 Residents by Park Category.
5 City of Fresno. 2024. Fresno Parks Master Plan with the 2023 Technical Amendment. Chapter 1, Introduction, page 11. Website: https://www.fresno.gov/parks/parksmasterplan/ (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-8
Table 4.6.C: Parks and Open Space in the Vicinity of the Specific Plan Area
Facility Name Existing Acreage Park Type
Broadway Pocket Park 0.09 Pocket
Courthouse Park 13.94 Community Facility
Cultural Arts District Park 0.78 Pocket
Dicky Playground 2.02 Neighborhood
Eaton Plaza 1.38 Neighborhood
Euless Park 8.95 Community Facility
Fink-White Park 10.68 Neighborhood
Granny's Park 1.17 Pocket
Lafayette Park 4.35 Neighborhood
Manchester Park 9.42 Neighborhood
Quigley Playground 8.96 Neighborhood
Radio Park 7.46 Neighborhood
Roeding Park 144.62 Regional
Romain Playground 7.88 Neighborhood
Total: 221.77 acres
Sources: City of Fresno (2019); City of Fresno (2024) Fresno Parks Master Plan with the 2023 Technical Amendment, Figure 3.7 “Park Site Information”.
4.6.3 Regulatory Setting
There are no federal regulations pertaining to park and recreation services that apply to the Specific Plan Area, so this discussion summarizes the key State and local regulations.
4.6.3.1 State Policies and Regulations
Quimby Act. Under California State Law, the Quimby Act sets a generally applicable standard of
3.0 acres of park space per 1,000 residents as the maximum that can be required by a city or county as a condition of approval of a residential subdivision. Cities with a ratio of higher than 3 acres per 1,000 persons can set a standard of up to 5 acres per 1,000 persons for new development. The calculation of a city’s park space to population ratio is based on a comparison of the population count of the last federal census to the amount of city-owned parkland. The Quimby Act does not preclude a city from establishing a higher parkland standard, just restricts the amount that can be charged to a new residential development. A 1982 amendment (Assembly Bill [AB] 1600) requires agencies to clearly show a reasonable relationship between the public need for a recreation facility or parkland and the type of development project on which the fee is imposed.
4.6.3.2 Local Policies and Regulations
The following is a summary of the applicable policies included in the City’s approved General Plan and Municipal Code that are related to recreation and applicable to the proposed project.
City of Fresno General Plan. The current citywide park fee is based upon a ratio of 3.0 acres per 1,000 residents. This was established under the City’s previous Urban Growth Management Program and 1989 Master Plan for Parks and Recreation. This 3.0-acre parkland standard was maintained LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-9
through the adoption of the 2025 Fresno General Plan, the subsequent Park Facilities Impact Fee & Parkland Dedication Study, and the adoption of the citywide Park Facilities Fee ordinance.
The following objectives and policies from the draft Specific Plan are relevant to the provision of parks within the Specific Plan Area.
Parks, Open Space, and Schools Element.
Objective POSS‐1: Provide an expanded, high quality and diversified park system, allowing for varied recreational opportunities for the entire Fresno community.
POSS‐1‐a: Parkland Standard. Implement a standard of at least three acres of public parkland per 1,000 residents for Pocket, Neighborhood, and Community parks throughout the city, while striving for five acres per 1,000 residents for all parks throughout the city, subject to identifying additional funding for Regional Parks, Open Space/Natural Areas, and Special Use Parks/Facilities.
POSS‐1‐b: Parks Implementation Planning. Conduct ongoing planning to implement park policies established in this General Plan and continue to strive for well-maintained and fully accessible playgrounds, with accessible amenities, throughout the city. • Keep an up-to-date inventory of existing and planned parks, including locations mapped on the Parks and Open Space Diagram;
• Plan for acquiring new parkland designated in the General Plan, as shown in Figure POSS-1;
• Establish a standard protocol for working with new development to arrange for parkland acquisition and dedication;
• Establish a protocol for working with established neighborhoods to provide needed parks, including the fostering of neighborhood and district associations to help plan, acquire, improve and care for public parks, and coordinating new City service facilities to provide new open space;
• Establish detailed design, construction, and maintenance standards; • Prepare an assessment of the recreation needs of existing and future residents; • Create an action plan defining priorities, timeframes, and responsibilities; • Adopt and implement a comprehensive financing strategy for land acquisition, park development, operations, and maintenance;
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-10
• Identify opportunities for using existing or planned park space as passive stormwater storage, treatment, and conservation areas that also provide scenic and/or recreational opportunities;
• Identify opportunities for siting and using existing or planned park space as passive “purple pipe” waste water storage, treatment, and conservation areas that also provide scenic and/or recreational opportunities; and
• Update the Parks Master Plan.
POSS-1-c: P
ublic Input in Park Planning. Continue to provide opportunities for public participation in the planning and development of park facilities and in creation of social, cultural, and recreational activities in the community.
POSS-1-d: Add
itional Parkland in Certain Areas. Strive to obtain additional parkland of sufficient size to adequately serve underserved neighborhood areas and along BRT corridors in support of new and intense residential and mixed use infill development. • Identi
fy, where appropriate, joint use opportunities in siting parks with other City service facility needs.
POSS-1-e: Cri
teria for Parks in Development Areas. Continue to use park size and service area criteria for siting new parks and planning for parks in Development Areas:
Park Type Size Range (Acreage) Population Served Service Area Radius Neighborhood 2.01 to 10 10,000–15,000 Up to 1 mile
Community 10.01 to 40 50,000–80,000 Up to 4 miles
Regional More than 401 100,000 100,000 residents
1 Or when amenities provide regional service.
POSS-1-f: Parks and Open Space Diagram. Require parks to be sited and sized as shown on the Parks and Open Space Diagram (Figure POSS-1) of the General Plan, subject to the following:
• All n
ew park designations carry dual land use designations, so that if a park is not needed, private development consistent with zoning and development standards may be approved. (See Figure LU-2: Dual Designation Diagram in the Urban Form, Land Use, and Design Element);
• Revised and/or additional park sites will be identified through subsequent implementation and planning in established neighborhoods and Development Areas; • Locations for future park sites as shown on Figure POSS-1 are schematic to the extent that park sites may be relocated as necessity and opportunity dictate, and a General Plan amendment is not required if the park continues to serve the target areas as determined by the Planning Director; and
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-11
• A park may be located on any suitable land in the general vicinity of the sites depicted.
However, the zoning of potential park sites must be made consistent with the General Plan.
Objective POSS‐2. Ensure that adequate land, in appropriate locations, is designated and acquired for park and recreation uses in infill and growth areas.
POSS-2-b: Park and Recreation Priorities. Use the following priorities and guidelines in acquiring and developing parks and recreation facilities:
• Acqu
ire and develop neighborhood park space in existing developed neighborhoods that are deficient of such space and in areas along BRT corridors that are designated as priorities for encouraging new mixed-use transit-oriented development; • Provide accessible recreation facilities in established neighborhoods with emphasis on those neighborhoods currently underserved by recreation facilities; • Improve established neighborhood parks with emphasis on those neighborhoods with the greatest need;
• Acquire and develop neighborhood and community parks in new Development Areas; • Recognize community parks as a special need in areas that lack these facilities or are planned for transit supportive urban densities, and explore all potential sources of revenue to secure and develop appropriate sites including joint use facilities; • Develop new special purpose parks, such as outdoor gym equipment, natural resource based trail parks, equestrian centers, dog parks, and amphitheaters, as well as alternative recreation facilities, such as community recreation centers, passive wildlife observation park, cultural heritage and diversity park, military veterans memorial park, and universal access open space park; and
• Acquire and develop park and open space in established neighborhoods and Development Areas, prioritizing existing neighborhoods with the greatest deficiencies, so that all residents have access to park or open space within one-half mile of their residence. Develop these facilities to be fully accessible to individuals with disabilities as required by law.
POSS-2-c: Rev
iew of Development Applications. Coordinate review of all development applications (i.e., site plans, conditional use permits, and subdivision maps) in order to implement the parks and open space standards of this Plan. • Assure
the provision of adequate active and passive open spaces and facilities as appropriate within residential subdivisions through Development Code requirements for mandatory dedication and improvement of land and/or development fees.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-12
• Require the provision of appropriate outdoor living areas or private open space in multi- family residential developments not subject to the Subdivision Map Act. • Request open space easements where feasible and warranted to secure appropriate public use of sensitive areas with scenic or recreation values, and for buffering space for sensitive areas.
• Require provision of appropriate open space areas in private projects, in the form of trails, enhanced landscaped setbacks, parks, and water features. • Evaluate the merits of establishing a development bonus entitlement program in which development incentives (i.e., bonus densities, bonus floor area square footage) are provided for contributions to public recreational facilities on-site or in the vicinity of the development project.
POSS-2-d: Cre
ation Opportunities near Freeway Corridors. Negotiate with Caltrans, other public agencies, and private property owners to develop remnant parcels along freeway corridors for appropriate recreational uses.
POSS-2-e: Op
en Space Dedication for Residential Development. Ensure new residential developments provide adequate land for parks, open space, landscaping, and trails through the dedication of land or otherwise providing for Pocket Parks, planned trails, and other recreational space, maintained by an HOA, CFD, or other such entity.
Obje
ctive POSS‐3. Ensure that park and recreational facilities make the most efficient use of land; that they are designed and managed to provide for the entire Fresno community; and that they represent positive examples of design and energy conservation.
POSS-3-a: Cent
ralized Park Locations. Site parks central and accessible to the population served, while preserving the integrity of the surrounding neighborhood.
POSS-3-b: Park
Location and Walking Distance. Park Location and Walking Distance. Site Pocket and Neighborhood Parks within a half-mile walking distance of new residential development.
POSS-3-c: L
ink Parks with Walkways. Link public open space to adjacent, schools, and residential uses and Activity Centers through a series of landscaped linear walkways and bikeways that enhance and encourage pedestrian use.
POSS-3-e: Min
imum Park Size for Active Recreation. Minimize City acquisition or acceptance of dedication of park sites less than two acres in size for active recreational uses, except where maintenance costs are secured through a CFD, HOA, or other such mechanism.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-13
POSS-3-f: Park Design Guidelines. Park Design Guidelines. Create, maintain, and apply park des
ign guidelines, with provisions for appropriate amenities for each park type, which may include:
• Mini
mum and maximum shade.
• Protections from shading by adjacent buildings.
• Accessibility to persons with disabilities.
• Street trees and landscaped median strips in adjacent arterial roads. • Art and points of attraction.
• Landscape and hardscape features.
