Exhibit M - Draft EIR — Fresno City Council, November 20, 2025 (part 1 of 2)

Exhibit M
Draft Environmental Impact Report (DEIR)
The DEIR Appendices can be downloaded from this link:
https://fresno-tower-cityoffresno.hub.arcgis.com/pages/ documents
This page intentionally left blank
August 2025

PUBLIC REVIEW DRAFT

ENVIRONMENTAL IMPACT REPORT

TOWER DISTRICT SPECIFIC PLAN UPDATE

FRESNO, CALIFORNIA

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

State Clearinghouse Number: 2025050309

LSA
This page intentionally left blank
August 2025

PUBLIC REVIEW DRAFT

ENVIRONMENTAL IMPACT REPORT

TOWER DISTRICT SPECIFIC PLAN UPDATE

FRESNO, CALIFORNIA

Submitted to:

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

Prepared by:

LSA
2565 Alluvial Avenue, Suite 112
Clovis, California 93611
(559) 490-1210

Project No. 20241643
LSA
This page intentionally left blank

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)
i

TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................... i FIGURES AND TABLES ............................................................................................................................ iv LIST OF ABBREVIATIONS AND ACRONYMS ............................................................................................ vi

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

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

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

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

1.2.2 Project Description ............................................................................................................. 1-2

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

1.2.4 Significant and Unavoidable Adverse Impacts.................................................................... 1-3

1.2.5 Lead Agency, Responsible, and Trustee Agencies .............................................................. 1-3

1.3 Summary of Project Alternatives ...................................................................................... 1-4

1.3.1 No Project Alternative ........................................................................................................ 1-4

1.3.2 Recreation Alternative ........................................................................................................ 1-4

1.4 Areas of Controversy ......................................................................................................... 1-4

1.5 Public Review of the Draft EIR ........................................................................................... 1-5

1.6 Executive Summary Matrix ............................................................................................... 1-6

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

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

2.2 Type of EIR ......................................................................................................................... 2-2

2.3 Environmental Review Process ......................................................................................... 2-3

2.3.1 Notice of Preparation ......................................................................................................... 2-3

2.3.2 Scoping Meeting ................................................................................................................. 2-5

2.3.3 Effects Determined to be Potentially Significant ................................................................ 2-5

2.4 Organization of this Draft EIR ............................................................................................ 2-5

2.5 Project Applicant and Lead, Responsible, and Trustee Agencies ..................................... 2-6

2.6 Review of this Draft EIR ..................................................................................................... 2-7

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

3.1 Project Location ................................................................................................................ 3-1

3.2 Proposed Project Characteristics ...................................................................................... 3-1

3.3 Tower District Existing Characteristics .............................................................................. 3-7

3.3.1 Land Uses .......................................................................................................................... 3-11

3.3.2 Zoning ............................................................................................................................... 3-14

3.4 Existing Specific Plan ....................................................................................................... 3-15

3.5 Project Objectives ........................................................................................................... 3-15

3.6 Specific Plan Updates ...................................................................................................... 3-16

3.6.1 Conservation and Historic Preservation ........................................................................... 3-16

3.6.2 Land Use ........................................................................................................................... 3-17

3.6.3 Proposed Land Use Changes ............................................................................................. 3-18

3.6.4 Development Capacity...................................................................................................... 3-18

3.6.5 Parks and Open Spaces ..................................................................................................... 3-22

3.6.6 Circulation ......................................................................................................................... 3-23 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)
ii

3.6.7 Utilities ............................................................................................................................. 3-24

3.6.8 Implementation ............................................................................................................... 3-24

3.7 Design Standards and Guidelines ................................................................................... 3-24

3.8 Tower Entertainment District ......................................................................................... 3-26

3.9 Related Planning Efforts ................................................................................................. 3-26

3.9.1 Southern Blackstone Smart Mobility Strategy ................................................................. 3-26

3.9.2 Fresno 6th Cycle Housing Element ................................................................................... 3-27

3.9.3 Fresno Climate Adaptation Plan and Environmental Justice Element ............................. 3-27

3.9.4 Fresno Active Transportation Plan .................................................................................. 3-27

3.9.5 Fresno Vision Zero Action Plan ........................................................................................ 3-27

3.10 Discretionary Actions and Uses of this EIR ..................................................................... 3-27

4.0 EVALUATION OF ENVIRONMENTAL IMPACTS .................................................... 4-1

4.1 Air Quality ...................................................................................................................... 4.1-1

4.1.1 Introduction .................................................................................................................... 4.1-1

4.1.2 Existing Environmental Setting ....................................................................................... 4.1-1

4.1.3 Regulatory Framework ................................................................................................. 4.1-16

4.1.4 Significance Criteria ...................................................................................................... 4.1-25

4.1.5 Impacts and Mitigation Measures ................................................................................ 4.1-27

4.2 Biological Resources ...................................................................................................... 4.2-1

4.2.1 Introduction .................................................................................................................... 4.2-1

4.2.2 Existing Environmental Setting ....................................................................................... 4.2-2

4.2.3 Regulatory Setting ........................................................................................................ 4.2-14

4.2.4 Significance Criteria ...................................................................................................... 4.2-23

4.2.5 Impacts and Mitigation Measures ................................................................................ 4.2-24

4.3 Cultural Resources and Tribal Cultural Resources ......................................................... 4.3-1

4.3.1 Introduction .................................................................................................................... 4.3-1

4.3.2 Existing Environmental Setting ....................................................................................... 4.3-1

4.3.3 Regulatory Setting .......................................................................................................... 4.3-7

4.3.4 Significance Criteria ...................................................................................................... 4.3-15

4.3.5 Impacts and Mitigation Measures ................................................................................ 4.3-16

4.4 Greenhouse Gas Emissions ............................................................................................ 4.4-1

4.4.1 Introduction .................................................................................................................... 4.4-1

4.4.2 Existing Environmental Setting ....................................................................................... 4.4-1

4.4.3 Regulatory Setting .......................................................................................................... 4.4-6

4.4.4 Significance Criteria ...................................................................................................... 4.4-18

4.4.5 Impacts and Mitigation Measures ................................................................................ 4.4-18

4.5 Noise .............................................................................................................................. 4.5-1

4.5.1 Introduction .................................................................................................................... 4.5-1

4.5.2 Existing Environmental Setting ....................................................................................... 4.5-1

4.5.3 Regulatory Setting .......................................................................................................... 4.5-8

4.5.4 Significance Criteria ...................................................................................................... 4.5-16

4.5.5 Impacts and Mitigation Measures ................................................................................ 4.5-16

4.6 Recreation ...................................................................................................................... 4.6-1

4.6.1 Introduction .................................................................................................................... 4.6-1

4.6.2 Existing Environmental Setting ....................................................................................... 4.6-1

4.6.3 Regulatory Setting .......................................................................................................... 4.6-8

4.6.4 Significance Criteria ...................................................................................................... 4.6-15

4.6.5 Impacts and Mitigation Measures ................................................................................ 4.6-16 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)
iii

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

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

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

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

5.2 Significant Irreversible Changes ........................................................................................ 5-4

5.3 Significant Unavoidable Impacts ....................................................................................... 5-6

6.0 ALTERNATIVES ................................................................................................. 6-1

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

6.2 Proposed Project ............................................................................................................... 6-2

6.2.1 Project Characteristics ........................................................................................................ 6-2

6.2.2 Project Objectives ............................................................................................................... 6-2

6.2.3 Significant Unavoidable Impacts of the Proposed Project ................................................. 6-3

6.3 Selection of Alternatives ................................................................................................... 6-3

6.3.1 Alternatives Considered but Rejected ................................................................................ 6-3

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

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

6.4.2 Environmental Analysis ...................................................................................................... 6-5

6.4.3 Overview of Potential Impacts Compared to Proposed Project ......................................... 6-5

6.4.4 Compatibility with Project Objectives ................................................................................ 6-8

6.5 Alternative 2: Recreation Alternative ............................................................................... 6-8

6.5.1 Description ......................................................................................................................... 6-8

6.5.2 Environmental Analysis ...................................................................................................... 6-9

6.5.3 Overview of Potential Impacts Compared to Proposed Project ....................................... 6-10

6.5.4 Compatibility with Project Objectives .............................................................................. 6-10

6.6 Environmentally Superior Alternative ............................................................................. 6-10

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

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

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

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

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

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)
iv

FIGURES AND TABLES

FIGURES
Figure 3-1: Regional Location and Local Vicinity Map ........................................................................ 3-3 Figure 3-2: Project Location ................................................................................................................ 3-5 Figure 3-3: Existing General Plan Land Uses ....................................................................................... 3-9 Figure 3-4: Planned Land Uses .......................................................................................................... 3-19 Figure 4.1-1: California Population, Gross State Product (GSP), Diesel Cancer Risk, and Diesel Vehicle Miles Traveled (VMT) Regulatory Context ............................................. 4.1-15 Figure 4.2-1: Biological Study Area .................................................................................................. 4.2-3 Figure 4.5-1: Typical A-Weighted Sound Levels ............................................................................... 4.5-3 Figure 4.6-1: Parks in the Specific Plan Area .................................................................................... 4.6-5

TABLES
Table 1.A: Executive Summary Matrix ................................................................................................ 1-7 Table 3.A: Existing General Plan Land Uses ...................................................................................... 3-14 Table 3.B: Development Capacity by Proposed Land Use Designation - Vacant and Underutilized Sites ................................................................................................................... 3-21 Table 3.C: Residential Development Capacity-Underutilized Sites................................................... 3-22 Table 3.D: Non-Residential Development Capacity-Underutilized Sites .......................................... 3-22 Table 3.E: Zoning Designations Subject to Design Standards and Guidelines .................................. 3-26 Table 3.F: Potential Permits and Approvals ...................................................................................... 3-28 Table 4.1.A: Sources and Health Effects of Air Pollutants ............................................................... 4.1-4 Table 4.1.B: Federal and State Ambient Air Quality Standards ....................................................... 4.1-9 Table 4.1.C: San Joaquin Valley Air Basin Air Quality Attainment Status ...................................... 4.1-13 Table 4.1.D: Ambient Air Quality at Nearby Monitoring Stations ................................................. 4.1-14 Table 4.1.E: Screening Levels for Potential Odor Sources ............................................................. 4.1-22 Table 4.1.F: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year) .. 4.1-26 Table 4.1.G: Project Construction Emissions (tons per year) ........................................................ 4.1-32 Table 4.1.H: Estimated Operational Emissions (tons per year) ..................................................... 4.1-35 Table 4.1.I: CARB Recommendations for Siting New Sensitive Land Uses .................................... 4.1-40 Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area ................................... 4.2-6 Table 4.2.B: Special-Status Species with Potential to Occur within the Specific Plan Area ........... 4.2-14 Table 4.3.A: Cultural Resources Within the Project Area ................................................................ 4.3-6 Table 4.3.B: Tower District Specific Plan Update – Conservation & Historic Preservation Objectives and Policies ......................................................................................................... 4.3-17 Table 4.4.A: Global Warming Potential of Greenhouse Gases ........................................................ 4.4-3 Table 4.4.B: City of Fresno GHG Emissions by Sector for 2016 ....................................................... 4.4-6 Table 4.4.C: Operational Greenhouse Gas Emissions .................................................................... 4.4-21 Table 4.5.A: Definitions of Acoustical Terms ................................................................................... 4.5-2 Table 4.5.B: Long-Term Ambient Noise Monitoring Results ............................................................ 4.5-7 Table 4.5.C: Summary of USEPA Noise Levels ................................................................................. 4.5-8 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)
v
Table 4.5.D: Summary of Human Effects in Areas Exposed to 55 dBA CNEL ................................... 4.5-9 Table 4.5.E: Detailed Assessment Daytime Construction Noise Criteria ......................................... 4.5-9 Table 4.5.F: Interpretation of Vibration Criteria for Detailed Analysis .......................................... 4.5-10 Table 4.5.G: Construction Vibration Damage Criteria .................................................................... 4.5-10 Table 4.5.H: Interpretation of Vibration Criteria for Detailed Analysis .......................................... 4.5-11 Table 4.5.I: Construction Vibration Damage Criteria ..................................................................... 4.5-11 Table 4.5.J: Transportation (Non-Aircraft) Noise Sources .............................................................. 4.5-12 Table 4.5.K: Stationary Noise Sources ............................................................................................ 4.5-12 Table 4.5.L: Typical Construction Equipment Noise Levels ............................................................ 4.5-18 Table 4.5.M: Summary of Construction Phase, Equipment, and Noise Levels .............................. 4.5-19 Table 4.5.N: Vibration Source Amplitudes for Construction Equipment ....................................... 4.5-21 Table 4.6.A: Desirable Park Facility Standards ................................................................................. 4.6-2 Table 4.6.B: Existing and Planned Parks within the Specific Plan Area ............................................ 4.6-3 Table 4.6.C: Parks and Open Space in the Vicinity of the Specific Plan Area ................................... 4.6-8 Table 4.6.D: Park Facilities Fee Program ........................................................................................ 4.6-15 Table 6.A: Comparison of Alternatives .............................................................................................. 6-11

APPENDICES
A: N OTICE OF PREPARATION
B: N OTICE OF PREPARATION COMMENTS
C: INITIAL STUDY
D: SPECIFIC PLAN UPDATE OBJECTIVES AND POLICIES AND CONSISTENCY ANALYSIS E: AIR QUALITY/GREENHOUSE GAS EMISSIONS/ENERGY IMPACT ANALYSIS F: BIOLOGICAL RESOURCE EVALUATION
G: CULTURAL CONSTRAINTS ASSESSMENT
H: NOISE AND VIBRATION IMPACT ANALYSIS
I: TRANSPORTATION MEMORANDUM
J: NATIVE AMERICAN TRIBAL CONSULTATION
K: WATER SUPPLY ASSESSMENT

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)
vi

LIST OF ABBREVIATIONS AND ACRONYMS
°F degrees Fahrenheit
µg/m3 micrograms per cubic meter
AAQS Ambient Air Quality Standards
AB Assembly Bill
ADT average daily traﬃc
ADU accessory dwelling unit
AH Apartment House
AIRFA American Indian Religious Freedom Act
ALUC Airport Land Use Commission
APE Area of Potential Eﬀects
APS Alternative Planning Strategy
AQMP Air Quality Management Plan
ATP Active Transportation Plan
BAU business-as-usual
BRE Biological Resource Evaluation
BSA Biological Study Area
CAA Federal Clean Air Act
CAAQS California Ambient Air Quality Standards
CAL FIRE California Department of Forestry and Fire Protection CalEPA California Environmental Protection Agency
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
California Register California Register of Historical Resources CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CAPCOA California Air Pollution Control Oﬃcers Association CARB California Air Resources Board
CAT climate action team
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)
vii
CC Commercial Community
CCAA California Clean Air Act
CCAP Climate Change Action Plan
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFD Community Facilities District
CFR Code of Federal Regulations
CG Commercial General
CH4 methane
City City of Fresno
CLG Certiﬁed Local Government
CMS Commercial Main Street
CMX Corridor/Center Mixed Use
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CWHR California Wildlife Habitat Relationships
dB decibels
dBA A-weighted sound level
District City of Fresno Tower District
DOC California Department of Conservation
DPR California Department of Parks and Recreation
DTSC California Department of Toxic Substances Control
DWR California Department of Water Resources
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)
viii
EIR Environmental Impact Report
EO Executive Order
ESA federal Endangered Species Act
EV electric vehicle
FAR Floor Area Ratio
FAX Fresno Area Express
FCOG Fresno Council of Governments, also Fresno COG
FHWA Federal Highway Administration
FIP Federal Implementation Plan
FMFCD Fresno Metropolitan Flood Control District
FRA Federal Railroad Administration
Fresno COG Fresno Council of Governments, also FCOG
FTA Federal Transit Administration
FUSD Fresno Uniﬁed School District
GAMAQI SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts GHGs greenhouse gases
GHGRx Greenhouse Gas Reduction Exchange
GWP global warming potential
HCD California Department of Housing and Community Development HFCs hydroﬂuorocarbons
HI Hazard Index
HOA Home Owners Association
HP helipad
HRA health risk assessment
HSC Health and Safety Code
HVAC heating, ventilation, and air conditioning
IL Light Industrial
in/sec inches per second
IPCC Intergovernmental Panel on Climate Change
LCFS Low Carbon Fuel Standard
LCI Governor ’s Oﬃce of Land Use and Climate Innovation 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)
ix
Ldn day-night average level
Leq equivalent continuous sound level
LEV Low-Emission Vehicle
Lmax maximum instantaneous sound level
LOS level of service
LPG liqueﬁed petroleum gas
MBTA Migratory Bird Treaty Act
MEI maximally exposed individual
MICR maximum individual cancer risk
MLD Most Likely Descendant
MMT million metric tons
MPOs Metropolitan Planning Organizations
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAGPRA Native American Graves Repatriation Act
NAHC Native American Heritage Commission
National Register National Register of Historic Places
NCCP Natural Community Conservation Plan
NCCP/HCP Natural Community Conservation Plan/Habitat Conservation Plan NF3 nitrogen triﬂuoride
NHPA National Historic Preservation Act of 1966
NMX Neighborhood Mixed-Use
NO2 nitrogen dioxide
NOC Notice of Completion
NOP Notice of Preparation
NOX nitrogen oxides
NPPA Native Plant Protection Act
NPS National Park Service
O Oﬃce
O3 ozone
OEHHA California Oﬃce of Environmental Health Hazard Assessment 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)
x
OHP California Oﬃce of Historic Preservation
OHWM ordinary high water mark
OITC Outdoor/Indoor Transmission Class
OPR Oﬃce of Planning and Research
Pb lead
PFCs perﬂuorocarbons
PG&E Paciﬁc Gas and Electric Company
PI Public and Institutional
PM particulate matter
PM2.5 particulate matter less than 2.5 microns in size PM10 particulate matter less than 10 microns in size
PMP Parks Master Plan
ppb parts per billion
PPV peak particle velocity
PR Park and Recreation
PRC Public Resources Code
project Tower District Speciﬁc Plan Update, also Speciﬁc Plan Update RM-1 Residential Multi-Family, Medium High Density
RM-2 Residential Multi-Family, Urban Neighborhood
RM-3 Residential Multi-Family, High Density
RMS root-mean-square
ROGs reactive organic gases
RPS Renewables Portfolio Standard
RS-4 Residential Medium Low Density
RS-5 Residential Single-Family, Medium Density
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SB Senate Bill
SCS Sustainable Communities Strategy
SF6 sulfur hexaﬂuoride
SHPO State Historic Preservation Oﬃce
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)
xi
SIP State Implementation Plan
SJVAB San Joaquin Valley Air Basin
SJVAPCD San Joaquin Valley Air Pollution Control District SLC California State Lands Commission
SO2 sulfur dioxide
SOI sphere of inﬂuence
Speciﬁc Plan Area Fresno Tower District Speciﬁc Plan Area Speciﬁc Plan Update Fresno Tower District Speciﬁc Plan Update SR- State Route
SSC Species of Special Concern
SSJVIC Southern San Joaquin Valley Information Center
STC Sound Transmission Class
SWPPP Storm Water Pollution Prevention Plan
SWRCB State Water Resources Control Board
T-BACTs best available control technologies for toxics
TAC toxic air contaminant
TCRs tribal cultural resources
UPRR Union Paciﬁc Railroad
USACE United States Army Corps of Engineers
USC United States Code
USEPA United States Environmental Protection Agency
VdB vibration velocity decibels
VMT vehicle miles traveled
VOCs volatile organic compounds
ZEV zero-emission vehicle

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)
xii
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)
1-1

1.0 EXECUTIVE SUMMARY

1.1 PURPOSE
This Draft Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental impacts associated with the implementation of the Tower District Specific Plan Update (Specific Plan Update), also referred to as the proposed project. This Draft EIR has been prepared in conformance with CEQA (California Public Resources Code, Section 21000, et seq.); the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000, et seq.); and procedures for implementing CEQA as adopted by the City of Fresno.

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

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

1.2.1 Project Location
The City of Fresno is located in Fresno County in the central San Joaquin Valley, approximately 200 miles north of Los Angeles and 170 miles south of Sacramento. The Tower District (District) is an approximately 1,869-acre area located immediately north of Downtown Fresno and the State Route (SR) 180 freeway, and one mile east of the SR-99 corridor. To the north of Fresno is Madera County, to the northeast and adjacent to Fresno is the City of Clovis, and unincorporated land is located to the east, south, and west of Fresno.

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)
1-2
District is the geographic area for which the Specific Plan Update establishes policies conservation, future growth, and change, and conservation.

1.2.2 Project Description
The proposed project would update the 1991 Tower District Specific Plan (1991 Specific Plan) to respond to both continuing and new issues in the Tower District. Recent decades have led to greater emphasis on housing availability and affordability, expanding recreational opportunities, and calming auto-oriented roadways. At the same time, the Specific Plan Update maintains the guiding principles from the 1991 Specific Plan and continues the focus on neighborhood character, walkability, and historic resources.

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 both neighborhood conservation and 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 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.

The proposed project would also implement land use changes that would maintain and enhance the character-defining elements associated with the Tower District while allowing for future growth. The Specific Plan Update would promote more mixed-use development along commercial corridors by re-designating a portion of Blackstone Avenue from neighborhood mixed use to corridor/center mixed-use and by re-designating a portion of Shields Avenue from office to neighborhood mixed-use areas, specifically on Blackstone Avenue and Shields Avenue. The Specific Plan Update would also expand the Apartment House (AH) Overlay zoning designation along Olive Avenue, from North Fruit Avenue to North Echo Avenue, and allow medium low density residential uses at Terrace Gardens, Porter Tract, and Wilson Island. Additionally, the existing Tower District Design Guidelines adopted in 2005 are proposed to be updated by the Tower District Design Standards and Guidelines as part of the proposed project. The updated Design Standards and Guidelines reflect the policy direction of the Specific Plan Update and are intended to result in compatible development.

1.2.3 Project Objectives
CEQA Guidelines Section 15124(b) states that an EIR project description must include “[a] statement of objectives sought by the proposed project. The statement of objectives should include the underlying purpose of the project.” The project objectives are:

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.

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)
1-3

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.

6. Increase opportunities for recreation within walking distance of Tower District residents.

7. Promote environmental sustainability and climate resilience

1.2.4 Significant and Unavoidable Adverse Impacts
The proposed project would result in a significant and unavoidable impact to Recreation.

1.2.5 Lead Agency, Responsible, and Trustee Agencies
The project applicant and lead agency for the proposed project is the City of Fresno. The City is the public agency that has the principal responsibility for certifying the EIR, approving or carrying out the project, or disapproving the project. Although the City is the CEQA Lead Agency for the project, other agencies also have discretionary authority related to components of the project and approvals or serve as a responsible and/or trustee agency in connection to the project. These agencies include:
 California Department of Transportation (Caltrans), including the Division of Aeronautics  California Air Resources Board (CARB)
 California Department of Conservation (DOC)
 California Department of Fish and Wildlife (CDFW)
 California Department of Forestry and Fire Protection (CAL FIRE)  California Department of Housing and Community Development (HCD)  California Department of Parks and Recreation (DPR)
 California Department of Toxic Substances Control (DTSC)  California Public Utilities Commission (CPUC)
 California State Office of Historic Preservation (OHP)  California State Lands Commission (SLC)
 California State Water Resources Control Board (SWRCB)  Central Valley Regional Water Quality Control Board (Central Valley RWQCB)  Fresno Airport Land Use Commission (Fresno ALUC)
 Fresno Metropolitan Flood Control District (FMFCD)
 Fresno Irrigation District
 Fresno Unified School District (FUSD)
 San Joaquin Valley Air Pollution Control District (SJVAPCD)

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

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)
1-4

1.3.1 No Project Alternative
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 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. 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. 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. Similar to existing conditions, future development within the Specific Plan Area that trigger significant impacts under CEQA would be required to prepare Environmental Impact Reports and adopt statements of overriding consideration pursuant to CEQA Guidelines Section 15093.

1.3.2 Recreation Alternative
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. Conceptually, this alternative would involve the 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 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.

1.4 AREAS OF CONTROVERSY
Pursuant to CEQA Guidelines Section 15123(b), a summary section includes a discussion of potential areas of controversy known to the lead agency, including issues raised by agencies and the public during the scoping process. The following are the known potential areas of controversy:
 Land Use – impacts related to the proposed land use changes, including impacts on existing and future infrastructure and land use changes conflicting with other local planning documents, which could occur under the proposed project.
 Transportation – impacts related to increased vehicle miles traveled (VMT) and queueing near SR 180, compliance with Statewide Transportation and Climate Plans, compatibility of the proposed implementation of Fresno’s Active Transportation Plan, and existing circulation patterns.

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)
1-5
 Air Quality – impacts related to increased emissions related to the proposed project, including construction and operational emissions and the need for proper air quality analysis, mitigation, and compliance with applicable air quality plans, and sensitive receptors and their proximity to emissions sources.
 Greenhouse Gas (GHG) Emissions – impact on GHG emissions and the need for incorporating GHG reduction strategies into the proposed project.

1.5 PUBLIC REVIEW OF THE DRAFT EIR
Upon completion of this Draft EIR, the City of Fresno prepared and filed a Notice of Completion (NOC) with the California Office of Planning and Research/State Clearinghouse to begin the public review period (Public Resources Code, Section 21161) on August 15, 2025. Concurrent with the NOC, the City of Fresno distributed a Notice of Availability (NOA) in accordance with Section 15087 of the CEQA Guidelines. The NOA was mailed to the organizations and individuals who previously requested such a notice to comply with Public Resources Code Section 21092(b)(3). This Draft EIR was distributed to the Governor's Office of Land Use and Climate Innovation/State Clearinghouse in accordance with Section 15206 of the CEQA Guidelines. This Draft EIR was also published in the Fresno Bee newspaper to comply with Section 15087(a) of the State CEQA Guidelines and was distributed to affected agencies, surrounding cities and municipalities, and all interested parties.

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

City of Fresno
Planning and Development Department
2600 Fresno Street, Room 3065, Third Floor
Fresno, CA 93721
Monday through Friday: 8:00 a.m. to 5:00 p.m.

Saturday and Sunday: Closed
Fresno Central Library
2420 Mariposa Street
Fresno, CA 93721
Monday through Thursday: 10:00 a.m. to 7:00 p.m.

Friday and Saturday: 10:00 a.m. to 5:00 p.m.

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

Gillis Branch Library
629 West Dakota Avenue
Fresno, CA 93705
Monday through Thursday: 9:00 a.m. to 7:00 p.m.

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

Sunday: Closed.

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)
1-6
In addition, the Draft EIR, including the appendices, is available for review at the following City of Fresno website:
www.fresno.gov/tdsp
Agencies, organizations, individuals, and all other interested parties not previously contacted, or who did not respond to the NOP or attended the scoping meeting, currently have the opportunity to comment on this Draft EIR during the 45-day public review period. Written comments on this Draft EIR should be addressed to:

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

1.6 EXECUTIVE SUMMARY MATRIX
Table 1.A below summarizes the impacts, mitigation measures, and resulting level of significance after mitigation for the relevant environmental issue areas evaluated for the proposed project. The significance conclusions for the following sections are included for informational purposes, but are not included in the Draft EIR as they were screened out as having “no impact” or a “less than significant” impact in the Initial Study (Appendix C): aesthetics, agriculture and forestry resources, energy, geology and soils, 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. Table 1.A is intended to provide an overview; narrative discussions for the issue areas are included in the corresponding sections of this Draft EIR. Table 1.A is included in the Draft EIR pursuant to CEQA Guidelines Section 15123(b)(1).

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) 1-7
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

AES-3: The proposed project would not substantially
degrade the existing visual character or quality of public views of the site and its surroundings (public views are those that are experienced from publicly accessible vantage point), and due to the location of the project in an urbanized area, the project would not conflict with applicable zoning and other regulations governing scenic quality.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

AGRICULTURE AND FORESTRY
AG-1: The proposed project would not convert Prime
Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.

No Impact. No mitigation measur es are required. No Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

AG-3: The proposed project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or
No Impact. No mitigation measur es are required. No Impact.

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) 1-8
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
timberland zoned Timberland Production (as defined by
Government Code section 51104(g)).

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

No Impact. No mitigation measur es are required. No Impact.

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

No Impact. No mitigation measur es are required. No Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Potentially
Significant Impact.

Mitigation Measure AIR-1a
Prior to future discretionary approval for projects that require environmental evaluation under CEQA,
development project applicants shall prepare and
submit to the Director of the Planning and
Development Department, or designee, a technical
health risk assessment (HRA) evaluating potential
project construction phase-related air quality impacts.

The evaluation shall be prepared in conformance with
San Joaquin Valley Air Pollution Control District
(SJVAPCD) methodology for assessing construction
impacts. If construction-related air pollutants are
determined to have the potential to exceed the
SJVAPCD adopted threshold of significance, project
applicants for new development projects shall be
Less Than
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) 1-9
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
required to incorporate mitigation measures into
construction plans to reduce air pollutant emissions
during construction activities. Mitigation measures can include, but are not limited to:
 Maintain construction equipment and provide
current certificate(s) of compliance for CARB’s In-
Use Off-Road Diesel-Fueled Fleets Regulation
[CCR Title 13, Sections 2449 and 2449.1] to
SJVAPCD; and
 Maintain all construction equipment in proper
working condition according to manufacturer’s
specifications. The equipment must be checked
by a certified mechanic and determined to be
running in proper condition before it is operated.

Documentation of a certified mechanic’s
inspection and determinations shall be
maintained by the Construction Manager and
available for City inspection upon reasonable
request.

The identified measures shall be included as part of
the project Conditions of Approval. If the
recommendations of the HRA are insufficient to
reduce impacts to levels at or below SJVAPCD’s
threshold of 20 in one million, such development with
significant cancer risk (i.e., that exceed that threshold) shall be prohibited.

Mitigation Measure AIR-1b
Prior to future discretionary approval for projects that require environmental evaluation under CEQA, the
City of Fresno (City) shall evaluate new development
proposals for new industrial or warehousing land uses
that: (1) have the potential to generate 100 or more
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) 1-10
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
truck trips per day or have 40 or more trucks with
operating diesel-powered transport refrigeration
units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing
homes), as measured from the property line of the
project to the property line of the nearest sensitive
use. Such projects shall submit a HRA to the City
Department of Development and Resource
Management. The HRA shall be prepared in
accordance with policies and procedures of the most
current State Office of Environmental Health Hazard
Assessment (OEHHA) and the SJVAPCD. If the HRA
shows that the incremental health risks exceed their
respective thresholds, as established by the SJVAPCD
at the time a project is considered, the applicant will be required to identify and demonstrate that best
available control technologies for toxics (T-BACTs),
including appropriate enforcement mechanisms to
reduce risks to an acceptable level. T-BACTs may
include, but are not limited to:
 Restrict idling on site by shutting equipment off
when not in use or reducing idling time to 3
minutes as enforced by an identified compliance
officer within the construction crew. Idling
restrictions shall be enforced by highly visible
posting at the site entry, posting at other on-site
locations frequented by truck drivers,
conspicuous inclusion in employee training and
guidance material and owner, operator or tenant
direct action as required;
 Electrify warehousing docks to reduce diesel
particulate matter; Reque use of newer
equipment and/or vehicles;
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) 1-11
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
 Provide charging infrastructure for: electric
forklifts, electric yard trucks, local drayage trucks,
last mile delivery trucks, electric and fuel-cell
heavy duty trucks; and/or
 Install solar panels, zero-emission backup
electricity generators, and energy storage to
minimize emissions associated with electricity
generation at the project site.

T-BACTs identified in the HRA shall be identified as
mitigation measures in the environmental document
and/or incorporated into the site plan.

Mitigation Measure AIR-1c
Locate sensitive land uses (e.g., residences, schools,
and daycare centers) to avoid incompatibilities with
recommended buffer distances identified in the most
current version of the California Air Resources Board
(CARB) Air Quality and Land Use Handbook: A
Community Health Perspective (CARB Handbook).

Sensitive land uses that are within the recommended
buffer distances listed in the CARB Handbook shall
provide enhanced filtration units or submit an HRA to
the City. If the HRA shows that the project would
exceed the applicable SJVAPCD thresholds, mitigation
measures capable of reducing potential impacts to an
acceptable level must be identified and approved by
the City.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Potentially
Significant Impact.

Refer to Mitigation Measures AIR-1a, AIR-1b, and
AIR-1c.

Less Than
Significant Impact.

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) 1-12
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

BIOLOGICAL RESOURCES
BIO-1: The proposed project could have a substantial
adverse effect, either directly or through habitat
modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Potentially
Significant Impact.

Mitigation Measure BIO-1a: Avoidance Measures for
Bats.

1. A qualified biologist with experience in assessing
trees for bat roosts will survey all trees to be
removed during construction for suitability as bat
roosts. If a tree is deemed suitable, the qualified
biologist will conduct a night emergence survey
of the suitable roost tree 1 to 2 nights prior to
tree removal using night vision and/or infrared-
sensitive camera equipment and bioacoustic
recording equipment. If surveys are negative,
trees should be removed immediately.

2. If night emergent surveys are positive, trees
should be removed using a two-step process for 2
consecutive days and should be monitored by a
qualified biologist. On the first day, small
branches and small limbs that do not contain
potential roost habitat (e.g., cavities, crevices,
exfoliating bark) will be removed using
chainsaws. On the second day, the remainder of
the tree will be removed. The disturbance caused
by chainsaw noise and vibration, coupled with
the physical alteration of the tree will cause
colonial bat species to abandon the roost tree
after nightly emergence for foraging. Removing
the tree the next day prevents re-habituation and
re-occupation of the altered tree.

3. Any trees suitable as bat roost will be removed
during one of the following periods to avoid harm
to young or hibernating bats:

Less Than
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) 1-13
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
a) Between approximately March 1 and April
15 (or after evening temperatures rise above
45 degrees Fahrenheit [°F], and less than 0.5
inch of rainfall in 24 hours occurs).
b) After maternity season and prior to winter
torpor or hibernation, September 1 through
about October 15 (or before evening
temperatures fall below 45°F, and prior to
greater than 0.5 inch of rainfall within 24
hours).

Mitigation Measure BIO-1b: Pre-activity Nesting Bird
Surveys.

If future development and site-specific project
activities facilitated by the implementation of the
Specific Plan Update must occur during the nesting
season (February 15 to August 31), pre-activity nesting bird surveys will be conducted by a qualified biologist in accordance with the California Department of Fish
and Wildlife (CDFW) and/or the United States Fish and
Wildlife Service (USFWS) no more than 7 days prior to
the start of construction at the construction site, and a 250-foot buffer for songbirds and a 500-foot buffer for raptors (other than Swainson’s hawk [Buteo
swainsoni]) will be installed. If no active nests are
found, no further action is required; however, note
that nests may become active at any time throughout
the summer, including when construction activities
are occurring. If active nests are found during the
survey or at any time during future project
construction facilitated by implementation of the
Tower District Specific Plan Update, the project
proponent shall install an avoidance buffer ranging
from 50 feet to 350 feet will be required, as
determined by a qualified biologist. The avoidance
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) 1-14
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
buffer will remain in place until the biologist has
determined that the young are no longer reliant on
the nest. Work may occur within the avoidance buffer
under the approval and guidance of the biologist. The
qualified biologist will have the ability to stop
construction if nesting adults show signs of distress.

BIO-2: The proposed project could have a substantial
adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or US Fish and Wildlife Service.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

BIO-3: The project would have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

BIO-4: The project could interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

BIO-7: The project, in combination with other projects, could contribute to a significant cumulative impact related to biological resources.

Potentially
Significant Impact.

Refer to Mitigation Measures BIO-1a and BIO-1b. Less Than Significant Impact.

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

Potentially
Significant Impact.

Mitigation Measure CUL-1a
If previously unknown resources are encountered
before or during grading activities, construction shall Less Than
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) 1-15
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
stop in the immediate vicinity of the find and a
qualified historical resources specialist shall be
consulted to determine whether the resource requires
further study. The qualified historical resources
specialist shall make recommendations to the City of
Fresno (City) on the measures that shall be
implemented to protect the discovered resources,
including but not limited to excavation of the finds and evaluation of the finds in accordance with Section
15064.5 of the State CEQA Guidelines and the City’s
Historic Preservation Ordinance.

Appropriate measures for significant resources could
include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery
excavations of the finds.

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

Mitigation Measure CUL-1b
Prior to approval of any discretionary project that
could result in an adverse change to a potential
historic and/or cultural resource, the City shall require a site-specific evaluation of historic and/or cultural
resources by a professional who meets the Secretary
of the Interior’s Qualifications. The evaluation shall
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) 1-16
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
provide recommendations to mitigate potential
impacts to historic and/or cultural resources and shall be approved by the Director of Planning and
Development.