• Street furniture, signage, and lighting.
• Food sales and entertainment.
• Restroom facilities, play structures, and picnic shelters. • Landscape design synthesis with input from civil engineers and hydrologists, educators and daycare providers, fitness trainers and coaches, police officers and experts in crime prevention through environmental design, as appropriate. • Solar panels, new LED lighting, and water efficiency improvements. Sports field areas designed to allow periodic changes in field locations to minimize wear areas and provide sufficient fields to host regional, state, or national tournaments. • Using topography to create interesting and visually appealing spaces and forms. • Use of waterways as a key design influence, a focus of restoration, and an opportunity to provide for public enjoyment of views.
• Reflecting the agricultural and horticultural heritage of the site or area. • Connecting with surrounding areas in a way that encourages expanded pedestrian activity.
• Creating individual places within a park that respond to the needs of a broad range of park users, from youth to the elderly.
• Creating places of delight that engage the senses.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-14
• Creating places that engage the mind, by treating park features as opportunities for interpretation and questioning.
• Using sustainable design practices, and highlighting these as opportunities for learning.
POSS-3-g: P
ark Security and Design. Park Security and Design. Promote safety, attractiveness, and compatibility between parks and adjacent residential areas through design, maintenance, and enforcement of park regulations • Requi
re the installation of security lighting for parking, points of access, and building areas at all public recreation and park sites.
• Keep neighborhood eyes on parks to increase security.
POSS-3-h: Coo
rdination with School Districts. Continue to coordinate with school districts to explore opportunities for joint use of both outdoor and indoor recreation facilities, such as playgrounds, play fields, and gymnasiums, for City recreation programs.
POSS-3-i: Jo
int Use with Drainage Facilities. Continue to seek joint use agreements for use of FMFCD stormwater drainage facilities.
Objective POSS‐4. Pursue sufficient and dedicated funding for parks acquisition, operations, and maintenance.
POSS-4-a: Supplemental Revenue. Seek revenue sources to supplement General Fund supp
ort for basic park maintenance and basic recreational services.
POSS-4-b: O
peration and Maintenance Financing. Continue to require new residential development to form lighting and landscaping maintenance districts or community facility districts or ensure other means of financing to pay for park operations and maintenance.
POSS-4-c: Im
provements in Established Neighborhoods. Seek agreements with formal neighborhood associations and institutions for improvements and ongoing maintenance of parks in established neighborhoods.
Fresno P
arks Master Plan. The Fresno Parks Master Plan was created as a means to describe the vision for improving Fresno’s park and open space system based on robust community engagement and thorough analysis. The planning process began with a detailed needs assessment conducted by consultants, City of Fresno staff, residents, and stakeholders, to evaluate Fresno’s individual parks and the park system as a whole. This included examining the City’s General Plan parkland acreage goals, population growth, and demographic information as part of a comprehensive level of service evaluation. Mapping and analysis of existing parks and their service areas revealed how well or inadequately each neighborhood is currently served by parks and recreation amenities. Recreational programs were also evaluated. In 2024, a Technical Amendment of the Fresno Parks Master Plan provided a strategic reframing given the influx of funds from Measure P, which provides a guaranteed, local funding source for parks through a 3/8-cent sales tax in the City of Fresno.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-15
City of Fresno Municipal Code. The following impact fees apply to parks and recreational services in Fresno:
• Park Facilities Fee: Section 12-4.701 of the Fresno Municipal Code states: In order to implement the Goals, objectives and policies of the City’s General Plan, and to mitigate the impacts caused by future development in the city, certain park facilities must be constructed. The City Council has determined that a Park Facilities Fee is needed in order to pay for (a) land acquisition for, and design, engineering, and construction of the public facilities designated in the Council resolution and reasonable costs of outside consultant studies related thereto; (b) to reimburse the city for designated public facilities construction by the city with funds (other than gifts or grants) from other sources together with accrued interest; (c) to reimburse developers who have designed and constructed designated public facilities which are oversized and supplemental size, length, or capacity; and/or (d) to pay for and/or reimburse costs of program development and ongoing administration of the Park Facilities Fee program. Table 4.6.D below describes the Park Facilities Fees under different fee programs by type of development, as established in the City’s Master Fee Schedule.
Table 4.6.D: Park Facilities Fee Program
Type Park Facility
Impact Fee
Quimby Parkland
Dedication Fee
Single-Family Residential/per unit $3,590.26 $1,552.49
Multi-Family Residential/per unit (>7.5
units/acre) $2,706.28 $1,171.92
Source: City of Fresno Master Fee Schedule, Effective July 2024 (City of Fresno 2024).
• Street Facilities Fees: Section 12-4.1001 of the Fresno Municipal Code states: In order to implement the goals and objectives of the City’s General Plan, and to mitigate the impacts caused by future development in the City, certain street facilities must be constructed. The City Council has determined that street facilities fees are needed in order to finance these public facilities and to pay for each development’s fair share of the construction and acquisition costs of these improvements. Based on this determination, Council adopted, by resolution amending the Master Fee Schedule, a Citywide Regional Street Impact Fee (“Citywide Street Fee”) and a New Growth Area Major Street Fee (“Growth Area Street Fee”). Council adopts this Article to require the imposition of these street facilities fees on new development in the City.
4.6.4 Significance Criteria
The thresholds for impacts to recreation facilities 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 related to recreation if it would:
• Result in substantial adverse physical impacts associated with the provision of new or physically altered parks or recreation facilities, or the need for new or physically altered parks or recreation facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives; LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-16
• 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; or • Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
4.6.5 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to parks and recreation that could result from implementation of the Specific Plan Update. 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 draft Specific Plan 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-signif
icant level.
Cumulative impacts are also addressed.
4.6.5.1 P
roject Impacts
The following discussion describes the potential impacts related to recreation that could result from implementation of the Specific Plan Update.
REC‐1 The
proposed project would result in substantial adverse physical impacts associated with the provision of new or physically altered parks or recreation facilities, or the need for new or physically altered parks or recreation facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives.
The Fresn
o Parks Master Plan, adopted in December 2024, identified a level of service (LOS) goal for pocket, neighborhood and community parks of 3.0 acres of parks per 1,000 residents. For regional, open space/natural areas, and special use parks, a LOS goal of 2.0 acres of parks per 1,000 residents was identified. According to the 2023 Fresno Multi-jurisdictional 2023–2031 Housing Element, the City of Fresno’s average household size was 3.0 persons per household. The Tower District is among the more densely populated areas of Fresno, with many blocks exceeding 9,000 people per square mile. As of the 2020 U.S. Census, there are approximately 7,336 residential units within the Specific Plan Area, and a total population of 20,200, based on the census track block groups whose population is all or mainly in the Specific Plan Area.
6, 7 The Specific Plan Area has approximately
6.7 acres of existing useable parks, which equates to a park ratio of 0.33 acre per 1,000 residents.
Implementation of the Specific Plan Update would result in approximately 537 more projected residential units than previously projected under existing planned land uses, for a total of 2,807 new residential uses by the build out of the proposed project. Using the City average of 3.0 persons per household, this would increase the existing population within the Specific Plan Area by approximately 8,621 residents for a total of 30,429 residents within the Specific Plan Area under full
6 City of Fresno. 2025. Draft Tower District Specific Plan Update. 7 U.S. Census Bureau. 2020. Existing Land Uses.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-17
build out by the horizon year of 2046.8 The additional residential growth would result in an increase in demand for parks and recreation facilities. Based on the General Plan standard of 3.0 acres of public parkland per 1,000 residents, the proposed project would require the dedication of approximately 91.3 acres9 of useable parkland to meet the standard. With the 6.7 acres of existing useable parkland, this would require a total of approximately 84.6 acres of new parkland.
The development of new parks or the expansion of existing parks that would be required as a result of the implementation of the Specific Plan Update could result in significant adverse environmental impacts. Additionally, impacts likely to be associated with the construction and operation of new or expanded park facilities would be air quality/greenhouse gas emissions, noise, traffic, and lighting.
Future development facilitated by the Specific Plan Update would be required to comply with City of Fresno General Plan objectives and policies related to parks, as stated in Section 4.7.3.2, Local Regulations, and with Sections 12.4-509, Urban Growth Management Park Fees, and 12.4-701, Park Facilities Fee, in the City of Fresno Municipal Code. The General Plan Objective POSS-1 and Policies POSS-1-a through POSS-1-f and Objective POSS-2, Policies POSS-2-b, through POSS-2-d, Objective POSS-3, Policies POSS-3-a through POSS-3-c and POSS-3-e through POSS-3-i, and Policies POSS-4-a through POSS-4-c are relevant to the provision of parkland in the Specific Plan Area. Additionally, future development would be required to comply with Policy POSS-2-e, which ensures that new residential developments provide adequate land for parks and open space, along with other recreational space.
Additional parks and open space could be developed or planned as the Specific Plan Update is being implemented in order to meet the citywide standard. Furthermore, the Specific Plan Update includes the following objectives and policies, shown in Table 4.6.E, related to parks and public facilities that would not conflict with adopted City policies and support the development of new recreational facilities within the Specific Plan Area.
Future development facilitated by the Specific Plan Update would be required to comply with Sections 12-4.701 through 12-4.706 and Section 12-4.1001 of the Fresno Municipal Code, which requires each development to pay a Park Facilities Fee and Street Facilities Fee in order to mitigate the impacts on park facilities caused by future development in the City, and to finance public facilities and to pay for each development’s fair share of the construction and acquisition costs of these improvements. Payment of the appropriate development impact fees would offset the construction and acquisition costs of required park and public facility improvements.
8 (20,200 existing residents + 8,621 new residents) = 30,429 total residents 9 ( 30,429 total residents*3 acres/1,000 residents) = 91.3 acres LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-18
Table 4.6.E: Tower District Specific Plan Update – Parks & Public Facilities Objectives and Policies
Policy Description
Objective POS 1: Increase and Enhance Public Open Space Areas and Amenities in the Tower District.
Policy POS 1.1: Provide parks in
accordance with the Parks Master Plan.
Pursue opportunities for new parks and public spaces in the Tower District according to the policies and the standards adopted in the Parks Master Plan. Give priority to improvements in park-deficient areas, consistent with the Measure P implementation process.
Policy POS 1.2: New park acquisition. Strategically pursue land for the acquisition and establishment of new parks in alignment with the Parks Master Plan. Two new parks have been developed or are near completion: Broadway Parque and Trolley Park. These projects will be valuable additions for Tower District residents. Future opportunities that should be explored include:
• A public plaza in the central core near the Tower Theatre. • Mini parks and community gardens on vacant land, City-owned land, and unneeded portions of school properties. Explore opportunities in Van Ness Village, adjacent to the Fire Station at Clinton and Arthur and at the corner of Clinton and Palm, at the northeast corner of the Hamilton School site.
• Privately-owned public spaces created as part of new development on large sites, which might be required of larger development projects like Blackstone Avenue corridor.
Policy POS 1.3: Work in partnership
with public agencies and the
community to enhance existing parks,
and other types of open space, for
greater recreational value.
• Ted C. Wills. Advocate for a park master planning process and redesign that could make better use of the space and provide more amenities.
Reuse of the parking lot and the school campus should be considered. • Roeding Park. Advocate for a park master planning process and redesign that could make this park a more valuable asset for the City as a whole.
Policy POS 1.4: Measure P funding. Leverage Measure P funding for acquisition and development of new parks and improvements to existing parks.
Policy POS 1.5: Pursue joint-use
partnerships with schools in the Tower
District.
New joint-use partnerships should be designed to improve the capability of utilizing the District’s open space for passive and active recreational and leisure opportunities by adding landscaping, lighting, picnic facilities, and other appropriate amenities, and by extending hours of use. Consider parking needs of the community when entering into joint use agreements.
Joint-use agreements should not diminish the need to create new parks in the Tower District.
Policy POS 1.6: Clean up Dry Creek. Develop and implement a clean-up action program for Dry Creek that engages neighboring residents and businesses.
Policy POS 1.7: Greenway and parks
along Dry Creek.
Initiate a dialogue between the City of Fresno, the Fresno Irrigation District, and residents to reach agreements around opportunities for access and visibility along Dry Creek. Study the feasibility of increasing public access to Dry Creek. Seek to acquire vacant or key parcels along Dry Creek to act as greenway nodes, enhancing the corridor and providing more access. Include further planting of trees and vegetation along the Dry Creek Canal in addition to trash cans, pet pick up stations, and public benches to ensure ADA compliance is met.
Policy POS 1.8: Transportation impact
mitigation and funding.
Work with Caltrans, UP, and BSNF to ensure that rights-of-way adjacent to major transportation facilities are landscaped to help protect the neighborhood from visual, air quality, and noise impacts from freeways and rail corridor. Seek Federal and State funding to provide transportation mitigation and environmental enhancement along major transportation facilities (i.e., Highway 180, High Speed Rail).
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-19
Table 4.6.E: Tower District Specific Plan Update – Parks & Public Facilities Objectives and Policies
Policy Description
Objective POS 2: Improve Access to Parks for Tower District Residents Policy POS 2.1: Remove barriers to
access parks.
Ensure that parks in the Tower District are designed and managed in a way that maintains access and a sense of welcome from the street. Specifically, minimize the use of fences and gates along the street edges of parks, and address safety by improving lighting and visual sight lines.
Policy POS 2.2: Pedestrian and bike
overcrossings.
Advocate for high-quality pedestrian and bike access to Roeding Park at Olive Avenue rail corridor overcrossing at the District’s western edge.
Objective POS 3: Recognize that Streets Serve as Public Open Space and provide for Their Improvement in Tower District.
Policy POS 3.1: Sidewalks as public
space.
Plant trees and make other streetscape improvements to enhance pedestrian environments, particularly along the Tower District’s commercial corridors. See also Circulation policies. Refer to the City’s Urban Forestry Management Plan for a list of approved street trees.
Objective POS 4: Align Public Facilities and Services with Community Needs to Support Quality of Life in the Tower District
Policy POS 4.1: Tower Public Library. Work with Fresno County to bring a library back to the Tower District, by relocating an existing branch or creating a new branch. Support this effort through actions that may include, but are not limited to, zoning to allow for a library and allowing for the joint use of City-owned facilities. Enhance the quality of Gillis Library Branch, which currently serves the District.
Policy POS 4.2: Public safety patrols.
Recommend maintaining consistent police presence through a combination of Patrol Officers, Bicycle Patrol Officers, Traffic Officers, and Contract Law Enforcement Services as community based safety options. Explore a stand- alone budget to additionally support entertainment district peak hours and special events. Community based options could include potential partnerships with neighborhood watch and ambassador programs.
Policy POS 4.3: Safe and welcoming
public open space.
Design and program parks, plazas, and other public open space to be welcoming to all users. Strategies to employ include: space activation using design features and programmed activities, adequate lighting, uninterrupted lines of sight from streets into the space, absence of subareas that can be readily appropriated for unwanted activities, and on-going high-quality repair and maintenance.
The population increase projected under the proposed project is within the population growth contemplated by the General Plan and the 2023–2031 Housing Element. However, the Specific Plan Update does not implement the creation of new parks or recreation facilities, and there are approximately 84.6 acres less than the total parkland acreage needed to meet the citywide parks and open space standard of 3.0 acres per 1,000 residents. Therefore, potential impacts related to the provision of parks and recreation services could be significant.
Level of Significance Without Mitigation: Potentially Significant Impact Impact REC-1: The proposed project could result in substantial adverse physical impacts associated with the provision of new or physically altered park and recreational facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-20
Mitigation Measure REC-1a As new development occurs in the Specific Plan Area, the City of Fresno (City) shall periodically (every 5 years) monitor residential population growth compared to development of new parklands for the purpose of evaluating the strength of the Tower District Specific Plan Update to meet the ratio of 3.0 acres of parkland per 1,000 population. If the ratio is not met, the City shall explore additional ways to increase the amount of dedicated parkland in the Specific Plan Area, including but not limited to designating additional lands for parkland development.
Mitigation Measure REC-1b As future parks and recreational facilities are planned, the City shall evaluate if specific environmental effects would occur. Typical impacts from construction and operation of parks and recreational facilities include air quality/greenhouse gas emissions, noise, traffic, and lighting. Typical mitigation to reduce potential impacts includes:
• Air Quality/Greenhouse Gas Emissions: Install solar panels, zero- emission backup electricity generators, and energy storage to minimize emissions associated with electricity.
• Noise: Barriers and setbacks placed on parks and recreational facilities.
• Traffic: Traffic devices for circulation.
• Lighting: Provision of hoods and deflectors on lighting fixtures for stadium lights.
Level of Significance With Mitigation: Significant and Unavoidable Impact Mitigation Measures REC-1a and REC-1b would reduce potential impacts resulting from implementation of the Specific Plan Update on parks and public facilities; however, because the existing amount of parkland and recreational facilities within the Specific Plan Area does not meet City standards, and no construction of new park facilities is planned through the implementation of the Specific Plan Update, this potential impact would be considered significant and unavoidable.
REC‐2 The
proposed project would increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of a facility would occur or be accelerated.
Refer
to impact discussion REC-1, above. Implementation of the Specific Plan Update would result in a population increase of approximately 8,621 residents for a total of 30,429 residents within the Specific Plan Area10 by full build out in horizon year 2046. The additional residential growth would
10 (20,200 existing residents + 7,729 new residents) = 27,929 total residents LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-21
result in an increase in demand for parks and recreation facilities. Based on the City’s General Plan and Parks Master Plan standard of 3.0 acres of public parkland per 1,000 residents, the proposed project would require the dedication of approximately 91.311 of useable parkland to meet the standard. While the Specific Plan Update introduces park opportunity areas for future study, as well as objectives and policies to guide the development of future park and recreation facilities, no new parks are actively proposed to be constructed or expanded under the Specific Plan Update. Existing parks within the Specific Plan Area would see an increase in use by the proposed population increase, which could accelerate and substantially deteriorate the existing facilities. Future individual development projects facilitated by the Specific Plan Update would be required to comply with the Park Facilities Impact Fee, which would allow new parks to be constructed at appropriate sites within the Specific Plan Area. However, impacts could be significant, as the proposed project would result in 84.6 acres less than the total parkland acreage needed to meet the citywide parks and open space standard of 3.0 acres per 1,000 residents.
Level of Significance Without Mitigation: Potentially Significant Impact Impact REC-2: Implementation of the Specific Plan Update would facilitate increased population which could 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.
Mitigation Measures: Refer to Mitigation Measure REC-1a, above.
Level of Significance With Mitigation: Significant and Unavoidable Impact Implementation of Mitigation Measure REC-1a would reduce potential impacts resulting from implementation of the Specific Plan Update on parks and public facilities; however, because the existing amount of parkland and recreational facilities within the Specific Plan Area does not meet City standards, and no construction of new park facilities is planned through the implementation of the Specific Plan Update, this potential impact would be considered significant and unavoidable.
REC‐3 The
proposed project does not include recreational facilities and would require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
Refer
to impact discussion REC-1, above. The development of new parks or the expansion of existing parks that would be required as a result of the implementation of the Specific Plan Update could result in significant adverse environmental impacts. The construction and operation of new or expanded parks facilities could result in significant adverse environmental impacts such as air quality, greenhouse gas emissions, noise, traffic, and lighting. Impacts resulting from the construction or expansion of parks would be offset by the City’s Parks Facilities Fee, which requires that new development in the Specific Plan Area pay a fair -sha
re-fee
to aid in the cost of the
construction or the expansion of public parks. The General Plan includes Objective POSS-1 and
Policies POSS- 1-a thr
ough POSS-1-f an
d Objective POSS-2, P
olicies POSS-2-b, t
hrough POSS-2-d,
11 (27,929 total residents*3 acres/1,000 residents) = 83.79 acres LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-22
Objective POSS-3, Policies POSS-3-a thr ough POSS-3-c thro ugh POSS-3-I, a nd Policies POSS-4-a thr
ough POSS-4-c, which
would be relevant to the provision of parkland in the Specific Plan Area.
Level
of Significance Without Mitigation: Potentially Significant Impact Impact PSR-3: Implementation of the Specific Plan Update could require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment.
Mitigation Measures: Refer to Mitigation Measure REC-1b, above.
Level of Significance With Mitigation: Less Than Significant Impact Compliance with Mitigation Measure REC-1b would reduce potential construction impacts resulting from implementation of the Specific Plan Update, which would reduce potential impact to a less than significant level.
4.6.5.2 Cumulative Impacts
REC‐4 The
proposed project, in combination with past, present, and reasonably foreseeable projects, would result in potentially significant cumulative impacts with respect to recreation.