During project-specific environmental review of
development under the proposed plan, before altering
or otherwise affecting a building or structure that is 50 years old or older, the City shall require project
applicants to retain a qualified architectural historian meeting the Secretary of Interior's Professional
Qualifications Standards to record the building or
structure on a California Department of Parks and
Recreation DPR 523 form or equivalent
documentation, if the building has not previously been
evaluated. Its significance shall be assessed and
documented by a qualified architectural historian in
accordance with the significance criteria set forth for historic resources under CEQA Guidelines Section
15064.5. The evaluation process shall include the
development of appropriate historical background
research as context for the assessment of the
significance of the structure in the history of the City and the region. For buildings, structures, and other
resources determined through this evaluation process
not to meet the CEQA historical resource criteria, no
further mitigation is required. For any building,
structure, and or other resource that qualifies as a
historic resource, the architectural historian and the
future project-specific applicant shall consult to
consider measures that would enable projects under
the proposed plan to avoid direct or indirect impacts
to the historic building or structure. These could
include preserving the building on site, using it “as is,” or other measures that would not materially alter the
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) 1-17
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
historically significant components of the building or
structure. If the project cannot feasibly avoid
modifications to the historically significant features of the historic building or structure, the following
measures shall be undertaken as appropriate:
 If the building or structure can be preserved on-
site, but remodeling, renovation or other
alterations are required, this work shall be
conducted in compliance with The Secretary of
the Interior’s Standards for the Treatment of
Historic Properties with Guidelines for
Preserving, Rehabilitating, Restoring, and
Reconstructing Historic Buildings (NPS 2017).
 If a significant historic building or structure is
proposed for major alteration or renovation, or
to be moved and/or demolished, the City shall
ensure that a qualified architectural historian
thoroughly documents the building and
associated landscaping and setting.

Documentation shall include still and video
photography and a written documentary record
of the building to the standards of the Historic
American Building Survey or Historic American
Engineering Record, including accurate scaled
mapping, architectural descriptions, and scaled
architectural plans, if available. A copy of the
record shall be provided to the City. The record
shall be accompanied by a report containing site-
specific history and appropriate contextual
information. This information shall be gathered
through site specific and comparative archival
research, and oral history collection as
appropriate.

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) 1-18
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
If preservation and reuse at the site are not feasible, the historical building shall be documented as
described in item (2) and, when physically and
financially feasible, be moved and preserved or
reused.

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

Potentially
Significant Impact.

Mitigation Measure CUL-2
Subsequent to a preliminary City review of grading
plans for future development projects facilitated by
the Specific Plan Update, if there is evidence that a
project will include excavation or construction
activities within previously undisturbed soils, a field survey and literature search for prehistoric
archaeological resources shall be conducted. The
following procedures shall be followed.
 If prehistoric resources are not found during
either the field survey or literature search,
excavation and/or construction activities can
commence. In the event that buried prehistoric
archaeological resources are discovered during
excavation and/or construction activities,
construction shall stop in the immediate vicinity
of the find and a qualified archaeologist shall be
consulted to determine whether the resource
requires further study. The qualified
archaeologist shall make recommendations to
the City of Fresno on the measures that shall be
implemented to protect the discovered
resources, including but not limited to excavation
of the finds and evaluation of the finds in
accordance with Section 15064.5 of the State
CEQA Guidelines. If the resources are determined
to be unique prehistoric archaeological resources
as defined under Section 15064.5 of the State
CEQA Guidelines, mitigation measures shall be
Less Than
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) 1-19
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
identified by the monitor and recommended to
the City of Fresno. Appropriate measures for
significant resources could include avoidance or
capping, incorporation of the site in green space,
parks, or open space, or data recovery
excavations of the finds. No further grading shall
occur in the area of the discovery until the Lead
Agency approves the measures to protect these
resources. Any prehistoric archaeological artifacts
recovered as a result of mitigation shall be
provided to a City-approved institution or person
who is capable of providing long-term
preservation to allow future scientific study.

If prehistoric resources are found during the field
survey or literature review, the resources shall be
inventoried using appropriate State record forms and
submit the forms to the Southern San Joaquin Valley
Information Center. The resources shall be evaluated
for significance. If the resources are found to be
significant, measures shall be identified by the
qualified archaeologist. Appropriate mitigation
measures for significant resources could include
avoidance or capping, incorporation of the site in
green space, parks, or open space, or data recovery
excavations of the finds. In addition, appropriate
mitigation for excavation and construction activities in the vicinity of the resources found during the field
survey or literature review shall include an
archaeological monitor. The monitoring period shall
be determined by the qualified archaeologist. If
additional prehistoric archaeological resources are
found during excavation and/or construction
activities, the procedure identified above for the
discovery of unknown resources shall be followed.

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) 1-20
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
CUL-3: The project would not disturb any human remains, including those interred outside of dedicated cemeteries.

Potentially
Significant Impact.

Mitigation Measure CUL-3
In the event that human remains are unearthed during
excavation and grading activities of any future
development project, all activity shall cease
immediately. Pursuant to Health and Safety Code
(HSC) Section 7050.5, no further disturbance shall
occur until the County Coroner has made the
necessary findings as to origin and disposition
pursuant to Public Resources Code (PRC) Section
5097.98(a). If the remains are determined to be of
Native American descent, the coroner shall within 24
hours notify the Native American Heritage
Commission (NAHC). The NAHC shall then contact the
most likely descendent of the deceased Native
American, who shall then serve as the consultant on
how to proceed with the remains. Pursuant to PRC
Section 5097.98(b), upon the discovery of Native
American remains, the landowner shall ensure that
the immediate vicinity, according to generally
accepted cultural or archaeological standards or
practices, where the Native American human remains
are located is not damaged or disturbed by further
development activity until the landowner has
discussed and conferred with the MLDs regarding their
recommendations, if applicable, taking into account
the possibility of multiple human remains. The
landowner shall discuss and confer with the
descendants all reasonable options regarding the
descendants' preferences for treatment.

Less Than
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) 1-21
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
CUL-4: The project would not result in a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
 Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or
 A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of PRC Section 5024.1. In applying the
criteria set forth in subdivision (c) of PRC Section
5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Potentially
Significant Impact.

Refer to Mitigation Measures CUL-1a, CUL-1b, CUL-2,
and CUL-3.

Less Than
Significant Impact.

CUL-5: The project, in combination with other projects, could contribute to a significant cumulative impact related to cultural resources and tribal cultural resources.

Potentially
Significant Impact.

Refer to Mitigation Measures CUL-1a, CUL-1b, CUL-2,
and CUL-3.

Less Than
Significant Impact.

ENERGY
ENG-1: The proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during
project construction or operation.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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) 1-22
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

GEOLOGY AND SOILS
GEO-1: The proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known fault, strong seismic ground shaking, seismic-related ground
failure, or landslides.
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for the area or based on other substantial evidence of a known fault. Refer to Division of Mines and Geology Special Publication 42;
ii. Strong seismic ground shaking;
iii. Seismic-related ground failure, including liquefaction; or iv. Landslides.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

GEO-2: The project would not result in substantial soil erosion or the loss of topsoil.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

GEO-4: The project would not be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated), creating substantial direct or indirect risks to life or property.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

GEO-5: The project does not contain soils incapable of
adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not
available for the disposal of waste water.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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) 1-23
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
GEO-6: The proposed project could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Potentially
Significant Impact.

Mitigation Measure GEO-1: Paleontological/Geologic
Features
Subsequent to a preliminary City of Fresno review of
the project grading plans, if there is evidence that a
project will include excavation or construction
activities within previously undisturbed soils, a field survey and literature search for unique
paleontological/geological resources shall be
conducted. The following procedures shall be
followed:
 If unique paleontological/geological resources
are not found during either the field survey or
literature search, excavation and/or
construction activities can commence. In the
event that unique paleontological/geological
resources are discovered during excavation
and/or construction activities, construction shall
stop in the immediate vicinity of the find and a
qualified paleontologist shall be consulted to
determine whether the resource requires
further study. The qualified paleontologist shall
make recommendations to the City on the
measures that shall be implemented to protect
the discovered resources, including but not
limited to, excavation of the finds and evaluation
of the finds. If the resources are determined to
be significant, mitigation measures shall be
identified by the monitor and recommended to
the Lead Agency. Appropriate mitigation
measures for significant resources could include
avoidance or capping, incorporation of the site
in green space, parks, or open space, or data
recovery excavations of the finds. No further
grading shall occur in the area of the discovery
Less Than
Significant Impact.

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) 1-24
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
until the Lead Agency approves the measures to
protect these resources. Any paleontological/
geological resources recovered as a result of
mitigation shall be provided to a City-approved
institution or person who is capable of providing
long-term preservation to allow future scientific
study.
 If unique paleontological/geological resources
are found during the field survey or literature
review, the resources shall be inventoried and
evaluated for significance. If the resources are
found to be significant, mitigation measures
shall be identified by the qualified
paleontologist. Similar to above, appropriate
mitigation measures for significant resources
could include avoidance or capping,
incorporation of the site in green space, parks,
or open space, or data recovery excavations of
the finds. In addition, appropriate mitigation for
excavation and construction activities in the
vicinity of the resources found during the field
survey or literature review shall include a
paleontological monitor. The monitoring period
shall be determined by the qualified
paleontologist. If additional paleontological/
geological resources are found during
excavation and/or construction activities, the
procedure identified above for the discovery of
unknown resources shall be followed.

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

Potentially
Significant Impact.

Refer to Mitigation Measures GEO-1.

Less Than
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) 1-25
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

GREENHOUSE GAS EMISSIONS
GHG-1: The proposed project would result in a potentially significant impact related to GHG emissions.

Potentially
Significant Impact.

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
Less Than
Significant Impact.

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) 1-26
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
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 vehicles measures. The identified measures
shall be included as part of the conditions of approval.

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.

Potentially
Significant Impact.

Refer to Mitigation Measure GHG-1. Less Than
Significant Impact.

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

Potentially
Significant Impact.

Refer to Mitigation Measure GHG-1. Less Than
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) 1-27
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

HAZ-3: The project would not emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

HAZ-4: The project could be located on a site which is
included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a
result, would create a significant hazard to the public or the environment.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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) 1-28
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

HYD-2: The project would not substantially decrease
groundwater supplies or interfere substantially with
groundwater recharge such that the project may impede
sustainable groundwater management of the basin.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

HYD-3: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
 Result in a substantial erosion or siltation on- or off-site;  Substantially increase the rate or amount of surface
runoff in a manner which would result in flooding on- or off-site;
 Create or contribute runoff water which would exceed
the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of
polluted runoff; nor
 Impede or redirect flood flows.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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) 1-29
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

LU-2: The proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of
avoiding or mitigating an environmental effect.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

MINERAL RESOURCES
MIN-1: The proposed project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

MIN-2: The proposed project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

NOISE
NOI-1: The project could generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Potentially
Significant Impact.

Mitigation Measure NOI-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
Community Development Director. Measures shall be
implemented to reduce construction noise to the FTA
construction noise criteria or below if construction
Less Than
Significant Impact.

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) 1-30
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
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 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.

NOI-2: The project could generate excessive groundborne vibration or groundborne noise levels.

Potentially
Significant Impact.

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.

Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Potentially
Significant Impact.

Refer to Mitigation Measures NOI-1a, NOI-1b, and
NOI-2.

Less Than
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) 1-31
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

POPULATION AND HOUSING
POP-1: The proposed project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or
indirectly (for example, through extension of roads or other infrastructure).

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

POP-2: The proposed project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

PUBLIC SERVICES
PSR-1: The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities (fire protection, police protection, schools, and other public facilities), or the need for new or physically altered
governmental facilities.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

RECREATION
REC-1: The proposed project would not 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.

Potentially
Significant Impact.

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.

Significant and
Unavoidable
Impact.

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) 1-32
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
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.

REC-2: The proposed project would not increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be accelerated.

Potentially
Significant Impact.

Refer to Mitigation Measure REC-1a. Significant and
Unavoidable
Impact.

REC-3: The proposed project would not include recreational facilities or require the construction or expansion of
recreational facilities that might have an adverse physical effect on the environment.

Potentially
Significant Impact.

Refer to Mitigation Measure REC-1b. Significant and
Unavoidable
Impact.

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

Potentially
Significant Impact.

Refer to Mitigation Measures REC-1a and REC-1b. Significant and Unavoidable
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) 1-33
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

TRA-3: The proposed project would not substantially
increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

UTILITIES
UTL-1: The project would not require nor result in the
relocation or construction of new or expanded water,
wastewater treatment or storm water drainage, electric
power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

UTL-2: The project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry
years.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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) 1-34
Table 1.A: Executive Summary Matrix
Potential Environmental Impact
Level of
Significance
Before Mitigation
Mitigation Measures
Level of
Significance
After Mitigation
UTL-4: The project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

UTL-6: The project, in combination with other projects, would not contribute to a significant cumulative impact related to utilities and service systems.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

WF-2: The proposed project would not, due to slope,
prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

WF-3: The proposed project would not require the
installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the
environment.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

WF-4: The proposed project would not expose people or
structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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

Less Than
Significant Impact.

No mitigation measures are required. Less Than
Significant Impact.

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)
2-1

2.0 INTRODUCTION
The City of Fresno (City) proposes to update the Tower District Specific Plan (hereinafter referred to as the “proposed project” or “Specific Plan Update”), including the associated approvals and entitlements proposed by the City and included in the Specific Plan Update. For the proposed project, the Specific Plan Area encompasses the Tower District, which is centrally located within the City of 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 tracks to the west. 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.

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

California Government Code Section 65451 authorizes local jurisdictions to adopt specific plans “for the systematic implementation of the general plan for all or part of the area covered by the general plan.”
1 This EIR is intended to serve as an informational document for the public agency decision- makers
and the public regarding the potential environmental impacts associated with new regulatory areas not previously studied in the Tower District’s 1991 Specific Plan EIR,2 and updates previously studied areas to bring them up to date with modern regulations. In addition to identifying potential environmental impacts that were found to have potentially significant impacts, this EIR also provides a current regulatory framework and applicable mitigation measures.

This EIR is the primary reference document for the formulation and implementation of a mitigation monitoring program for the Specific Plan Update. Environmental impacts cannot always be mitigated to a level that is considered less than significant. In accordance with Section 15093(b) of the State CEQA Guidelines, if a lead agency such as the City of Fresno approves a project (i.e., text changes to the Specific Plan and implementation of the Specific Plan Update) that has significant impacts that are not substantially mitigated (i.e., significant unavoidable impacts), the lead agency 1 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). 2 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).

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)
2-2
shall state in writing the specific reasons for approving the project, based on the final CEQA documents and any other information in the public record for the project. This is termed in Section 15093 of the State CEQA Guidelines, “a statement of overriding considerations.” For the approved Specific Plan, the following impacts were found to be significant and unavoidable:
• Impacts related to parks and recreation
These impacts are discussed in more detail throughout Chapter 4.0 of this EIR.

2.2 TYPE OF EIR
The City is updating the 1991 Specific Plan to respond to issues in the Tower District that have remained, changed, and emerged. Recent decades have led to greater emphasis on housing availability and affordability, expanding recreational opportunities, and calming auto-oriented roadways. At the same time, the Specific Plan Update maintains the guiding principles from the 1991 Specific Plan and continues the focus on neighborhood character, walkability, and historic resources. As previously mentioned, the intent of this EIR is to describe the potential impacts associated with the implementation of the Specific Plan Update. A program-level EIR is appropriate for a series of actions that can be characterized as one large project and are related either:

1. Geographically,

2. As logical parts in the chain of contemplated actions,

3. In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or

4. As individual activities carried out under the same authorization statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

The use of this EIR provides an opportunity for a more exhaustive consideration of effects and alternatives than otherwise would be practical under a project-specific EIR. However, subsequent activities occurring as a result of program/project approval and certification of a program-level EIR must be further evaluated to determine whether or not an additional environmental document must be prepared. If an agency finds that no new effects could occur and that no new mitigation would be required, then the agency can determine that subsequent activities are covered under the EIR, and no further environmental documentation would be required. Conversely, an agency may determine that future projects could require the preparation of a new Initial Study, Mitigated Negative Declaration, or new EIR. If new environmental documentation is required, the EIR can be used to focus the scope of the subsequent environmental document (State CEQA Guidelines, Section 15168).

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)
2-3

2.3 ENVIRONMENTAL REVIEW PROCESS
The California Environmental Quality Act (CEQA) Public Resources Code (PRC) Section 21000, et seq., requires that a public agency prepare an EIR when the public agency finds substantial evidence that the project may have a significant effect on the environment (PRC Section 21080 (d)). The basic purposes of CEQA are to:

1. Inform governmental decision makers and the public about the potential significant environmental effects of proposed activities;

2. Identify the ways that environmental damage can be avoided or significantly reduced;

3. Prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible; and

4. Disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose if significant effects are involved.

In compliance with the State CEQA Guidelines, the City has taken steps to maximize opportunities for the public and other public agencies to participate in the environmental review process. The City conducted the scoping process, issued a Notice of Preparation (NOP) for the proposed project, and determined that an EIR was required to evaluate the potentially significant environmental effects of the proposed project and related actions. In addition, a public scoping meeting was held, as discussed further below.

2.3.1 Notice of Preparation
The scope of this EIR includes issues identified by the City of Fresno during the preparation of the NOP for the proposed project. The NOP was prepared in accordance with Section 15082 of the State CEQA Guidelines. The purpose of the NOP is to provide the responsible and trustee agencies and the Governor’s Office of Planning and Research with sufficient information describing the project and the potential environmental effects to assist the agencies to provide a meaningful response.

The NOP was circulated for agency review as well as public review on May 7, 2025 (see Appendix A).

In addition, a public notice of the NOP and a Notice of Public Scoping Meeting were published in the Fresno Bee on May 7, 2025. Responses to the NOP were requested within 30 days after receiving the NOP, or no later than June 9, 2025. Copies of written comments received in response to the NOP are included in Appendix B.

In accordance with the State CEQA Guidelines, Section 15082, the NOP was circulated to responsible agencies and individuals for a period of 30 days, during which time written comments were solicited pertaining to environmental issues and topics that the Draft EIR should evaluate.

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)
2-4
Responses to the NOP were received from the following agencies:
• California Department of Transportation, District 6
• Fresno Metropolitan Flood Control District
• San Joaquin Valley Air Pollution Control District
• Native American Heritage Commission
The following persons/organizations submitted written comments on the NOP:
• Shehadey Enterprise Solutions
Key environmental issues and concerns raised in response to the NOP scoping process included:
• Land Use: Commenters expressed concerns about impacts related to the proposed land use changes, including impacts on existing and future infrastructure, which could occur under the proposed project. Commenters expressed concerns about land use changes conflicting with other local planning documents which were analyzed based on land uses outlined in the 2014 Fresno General Plan.3 Impacts related to Land Use are discussed in the Initial Study attached as Appendix C of this EIR and were determined to be less than significant. • Transportation: Commenters expressed concerns about transportation-related impacts, particularly increased vehicle miles traveled (VMT) and queueing near SR 180, as well as the proposed project’s compliance with Statewide Transportation and Climate Plans. Additional concerns were raised regarding the compatibility of the proposed implementation of Fresno’s Active Transportation Plan, and existing circulation patterns. Impacts related to Transportation are discussed in the Initial Study attached as Appendix C of this EIR, and were determined to be less than significant.
• Air Quality: Commenters expressed concerns about increased emissions related to the proposed project, including construction and operational emissions and the need for proper air quality analysis, mitigation, and compliance with applicable air quality plans. Additionally, commenters expressed concerns about sensitive receptors and their proximity to emissions sources. These issues are addressed in Section 4.1, Air Quality. Impacts related to Air Quality were determined to be less than significant with mitigation incorporated. • Greenhouse Gas (GHG) Emissions: Commenters expressed concerns about the proposed project’s impact on GHG emissions and the need for incorporating GHG reduction strategies into the proposed project. These issues are addressed in Section 4.4, Greenhouse Gas Emissions.

Impacts related to GHG emissions were determined to be less than significant with mitigation incorporated.
3 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 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)
2-5
Please note that these are not exhaustive lists of areas of controversy, but rather key issues that were raised during the scoping process. Appendix A includes the NOP, and Appendix B includes copies of written comments received in response to the NOP.

2.3.2 Scoping Meeting
Since the proposed project includes amending the text of the Specific Plan, the project is considered to be of regional or area-wide significance in accordance with Section 15206 of the State CEQA Guidelines. For projects of regional or area-wide significance, at least one scoping meeting is required as identified in Section 15082(c) (1) of the State CEQA Guidelines. During the agency and public review period for the NOP, the City of Fresno held a public scoping meeting on May 27, 2025, at the Fresno City Hall, 2600 Fresno Street, Room 2120, Fresno, CA 93721. No comments were received from the public, State agencies, or other interested parties at the public scoping meeting.

2.3.3 Effects Determined to be Potentially Significant
Based on the previous analysis as well as the comments that were received during the scoping process, the following environmental issues are addressed in the EIR:
• Air Quality
• Biological Resources
• Cultural Resources
• Greenhouse Gas Emissions
• Noise
• Recreation

2.4 ORGANIZATION OF THIS DRAFT EIR
This EIR is organized into the following chapters, which contain the contents of an EIR as required by Sections 15120 through 15132 of the State CEQA Guidelines. • Chapter 1.0: Executive Summary. This chapter provides a summary of the proposed project and the project alternatives that will be addressed in the Draft EIR, including a summary table of project and cumulative impacts, recommended mitigation measures, and the level of significance after mitigation for each environmental issue. This chapter includes the project and cumulative issues addressed in Chapter 4.0, Evaluation of Environmental Impacts. • Chapter 2.0: Introduction. This chapter includes an introduction and overview describing the purpose of this Draft EIR, along with its scope and components. • Chapter 3.0: Project Description. This chapter provides a detailed description of the project, including the location and project characteristics. A discussion of the intended uses of this Draft EIR, project background, project objectives, and project approvals needed for the project are also included.
• Chapter 4.0: Evaluation of Environmental Impacts. This chapter provides an overview of the project and cumulative environmental setting. The project setting focuses on the environmental 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)
2-6
conditions within the Specific Plan Area. The cumulative setting identifies the environmental conditions within the cumulative study area.

This chapter is divided into six sections that are organized into major topical areas that provide analysis of the potentially significant environmental impacts associated with the proposed project. Each topical section includes a description of the environmental setting, regulatory setting, significance criteria, project impacts, cumulative impacts, mitigation measures, and level of significance after mitigation.
• Chap
ter 5.0: CEQA-Requi
red. This chapter provides a summary of significant environmental impacts, including those that are significant prior to mitigation, significant and unavoidable, growth-inducing, and irreversible impacts.
• Chap
ter 6.0: Alternatives. This chapter includes a discussion of potential alternatives that could meet the basic objectives of the project and reduce potential significant environmental impacts of the proposed project.
• Chapter 7.0: Report Preparation. This chapter provides a list of the organizations who prepared this Draft EIR, and a listing of the references used to prepare this Draft EIR. • Appendices. The appendices contain the NOP, comments on the NOP, Initial Study, and the technical studies and information that were prepared and used to support the analyses and conclusions in this EIR.

The Final EIR will be prepared after the public review period for this Draft EIR has been completed.

The Final EIR will include comments and recommendations received on the Draft EIR during the public review period; a list of persons, organizations, and public agencies commenting on the Draft EIR; written responses to significant environmental issues identified in the comments received; and any other information added by the City of Fresno.

2.5 PROJECT APPLICANT AND LEAD, RESPONSIBLE, AND TRUSTEE AGENCIES The project Applicant and lead agency for the proposed project is the City of Fresno. The City is the public agency that has the principal responsibility for certifying the Draft EIR, approving and carrying out the project, or disapproving the project.

The responsible agencies are State and local public agencies other than the lead agency that have authority to carry out or approve a project or that are required to approve a portion of a project for which the lead agency is preparing or has prepared an EIR or Negative Declaration. There are no agencies other than the City of Fresno that have approval or permitting authority for the adoption of the Specific Plan Update. Implementation of the proposed project would involve many responsible agencies depending upon the specifics of the subsequent projects. Following are some of the agencies that could be required to act as responsible agencies for subsequent projects:

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)
2-7
• California Department of Transportation (Caltrans), including the Division of Aeronautics • California Air Resources Board (CARB)
• California Department of Conservation (DOC)
• California Department of Fish and Wildlife (CDFW)
• California Department of Forestry and Fire Protection (CAL FIRE) • California Department of Housing and Community Development (HCD) • California Department of Parks and Recreation (DPR)
• California Department of Toxic Substances Control (DTSC) • California Public Utilities Commission (CPUC)
• California State Office of Historic Preservation (OHP) • California State Lands Commission (SLC)
• California State Water Resources Control Board (SWRCB) • Central Valley Regional Water Quality Control Board (Central Valley RWQCB) • Fresno Airport Land Use Commission (Fresno ALUC)
• Fresno Metropolitan Flood Control District (FMFCD)
• Fresno Irrigation District (FID)
• Fresno Unified School District (FUSD)
• San Joaquin Valley Air Pollution Control District (SJVAPCD) • Any Other Responsible or Trustee Agency that may need to provide discretionary approval The trustee agencies under CEQA are public agencies with legal jurisdiction over natural resources that are held in trust for the people of California and that would be affected by a project, whether or not the agencies have authority to approve or implement a project. It is anticipated that development under the approved Specific Plan could affect lands under the jurisdiction of a Trustee Agency such as the California Department of Fish and Wildlife, the California State Lands Commission, and the California State Department of Parks and Recreation.

2.6 REVIEW OF THIS DRAFT EIR
Upon completion of this Draft EIR, the City of Fresno prepared and filed a Notice of Completion (NOC) with the Governor’s Office of Planning and Research/State Clearinghouse to begin the public review period (Public Resources Code, Section 21161). Concurrent with the NOC, the City of Fresno distributed a Notice of Availability (NOA) in accordance with Section 15087 of the State CEQA Guidelines. The NOA was mailed to the organizations and individuals who previously requested such a notice to comply with Public Resources Code Section 21092(b)(3). This Draft EIR was distributed to the Governor’s Office of Planning and Research/State Clearinghouse and the Fresno Council of Governments in accordance with Section 15206 of the State CEQA Guidelines. This Draft EIR was also published in the Fresno Bee newspaper to comply with Section 15087(a) of the State CEQA Guidelines and was distributed to affected agencies, surrounding cities and municipalities, and all interested parties. During the public review period, this Draft EIR, including the appendices, is available for review at the following locations:

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)
2-8
City of Fresno
Planning and Development Department
2600 Fresno Street, Room 3065, Third Floor
Fresno, CA 93721
Monday through Friday: 8:00 a.m. to 5:00 p.m.

Saturday and Sunday: Closed
Fresno Central Library
2420 Mariposa Street
Fresno, CA 93721
Monday through Thursday: 10:00 a.m. to 7:00 p.m.

Friday and Saturday: 10:00 a.m. to 5:00 p.m.

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

Gillis Branch Library
629 West Dakota Avenue
Fresno, CA 93705
Monday through Thursday: 9:00 a.m. to 7:00 p.m.

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

Sunday: Closed.

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

LSA
3-1

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)

3.0 PROJECT DESCRIPTION
This following describes the proposed updates to the Tower District Specific Plan Update (proposed project or Specific Plan Update), and associated approvals and entitlements proposed by the City of Fresno (City) and included in the Specific Plan Update. The City is the California Environmental Quality Act (CEQA) lead agency and has final authority to approve the proposed project and certify the Environmental Impact Report (EIR).

3.1 PROJECT LOCATION
The City of Fresno is located in Fresno County in the central San Joaquin Valley, approximately 200 miles north of Los Angeles and 170 miles south of Sacramento. The Tower District (District) is an approximately 1,869-acre area located immediately north of Downtown Fresno and the State Route (SR) 180 freeway, and one mile east of the SR-99 corridor. Figure 3-1, Regional Location and Local Vicinity, shows the City of Fresno in its regional context. To the north of Fresno is Madera County, to the northeast and adjacent to Fresno is the City of Clovis, and unincorporated land is located to the east, south, and west of Fresno.

The Tower District Specific Plan Area (Specific Plan Area) for the proposed project encompasses the Tower District, which is centrally located within Fresno and is home to approximately 20,200 residents. The District is generally bound by Shields Avenue to the north, Blackstone Avenue to the east, SR-180 to the south, and Fruit Avenue and the Union Pacific Railroad tracks to the west. Figure 3-2, Project Location, shows the location of the Specific Plan Area within the City. The District is the geographic area for which the Specific Plan Update establishes policies conservation, future growth, and change, and conservation.

3.2 PROPOSED 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 both neighborhood conservation and 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 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.

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)
3-2
This page intentionally left blank

LSA
LSA
$
7500 15000
FEET
SOURCE: Esri World Imagery (2025)
c::J Tower District Boundary
County Boundary
D City of Fresno
D City of Clovis
l:\2024\20241643\GIS\Pro\Tower District Specific Plan Update\Tower District Specific Plan Update.aprx (7/14/2025) FIGURE 3-1
Tower District Specific Plan Update
Regional Location and Local Vicinity

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)
3-4
This page intentionally left blank

LSA
Q) z
f-
z
s Ave
W Cornell Av
W Princeton Ave
Harvard Ave
n Ave
W Yale Ave
ley Ave
Q)
> <{
0 1,, tz,.

C
Q)
0 (90
z 19,.._
"11,,
(9
ive Ave
Reeding Park
nt
I Pa rk
WO
1,, ti,
($)
Q)
>
<{
:::, ,._
LL
z
> <{ Q)
C ,._ ,._
:::, 0 ..c ..., ..c
<{ z z
Q)
>
<{
Q) ,._
:::, >
..c <{
t'. Q)
<{ C ,._
z 0
..c
f-
z
ive Ave
<{ >
<t
C
0 E en Q)
,._ ro >
<ti <{
I z Q)
Ol
z Q)
E Cornell Ave 0
u
z
E Princeton Ave
E Harvard Ave
E Clinton Ave
E Yale Ave
E Weldon Ave
Q)
> <{
<ti
2 <ti
E McKinley Ave ~
z
Q) Q)
Q) > >
Q) Q) <{ > <{
> > <{ Q)
<{ <t
C
0 0 Ol
C
E
en ..c Q)
0 u
en s w 0 ,._ ro u ,._ a.. z z
<ti z I z
z
E Olive Ave Q)
> <{
en
E Dennett Ave en
Q)
z
C
E Dudley Ave
<ti
>
z
E Thomas Ave
E Divisadero St
LSA c::J Tower Distri ct Boundary
850 1700
FEET
SOURCE: Esri Outdoor Contour Map (2025)
l:\2024\2024 1643\G IS\Pro\Tower Dist ri ct Specifi c Plan Update\ Towe r Distr ict Specific Plan Update.aprx (7/14/2025) Q)
> <{
,._
<ti

0..
0 a..
z
Q)
> Q)
Hernd <{ >
<{ Cana ,._
<ti C
~ C
Q)
Q)
...,
~ V)
0 Q)
z z '-+= '+-
E w
z
E Harvard Ave
E Yal Ave
Fresno City
College E University Ave
z
0 )>
<
(D
...,
V)
<ti ...,
en
Q) Q)
> ..c
f-<{
C z
C
Q)
~
z
I
U)~
z
Q)
>
<{
C
C
Q) E McKenzie Ave
~
z
"'I.

FIGURE 3-2
Tower District Specific Plan Update
Project Location

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)
3-6
This page intentionally left blank

LSA
3-7

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)

3.3 TOWER DISTRICT EXISTING CHARACTERISTICS
Established in the early 20th-century as a streetcar suburb, the Tower District is built on a combination of walkable streets and a diversity of places for entertainment and leisure. It has established itself as a highly livable place within the city that offers a mix of multi-family and single- family housing, small businesses, industrial employers, schools, and parks. The District is one of Fresno’s leading cultural and entertainment districts and is distinguished by its vibrant and diverse community, encompassing a rich mosaic of ethnic groups, families, singles, retirees, students, artists, and workers from various professions. Annual community events underscore strong community engagement and pride, which nurtures a deep sense of belonging.

The Specific Plan Area is home to a diverse population of approximately 20,200 residents, with approximately 17 percent of residents identifying as belonging to two or more races and over 50 percent identifying as Hispanic or Latino. 1 It is home to a mix of long-time residents, young professionals, artists, and families who all contribute to the cultural mosaic. Approximately 21 percent of residents are under the age of 18, 32 percent are between the ages of 35 and 59, and 21 percent of residents are 60 or older.

Existing land use patterns within the Specific Plan Area are typical of an American streetcar suburb allowing residents to walk to their destination or to public transit stops. Because of this, commercial corridors developed along the paths where streetcar lines previously existed, such as along Fulton, Olive, Belmont, Wishon, and Blackstone Avenues. While some commercial areas have retained their pedestrian-oriented design, many sites have been redeveloped over time to reflect an auto-oriented design.

As shown on Figure 3-3, Existing General Plan Land Uses, land uses within the Specific Plan Area include single-family residential uses, which comprise over half of the land area, medium density residential uses, high density residential uses, public uses such as schools, parks and recreation sites, and light industrial uses, which are generally confined to the southwest edge of the District.

The Specific Plan Area 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 Union Pacific Railroad line and Golden State Boulevard.

The Specific Plan Area is served by the Fresno Unified School District, as well as the State Center Community College District. Public schools within the Specific Planning Area include Dailey Elementary School, Heaton Elementary School, Muir Elementary School, and Susan B. Anthony Elementary School, Hamilton Middle School, and Fresno High School. Additionally, Fresno City College is centrally located within the Specific Plan Area and provides a range of post-secondary opportunities for District residents.

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 March 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)
3-8
This page intentionally left blank

LSA
J !
; ... 1 '
t°mellAve
• -Pnnceton Ave
111111111 = =
HaNardAve
1111111 = = =
Clinton Ave - -
-
Yale Ave
11111111111
1111111=
Weldon Ave
University Ave
McKinley
Home Ave 1111111
Floradora Ave
Hedges Ave
Olive Ave
Belmont Ave
Franklin Ave
Dry Creek Canal
LSA
$

0.2 0.4
MILES
-
l:\2024\20241643\G\Existing_LandUse .ai (8/13/2025)
~
[
• ,!l!
~
Herrdon Canal
Shields Ave
Cornell Ave
Princeton Ave
,o~'O'l><b •
.,,,,-/" ♦ "'
't-'Jl.,')c;,;.,,,,,,
.,o./
if <' f
I g z
~ ~
~
I r
£ ~ I f ! i !
~
~
2: 0
li'
~
I
. - • .I
.-
~ : ~ Project Boundary
Public Facilities
- Commercial - Community
- Commercial - General
- Commercial - Main Street
- Employment - Light Industrial
- Employment - Office
- Neighborhood Mixed-Use
- OpenSpace
Residential - Medium Density
- Residential - Medium High Density
- Residential - Urban Neighborhood
- Residential - High Density
FIGURE 3-3
Tower District Specific Plan Update
Existing General Plan Land Uses

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)
3-10
This page intentionally left blank

LSA
3-11

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)
The Tower District currently contains approximately 8 acres of park land at five sites. The Ted C.

Willis Community Center and San Pablo Park are located in the southeast corner of the Specific Plan Area, Broadway Parque is located in the south-central area, and Trolley Park is centrally located within the District, along with the Van Ness Boulevard Greenbelt. Additionally, Lafayette Park is located just outside the District to the northeast, and Roeding Regional Park is immediately west of the District across the Union Pacific Railroad line and Golden State Boulevard.

Other community facilities include the Ted C. Willis Community Center, several churches, and a senior center. The Gillis Branch of the Fresno County Public Library is located northwest of the Specific Plan Area and serves the District.

3.3.1 Land Uses
The Fresno General Plan, adopted in 2014, includes land use patterns and policies that encourage infill development and revitalization of older neighborhoods. The following provides a description of the General Plan land use categories that are utilized in the Tower District Specific Plan.

3.3.1.1 Residential
Residential land use provides for a wide range of neighborhoods and housing types.

Residential land uses also allow as permitted uses neighborhood‐serving community facilities such as parks, churches, schools, family daycare, libraries, community gardens, and farmers markets.

Residential uses are designated by density as follows:

Medium Low Density. The Medium Low Density designation is intended to provide for single‐family detached housing with densities of 3.5 to 6 units per acre.

Medium Density. Medium Density residential covers developments of 5 to 12 units per acre and is intended for areas with predominantly single‐family residential development, but can also accommodate a mix of housing types, from small‐lot starter homes, zero‐lot‐line developments, and duplexes, to townhouses. Many of the City’s existing neighborhoods fall within this designation.

Medium High. Medium High Density residential is intended for neighborhoods with a mix of single‐ family residences, townhomes, garden apartments, and multi‐family units intended to support a fine‐grain, pedestrian scale. This land use accommodates densities from 12 to 16 units per acre overall. Individual parcels may have densities outside of that range as long as a master planned neighborhood has an average density that conforms.

High Density. High Density residential is intended to accommodate attached homes, two‐ to four‐ plexes, and apartment buildings, supported by walkable access to frequent transit, retail and services, and community facilities such as parks and schools. High Density allows for 30 to 45 units per acre.