As state
d above, implementation of the Specific Plan Update is projected to generate an increase in the population of approximately 8,621 residents, as compared to land uses allowed under existing conditions, requiring the dedication of approximately 91.3 acres of useable parkland. Useable parkland refers to pocket, neighborhood, and community parks. The Specific Plan Area currently has approximately 8.2 acres of parkland, of which 6.7 acres is usable. The City of Fresno Sphere of Influence (the cumulative setting for impacts to park facilities) has 632 acres of parks. The Fresno Parks Master Plan identified 1,751 acres to meet recreation needs of Fresno’s future population (General Plan Horizon Year 2035), whereas the General Plan identified the need for nearly 2,313 acres of new pocket, neighborhood, and community parks by the General Plan Horizon year of 2035 in the Fresno Sphere of Influence.
12 Although neither the Specific Plan Area nor the cumulative setting would meet the 3.0 acre per 1,000 residents ratio parkland standard, implementation of the objectives and policies proposed in the Specific Plan Update would encourage future development of additional park area.
Future development facilitated by the Specific Plan Update would require additional CEQA documentation to determine future impacts to parks and recreational facilities. Individual development projects would be required to comply with the Park Facilities and Street Facilities Impact Fees, which would allow new parks and public facilities to be constructed at appropriate sites within the cumulative setting and be adequately maintained. While the Specific Plan Update introduces park opportunity areas for future study, as well as objectives and policies to guide the development of future park and recreation facilities, no new parks are actively proposed to be
12 City of Fresno. 2014. Fresno General Plan, Chapter 5 Parks, Open Space and Schools, Table 5-5: Total Existing And Future Park Needs Scenarios.
LSA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
(08/14/25) 4.6-23
constructed or expanded under the Specific Plan Update. Therefore, cumulative impacts could be significant, as the Specific Plan Update would result in 84.6 acres less than the total parkland acreage needed to meet the citywide parks and open space standard of 3.0 acres per 1,000 residents.
The objectives and policies proposed under the Specific Plan Update would seek to improve existing park facilities and develop new park and recreation facilities within the Specific Plan Area. Policy POS
1.1 seeks to pursue opportunities for new parks and public spaces in the Specific Plan Area according to the policies and standards adopted in the Fresno Parks Master Plan and give priority to improvements in park-deficient areas, consistent with the Measure P implementation process.
Policy POS 1.2 aims to strategically pursue land for the acquisition and establishment of new parks.
Policy POS 1.3 aims to encourage partnership with public agencies and the community to enhance existing open spaces for greater recreational value. Development facilitated through implementation of the Specific Plan Update would also be required to comply with Fresno Municipal Code Sections 12-4.701 through 12-4.706, which require payment of park facilities fees to finance park facility improvements.
Level of Significance Without Mitigation: Potentially Significant Impact Impact REC-4: Implementation of the Specific Plan Update, in combination with past, present, and reasonably foreseeable projects, could result in potentially significant cumulative impacts with respect to recreation.
Mitigation Measures: Refer to Mitigation Measures REC-1a and REC-1b.
Level of Significance With Mitigation: Significant and Unavoidable Impact Mitigation Measures REC-1a and REC-1b would reduce potential impacts resulting from implementation of the Specific Plan Update on parks and public facilities; however, because the existing amount of parkland and recreational facilities within the Specific Plan Area does not meet City standards, and no construction of new park facilities is planned through the implementation of the Specific Plan Update, this impact would be considered cumulatively significant and unavoidable.
LSA
T OWER D ISTRICT S PECIFIC P LAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC R EVIEW D RAFT E NVIRONMENTAL I MPACT R EPORT
A UGUST 2025
(08/14/25) 4.6-24
This page intentionally left blank
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
5-1
5.0 CEQA-REQUIRED ASSESSMENT CONCLUSIONS
As required by CEQA, this chapter discusses the following types of impacts that could result from implementation of the Tower District Specific Plan Update (proposed project or Specific Plan Update) for the City of Fresno (City): growth-inducing impacts; significant irreversible changes; effects found not to be significant; and significant unavoidable effects.
5.1 GROWTH INDUCEMENT
This section summarizes the proposed project’s potential growth-inducing impacts on the surrounding community. A project is considered growth-inducing if it would directly or indirectly foster substantial economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding environment. Examples of projects likely to have significant growth-inducing impacts include extensions or expansions of infrastructure systems beyond what is needed to serve project-specific demand, and development of new residential subdivisions or industrial parks in areas that are only sparsely developed or are underdeveloped. Typically, development projects on sites that are designated for development and surrounded by existing suburban uses are not considered adversely growth-inducing because growth in areas that already have development and infrastructure available to serve new development are generally considered environmentally beneficial.
Section 15126.2(e) of the State CEQA Guidelines requires that an EIR evaluate the growth inducing impacts of a proposed action:
Discuss the way in which a proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.
Included in this are projects that would remove obstacles to population growth (a major expansion of a wastewater treatment plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also, discuss the characteristics of some projects, which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
There are two types of growth inducing impacts, direct and indirect. To assess the potential for growth inducing impacts, the project characteristics that may encourage and facilitate activities that may individually or cumulatively affect the environment must be evaluated. Growth‐inducing impacts can occur when the development of a project imposes new burdens on a community by directly inducing population growth, or by leading to the construction of additional developments in the same area of the proposed project. Also included in this category are projects that would remove physical obstacles to population growth (such as a new road into an undeveloped area or a wastewater treatment plant with excess capacity that could allow additional new development in the service area). Construction of these types of infrastructure projects cannot be considered isolated from the development they facilitate and serve. Projects that physically remove obstacles to LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
5-2
growth or projects that indirectly induce growth are those that may provide a catalyst for future unrelated development in the area (such as a new residential community that requires additional commercial uses to support residents).
Based on the information provided in State CEQA Guidelines Section 15126.2(e) quoted above, two specific issues must be addressed when determining the growth‐inducing impacts of a project:
• Elimination of Obstacles to Population Growth. The extent to which additional infrastructure capacity (such as extension of roads, sewer, water infrastructure etc.) or change in regulatory structure (such as a change in policies) will allow additional development; and • Economic Growth. The extent to which a proposed project could result in increased activity in the local economy or the regional economy.
Each of the growth‐inducing impacts above are discussed in more detail below.
5.1.1 Elimination of Obstacles to Population Growth
Eliminating physical or regulatory obstacles to growth can result in a growth‐inducting impact because those obstacles are removed. An example of a physical obstacle to growth is the need for public service infrastructure (such as roadways, water mains, sewer lines etc.). Extending public service infrastructure into an area that lacks infrastructure would induce population growth because the infrastructure needed to serve the area would be available, and therefore, the area would then have the capacity to allow population growth. Also, the addition, deletion or alteration of a regulatory obstacle (such as a growth or development policy) could result in new growth because the regulatory obstacle would be altered such that new growth would subsequently not be hindered.
As described in Chapter 3.0, Project Description, the implementation of the Specific Plan Update would result in approximately 537 more projected residential units than previously projected under existing planned land uses, for a total of 2,807 new residential uses by the build out of the proposed project. Given the nature of the proposed project, the implementation of the Specific Plan Update would not significantly increase the demands for public services (i.e., fire and police protection, schools, and libraries) or utility and service systems (i.e., water, wastewater, stormwater, and solid waste). As described in Section 4.6, Recreation, there would be a significant unavoidable impact to recreation. Overall, the proposed project would not establish an essential public service that could remove an impediment to growth.
The intent of the proposed project is to provide strategic and comprehensive guidance for making decisions regarding the Tower District’s built environment and landscape character, land use and activities, public open space, community facilities, transportation, and other forms of infrastructure within the Specific Plan Area. Additionally, as discussed in the Initial Study (Appendix C), implementation of the proposed Specific Plan Update would not exceed the City’s projection for future growth and would be consistent with the General Plan and Housing Element goals to provide additional residential units to support the growing population within the city and county.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
5-3
The Specific Plan Update includes the following objectives and policies that encourage population growth:
Objective LU 2 Retain and expand the existing inventory of affordable housing in the Tower District and discourage displacement of its residents.
Policy LU 2.1 Promote mixed-use development along commercial corridors.
Policy LU 2.2 Enable development of well-designed “missing middle” housing within single-family and other areas.
Policy LU 2.3 Discourage the redevelopment of existing residential uses for commercial-only development.
Policy LU 2.5 Encourage the application of citywide anti-displacement policies within the Tower District.
Policy LU 2.6 To be consistent with existing use, consider rezoning of existing legal non- conforming multi-family residential uses to the density-appropriate zoning district.
Objective LU 3 Encourage appropriate mixed-use and multifamily development by reducing obstacles to feasibility of potential development projects.
Policy LU 3.2 Consider regulatory changes to reduce costs and risks associated with mixed-use and multifamily development, such as to reduce parking requirements where justified by TDM measures (see Chapter 6) and anticipated parking demand, and provide greater flexibility in addressing private open space requirements.
Policy LU 3.3 Consider ways to increase potential residential yields, such as by increasing allowable densities and building heights as appropriate.
Policy LU 3.5 Actively increase the affordable housing inventory in Tower District.
Policy LU 3.6 Proactively identify underutilized parcels for affordable housing and mixed-use development where appropriate.
5.1.2 Promotion of Economic Growth
The promotion of economic growth is the extent to which a proposed project could cause increased activity in the local or regional economy. A “multiplier effect” is an economic phrase which pertains to the interrelationships between various sectors of the economy. The multiplier effect is a quantitative description and can be described as how an increase in some economic activity starts a chain reaction that generates more activity than the original increase.
The proposed land use patterns and policies that would be implemented as part of the Specific Plan Update are designed in part to promote commercial activity, maintain compatibility with industrial LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
5-4
employment and improve overall economic development and plan for future growth opportunities.
The Specific Plan Update includes the following objectives and policies that encourage economic growth:
Objective LU 4 Maintain and enhance existing and promote new neighborhood-serving pedestrian-oriented retail service and businesses within the Tower District, which is consistent with historic patterns of development. Make commercial areas safe, convenient, and welcoming focal points for neighborhood activities and public life.
Policy LU 4.1 Support small commercial businesses.
Objective LU 5 Balance neighborhood serving commercial needs and quality of life with the cultivation of a successful cultural and entertainment district.
Policy LU 5.4 Permanently implement the Sidewalk Vendors Pilot Program in the Tower District, with adjustments.
Policy LU 5.5 Support the Tower Marketing Committee or other Business Improvement District (BID) or Public Business Improvement District (PBID) to support on-going commercial area marketing, organization of festivals and other events, enhanced landscape maintenance and sidewalk cleaning, graffiti abatement, and other beneficial programs.
Objective LU 6 Ensure compatibility among light industrial and residential uses in the Tower District.
Policy LU 6.1 Maintain industrial zoning for existing industrial uses, while striving to mitigate their negative effects on residential areas.
Policy LU 6.2 Allow light industrial uses to have neighborhood-serving retail.
Objective LU 7 Recognize the unique strengths and address the needs of the Tower District’s subdistricts and corridors.
Policy LU 7.1 Reinforce Fulton Street and Van Ness Avenue as major corridors with commercial destinations that serve Tower District’s Central Area and adjacent neighborhoods.
5.2 SIGNIFICANT IRREVERSIBLE CHANGES
As mandated by the State CEQA Guidelines, an EIR must address any significant irreversible environmental change that would result from project implementation. According to Section 15126.2(d) of the State CEQA Guidelines, such a change would occur if one of the following scenarios is involved:
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
5-5
• The project would involve a large commitment of nonrenewable resources; • Irreversible damage would result from environmental accidents associated with the project; or • The proposed consumption of resources is not justified (e.g., the project would result in the wasteful use of energy).
The environmental effects of the proposed project are summarized in the Executive Summary and thoroughly discussed in Section 4.0, Evaluation of Environmental Impacts. Implementation of the project would require the long‐term commitment of natural resources and land, as discussed below.
Approval and implementation of the proposed project would provide a framework for future development and redevelopment within the Specific Plan Area. The proposed project includes land uses changes that would commit future generations to specific development within the Specific Plan Area. The proposed land use patterns and policies are designed to provide diverse housing types at various affordability levels, promote commercial activity, maintain compatibility with industrial employment, promote recreation and education, and improve overall economic development and plan for future growth opportunities while maintaining the character of the community. Because the Specific Plan Area is largely developed and is surrounded by other urban and built-up areas containing similar land use patterns, the proposed project would not commit future generations to land use patterns that are inconsistent with existing patterns both with the Specific Plan Area and the surrounding vicinity.
Approval and implementation of the proposed project would result in future development and redevelopment within the Specific Plan Area which would result in an irretrievable commitment of nonrenewable resources including energy consumption and construction related materials. This consumption would occur during each individual project’s construction phase and would continue throughout its operational lifetime. Future development would require a commitment of resources including building materials; fuel and operational materials/resources; and transportation of goods and people to and from individual project sites. Construction would require the consumption of resources that are not renewable, or which may renew so slowly as to be considered non- renewable. These resources include, but are not limited to, lumber and other forest products; aggregate materials used in concrete and asphalt; metals; and water. Fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment.
Development implemented from approval of the proposed project would consume resources similar to those currently consumed within Fresno (e.g., energy resources such as electricity and natural gas, petroleum-based fuels required for vehicle trips, fossil fuels, and water). Fossil fuels would represent the primary energy source associated with construction activities, and the existing, finite supplies of these natural resources would be incrementally reduced. As stated, given the nature of the improvements, operational activities requiring the substantial consumption of natural resources are not anticipated and would be analyzed at the project level. Nonetheless, the proposed project’s energy requirements under both construction and operations represent a long-term commitment of essentially non-renewable resources. Energy related impacts were discussed in the Initial Study for the proposed project, which is included as Appendix C of this EIR, and were found to be less than significant.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
5-6
Additionally, Section 4.4, Greenhouse Gas Emissions, of this EIR, analyzed GHG related impacts that would result from implementation of the proposed project. GHG related impacts were found to be less than significant with mitigation incorporated. The analysis utilized the California Emissions Estimator Model version 2022.1 (CalEEMod) to quantify impacts that would result from the implementation of the proposed project. Further, the proposed project includes objectives and policies aimed at reducing the consumption of non-renewable energy sources and promoting sustainable development.
Future construction activities associated with implementation of the proposed project could release hazardous materials into the environment through reasonably foreseeable upset and accident conditions; refer to Section IX, Hazards and Hazardous Materials, of the Initial Study (Appendix C).
All potential demolition, grading, and excavation activities would be subject to the established regulatory framework to ensure that hazardous materials are not released into the environment.
Compliance with the established regulatory framework would protect against a significant and irreversible environmental change resulting from the accidental release of hazardous materials.
Implementation of the Specific Plan Update would facilitate development that could involve demolition and construction activities that carry the potential for environmental accidents.
However, construction and demolition related activities would be subject to oversight by all applicable City, State, and federal agencies. Additionally, industrial uses allowed under the proposed project, which are typically associated with an increased risk of environmental accidents, would be confined to a small portion in the southwest corner of the Specific Plan Area where light industrial uses are already present. Therefore, the proposed project would not result in a substantial risk of environmental accident.
5.3 SIGNIFICANT UNAVOIDABLE IMPACTS
The environmental effects of the proposed project, along with recommended mitigation measures, are summarized in the Executive Summary and discussed in detail in Section 4.0, Evaluation of Environmental Impacts. The following environmental issues discussed in the Draft EIR were determined to result in less-than-significant impacts, or can be reduced to less-than-significant levels with the incorporation of mitigation measures:
• Air Quality (with mitigation incorporated)
• Biological Resources (with mitigation incorporated)
• Cultural Resources (with mitigation incorporated)
• Greenhouse Gas Emissions (with mitigation incorporated) • Noise (with mitigation incorporated)
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
5-7
Section 15126.2(c) of the State CEQA Guidelines requires that an EIR describe any significant impacts, including those that can be mitigated but not reduced to less than significant levels, as a result of implementation of the project. The following environmental issues were determined to result in potential significant and unavoidable impacts, even after implementation of feasible mitigation.
• Recreation – the existing amount of parkland and recreational facilities within the Specific Plan Area does not meet city standards, and no construction of new park facilities is planned through the implementation of the Specific Plan.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
5-8
This page intentionally left blank
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-1
6.0 ALTERNATIVES
6.1 INTRODUCTION
Section 15126.6(a) of the California Environmental Quality Act (CEQA) Statue and Guidelines (State CEQA Guidelines), requires that an Environmental Impact Report (EIR) include a discussion of a reasonable range of project alternatives that would “feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any significant effects o the project, and evaluate the comparative merits of the alternatives.” CEQA does not require an EIR to consider every conceivable alternative to a project, but rather it must consider a range of feasible alternatives that would assist decision-makers and the public in evaluating the comparative merits of alternatives to a proposed project. Therefore, this chapter identifies potential alternatives to the proposed Tower District Specific Plan Update (proposed project) and evaluates them as required by CEQA.
Key provisions to the State CEQA Guidelines on alternatives (Section 15126.6[b] through [f]) are summarized below to explain the foundation and legal requirements of the alternatives analysis in the EIR:
• The discussion of alternatives shall focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the Project Objectives or would be more costly (15126.6[b]).
• The specific alternative of “no project” shall also be evaluated along with its impact (15126.6[e][1]). The “no project” analysis shall discuss the existing conditions at the time the Notice of Preparation is published and at the time the environmental analysis is commenced, as well as what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (15126.6[e][2]).
• The range of alternatives required in an EIR is governed by the “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision-making. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent) (15126.6[f]).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-2
• For alternative locations, only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR (15126.6[f][2][A]). • If the lead agency concludes that no feasible alternative locations exist, it must disclose the reasons for this conclusion and should include the reasons in the EIR. For example, in some cases there may be no feasible alternative locations for a geothermal plant or mining project, which must be in close proximity to natural resources at a given location (15126.6[f][2][B]). • An EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative (15126.6[f][3]).
6.2 PROPOSED PROJECT
6.2.1 Project Characteristics
The intent of the proposed project is to provide strategic and comprehensive guidance for making decisions regarding the Tower District’s built environment and landscape character, land use and activities, public open space, community facilities, transportation, and other forms of infrastructure within the Specific Plan Area. The Specific Plan Update establishes a shared set of goals, objectives, policies, and implementing actions for the future growth and change of the Specific Plan Area. The Specific Plan Update also aids in implementing the broader goals and policies for the City of Fresno outlined in the General Plan in a manner that can better meet the needs of the Tower District. This update is intended to streamline development within the Specific Plan Area by updating the Specific Plan’s environmental analysis pursuant to CEQA requirements, and by providing a current regulatory framework and applicable mitigation measures.
6.2.2 Project Objectives
An EIR must only discuss in detail an alternative that is capable of feasibly attaining most of the basic objectives associated with the action, while at the same time avoiding or substantially lessening any of the significant effects associated with the proposed project. Below are the project objectives, as provided in Section 3.5, Project Objectives.
1. Enhance the livability and social diversity of the Tower District’s residential neighborhoods and create housing opportunities that make the District inclusive and welcoming.
2. Nurture the mutually supportive relationship between the Tower District’s residential neighborhoods and vibrant commercial areas.
3. Conserve and revitalize the Tower District’s historic resources.
4. Shape the character of new development to complement the Tower District’s character as a walkable place not dominated by the automobile.
5. Provide effective transportation access for pedestrians, bicyclists, motorists, and transit users, and emphasize the importance of pedestrian-friendly environments.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-3
6. Increase opportunities for recreation within walking distance of Tower District residents.
7. Promote environmental sustainability and climate resilience.
6.2.3 Significant Unavoidable Impacts of the Proposed Project As described in Chapter 1.0, Executive Summary, and in Appendix C, Initial Study, the proposed project would result in either no impacts or less than significant impacts related to aesthetics, agriculture and forestry resources, energy, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, public services, transportation and traffic, utilities and service systems, and wildfire.
As described in Chapter 4.0, Evaluation of Environmental Impacts, and in Appendix C, Initial Study, the proposed project would result in less than significant impacts after implementation of mitigation related to air quality, biological resources, cultural resources, geology and soils, greenhouse gas emissions, noise, and tribal cultural resources. The proposed project would result in a significant unavoidable impact related to recreation.
6.3 SELECTION OF ALTERNATIVES
Pursuant to State CEQA Guidelines Section 15126.6(a), an EIR shall describe a range of reasonable alternatives to the project that would feasibly attain most of the basic objectives of the project, avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. Only those impacts found significant and unavoidable are relevant in making the final determination of whether an alternative is environmentally superior or inferior to the proposed project. As detailed in the Initial Study and Section 4.1 through Section 4.6 of this EIR, upon compliance with existing regulations and mitigation measures, implementation of the Specific Plan Update would not result in any significant and unavoidable impacts with the exception of parks impacts, as analyzed in Section 4.6, Recreation.
6.3.1 Alternatives Considered but Rejected
In accordance with State CEQA Guidelines Section 15126.6(c), an EIR should identify any alternatives that were considered for analysis but rejected as infeasible and briefly explain the reasons for their rejection. According to State CEQA Guidelines, among the factors that may be used to eliminate alternatives from detailed consideration are the alternative’s failures to meet most of the basic project objectives, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts.