Urban Neighborhood. Urban Neighborhood residential covers densities from 16 to 30 units per acre, which will require multi‐family dwellings but still allows for a mix of housing types including single‐family houses. This land use is intended to provide for a compact community that includes 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)
3-12
community facilities and walkable access to park land and commercial services, and supports efficient, frequent transit service. Urban Neighborhood is designated for targeted areas with complementary land uses adjacent.

3.3.1.2 Commercial
Commercial land use designations allow a wide range of retail and service establishments intended to serve local and regional needs. Commercial Main Street is the only commercial zone district in the Tower District that allows residential with a commercial component.

Main Street. Main Street commercial encourages a traditional “Main Street” character with active storefronts, outdoor seating, and pedestrian‐oriented design. This designation promotes primarily one- to two-story retail uses, with moderate office and residential as supportive uses. It also preserves small‐scale, fine‐grain character in neighborhoods where single‐family residential and townhomes are predominant. The maximum Floor Area Ratio (FAR) is 1.0. A FAR is the ratio of a building's total floor area to the size of a site. An example is a 3‐acre site with a 1.0 FAR that could have up to approximately 130,000 square feet of floor area within a building (equivalent to 3 acres or one-to-one ratio).

Community. Community commercial is intended for pedestrian‐oriented commercial development that primarily serves local needs such as convenience shopping and offices. Many of the City’s current commercial districts fall into this designation. Specific uses allowed include medium‐scale retail, office, civic and entertainment uses, supermarkets, drug stores and supporting uses. The maximum FAR is 1.0.

General. This designation is intended for a range of retail and service uses that are not appropriate in other areas because of higher volumes of vehicle traffic and potential adverse impacts on other uses. Development such as strip malls would fall into this designation. Examples of allowable uses include building materials, storage facilities with active storefronts, equipment rental, wholesale businesses, and specialized retail not normally found in shopping centers. The maximum FAR is 2.0.

3.3.1.3 Employment
Office. The Office land use designation is intended for administrative, financial, business, professional, medical, and public offices. This designation is mainly intended to apply to existing office uses on smaller lots, generally located on arterial roadways. This designation is also considered compatible with existing residential neighborhoods given the smaller level of noise and traffic generation as compared to commercial uses. Retail uses would be limited to business services and food services and convenience goods for those who work in the area. The maximum FAR is 2.0.

Light Industrial. The Light Industrial designation accommodates a diverse range of light industrial uses, including limited manufacturing and processing, research and development, fabrication, utility equipment and service yards, wholesaling, warehousing, and distribution activities. Small‐scale retail and ancillary office uses are also permitted. Light Industrial areas may serve as buffers between Heavy Industrial and other land uses and otherwise are generally located in areas with good transportation access, such as along railroads and freeways. The maximum FAR is 1.5.

LSA
3-13

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)

3.3.1.4 Mixed Use
Mixed‐use land use designations are based on commercial uses and require a residential component.

Neighborhood Mixed Use. This designation provides for mixed‐use districts of local‐serving, pedestrian‐oriented commercial development, such as convenience shopping and professional offices in two‐ to three‐story buildings. Development is expected to include ground-floor neighborhood retail uses and upper‐level housing or offices, with a mix of small lot single-family houses, townhomes, and multi‐family dwelling units on side streets, in a horizontal or vertical mixed‐use orientation. The built form will have a scale and character that is consistent with pedestrian‐orientation, to attract and promote a walk‐in clientele, with small lots and frequent roadway and pedestrian connections permitting convenient access from residences to commercial space. Automobile‐oriented uses are not permitted. The minimum density is 12 units per acre and the maximum FAR is 1.5. NMX has no maximum density, but height is limited to 40 feet.

Corridor/Center Mixed Use. The Corridor/Center Mixed Use designation is higher intensity than Neighborhood Mixed Use and is intended to allow for either horizontal or vertical mixed‐use development in multiple story buildings along key circulation corridors in the city where height and density can be easily accommodated. Ground‐floor retail and upper‐floor residential or offices are the primary uses, with personal and business services and public and institutional space as supportive uses. Development will facilitate the transformation of existing transportation corridors into vibrant, highly walkable areas with broad, pedestrian‐friendly sidewalks, trees, landscaping, and local‐serving uses with new buildings that step down in relationship to the scale and character of adjacent neighborhoods. This designation will largely apply along arterial streets, at targeted locations between regional activity centers. The minimum residential density is 16 units per acre with minimum 40 percent residential uses, and the maximum FAR is 1.5. CMX has no maximum density, but height is limited to 60 feet.

3.3.1.5 Open Space
These designations apply to open space areas that are not parks or trails, such as riparian corridors, the clear zone around Fresno‐Yosemite International Airport, and the San Joaquin River bottom, which is primarily designated as open space even though it includes a limited number of existing homes. Within open space, there is a Multi‐Use designation that is located along the San Joaquin River Corridor that allows parks, open space, bathrooms, launch areas for canoes, parking, and sand/gravel facilities.

3.3.1.6 Public Facilities
These designations apply to lands owned by public entities, including City Hall and other City buildings, county buildings, schools, colleges, the municipal airport and hospitals. They also include public facilities such as fire and police stations, City‐operated recycling centers and sewage treatment facilities. In addition, these designations apply to public facilities, including neighborhood, community and regional parks, recreational centers, and golf courses. It also applies to multi‐ 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)
3-14
purpose trails that serve both regional and neighborhood level needs, some of which are paved while others, in particular those found along the San Joaquin River Bluff Environs, may be unpaved.

The existing General Plan land use designations in the Specific Plan Area include a mix of residential, commercial, public institutions, and pockets of industrial uses. Table 3.A, below, provides a summary of the existing non-residential square-footage and residential units within the District.

According to U.S. Census Bureau data, there are currently 7,336 residential units and 3,089,407 square feet of non-residential area within the Specific Plan Area.

Table 3.A: Existing General Plan Land Uses
Land Use Area (sq ft) Residential Units
Residential - Medium Density 7,516,813 5,893
Residential - Medium High Density 189,231 237
Residential - High Density 3,432 5
Residential - Urban Neighborhood 210,968 211
Commercial - Main Street 1,853,282 623
Commercial - Community 172,032 3
Commercial - General 15,538 0
Employment - Office 115,243 44
Employment - Light Industrial 422,229 24
Neighborhood Mixed-Use 365,254 169
Open Space 87,094 95
Public Facility 58,735 32
TOTAL 11,009,851 7,336
Source: U.S. Census Bureau Data (2020).

3.3.2 Zoning
Based on the City’s Citywide Development Code Chapter of the Municipal Code (Chapter 15 of the Municipal Code),
2 the Specific Plan Area contains the following zoning districts:
• Residential Single-Family, Medium Density (RS-5)
• Residential Multi-Family, Medium High Density (RM-1)
• Residential Multi-Family, Urban Neighborhood (RM-2)
• Residential Multi-Family, High Density (RM-3)
• Commercial Main Street (CMS)
• Commercial Community (CC)
• Commercial General (CG)
• Office (O)
• Light Industrial (IL)

2 City of Fresno. 2025. Municipal Code. Website: https://library.municode.com/ca/fresno/codes/code_of_ ordinances?nodeId=14478 (accessed March 24, 2025).

LSA
3-15

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)
• Neighborhood Mixed-Use (NMX)
• Park and Recreation (PR)
• Public and Institutional (PI)

3.4 EXISTING SPECIFIC PLAN
California Government Code Section 65450 authorizes local jurisdictions to adopt specific plans “for the systematic implementation of the general plan for all or part of the area covered by the general plan.”3 The existing Tower District Specific Plan (1991 Specific Plan)4 was adopted in 1991 in response to incompatible development within the City in the latter half of the 20th century. The 1991 Specific Plan emphasized conservation and historic preservation that remains an important focus of the Specific Plan Update.

Since the previous Tower District Specific Plan was adopted in 1991, several amendments and updates to the City’s General Plan have occurred, and new local, State, and/or federal regulations have been enacted. This proposed project analyzes new regulatory areas not previously studied in the 1991 Specific Plan, and updates previously studied areas to bring them up to date with modern regulations. Additionally, the existing Tower District Design Guidelines were adopted in 2005, and are proposed to be replaced and updated by the Tower District Standard and Guidelines as part of the proposed project. The updated Design Standards and Guidelines reflect the policy direction of the Specific Plan Update and are intended to result in compatible development.

3.5 PROJECT OBJECTIVES
Like the 1991 Specific Plan, the Specific Plan Update is divided into seven chapters: Introduction, Conservation and Historic Preservation, Land Use, Parks and Open Spaces, Circulation, Utilities, and Implementation, which are described in detail below. A set of objectives and policies are provided in Chapters 2 through 6, and implementing actions are provided in Chapter 7. Seven guiding principles have been formulated to guide the Specific Plan Update’s policy approach, some retained from the 1991 Specific Plan, representing the continuity of values and needs in the District. These principles are:

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.

3 State of California Government Code. 1985. Article 8. Specific Plans [65450 - 65457]. Website:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&section Num=65451.&article=8.&highlight=true&keyword=Specific%20Plan (accessed February 12, 2025). 4 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).

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)
3-16

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.

6. Increase opportunities for recreation within walking distance of Tower District residents.

7. Promote environmental sustainability and climate resilience.

3.6 SPECIFIC PLAN UPDATES
The proposed project would update the 1991 Specific Plan to respond to both continuing and new issues in the Tower District. Recent decades have led to greater emphasis on housing availability and affordability, expanding recreational opportunities, and calming auto-oriented roadways. At the same time, the Specific Plan Update maintains the guiding principles from the 1991 Specific Plan and continues the focus on neighborhood character, walkability, and historic resources.

The Specific Plan Update was drafted by City staff and consultants after engaging the community throughout the planning process. The community engagement process included public meetings, community workshops, stakeholder interviews, and online surveys. The Specific Plan Update identifies issues, explores options, formulates recommendations, establishes priorities, and cultivates a sense of shared stewardship by both the City and Tower District residents. Additionally, a new Specific Plan Implementation Committee, which is comprised of District residents and included members who helped inform the 1991 Specific Plan, brought a deep knowledge of the planning area and its issues and had a strong hand in formulating the Specific Plan Update’s objectives and policies.

During the planning process, emphasis was placed on health and equity within the Specific Plan Area. Health and equity underpin the objectives, policies, and focus areas which are designed to have positive health and equity outcomes. As a planning outcome, health reflects a state of physical, mental, and social well-being. Equity gives every individual an equal opportunity to make the most of their lives by eliminating barriers. In order to effectively analyze the state of health and equity within the District, six broad categories were studied: Housing Stability, Access to Jobs, Active Lifestyle, Access to Healthy Food, Environmental Comfort, and Air Quality.

3.6.1 Conservation and Historic Preservation
As established in the 1991 Specific Plan, the proposed project still maintains a focus on conservation and historic preservation. The Tower District’s established character is an important facet of the Specific Plan Area and reflects influential periods such as walkable streetcar suburban tracts developed in the early 20th century. There are over 300 identified historic resources with the city, and 44 lie within the Specific Plan Area.5 Older buildings and other features within the District, including the District’s namesake Tower Theatre, have been formally designated as local landmarks

5 Historic Fresno. 2020. A Guide to Historic Architecture in Fresno, California. Website: https://www.historic fresno.org/home.htm (accessed February 10, 2025).

LSA
3-17

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)
with a few also listed in the National Register of Historic Places.6 Additionally, the District is home to two formally designated historic districts: the Porter Tract and Wilson Island districts.7 Other areas and distinct features within the District have been identified in the Specific Plan Update as potentially eligible for further analysis including: Wilson’s North Fresno Tract, the Terrace Gardens, Adoline-Palm, Lower Fulton-Van Ness, and the Courts Thematic Group.8 The Specific Plan Update would allow for continued infill development that would connect public spaces, community life, and support local shops while reinforcing the District’s historic sense of place. The Specific Plan Update seeks to maximize the benefits of preservation and use of historic resources within the District to guide planning decisions and protect resources.

3.6.2 Land Use
The Land Use chapter of the Specific Plan Update considers existing and proposed future uses and activities within the District and sets parameters regarding allowable activities and the characteristics of future development. It establishes a framework for how future development in the District could meet community aspirations while addressing needs.

The Specific Plan Update aims to retain the character of the District while promoting new investments. The proposed land use patterns and policies are designed to address a wide range of social, economic, and environmental challenges within the District. Further, the proposed changes are designed to help maintain and improve the community’s desired character, 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.

3.6.2.1 Diverse and Affordable Housing
The Specific Plan Update aims to create more multi-unit housing that is affordable for residents and provides more access to the local community.

3.6.2.2 Commercial Activity
The District contains merchants, restauranteurs, and cultural venues that are integral to community life and provide a distinct sense of place. The Specific Plan Update retains the existing Commercial Main Street (CMS) land use and zoning designation that requires ground-floor commercial uses in the heart of the District’s commercial areas. However, the expansion of the Apartment House (AH) Overlay zoning designation would allow for additional multi-unit development without the ground- floor commercial requirements west of the commercial area around the Tower Theater along Olive Avenue.

6 Historic Fresno. 2020. A Guide to Historic Architecture in Fresno, California. Website: https://www.historic fresno.org/home.htm (accessed February 10, 2025).
7 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 March 2025). 8 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)
3-18

3.6.2.3 Industrial Employment and Compatibility
Light industrial uses are located along the southwest boundary of the Specific Plan Area. These areas are important historical and economic centers, as they bring employment opportunities. Some of these businesses have been in the neighborhood for many decades and have long-standing relationships with local residents and institutions.

3.6.3 Proposed Land Use Changes
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, as shown in Figure 3-4, Planned Land Uses. The Specific Plan Update would promote more mixed-use development along commercial corridors by re-designating a portion of Blackstone Avenue from neighborhood mixed use to corridor/center mixed-use and by re-designating a portion of Shields Avenue from office to neighborhood mixed-use areas, specifically on Blackstone Avenue and Shields Avenue. This would allow for ground-level commercial uses fronting public streets and sidewalks, while residential uses would be located above or behind. This would continue to promote the walkability of the District while allowing for greater residential development. Additionally, medium low density residential uses would be allowed at Terrace Gardens, Porter Tract, and Wilson Island.

3.6.4 Development Capacity
The majority of the Specific Plan Area is already developed and not expected to change. However, the Specific Plan Update highlights underutilized sites as candidates for investment and restoration.

Underutilized sites are generally located along the District’s commercial corridors. Enlarging or redeveloping existing buildings would allow for buildings in poor condition or low economic value to be improved. Many factors impact potential for new development, such as location, size, access, density, FAR, building heights, parking, and open space. Redeveloping underutilized sites would allow for decreased development costs while maintaining quality and community character.

Table 3.B below provides a summary of development capacity based on proposed land use designations under the proposed project.

3.6.4.1 Residential
Land uses allowing for residential growth within the Specific Plan Area include Residential Medium Low Density (RS-4), Residential Medium Density (RS-5), Residential Medium High Density (RM-1), Residential Urban Neighborhood (RM-2), and Residential High Density (RM-3), as well as Commercial Main Street (CMS), Neighborhood Mixed Use (NMX), and Corridor/Center Mixed Use (CMX).

Under current zoning within the District, residential development is estimated to have a capacity of 2,271 new housing units. Because this capacity accounts for the redevelopment of areas currently identified as underutilized sites, the net gain of residential units under the existing zoning capacity is 2,212 new residential units. The rezoning and land use changes proposed under the Specific Plan Update would result in an increased capacity totaling 2,807 residential units, which would total a net increase of 2,748 residential units when existing units on underutilized sites are taken into account.

LSA
FIGURE 3-4
Planned Land Uses
Tower District Speciﬁc Plan Update
I:\2024\20241643\G\Proposed_LandUse.ai (7/23/2025)
SOURCE: City of Fresno 2025

SECURE PARKING

PUBLIC PARKING

PUBLIC PARK

POLICE STATION

0.40.20 MILES
LAND USE | 59
FIGURE 3.2 | Planned Land Use
u I
Harvard Ave i
Clinton Ave !1
Yale Ave
Weldon Ave I
University Av~
I
HomeAve I
Floradora Avt
Hedges Ave !
Thomas Ave
Reeding Park
Belmont Ave
Franklin Ave
LSA
$
:;, --i =,
5' 0
!s 3
"' ~ ~
"' "'
~ ... ~ ..
3 ~ ;;;-
0 ~
:,
:,
; ~ "' "'
<
"'
'\?,c,
,·
['.l'
=,
0 ~
"'
"' a ..

0. ~ '<
~
-s,.s,.
:E s: .;;· ..
::T a 0 .. :,
>
~ is
"'
Porter
Tract
(") 0
Q. ~
m
f
(0
"' ►
~ <
"' "'
Shields Ave
Simpson Ave
Cornel l Ave
Michigan Ave
Princeton Ave
Brown Ave
Harvard Ave
Terrace Ave
I ■
11111
Lafayette
Park
~ .-·-'
~·1~ ....... • --
... ,P.arl<
~,i>i /
1\0~ •
e,'I>~ ,,.
.. .,,,,..
~,~Qi.
~o,'l>: -;,,,,
~,,,,
g ~ ~
g
:,
"' 3 z
~: "' ~ "' "' ~ ~ "' "'
(")
Q.
m
(0
"' ~
"'
;Ji' 'tJ 0
;<' u
~ ►
<
"'
►
<
"'
VI G) Q a, .. m ii, :, a, 5 < " 'ii ,,.
~ "' "' <T ~ ;;
0 "'
:,
~ ~ "' ~ "' "'
CD ..- • ■
[ • • ....I Project Boundary ,,.
s :,
"' ~
D Proposed Land Use Changes
Public Facilities
- Commercial Community
- Commercial General
- Commercial Main Street
- Employm ent Light Industrial
- Employment Office
Neighborhood Mixed Use
- Corridor/Center Mixed Use
- Open Space
---
Residential Medium
Low Density
Residential Medium Density
Residential Medium
High Density
Residential Urban
Neighborhood
Residential High Density

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)
3-20
This page intentionally left blank

LSA
3-21

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)
Table 3.B: Development Capacity by Proposed Land Use Designation - Vacant and Underutilized Sites
Existing Land Use
Designation
Vacant and
Underutilized
Land (acres)
Existing
Units
Projected
New Units
(gross)
Projected
New Units
(net)
Existing
Non-
Residential
Floor Area
(sf)
Projected
New Non-
Residential
Floor Area
(sf) (gross)
Projected
New Non-
Residential
Floor Area
(sf) (net)
Residential
Residential
Medium Low

0.0 - - - 0 - -
Residential
Medium Density 5.1 - 45 45 2,000 - -
Residential
Medium High

1.2 - 19 19 0 - -
Residential Urban
Neighborhood 0.3 - 8 8 0 - -
Residential High
Density 0.0 - - - 0 - -
Mixed Use
Neighborhood
Mixed Use 6.8 0 437 437 46,672 119,006 72,334
Corridor/Center
Mixed Use 8.8 9 659 650 55,808 191,446 135,638
Commercial
Commercial Main
Street 34.1 44 1,639 1,595 257,420 594,792 337,372
Commercial
Community 0.9 0 - - 6,274 24,306 18,032
Commercial
General 0.0 0 - - 0 - -
Employment
Employment
Office 0.0 0 - - 0 - -
Employment Light
Industrial 13.1 6 - -6 138,558 456,143 317,585
Public Facilities 0.0 0 - - 0 - -
TOTAL 70.3 59 2,807 2,748 506,732 1,385,694 880,962
Source: LSA (2025).

The proposed designations would increase residential development capacity by an estimated 537 units compared with current zoning and land use designations. Table 3.C below shows a summary of residential development capacity within the District under 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)
3-22
Table 3.C: Residential Development Capacity-Underutilized Sites Tower District Specific Plan Area Existing Units Projected New Units (gross)
Projected New Units
(net)
Existing Land Use Designations 59 2,271 2,212
Proposed Land Use Designations 59 2,807 2,748
Change - 537 537
Source: LSA (2025).

3.6.4.2 Non-Residential
The majority of commercial development within the District lies within the southern half of the Specific Plan Area with major development corridors along Van Ness Avenue, Fulton Street, Olive Avenue, and Belmont Avenue. Additional pockets of commercial development can be found throughout the Specific Plan Area including the Trolley Park area, along Maroa Avenue, and the McKinley and Palm Avenue intersection, as well as on isolated parcels. Mixed Use corridors within the Specific Plan Area are located on the northern boundary along Shields Avenue as well as on the eastern boundary along Blackstone Avenue. Under current zoning, the District has an estimated capacity for 1,406,600 square feet of new non-residential floor area, which equals just under 900,000 square feet of net new non-residential floor area when considering the loss of existing development on underutilized sites. The proposed zoning and land use changes would result in approximately 1,385,700 square feet of non-residential development, with a net increase of 881,000 square feet after existing development is accounted for. The proposed designations would decrease non-residential development capacity by an estimated 18,800 square feet compared with current land use designations. Table 3.D below provides a summary of the non-residential development capacity within the Specific Plan Area under the proposed project.

Table 3.D: Non-Residential Development Capacity-Underutilized Sites Tower District
Specific Plan Area
Existing Non-
Residential Floor
Area (sf)
Projected New Non-
Residential Floor Area
(sf) (gross)
Projected New Non-
Residential Floor Area (sf)
(net)
Existing Land Use
Designations
506,732 1,406,600 899,800
Proposed Land Use
Designations
506,732 1,385,700 881,000
Change - -20,900 -18,800
Source: LSA (2025).

3.6.5 Parks and Open Spaces
The Parks and Open Spaces chapter of the Specific Plan Update would influence how parks and other public facilities would be enhanced and developed through physical improvements and programming activities. Parks and other public facilities support community life and contribute to the physical and psychological well-being of those who frequent the District. This chapter also addresses other public facilities including trails, schools, and libraries.

LSA
3-23

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)
The Specific Plan Area currently contains approximately 8 acres of park land at five sites: Ted C. Wills Park Community Center, San Pablo Park, Trolley Park, Broadway Parque, and Van Ness Boulevard Greenway. The current ratio of 0.33 park acres per 1,000 residents is below the City standard of 3.0 acres per 1,000 residents. Additionally, the Parks and Open Spaces chapter identifies other study areas as sites for potential future parks. The Specific Plan Update provides guidance for maximizing the use of current open spaces within the Specific Plan Area, including enhancing existing parks and building partnerships with school sites to provide after-hours access to residents of the District.

The Specific Plan Update considers the potential for pocket parks and community gardens on City- owned land, unused parts of school sites, and privately-owned vacant parcels throughout the District that may be candidates for open space areas. There are several schools located within the Specific Plan Area that are operated by the Fresno Unified School District including Dailey Elementary, Heaton Elementary, Susan B. Anthony Elementary, Muir Elementary, and Hamilton Middle School, as well as Fresno High School, which is centrally located within the District, and Fresno City College. The joint use of school sites in collaboration with the school district is identified as an option for increasing the amount of public open space available for District residents.9 The Tower District was previously home to the Gillis Branch of the Fresno County Public Library that moved out of the District to the corner of Dakota and Fruit Avenues, just north of the District, in 1975.10 The Specific Plan Update calls on the City to collaborate with the Fresno County Public Library and support community efforts to bring a library back to the District.

3.6.6 Circulation
The Circulation chapter of the Specific Plan Update focuses on circulation across the overall street network and the design of streets themselves, as well as planned circulation improvements within the Specific Plan Area. The District’s street infrastructure provides access and mobility across its principal transportation modes: driving, walking, bicycling, and public transit. The chapter builds upon the foundation for how streets should work to move people and goods in order to promote the City’s General Plan goal of providing residents with “complete streets.” While the latter half of the 20th century saw an increase in accommodating vehicular traffic, which remains the dominant mode of transportation in the District, the grid-style circulation pattern throughout the Specific Plan Area provides a walkable, bike-friendly environment. “Walkability” is an integral component of the District’s character and was identified as a key issue early in the community engagement process. Improving the overall walkability and improving pedestrian safety within the Specific Plan Area is an overall goal of the Circulation chapter.

Recent development within the Specific Plan Area has focused on improvements to bicycle-related infrastructure. Separated bike lanes have been installed along major collector and arterial streets including Van Ness, Wishon, Palm, and Belmont Avenues. The need for continued improvements to

9 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 March 2025). 10 Fresno County Public Library. 2025. Gillis Branch Library. Website: https://www.fresnolibrary.org/branch/ gil.html (accessed February 12, 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)
3-24
bicycle facilities, including utilizing available funds and the City’s Active Transportation Plan (ATP), is an overall goal of the Circulation chapter.

The Fresno Area Express (FAX) bus service operates eight fixed-route service lines throughout the Specific Plan Area, including high frequency transit lines along Blackstone Avenue, which provide transport within the District as well as connections throughout the city. Public transit plays an important role in the mobility of residents within the District by providing an alternative to car ownership and a mode of transportation for those unable to drive due to age or disability. FAX service in the District also includes a paratransit “Handy Ride” service for eligible residents with limited ability or mobility.

3.6.7 Utilities
The Utilities chapter of the Specific Plan Update focuses on the status of public utilities and their associated infrastructure within the District. As the District is already urbanized and built out, utility infrastructure is currently in place. The Utilities chapter describes the status of existing utility infrastructure in the context of the City’s goal of moving towards a more sustainable and resource- efficient infrastructure and includes policies related to incentivizing utilities, ensuring they are aesthetically compatible with the Tower District, and resource conservation and resilience. Like the rest of the City, the Specific Plan Area relies on both groundwater and surface water. Sewer service is provided by the City of Fresno, which operates its own wastewater collection system. Stormwater management within the Specific Plan Area and the City is provided by the Fresno Metropolitan Flood Control District (FMFCD). The Solid Waste Management Division of the City handles the collection of municipal solid waste, recyclables, and green waste for the City, including the Specific Plan Area.

3.6.8 Implementation
The Implementation chapter outlines the key actions needed to carry out the vision, objectives, and policies for the proposed project as established in the Specific Plan Update. It identifies the responsible parties, including relevant City departments, review bodies, and partner agencies or organizations with the potential to be involved in implementation of the particular action.

Additionally, this chapter identifies potential resources and funding sources for implementation of the Specific Plan Update.

3.7 DESIGN STANDARDS AND GUIDELINES
The Tower District is a special place within the City of Fresno, with a long history and distinctive architecture and urban form, designed around public transit and pedestrians, which makes them unique compared to areas that were built later with the automobile as their central focus. The proposed updated Design Standards and Guidelines are built upon historic development patterns, the Citywide Development Code, the original Design Guidelines, and the Specific Plan Update, in order to guide development projects to make positive contributions to the District’s uniqueness, beauty, and walkability. The updated Design Standards and Guidelines are intended to preserve the essence of the District while facilitating compatible infill development.

LSA
3-25

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)
These Design Standards and Guidelines would be implemented with the proposed project and are based in large part on the original Tower District Design Guidelines that were adopted in 2005. The purposes of the original Design Guidelines remain relevant and would continue to guide development:

1. To assist property owners and developers by clearly describing what is expected of projects in the Tower District Specific Plan Area, thus minimizing delay and uncertainty.

2. To assist City and community review authorities by guiding development to ensure that new projects enhance the established character of the area and increase their viability.

3. To assist the City and community review authorities by making it clear to developers and property owners what is expected of them from new development and the remodeling of existing buildings.

4. To maintain the integrity and further the implementation of the goals, objectives, and policies of the Tower District Specific Plan.

The updated Design Standards and Guidelines also address needs, considerations, and practices that have emerged since adoption of the original Design Guidelines. These additional purposes include:

1. Incorporate best practices for urban design and architecture that have emerged as practices have been applied and tested, and as innovation has occurred.

2. Account for the State of California legislation that limits local government discretion in the review and approval of housing projects by emphasizing clarity, fairness, and timeliness.

Specifically, anticipate applications for qualifying housing projects, for which State law limits review to established “objective standards” that “involve no personal or subjective judgement … and are uniformly verifiable by reference to an external and uniform benchmark …”.

3. Support implementation of the City’s Housing Element and housing production by avoiding development standards that could make the maximum allowable density (as stated in the Development Code) physically or financially infeasible.

4. Emphasize development compatibility with Tower District’s unique sense of place through the use of objective standards for essential design attributes and continued use of design guidelines where flexibility in interpretation is needed.

Future development projects proposed in the zoning designations in the Specific Plan Area shown in Table 3.E below would be subject to regulations within the Development Code and the updated Design Guidelines and Standards. Future projects would also conform to the requirements of the underlying zoning district, all applicable overlay districts, and all other Articles within the Development Code.

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)
3-26
Table 3.E: Zoning Designations Subject to Design Standards and Guidelines Zoning Designation Applicable Section
Residential Single-Family Districts
(RS-1, RS-2, RS-3, RS-4, or RS-5)
Section II. Residential Single-Family Districts
Residential Multi-Family Districts
(RM-1, RM-2, RM-3, or RM-MH)
Section III. Residential Multi-Family Districts
Mixed Use Districts
(NMX, CMX, or RMX)
Section IV. Mixed-Use and Commercial Districts
Commercial Districts
(CMS, CC, CR, CG, CH, or CRC)
Section IV. Mixed-Use and Commercial Districts
All Other Districts Not Applicable
Source: LSA (2025).

Note: Subareas within the Tower District are also regulated by the Apartment House Overlay (AHO) zoning designation, which allows multifamily development without ground-floor commercial where it would otherwise be required, along with other AHO requirements.

3.8 TOWER ENTERTAINMENT DISTRICT
A Tower Entertainment District will be created to further support development of the district while addressing issues of compatibility with nearby residential uses, including noise mitigation considerations. A text amendment to the Development Code establishing an overlay will be proposed to formally establish this new district.

3.9 RELATED PLANNING EFFORTS
This section discusses other planning efforts within the City of Fresno and their current status that relate to the proposed project.

3.9.1 Southern Blackstone Smart Mobility Strategy
The Southern Blackstone Smart Mobility Strategy was completed in 2019 with the goal of developing a complete streets strategy to increase the effectiveness of public transportation and meet the needs of all transportation modes and users, particularly bicyclists and pedestrians, along the 2.5 miles of southern Blackstone Avenue from Dakota Avenue to SR-180. Goals of the study include increasing safety and access for all travel modes, enhanced streetscapes, safe and convenient pedestrian crossings, safe and convenient bicycle access, convenient and accessible transit, better connectivity to adjacent neighborhoods, and improved accessibility to existing and future businesses. The Specific Plan Area is bordered on the east side by Blackstone Avenue including the section from Clinton Avenue to SR-180, which includes the Weldon/Fresno City College and the Olive/Tower Gateway activity centers that are part of the project area for the Mobility Plan.

As this strategy is implemented, access from the Specific Plan area to the destinations on the Blackstone Corridor will be improved.

LSA
3-27

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)

3.9.2 Fresno 6th Cycle Housing Element
The Fresno 6th Cycle Housing Element (2023 to 2031) is currently adopted and being implemented.

The intent of the Housing Element is to ensure that the City makes a meaningful effort and commits available resources to meeting the housing needs of all economic segments of the community. The Housing Element establishes long-term goals and policies and specific implementation programs to meet housing needs as specific by State law. These goals and policies apply in the Specific Plan area, and several housing element sites are identified within the plan boundaries.

3.9.3 Fresno Climate Adaptation Plan and Environmental Justice Element The Fresno Climate Adaptation Plan and Environmental Justice Element is being developed in response to California Senate Bills 379 and 1000. The Climate Adaptation Plan will help prepare Fresno for the effects of climate change including the potential for flooding, extreme heat, drought, wildfire, and air pollution. The Environmental Justice Element aims to improve public health for frontline communities by ensuring equitable protection from pollution and access to resources that promote health. Both the Climate Adaptation Plan and the Environmental Justice Element cover the whole of the City, including the Tower District.

3.9.4 Fresno Active Transportation Plan
The City is currently in the process of updating its 2017 Active Transportation Plan to continue to meet the City’s needs. The Fresno Active Transportation Plan establishes a comprehensive guide that outlines the vision for active transportation. The update reinforces the City’s commitment to improving active transportation such as walking, biking, wheelchair use, and other human-powered travel modes, by enhancing accessibility, safety, and connectivity. The Active Transportation Plan covers the whole of the City, including the Tower District.

3.9.5 Fresno Vision Zero Action Plan
The Fresno City Council has made roadway safety a top priority for the City and has committed to eliminating traffic fatalities within the city. The Fresno Vision Zero Action Plan (Plan) is crucial to acting on the City’s commitments to systemic change leading to the elimination of traffic fatalities and serious injuries while increasing health, safety, and equitable mobility for all. The Vision Zero Action Plan is in active development and will outline a strategic planning framework to prioritize and implement safety enhancements that most effectively improve safety for all users as a first step towards the aspirational goal of eliminating traffic deaths.

3.10 DISCRETIONARY ACTIONS AND USES OF THIS EIR
The City is the Lead Agency under CEQA responsible for approval and certification of the Draft EIR. It is the City’s intent that the Draft EIR can be reviewed and tiered from, as appropriate, for evaluations of environmental issues associated with subsequent projects when such approvals require discretionary actions by the City and/or Responsible Agencies. If the City or Responsible Agencies tier off the Draft EIR, the agency approving the subsequent discretionary actions will be responsible to determine if the environmental evaluation in the Draft EIR adequately addresses the potential effects associated with the subsequent projects. A list of these agencies and potential permits and approvals that may be required for this project is provided in Table 3.F, below.

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)
3-28
Table 3.F: Potential Permits and Approvals
Lead Agency Permits/Approvals
City of Fresno  Certification of the TDSP EIR and adoption of the Findings of Fact, Statement of Overriding Considerations, and Mitigation Monitoring and Reporting Program  Repeal of 1991 Tower District Specific Plan
 Adoption of the Tower District Specific Plan
 Amendment of the General Plan Land Use Map to incorporate the land use changes of the Specific Plan
 Repeal of 2005 Tower District Design Guidelines
 Adoption of the Tower District Design Standards and Guidelines  Rezone of parcels requiring a zone change for consistency with land use changes and implementation of the extension of the Apartment House Overlay  Amendment of the Development Code to implement the Tower Entertainment District Source: LSA (2025).

As future development in accordance with the Specific Plan Update is proposed for development, numerous agencies may be defined as Responsible and Trustee Agencies. Development of these future projects may require approval of discretionary actions by other agencies. These Responsible and Trustee Agencies can use the Draft EIR for their discretionary approval, if they determine that the environmental evaluation adequately addresses the effects associated with the discretionary action requested of them for approval.

The following is a general list of potential Responsible and Trustee Agencies that may have jurisdiction over future development projects within the Specific Plan Area. • California Department of Transportation (Caltrans), including the Division of Aeronautics • California Air Resources Board (CARB)
• California Department of Conservation (DOC)
• California Department of Fish and Wildlife (CDFW)
• California Department of Forestry and Fire Protection (CAL FIRE) • California Department of Housing and Community Development (HCD) • California Department of Parks and Recreation (DPR)
• California Department of Toxic Substances Control (DTSC) • California Public Utilities Commission (CPUC)
• California State Office of Historic Preservation (OHP) • California State Lands Commission (SLC)
• California State Water Resources Control Board (SWRCB) • Central Valley Regional Water Quality Control Board (Central Valley RWQCB) • Fresno Airport Land Use Commission (Fresno ALUC)
• Fresno Metropolitan Flood Control District (FMFCD)
• Fresno Irrigation District
• Fresno Unified School District (FUSD)
• San Joaquin Valley Air Pollution Control District (SJVAPCD) • Sewer Districts (Various)
• Water Districts (Various)
• Any Other Responsible or Trustee Agency that may need to provide discretionary approval 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)
4-1

4.0 EVALUATION OF ENVIRONMENTAL IMPACTS
This chapter contains an analysis of each potentially significant environmental issue that has been identified for the implementation of the Tower District Specific Plan Update (proposed project or Specific Plan Update). The following discussion: (1) identifies how a determination of significance is made; (2) identifies the environmental issues addressed in this chapter; (3) describes the context for the evaluation of cumulative effects; (4) lists the format of the topical issue section; and (5) provides an evaluation of each potentially significant issue in Sections 4.1 through 4.6.

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

Unlike a Project Environmental Impact Report (EIR), which addresses the environmental impacts of a specific development project, a Program EIR addresses the potential impacts of a series of actions that can be characterized as one large project. Because there is no specific development project being proposed at this time, a Project EIR cannot be prepared, as no specific project level details are available. The proposed project, which includes updates to the Tower District Specific Plan, provides 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 Tower District Specific Plan Area that 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 tracks to the west. Therefore, preparation of a Program EIR for the proposed project is appropriate, and required, as the project elements are one large project that are related, as described in the State CEQA Guidelines Section 15168 either:

1. Geographically;

2. As logical parts in the chain of contemplated actions;

3. In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or

4. As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

The use of a Program EIR provides an occasion for a more exhaustive consideration of effects and alternatives than otherwise would be practical under a Project EIR. However, future discretionary projects facilitated by certification of a Program EIR must be further evaluated in light of the Program EIR to determine whether or not an additional environmental document must be prepared.

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)
4-2
Therefore, the City will determine whether future projects require the preparation of a new Initial Study, Mitigated Negative Declaration, or new EIR. Under CEQA, environmental documentation is required on all discretionary actions, which includes the approval of the proposed project. The purpose of the CEQA process is to disclose environmental impacts of a proposed project to the general public and agencies, who then have the ability to have their comments considered by decision makers.

The proposed project would be continually implemented over a period of around 20 years. This Draft EIR has been prepared as a Program EIR for the following reasons:
• The proposed project would be implemented over a 20-year period. • The proposed project would be implemented over a large geographic area, which is defined as the total area within the Specific Plan Area.
• Development plans and details have not been developed for new projects that could be facilitated by project approval.

Therefore, the use of a Program EIR is appropriate in evaluating project-related environmental impacts resulting from implementation of the proposed project.

ISSUES ADDRESSED IN THE DRAFT EIR
Sections 4.1 through 4.6 of this chapter describe the environmental setting of the project as evaluated in the Program EIR and the impacts that are expected to result from implementation of the proposed project. Mitigation measures are proposed to reduce potential impacts, where required.

1. Air Quality

2. Biological Resources

3. Cultural Resources

4. Greenhouse Gas Emissions

5. Noise

6. Recreation

ENVIRONMENTAL SETTING
This chapter has been prepared in accordance with State CEQA Guidelines Section 15125, which states: “An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. The environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to an understanding of the physical effects of the proposed project and its alternatives.”
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)
4-3
The Notice of Preparation for the proposed project was published on May 7, 2025. Thus, each of the environmental topical sections in this chapter includes a discussion of physical conditions in the Specific Plan Area on or around May 2025.

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

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

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

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

AIR Air Quality
BIO Biological Resources
CUL Cultural Resources
GHG Greenhouse Gas Emissions
NOI Noise
REC Recreation
Impacts are also categorized by type of impact, as follows: Less Than Significant (LTS), Significant (S), and Significant and Unavoidable (SU).

ENVIRONMENTAL ISSUES
Sections 4.1 through 4.6 of this chapter describe the environmental setting of the project as it relates to each specific environmental topic evaluated in the EIR and the impacts that are expected to result from implementation of the proposed project. Mitigation measures are proposed to reduce potential impacts, where required. The following environmental topics were not included in the Draft EIR as they were screened out as having “no impact” or a “less than significant” impact in the Initial Study (Appendix C): aesthetics, agriculture and forestry resources, energy, geology and soils, 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.

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)

4.1-1

4.1 AIR QUALITY

4.1.1 Introduction
This section describes the existing air quality setting for the Tower District Specific Plan Update (proposed project or Specific Plan Update) for the City of Fresno (City) in the Specific Plan Area and has been prepared using the methodologies and assumptions contained in the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI).
1 In keeping with these guidelines, this section describes existing air quality and the regulatory framework for air quality. For the proposed project, the Tower District Specific Plan Area (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. The section also describes the potential effects of the implementation of the Specific Plan Update on air quality, including the effects of construction and operational traffic associated with the proposed project on regional pollutant levels and health risks. Mitigation measures to reduce potentially significant air quality impacts are identified, as necessary.

4.1.2 Existing Environmental Setting
The Tower District is located within the city of Fresno which is located in the county of Fresno and within the San Joaquin Valley Air Basin (SJVAB). The SJVAB consists of seven counties: Kings, Madera, San Joaquin, Merced, Stanislaus, and Fresno Counties, and a portion of Kern County. The local agency with jurisdiction over air quality in the basin is the SJVAPCD. Regional and local air quality is impacted by topography, dominant airflows, atmospheric inversions, location, and season.

The following discussion provides an overview of existing air quality conditions in the region and in the city of Fresno. Ambient air quality standards and the regulatory framework are summarized and climate, air quality conditions, and typical air pollutant types and sources are also described.

4.1.2.1 Study Area for Project Impacts
The study area for project impacts regarding air quality is the Specific Plan Area and proximate sensitive receptors potentially impacted by a project within the Specific Plan Area because implementation of the proposed project is limited to areas within the Specific Plan Area. However, implementation of the Specific Plan Update would include the cumulative results of several separate projects over the length of buildout requiring separate approvals that add to emissions generated from existing development. Air quality impacts are inherently cumulative in nature. For example, the largest source of emissions, motor vehicles, would occur as individuals travel throughout the Specific Plan Area.

1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015a. CEQA, Guidance/Policies/Rules, Guidance for Assessing and Mitigating Air Quality Impacts. March 19. Website: www.valleyair.org/ transportation/ceqa_idx.htm (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)

4.1-2

4.1.2.2 Study Area for Cumulative Impacts
The study area for the analysis of cumulative regional air quality impacts is the SJVAB which includes the Counties of San Joaquin, Stanislaus, Merced, Madera, Fresno, Kings, Tulare and a portion of Kern County. Under the Federal Clean Air Act, any monitoring location that exceeds ambient air quality ozone and particulate standards within the air basin results in the entire air basin to be designated nonattainment. Therefore, an exceedance in the Tower District, Fresno, or another area in the SJVAB would affect the attainment status of the rest of the San Joaquin Valley even if no other location exceeds a standard. Because of this, air quality plans must provide reductions that demonstrate attainment at the location with the highest concentration in the basin and that cleaner locations would attain the standards earlier.

Air pollutants can remain in the atmosphere for long periods and can build to unhealthful levels when stagnant conditions that are common in the San Joaquin Valley occur. Pollutants are transported downwind from urban areas with many emission sources but also are recirculated to the urban areas by wind eddies and upslope/downslope mountain and valley winds. Therefore, emissions from large urban areas like the city of Fresno, where the Tower District is located, have the potential to create regional air quality impacts for ozone and particulate matter (PM) in addition to localized impacts for carbon monoxide (CO), nitrogen dioxide (NO 2 ), and PM.

The analysis of regional emissions is based on a summary of projections approach as provided in Section 15130(b)(1)(B) of the State CEQA Guidelines. The applicable projections include those provided within the air quality attainment plans for SJVAB prepared by the SJVAPCD. The study area for the analysis of cumulative localized impacts is limited to areas with sensitive receptors that are in the immediate vicinity of specific sources.

4.1.2.3 Air Pollutants and Health Effects
Both State and federal governments have established health-based ambient air quality standards for six criteria air pollutants: CO, ozone (O
3), NO2, sulfur dioxide (SO2), lead (Pb), and suspended particulate matter. In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Two criteria pollutants, O 3 and NO2, are
considered regional pollutants because they (or their precursors) affect air quality on a regional scale. Pollutants such as CO, SO2, and Pb are considered local pollutants that tend to accumulate in the air locally.

The primary pollutants of concern in the City of Fresno are O3, CO, and suspended particulate matter. Significance thresholds established by an air quality district are used to manage total regional and local emissions within an air basin based on the air basin’s attainment status for criteria pollutants. These emission thresholds were established for individual development projects that would contribute to regional and local emissions and could adversely affect or delay the air basin’s projected attainment target goals for nonattainment criteria pollutants.

Because of the conservative nature of the significance thresholds, and the basin-wide context of individual development project emissions, there is no direct correlation between a single project and localized air quality-related health effects. One individual project that generates emissions 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)

4.1-3
exceeding a threshold does not necessarily result in adverse health effects for residents in the project vicinity. This condition is especially true when the criteria pollutants exceeding thresholds are those with regional effects, such as ozone precursors like nitrogen oxides (NOX) and reactive organic gases (ROG).

Further, by its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to by itself result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant. In developing thresholds of significance for air pollutants, the air quality districts have considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.

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

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

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

Air pollutants and their health effects, and other air pollution-related considerations are summarized in Table 4.1.A and are described in more detail below.

Ozone. Ozone (O
3) is a secondary air pollutant produced in the atmosphere through a complex series of photochemical reactions involving ROG and NOX. The main sources of ROG and NOx, often referred to as ozone precursors, are combustion processes (including combustion in motor vehicle engines) and the evaporation of solvents, paints, and fuels. Automobiles are typically the largest source of ozone precursors. Ozone is referred to as a regional air pollutant because its precursors are transported and diffused by wind concurrently with ozone production through the photochemical reaction process. Ozone causes eye irritation, airway constriction, and shortness of breath and can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema.

Carbon Monoxide. CO is an odorless, colorless gas usually formed as the result of the incomplete combustion of fuels. The single largest source of CO is motor vehicles. CO transport is limited – it disperses with distance from the source under normal meteorological conditions. However, under certain extreme meteorological conditions, CO concentrations near congested roadways or intersec- tions may reach unhealthful levels that adversely affect local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients). Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service (LOS) or with extremely high traffic volumes. Exposure to high concentrations of CO reduces the oxygen-carrying capacity of 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)

4.1-4
Table 4.1.A: Sources and Health Effects of Air Pollutants Pollutants Sources Primary Effects
Ozone (O3)  Precursor sources:1 motor vehicles,
industrial emissions, and consumer
products.
 Respiratory symptoms.
 Worsening of lung disease leading to premature
death.
 Damage to lung tissue.
 Crop, forest, and ecosystem damage.
 Damage to a variety of materials, including
rubber, plastics, fabrics, paints, and metals.

Particulate Matter Less
than 2.5 Microns in
Diameter (PM

2.5)
 Cars and trucks (especially diesels).
 Fireplaces, woodstoves.
 Windblown dust from roadways,
agriculture, and construction.
 Premature death.
 Hospitalization for worsening of cardiovascular
disease.
 Hospitalization for respiratory disease.
 Asthma-related emergency room visits.
 Increased symptoms, increased inhaler usage.

Particulate Matter Less
than 10 Microns in
Diameter (PM10)
 Cars and trucks (especially diesels).
 Fireplaces, woodstoves.
 Windblown dust from roadways,
agriculture, and construction.
 Premature death and hospitalization, primarily
for worsening of respiratory disease.
 Reduced visibility and material soiling.

Nitrogen Oxides (NOX)  Any source that burns fuels such as cars, trucks, construction and farming
equipment, and residential heaters
and stoves.
 Lung irritation.
 Enhanced allergic responses.

Carbon Monoxide (CO)  Any source that burns fuels such as cars, trucks, construction and farming
equipment, and residential heaters
and stoves.
 Chest pain in patients with heart disease.
 Headache.
 Light-headedness.
 Reduced mental alertness.

Sulfur Oxides (SOX)  Combustion of sulfur-containing fossil fuels.
 Smelting of sulfur-bearing metal ores.
 Industrial processes.
 Worsening of asthma: increased symptoms,
increased medication usage, and emergency
room visits.

Lead (Pb)  Contaminated soil.  Impaired mental functioning in children.  Learning disabilities in children.
 Brain and kidney damage.

Toxic Air Contaminants
(TACs)
 Cars and trucks (especially diesels).
 Industrial sources, such as chrome
platers.
 Neighborhood businesses, such as dry
cleaners and service stations.
 Building materials and products.
 Cancer.
 Reproductive and developmental effects.
 Neurological effects.

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

the blood and can cause headaches, nausea, dizziness, and fatigue, impair central nervous system function, and induce angina (chest pain) in persons with serious heart disease. Extremely high levels of CO, such as those generated when a vehicle is running in an unventilated garage, can be fatal.

Particulate Matter. Particulate matter is a class of air pollutants that consists of heterogeneous solid and liquid airborne particles from human-made and natural sources. Particulate matter is categorized in two size ranges: PM10, for particles less than 10 microns in diameter, and PM2.5, for 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)

4.1-5
particles less than 2.5 microns in diameter. Motor vehicles are the primary generators of particulates, through tailpipe emissions as well as brake pad, tire wear, and entrained road dust.

Wood burning in fireplaces and stoves, industrial facilities, and ground-disturbing activities such as construction are other sources of such fine particulates. These fine particulates are small enough to be inhaled into the deepest parts of the human lung and can cause adverse health effects. According to the California Air Resources Board (CARB), studies in the United States and elsewhere have demonstrated a strong link between elevated particulate levels and premature deaths, hospital admissions, emergency room visits, and asthma attacks, and studies of children’s health in California have demonstrated that particle pollution may significantly reduce lung function growth in children.
2 Statewide attainment of particulate matter standards could reduce premature deaths, hospital admissions for cardiovascular and respiratory disease, asthma-related emergency room visits, and episodes of respiratory illness in California.

Nitrogen Dioxide. NO2 is a reddish brown gas that is a byproduct of combustion processes. Automo- biles and industrial operations are the main sources of NO2. Aside from its contribution to ozone formation, NO2 also contributes to other pollution problems, including a high concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases lung function and may reduce resistance to infection.

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

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

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

2 California Air Resources Board (CARB). 2020. Inhalable Particulate Matter and Health (PM2.5 and PM10).

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

4.1-6
Toxic Air Contaminants. In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of pollutants of concern. Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen sulfide. Potential human health effects of TACs include birth defects, neurological damage, cancer, and death. There are hundreds of different types of TACs with varying degrees of toxicity. Individual TACs vary greatly in the health risk they present; at a given level of exposure, one TAC may pose a hazard that is many times greater than another.

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

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

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

The CARB Diesel Risk Reduction Plan is intended to substantially reduce diesel particulate matter emissions and associated health risks through introduction of ultra-low-sulfur diesel fuel—a step already implemented—and cleaner-burning diesel engines. 4 The technology for reducing diesel
particulate matter emissions from heavy-duty trucks is well established, and both State and federal agencies are moving aggressively to regulate engines and emission control systems to reduce and remediate diesel emissions.

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

3 California Air Resources Board (CARB). 2000a. Fact Sheet – California’s Plan to Reduce Diesel Particulate Matter Emissions. October. Website: www.arb.ca.gov/diesel/factsheets/rrpfactsheet.pdf (accessed July 2025).
4 California Air Resources Board (CARB). 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).

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)

4.1-7
pollutants. Engine exhaust, from diesel, gasoline, and other combustion engines, is a complex mixture of particles and gases, with collective and individual toxicological characteristics.

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

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

Asbestos. Asbestos is the name given to a number of naturally occurring fibrous silicate minerals that have been mined for their useful properties such as thermal insulation, chemical and thermal stability, and high tensile strength. The three most common types of asbestos are chrysotile, amosite, and crocidolite. Chrysotile, also known as white asbestos, is the most common type of asbestos found in buildings. Chrysotile makes up approximately 90 to 95 percent of all asbestos contained in buildings in the United States.

Construction sometimes requires the demolition of existing buildings that may include materials containing asbestos. Although the project does not call for demolition specifically, some demolition does occur as a result of the ongoing implementation of the Specific Plan. In addition, asbestos is also found in a natural state known as naturally occurring asbestos. Exposure and disturbance of rock and soil that naturally contain asbestos can result in the release of fibers into the air and consequent exposure to the public. Asbestos most commonly occurs in ultramafic rock that has undergone partial or complete alteration to serpentine rock (serpentinite) and often contains chrysotile asbestos. In addition, another form of asbestos, tremolite, can be found associated with ultramafic rock, particularly near faults. Sources of asbestos emissions include unpaved roads or driveways surfaced with ultramafic rock, construction activities in ultramafic rock deposits, or rock quarrying activities where ultramafic rock is present.

Exposure to asbestos is a health threat; exposure to asbestos fibers may result in health issues such as lung cancer, mesothelioma (a rare cancer of the thin membranes lining the lungs, chest, and abdominal cavity), and asbestosis (a non‐cancerous lung disease that causes scarring of the lungs).

The CARB has an Air Toxics Control Measure for construction, grading, quarrying, and surface mining operations requiring the implementation of mitigation measures to minimize emissions of asbestos- laden dust. The measure applies to road construction and maintenance, construction and grading operations, and quarries and surface mines when the activity occurs in an area where naturally occurring asbestos is likely to be found. Areas are subject to the regulation if they are identified on maps published by the Department of Conservation as ultramafic rock units or if the Air Pollution 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)

4.1-8
Control Officer or owner/operator has knowledge of the presence of ultramafic rock, serpentine, or naturally occurring asbestos on the site. The measure also applies if ultramafic rock, serpentine, or asbestos is discovered during any operation or activity.

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

Both the USEPA and the CARB have established ambient air quality standards for the following com- mon pollutants: CO, O
3, NO2, SO2, Pb, and suspended particulate matter. In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. These ambient air quality standards are levels of contaminants that avoid specific adverse health effects associated with each pollutant.

Federal standards include both primary and secondary standards. Primary standards establish limits to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, and damage to animals, crops, vegetation, and buildings. State and federal standards for the criteria air pollutants are listed in Table 4.1.B.

4.1.2.5 Existing Climate and Air Quality
The following provides a discussion of the local and regional air quality and climate in the Specific Plan Area.

Regional and Local Air Quality. Air quality is a function of both local climate and local sources of air pollution. The amount of a given pollutant in the atmosphere is determined by the amount of the pollutant released and the atmosphere's ability to transport and dilute the pollutant. The major determinants of transport and dilution are wind, atmospheric stability, terrain, and for photochemical pollutants, sunshine.

The Specific Plan Area is located within the SJVAB and is under the jurisdiction of the SJVAPCD. A region’s topographic features have a direct correlation with air pollution flow and therefore are used to determine the boundary of air basins. The SJVAB is comprised of approximately 25,000 square miles and covers of eight counties including Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus and Tulare, and the western portion of Kern County. The SJVAB is defined by the Sierra Nevada mountains in the east (8,000 to 14,000 feet in elevation), the Coast Ranges in the west (averaging 3,000 feet in elevation), and the Tehachapi mountains in the south (6,000 to 8,000 feet in elevation). The valley is basically flat with a slight downward gradient to the northwest. The valley opens to the sea at the Carquinez Straits where the San Joaquin-Sacramento Delta empties into San Francisco Bay. An aerial view of the SJVAB would simulate a “bowl” opening only to the north. These topographic features restrict air movement through and out of the basin.

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)

4.1-9
Table 4.1.B: Federal and State Ambient Air Quality Standards Pollutant
Averaging
Time
California Standards1 Federal Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Method7
Ozone
(O3)8
1-Hour 0.09 ppm
(180 μg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8-Hour 0.07 ppm
(137 μg/m3)

0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)9
24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μg/m3 Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 μg/m3 –
Fine
Particulate
Matter
(PM2.5)9
24-Hour - 35 μg/m3 Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 μg/m3 Gravimetric or Beta
Attenuation 9.0 μg/m3 15
Carbon
Monoxide
(CO)
8-Hour 9.0 ppm
(10 mg/m3) Non-Dispersive
Infrared
Photometry
(NDIR)
9 ppm
(10 mg/m3) – Non-Dispersive
Infrared
Photometry
(NDIR)
1-Hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8-Hour
(Lake Tahoe)
6 ppm
(7 mg/m3) – –
Nitrogen
Dioxide
(NO2)10
Annual
Arithmetic
Mean

0.03 ppm
(57 μg/m3) Gas Phase
Chemi-luminescence
53 ppb
(100 μg/m3)
Same as
Primary
Standard
Gas Phase
Chemi-
luminescence 1-Hour 0.18 ppm
(339 μg/m3)
100 ppb
(188 μg/m3) -
Lead
(Pb)12,13
30-Day
Average 1.5 μg/m3
Atomic
Absorption
– –
High-Volume
Sampler and
Atomic
Absorption
Calendar
Quarter – 1.5 μg/m3
(for certain areas)12 Same as
Primary
Standard
Rolling 3-
Month
Average9
– 0.15 μg/m3
Sulfur
Dioxide
(SO2)11

24-Hour 0.04 ppm
(105 μg/m3)
Ultraviolet
Fluorescence

0.14 ppm
(for certain areas) –
Ultraviolet
Fluorescence;
Spectro-
photometry
(Pararosaniline
Method)
3-Hour – – 0.5 ppm
(1300 μg/m3)
1-Hour 0.25 ppm
(655 μg/m3)
75 ppb
(196 μg/m3)11 –
Annual
Arithmetic
Mean
– 0.030 ppm
(for certain areas)11 –
Visibility-
Reducing
Particles12
8-Hour See footnote 14
Beta Attenuation
and Transmittance
through Filter Tape.

Federal

Standards

Sulfates 24-Hour 25 μg/m3 Ion Chromatography
Hydrogen
Sulfide 1-Hour 0.03 ppm
(42 μg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride10 24-Hour 0.01 ppm
(26 μg/m3) Gas Chromatography
Source: California Air Resources Board (2016) (Website: https://www.arb.ca.gov/research/aaqs/aaqs2.pdf).

Table notes are provided on the following page.

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)

4.1-10
1 California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California Ambient Air Quality Standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2 National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over 3 years, are equal to or less than the standard.

Contact USEPA for further clarification and current national policies. 3 Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
4 Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level of the air quality standard may be used.
5 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. 6 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
7 Reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the USEPA. 8 On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. 9 On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing national 24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. 10 To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. 11 On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

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

To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
12 The CARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.
13 The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
14 In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.
15 On February 7, 2024, the federal annual PM2.5 standard was revised from 12.0 µg/m3 to 9.0 µg/m3. °C = degrees Celsius
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency

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)

4.1-11
Although marine air generally flows into the basin from the San Joaquin River Delta, the Coast Range hinders wind access into the SJVAB from the west, the Tehachapi Mountains prevent southerly passage of air flow, and the high Sierra Nevada range is a significant barrier to the east. These topographic features result in weak air flow which becomes blocked vertically by high barometric pressure over the SJVAB. As a result, the SJVAB is highly susceptible to pollutant accumulation over time. Most of the surrounding mountains are above the normal height of summer inversion layers (1,500 to 3,000 feet).

Local climatological effects, including wind speed and direction, temperature, inversion layers, precipitation and fog, can exacerbate the air quality in the SJVAB. Wind speed and direction play an important role in dispersion and transport of air pollutants. Wind at the surface and aloft can disperse pollution by mixing vertically and by transporting it to other locations. For example, in the summer, wind usually originates at the north end of the SJVAB and flows in a south-southeasterly direction through the SJVAB, through Tehachapi pass, into the Southeast Desert Air Basin. In the winter, wind direction is reversed and flows in a north-northwesterly direction. In addition to the seasonal wind flow, a sea breeze flows into SJVAB during the day and a land breeze flowing out of the SJVAB at night.

The diversified wind flow enhances the pollutant transport capability within SJVAB.

The annual average temperature varies throughout the SJVAB, ranging from the low 40s to high 90s, measured in degrees Fahrenheit (°F). With a more pronounced valley influence, inland areas show more variability in annual minimum and maximum temperatures than coastal areas. The climatological station closest to the site is the Fresno Yosemite International Airport Station (043257). The monthly average maximum temperature recorded at this station from January 1948 to June 2016 ranged from 54.6°F in January to 98.3°F in July, with an annual average maximum of

76.5°F. The monthly average minimum temperature recorded at this station ranged from 35.3°F in December to 65.7°F in July, with an annual average minimum of 50.4°F. 5 These levels are still
representative of the Specific Plan Area. January and December are typically the coldest months and July is typically the warmest month in this area of the SJVAB.

The majority of annual rainfall in the SJVAB occurs between November and March. Summer rainfall is minimal and is generally limited to scattered thundershowers in desert regions and slightly heavier showers near the lower portion of the Basin and along the Sierra Nevada mountains to the east. Average monthly rainfall during that period varied from 0.01 inches in July and August to 2.09 inches in January, with an annual total of 10.89 inches. 6 Patterns in monthly and yearly rainfall totals
are predictable due to the recognizable differences in seasons within the valley.

The vertical dispersion of air pollutants in the SJVAB is limited by the presence of persistent temperature inversions. Because of cooling of the atmosphere, air temperature usually decreases with altitude. A reversal of this atmospheric state, where the air temperature increases with height, is termed an inversion. Inversions can exist at the surface, or at any height above the ground. The height of the base of the inversion is known as the “mixing height.” This is the level within which

5 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).
6 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)

4.1-12
pollutants can mix vertically. Air above and below the inversion base does not mix because of the differences in air density. Semi-permanent systems of high barometric pressure fronts frequently establish themselves over the SJVAB, preventing low pressure systems that might otherwise bring rain and winds that clean the air.

Inversion layers are significant in determining ozone formation, and CO and PM 10 concentrations.

Ozone and its precursors will mix and react to produce higher ozone concentrations under an inversion. The inversion will also simultaneously trap and hold directly emitted pollutants such as carbon monoxide. PM
10 is both directly emitted and created in the atmosphere as a chemical reaction. Concentration levels of pollutants are directly related to inversion layers due to the limitation of mixing space.

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

The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are lowest. Periods of low inversions and low wind speeds are conditions favorable to high concentrations of CO and PM

10. In the winter, the greatest pollution problems are CO and NOx because of extremely low inversions and air stagnation during the night and early morning hours. In the summer, the longer daylight hours and the brighter sunshine combine to cause a reaction between hydrocarbons and oxides of nitrogen to form photochemical smog.

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

2.5 standard is met if the 3‐year average of the
annual average PM2.5 concentration is less than or equal to the standard. The current attainment designations for the basin are shown in Table 4.1.C.

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)

4.1-13
Table 4.1.C: San Joaquin Valley Air Basin Air Quality Attainment Status Pollutant State Federal
Ozone (1-hour) Severe/Nonattainment Not Applicable
Ozone (8-hour) Nonattainment Extreme Nonattainment
PM10 Nonattainment Attainment (Maintenance)
PM2.5 Nonattainment Nonattainment
Carbon Monoxide Attainment Attainment (Maintenance)
Nitrogen Dioxide Attainment Unclassified/Attainment
Lead Attainment Unclassified/Attainment
Sulfur Dioxide Attainment Unclassified
Sulfates Attainment No Federal Standard
Hydrogen Sulfide Unclassified No Federal Standard
Source: California Air Resources Board and United States Environmental Protection Agency (2023).

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

Ambient air data collected at permanent monitoring stations are used by the USEPA to identify regions as attainment or nonattainment depending on whether the regions met the requirements stated in the primary National Ambient Air Quality Standards (NAAQS). Attainment areas are required to maintain their status through moderate, yet effective air quality maintenance plans.

Nonattainment areas are imposed with additional restrictions as required by the USEPA. In addition, different classifications of attainment such as marginal, moderate, serious, severe, and extreme are used to classify each air basin in the state on a pollutant-by-pollutant basis. Different classifications have different mandated attainment dates and are used as guidelines to create air quality management strategies to improve air quality and comply with the NAAQS by the attainment date.

A region is determined to be unclassified when the data collected from the air quality monitoring stations do not support a designation of attainment or nonattainment, due to lack of information, or a conclusion cannot be made with the available data.

The SJVAPCD, together with the CARB, maintains ambient air quality monitoring stations in the SJVAB. The air quality monitoring stations closest to the Specific Plan Area are located at 908 North Villa Avenue in Clovis and 3727 North First Street in Fresno, California.

Pollutant monitoring results for years 2021 to 2023 at the nearby ambient air quality monitoring stations, shown in Table 4.1.D, indicate that air quality in the area has generally been moderate. As indicated in the monitoring results, the State PM
10 standard was exceeded 111 times in 2021, 73
times in 2022 and an unknown number of times in 2023. In addition, the federal PM10 standard was exceeded an unknown number of times in 2021 but not exceeded in 2022 or 2023. The federal PM2.5 standard had 22 exceedances in 2021, four exceedances in 2022, and no exceedances in 2023. The State 1-hour ozone standard was exceeded six times in 2021, no times in 2022, and an unknown number of times in 2023. The State 8-hour ozone standard was exceeded 37 times in 2021, 26 times in 2022, and 21 times in 2023. The federal 8-hour standard was exceeded 34 times in 2021, 23 times in 2022, and 21 times in 2023. The CO, NO2, and SO2 standards were not exceeded in this area during the 3-year period.

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)

4.1-14
Table 4.1.D: Ambient Air Quality at Nearby Monitoring Stations Pollutant Standard 2021 2022 2023
Carbon Monoxide (CO)
Maximum 1-hour concentration (ppm) 1.3 1.3 1.5
Number of days exceeded: State: > 20 ppm 0 0 0
Federal: > 35 ppm 0 0 0
Maximum 8-hour concentration (ppm) 1.2 1.1 1.3
Number of days exceeded: State: > 9 ppm 0 0 0
Federal: > 9 ppm 0 0 0
Ozone (O3)
Maximum 1-hour concentration (ppm) 0.123 0.109 0.102
Number of days exceeded: State: > 0.09 ppm 6 0 ND
Maximum 8-hour concentration (ppm) 0.100 0.084 0.083
Number of days exceeded: State: > 0.07 ppm 37 26 21
Federal: > 0.07 ppm 34 23 21
Coarse Particulates (PM10)
Maximum 24-hour concentration (µg/m3) 208.8 127.0 104.0 Number of days exceeded: State: > 50 µg/m3 111 73 ND
Federal: > 150 µg/m3 ND 0 0
Annual arithmetic average concentration (µg/m3) 32.6 43.2 36.2 Exceeded for the year: State: > 20 µg/m3 Yes Yes ND
Federal: > 50 µg/m3 No No ND
Fine Particulates (PM2.5)
Maximum 24-hour concentration (µg/m3) 104.6 41.9 34.7
Number of days exceeded: Federal: > 35 µg/m3 22 4 0
Annual arithmetic average concentration (µg/m3) 10.2 15.1 10.5 Exceeded for the year: State: > 12 µg/m3 Yes No No
Federal: > 15 µg/m3 Yes No No
Nitrogen Dioxide (NO2)
Maximum 1-hour concentration (ppm) 0.049 0.051 0.048
Number of days exceeded: State: > 0.250 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.008 0.008 0.009 Exceeded for the year: Federal: > 0.053 ppm No No No
Sulfur Dioxide (SO2)2
Maximum 1-hour concentration (ppm) 0.008 0.003 0.005
Number of days exceeded: State: > 0.25 ppm 0 0 0
Maximum 24-hour concentration (ppm) 0 0 0
Number of days exceeded: State: > 0.04 ppm 0.003 0.001 0.002 Federal: > 0.14 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.00042 0.0004 0.0003 Exceeded for the year: Federal: > 0.030 ppm No No No
Sources: CARB (2023) and USEPA (2023).
1 On February 7, 2024, the federal annual PM2.5 standard was revised from 12.0 µg/m3 to 9.0 µg/m3. However, since the data presented in Table E is through 2022, it uses the 12.0 µg/m3 standard that was in effect through 2022. 2 Data for SO2 was taken from 3727 North First Street, Fresno monitoring station. All other data was taken from 908 North Villa Avenue, Clovis Monitoring Station.
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value. ppm = parts per million
USEPA = United States Environmental Protection Agency

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)

4.1-15
Toxic Air Contaminant Trends. In 1984, the CARB adopted regulations to reduce TAC emissions from mobile and stationary sources, as well as consumer products. A CARB study showed that ambient concentrations and emissions of the seven TACs responsible for the most cancer risk from airborne exposure declined by 76 percent between 1990 and 2012.7 Concentrations of diesel particulate matter, a key TAC, declined by 68 percent between 1990 and 2012, despite a 31 percent increase in State population and an 81 percent increase in diesel vehicle miles traveled (VMT), as shown on Figure 4.1-1, below. The study also found that the significant reductions in cancer risk to California residents from the implementation of air toxics controls are likely to continue.

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

Figure 4.1-1: California Population, Gross State Product (GSP), Diesel Cancer Risk, and Diesel Vehicle Miles Traveled (VMT) Regulatory Context The USEPA and the CARB regulate direct emissions from motor vehicles. The SJVAPCD is the regional agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as monitoring ambient pollutant concentrations.

4.1.2.6 Sensitive Receptors
Those individuals who are sensitive to air pollution include children, the elderly, and persons with pre‐existing respiratory or cardiovascular illness. The SJVAPCD considers a sensitive receptor to be a location that houses or attracts children, the elderly, people with illnesses, or others who are especially sensitive to the effects of air pollutants. Examples of sensitive receptors include hospitals,

7 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).
100%
0 O'I
O'I
""" E
2 ';; 0%
QI)
C
ta
.c u
'$.
-100%
1990 1995 2000
LSA
DieselVMT
Popul
1 ation
Diesel Cancer Ris
2005 2010

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)

4.1-16
residences, convalescent facilities, and schools. There are many sensitive receptors throughout the city of Fresno and the Specific Plan Area.

4.1.3 Regulatory Framework
Federal, State, and local air districts have passed laws and regulations intended to monitor and improve air quality. The Specific Plan Area is subject to the rules and regulations imposed by the SJVAPCD, the California Air Resource Board (CARB), and the United States Environmental Protection Agency (USEPA). The USEPA and CARB regulate direct emissions from motor vehicles while the SJVAPCD is the regional agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as monitoring ambient pollutant concentrations. The federal, State, regional, and local regulatory framework that is applicable to the proposed project is discussed below.

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

The federal CAA required the USEPA to establish primary and secondary national ambient air quality standards (NAAQS) and required each state to prepare an air quality control plan referred to as a State Implementation Plan (SIP). The federal CAA Amendments of 1990 added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins as reported by their jurisdictional agencies. The USEPA has responsibility to review all state SIPs to determine conformity with the mandates of the federal CAA and determine if implementation will achieve air quality goals. If the USEPA determines a SIP to be inadequate, a Federal Implementation Plan (FIP) may be prepared for the nonattainment area, which imposes additional control measures. Failure to submit an approvable SIP or to implement the plan within the mandated timeframe may result in sanctions on transportation funding and stationary air pollution sources in the air basin.

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

4.1.3.2 State Policies and Regulations
The CARB is the Lead Agency for implementing air quality regulations in the State. Key efforts by the State are described below.

California Clean Air Act. In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain compliance with California Ambient Air Quality Standards (CAAQS) for carbon monoxide, ozone, sulfur dioxide and nitrogen dioxide by the earliest 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)

4.1-17
practical date. The CCAA provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district-wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.

Legal authority for California to regulate sources of air pollution is found in federal and State law.

The CARB is charged with coordinating regional and local efforts to attain and maintain State and nation air quality standards. The CARB has been given authority to regulate many sources that would normally be pre‐empted by federal regulations through the issuance of waivers.

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

Low-Emission Vehicle Program. The CARB introduced the Low‐Emission Vehicle (LEV) program in 1990. The first LEV standards ran from 1994 through 2003 before, the LEV II regulations, which ran from 2004 through 2010, were introduced which represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars, rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 SIP. In 2012, CARB again amended the LEV regulations with the introduction of the LEV III standards. These amendments include more stringent emission standards for both criteria pollutants and greenhouse gases for new passenger vehicles.

Air Quality Land Use Handbook. The CARB has developed an Air Quality and Land Use Handbook 8 which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process.

According to the CARB Handbook, recent air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals found in vehicle emissions are responsible for much of the overall cancer risk related to airborne toxins in California.

The CARB Handbook recommends that county and city planning agencies strongly consider proximity to vehicle emission sources when finding new locations for "sensitive" land uses including homes, medical facilities, daycare centers, schools, and playgrounds.

8 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.

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)

4.1-18
Land use designations with air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners and large gasoline service stations. Key recommendations in the Handbook include taking steps to avoid sitting new, sensitive land uses within the following proximities:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000 vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard; • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries; • Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet); and
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater).

The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use agencies have to balance other considerations, such as housing and transportation needs, economic development priorities, and other quality of life issues.

The recommendations are generalized and do not consider site specific meteorology, freeway truck percentages, or other factors that influence risk for a particular project site. The purpose of the land use compatibility analysis is to further examine the project site for actual health risk associated with the location of new housing on the project site.

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

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

The SJVAPCD’s Air Quality Attainment Plans include measures to promote air quality elements in county and city general plans as one of the primary means of reducing indirect emissions such as those from land use development projects. The approved General Plan is the primary long range planning document used by cities and counties to direct development. Since air districts have no authority over land use decisions, it is up to cities and counties to ensure that their general plans help achieve air quality goals. Section 65302.1 of the California Government Code requires cities 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)

4.1-19
and counties in the San Joaquin Valley to amend appropriate elements of their general plans to include data, analysis, comprehensive goals, policies, and feasible implementation strategies to improve air quality in their next housing element revisions. 9 The SJVAB is classified nonattainment for ozone, PM10, and PM2.5. The SJVAPCD had adopted project level thresholds based on a cumulative contribution of ozone precursors ROG and NOx of 10 tons per year and thresholds for PM10 and PM2.5 of 15 tons per year.

Current Air Quality Plans. The SJVAPCD is responsible for formulating and implementing the Air Quality Management Plan (AQMP) for the SJVAB. The main purpose of an AQMP is to bring the area into compliance with federal and State air quality standards. The SJVAPCD does not have one single AQMP for criteria pollutants, rather the SJVAPCD address each criteria pollutant with its own Plan. The SJVAPCD has the following AQMPs:
10 • 2024 Plan for the 2012 Annual PM2.5 Standard
• 2022 Plan for the 2015 8-Hour Ozone Standard
• 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards • 2016 Moderate Area Plan for the 2012 PM2.5 standard
• 2016 Plan for the 2008 8-Hour Ozone Standard
• 2013 Plan for the Revoked 1-Hour Ozone Standard
• 2007 PM10 Maintenance Plan
• 2004 Revision to the California State Implementation Plan for Carbon Monoxide The SJVAPCD’s AQMPs incorporate the latest scientific and technological information and planning assumptions, including updated emission inventory methodologies for various source categories. The SJVAPCD’s AQMPs included the integrated strategies and measures needed to meet the National Ambient Air Quality Standards (NAAQS), implementation of new technology measures, and demonstrations of attainment of the 1-hour and 8-hour ozone NAAQS as well as the latest 24-hour and annual PM

2.5 standards.