6.3.1.1 Off-Site Alternative
Off-site alternatives generally involve moving a project to another location. As this EIR analyzes an update to an existing specific plan for an established infill area at a programmatic-level, and not a defined site-specific project, an off-site alternative to the Tower District Specific Plan Update is infeasible. Implementation of the Specific Plan Update cannot occur outside of the Specific Plan Area. Furthermore, the objectives of the proposed project are to enhance the livability of the Tower District neighborhoods, conserve and revitalize the Tower District’s historic resources, and support the relationship between the residential and commercial areas of the District. These objectives LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-4
cannot be accomplished in an area outside of the Specific Plan Area that would still meet the objectives for the Tower District. For these reasons, the Off-Site Alternative is infeasible and dismissed from further evaluation.
6.3.1.2 Palm Avenue Commercial Corridor Alternative
During early scoping of the proposed project, an alternative was proposed that would promote commercial accessory development units (ADU) along the east side of Palm Avenue between McKinley Avenue and Clinton Avenue. This alternative would allow commercial ADU development along the Palm Avenue frontage in an area that is established as residential single-family development. This alternative would encourage development of the area along Palm Avenue with more active frontage, the rear property line fencing that currently fronts Palm Avenue in this location. This alternative would also provide live/work opportunities for Tower District residents.
However, this alternative was discarded because it could have compromised the livability of the existing residential properties by introducing commercial uses, potentially introduced safety concerns associated with increased traffic and vehicles along Palm Avenue, and diluted economic opportunities within the District that are focused along Olive Avenue, Wishon Avenue, Belmont Avenue, and Blackstone Avenue. These areas have vacant commercial properties and are included in the Specific Plan Update for revitalization to encourage continued commercial and mixed-use development. For these reasons, the Palm Avenue Commercial Corridor Alternative was dismissed from further evaluation.
6.4 ALTERNATIVE 1: NO PROJECT ALTERNATIVE
6.4.1 Description
Pursuant to CEQA Guidelines, the No Project Alternative is required as part of the “reasonable range of alternatives” to allow decision makers to compare the impacts of approving the proposed project with the impacts of taking no action or not approving the proposed project. Under the No Project Alternative, the proposed Specific Plan Update would not be adopted. Development within the Specific Plan Area would continue to be implemented in accordance with the existing Tower District 1991 Specific Plan (1991 Specific Plan) and land use and zoning changes allowed under the General Plan. Despite the lack of an update under the No Project Alternative, the distribution and location of projected growth within the Specific Plan Area would occur in a manner consistent with the City’s General Plan and zoning documents. As described in Chapter 3.0, Project Description, the existing land use and zoning designations anticipate that the Specific Plan Area would result in an increase of 2,271 additional residential units, for a total of 9,607 residential units within the Tower District, as the 1991 Specific Plan and General Plan is implemented through the Horizon Year of 2035.
The identified improvements proposed in the Specific Plan Update for the Tower District would not be implemented. Land use and zoning changes would not be implemented, and any future development would be consistent with the current allowed land use and zoning designations. Under this alternative, the Apartment House (AH) Overlay zoning designation would not be expanded along Olive Avenue, and the proposed medium-low density residential uses at Terrace Gardens, Porter Tract, and Wilson Island would not be implemented, nor would the proposed Neighborhood Mixed Use zoning along Shields Avenue or the Corridor-Center Mixed Use zoning along Blackstone Avenue.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-5
6.4.2 Environmental Analysis
The No Project Alternative would result in no changes to the land use or zoning designations within the Specific Plan Area. Future development would continue as consistent with the current General Plan designations. Although the No Project Alternative would not update the text of the 1991 Specific Plan, or the land use and zoning changes allowed under the General Plan, development as outlined in the 1991 Specific Plan and General Plan would continue to occur.
The effects that were found to be significant prior to mitigation under the Specific Plan Update Draft EIR (air quality, biological resources, cultural resources and tribal cultural resources, geology and soils, greenhouse gas emissions, and noise,) would continue to occur as site-specific development allowed under the General Plan occurs. Significant and unavoidable effects to recreation associated with continued development within the Specific Plan Area would continue to occur as build out of the 1991 Specific Plan and General Plan continues, as no additional park space or recreation facilities are planned within the Specific Plan Area.
6.4.3 Overview of Potential Impacts Compared to Proposed Project The potential environmental impacts associated with the No Project Alternative when compared to the proposed project are described below.
Aesthetics. As with the proposed Specific Plan Update, future development under the No Project Alternative would not block views, would not degrade the existing visual character or quality of the area, and would not introduce new sources of substantial light or glare that would adversely affect views in the area. Thus, overall impacts related to aesthetics would be similar when comparing the No Project Alternative to the proposed project.
Agriculture and Forestry Resources. As with the proposed Specific Plan Update, future development under the No Project Alternative would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a non-agricultural use, and existing zoning designations would remain in place. Additionally, future development would not result in the loss of forest land or conversion of forest land to non-forest uses. Thus, overall impacts related to agriculture and forestry resources would be similar when comparing the No Project Alternative to the proposed project.
Air Quality. Implementation of the No Project Alternative would result in a similar level of continued development within the Specific Plan Area, as compared to the proposed project. The majority of the area within the Specific Plan Area is already developed and is not expected to change. Under the No Project Alternative, future development would continue as allowed under the General Plan, and development by the Horizon Year of 2035 would result in 537 fewer residential units and 18,800 square feet of additional non-residential uses as compared to the buildout of the Specific Plan Update. The air quality impacts under the proposed project are fully mitigable with implementation of the mitigation measures proposed in this Draft EIR. Therefore, air quality impacts under the No Project Alternative would be similar, as future construction and operation of the existing uses would not be significantly different than the proposed project.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-6
Biological Resources. As with the proposed Specific Plan Update, future development under the No Project Alternative would not have significant impacts on biological resources. The biological resources impacts under the proposed project are fully mitigable with implementation of the mitigation measures proposed in this Draft EIR. Under the No Project Alternative, the potential to modify habitat for any special-status species identified in the Draft EIR would be similar to that of the impacts potentially resulting from the proposed project. Given the areas of impact, any development occurring in the Specific Plan Area would result in potential impacts to habitat and special status species. As a result, impacts to biological resources would be similar when comparing the No Project Alternative to the proposed project.
Cultural and Tribal Cultural Resources. As with the proposed Specific Plan Update, future development under the No Project Alternative would not have significant impacts on cultural resources and tribal cultural resources. The cultural resources and tribal cultural resources impacts under the proposed project are fully mitigable with implementation of mitigation measures proposed in this Draft EIR. Under the proposed project, potential impacts to cultural resources would result on a site-by-site basis mostly from previously unknown sites. Under the No Project Alternative, future development under the General Plan would be similar and would require the same mitigation measures to reduce the potential impacts to less-than-significant levels. As a result, potential impacts to cultural resources and tribal cultural resources would be similar when comparing the No Project Alternative to the proposed project.
Energy. As with the proposed Specific Plan Update, future development under the No Project Alternative would not have significant impacts on energy. The energy impacts under the proposed project are fully mitigable with implementation of the mitigation measures proposed in this Draft EIR. The No Project Alternative would continue development within the Specific Plan Area in line with the approved land use and zoning designations of the General Plan. Energy required for construction and continued implementation of the No Project Alternative would be similar compared to the proposed project; therefore, impacts would be similar.
Geology and Soils. As with the proposed Specific Plan Update, future development under the No Project Alternative would not have significant impacts on geology and soils. Implementation of this alternative would involve site-specific construction grading and other ground-disturbing activities for future development similar to the proposed project in the Specific Plan Area. Therefore, this alternative would have similar impacts associated with seismic ground-shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this alternative. Overall, impacts to geology and soils would be similar.
Greenhouse Gas Emissions. As with the proposed Specific Plan Update, future development under the No Project Alternative would not have significant impacts on greenhouse gas emissions. The existing General Plan, which would be carried forward under the No Project Alternative, includes goals, objectives, and policies aimed at reducing greenhouse gas emissions. The greenhouse gas emission impacts under the proposed project are fully mitigable with implementation of the mitigation measures proposed in this Draft EIR. The No Project Alternative would result in a similar level of overall development as the proposed plan, and GHG emissions would be similar.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-7
Hazards and Hazardous Materials. Implementation of the proposed project and the No Project Alternative would implement development in the Specific Plan Area, which could include sites that contain hazardous materials. Additional site analysis would be required to ensure that potentially hazardous conditions would not adversely affect the public or the environment. As a result, impacts related to hazards and hazardous materials would be similar under the No Project Alternative when compared to the proposed project.
Hydrology and Water Quality. The hydrology and water quality impacts under the proposed project would be considered less than significant. Similarly, as a result of buildout of the General Plan, the No Project Alternative would be required to implement policies of the General Plan and impacts would be less than significant. As a result, impacts related to hydrology and water quality would be similar under the No Project Alternative when compared to the proposed project.
Land Use and Planning. Implementation of the No Project Alternative would result in development of urban land uses within the same footprint as the proposed project and would be largely consistent with the General Plan. Similar to the proposed plan, the No Project Alternative would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect. The proposed plan involves land use and zoning changes to facilitate the implementation of the objectives of the Specific Plan Update, and less than significant impacts were identified for the proposed project. As the No Project Alternative would retain the existing land uses and zoning designations allowed under the General Plan, it would have a slightly reduced impact compared with the proposed project.
Mineral Resources. Implementation of the No Project Alternative would involve site-specific construction and other ground-disturbing activities for future development similar to the proposed project in the Specific Plan Area. Overall, impacts to mineral resources would be similar.
Noise. Implementing the No Project Alternative would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related noise would be similar.
Even though this alternative would include a different mix of urban land uses (slightly less residential and more commercial), operational noise and traffic noise would also be similar to the proposed plan due to the existing and projected residential uses and minimal decrease in non-residential area.
Overall, noise impacts would be similar.
Population and Housing. The proposed project would result in a slight increase in population due to the land use and zoning designation changes, which would increase the total projected residential area by 537 units as compared to the No Project Alternative. The impacts are considered less than significant given the projected growth under the General Plan and Housing Element. However, because the No Project Alternative would result in continued implementation of the General Plan, which would result in slightly fewer residential units when compared to the proposed Plan, the No Project Alternative would result in slightly fewer impacts with respect to population and housing.