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

Ozone Plans. The SJVAPCD’s Governing Board approved the 2022 Plan for the 2015 8-hour ozone standard on December 15, 2022. The comprehensive strategy in this plan will reduce NO
x emissions by 72 percent by 2037 and will bring the San Joaquin Valley into attainment of USEPA’s 2015 8-hour ozone standard as expeditiously as practicable by the 2037 attainment deadline.

9 California Legislative Information. 2025. California Government Code. Website: https://leginfo.legislature. ca.gov/faces/codes_displaySection.xhtml?sectionNum=65302.01.&nodeTreePath=12.1.10.3&lawCode= GOV (accessed June 10, 2025).
10 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2025. Air Quality Attainment Plans. Website:
https://ww2.valleyair.org/rules-and-planning/air-quality-plans/ (accessed June 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)

4.1-20
Particulate Matter Plans. The SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007 to assure the SJVAB’s continued attainment of the USEPA’s PM10 standard.

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

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

The SJVAPCD prepared the 2012 PM2.5 Plan to bring the San Joaquin Valley into attainment of the USEPA’s most recent 24‐hour PM2.5 standard of 35 μg/m³. The CARB approved the SJVAPCD’s 2012 PM2.5 Plan at a public hearing on January 24, 2013. The plan, approved by the SJVAPCD Governing Board on December 20, 2012, will bring the valley into attainment for USEPA’s 1997 PM2.5 standard as expeditiously as practicable, but no later than, December 31, 2020.

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

Rules and Regulations. The SJVAPCD rules and regulations that may apply to projects that will occur during buildout of the Specific Plan Area include but are not limited to the following:
• Rule 2280 – Portable Equipment Registration. Portable equipment used at project sites for less than six consecutive months must be registered with the SJVAPCD. The SJVAPCD will issue the registrations 30 days after receipt of the application. • Rule 2303 – Mobile Source Emission Reduction Credits. A project may qualify for SJVAPCD vehicle emission reduction credits if it meets the specific requirements of Rule 2303 for any of the following categories:
○ Low-Emission Transit Buses
○ Zero-Emission Vehicles
○ Retrofit Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles ○ Retrofit Heavy-Duty Vehicles
• Rule 4102 – Nuisance. The purpose of this rule is to protect the health and safety of the public and applies to any source operation that emits or may emit air contaminants or other materials.

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)

4.1-21
• Rule 4601 – Architectural Coatings. The purpose of this rule is to limit Volatile Organic Compounds (VOC) emissions from architectural coatings. Emissions are reduced by limits on VOC content and providing requirements on coatings storage, cleanup, and labeling.
• Rule 4641 – Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations. The purpose of this rule is to limit VOC emissions from asphalt paving and maintenance operations. The paving operations for new development and existing paved surfaces will be subject to Rule 4641.
• Rule 8011 – General Requirements: Fugitive Dust Emission Sources. Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, including construction operations, must control fugitive dust emissions in accordance with SJVAPCD Regulation VIII. According to Rule 8011, the SJVAPCD requires the implementation of control measures for fugitive dust emission sources. For projects in which construction-related activities would disturb equal to or greater than 1 acre of surface area, the SJVAPCD recommends that demonstration of receipt of an SJVAPCD- approved Dust Control Plan or Construction Notification Form, before issuance of the first grading permit, be made a condition of approval.
• Regulation VIII – Fugitive PM
10 Prohibitions. Rules 8011‐8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and track out, etc. All development projects that involve soil disturbance are subject to at least one provision of the Regulation VIII series of rules.
• Rule 9410 – Employer Based Trip Reduction. The purpose of this rule is to reduce vehicle miles traveled (VMT) from private vehicles used by employees to commute to and from their worksites in order to reduce emissions of NO
x, VOC and PM. The rule requires
larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes. The rule uses a menu-based Employer Trip Reduction Implementation Plan and periodic reporting requirements to evaluate performance on a phased‐in compliance schedule.
• Rule 9510 – Indirect Source Review. This rule reduces the impact of NO x and PM10
emissions from new development projects. The rule places application and emission reduction requirements on development projects meeting applicability criteria in order to reduce emissions through onsite mitigation, offsite SJVAPCD‐administered projects, or a combination of the two. Compliance with SJVAPCD Rule 9510 reduces emissions impacts through incorporation of onsite measures as well as payment of an offsite fee that funds emission reduction projects in the Air Basin. The emissions analysis for Rule 9510 is detailed and is dependent on the exact project design that is expected to be constructed or installed. Compliance with Rule 9510 is separate from the CEQA process, 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)

4.1-22
though the control measures used to comply with Rule 9510 may be used to mitigate significant air quality impacts.
• Odor impacts on
residential areas and other sensitive receptors, such as hospitals, day- care centers, schools, etc., warrant the closest scrutiny, but consideration could also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas. While offensive odors rarely cause any physical harm, they can be very unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and the SJVAPCD.

Two situations create a potential for odor impact. The first occurs when a new odor source is located near an existing sensitive receptor. The second occurs when a new sensitive receptor locates near an existing source of odor. The SJVAPCD has determined the common land use types that are known to produce odors in the Basin. These types are shown in Table 4.1.E, along with recommended distances to screen for potential odor impacts.

Table 4.1.E: Screening Levels for Potential Odor Sources Odor Generator Distance
Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Composting Facility 1 mile
Petroleum Refinery 2 miles
Asphalt Batch Plant 1 mile
Chemical Manufacturing 1 mile
Fiberglass Manufacturing 1 mile
Painting/Coating Operations (e.g., auto body shop) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Source: San Joaquin Valley Air Pollution Control District (2015b).

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

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)

4.1-23
communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every four years. The SCS is intended to show how integrated land use and transportation planning can lead to lower greenhouse gas (GHG) emissions from autos and light trucks. Fresno COG has included the SCS in its 2022 RTP.

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

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

In practice, air quality plans include criteria pollutant emission budgets required for attainment of air quality standards by mandated deadlines. The budgets must not be exceeded considering projected growth in mobile source activity. The FCOG 2024 Conformity Analysis determined that the conformity tests for ozone, PM
10 and PM2.5 revealed that all years are projected to be less than the approved emissions budgets and, as such, the conformity tests are satisfied.11

4.1.3.4 Local Policies and Regulations
The following is a summary of the applicable policies included in the City’s approved General Plan that are related to air quality and applicable to the proposed project.

City of Fresno General Plan. The approved General Plan is a set of policies and programs that form a blueprint for the physical development of the City. The following objectives and policies related to air quality are presented in various elements of the approved General Plan:

Resource Conservation and Resilience Element.

Objective RC‐4: In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take necessary actions to achieve and maintain compliance with State and federal air quality standards for criteria pollutants.

Policy RC-4-a: Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and mobile

11 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.fresno cog.org/wp-content/uploads/2023/11/Final-FresnoCOG-2025-FTIP-Conformity-Boilerplate_05312024-

1.pdf (accessed June 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)

4.1-24
sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan.

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

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

Policy RC-4-d: Forward Information. Forward information regarding proposed General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals that require air quality evaluation, and amendments to development regulations to the SJVAPCD for their review of potential air quality and health impacts.

Policy RC-4-e: Support Employer-Based Efforts. Support and promote employer implementation of staggered work hours and employee incentives to use carpools, public transit, and other measures to reduce vehicular use and traffic congestion.

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

Policy RC-4-j: All Departments. Continue to develop and implement in all City departments, operational policies to reduce air pollution.

Policy RC-4-k: Electric Vehicle Charging. Develop standards to facilitate electric vehicle charging infrastructure in both new and existing public and private buildings, in order to accommodate these vehicles as the technology becomes more widespread.

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)

4.1-25
Healthy Communities Element.

Pol
icy HC-3-b: Ho
using-Related Illness Assessment and Testing. Support efforts to provide community assessment and testing programs for housing-related illnesses (i.e., blood lead levels, respiratory health, and skin conditions).

Pol
icy HC-3-d: Gr
een Standards for Affordable Housing. Provide appropriate incentives for affordable housing providers, agencies, non-profit, and market rate developers to use LEED and CALGreen Tier 1 or Tier 2 standards or third-party equivalents.

Pol
icy HC-3-f: N
ew Drive-Through Facilities. Incorporate design review measures in the Development Code to reduce vehicle emissions resulting from queued idling vehicles at drive-through facilities proximate to residences.

4.1.4 Significance Criteria
The thresholds for impacts to air quality used in this analysis are consistent with Appendix G of the State CEQA Guidelines. The implementation of the Specific Plan Update would result in a significant impact related to air quality if it would:
• Conflict with or obstruct implementation of the applicable air quality plan; • Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard; • Expose sensitive receptors to substantial pollutant concentrations; or • Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The SJVAPCD is the applicable air pollution control district for the SJVAB, which includes the city of Fresno and the Tower District. The SJVAPCD has adopted thresholds of significance in its GAMAQI that are used where appropriate in the following analysis. While the final determination of whether a project is significant is within the purview of the Lead Agency pursuant to Section 15064(b) of the State CEQA Guidelines, SJVAPCD recommends that its quantitative air pollution thresholds be used to determine the significance of project emissions. If the City as Lead Agency finds that the project has the potential to exceed these air pollution thresholds, the project will be considered to have significant air quality impacts.

4.1.4.1 Regional Emissions Thresholds
A threshold of significance is defined by the SJVAPCD in its GAMAQI 12 as an identifiable quantitative,
qualitative, or performance level of a particular environmental effect. Non-compliance with a

12 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. March 19. Website: www.valleyair.org/transportation/ceqa_idx.htm (accessed June 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)

4.1-26
threshold of significance means the effect will normally be determined to be significant. Compliance with a threshold of significance means the effect normally will be determined to be less than significant. The SJVAPCD has established thresholds of significance for criteria pollutant emissions generated during construction and operation of projects as shown in Table 4.1.F, below.

Table 4.1.F: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year)
CO NOx ROG SOx PM10 PM2.5
Construction Thresholds 100 10 10 27 15 15
Operation Thresholds 100 10 10 27 15 15
Source: Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015a).

CO = carbon monoxide
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
ROG = reactive organic gas
SJVAPCD = San Joaquin Valley Air Pollution Control District SOX = sulfur oxides

The emissions thresholds in the SJVAPCD GAMAQI were established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks.

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

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the SJVAB:
• MICR: MICR is the estimated probability of a maximally exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 70 years for adults and 9 years for children in residential locations, 350 days per year. The SJVAPCD’s Update to the District’s Risk Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 20 in 1 million.
• Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multi- pathway consideration when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location.

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)

4.1-27
• Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

4.1.5 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to air quality 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.

4.1.5.1 Project Impacts
The following discussion describes the potential impacts related to air quality that could result from the implementation of the Specific Plan Update.

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

The proposed project was assessed to determine if the impacts from implementation of the Specific Plan Update would conflict with or obstruct the implementation of the applicable attainment plan.

As defined above, the proposed project is the buildout facilitated by implementation of the Specific Plan Update. Buildout is predicted to occur at growth rates consistent with those used by the SJVAPCD to develop plans for all nonattainment pollutants in the SJVAB. The growth rate used for this analysis results in buildout by the year 2046.

An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a nonattainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. To bring the San Joaquin Valley into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8-hour ozone standard in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 70 parts per billion (ppb) 8-hour ozone standard.

To ensure the SJVAB’s continued attainment of the USEPA PM 10 standard, the SJVAPCD adopted the
2007 PM10 Maintenance Plan in September 2007.13 The SJVAPCD adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards in November 2018 to address the USEPA 1997 annual PM2.5

13 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).

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)

4.1-28
standard of 15 micrograms per cubic meter (µg/m3) and 24-hour PM2.5 standard of 65 µg/m3, the 2006 24-hour PM2.5 standard of 35 μg/m³, and the 2012 annual PM2.5 standard of 12 μg/m³.14 CEQA requires that certain proposed projects be analyzed for consistency with the applicable air quality plan as it relates to a region’s non-attainment status. An air quality plan describes air pollution control strategies to be implemented in a non-attainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. As discussed above, the SJVAB is designated as non-attainment for O 3 and
PM2.5 for federal standards and non-attainment for O3, PM10, and PM2.5 for State standards.

Therefore, to bring the SJVAB into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8-Hour Ozone Standard in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 75 ppb 8-hour ozone standard.

To assure the SJVAB’s continued attainment of the USEPA PM 10 standard, the SJVAPCD adopted the
2007 PM10 Maintenance Plan in September 2007. SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions) is designed to reduce PM10 emissions generated by human activity. The SJVAPCD adopted the 2018 plan for the 1997, 2006, and 2012 PM2.5 standards to address the USEPA federal annual PM2.5 standard of 12 µg/m3, established in 2012.

For a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant impact on air quality. In addition, emission reductions achieved through implementation of offset requirements are a major component of the SJVAPCD air quality plans.

As discussed below, construction of the proposed project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. In addition, as discussed below and shown in Table 4.1.H, long-term operational emissions associated with the proposed project, including area, energy, and mobile source emissions, would also not exceed SJVAPCD established significance thresholds. Therefore, impacts related to the proposed project’s potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant.

In addition, reductions anticipated from existing regulations and adopted control measures will result in emissions continuing to decline. The proposed project would allow for implementation of the City’s sustainability efforts that reduce motor vehicle use and energy consumption. This is accomplished with more compact development achieved by increasing development density and by providing a land use pattern and transportation infrastructure more supportive of public transportation, walking, and bicycling. The City also participates in regional planning efforts and works closely with FCOG in developing Regional Transportation Plans and capital improvement plans. These efforts contribute to the attainment strategy for the SJVAB.

14 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15. Website: http://valleyair.org/pmplans/documents/2018/pm -plan- adopted/2018-Plan-for-the-1997-2006-and-2012-PM2.5-Standards.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)

4.1-29
Furthermore, the SJVAPCD has adopted rules and regulations specifically designed to reduce the impacts of growth on the applicable air quality plans. For example, Rule 9510, Indirect Source Review, was adopted to provide emission reductions needed by the SJVAPCD to demonstrate attainment of the federal PM
10 standard and contribute to reductions that assist in attaining federal ozone standards. Rule 9510 also contributes toward attainment of State standards for these pollutants. The SJVAPCD’s Regulation VIII, Fugitive PM
10 Prohibitions, requires controls for sources of
particulate matter necessary for attaining the federal PM10 standards and achieving progress toward attaining the State PM10 standards. Rule 2201, New and Modified Stationary Source Review, requires new and modified stationary/industrial sources provide emission controls and offsets that ensure that stationary sources decline over time and do not impact the applicable air quality plans.

Development associated with the proposed project would comply with these rules and regulations providing additional support for the conclusion that it would not interfere or obstruct with the application of the attainment plans.

Therefore, the proposed project’s potential air quality impacts from construction and operation would not exceed any applicable threshold of significance and would not conflict with or obstruct the applicable Clean Air Plan. Therefore, the proposed project’s potential impacts on the applicable air quality plan are less than significant. No mitigation would be required.

Level of Significance Without Mitigation: Less than Significant Impact AIR-2 The proposed project would not result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under an applicable federal or State ambient air quality standard.

Construction activities would generate emissions at the site from off-road construction equipment, and on roadways as a result of construction-related truck hauling, vendor deliveries, and worker commuting. Operational activities would also generate emissions within the Specific Plan Area from miscellaneous on-site sources, such as natural gas combustion for cooking, heating, and landscaping equipment, and from operational-related traffic. This analysis utilized the California Emissions Estimator Model (CalEEMod) version 2022.1 to quantify the criteria pollutant emissions for both construction and operation of the proposed project. The maximum daily emissions are calculated for the criteria pollutants. The CalEEMod outputs are contained in Appendix E of this EIR, Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report (LSA 2025a)
15 (Air Quality, GHG, and Energy Analysis Report).

Guidance from the United States Environmental Protection Agency (USEPA), the California Air Resources Board (CARB), and the SJVAPCD, and emissions modeling software (specifically, CalEEMod
16) were used to calculate the criteria pollutant emissions from the proposed project.

15 LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
16 California Air Pollution Control Officers Association (CAPCOA). 2017. California Emissions Estimator Model. Version 2016.3.2. Website: http://www.caleemod.com/ (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)

4.1-30
The SJVAB is designated as non-attainment for O3 and PM2.5 for federal standards and non- attainment for O3, PM10, and PM2.5 for State standards. The SJVAPCD’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.

Although these thresholds are intended for use on individual development projects, no other quantitative plan level threshold has been adopted. Implementation of the proposed project would provide for the development of numerous individual development projects that would be subject to the project level thresholds at the time they are proposed. Large individual projects are likely to exceed the thresholds during project construction and operation.

The
following analysis assesses the potential impacts associated with the buildout of the proposed project that would result in air pollutant emissions from short-term construction activities and long-
term p
roject operation.

Con
struction. During construction, short-term degradation of air quality may occur due to the release of particulate emissions generated by grading, paving, building, and other activities.

Emissions from construction equipment are also anticipated and would include CO, NO x, ROG,
directly-emitted particulate matter (PM2.5 and PM10), and TACs such as diesel exhaust particulate matter.

Construction activities associated with implementation of the proposed project would include site preparation, grading, paving, and building activities. Construction-related effects on air quality from the proposed project would be greatest during the site preparation phase due to the disturbance of soils. If not properly controlled, these activities would temporarily generate particulate emissions.

Sources of fugitive dust would include disturbed soils at the construction site. Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PM
10 emissions would vary from day to day,
depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and the amount of operating equipment. Larger dust particles would settle near the source, while fine particles would be dispersed over greater distances from the construction site.

Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. The SJVAPCD has implemented Regulation VIII measures for reducing fugitive dust emissions (PM
10). Consistent with SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions), the following controls are required to be included as specifications for the proposed project and implemented at 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)

4.1-31
the construction site. With the implementation of Regulation VIII measures, fugitive dust emissions from construction activities would not result in adverse air quality impacts. • All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/ suppressant, covered with a tarp or other suitable cover or vegetative ground cover. • All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant. • All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking.
• When materials are transported off-site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least 6 inches of freeboard space from the top of the container shall be maintained.
• All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. (The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions.

Use of blower devices is expressly forbidden.)
• Following the addition of materials to, or the removal of materials from, the surface of out-door storage piles, said piles shall be effectively stabilized of fugitive dust emission utilizing sufficient water or chemical stabilizer/suppressant.

In addition to dust-related PM
10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, SO2, NOx, ROG, and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

Construction emissions 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 plan in 2026. However, 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 future construction will begin in January 2026 and be operational in 2046.

Construction phases are expected to occur consecutively; therefore, this analysis evaluates construction emissions as a whole and not per phase. Site preparation would include removal of rocks, debris, and vegetation from the Specific Plan Area. 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 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)

4.1-32
worker and truck trips and construction fleet activities) from CalEEMod were used. Construction- related emissions are presented in Table 4.1.G. CalEEMod output sheets are included in Appendix E in the Air Quality, GHG, and Energy Analysis Report (LSA 2025a).17 Table 4.1.G: Project Construction Emissions (tons per year) Project Construction Year ROG NOX CO SOX PM10 PM2.5
2026 0.1 5.1 3.7 <0.1 1.1 0.6
2027 0.2 6.1 4.4 <0.1 0.8 0.4
2028 0.7 5.1 7.5 <0.1 1.3 0.4
2029 1.0 4.1 9.1 <0.1 1.9 0.5
2030 0.9 4.0 8.6 <0.1 1.9 0.5
2031 0.9 3.9 8.2 <0.1 1.9 0.5
2032 0.8 3.8 7.9 <0.1 1.9 0.5
2033 0.8 3.8 7.9 <0.1 1.9 0.5
2034 0.8 3.8 7.2 <0.1 1.9 0.5
2035 0.7 3.7 7.0 <0.1 1.9 0.5
2036 0.7 3.7 6.8 <0.1 1.9 0.5
2037 0.7 3.6 6.6 <0.1 1.9 0.5
2038 0.6 3.6 6.4 <0.1 1.9 0.5
2039 0.6 3.6 6.3 <0.1 1.9 0.5
2040 0.6 3.5 6.1 <0.1 1.9 0.5
2041 0.6 3.5 6.1 <0.1 1.9 0.5
2042 0.5 3.5 6.0 <0.1 1.9 0.5
2043 0.5 3.2 5.2 <0.1 1.6 0.4
2044 2.8 1.2 1.2 <0.1 0.2 0.1
2045 8.5 0.2 0.8 <0.1 0.3 0.1
2046 0.1 <0.1 <0.1 <0.1 <0.1 <0.1
Maximum Annual
Construction Emissions

8.5 6.1 9.1 <0.1 1.9 0.5
SJVAPCD Thresholds 10.0 10.0 100.0 27.0 15.0 15.0
Exceeds? No No No No No No
Source: Compiled by LSA (July 2025).

CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOCs = volatile organic compounds

As shown in Table 4.1.G, construction emissions for the proposed project would not exceed the SJVAPCD annual threshold for construction emissions.

The buildout associated with the proposed project would result in numerous potentially individual development projects. Information regarding specific development projects, soil conditions, and the location of sensitive receptors in relation to the various projects would be needed in order to determine localized impacts associated with construction activity. However, overall estimates based on annual rates of construction activity required to reach buildout provide a reasonable method for determining an annual contribution rate for construction emissions. Emissions from construction

17 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)

4.1-33
activities are expected to decline over time as new cleaner equipment replaces older higher emitting equipment.

Furthermore, SJVAPCD and State regulations have been created to reduce construction emissions.

SJVAPCD Regulation VIII includes requirements to control fugitive dust emissions during construction activities and requires commercial projects over 5 acres and residential projects over 10 acres to file a Dust Control Plan. If measures included in the Dust Control Plan prove inadequate to control fugitive dust, construction contractors must implement additional controls or cease dust generating construction activities. In addition, projects smaller than the Dust Control Plan size thresholds must still comply with most other Regulation VIII requirements. The SJVAPCD indicates that the control measures in Regulation VIII are required by regulation for all construction sites to reduce fugitive dust emissions. These control measures are intended to reduce the amount of PM 10 emissions during the construction period. Implementation of the fugitive dust control measures outlined in Mitigation Measure AIR-1, would ensure that the proposed project complies with Regulation VIII and further reduces the short-term construction period air quality impacts. The GAMAQI also lists additional measures that may be required because of sheer project size or proximity of the project to sensitive receptors. The additional measures are referred to as “enhanced control measures” in the GAMAQI. These enhanced control measures have been added as amendments to Regulation VIII, so they are no longer considered mitigation measures that could be imposed on very large or sensitive projects, but standard control measures required for rule compliance.

The
CARB has also adopted regulations for new off-road
diesel engines and equipment that result in
cleaner equipment being placed in service as older, higher emitting equipment is retired. The CARB also adopted the in
-use
off-road d
iesel vehicle regulation requiring NOx and PM10 emission reductions from equipment and vehicles currently in operation. CARB also requires retrofits of existing equipment to reduce particulate emissions that will help reduce emissions from older equipment. Regulations are normally implemented over a 5 to 10 year period at which time a new round of regulations are proposed if they are still needed to attain the air quality standards. The CARB has a long history of tightening regulations as technology advances increase the feasibility of additional controls. Large individual projects that exceed the SJVAPCD project thresholds will be required to include feasible mitigation measures that reduce the significant impact. The measures could include additional onsite controls or off
-site
mitigation fees that reduce emissions to less than
significant levels.

Furt
hermore, Rule 9510 – Indirect Source Review requires projects to reduce exhaust related construction emissions by 20 percent for NOx and by 50 percent for PM10; however, significance for these emissions is based on whether projects exceed the SJVAPCD annual quantitative thresholds.

Therefore, construction associated with implementation of the proposed project would result in a less than significant impact related to a cumulative considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State ambient air quality standard. Compliance with SJVAPCD regulatory measures would further reduce construction emissions to a less than significant level. Therefore, construction of the proposed project would result in a less than significant impact. No mitigation would be required.

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)

4.1-34
Operation. Long-term air pollutant emission impacts are those associated with mobile sources (e.g., vehicle trips), energy sources (e.g., electricity and natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment.

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

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

Energy source emissions result from activities in buildings for which electricity and natural gas are used. The quantity of emissions is the product of usage intensity (i.e., the amount of electricity or natural gas) and the emission factor of the fuel source. It is not yet known whether the proposed project would utilize natural gas. As described in Section 4.4 Greenhouse Gas Emissions, future development projects would need to implement Mitigation Measure GHG-1, which would require projects to incorporate project design measures consistent with the 2022 Scoping Plan GHG requirements, including limiting the use of natural gas in new development. However, consistent with existing buildings that use natural gas and in order to provide a more conservative analysis, this analysis conservatively assumes that natural gas will continue to be used by existing buildings and is included as part of the project operations.

Area source emissions consist of direct sources of air emissions located at a project site, including architectural coatings and the use of landscape maintenance equipment.

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 proposed project would promote more mixed-use development along commercial corridors served by transit by creating corridor/center mixed use and neighborhood mixed use areas, specifically on Blackstone Avenue and Shields Avenue. This would allow for ground level commercial uses fronting public streets and sidewalks, while residential uses would be located above or behind. This would continue to promote the walkability of the Tower District and reduction of vehicle miles traveled while allowing for greater residential development.

Consistent with the SJVAPCD guidance for estimating emissions associated with land use development projects, CalEEMod was used to calculate the long-term operational emissions associated with the proposed project. The proposed project analysis was conducted using land use codes Single Family Housing, Apartments Low Rise, Industrial Park, and Strip Mall. Trip generation rates used in CalEEMod for the proposed project were based on the project’s trip generation described in Section 4.17, Transportation, of the Initial Study (included in Appendix C of this EIR), 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. Where project-specific data were not available, default assumptions (e.g., energy usage, water usage, and solid waste generation) 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)

4.1-35
CalEEMod were used to estimate project emissions. CalEEMod output sheets are included in Appendix E in the Air Quality, GHG, and Energy Analysis Report.18 The majority of the area within the Specific Plan Area is already developed and not expected to change. However, implementation of the proposed project would allow for future development projects in the Tower District Specific Plan Area that would result in potential increase in planned residential uses and a decrease in commercial land uses when compared to the 1991 Specific Plan and General Plan approved land uses. Therefore, long-term operational emissions associated with those land uses 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.

Therefore, this analysis was conducted using land use codes Single Family Housing, Apartments Low Rise, Industrial Park, and Strip Mall. Trip generation rates used in CalEEMod were based on the trip generation described in Section 4.17, Transportation, which identifies that the buildout of the 1991 Specific Plan and General Plan would generate approximately 36,054 ADT, which was included in CalEEMod. This analysis assumes an operational year of 2046, 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, in the Air Quality, GHG, and Energy Analysis Report (LSA 2025a). 19 The estimated operational emissions for the proposed project and the estimated emissions associated with the Approved Specific Plan are shown in Table 4.1.H.

Table 4.1.H: Estimated Operational Emissions (tons per year) Emission Source ROG NOX CO SOX PM10 PM2.5
Approved Specific Plan – Existing Emissions
Mobile 22.6 19.3 131.8 0.3 24.2 6.3
Area 17.1 1.2 35.1 0.1 3.0 2.9
Energy 0.2 3.7 1.9 <0.1 0.3 0.3
Total Existing Emissions 39.8 24.2 168.8 0.4 27.5 9.5
Proposed Project Emissions
Mobile 12.2 11.2 78.5 0.2 25.5 6.6
Area 17.9 0.2 17.6 <0.1 <0.1 <0.1
Energy 0.3 4.4 2.3 <0.1 0.4 0.4
Total Proposed Project
Emissions

30.4 15.8 98.4 0.2 25.9 7.0
Total Net Emissions (Proposed
Project – Existing Emissions)
-9.4 -8.4 -70.4 -0.2 -1.6 -2.5
SJVAPCD Thresholds 10.0 10.0 100.0 27.0 15.0 15.0
Exceeds Threshold? No No No No No No
Source: Compiled by LSA (July 2025).

18 LSA Associates, Inc. (LSA). 2025a. Tower District Specific Plan Air Quality, Greenhouse Gas Emissions, and Energy Impact Analysis Report.
19 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)

4.1-36
The results in Table 4.1.H indicate the total net operational emissions would not exceed the significance criteria for annual ROG, NOx, CO, SOx, PM10, or PM2.5 emissions. The air quality 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 air quality impacts to further ensure that operational-related emissions are reduced to the maximum extent feasible for projects that require environmental evaluation under CEQA.

Since the 1991 Specific Plan (Approved Specific Plan), there has been a shift to mandate clean energy (such as solar, hydroelectric, wind, and nuclear sources), resulting in reductions in air quality 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 criteria pollutant emissions. Various policies of the Fresno General Plan and the proposed Specific Plan Update would promote complete streets, mixed-use and transit-oriented neighborhoods, and increased capacity for alternative transportation modes, which would help further reduce air pollutant emissions. Implementation of 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.

Therefore, operation of the proposed project would result in a less-than-significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the proposed project region is in nonattainment under an applicable federal or State ambient air quality standard.

Impacts would be less than significant, and no mitigation would be required.

Level of Significance Without Mitigation: Less than Significant Impact AIR-3 The proposed project would expose sensitive receptors to substantial pollutant concentrations.

Localized Health Risk. Proposed projects associated with the implementation of the proposed project that would emit TACs would require review under SJVAPCD rules and regulations or review under CEQA, especially if located near sensitive receptors. Projects with sensitive receptors proposed near localized sources of TAC emissions (e.g., residents to be located near major roadways or stationary sources) could expose new sensitive populations to TACs and other air pollutants.

According to the CARB and SJVAPCD, exposure to elevated levels of TACs contribute to elevated health risks. The CARB recommends that buffers should be included to avoid exposure of sensitive receptors to TAC sources. Risk levels drop dramatically beyond 500 feet from a source due to dispersion of emissions with distance.

It should be noted that the amount of emissions from a project does not necessarily correspond to the concentrations of air pollutants. A dispersion modeling analysis would be necessary to calculate 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)

4.1-37
health risk from project implementation. However, since it is not possible to translate the amount of an unknown future specific project’s emissions to a particular concentration, it is not possible to calculate the risk factor for a particular health effect at the time of this analysis.

Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema and a decrease in lung function. Particulate matter can also lead to a variety of health effects in people. These include premature death of people with heart or lung disease, heart attacks, irregular heartbeat, decreased lung function, and increased respiratory symptoms.

Regional emissions of criteria pollutants contribute to these known health effects. The SJVAPCD is the primary agency responsible for ensuring the health and welfare of sensitive individuals and that they are not exposed to elevated concentrations of criteria pollutants in the SJVAB. The SJVAPCD’s numeric regional mass daily emission thresholds are based in part on Section 180 (e) of the CAA. The numeric regional mass daily emission thresholds are intended to provide a means of consistency in significance determination within the environmental review process. To achieve the health-based standards established by the USEPA, the SJVAPCD prepares an AQMP that details regional programs to attain the ambient air quality standards.

Notwithstanding, simply exceeding the SJVAPCD’s numeric regional mass daily emission thresholds does not constitute a particular health impact to an individual nearby. The reason for this is that the mass daily emission thresholds are in tons/year emitted into the air, whereas health effects are determined based on the concentration of a pollutant in the air at a particular location (e.g., ppm by volume of air or µg/m
3of air). CAAQS and NAAQS were developed to protect the most susceptible population groups from adverse health effects and were established in terms of ppm or µg/m3 for the applicable emissions.

As shown in Table 4.1.G and Table 4.1.H, project emissions would not be expected to exceed the most stringent applicable NAAQS or CAAQS for NOX, PM2.5, and PM10. It should be noted that the AAQS are developed and represent levels at which the most susceptible persons (children and the elderly) are protected. In other words, the AAQS are purposefully set low to protect children, the elderly, and those with existing respiratory problems. Furthermore, air quality trends for emissions of NO
X, VOCs, and O3 (which is a byproduct of NOX and VOCs) have been trending downward within the SJVAB even as development has increased over the last several years. Therefore, implementation of the Specific Plan Update is not expected to result in any SJVAB-wide increase in health effects.

As noted in the Brief of Amicus Curiae by the SJVAPCD (2015), the SJVAPCD has acknowledged that currently available modeling tools are not equipped to provide a meaningful analysis of the correlation between an individual development project’s air emissions and specific human health impacts. (See page 4 of the SJVAPCD Brief of Amicus Curiae.) Additionally, the SJVAPCD acknowledges that health effects quantification from O 3, as an example, is
correlated with the increases in ambient level of O3 in the air (concentration) that an individual person breathes. The SJVAPD indicates that it would take a large amount of additional emissions to result in a modeled increase in ambient O
3 levels over the entire region. As such, it is not currently possible to accurately quantify O3-related health impacts caused by NOX or VOC emissions from 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)

4.1-38
relatively small projects (defined as projects with a regional scope) due to photochemistry and regional model limitations.

Therefore, the project’s emissions are not sufficiently high to use a regional modeling program to correlate health effects on a Basin-wide level. Further, the SJVAPCD acknowledges the same:
“…the Air District is simply not equipped to analyze and to what extent the criteria pollutant emissions of an individual CEQA project directly impact human health in a particular area…even for projects with relatively high levels of emissions of criteria pollutant precursor emissions.” (See page 8 of the SJVAPCD Brief of Amicus Curiae.) The SJVAPCD Brief of Amicus Curiae is incorporated by reference into this environmental documentation for this project. Current scientific, technological, and modeling limitations prevent the relation of expected adverse air quality impacts to likely health consequences.

Since the results shown in Table 4.1.H indicate the proposed project’s operational emissions would not exceed significance criteria, the project would not result in a cumulatively considerable net increase of any criteria pollutant for which the proposed project region is in nonattainment under an applicable federal or State ambient air quality standard. The State and federal ambient air quality standards were established to protect public health. Therefore, since the significance criteria was set at a level to protect public health, the proposed project would not generate operational emissions that would result in impacts to public health.

Toxic Air Contaminant Emissions. Emissions of TACs would be controlled through permits issued by SJVAPCD and would be subject to further study and health risk assessment prior to the issuance of any necessary air quality permits. Since it is not possible to determine the amount of TAC concentrations at the time of this analysis, it is not possible to calculate the risks for a particular health effect within the Specific Plan Area. The proposed project is a programmatic project and until specific future projects are proposed, the associated TAC emissions cannot be determined or modeled at this time. Future development projects subject to environmental review under CEQA would be required to analyze potential TAC emissions and include mitigation as appropriate.

During construction and operation, the proposed project could result in emissions of several TACs that could potentially impact nearby sensitive receptors. The SJVAPCD has defined health risk significance thresholds. These thresholds are represented as a cancer risk to the public and a non- cancer hazard from exposures to TACs. Cancer risk represents the probability (in terms of risk per million individuals) that an individual would contract cancer resulting from exposure to TACs continuously over a period of several years. The SJVAPCD’s latest threshold of significance for TAC emissions is an increase in cancer risk for the maximally exposed individual of 20 in a million (formerly 10 in a million). Exposures to TACs can also result in both short-term (acute) or long-term (chronic) non-cancer health impacts. Such impacts could include illnesses related to reproductive effects, respiratory effects, eye sensitivity, immune effects, kidney effects, blood effects, central nervous system, birth defects, or other adverse environmental effects.

Project construction would involve the use of diesel-fueled vehicles and equipment that emit DPM, which is considered a TAC. Industrial land uses, such as chemical processing facilities, chrome- 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)

4.1-39
plating facilities, dry cleaners, and gasoline-dispensing facilities, have the potential to be substantial stationary sources that would require a permit from the SJVAPCD for emissions of TACs. The proposed project would allow for commercial and light industrial land uses that may include dry cleaners and gasoline-dispensing facilities. Emissions of TACs would be controlled through permits issued by the SJVAPCD and would be subject to further study and an HRA prior to the issuance of any necessary air quality permits. In addition to stationary/area sources of TACs, commercial and industrial operations could generate a substantial amount of diesel particulate matter emissions from off-road equipment use and truck idling. Land use projects are required to comply with AB 2588 and CARB standards for diesel engines. As stated above, until specific future projects are proposed, the associated emissions cannot be determined or modeled at this time. However, mitigation has been identified so that future projects would be subject to environmental review under CEQA and would be required to analyze potential emissions and include mitigation as appropriate.

Siting of Sensitive Receptors. Because placement of sensitive land uses falls outside CARB’s jurisdiction, CARB developed and approved the 2005 Air Quality and Land Use Handbook 20 address
the siting of sensitive land uses in the vicinity of freeways, distribution centers, rail yards, ports, refineries, chrome-plating facilities, dry cleaners, and gasoline-dispensing facilities. This guidance document was developed to assess compatibility and associated health risks when placing sensitive receptors near existing pollution sources.

CARB’s recommendations for the siting of new sensitive land uses were based on a compilation of recent studies that evaluated data on the adverse health effects from proximity to air pollution sources. The key observation in these studies is that proximity to air pollution sources substantially increases both exposure and the potential for adverse health effects. Respiratory and cardiovascular problems including asthma, lung cancer, and premature death have been associated with living near major roadways and freeways.
21 Children who live near major roadways and freeways have been found to have higher asthma rates and reduced lung function.22 There are three carcinogenic toxic air contaminants that constitute the majority of the known health risks from motor vehicle traffic:

DPM from trucks and benzene and butadiene from passenger vehicles. Exposure to DPM accounts for more than 80 percent of the total carcinogenic risk in the SJVAB. 23 It has been found that
outdoor concentrations are highest near the roadway and decrease with increasing distance downwind of the source.
24 CARB recommends avoiding siting new sensitive land uses within 500

20 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.
21 Balmes, J.R., Earnest, G., Katz, P.P., Yelin, E.E., Eisner, M.D., Chen, H., Trupin, L., Lurmann, F., and Blanc, P.D. 2009. Exposure to traffic: Lung function and health status of adults with asthma. The Journal of Allergy and Clinical Immunology, 123(3):626–631.
22 California Air Resources Board (CARB). 2013. Overview of the Children’s Health Study. Website:
https://ww2.arb.ca.gov/resources/documents/childrens-health-study (accessed July 2025). 23 South Coast Air Quality Management District (SCAQMD). 2008. Multiple Air Toxics Exposure Study in the South Coast Air Basin (MATES III). September.
24 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)

4.1-40
feet of urban roads with more than 100,000 vehicles per day or rural roads with more than 50,000 vehicles per day.25
Table 4.1.I shows a summary of the other CARB recommendations for siting new sensitive land uses within the vicinity of air pollutant sources. Recommendations in the table are based on data that show that localized air pollution exposures can be reduced by as much as 80 percent by following CARB minimum distance separations.

Table 4.1.I: CARB Recommendations for Siting New Sensitive Land Uses Source/Category Advisory Recommendations
Freeways and High-
Traffic Roads
Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day.

Distribution Centers Avoid siting new sensitive land uses within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week). Take into account the configuration of existing distribution centers and avoid locating residences and other sensitive land uses near entry and exit points.

Rail Yards Avoid siting new sensitive land uses within 1,000 feet of a major service and maintenance rail yard. Within 1 mile of a rail yard, consider possible siting limitations and mitigation approaches.

Ports Avoid siting new sensitive land uses immediately downwind of ports in the most heavily affected zones. Consult local air districts or CARB on the status of pending analyses of health risks.

Refineries Avoid siting new sensitive land uses immediately downwind of petroleum refineries. Consult with local air districts and other local agencies to determine an appropriate separation.

Chrome Platers Avoid siting new sensitive land uses within 1,000 feet of a chrome plater.

Dry Cleaners using
Perchloroethylene
Avoid siting new sensitive land uses within 300 feet of any dry cleaning operation. For operations with two or more machines, provide 500 feet. For operations with three or more machines, consult with the local air district. Do not site new sensitive land uses in the same building with perchloroethylene dry cleaning operations.

Gasoline Dispensing
Facilities
Avoid siting new sensitive land uses within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater). A 50-foot separation is recommended for typical gas dispensing facilities.

Source: CARB (2005).

CARB = California Air Resources Board

New sensitive receptors, such as proposed residential uses, could be sited within the buffer distances (shown in Table 4.1.I) to TAC sources associated with areas designated for commercial and industrial operations. CEQA does not generally require an agency to consider the effects of existing environmental conditions on a proposed project’s future users or residents. However, as with other laws and regulations enforced by other agencies that protect public health and safety, the City, as the Lead Agency, has authority other than CEQA to require measures to protect public health and safety.

25 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.

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)

4.1-41
Future development associated with the implementation of the proposed project would be required to comply with AB 2588, and CARB standards for diesel engines. While existing City policies and regulations are intended to minimize impacts associated with sensitive receptors, mitigation measures for future project developments that implement these policies and regulations are identified to ensure that the intended environmental protections are achieved.

Level of Significance Without Mitigation: Potentially Significant Impact Impact AIR-1: The proposed project would expose sensitive receptors to substantial pollutant concentrations.

Mitigation Measure AIR-1a Prior to future discretionary approval for projects that require environmental evaluation under CEQA (i.e. non-exempt projects),

development project applicants shall prepare and submit to the Director of the Planning and Development Department, or designee, a technical health risk assessment (HRA) evaluating potential project construction phase-related air quality impacts. The evaluation shall be prepared in conformance with San Joaquin Valley Air Pollution Control District (SJVAPCD) methodology for assessing construction impacts. If construction-related air pollutants are determined to have the potential to exceed the SJVAPCD adopted threshold of significance, project applicants for new development projects shall be required to incorporate mitigation measures into construction plans to reduce air pollutant emissions during construction activities. Mitigation measures can include, but are not limited to:
• Maintain construction equipment and provide current
certificate(s) of compliance for CARB’s In-Use Off-Road Diesel- Fueled Fleets Regulation [CCR Title 13, Sections 2449 and 2449.1] to SJVAPCD; and
• Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and
determined to be running in proper condition before it is operated. Documentation of a certified mechanic’s inspection and determinations shall be maintained by the Construction Manager and available for City inspection upon reasonable request.

The identified measures shall be included as part of the project Conditions of Approval. If the recommendations of the HRA are insufficient to reduce impacts to levels at or below SJVAPCD’s threshold of 20 in one million, such development with significant cancer risk (i.e., that exceed that threshold) shall be prohibited.

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)

4.1-42
Mitigation Measure AIR-1b Prior to future discretionary approval for projects that require environmental evaluation under CEQA (i.e. non-exempt projects), the City of Fresno (City) shall evaluate new development proposals for new industrial or warehousing land uses that: (1) have the potential to generate 100 or more truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use. Such projects shall submit a HRA to the City Department of Development and Resource Management. The HRA shall be prepared in accordance with policies and procedures of the most current State Office of Environmental Health Hazard Assessment (OEHHA) and the SJVAPCD. If the HRA shows that the incremental health risks exceed their respective thresholds, as established by the SJVAPCD at the time a project is considered, the applicant will be required to identify and demonstrate that best available control technologies for toxics (T-BACTs), including appropriate enforcement mechanisms to reduce risks to an acceptable level. T-BACTs may include, but are not limited to:
• Restrict idling on site by shutting equipment off when not in use or reducing idling time to 3 minutes as enforced by an identified compliance officer within the construction crew. Idling restrictions shall be enforced by highly visible posting at the site entry, posting at other on-site locations frequented by truck drivers, conspicuous inclusion in employee training and guidance material and owner, operator or tenant direct action as required;
• Electrify warehousing docks to reduce diesel particulate matter; Reque use of newer equipment and/or vehicles;
• Provide charging infrastructure for: electric forklifts, electric yard trucks, local drayage trucks, last mile delivery trucks, electric and fuel-cell heavy duty trucks; and/or
• Install solar panels, zero-emission backup electricity generators, and energy storage to minimize emissions associated with electricity generation at the project site.

T-BACTs identified in the HRA shall be identified as mitigation measures in the environmental document and/or incorporated into the site plan.

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)

4.1-43
Mitigation Measure AIR-1c Locate sensitive land uses (e.g., residences, schools, and daycare centers) to avoid incompatibilities with recommended buffer distances identified in the most current version of the California Air Resources Board (CARB) Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook). Sensitive land uses that are within the recommended buffer distances listed in the CARB Handbook shall provide enhanced filtration units or submit a HRA to the City. If the HRA shows that the project would exceed the applicable SJVAPCD thresholds, mitigation measures capable of reducing potential impacts to an acceptable level must be identified and approved by the City.

Level of Significance With Mitigation: Less than Significant Impact Compliance with Mitigation Measure AIR-1a would require future development projects in the Planning Area to evaluate and mitigate potential TAC exposure related to project-level construction activity. Mitigation Measure AIR-1b would ensure that mobile sources of TACs not covered under SJVAPCD permits are considered during subsequent project-level environmental review. Mitigation Measure AIR-1b would require the preparation of project-specific technical health risk assessments for certain discretionary large industrial or warehousing uses to evaluate operational-related health risk impacts to further ensure that operational-related emissions are reduced to a less than significant level. However, information regarding operational characteristics of future specific development projects and the associated emissions cannot be determined at the time of this analysis; therefore, cumulative growth within the City could result in potential TAC health could cumulatively contribute to elevated health risks in the city. Mitigation Measure AIR-1c identifies the use of the discretionary review process for residential and other sensitive land uses near freeways to impose site plan and design features aimed at minimizing exposure to environmental pollution.

Implementation of Mitigation Measures AIR-1a, AIR-1b, and AIR-1c would serve to ensure that the impacts due to the implementation of the proposed project are assessed to determine if they would expose sensitive receptors to potentially significant impacts from TAC emissions. Therefore, compliance with Mitigation Measures AIR-1a, AIR-1b, and AIR-1c would ensure the potential TAC health risk impact associated with the implementation of the proposed project would be less than significant.

AIR-4 The proposed project would result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The City of Fresno has many sources with the potential to generate odors including wastewater treatment facilities, landfills, transfer stations, recycling centers, manufacturing plants, food processors, painting operations, and rendering plants. Based on review of odor complaint history, very few of these facilities experience substantial odor complaints over the last three years.

Implementation of the proposed project could result in the odor sources being located near sensitive receptors and could result in significant impacts on sensitive receptors. These potential odor impacts on new sensitive receptors could be significant. When potential odor impacts on these 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)

4.1-44
new sensitive receptors occur, the SJVAPCD has authority under Rule 4102 to require the owner of the odor‐generating source to take actions that would reduce impacts to less than significant.

In addition, potential impacts from odor sources would be mitigated through compliance with General Plan Policy PU‐9‐d and by enforcement actions by agencies with regulatory authority over odors. General Plan Policy PU‐9‐d would ensure that waste and recycling facilities are properly located. Potential odor impacts from waste and recycling facilities is one of the primary factors considered in the location decision and are regulated by the State of California through the California Department of Resources Recycling and Recovery (CalRecycle) and the Local Enforcement Agency delegated by the State. The SJVAPCD addresses odor issues through Rule 4102 – Nuisance.

Facilities creating nuisance odors generating public complaints can result in SJVAPCD enforcement action. Individual development projects are required to determine if odors would be a potentially significant impact as part of CEQA review. The approved General Plan does not identify specific projects that are likely to result in an increase in odors. However, projects meeting the screening criteria are likely to be proposed in the Specific Plan Area. In addition, projects containing sensitive receptors are likely to be proposed near existing odor sources. Projects proposing new receptors within screening level distances will reduce the impact to less than significant through procedures provided by Rule 4102. Proposal of a new source within the screening distance would require the applicant to demonstrate that the proposed facility includes odor controls within its design and through implementation of odor management practices to reduce odors to less than significant.

Therefore, impacts would be less than significant. No mitigation would be required.

Level of Significance Without Mitigation: Less than Significant Impact

4.1.5.2 Cumulative Impacts
AIR-5 The proposed project would have a significant effect on the environment if it – in combination with other projects – would contribute to a significant cumulative impact related to air quality.

According to the SJVAPCD, regional air pollution is largely a cumulative impact. No single project is sufficient in size to independently create regional nonattainment of ambient air quality standards.

Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts.

The SJVAPCD is currently designated as a nonattainment area for State and national ozone standards and national particulate matter ambient air quality standards. SJVAPCD nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

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)

4.1-45
In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.

Therefore, if the proposed project’s annual emissions of construction- or operational-related criteria air pollutants exceed any applicable threshold established by the SJVAPCD, the proposed project would result in a considerable contribution to a cumulatively significant impact. As shown in Table 4.1.G and Table 4.1.H, the proposed project would not generate significant construction and operational emissions. As shown in the project-specific air quality impacts discussion above, the proposed project would not result in significant impacts and therefore the proposed project would not result in a cumulatively considerable contribution to regional air quality impacts. Cumulative impacts would be considered less than significant. However, future development under the proposed project would be required to comply with CARB motor vehicle standards, SJVAPCD regulations from stationary sources and architectural coatings, Title 24 energy efficiency standards, and the General Plan and policies.

As demonstrated in the analysis, cumulative growth within the city could result in potential TAC health risks exceeding applicable standards and cumulatively contributing to elevated health risks in the SJVAB. While existing City policies and regulations are intended to minimize impacts associated with sensitive receptors, mitigation measures for future project developments that implement these policies and regulations are identified to ensure that the intended environmental protections are achieved. The implementation of Mitigation Measure AIR-1 would reduce the potential of potential TAC exposure from construction activities envisioned under the proposed project. Compliance with Mitigation Measure AIR-2 would ensure that mobile sources of TACs not covered under SJVAPCD permits are considered during subsequent project-level environmental review. However, information regarding operational characteristics of future specific development projects and the associated emissions cannot be determined at the time of this analysis; therefore, cumulative growth within the City could result in potential TAC health could cumulatively contribute to elevated health risks in the city. Mitigation Measure AIR-3 identifies the use of the discretionary review process for residential and other sensitive land uses near freeways to impose site plan and design features aimed at minimizing exposure to environmental pollution.

Level of Significance Without Mitigation: Potentially Significant Impact Impact AIR-2: The proposed project could contribute to a significant cumulative impact related to air quality
Mitigation Measures: Implement Mitigation Measures AIR-1a, AIR-1b, and AIR-1c.

Level of Significance With Mitigation: Less than Significant Impact Compliance with Mitigation Measures AIR-1a, AIR-1b, and AIR-1c would ensure the potential TAC health risk impact associated with the implementation of the proposed project would be less than significant. Therefore, with the implementation of mitigation, the proposed project’s cumulative air quality impacts on sensitive receptors are 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)

4.1-46
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)

4.2-1

4.2 BIOLOGICAL RESOURCES

4.2.1 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 biological resources that are known to occur within the Tower District Specific Plan Area (Specific Plan Area), including vegetation communities, special‐status plant and wildlife species and their associated habitats, and special‐ status natural communities, including riparian communities and wetlands. This section also addresses local, State, and federal regulations as they pertain to project impacts on biological resources. 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.

As discussed in the Initial Study to this Draft Environmental Impact Report (EIR) (Appendix C), the proposed project would result in a potentially significant impact related to a special-status animal species. The analysis included in the Initial Study addresses all other potential environmental impacts to biological resources related to implementation of the proposed project. Therefore, this section is limited to impact discussions related to special-status animal species and cumulative impacts to biological resources.

For the purposes of this evaluation, “special‐status species” are those species that meet one or more of the following criteria:

4.2.1.1 Listed Species
“Listed species” includes those species that are:

1. Listed or proposed for listing as threatened or endangered under the federal Endangered Species Act (ESA) or candidates for possible future listing as threatened or endangered under the ESA (50 Code of Federal Regulations [CFR] §17.12); and/or

2. Listed or candidates for listing by the State of California as threatened or endangered under the California Endangered Species Act (CESA) (Fish and Game Code §2050 et seq.).

4.2.1.2 “Other Special‐Status Species”
“Other special‐status species” include those species that are:

1. Listed as rare under the California Native Plant Protection Act (Fish and Game Code §1900 et seq.).

2. Meet the definition of rare or endangered under the California Environmental Quality Act [CEQA] §15380(b) and (d). Species that may meet the definition of rare or endangered include the following:

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)

4.2-2
• Species considered by the California Native Plant Society (CNPS) to be “rare, threatened or endangered in California” (California Rare Plant Ranks (CRPR) 1A, 1B, 2A, and 2B); • Species that may warrant consideration on the basis of local significance or recent biological information; or
• Some species included on the California Natural Diversity Database’s (CNDDB) Special Plants, Bryophytes, and Lichens List.

3. Considered a locally significant species, that is, a species that is not rare from a statewide perspective but is rare or uncommon in a local context such as within a county or region (CEQA §15125 (c)) or is so designated in local or regional plans, policies, or ordinances (State CEQA Guidelines, Appendix G). Examples include a species at the outer limits of its known range or a species occurring on an uncommon soil type.

4. Listed as “Species of Special Concern” or as California Fully Protected Species by the California Department of Fish and Wildlife (CDFW);

5. Listed as “Species of Concern” by the United States Fish and Wildlife Service (USFWS).

4.2.1.3 “Special‐Status Natural Communities”
In general, “special‐status natural communities” include those communities that are of limited distribution statewide or within a county or region; communities that are of special concern to resource agencies; and communities that, because they are vulnerable to the environmental effects of projects, are assessed or protected under CEQA Section 1600 of the California Fish and Game Code, and/or Section 404 of the Clean Water Act, among others. The most current version of the CDFW’s List of Vegetation Alliances and Associations (or “Natural Communities List”) (2010) indicates which natural communities are considered “special‐status” in the State of California.

4.2.2 Existing Environmental Setting
The Specific Plan Area covers an approximately 1,870-acre area located immediately north of Downtown Fresno and SR-180, and 1 mile east of the SR-99 corridor in Fresno, Fresno County, California. The Specific Plan Area is generally flat, occupied by a mix of residential, commercial, and light industrial uses, and bounded by West Shields Avenue to the north, North Blackstone Avenue to the east, SR-180 to the south, and North Fruit Avenue and UPRR tracks to the west. The Biological Study Area (BSA) for project impacts to biological resources includes the Specific Plan Area and a 500-foot buffer surrounding the Specific Plan Area, as shown in Figure 4.2-1, Biological Study Area, as this is the area that may have either direct or indirect effects on biological resources.

LSA
LSA
0 FEET
850 1700
SOURCE: Google Maps (2025)
c::J Project Boundary
c::J Biological Study Area (500-ft Buffer)
l:\2024\20241643\GIS\Pro\Tower District Specific Plan Update\Tower District Specific Plan Update.aprx (7/14/2025) FIGURE 4.2-1
Tower District Specific Plan Update
Biological Study Area

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)

4.2-4
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)

4.2-5

4.2.2.1 Vegetation and Other Land Cover
The BSA is entirely developed and qualifies as Urban under the California Wildlife Habitat Relationships (CWHR). Most of the Specific Plan Area consists of single-family residential use, interspersed with multi-family residential, commercial, institutional, and light industrial use.

Institutional developments include Fresno City College, Fresno High School, and several grade school facilities. Commercial development is concentrated along North Blackstone Avenue, Belmont Avenue, East Olive Avenue, and North Van Ness Avenue. Light industrial use is present in the southwestern portion of the Specific Plan Area, along North Palm Avenue and south of Belmont Avenue. Several native and non-native trees are present throughout the developed habitat but are most dense where residential development dominates. Within the Specific Plan Area, there are a wide variety of native and non-native trees and shrubs, including palms (Washingtonia sp.), magnolias (Magnolia sp.), eucalyptus (Eucalyptus sp.), cypress (Cupressus sp., Hesperocyparis sp.), pines (Pinus sp.), sycamores (Platanus racemosa), pepper trees (Schinus sp.), and more.

4.2.2.2 General Wildlife
Observed wildlife were typical of the landscape and time of year and included California ground squirrel (Otospermophilus beecheyi), northern mockingbird (Mimus polyglottos), scrub jays (Aphelocoma californica), rock doves (Columba livia), mourning doves (Zenaida macroura), European starlings (Sturnus vulgaris), and numerous small songbirds (e.g., house sparrows [Passer domesticus] and house finches [Haemorrhous mexicanus]).

4.2.2.3 Special-Status Species
A Biological Resource Evaluation (BRE)
1 was completed for the proposed project in July 2025, and is included as Appendix F of the EIR. The literature review identified eight special-status plant species known or with potential to occur in the vicinity of the BSA; however, none of the eight special-status plant species has the potential to occur within the vicinity of the BSA due to the highly disturbed nature of the Specific Plan Area and the lack of suitable habitat conditions. The literature review identified 22 special-status animal species known or with potential to occur in the vicinity of the BSA, of which only one special-status animal species was determined to have a potential to occur within the vicinity of the BSA, the Western mastiff bat. The complete list of special-status species evaluated for the proposed project is included in Table 4.2.A, below.

1 LSA Associates, Inc. (LSA). 2025b. Biological Resources Evaluation Tower District Specific Plan Update Fresno, Fresno County, California. July.

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)

4.2-6
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Plants
Castilleja campestris
var. succulenta

succulent owl’s clover
US: T
CA: —
CRPR: 1B.2
Annual herb (hemiparasitic); blooms (March) April-
May; vernal pools (often acidic); elevation from 165 to 2,460 feet; Fresno, Madera, Merced, Mariposa, San
Joaquin, Stanislaus counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Caulanthus californicus

California jewelflower
US: E
CA: E
CRPR: 1B.1
Annual herb; blooms February-May; chenopod scrub,
pinyon and juniper woodland, valley and foothill
grassland; elevation from 200 to 3,280 feet; Fresno,
Kings, Kern, Santa Barbara, San Luis Obispo, Tulare
counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Imperata brevifolia

California satintail
US: —
CA: —
CRPR: 2B.1
Perennial rhizomatous herb; blooms September-May;
chaparral, coastal scrub, meadows and seeps (often
alkali), Mojavean desert scrub, riparian scrub, elevation from 0 to 3,985 feet; Butte, Fresno, Imperial, Inyo,
Kern, Lake, Los Angeles, Orange, Riverside, San
Bernardino, Tehama, Tulare, Ventura counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Leptosiphon serrulatus

Madera leptosiphon
US: —
CA: —
CRPR: 1B.2
Annual herb; blooms April-May; cismontane woodland,
lower montane coniferous forest; elevation from 985 to
4,265 feet; Fresno, Kern, Madera, Mariposa, Tulare
counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Orcuttia inaequalis

San Joaquin Valley
Orcutt grass
US: T
CA: E
CRPR: 1B.1
Annual herb; blooms April-September; vernal pools;
elevation from 35 to 2,475 feet; Fresno, Madera,
Merced, Solano, Stanislaus, Tulare counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Orcuttia pilosa

hairy Orcutt grass
US: E
CA: E
CRPR: 1B.1
Annual herb; blooms May-September; vernal pools;
elevation from 150 to 655 feet; Glenn, Madera,
Merced, Stanislaus, Tehama counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Sagittaria sanfordii

Sanford’s arrowhead
US: —
CA: —
CRPR: 1B.2
Perennial rhizomatous herb (emergent); blooms May-
October (November); marshes and swamps (shallow
freshwater); elevation from 0 to 2,135 feet; Butte, Del Norte, El Dorado, Fresno, Kings, Los Angeles, Madera,
Merced, Mariposa, Marin, Napa, Orange, Sacramento,
San Bernardino, Santa Clara, Shasta, San Joaquin, San
Mateo, Solano, Sutter, Tehama, Tulare, Ventura, Yuba
counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

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)

4.2-7
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Tuctoria greenei

Greene’s tuctoria
US: E
CA: R
CRPR: 1B.1
Annual herb; blooms May-July (September); vernal
pools; elevation from 100 to 3,510 feet; Butte, Fresno, Glenn, Madera, Merced, Modoc, Shasta, San Joaquin,
Stanislaus, Tehama, Tulare counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Fish
Mylopharodon
conocephalus

hardhead
US: —
CA: SSC
Found in Klamath/North Coast flowing waters and
Sacramento/San Joaquin flowing waters; require clear,
deep pools with sand/gravel/boulder bottoms and slow
water velocity.

No Dry Creek Canal is not part of the species
range. The BSA intersects the range for
this species, but the BSA is nearly 5 miles
south of the range.

Invertebrates
Branchinecta lynchi

vernal pool fairy shrimp
US: T
CA: —
Occur in a variety of vernal pool habitats that range
from small, clear pools to large, turbid and alkaline
pools; more common in pools less than 0.05 acre,
typically as part of larger vernal pool complexes; adults active from early December to early May; pools must
hold water for at least 18 days, the minimum to
complete the life cycle if temperatures are optimal;
eggs are laid in spring and persist through the dry
season as cysts; current California distribution includes the Central Valley and coast ranges; threatened by
habitat loss, degradation, and fragmentation, and
interference with vernal pool hydrology.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Bombus crotchii

Crotch’s bumble bee
US: —
CA: C
Nearly endemic to California; occurs in grassland and
shrublands in southern and central California; flight
period for queens is from late February to late October; flight period for workers and males is from late March
through September; nests underground; likely
overwinters in soft soil or under leaf litter; generalist forager; food plant genera include Antirrhinum,
Phacelia, Clarkia, Dendromecon, Eschscholzia, and
Eriogonum.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

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)

4.2-8
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Desmocerus californicus
dimorphus

valley elderberry
longhorn beetle
US: T
CA: —
Requires elderberry shrubs for reproduction and
survival, with stems greater than 1 inch; occurs only in the Central Valley north of the San Joaquin River;
occurs below 500 feet elevation; eggs laid on
elderberry shrubs; larvae burrow into stems for food
and metamorphosis; adults emerge from the stem and
spend the remainder of their lives on the same shrub or on the ground underneath.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Danaus plexippus

monarch butterfly
US: PT
CA: —
Migrant; lays eggs on milkweed (primarily Asclepias
spp.); overwinters along the coast in dense stands of
eucalyptus, Monterey pine, and Monterey cypress that
provide indirect sunlight, moisture for hydration,
protection from winds, and above-freezing
temperatures.

No No recorded occurrences within 5 miles
of the BSA. No suitable wintering or
breeding habitat is present.

Amphibians
Ambystoma
californiense

California tiger
salamander pop. 1
US: T
CA: T, SSC
Small salamander found in vernal and seasonal pools
and associated grasslands, oak savanna and woodland,
and coastal scrub in the Central Valley from Tulare
County north to the Sacramento area and along the
Central Coast from Santa Barbara County north to the
San Franciso Bay; 0–3,200 feet elevation; spends most
of the year in small mammal burrows; breeding season
is November–February; requires seasonal ponds for
breeding and egg laying; can travel more than 3,000
feet between aquatic and upland habitats.

No The BSA is heavily developed and lacks
natural habitat that could support this
species. Spea hammondii

western spadefoot
US: PT
CA: SSC
Species relies on vernal pools for breeding where
predators cannot become established; open areas with
sand or gravelly soils in a variety of habitats: grasslands, coastal scrub, woodlands, chaparral, sandy washes,
lowland river floodplains, alkali flats, foothills, and mountains; endemic to California and northern Baja
California; distribution is from Redding south
throughout the Central Valley and foothills, throughout the South Coast Ranges into coastal southern California to the Transverse and Peninsular mountains; elevation
is from sea level to 4,500 feet.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

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)

4.2-9
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Reptiles
Actinemys marmorata

northwestern pond
turtle
US: PT
CA: SSC
Highly aquatic and diurnally active; found in ponds,
lakes, rivers, streams, creeks, marshes, and irrigation ditches with vegetation and rocky/muddy bottoms;
wide variety of habitats; needs basking areas near
water (logs, rocks, vegetation mats, banks); may enter
brackish water and even seawater; digs nest on land
near water; range is from north of the San Francisco
Bay area south, including the Central Valley.

No The BSA is heavily developed and lacks
suitable upland habitat. High levels of
disturbance would preclude this species
from using Dry Creek Canal.

Anniella pulchra

northern California
legless lizard
US: —
CA: SSC
Secretive fossorial lizard found in many habitats,
especially valley and foothill grassland, chaparral,
coastal scrub, and coastal dune; most commonly
associated with sandy or loose organic soils with leaf
litter; elevation from near sea level to 6,000 feet; may hibernate in inland areas with colder winter
temperatures; primarily associated with foothills and
mountains from Ventura County north to San Joaquin
and Contra Costa counties, and in the western Sierra
Nevada foothills in Fresno and Tulare counties.

No The BSA is heavily developed and lacks
natural habitat that could support this
species. Arizona elegans
occidentalis

California glossy snake
US: —
CA: SSC
Scrub and grassland habitats, often with loose or sandy soils. Patchily distributed from the eastern portion of San Francisco Bay to southern San Joaquin Valley and in non-desert areas of southern California. Also occurs in Baja California, Mexico.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Gambelia silus [=sila]

blunt-nosed leopard
lizard
US: E
CA: E, FP
Occurs in semiarid habitats within the southern Central Valley and Cuyama Valley; habitats typically are flat and have large open areas with scattered shrubs for refuge; uses small mammal burrows for shelter; spends most of
the year underground, surfacing in spring/early
summer to breed and eat; hatchlings surface in the fall to eat; may interbreed with long-nosed leopard lizard
in Cuyama Valley; threatened by habitat
loss/fragmentation and drought; elevation from 100–
2,400 feet.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

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)

4.2-10
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Phrynosoma blainvillii

coast horned lizard
US: —
CA: SSC
Prefers sandy/loose soils in grassland, forests,
woodlands, and open chaparral; often found along
sand washes and dirt roads with scattered shrubs for
refuge; specializes in consuming ants; distribution
includes coastal California from Baja California north to the Bay Area, southeastern desert regions, southern
Central Valley flats and foothills, and surrounding
mounts on drier, warmer slopes; threatened by habitat
loss/fragmentation and the spread of invasive ant
species displacing native prey; elevation from sea level to 8,000 feet.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Birds
Agelaius tricolor

tricolored blackbird
US: —
CA: T, SSC
Colonial breeder that prefers freshwater, emergent
wetlands with tall, dense cattails or tules, but also
thickets of willow, blackberry, wild rose, and tall herbs; breeding colonies are minimum approximately 50 pairs;
forages in pastures, grain fields, and similar habitats near breeding areas.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Athene cunicularia

burrowing owl
US: —
CA: C, SSC
Occupies a variety of open, semi-arid to arid habitats
throughout central and southern California, including
desert regions; prefers open habitats with few shrubs
or trees; most active around sunrise and sunset; utilizes burrows constructed by mammals year-round for
shelter and nesting; well documented in urban areas
where patches of undeveloped areas are present (e.g.,
canals, airports, drainage basins) and in areas of dense agricultural development, particularly where canals
provide burrow habitat; forages primarily for rodents
and insects within several miles of its burrow, usually in open, grassy habitats if available; has been observed
hunting bats and insects around parking lot lights;
threats include development resulting in habitat
loss/fragmentation.

No Unprocessed CNDDB record of an owl
less than 1 mile to the south of the BSA
from 2018 in the UPRR corridor. No
records confirm nests within the BSA.

Burrowing owls can adapt to urban
areas but still need open space, which is
lacking in the BSA.

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)

4.2-11
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Buteo swainsoni

Swainson’s hawk
US: —
CA: T
Resident and migrant throughout the Central Valley,
Klamath Basin, Northeastern Plateau, Mojave Desert,
Antelope Valley, and elsewhere; breeds in stands with
few trees in juniper-sage flats, riparian areas, and in oak savannahs; usually nests in scattered trees
surrounded by foraging habitat; forages primarily for
small mammals in grasslands and open desert
scrublands or suitable grain fields or livestock pastures; occasionally eats insects, amphibians, reptiles, and
birds; usually found near water.

No Several recorded occurrences in the
area, many of which are considered
historic. Species is now largely
constrained to the outer margins of the
city. There is a very high level of
disturbance within the BSA that would
discourage both the hawks and their
prey.

Coccyzus americanus

yellow-billed cuckoo
US: T
CA: E
Found in scattered occurrences of valley foothill and
desert riparian habitats in the Sacramento and Owens
valleys, the southern San Joaquin Valley, and southern
California; migrant; winters in South America and
breeds in California from June to September; prefers
dense riparian thickets, especially willows; breeds in
river bottoms and other mesic habitats where humidity
is high; forages for insects but occasionally eats frogs, lizards, and sometimes fruit.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

Vireo bellii pusillus

least Bell’s vireo
US: E
CA: E
Widespread throughout western Sierra Nevada and
coastal valleys and foothills south of Santa Clara
County; occurs below 2,000 feet elevation; migrant;
winters in Mexico and breeds in California from March
to August; nests in dense riparian habitat along
streams; prefers willows, cottonwoods, Baccharis, wild
blackberry, or mesquite; feeds on insects and some
fruits.

No The BSA is heavily developed and lacks
natural habitat that could support this
species.

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)

4.2-12
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Mammals
Antrozous pallidus

pallid bat
US: —
CA: SSC
Occurs in low elevations in deserts, grasslands,
shrublands, woodlands, and forest throughout
California from sea level up through mixed conifer
forests; most common in open, dry, habitats with rocky
areas for roosting; roosts usually in groups of 20 or
more; day roosts in caves, crevices, mines, and
occasionally hollow trees and buildings; night roosts
sometimes in more open areas; roost must protect
against high temps; maternity colonies form in April;
hibernates in winter; needs water; very sensitive to
roost disturbance.

No One recorded occurrence within the BSA
from 1909 (EONDX 66606).

There is a very high level of disturbance
that would discourage this species from
roosting within the BSA.

Dipodomys nitratoides
exilis

Fresno kangaroo rat
US: E
CA: E
Occurs on alkali open grassland on bare alkaline clay-
based soils; nocturnal species; burrows with tunnels
approximately 12 to 15 inches below ground;
threatened by predation and disease; historically
occurred on the valley floor in Kings, Fresno, Madera,
and Merced counties, but may be extirpated.

No Two recorded occurrences within the
BSA are historic and considered
extirpated. The BSA is heavily developed
and lacks natural habitat that could
support this species.

Eumops perotis
californicus

western mastiff bat
US: —
CA: SSC
Uncommon resident in southeastern San Joaquin Valley
and Coast Ranges; conifer and deciduous woodlands,
coastal scrub, annual and perennial grassland, desert
scrub, chaparral, palm oases, and urban habitats; roosts in crevices on cliff faces, high buildings, trees, and
tunnels; needs vertical faces to drop off to take flight; nursery roosts in tight rock crevices or buildings; rarely uses night roosts; nonmigratory; active year-round;
eats insects.

Yes Nearest record is less than 0.5 mile to
the southeast and presumed extent
(EONDX 66374). Known to occur in
urban areas. Several large trees in BSA
that could support species.

Taxidea taxus

American badger
US: —
CA: SSC
Found throughout California except in the North Coast
area; open grasslands, deserts, and edge of scrub and
woodland habitats; requires loose soils; does not occur in irrigated agriculture; active year-round, both
nocturnal and diurnal; young are born in March and
April; primarily eats small mammals and occasionally
reptiles, insects, birds, eggs, and carrion; capable of digging a new den each night.

No Two recorded occurrences in the BSA
are on the outskirts of the city. The BSA
is heavily developed and lacks natural
habitat that could support this species.

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)

4.2-13
Table 4.2.A: Special-Status Species in the Vicinity of the Specific Plan Area Scientific Name /
Common Name Status Habitat Requirements Potential to
Occur Rationale
Vulpes macrotis mutica

San Joaquin kit fox
US: E
CA: T
Endemic to the Central Valley; San Joaquin Valley,
Carrizo Plain, Salinas Valley, Cuyama Valley, and other small valleys in western foothills; arid to semi-arid
grasslands, open shrublands, savannahs, and grazed
lands with loose-textured soils; highly adaptable and
documented in urban developed areas; uses burrows
year-round for shelter, escape from predators, and
rearing young; will use man-made structures, such as
pipes, for denning; feeds primarily on small mammals
but will also consume birds, reptiles, and insects and
scavenge for human food; intensively maintained
agricultural areas avoided; threatened by habitat loss
and fragmentation, vehicle strikes, and disease; current mange outbreak in urban population in Bakersfield and
in nearby natural areas.

No One recorded occurrence within the BSA
from 1993 with a non-specific location
(EONDX 53873). Although the species
can adapt to urban environments, it has
not been seen in decades in the Fresno
area, and the urban density of the BSA is
considerably higher than other urban
areas in which this species has been
documented.

Sources: CDFW (2025a, 2025b); CNPS (2025); USFWS (2025b); Zeiner et al. (1990).

Status:

E Listed as endangered
T Listed as threatened
PT Proposed Threatened
C Candidate for federal Listing
FP California Fully Protected
SSC California Species of Special Concern
CRPR (California Rare Plant Rank):
1A Presumed Extinct in California
1B Rare, Threatened, or Endangered in California and elsewhere 2A Plants presumed extirpated in California, but more common elsewhere 2B Plants Rare, Threatened, or Endangered in California, but more common elsewhere CRPR Threat Code Extension:
.1 Seriously endangered in California (over 80% of occurrences threatened / high degree and immediacy of threat)
.2 Fairly endangered in California (20–80% occurrences threatened) .3 Not very endangered in California (<20% of occurrences threatened) Abbreviations:

BSA = Biological Study Area
CA = California
CDFW = California Department of Fish and Wildlife
CNDDB = California Natural Diversity Database
CNPS = California Native Plant Society
EONDX = Element Occurrence Index
US = United States
USFWS = United States Fish and Wildlife Service
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)

4.2-14
As shown in Table 4.2.B, western mastiff bat (Eumops perotis californicus) is the one state species of special concern that has the potential to occur within the Specific Plan Area. It is an uncommon resident in southeastern San Joaquin Valley and Coast Ranges and occurs in a wide variety of habitats including conifer and deciduous woodlands, coastal scrub, annual and perennial grassland, desert scrub, chaparral, palm oases, and urban habitats. It roosts in crevices on cliff faces, high buildings, trees, and tunnels that include vertical faces to drop off to take flight. Nursery roosts are typically found in in tight rock crevices or buildings. It rarely uses night roosts. The nearest occurrence was recorded in 1991 in downtown Fresno and is presumed extant (Element Occurrence Index [EONDX] 66374; CDFW 2025a). Trees throughout the BSA could be suitable for roosting, and the BSA contains suitable foraging habitat for western mastiff bat.