Public Services and Recreation. The No Project Alternative would not increase the population in a way that would impact fire services, police services, or school operations. The Specific Plan Area would continue to be underserved by parks and recreational facilities, as the area in its existing LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-8
condition does not meet the current ratio for adequate service. Therefore, the impacts would be similar as compared to the proposed project.
Transportation. The No Project Alternative would continue implementation of the land use and zoning designations allowed under the General Plan. The Specific Plan Area is currently in a low VMT zone, and the proposed project would have less than significant impacts due to implementation of the Specific Plan Update. The No Project Alternative would not conflict with applicable plans, programs, ordinances, or policies or increase transportation hazards. Impacts would be similar to the proposed project.
Utilities and Service Systems. The proposed project would have slightly greater development capacity than the projected growth under the General Plan. However, the growth anticipated under the General Plan is acknowledged in the 2023-2031 Housing Element, and would not impact the utility and service systems in the Specific Plan Area greater than is currently estimated. Therefore, impacts would be similar between the No Project Alternative and proposed project, as development would not exceed the needs for the uses allowed under the 1991 Specific Plan and General Plan.
Wildfire. Implementation of the proposed project would have less than significant impacts to wildfire. The Specific Plan Area is in a developed and urban area and is not located within a Very High Fire Hazard Severity Zone. There would not be impairment to emergency response or evacuation plans, threat of uncontrolled wildfire, or risk of landslides as a result of runoff, post-fire slope instability, or drainage changes. Impacts under the No Project Alternative would be similar to the proposed project.
6.4.4 Compatibility with Project Objectives
Under the No Project Alternative, the Specific Plan Update would not be implemented and therefore this alternative does not meet any of the project objectives.
6.5 ALTERNATIVE 2: RECREATION ALTERNATIVE
6.5.1 Description
The Fresno General Plan, adopted in December 2014, and Parks Master Plan (PMP), adopted in December 2024, identified a level of service (LOS) goal for pocket, neighborhood and community parks of 3.0 acres of parks per 1,000 residents. For regional, open space/natural areas, and special use parks, a LOS goal of 2.0 acres of parks per 1,000 residents was identified. As discussed in Section
4.6, Recreation, there are four parks classified as Pocket, Neighborhood, or Community parks within the Specific Plan Area: Broadway Parque, San Pablo Park, Ted C Wills Park, and Trolley Park. These parks total approximately 6.7 acres of useable recreation space within the Specific Plan Area, for a ratio of 0.33 acre per 1,000 residents, which is below the City’s LOS goal.
The Recreation Alternative would prioritize providing more parks and recreation facilities within the Specific Plan Area, specifically on vacant sites, including the areas highlighted as “park opportunity LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-9
areas for study” in the Specific Plan Update.1 Currently, there are approximately 79 vacant sites in the Tower District, distributed over the entire planning area, ranging in size from 0.03 to 0.79 acres in size. These vacant sites could only be developed as pocket parks and would not meet the need for a neighborhood park (2-10 acres) or a community park (10-40 acres).
Conceptually, this alternative would involve development of vacant sites within the Specific Plan Area with recreational uses including active and passive park facilities such as trails, picnic areas, playground and tot lots, landscaped areas, and open spaces. Most of these vacant sites would require purchase by the City, as they are under private ownership. Under the proposed project, the majority of these sites are included in the development capacity for future residential development.
By prioritizing parks and recreation facilities and designating additional land for parkland development at vacant sites, this would also slightly decrease the projected residential units to be developed through implementation of the proposed project.
6.5.2 Environmental Analysis
As discussed in the PMP, parkland within the City of Fresno needs to increase by 1,095 acres to meet the General Plan overall level of service goals for Fresno’s current population, and by 1,751 acres to meet recreation needs of Fresno’s future population (General Plan Horizon Year 2035). And, while the ratio of parkland for the City is higher than that of the Tower District, the provision of parkland is not even across the City. As described in the impact analysis in Section 4.6.5, the implementation of the Specific Plan Update would result in approximately 537 more projected residential units than previously projected under existing planned land uses, for a total of 2,807 new residential uses by the build out of the proposed project. Using the City average of 3.0 persons per household, this would increase the existing population within the Specific Plan Area by approximately 8,621 residents for a total of 30,429 residents within the Specific Plan Area under full build out by 2046.
Based on the General Plan standard of 3.0 acres of public parkland per 1,000 residents, the proposed project would require the dedication of approximately 91.3 acres of useable parkland to meet the standard. With the 6.7 acres of existing useable parkland, this would require a total of approximately 84.6 acres of new parkland to meet the level of service goal. The Recreation Alternative would slightly reduce the number of new residential units, as the vacant land would be utilized for park and recreation facilities instead of housing. Therefore, the potential residential growth under the Recreation Alternative would result in a slightly decreased demand for parks and recreation facilities as compared to the proposed project. However, while the Recreation Alternative would provide more parks and recreation facilities within the Specific Plan Area, it would not be able to fully meet the City’s LOS goals to provide 3.0 acres per 1,000 residents.
Additionally, as the Tower District is a highly-developed and urban area, the vacant sites that could be utilized for potential parks and recreation facilities are not all readily available to the City or easily accessible to the general public. The vacant sites within the Specific Plan Area are constrained by the acreage of the parcels, and therefore could only be developed as pocket parks and would not meet the need for a neighborhood park (2-10 acres) or a community park (10-40 acres). The location of these parks would also be dependent on the vacant sites, which are not spread geographically
1 City of Fresno. 2025. Draft Tower District Specific Plan Update. Website: https://www.fresno.gov/wp- content/uploads/2024/07/DRAFT-Tower-District-Specific-Plan_20240711_v2.pdf (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-10
equally throughout the Specific Plan Area. Therefore, the potential parks would not serve all residents of the Tower District, as the service area radius for pocket parks is only up to 0.5-miles. As discussed in the PMP, parks and open spaces must feel inviting, comfortable, and safe in order to best serve the entire community.
2 Guidelines for the design of parks and open spaces should prioritize amenities that attract positive social activities, have high visibility and natural surveillance with clear lines of sight, create inviting park perimeters with clearly labeled entry and exit points, and be easily maintainable.
6.5.3 Overview of Potential Impacts Compared to Proposed Project The Recreation Alternative would continue to implement the Specific Plan Update, with the provision to utilize vacant sites and dedicate additional land for the development of parks and recreation facilities. For the purpose of this analysis, it is assumed that all mitigation measures for implementation of the proposed Specific Plan Update would apply to the Recreation Alternatives and similar reductions in impacts would be achieved through such mitigation. The Recreation Alternative would continue to result in either no impacts or less than significant impacts related to aesthetics, agriculture and forestry resources, energy, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, public services, transportation and traffic, utilities and service systems, and wildfire. The Recreation Alternative would also result in less-than-significant impacts after implementation of mitigation related to air quality, biological resources, cultural resources, geology and soils, greenhouse gas emissions, noise, and tribal cultural resources.
However, under this Alternative, the City’s LOS goal of 3.0 acres per 1,000 residents would still not be met, and the significant and unavoidable impact to recreation would remain. Therefore, the potential impacts of the Recreation Alternative are the same as the proposed project, with a significant and unavoidable impact to recreation.
6.5.4 Compatibility with Project Objectives
The Recreation Alternative would meet most of the Project Objectives, as it would continue to implement the Specific Plan Update, with a specific emphasis on the Project Objective to increase opportunities for recreation within walking distance of Tower District residents. However, as the potential sites for new park and recreation facilities may coincide with vacant lots that are included in the development capacity analysis for the Specific Plan Update, the Recreation Alternative would decrease the amount of potential future residential units. Therefore, the Recreation Alternative would not be consistent with the Project Objective to create housing opportunities within the Tower District.
6.6 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
State CEQA Guidelines Section 15126.6(e)(2) indicates that an analysis of alternatives to a project shall require the identification of an Environmentally Superior Alternative, and that if the No Project Alternative is the Environmentally Superior Alternative, then the EIR shall also identify an
2 City of Fresno. 2024. Fresno Parks Master Plan with the 2023 Technical Amendment. Website:
https://www.fresno.gov/parks/parksmasterplan/ (accessed July 2025).
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
6-11
Environmentally Superior Alternative among the other alternatives. Table 6.A provides, in summary format, a comparison of the level of impacts for each alternative to the proposed project. As shown in Table 6.A, the No Project Alternative would be the environmentally superior alternative as it would result in no new environmental impacts and would reduce some of the proposed project impacts. However, the No Project Alternatives would not meet the Project Objectives. Therefore, the Recreation Alternative would be the Environmentally Superior Build Alternative, as it has similar impacts as the proposed project and slightly reduced impact to recreation, even though it would not fully mitigate for the significant and unavoidable impact to recreation and would not fully attain all of the Project Objectives.
Table 6.A: Comparison of Alternatives
Environmental Topic
Level of Impact
Proposed Project (after
mitigation)
Alternative 1: No Project
Alternative
Alternative 2: Recreation
Alternative
Aesthetics Less Than Significant Similar Impact Similar Impact Agriculture and Forestry
Resources Less Than Significant Similar Impact Similar Impact Air Quality Less Than Significant Similar Impact Similar Impact Biological Resources Less Than Significant Similar Impact Similar Impact Cultural Resources and Tribal
Cultural Resources Less Than Significant Similar Impact Similar Impact Energy Less Than Significant Similar Impact Similar Impact Geology and Soils Less Than Significant Similar Impact Similar Impact Greenhouse Gas Emissions Less Than Significant Similar Impact Similar Impact Hazards and Hazardous
Materials Less Than Significant Similar Impact Similar Impact Hydrology and Water Quality Less Than Significant Similar Impact Similar Impact Land Use and Planning Less Than Significant Reduced Impact Similar Impact Mineral Resources Less Than Significant Similar Impact Similar Impact Noise Less Than Significant Similar Impact Similar Impact Population and Housing Less Than Significant Reduced Impact Similar Impact Public Services and
Recreation
Significant and
Unavoidable Similar Impact Slightly Reduced Impact
Transportation Less Than Significant Similar Impact Similar Impact Utilities and Service Systems Less Than Significant Similar Impact Similar Impact Wildfire Less Than Significant Similar Impact Similar Impact Attainment of Project
Objectives
Meets all of the Project
Objectives
Meets none of the Project
Objectives
Meets most of the Project
Objectives
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
6-12
This page intentionally left blank
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
7-1
7.0 REPORT PREPARATION
7.1 REPORT PREPARERS
7.1.1 City of Fresno
2600 Fresno Street, Room 3065, Third Floor
Fresno, CA 93721
7.1.2 LSA Associates, Inc.
2565 Alluvial Avenue, Suite 112
Clovis, CA 93611
7.2 REFERENCES
Balmes, J.R., G. Earnest, P.P. Katz, E.E. Yelin, M.D. Eisner, H. Chen, L. Trupin, F. Lurmann, and P.D.