Table 4.2.B: Special-Status Species with Potential to Occur within the Specific Plan Area
Scientific Name /
Common Name Status Potentially Affected by
Project Viability Threat?
Mammals
Eumops perotis californicus

western mastiff bat
US: —
CA: SSC
Yes No
Source: Compiled by LSA (2025)
SSC = California Species of Special Concern

4.2.3 Regulatory Setting
This section describes the relevant federal, State, and local (County and City) laws, regulations and policies pertaining to environmental impacts within the Specific Plan Area.

4.2.3.1 Federal Policies and Regulations
Federal Endangered Species Act. The USFWS administers the federal Endangered Species Act (ESA).

The ESA provides a process for listing species as either threatened or endangered and methods of protecting listed species. The ESA defines as “endangered” any plant or animal species that is in danger of extinction throughout all or a significant portion of its known geographic range. A “threatened” species is a species that is likely to become endangered. A “proposed” species is one that has been officially proposed by the USFWS for addition to the federal threatened and endangered species list.

Per Section 9 of the ESA, “take” of threatened or endangered species is prohibited. The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in such conduct (codified at 16 USC §1532(19). “Take” can include disturbance to habitats used by a threatened or endangered species during any portion of its life history. The presence of any federally threatened or endangered species in a project area generally imposes severe constraints on development, particularly if development would result in “take” of the species or its habitat. Under the regulations of the ESA, the USFWS may authorize “take” when it is incidental to, but not the purpose of, an otherwise lawful act.

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)

4.2-15
Federal Clean Water Act ‐ Section 404. The U.S. Army Corps of Engineers (USACE) administers Section 404 of the federal Clean Water Act (CWA). This section regulates the discharge of dredge and fill material into waters of the United States. “Discharge of fill material” is defined as the addition of fill material into waters of the United States, including, but not limited to, the following:
placement of fill that is necessary for the construction of any structure or impoundment requiring rock, sand, dirt, or other material for the structure’s construction; site development fills for recreational, industrial, commercial, residential, and other uses; causeways or road fills; and fill for intake and outfall pipes and sub‐aqueous utility lines (33 CFR §328.2[f]).

The USACE has established a series of nationwide permits that authorize certain activities in waters of the United States, if a proposed activity can demonstrate compliance with standard conditions.

Normally, USACE requires an individual permit for an activity that will affect an area equal to or in excess of 0.5 acre of waters of the United States. Projects that result in impacts to less than 0.5 acre can normally be conducted pursuant to one of the nationwide permits, if consistent with the standard permit conditions. USACE also has discretionary authority to require an Environmental Impact Statement for projects that result in impacts to an area between 0.1 and 0.5 acre. Use of any nationwide permit is contingent on the activities having no impacts to endangered species.

Federal Clean Water Act ‐ Section 401. Per Section 401 of the CWA, “any applicant for a Federal license or permit to conduct any activity including, but not limited to, the construction or operation of facilities, which may result in any discharge into the navigable waters, shall provide the licensing or permitting agency a certification from the State in which the discharge originates or will originate, or, if appropriate, from the interstate water pollution control agency having jurisdiction over the navigable waters at the point where the discharge originates or will originate, that any such discharge will comply with the applicable provisions of sections 1311, 1312, 1313, 1316, and 1317 of this title” (33 USC §1341(a)(1) ). Therefore, before the USACE will issue a Section 404 permit, applicants must apply for and receive a Section 401 water quality certification from the Regional Water Quality Control Board (RWQCB).

Waters of the United States. USACE has primary federal responsibility for administering regulations that concern “waters of the U.S.” The USACE acts under two statutory authorities, the Rivers and Harbors Act (Sections 9 and 10), which governs specified activities in “navigable waters of the U.S.,” and the Clean Water Act (CWA) (Section 404), which governs specified activities in “other waters of the U.S.,” including wetlands. The USACE requires that a permit be obtained if a project proposes placing structures within, over, or under navigable waters or discharging dredged or fill material into “waters of the U.S.” below the ordinary high-water mark in non-tidal waters. The U.S. Environmental Protection Agency (USEPA), USFWS, National Marine Fisheries Service (NMFS), and several other agencies can provide comments on USACE permit applications.

The federal government defines wetlands in CWA Section 404 as “areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support (and do support, under normal circumstances) a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR §328.3(b) and 40 CFR §230.3). The federal definition of wetlands requires three wetland identification parameters to be present: wetland hydrology, hydric soils, and hydrophytic vegetation.

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)

4.2-16
“Other waters of the U.S.” refers to those hydric features that are regulated by the CWA but are not wetlands (33 CFR §328.4). To be considered jurisdictional, these features must exhibit a defined bed and bank and an ordinary high-water mark. Examples of other waters of the U.S. include rivers, creeks, intermittent and ephemeral channels, ponds, and lakes. Human-made wetland areas that are not regulated under this act include stock watering ponds and created water treatment facilities.

Migratory Bird Treaty Act. The Migratory Bird Treaty Act (MBTA) protects all common wild birds found in the United States except the house sparrow, starling, feral pigeon, and resident game birds such as pheasant, grouse, quail, and wild turkey. Resident game birds are managed separately by each state. Under the MBTA, “it shall be unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture, kill, attempt to take, capture, or kill, possess, offer for sale, sell, offer to barter, barter, offer to purchase, purchase, deliver for shipment, ship, export, import, cause to be shipped, exported, or imported, deliver for transportation, transport or cause to be transported, carry or cause to be carried, or receive for shipment, transportation, carriage, or export, any migratory bird, any part, nest, or egg of any such bird, or any product, whether or not manufactured, which consists, or is composed in whole or part, of any such bird or any part, nest, or egg thereof …” (16 USC §703(a)).

4.2.3.2 State Policies and Regulations
California Endangered Species Act. The California Department of Fish and Wildlife (CDFW) administers the California Endangered Species Act (CESA). CESA applies to “endangered” or “threatened” birds, mammals, fish, amphibians, reptiles, and plants, but does not apply to insects (see 81 Cal. Op. Att'y Gen. 222 (1998)). The State of California considers an “endangered” species one whose prospects of survival and reproduction are in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease. Any species determined by the commission as “endangered” on or before January 1, 1985, is an “endangered species.” A “threatened” species is one present in such small numbers throughout its range that it is likely to become an endangered species in the foreseeable future in the absence of special protection or management. The California Endangered Species Act of 1970 created the categories of “Endangered” and “Rare.” The California Endangered Species Act of 1984 created the categories of “Endangered” and “Threatened.” On January 1, 1985, all animal species designated as “Rare” were reclassified as “Threatened” (see California Fish and Game Code §2067).

Section 2080 of the Fish and Game Code prohibits “take” of any species that the commission determines to be an endangered species or a threatened species. Take is defined in Section 86 of the Fish and Game Code as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” CESA allows for take incidental to otherwise lawful development projects. CESA emphasizes early consultation to avoid potential impacts to rare, endangered, and threatened species and to develop appropriate mitigation planning to offset project caused losses of listed species populations and their essential habitats.
“Candidate species” means a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for 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)

4.2-17
which the commission has published a notice of proposed regulation to add the species to either list (Fish and Game Code §2068).

The CDFW exercises authority over mitigation projects involving State‐listed species, including those resulting from CEQA mitigation requirements. Lead agencies are directed by the CESA to consult with the CDFW on projects or actions that could affect listed species. A “taking” may be authorized by the CDFW if an approved habitat management plan or management agreement that avoids or compensates for possible jeopardy is implemented. In addition, the CDFW requires preparation of mitigation plans in accordance with published guidelines.

California Department of Fish and Wildlife “Species of Special Concern.” A Species of Special Concern (SSC) is a species, subspecies, or distinct population of an animal (i.e., fish, amphibian, reptile, bird and mammal) native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
• Is extirpated from the State or, in the case of birds, in its primary seasonal or breeding role; • Is listed as Federally‐, but not State‐, threatened or endangered; • Meets the State definition of threatened or endangered but has not formally been listed; • Is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status;
• Has naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for State threatened or endangered status.

SSCs tend to have a number of factors in common, including that they:
• Occur in small, isolated populations or in fragmented habitat, and are threatened by further isolation and population reduction;
• Show marked population declines;
• Depend on a habitat that has shown substantial historical or recent declines in size and/or quality or integrity;
• Have few California records, or which historically occurred in the State but for which there are no recent records; and
• Occur largely in areas where current management practices are inconsistent with the animal's persistence.
“Species of Special Concern” is an administrative designation that carries no formal legal status per se, but signifies that the species is recognized as sensitive by the CDFW. Section 15380 of the State 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)

4.2-18
CEQA Guidelines clearly indicates that species of special concern should be included in an analysis of project impacts if they can be shown to meet the criteria of sensitivity outlined therein.

California Native Plant Protection Act. In 1977, the Legislature formally recognized the status of rare or endangered plants with the passage of the Native Plant Protection Act (NPPA) (Fish and Game Code, Section 1900 et seq.). The NPPA directed the CDFW to preserve, protect, and enhance rare and endangered plants in California. The NPPA also authorized the Fish and Game Commission to designate native plants as “rare” or “endangered” and to require permits for collecting, transporting, or selling such plants.

Under Section 1901 of the California Fish and Game Code, “native plant” means a plant growing in a wild uncultivated state, which is normally found native to the plant life of this state. A species, subspecies, or variety is considered “endangered” when its prospects of survival and reproduction are in immediate jeopardy from one or more causes. A species, subspecies, or variety is considered “rare” when, although not presently threatened with extinction, it is in such small numbers throughout its range that it may become endangered if its present environment worsens.

Under Section 1913(c) of the NPPA, the owner of land where a rare or endangered native plant is growing is required to notify the department at least 10 days in advance of changing the land use to allow for salvage of plant.

Fish and Wildlife Protection - California Fish and Game Code, Sections 1600 to 1603. The California Fish and Game Code mandates that “it is unlawful for any person to substantially divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake designated by the department, or use any material from the streambeds, without first notifying the department of such activity.” CDFW jurisdiction includes ephemeral, intermittent, and perennial watercourses, including dry washes, characterized by the presence of hydrophytic vegetation, the location of definable bed and banks, and the presence of existing fish or wildlife resources.

Furthermore, CDFW jurisdiction is often extended to habitats adjacent to watercourses, such as oak woodlands in canyon bottoms or willow woodlands that function as part of the riparian system.

Historic court cases have further extended CDFW jurisdiction to include watercourses that seemingly disappear, but re‐emerge elsewhere. Under the CDFW definition, a watercourse need not exhibit evidence of an OHWM to be claimed as jurisdiction. However, CDFW does not regulate isolated wetlands; that is, those that are not associated with a river, stream, or lake.

Porter‐Cologne Water Quality Act. The RWQCB regulates actions that would involve “discharging waste, or proposing to discharge waste, within any region that could affect the water of the state” (Water Code Section 13260(a)), pursuant to provisions of the Porter‐Cologne Water Quality Act. “Waters of the State” are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state” (Water Code Section 13050 (e)).

Regional Water Quality Control Board Regulated Activities. Under Section 401 of the CWA, the RWQCB regulates all activities that are regulated by the USACE. Additionally, under the Porter‐ Cologne Water Quality Act, the RWQCB regulates all activities, including dredging, filling, or 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)

4.2-19
discharge of materials into waters of the state that are not regulated by the USACE due to a lack of connectivity with a navigable water body and/or lack of an OHWM.

California Fish and Game Code ‐ Section 3503 and Section 3511. The CDFW administers the California Fish and Game Code. There are particular sections of the Fish and Game Code that are applicable to natural resource management. For example, Section 3503 of the Fish and Game Code states it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird that is protected under the MBTA. Fish and Game Code Section 3503.5 further protects all birds in the orders Falconiformes and Strigiformes, birds of prey such as hawks and owls, and their eggs and nests, from any form of take. Disturbance that causes nest abandonment and/or loss of reproductive effort is also considered a “taking” by the CDFW. Fish and Game Code Section 3511 lists fully protected bird species where the CDFW is unable to authorize the issuance of permits or licenses to take these species.

Natural Community Conservation Planning Act ‐ Fish and Game Code Sections 2800 et seq. The State of California has adopted the Natural Community Conservation Planning and Habitat Conservation Planning (NCCP/HCP) program to focus on creating a multiple‐species, multiple‐ habitat subregional Reserve System and implementing a long‐term “adaptive management” program. To accomplish this, the NCCP/HCP creates a subregional habitat Reserve System and implements a coordinated program to manage biological resources within the habitat reserve. The creating of a defined Reserve System provides certainty to the public and to affected landowners with respect to the location of future development and open space within the subregion. The NCCP/HCP was developed with coordination through the CDFW and the USFWS, in order to account for the CESA and the federal ESA. The Specific Plan Area does not occur within any NCCP/HCP designated area.

California Native Plant Society. The California Native Plant Society (CNPS) maintains a list of plant species native to California that have low numbers, limited distribution, or are otherwise threatened with extinction. This information is published in the Inventory of Rare and Endangered Plants of California. Potential impacts to populations of CNPS‐listed plants require consideration under CEQA.

The following identifies the definitions of the California Rare Plant Ranks (formerly known as the CNPS lists):
• California Rare Plant Rank 1A: Plants believed extirpated in California and either rare or extinct elsewhere.
• California Rare Plant Rank 1B: Plants rare, threatened, or endangered in California and elsewhere.
• California Rare Plant Rank 2A: Plants presumed extirpated in California, but more common elsewhere.
• California Rare Plant Rank 2B: Plants rare threatened or endangered in California but more common elsewhere.

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)

4.2-20
• California Rare Plant Rank 3: Plants about which more information is needed ‐ a review list. • California Rare Plant Rank 4: Plants of limited distribution – a watch list.

The CNPS Threat Rank is an extension added onto the California Rare Plant Rank, which designates the level of threats by a 1 to 3 ranking, with 1 being the most threatened and 3 being the least threatened. Each threat rank is defined as follows:
• 0.1‐Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat).
• 0.2‐Moderately threatened in California (20 ‐ 80% occurrences threatened / moderate degree and immediacy of threat).
• 0.3‐Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known).

4.2.3.3 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 biological resources and applicable to the proposed project.

City of Fresno General Plan. The approved General Plan is a set of policies and programs that form a blueprint for the physical development of the City. The following objectives and policies related to biological resources are presented in various elements of the approved General Plan:

Parks, Open Space, and Schools Element.

Objective POSS-5: Provide for long-term preservation, enhancement, and enjoyment of plant, wildlife, and aquatic habitat.

Policy POSS‐5‐a: Habitat Area Acquisition: Support federal, State, and local programs to acquire significant habitat areas for permanent protection and/or conjunctive educational and recreational use.

Policy POSS‐5‐b: Habitat Conservation Plans: Participate in cooperative, multi-jurisdictional approaches for area-wide habitat conservation plans to preserve and protect rare, threatened, and endangered species.

Policy POSS‐5‐c: Buffers for Natural Areas: Require development projects, where appro- priate and warranted, to incorporate natural features (such as ponds, hedgerows, and wooded strips) to serve as buffers for adjacent natural areas with high ecological value.

Policy POSS‐5‐d: Guidelines for Habitat Conservation: Establish guidelines for habitat conservation and mitigation programs, including:

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)

4.2-21
• Protocols for the evaluation of a site's environmental setting and proposed design and operating parameters of proposed mitigation measures.
• Methodology for the analysis depiction of land to be acquired or set aside for mitigation activities.
• Parameters for specification of the types and sources of plant material used for any re- vegetation, irrigation requirements, and post-planting maintenance and other operational measures to ensure successful mitigation.
• Monitoring at an appropriate frequency by qualified personnel and reporting of data collected to permitting agencies.

Pol
icy POSS-5-e: P
ursue development of conjunctive habitat and recreational trail uses in flood control and drainage projects.

Com
mentary: Establishment of wildlife and aquatic habitat is unsuitable along primary conveyance systems to existing and future water treatment facilities. Certain waterways may be excluded from habitat development for this reason.

Pol
icy POSS-5-f: Re
gional Mitigation and Habitat Restoration. Coordinate habitat restoration programs with responsible agencies to take advantage of opportunities for a coordinated regional mitigation program.

Objective POSS‐6: Maintain and restore, where feasible, the ecological values of the San Joaquin River corridor.

Policy POSS-6-a: S an Joaquin River Parkway Master Plan. Support the San Joaquin River Conservancy in its efforts to update the San Joaquin River Parkway Master Plan by working with the other jurisdictions and the River Conservancy to create a comprehensive and feasible plan for preservation, conservation, and Parkway development.

Pol
icy POSS-6-b: Eff
ects of Stormwater Discharge. Support efforts to identify and mitigate cumulative adverse effects on aquatic life from stormwater discharge to the San Joaquin River.
• Avo
id discharge of runoff from urban uses to the San Joaquin River or other riparian corridors.
• Approve development on sites having drainage (directly or indirectly) to the San Joaquin River or other riparian areas only upon a finding that adequate measures for preventing pollution of natural bodies of water from their runoff will be implemented. • Periodically monitor water quality and sediments near drainage outfalls to riparian areas. Institute remedial measures promptly if unacceptable levels of contaminant(s) occur.

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)

4.2-22
Objective POSS‐7: Support the San Joaquin River Conservancy in its collaborative, multiagency efforts to develop the San Joaquin River Parkway.

Policy POSS-7-a: Preserve Wildlife Corridors. Acquire and expand natural reserves and wildlife corridors through purchase, easements, mitigation for proposed activities, or other mutually satisfactory transactions.

Pol
icy POSS-7-b: Wil
dlife Corridor along San Joaquin River. Create a wildlife corridor to provide continuous open space land and water areas parallel to the San Joaquin River within the jurisdiction of the City.
• Pres
erve a minimum width of 200 feet of riparian vegetation on both sides of the river. • Require the corridor to be wider when possible and/or necessary to protect additional areas of native plants and critical habitat (such as wildlife breeding areas). Re- establishment of a 200-foot or wider band of native plants is recommended in areas where 200 feet of riparian vegetation no longer exists along the river bank, to the maximum extent feasible from topologic and hydrologic standpoints. • Allow exceptions where the minimum-width corridor is infeasible due to topography, hydrology, or other constraints. An offsetting expansion may be approved in those instances on the opposite side of the river. Incorporate the bluff face into the wildlife corridor where steep bluffs drop directly into or close to the river.

Poli
cy POSS-7-c: M
onitoring River Corridor Conditions. Undertake periodic monitoring to determine the status of conditions and mitigation measures required for projects within, and in the vicinity of, the river corridor.
• Pur
sue a Memorandum of Understanding (MOU) or other agreement so that the San Joaquin River Conservancy can perform, or participate in, this monitoring program in order to furnish additional expertise, provide for cost efficiency, and to ensure consistency throughout the river corridor.
• Based on information obtained from monitoring, modifications in special permits, reclamation plans, and other documents, operating parameters for uses may be necessary to insure human health and safety and the well-being of riparian plants and wildlife.

Pol
icy POSS-7-d: Buf
fer Zones near Intensive Uses. Protect natural reserve areas and wildlife corridor areas in the San Joaquin River corridor whenever more intensive human uses exist or are proposed on adjacent lands. Use buffer zones to allow multiple uses on parts of the parkway while still protecting wildlife and native plants. • Req
uire studies of appropriate buffer widths to be approved by State and federal wildlife agencies before variances from standard buffer zone widths are granted.

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)

4.2-23
• Maintain natural riparian buffer zones with appropriate native plants (seed material and cuttings locally derived).
• Incorporate open space uses such as pasture, low-intensity agricultural activities, and the “rough” or marginal areas of golf courses, into buffer zones when they constitute an improvement in habitat over a previous use or degraded area. Evaluate and address the potential impacts of construction, cultural, and operational practices (such as grading, number of livestock per acre, lighting, and use of pesticides, herbicides, and fertilizers) before these uses are be approved for buffering.
• For nearby areas of the San Joaquin River corridor outside of the exclusive jurisdiction of the City, support efforts to work with other jurisdictions to achieve this policy.

City of Fresno Municipal Code. Chapter 13, Article 3 Street Trees and Parkways. This section of the City’s Municipal Code provides guidelines and requirements for the preservation and protection of existing street trees, as well as guidelines establishing the installation of City-owned trees along streets.

4.2.4 Significance Criteria
The thresholds for impacts to biological resources used in this analysis are consistent with Appendix G of the State CEQA Guidelines. Implementation of the Specific Plan Update would result in a significant impact related to biological resources if it would:
• Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
• Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
• Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
• Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites;
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
• Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation 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)

4.2-24
As discussed in the Initial Study to this Draft EIR (Appendix C), the proposed project would result in a potentially-significant impact related to a special-status animal species. The analysis included in the Initial Study addresses all potential environmental impacts to biological resources related to implementation of the proposed project. Therefore, this section is limited to impact discussions related to special-status animal species and cumulative impacts to biological resources.

4.2.5 Impacts and Mitigation Measures
This section describes the potential for significant impacts to biological resources associated with implementation of the proposed project, based on the standards of significance listed in the State CEQA Guidelines Appendix G, Environmental Checklist, along with consideration for other federal and State laws. 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.

4.2.5.1 Project Impacts
The following discussion describes the potential impacts related to biological resources that could result from the implementation of the Specific Plan Update.

BIO-1 The proposed project could have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

The BRE identified eight special-status plant species known or with potential to occur in the vicinity of the Specific Plan Area; however, none of the eight special-status plant species have the potential to occur within the Specific Plan Area due to the highly disturbed nature of the area and the lack of suitable habitat conditions. Therefore, the proposed project would have no impact on special-status plant species.

The BRE identified 22 special-status animal species known or with potential to occur in the vicinity of the Specific Plan Area, of which only one special-status animal species, the western mastiff bat, was determined to have a potential to occur within the Specific Plan Area.

As described in Section 4.2.2 above, the western mastiff bat occurs in a wide variety of habitats including conifer and deciduous woodlands, coastal scrub, annual and perennial grassland, desert scrub, chaparral, palm oases, and urban habitats. It roosts in crevices on cliff faces, high buildings, trees, and tunnels that include vertical faces to drop off to take flight. Nursery roosts are typically found in in tight rock crevices or buildings. While the nearest occurrence was recorded in 1991 in downtown Fresno and is presumed extant (Element Occurrence Index [EONDX] 66374; CDFW 2025a), trees throughout the BSA could be suitable for roosting, and the BSA contains suitable foraging habitat for western mastiff bat. Direct impacts could occur if the species is roosting in these trees when the project is constructed. Avoidance and minimization measures are prescribed below.

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)

4.2-25
The BSA contains suitable habitat that could support a variety of ground- and tree-nesting bird species protected under the MBTA and the California Fish and Game Code. Impacts to active nests could occur from direct disturbance of active nests during implementation of the proposed project, and from noise and vibration caused by construction activities; however, implementation of the proposed project is not expected to cause a significant reduction in nesting habitat in the area.

Direct project impacts to species listed as a candidate, sensitive, or special‐status species by local, state, and federal agencies should be avoided to the greatest extent feasible; however, it is acknowledged that future projects may not be able to avoid these species. Project‐related impacts that result in the direct take of a special‐status species may be considered a significant impact. The presence or absence of a special‐status species in the Specific Plan Area and the potential for implementation of the proposed project to impact a special-status species must be determined prior to project construction. If development within the Specific Plan Area would result in the direct take or loss of suitable habitat for the special‐status animal species that has the potential to occur in the Specific Plan Area, project‐level site-specific mitigation would be required to reduce the potential impacts to less-than-significant levels. Project impacts to special‐status species listed as threatened or endangered by CDFW and/or USFWS may also require agency consultation and/or take permits.

Proposed projects within the Specific Plan Area would incorporate project design features outlined in the objectives and policies of the General Plan. The General Plan includes specific implementing policies pertaining to biological resources that must be adhered to for development within the Specific Plan Area, specifically within the Open Space and Biological Resources Section of Chapter 5, the Parks, Open Space, and Schools Element. Project‐level implementation of the General Plan Policies would reduce potential project impacts to special‐status species and their associated habitats.

Level of Significance Without Mitigation: Potentially Significant Impact Impact BIO-1: Implementation of the Specific Plan Update would have a substantial adverse effect, either directly or through habitat modifications, on a special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Mitigation Measure BIO-1a Avoidance Measures for Bats.

1. A qualified biologist with experience in assessing trees for bat roosts will survey all trees to be removed during construction for suitability as bat roosts. If a tree is deemed suitable, the qualified biologist will conduct a night emergence survey of the suitable roost tree 1 to 2 nights prior to tree removal using night vision and/or infrared-sensitive camera equipment and
bioacoustic recording equipment. If surveys are negative, trees should be removed immediately.

2. If night emergent surveys are positive, trees should be removed using a two-step process for 2 consecutive days and should be monitored by a qualified biologist. On the first day, small 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)

4.2-26
branches and small limbs that do not contain potential roost habitat (e.g., cavities, crevices, exfoliating bark) will be removed using chainsaws. On the second day, the remainder of the tree will be removed. The disturbance caused by chainsaw noise and vibration, coupled with the physical alteration of the tree will cause colonial bat species to abandon the roost tree after nightly emergence for foraging. Removing the tree the next day prevents re-habituation and re-occupation of the altered tree.

3. Any trees suitable as bat roost will be removed during one of the following periods to avoid harm to young or hibernating bats:
a. Between approximately March 1 and April 15 (or after evening temperatures rise above 45 degrees Fahrenheit
[°F], and less than 0.5 inch of rainfall in 24 hours occurs). b. After maternity season and prior to winter torpor or hibernation, September 1 through about October 15 (or
before evening temperatures fall below 45°F, and prior to greater than 0.5 inch of rainfall within 24 hours).

Mitigation Measure BIO-1b Pre- activity Nesting Bird Surveys. If future development and site- specific project activities facilitated by the implementation of the Specific Plan Update must occur during the nesting season (February 15 to August 31), pre-activity nesting bird surveys will be conducted by a qualified biologist in accordance with the California Department of Fish and Wildlife (CDFW) and/or the United States Fish and Wildlife Service (USFWS) no more than 7 days prior to the start of construction at the construction site, and a 250-foot buffer for songbirds and a 500-foot buffer for raptors (other than Swainson’s hawk [Buteo swainsoni]) will be installed. If no active nests are found, no further action is required; however, note that nests may become active at any time throughout the summer, including when construction activities are occurring. If active nests are found during the survey or at any time during future project construction facilitated by implementation of the Tower District Specific Plan Update, the project proponent shall install an avoidance buffer ranging from 50 feet to 350 feet will be required, as determined by a qualified biologist. The avoidance buffer will remain in place until the biologist has determined that the young are no longer reliant on the nest. Work may occur within the avoidance buffer under the approval and guidance of the biologist.

The qualified biologist will have the ability to stop construction if nesting adults show signs of distress.

Level of Significance With Mitigation: Less than Significant Impact 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)

4.2-27
Implementation of Mitigation Measure BIO-1a and BIO-1b would serve to ensure that the impacts of the implementation of the proposed project would reduce impacts to special-status animal species to a less than significant level.

4.2.5.2 Cumulative Impacts
State CEQA Guidelines Section 15355 requires an analysis of cumulative impacts, which are defined as, “two or more individual effects which, when considered together, are considerable, or which compound or increase other environmental impacts.”
BIO-2 The project, in combination with other projects, could contribute to a significant cumulative impact related to biological resources.

As discussed in Section 4.2.5.1, the proposed project could have significant impacts on special-status species prior to the incorporation of mitigation measures. Most direct and indirect impacts would result from construction-related disturbances and residential, industrial, and commercial development. However, the incremental effect of the proposed project, when combined with the effects created by other past and reasonably foreseeable projects, would not be cumulatively considerable or significant because future projects under implementation of the Specific Plan Update would be required to obtain regulatory approvals and implement the mitigation measures identified throughout this chapter. Potential impacts related to biological resources would be reduced through implementation of applicable local policies and objectives, and Mitigation Measure BIO-1a and BIO-1b, which would ensure protection of existing habitat, special-status plant and animal species, and potential wetlands, and ensure there are no conflicts with existing policies and regulations related to the protection of biological resources within the Specific Plan Area.

Also, because it would be speculative to assume the exact location and extent of development that would occur during implementation of the proposed project, future projects would be subject to project-level CEQA analysis which would further identify project specific impacts and mitigation measures at that time to ensure protection of biological resources. Therefore, because future projects would be subject to similar policies, mitigation, and regulations as the proposed project, for the protection of biological resources, as well as future CEQA analysis, a less than significant cumulative impact would occur.

Level of Significance Without Mitigation: Potentially Significant Impact.

Impact BIO-2: Implementation of the Specific Plan Update could result in cumulative impacts to biological resources.

Mitigation Measures: Refer to Mitigation Measures BIO-1a and BIO-1b.

Level of Significance With Mitigation: Less than Significant Impact Implementation of Mitigation Measures BIO-1a and BIO-1b would serve to ensure that the impacts of the implementation of the proposed project would reduce cumulative impacts to biological resources to a less than significant level.

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)

4.2-28
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)

4.3-1

4.3 CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES

4.3.1 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 the existing cultural and tribal cultural resources within the Tower District Specific Plan Area (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.

The descriptions in this section are based in part on information obtained from a records search conducted at the Southern San Joaquin Valley Information Center (SSJVIC) completed prior to adoption of the Specific Plan Update, background literature research, and a review of environmental compliance documents in and near the Specific Plan Area.

For the purposes of this analysis, an archaeological resource is considered any cultural resource that was deposited before Europeans established a Franciscan Mission in California (1769), although it has long been recognized that Europeans were present along the California Coast as early as the mid-16
th century and landed on the California Coast on several occasions. Buried resources deposited after 1769 are technically considered historical resources. Such resources would also include Native American resources deposited after that date.

The following information is provided in accordance with Section 15125 of the California Environmental Quality Act (CEQA). The environmental setting discussion provides a baseline discussion of the existing conditions within the Specific Plan Area and surrounding area. This section also addresses local, State, and federal regulations as they pertain to project impacts on cultural resources.

4.3.2 Existing Environmental Setting
The Tower District (District) was established in the early 20th century as one of Fresno’s first suburbs and is a typical representation of an American streetcar suburb. Streetcar lines extended from Downtown Fresno, located south of the District, and provided access to what was once farmland at the edge of the city. During the decades after World War II, conventions in development and neighborhood design changed dramatically as the emphasis shifted away from streetcars and pedestrians and catered to automobiles. Traditional building style changed from street-facing patterns to parking lots which lined public streets, changing the District’s character. Today, the District exhibits an exemplary heritage of buildings and site features from the early decades of the 20 th century.

Cultural resources include prehistoric‐era archaeological sites, historic‐era archaeological sites, Native American traditional cultural properties, sites of religious and cultural significance, and historical buildings, structures, objects, and sites. The importance of any single cultural resource is defined by the context in which it was first created, current public opinion and modern yet evolving 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)

4.3-2
analysis. From the analytical perspective, temporal and geographic considerations help to define the historical context of the Specific Plan Area.

4.3.2.1 Prehistoric Era and Ethnographic Overview
The San Joaquin Valley, along with the adjacent Sierra Nevada foothills and Coastal Ranges, possesses a rich and complex cultural history that spans over 11,000 years prior to European contact. The earliest widely accepted evidence of prehistoric occupation includes basally thinned, fluted projectile points—typically found along the shores of now-extinct lakes—indicating the presence of Paleo-Indian hunters between approximately 11,550 and 8,550 B.C.E.

At the time of European contact, the San Joaquin Valley and surrounding foothills were home to approximately 40 autonomous groups collectively identified as the Yokuts. These groups were traditionally divided into three major subgroups based on geography and language: the Northern Valley, the Foothill, and the Southern Valley Yokuts. Ethnographic evidence suggests that the area now encompassing the City of Fresno was historically within the territory of the Southern Valley Yokuts.
1 The Southern Valley Yokuts practiced a semi-sedentary hunter-gatherer lifestyle, relying on the seasonal availability of regional plant and animal resources. They resided in permanent villages during the fall through spring and moved within their territories during the summer to gather food, fish, and hunt game. Principal villages were commonly situated along perennial streams, while temporary camps and activity areas were distributed across the landscape. Bedrock milling features—frequently located near reliable water sources—represent some of the most enduring archaeological evidence of their long-term habitation.

The Yokuts were organized into distinct tribelets, each with its own name, dialect, and defined territory. These tribelets were typically governed by a hereditary chief residing in the principal village, who was aided by one or more advisors. Chiefs were responsible for community leadership, trade oversight, dispute resolution, and hosting visiting parties. Marriage customs were generally informal and patrilocal, leading to extended family groupings clustered around the male head of household. Polygamy was permitted but primarily practiced by men. There is limited evidence of widespread organized religious ceremonies among the Southern Valley Yokuts.

Material culture among the Southern Valley Yokuts was shaped by their resource-rich environment and supplemented through trade. They relied heavily on locally available materials such as tule, which was used extensively in house construction, basketry, mats, cradles, and watercraft. The abundance of waterways made rafts a central mode of transportation. Tools and weapons were crafted from wood, bone, and stone. Resources not available locally—such as obsidian, salt, acorns, and seashells—were acquired through an extensive trade network in exchange for asphaltum, steatite, and animal skins. Sweathouses, used exclusively by men, were a common feature in village life.

1 Wallace, William J. 1978. Southern Valley Yokuts. In Handbook of North American Indians, Vol 8, California. Smithsonian Institution, Washington D.C.

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)

4.3-3
Following European and, later, Mexican settlement in the San Joaquin Valley, the Yokuts population experienced a dramatic decline. By the latter half of the 19th century, widespread disease and displacement associated with European colonization had devastated indigenous communities. Like many Native groups in California, the Southern Valley Yokuts suffered a severe population decline.

4.3.2.2 Historic Era
Spanish exploration of the Central Valley began in the early 19th century, led by Gabriel Moraga.2 In expeditions between 1805 and 1808, Moraga named several key rivers including the Calaveras, Merced, Stanislaus, and Kings, and identified a tributary which would later become known as the San Joaquin River that borders the City of Fresno to the north. Moraga’s journeys were undertaken to locate sites for potential missions and to recover runaway neophytes. Following the transition from Spanish to Mexican rule, American trappers began utilizing the region’s natural resources, and the 1848 discovery of gold in California accelerated the influx of settlers. This wave of migration and development, particularly in the nearby mountains and foothills, led to a dramatic decline in Yokuts populations in the latter half of the 19
th century, primarily due to introduced diseases and expanding European settlements.

The discovery of additional mineral resources in the mid-19th century led to the establishment of small communities along rivers and streams in the foothills and mountains east and northeast of the city. Fresno County was formed in 1856, with its original county seat set in the foothill town of Millerton. Following a devastating flood in 1867 that affected Millerton and other nearby settlements, efforts began to establish a more secure regional trading center within the San Joaquin Valley. That same year, A.Y. Easterby founded a large agricultural enterprise in what is now central Fresno, and his partner Moses Church developed an innovative water delivery system that diverted water from the nearby Kings River. By 1871, Easterby’s 5,000-acre farm was producing irrigated wheat fields. The area gained further prominence when Central Pacific Railroad officials visited the site and designated it as a stop on the Central California Railroad, later known as the Southern Pacific line, following the company's renaming in 1884. After locals realized Fresno Station would become the trading center for the area, development spread beyond the original Easterby plat and began to be oriented toward roadways put in along Section lines in cardinal directions.

Eventually, irrigation companies, colonies, and districts were formed in the vicinity of various small towns including Fresno to promote agriculture. In 1875, the Central California Colony was established south of Fresno, which set the model for a system of development that was used throughout the San Joaquin Valley. Tracts of land were subdivided into 20–40 acre parcels, irrigated from a system of canals and often landscaped with boulevards of palms, eucalyptus or other drought‐resistant trees. By 1903, there were 48 separate colonies or tracts in Fresno County, which drew farmers and their families from Scandinavia and from across the United States. Fresno incorporated in 1885, with a population of over 3,000. Development was restricted to a six-block area beginning at and northeast from the Southern Pacific Railroad Depot.

2 Bancroft, Hubert Howe. 1884-1890. Hi story of California, 7 vols. The History Company, San Francisco, California.

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)

4.3-4
The first three decades of the 20th century were a period of steady growth and increasing prosperity for Fresno during which the City established itself as the primary city of the San Joaquin Valley. The City’s first electric streetcar was in use in 1902. By 1909, the first double‐track streetcar line was installed along J Street (now Fulton Street). By the early 1920s, streetcar lines would radiate out from the central business district to the north, east, south, and west, including into the Tower District, where farmland was being subdivided for suburban development. The expanding transit infrastructure, along with exponentially increasing private automobile ownership, made living further from the city center possible. Land within the central city became increasingly used for commercial and civic purposes.