Blanc. 2009. Exposure to traffic: Lung function and health status of adults with asthma. The Journal of Allergy and Clinical Immunology, 123(3):626–631.
Ban
croft, Hubert Howe. 1884-1890.
History of California, 7 vols. The History Company, San Francisco, California.
Bay Are
a Air Quality Management District (Bay Area Air District). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. April. Website: https://www.baaqmd.gov/~/media/files/planning-and-research/ ceqa/ceqa-thresholds-2022/justification-report-pdf.pdf?la=en (accessed June 2025).
California Air Pollution Control Officers Association (CAPCOA). 2017. California Emissions Estimator Model. Version 2016.3.2. Website: http://www.caleemod.com/ (accessed July 2025).
California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.
_____. 2013. Overview of the Children’s Health Study. Website: https://ww2.arb.ca.gov/resources/ documents/childrens-health-study (accessed July 2025).
_____. 2017a. California’s 2017 Climate Change Scoping Plan. November. _____. 2017b. Second Update to the Climate Change Scoping Plan: Building on the Framework (CARB 2017). Website: www.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping- plan/2017-scoping-plan-documents (accessed June 2025).
_____. 2017c. Short-Lived Climate Pollutant Reduction Strategy. March. Website: https://ww2.arb. ca.gov/sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed July 2025).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
7-2
_____. 2000a. Fact Sheet – California’s Plan to Reduce Diesel Particulate Matter Emissions. October.
Website: www.arb.ca.gov/diesel/fact sheets/rrpfactsheet.pdf (accessed July 2025). _____. 2000b. 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: www.arb.ca.gov/diesel/ documents/rrpFinal.pdf (accessed July 2025)._____. 2020. Inhalable Particulate Matter and Health (PM2.5 and PM10). Website:
ww2.arb.ca.gov/resources/inhalable-particulate-matter-and-health (accessed July 2025). _____. 2022a. 2022 Scoping Plan Update. May 10. Website: https://ww2.arb.ca.gov/sites/default/ files/2022-12/2022-sp.pdf (accessed July 2025).
_____. 2022b. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg- descriptions-sources (accessed July 2025).
_____. 2022c. Appendix D Local Actions – Draft 2022 Scoping Plan. May. Website: https://ww2.arb. ca.gov/sites/default/files/2022-05/2022-draft-sp-appendix-d-local-actions_0.pdf (accessed July 2025)
_____. 2023. California Greenhouse Gas Emissions for 2000 to 2021, Trends of Emissions and Other Indicators Report. Website: https://ww2.arb.ca.gov/sites/default/files/ 2023-12/2000_ 2021_ghg_inventory_trends.pdf (accessed July 2025).
California Air Resources Board (CARB) and United States Environmental Protection Agency (USEPA). 2025. Ambient Air Quality at Nearby Monitoring Stations.
California Department of Fish and Wildlife (CDFW). 2025a. California Natural Diversity Database (CNDDB) – Commercial version dated March 4, 2025. Website: https://wildlife.ca.gov/ Data/CNDDB/Maps-and-Data#rarefind (accessed March 2025). _____. 2025b. Biogeographic Information and Observation System (BIOS). Website: www.wildlife.ca. gov/data/BIOS (accessed March 2025).
California Legislative Information. 2025. California Government Code. Website: https://leginfo. legislature a.gov/faces/codes_displaySection.xhtml?sectionNum=65302.01.&node TreePath=12.1.10.3&lawCode=GOV (accessed June 10, 2025).
California Native Plant Society (CNPS). 2025. Inventory of Rare and Endangered Plants. V.7-08c- Interim 8-22-02. Website: www.rareplants.cnps.org (accessed March 2025).
City of Fresno. 1991. Tower District Specific Plan. March 26, 1991. Website: https://www.fresno. gov/wp-content/uploads/2023/04/Tower-District-Specific-Plan-.pdf (accessed July 2025).
City of Fresno. 2014. Fresno General Plan. Adopted December 18, 2014. Website: https://www. fresno.gov/wp-content/ uploads/2023/03/upload_temp_Consolidated-GP-10-13-2022_ compressed.pdf (accessed July 2025).
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
7-3
_____. 2014. Fresno General Plan. Chapter 5 Parks and Open Space, Table 5-2: City Park Space and Ration Per 1,000 Residents by Park Category.
_____. 2018. International Council for Local Environmental Initiatives (ICLEI) Local Governments for Sustainability, City of Fresno 2016 Inventory Update.
_____. 2024. Fresno Parks Master Plan with the 2023 Technical Amendment. Website:
https://www.fresno.gov/parks/parksmasterplan/ (accessed June 2025). _____. 2024. Master Fee Schedule, Effective July 2024. _____. 2025. Draft Tower District Specific Plan Update. Website: https://www.fresno.gov/ wp- content/uploads/2024/07/DRAFT-Tower-District-Specific-Plan_20240711_v2.pdf (accessed March 2025).
_____. 2025. Municipal Code. Website: https://library.municode.com/ca/fresno/codes/code_of_ ordinances?nodeId=14478 (accessed March 24, 2025).
_____. n.d. City of Fresno Parks and Recreation Facilities Finder. Website: https://www.fresno. gov/parks/ (accessed July 7, 2025).Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook. Roadway Construction Noise Model, FHWA HEP-06- 015. DOT-VNTSC-FHWA-06-02. NTIS No. PB2006-109012. August.
Federal Railroad Administration (FRA). 2012. High-Speed Ground Transportation Noise and Vibration Impact Assessment.
Fresno Council of Governments (FCOG). 2024. Conformity Analysis For the 2025 Federal Transportation Improvement and the 2022 Regional Transportation Plan Amendment No. 4.
Website: https://www.fresnocog.org/wp-content/uploads/2023/11/Final-FresnoCOG-2025- FTIP-Conformity-Boilerplate_05312024-1.pdf (accessed June 10, 2025).
Fresno County Airport Land Use Commission (Fresno County ALUC). 2023. Fresno County Airport Land Use Compatibility Plan. October. Website: https://www.fresnocog.org/wp- content/uploads/2025/06/2023-ALUCP.pdf (accessed July 2025).
Fresno County Public Library. 2025. Gillis Branch Library. Website: https://www.fresnolibrary.org/ branch/ gil.html (accessed February 12, 2025).
Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. April.
Harris, C.M., ed. 1998. Handbook of Acoustical Measurements and Noise Control.
Historic Fresno. 2020. A Guide to Historic Architecture in Fresno, California. Website:
https://www.historicfresno.org/home.htm (accessed February 10, 2025).
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
7-4
International Energy Agency. CO2 Emissions in 2022. Website: https://www.iea.org/reports/co2- emissions-in-2022 (accessed July 2025).
LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
_____. 2025b. Biological Resources Evaluation Tower District Specific Plan Update Fresno, Fresno County, California. July.
_____. 2025c. Constraints Assessment for the Tower District Specific Plan in Fresno, Fresno County, California. July.
_____. 2025d. Tower District Specific Plan Update Trip Generation and Vehicle Miles Traveled Analysis Memorandum.
Pacific Gas & Electric Company (PG&E). 2021. Exploring Clean Energy Solutions. Website:
https://www.pge.com/en_US/about-pge/environment/what-we-are-doing/clean-energy- solutions/clean-energy-solutions.page?WT.mc_id=Vanity_cleanenergy (accessed June 2024).
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:
pubs.acs.org/doi/full/10.1021/acs.est.5b02766 (accessed July 2025).
San Joaquin Valley Air Pollution Control District (SJVAPCD). 2007. 2007 PM10 Maintenance Plan and Request for Redesignation. Website: www.valleyair.org/Air_Quality_Plans/docs/ Maintenance%20Plan10-25-07.pdf (accessed July 2025).
_____. 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. March 19. Website:
www.valleyair.org/transportation/ceqa_idx.htm (accessed June 2025). _____. 2015b. Screening Levels for Potential Odor Sources. _____. 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15. Website:
http://valleyair.org/pmplans/documents/2018/pm-plan-adopted/2018-Plan-for-the-1997- 2006-and-2012-PM2.5-Standards.pdf (accessed July 2025). _____. 2025. Air Quality Attainment Plans. Website: https://ww2.valleyair.org/rules-and- planning/air-quality-plans/ (accessed June 10, 2025).
South Coast Air Quality Management District (SCAQMD). 2008. Multiple Air Toxics Exposure Study in the South Coast Air Basin (MATES III). September.
Southern San Joaquin Valley Information Center. 2025. Cultural Resources Within the Project Area.
LSA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
(08/13/25)
7-5
State of California Government Code. 1985. Article 8. Specific Plans [65450 - 65457]. Website:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV& sectionNum= 65451.&article=8.&highlight=true&keyword=Specific%20Plan (accessed February 12, 2025).
United States Census Bureau Data. 2020. Existing Land Uses United States Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information.
February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/black carbon/basic.html (accessed July 2025).
_____. 2023. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2022. Website:
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks (accessed July 2025).
United States Fish and Wildlife Service (USFWS). 2025a. Critical Habitat Portal. Website:
https://ecos.fws.gov/ecp/report/table/critical-habitat.html (accessed March 2025). _____. 2025b. Information for Planning and Consultation online Project planning tool. Website:
https://ecos.fws.gov/ipac/ (accessed March 2025).
Wallace, William J. 1978. Southern Valley Yokuts. In Handbook of North American Indians, Vol 8, California. Smithsonian Institution, Washington D.C.
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 July 2025).
Zeiner, D., W.F. Laudenslayer, Jr., and K.E. Mayer. 1990. California’s Wildlife. California Statewide Wildlife Habitat Relationship System, Volumes I, II, & III, with online updates. California Department of Fish and Wildlife. May.
Zhu, Y., Hinds, W.C., Kim, S., Shen, S., and Sioutas, C. 2002. Study of ultrafine particles near a major roadway with heavy-duty diesel traffic. Atmospheric Environment, 36(27):4323-4335.
LSA
T OWER D ISTRICT S PECIFIC PLAN U PDATE
F RESNO , C ALIFORNIA
P UBLIC REVIEW DRAFT E NVIRONMENTAL I MPACT REPORT
A UGUST 2025
(08/13/25)
7-6
This page intentionally left blank
LSA