4.3.2.3 Archaeological Resources
Archaeological resources may be considered to be either “unique archaeological resources” or “historical resources” as defined by CEQA and described previously. State CEQA Guidelines Section 21083.2 defines a “unique archaeological resource” as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it:
• Contains information needed to answer important scientific research questions, and there is a demonstrable public interest in that information;
• Has a special and particular quality, such as being the oldest of its type or the best available example of its type; and/or
• Is directly associated with a scientifically recognized important prehistoric or historic event or person.

Sites in the nearby foothills exhibit groundstone assemblages suggest that acorns and pine nuts were harvested when ripe by bands of mobile groups. Comparative ethnographic data suggests that mobile peoples with a seasonal round may have created a home base (village) in winter during these periods, then travelled to exploit pockets of certain resources in temporary encampments.

Lowland groups may have predominated in the Fresno area during the late Middle Holocene and archaeological sites dated to this time would likely exhibit foodstuff and processing tools more focused on lakeshore resources than grinding implements seen in upland sites. Soil strata found in the northwestern portion of the city has been defined as a Late Pleistocene non-marine alluvial fan covered with a veneer of late Holocene soil. In general, early and Middle Holocene alluvial deposits with cultural resources in them would typically be exposed only after several feet of soil has been removed. Soils near active stream channels are younger and are less likely to exhibit sites from this period except on intact dunes and at some depth.

Further, a cultural resources study found that no archaeological resources have been discovered within the Specific Plan Area. Known resources within a half-mile radius of the Specific Plan Area include buildings and structures and not buried resources. No pre-historic resources have been recorded in the vicinity and no ethnographic villages or camps are reported within or near the Specific Plan Area.

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)

4.3-5

4.3.2.4 Known Historical Resources
The City of Fresno has experienced extensive growth since the 1800s when the railroad arrived and the broad plain between the Kings River and San Joaquin River was hand-cleared of brush and native grasses. As agricultural commerce strengthened, most of the downtown area was transformed from little farms and railroad-supply businesses to a burgeoning agricultural center, then to the development of Victorian style blocks with grand hotels, to more modern styles evidenced in many Classical Revival buildings.

A Constraints Assessment (LSA 2025c)
3 was prepared for the proposed project in July 2025
(Appendix G). On May 21, 2025, staff at the Southern San Joaquin Valley Information Center (SSJVIC) at California State University, Bakersfield, conducted a record search. The SSJVIC is an affiliate of the California Office of Historic Preservation and is the official State repository for cultural resource records and reports for Fresno County. The objectives of this research are to (1) establish the status and extent of previously recorded resources and studies in the Specific Plan Area, and (2) note what types of previously undocumented resources might be expected within the various Drainage Areas and Growth Areas described above, based upon the existing data of known cultural resources and studies in the California Historical Resources Information System database. The record search included a review of previously documented prehistoric and historic-period and cultural resource records within the project site, as well as a review of cultural resources reports in the database.

The City of Fresno retains many of its historically significant buildings and structures through listings on various registers; local and national. Within the Specific Plan Area, data from the record search conducted at the SSJVIC indicates that there are 44 recorded resources and 20 reports that have been prepared within the Specific Plan Area. All resources recorded within the Specific Plan Area are historic. Of these 44 historic resources, 40 records are historic structures. The remaining four historic resources include two railroads, an overcrossing, and a debris deposit and associated trash deposit. These resources are listed in Table 4.3.A, below.

4.3.2.5 Native American Consultation
City staff consulted with the Native American Heritage Commission (NAHC) in July 2025. A letter to the NAHC was sent by City staff requesting a sacred lands search. The NAHC identified that there were no known sacred lands that were located within the Specific Plan Area; however, the NAHC provided a list of 10 Native American tribes to consult. The City sent letters to each of the tribes in July 2025. Appendix J includes the Native American consultation information.

3 LSA Associates, Inc. (LSA). 2025c. Constraints Assessment for the Tower District Specific Plan in Fresno, Fresno County, California. July.

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)

4.3-6
Table 4.3.A: Cultural Resources Within the Project Area Primary # Trinomial # Address Site Description
10-003930 CA-FRE-
003109H
Fresno County Southern Pacific Railroad Historic railroad 10-004245 - Hayhurst Residence
405 North Broadway Historic building
10-004246 - Mission Funeral Home
475 North Broadway Historic building
10-004247 - 315 East Brown Historic building
10-004271 - 415 North Ferger Avenue Historic building
10-004285 - J.B. Hill Feed Company
315 North H Street Historic structure
10-004309 - Paul Kindler House
1520 East Olive Avenue Historic building
10-004313 - The Mosgrove Home
660 East Pine Street Historic building
10-004319 - The Vincent Home
921 North San Pablo Avenue Historic building
10-004357 - Porteous Home
1095 North Van Ness Boulevard Historic building
10-004380 - McIndoo Residence
410 North Van Ness Boulevard Historic building
10-004381 - William Hanger Residence
425 North Van Ness Boulevard Historic building
10-004385 - 375 North Fulton Street Historic building
10-004386 - The Cobb Home
437 North Fulton Street Historic building
10-004387 - Stone Residence
408 North Fulton Street Historic building
10-004388 - The Proffitt Home
405 North Fulton Street Historic building
10-004431 - Fresno State Normal School
1101 East University Avenue Historic building
10-004432 - Fresno State College Library
1101 East University Avenue Historic building
10-004513 - Belmont Avenue Subway Historic railroad
10-004675 - Burlington Northern and Santa Fe Railway Historic railroad 10-005207 - Carnation Restaurant
644 East Olive Avenue Historic building
10-005208 - John G Porter House
420 North Van Ness Boulevard Historic building
10-005211 - 254 North Roosevelt Historic building
10-005213 - Newman J Levinson House
439 North Van Ness Boulevard Historic building
10-005216 - Ira H Brooks House
350 North Fulton Street Historic building
10-005217 - Fresno Veterinary Hospital
1212 East Belmont Historic building
10-005224 - The Turnbull/Butcher Residence
1614 East Englewood Avenue Historic building
10-005401 - Tower Theatre
1201 North Wishon Avenue Historic building
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)

4.3-7
Table 4.3.A: Cultural Resources Within the Project Area Primary # Trinomial # Address Site Description
10-005448 - 841-861 East Pine Apartment Court
841-861 East Pine Street Historic building
10-005449 - 830-844 East Pine Apartment Court
830-844 East Pine Street Historic building
10-005450 - 850-858 East Hedges Apartment Court
850-858 Hedges Historic building
10-005452 - 1333-1353 North Palm Bungalow Court
1353 North Palm Avenue Historic building
10-005454 - Normandy Village Apartments
840 East Brown Historic building
10-005455 - Tower Village Apartment Court
826-844 East Hedges Historic district
10-005913 - Fresno High School/Josiah Royce Hall
1839 North Echo Avenue Historic building
10-006032 - Weber Avenue Overcrossing Historic bridge
10-006099 - I.D. Schnabel Home
610 East McKinley Avenue Historic building
10-006528 - John M Wrightson Home
605 East McKinley Avenue Historic building
10-006529 - S.S. Beran Home
606 East McKinley Avenue Historic building
10-006960 - 1538 East Cinton Avenue Historic building
10-006961 - 1605 East Vassar Avenue Historic building
10-006962 CA-FRE-
003814H
1533 and 1539 East Vassar Avenue, 1688 East
Clinton Avenue Historic site
10-006963 - David’s Tire Shop
2315 North Blackstone Avenue Historic building
10-007545 - Belmont and Weber Archaeological Site Historic site Source: Southern San Joaquin Valley Information Center (2025).

4.3.3 Regulatory Setting
Federal, State, and local laws, regulations, plans, or guidelines that are potentially applicable to the Specific Plan Area are summarized below. The Section 106 compliance process associated with the National Historic Preservation Act of 1966 (NHPA) is commonly discussed within environmental impact reports (EIRs) but the process holds no regulatory requirement within Fresno unless cultural resources listed on the National Register of Historic Places (National Register) are adversely affected by a City‐approved project. Therefore, a review of the Federal process is necessary here only to provide background. Cultural resource law and regulations associated with the CEQA process are based upon, but are statutorily distinct from, the Section 106 process.

4.3.3.1 Federal Policies and Regulations
National Historic Preservation Act. The NHPA is the most concise and effective federal law dealing with historic preservation. Federal preservation law does not apply to the purpose of this analysis but a short review of the legislation is needed because the State and Local requirements have been derived from this legislation. The NHPA established guidelines to “preserve important historic, 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)

4.3-8
cultural, and natural aspects of our cultural heritage, and to maintain, wherever possible, an environment that supports diversity and a variety of individual choice.” The NHPA includes regulations specifically for federal land‐holding agencies, but also includes regulations (known as Section 106) which pertain to all projects that are funded, permitted, or approved by any federal agency and which have the potential to affect cultural resources. In addition, the NHPA authorizes the Secretary of the Interior to establish the National Register of Historic Places (The National Register). The National Register is an inventory of districts, sites, buildings, structures and objects significant at a national, State, or local level in American history, architecture, archaeology, engineering, and culture. The National Register is wholly maintained by the National Park Service, the Advisory Council on Historic Preservation, and the State Office of Historic Preservation (SHPO) and grants‐in-aid programs.

According to the National Park Service (NPS) and the SHPO, the City is a Certified Local Government (CLG). The CLG program is a preservation partnership between local, State, and national governments focused on promoting historic preservation at the grass roots level. The program is jointly administered by NPS and SHPO, with each local community working through a certification process to become recognized as a CLG. CLG’s become an active partner in the Federal Historic Preservation Program and the opportunities (and funding) it provides.

American Indian Religious Freedom Act (AIRFA) and Native American Graves Repatriation Act (NAGPRA). The American Indian Religious Freedom Act and Native American Graves Repatriation Act are designed to protect the rights of American Indians to practice their traditional religions and allow American Indians to reclaim human remains and other culturally significant items. AIRFA grants access to sacred sites, allows the use of sacred objects, and allows American Indians to participate in tradition religious ceremonies. NAGPRA provides an avenue for the return of Native American remains and other significant cultural items to be returned to their respective tribes by requiring consultation with tribes whose culturally significant artifacts are in the possession of a federally funded museum or agency. Additionally, NAGPRA also prohibits the unauthorized excavation or removal of Native American remains from federal or tribal lands.

4.3.3.2 State Policies and Regulations
California Register of Historical Resources. The California Register of Historical Resources (California Register) is an inventory of significant architectural, archaeological, and historical resources in the State of California. Important cultural resources can be listed in the California Register through a number of methods, and listing requires approval from the State Historic Resources Commission. Properties can be nominated to the California Register by local governments, private organizations, or citizens. State Historical Landmarks and National Register‐ listed properties gain automatic listing in the California Register. The evaluative criteria used by the California Register for determining eligibility are closely based on those developed by the National Park Service for the National Register of Historic Places. In order for a cultural resource to be significant, or in other words eligible, for listing in the California Register, it must reflect one or more of the following criteria (Public Resources Code [PRC] 5024.1c):

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)

4.3-9
• Criterion 1 (Events): Resources that are associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.
• Criterion 2 (Persons): Resources that are associated with the lives of persons important to local, California, or national history.
• Criterion 3 (Architecture): Resources that embody the distinctive characteristics of a type, period, region, or method of construction, or represent the work of a master, or possess high artistic values.
• Criterion 4 (Information Potential): Resources or sites that have yielded or have the potential to yield information important to the prehistory or history of the local area, California, or the nation.

California Environmental Quality Act. CEQA requires that public agencies assess the effects on historical resources of public or private projects that the agencies finance or approve. Historical resources are defined as buildings, sites, structures, objects, areas, places, records, or manuscripts that the lead agency determines to have historical significance, including architectural, archaeological, cultural, or scientific significance. CEQA requires that if a project results in an effect that may cause a substantial adverse change in the significance of a historical resource, alternative plans or mitigation measures must be considered.

However, only significant historical resources need to be addressed. Therefore, before the assessment of effects or development of mitigation measures, the significance of cultural resources must be determined. The steps that are normally taken in a cultural resources investigation for CEQA compliance are as follows:

1. Identify potential historical resources.

2. Evaluate the eligibility of historical resources.

3. Evaluate the effects of the project on all eligible historical resources.

In addition, properties that are listed in or eligible for listing in the National Register are considered eligible for listing in the California Register and thus are significant historical resources for the purposes of CEQA (PRC Section 5024.1[d][1]).

According to CEQA, a project with an effect that may cause a substantial adverse change in the significance of a historical resource may have a significant impact on the environment (State CEQA Guidelines Section 15064.5[b]). CEQA also states that a substantial adverse change in the significance of a resource means the physical demolition, destruction, relocation, or alteration of an historical resource or its immediate surroundings such that the significance of the resource would be materially impaired. Actions that would materially impair the significance of a historical resource are any actions that would demolish or materially and adversely alter the physical characteristics of a historical resource that convey its historical significance and qualify or justify its eligibility for 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)

4.3-10
inclusion in the California Register or in a local register or survey that meet the requirements of PRC Sections 5020.1(k) and 5024.1(g).

Significant Historical Resources under CEQA Guidelines. In completing an analysis of a project under CEQA, it must first be determined if the project site possesses a historical resource. A site may qualify as a historical resource if it falls within at least one of four categories listed in CEQA Guidelines Section 15064.5(a). The four categories are:

1. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code Section 5024.1, Title 14 CCR, Section 4850 et seq.).

2. A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements of section 5024.1 (g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.

3. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Pub.

Res. Code Section 5024.1, Title 14 CCR, Section 4852).

These conditions are related to the eligibility criteria for inclusion in the California Register (PRC Sections 5020.1[k], 5024.1, 5024.1[g]). A cultural resource may be eligible for inclusion in the California Register if it:
• Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
• Is associated with the lives of persons important in our past; • Embodies the distinctive characteristics of a type, period, region, or method of construction; represents the work of an important creative individual; or possesses high artistic values; or • Has yielded, or may be likely to yield, information important in prehistory or history.

The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to Section 5020.1(k) of the Pub. Resources Code), or identified in an historical resources survey (meeting the criteria in Section 5024.1(g) of the Pub. Resources Code) does not preclude a lead 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)

4.3-11
agency from determining that the resource may be an historical resource as defined in Pub.

Resources Code sections 5020.1(j) or 5024.1.

A lead agency must consider a resource that has been listed in, or determined to be eligible for listing in the California Register (Category 1) as an historical resource for CEQA purposes. In general, a resource that meets any of the other three criteria listed in CEQA Guidelines Section 15064.5(a) is also considered to be a historical resource unless “the preponderance of evidence demonstrates” that the resource is not historically or culturally significant.” State Health and Safety Code. The discovery of human remains is regulated according to California Health and Safety Code Section 7050.5, which states, “If human remains are encountered, no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be prehistoric, the Coroner will notify the NAHC, which will determine and notify Most Likely Descendant (MLD). With the permission of the landowner or his or her authorized representative, the MLD may inspect the site of the discovery.

The MLD shall complete the inspection within 24 hours of notification by the NAHC. The MLD may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials.”
California Government Code 65352.3‐5: Local Government‐Tribal Consultation. California Government Code Sections 65092, 65351, 65352, 65352.3, and 65352.4, formally known as Senate Bill (SB) 18, regulate the consultation with California Native American tribes having traditional lands located within the jurisdiction of applicable cities and counties. The intent of the underlying legislation was to provide all California Native American tribes that are on the contact list maintained by the Native American Heritage Commission, an opportunity to consult with specific local governments for the purpose of preserving and protecting their sacred places. Such consultations apply to the preparation, adoption and amendment of general plans.

Senate Bill 18. Senate Bill (SB) 18, signed into law in September 2004, requires local (city and county) governments to consult with California Native American tribes to aid in the protection of traditional tribal cultural places through local land use planning. The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting or mitigating impacts to cultural places. The consultation and notice requirements apply to adoption and amendment of both general plans (Government Code Section 65300 et seq.) and specific plans (Government Code Section 65450 et seq.). Specifically, Government Code Section 65352.3 requires local governments, prior to making a decision to adopt or amend a general plan, to consult with California Native American tribes identified by the NAHC for the purpose of protecting or mitigating impacts to cultural places. As previously discussed, the NAHC is the State agency responsible for the protection of Native American burial and sacred sites.

Assembly Bill 52. Assembly Bill (AB) 52, the Native American Historic Resource Protection Act, sets forth a proactive approach intended to reduce the potential for delay and conflicts between Native American and development interests. Projects subject to AB 52 are those that file a notice of preparation for an EIR or notice of intent to adopt a negative or mitigated negative declaration on or 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)

4.3-12
after July 1, 2015. AB 52 adds tribal cultural resources (TCR) to the specific cultural resources protected under CEQA. Under AB 52, a TCR is defined as a site, feature, place, cultural landscape (must be geographically defined in terms of size and scope), sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register, or included in a local register of historical resources. A Native American Tribe or the lead agency, supported by substantial evidence, may choose at its discretion to treat a resource as a TCR. AB 52 also mandates lead agencies to consult with tribes, if requested by the tribe, and sets the principles for conducting and concluding consultation.

Public Resources Code Section 5097.5. California Public Resources Code (PRC) Section 5097.5 prohibits the “knowing and willful” excavation or removal of any “vertebrate paleontological site…or any other archaeological, paleontological or historical feature, situated on public lands, except with express permission of the public agency having jurisdiction over such lands.” Public lands are defined as land that is owned or under the jurisdiction of the State or any city, county, district, authority, or public corporation, or any agency thereof.

4.3.3.3 Local Policies and Regulations
City of Fresno General Plan. The approved General Plan is a set of policies and programs that form a blueprint for the physical development of the City. The following objectives and policies related to cultural resources are presented in various elements of the approved General Plan:

Historic and Cultural Resources Element.

Objective HCR‐1: Maintain a comprehensive, citywide preservation program to identify, protect and assist in the preservation of Fresno’s historic and cultural resources.

Policy HCR‐1‐a: Certified Local Government. Maintain the City’s status as a Certified Local Government (CLG), and use CLG practices as the key components of the City’s preservation program.

Poli
cy HCR‐1‐b: Preserv
ation Office, Commission and Program. Maintain the Preservation Office, Historic Preservation Commission, and preservation program to administer the City’s preservation functions and programs
Polic
y HCR‐1‐c: Historic Preservation Ordinance. Maintain the provisions of the City’s Historic Preservation Ordinance, as may be amended, and enforce the provisions as appropriate.

Objective HCR‐2: Identify and preserve Fresno’s historic and cultural resources which reflect important cultural, social, economic and architectural features so that community residents will have a foundation upon which to measure and direct physical change.

Policy HCR‐2‐a: Identification and Designation of Historic Properties. Work to identify and evaluate potential historic resources and districts and prepare nomination forms for Fresno’s Local Register of Historic Resources and California and National registries, as appropriate.

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)

4.3-13
Policy HCR‐2‐b: Historic Surveys. Prepare historic surveys according to California Office of Historic Preservation protocols, as funding is available.

Policy HCR‐2‐c: Project Development. Prior to project approval, a subject parcel and its Area of Potential Effects (APE), without benefit of a prior historic survey, will be evaluated and reviewed for the potential for historical and/or cultural resources by a professional who meets the Secretary of Interior’s Qualifications. Survey costs shall be the responsibility of the project developer. Council may, but is not required, to adopt an ordinance to implement this policy.

Poli
cy HCR‐2‐d: Nat
ive American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, as required by State law, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.

Poli
cy HCR‐2‐f: Arch
aeological Resources. Consider State Office of Historic Preservation guidelines when establishing CEQA mitigation measures for archaeological resources.

Polic
y HCR‐2‐g: Demolition Review. Review all demolition permits to determine if the resource scheduled for demolition is potentially eligible for listing on the Local Register of Historic Resources. Consistent with the Historic Preservation Ordinance, refer potentially eligible resources to the Historic Preservation Commission and as appropriate to the City Council.

Polic
y HCR‐2‐k: City‐owned Resources. Maintain all City-ow
ned historic and cultural
resources in a manner that is consistent with the U.S. Secretary of the Interior’s Standards for the Treatment of Historic Properties, as appropriate.

Polic
y HCR‐2‐m: Local Register Listing. Recommend that property owners, who receive funds from the City of Fresno for rehabilitation of a property, consent to listing it on the Local Register of Historic Resources if the property meets the criteria for age, significance, and integrity. Publicly funded rehabilitation properties which may meet Local Register criteria will be presented to the City’s Historic Preservation Commission for review.

Policy HCR‐2‐n: Property Database and Informational System. Identify all historic resources within the city designated on the Local, State, or National register, and potential significant resources (building, structure, object or site) in existence for at least 45 years, and provide this information on the City’s website.

Objective HCR‐3: Promote a “New City Beautiful” ethos by linking historic preservation, public art, and planning principles for complete neighborhoods with green building and technology.

Polic
y HCR‐3‐a: A
daptive Reuse. Promote the adaptive reuse and integration of older buildings into new projects as part of the City’s commitment to nurturing a sustainable Fresno.

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)

4.3-14
Policy HCR‐3‐b: Co llaborate with the arts community to promote the integration of public art into historic buildings and established neighborhoods. Link arts activities (such as Art Hop) with preservation activities.

Polic
y HCR‐3‐c: Context Sensitive Design. Work with architects, developers, business owners, local residents and the historic preservation community to ensure that infill development is context-sensitive in its design, massing, setbacks, color, and architectural detailing.

Objective HCR‐4: Foster an appreciation of Fresno’s history and cultural resources.

Poli
cy HCR‐4‐d: Pub
lic Archives. Maintain public archives that include information on all designated historic properties, as well as historic surveys, preservation bulletins, and general local history reference materials. Post survey reports, Historic Preservation Commission minutes and agendas, and other information of public interest on the historic preservation page of the City’s website
City
of Fresno Municipal Code.

Historic Preservation Ordinance. The City of Fresno has established a Historic Preservation Commission and a Local Register of Historic Resources (Fresno Municipal Code, Chapter 12, Article 16). The Ordinance is used to provide local levels of control over the historical aesthetics of cultural resources within the City, and to ensure that the potential impact to locally significant historical resources that may be the subject of redevelopment are given reasonable consideration. The purpose of the ordinance is to:
…continue to preserve, promote and improve the historic resources and districts of the City of Fresno for educational, cultural, economic and general welfare of the public; to continue to protect and review changes to these resources and districts which have a distinctive character or a special historic, architectural, aesthetic or cultural value to this city, state and nation; to continue to safeguard the heritage of this city by preserving and regulating its historic buildings, structures, objects, sites and districts which reflect elements of the city's historic, cultural, social, economic, political and architectural history; to continue to preserve and enhance the environmental quality and safety of these landmarks and districts; to continue to establish, stabilize and improve property values and to foster economic development. (Article 16 Section 12‐1602(a).)
The ordinance provides legislative mechanisms to protect certain historical resources. Local registers of identified historical resources are known, including:

1. Heritage Properties. These are defined as a resource which is worthy of preservation because of its historical, architectural or aesthetic merit but which is not proposed for and is not designated as an Historic Resource under the ordinance.

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)

4.3-15

2. Historic Resources. These are defined as any building, structure, object or site that has been in existence more than fifty years and possesses integrity of location, design, setting, materials, workmanship, feeling and association, and is associated with events that have made a significant contribution to the broad patterns of city history, or is associated with the lives of persons significant in our past, or embodies the distinctive characteristics of a type, period or method of construction, or represents the work of a master or possesses high artistic values; or has yielded, or may be likely to yield, important information in prehistory or history; and has been designated as such by the Council pursuant to the provisions of the ordinance.

3. Local Historic Districts. These are defined as any finite group of resources related to one another in a clearly distinguishable way or any geographically definable area which possesses a significant concentration, linkage or continuity of sites, buildings, structures or objects united historically or aesthetically by plan or physical development. The Local Historic District must be significant as well as identifiable and it must meet Local Register Criteria for listing on that Register. Contributors to Historic Districts are defined as any Historic Resource that contributes to the significance of the specific Local Historic District or a proposed National Register Historic District under the criteria set forth in the ordinance.

4. National Register Historic Districts, which shall mean any finite group of resources related to one another in a clearly distinguishable way or any geographically definable area which possesses a significant concentration, linkage or continuity of sites, buildings, structures or objects united historically or aesthetically by plan or physical development. A National Register Historic District must be significant as well as identifiable and it must meet National Register Criteria for listing on that Register. Contributors to a National Register Historic District are defined as any individual Historic Resource which contributes to the significance of a National Register Historic District under the criteria set forth in the ordinance.

Certified Local Government. The Certified Local Government (CLG) Program is administered by the State Office of Historic Preservation (OHP). When a Lead Agency becomes a CLG it agrees to carry out the intent of and serve as a local steward of the National Historic Preservation Act and the Secretary of the Interior’s Standards. In meeting those standards, OHP serves as an advisor. The use of the National Register/California Register criteria and the Secretary of the Interior Standards integrates local, State, and federal levels of review. It brings clarity to the question of what resources are significant when it comes to CEQA and Section 106 of the National Historic Preservation Act. Adopting the Secretary of the Interior’s Standards will allow the use of categorical exemptions under CEQA, and likely result of findings of no adverse effect under Section 106. The use of these criteria and standards make environmental review faster, more efficient, and reduces costs and delays. The City has been certified as a CLG since September 1996.

4.3.4 Significance Criteria
The thresholds for impacts to cultural resources 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 related to cultural resources if it would:

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)

4.3-16
• Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5;
• Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5;
• Disturb any human remains, including those interred outside of formal cemeteries; • Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or
• Cause a substantial adverse change in the significance of a tribal cultural resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

4.3.5 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to cultural resources 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.

4.3.5.1 Project Impacts
The following discussion describes the potential impacts related to cultural resources that could result from implementation of the Specific Plan Update.

CUL‐1 Th
e project would cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.

A Co
nstraints Assessment was prepared for the project in July 2025, which listed 44 resources recorded within the Specific Plan Area. All resources recorded within the Specific Plan Area are historic. Of these historic resources, 40 records are historic structures. The remaining four historic resources include two railroads, an overcrossing, and a debris deposit and associated trash deposit.

Additionally, as discussed in Section 4.3.2 Existing Environmental Setting, much of the development within the Specific Plan Area occurred during the early to mid-20th century and thus would have the potential to meet the criteria for inclusion on the California Register of Historical Resources.

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)

4.3-17
The proposed project would support mixed-use development in targeted areas by developing or redeveloping vacant and underutilized parcels within the Specific Plan Area. Future development under the proposed project would include site preparation, grading, demolition, and other various construction activities which have the potential to result in an adverse change to a historic resource through demolition, destruction, alteration, or relocation.

As described in Section 4.3.3, Regulatory Setting, there are several existing regulations that would govern implementation of the proposed project. The California Historical Building Code establishes specific standards for the rehabilitation, preservation, restoration (including reconstruction), and relocation of buildings and properties formally recognized as historically significant by a State or local agency. Additionally, the City of Fresno’s Historic Preservation Ordinance provides a framework for the protection, enhancement, and management of designated Historic Resources and Historic Districts. Future development within the Specific Plan Area would also be required to adhere to General Plan Objectives HCR-1, HCR-2, HCR-3, and HCR-4 along with associated policies, which direct the City to identify, designate, and conserve sites and structures of historical, archaeological, and cultural value. Furthermore, Policies HCR-2-c and HCR-2-g require that evaluations of potential impacts on such resources be conducted by professionals who meet the Secretary of the Interior’s professional qualification standards.

The Specific Plan Update proposes objectives and policies to be implemented that focus on conservation and historic preservation of the Tower Districts resources and identity, as outlined in Table 4.3.B, below.

Table 4.3.B: Tower District Specific Plan Update – Conservation & Historic Preservation Objectives and Policies
Objective CHP 1: Recognize and Protect the Tower District’s Historic and Cultural Identity Policy CHP 1.1: Develop a historic
context statement for the Tower
District.

A comprehensive historic context statement should be developed by a qualified cultural resource professional, which describes: the district’s physical, social, and cultural development; identifies physical patterns associated with those developments; and recommends eligibility criteria and integrity thresholds for the designation of historic resources. The context statement should provide a consistent foundation for decisions about the identification, evaluation, and designation of historic properties in the community. The historic context statement should be developed in accordance with the standards and guidance provided by the National Park Service and the California Office of Historic Preservation. The historic context statement should be developed with the input of community members, local historic and cultural organizations, local social and educational institutions, and should consider the large body of previous historic resources studies developed for the City of Fresno, including studies within the Tower District.

Recognize that the historic context statement will be used to evaluate whether a potential historic resource should be designated, and that, by identifying character defining features within subdistricts, the statements can guide the development of context-appropriate development standards and guidelines.

Also note that the historic context statement should address contributions by persons and populations that have previously been overlooked or marginalized, such as women, communities of color, and the LGBTQ+ community.

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)

4.3-18
Table 4.3.B: Tower District Specific Plan Update – Conservation & Historic Preservation Objectives and Policies
Policy CHP 1.2: Protect the Tower
District’s cultural history and
resources.

Using historic context statements as a guide, continue to apply standards and procedures that regulate the alteration of designated historic resources, whether buildings and/or site features, and seek to prevent their loss. Require the character of infill development to comply with the Tower District Standards & Design Guidelines to be compatible within its historic context.

In accordance with State law, adopt context-appropriate design standards and guidelines, in recognition that some new housing projects may not be exempt from discretionary review. Note that incompatible new construction could distract from historic buildings, especially when adjacent to historic buildings, and could alter the character within historic districts. Also reinforce the historic character of the Tower District public streets and open spaces, by establishing design standards and guidelines for features like lighting, furnishings, trees, and landscape.

Policy CHP 1.3: Conduct new
historic resources survey(s) of the
Tower District.

Update historic resource surveys for the area. An updated historic resource survey should be used to establish a new baseline for historic preservation within the Tower District.

Policy CHP 1.4: Revive designation
efforts for previously proposed
historic districts.

The 1991 Tower District Specific Plan proposed several areas as potential historic districts that have not been formally listed or designated in the intervening years. The identified potential historic districts include:
 Adoline-Palm District (proposed)
 Terrace Gardens District (proposed)
 Wilson’s North Fresno Tract District (proposed)
 Lower Fulton-Van Ness (proposed)
 Bungalow Court District (proposed)
Prioritize these areas for historic resource surveys and the evaluation of designated and potential resources, to provide for their potential designation as historic districts.

Policy CHP 1.5: Initiate a study for
the historic designation of the
following areas:
• Area bounded by Olive and Van
Ness, down to Elizabeth and San
Pablo – east of Van Ness
• South of Belmont, West of
Broadway
Prioritize these areas for historic resource surveys and the evaluation of designated and potential resources, to provide for their potential designation as historic districts.

Policy CHP 1.6: In keeping with the
historic designation status, protect
the Tower Theater as a community
asset in alignment with the historic
preservation ordinance.

Policy CHP 1.7: Evaluate
designation of potential resources
in the public right-of-way.

Using historic resource survey(s) and community engagement for guidance, identify and evaluate public realm design elements that may be eligible for historic designation. These elements should be researched for their historic significance and, if eligible, nominated for designation accordingly. Elements located in the Tower District that have been discussed as [potential resources include but are not limited to the following:
 Historic hitching posts
 Van Ness Avenue “pineapple” streetlights
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)

4.3-19
Table 4.3.B: Tower District Specific Plan Update – Conservation & Historic Preservation Objectives and Policies
 Historic signage
 Sidewalk WPA stamps
 Stone gateway features on palm and Van Ness
Policy CHP 1.8: Highlight assets
important to community identity.

Buildings, structures, objects and sites that are not eligible for listing or designation as historic resources may still contribute to the character and identity of the community. These can include:
 Buildings that house or once housed long-term local businesses or institutions.
 Neighborhood-serving commercial nodes such as Weldon and Echo avenues near Fresno High School, the intersection of Van Ness and Floradora (Van Ness Village), and Fulton Stret (south of Olive).
 Street features such as streetlights, street signs, street trees, sidewalk parkways, and street medians not distinguished as historically significant,  Recognize historic businesses and institutions which continue to operate in the district.

These and other features may be highlighted using signage, maps, online resources, walking tours or other means.

Policy CHP 1.9: Elevate the visibility
of historic elements in the Tower
District.

Actively promote historic resources in the Tower District through walking tours, brochures, online resources, interpretive signage, plaques and displays. Use the District’s rich history as a draw for economic activity, including historic tourism, and community enjoyment.

Policy CHP 1.10: Heritage Trust and
Historic Preservation Fund.

Support the creation of a City of Fresno Heritage Trust and Historic Preservation Fund to support acquisition, rehabilitation, and maintenance of historic resources. Evaluate the feasibility of a right-of first refusal program for the trust to acquire historic properties.

Policy CHP 1.11: Historic museum Support the establishment of a museum in the Tower District, representing the Tower District, using a historic building or other building as an interactive place of learning.

Objective CHP 2: Maintain and Enhance Neighborhood Character-Defining Elements Policy CHP 2.1: Provide historic
preservation information, training
and accountability.

Provide information and training to help community members, new buyers, real estate professionals, government officials, staff, and other stakeholders to better understand the benefits, responsibilities, and potential difficulties of owning and managing historic properties. Work to preserve historic properties that have fallen into disrepair due to the neglect of their owners. Information readily available and helpful to community members should include the following:
 Basics regarding historic context, significance, integrity, and eligibility for historic listing on both local and national registers.
 Processes and requirements for nomination and designation of historic resources.
 Conformance with existing preservation standards and guidelines.  Available preservation incentives including Mills Act contracts, use of the California Historic Building Code, and technical assistance.  Environmental benefits of reusing existing materials and infrastructure.  Potential economic benefits of preservation, by creating new opportunities for education, cultural activities, and a recognizable destination.  Education to City leaders, community members, real estate professionals and other stakeholders on the value of historic preservation.

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)

4.3-20
Table 4.3.B: Tower District Specific Plan Update – Conservation & Historic Preservation Objectives and Policies
Policy CHP 2.2: Protect and
maintain existing character-defining
streetscape elements.

Provide protection and maintenance, including replacement when necessary, of existing character-defining streetscape elements such as streetlights, tree lawns, and street trees in addition to elements as referenced in CHP 1.5. Consider reinstallation of elements that have been removed such as granite curbs, “pineapple” streetlights and other features.

Policy CHP 2.3: Accessory Dwelling
Units (ADUs) in historic properties
Work with the Historic Preservation Commission and the Tower Design Review Committee to create ADU design standards to maintain ADU compatibility within historic districts.

Policy CHP 2.4: Affordable housing Work with affordable housing developers to promote acquiring historic and/or vacant buildings for the creation of affordable, multifamily housing through appropriate modernization and adaptive reuse.

Objective CHP 3: Use Zoning and Design Standards and Guidelines to Support Conservation of Historic Neighborhood Character
Policy CHP 3.1: Refine design
standards and guidelines.

Work with the Historic Preservation Commission and the Tower Design Review Committee to craft design standards and guidelines as may be used for historic properties, districts and centers. Recognize that California law has eliminated discretionary authority over the review of qualifying multifamily housing and residential solar projects and that, in such instances, objective standards are needed to maintain compatibility.

Policy CHP 3.2: Pedestrian-oriented
commercial development.

Prohibit development of suburban-style, strip commercial uses. Establish development standards and guidelines that support the creation of new and maintenance of existing pedestrian-oriented storefronts, by regulating ground- level use, entry, and window patterns.

Policy CHP 3.3: Encourage the
rehabilitation and adaptive reuse of
historic buildings.

Continue to establish streamlined approval processes, clear standards, guidance, and example plans for the reuse of historic buildings to allow alterations that maintain the building’s historic significance and integrity.

Standards should address typical reuse strategies such as additions to historic buildings, adaptive reuse of historic buildings for new uses, conversion of historic single-family properties for multi-family use, and the construction of ADUs. These standards can be tailored to specific property types within the Tower District.

Policy CHP 3.4: Continue to pursue
Code Enforcement to ensure
historic resources are adequately
maintained.

Objective CHP 4: Coordinate Plans and Programs of the Tower District and Downtown Fresno to Emphasize the Historic Connection
Policy CHP 4.1: Connection to
Downtown.

In all facets of development including streetscape, land-use and urban form, reinforce the historic relationship between Fulton and Van Ness Corridor and Downtown, through building form, street design, and signage.

Source: City of Fresno (2025).

While implementation of the Historic Preservation Ordinance, along with applicable State policies, General Plan objectives and policies, and the proposed Specific Plan Update objectives and policies would reduce potential impacts to historical resources, demolition of historic resources could still be necessary as part of implementation of the proposed project due to health and safety concerns.

Additionally, modifications to historical resources may be proposed, which would be required to comply with the Secretary of the Interior’s Standards for the Treatment of Historic Properties, as referenced in the Historic Preservation Ordinance. Compliance with all applicable Federal, State, 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)

4.3-21
local regulations and policies governing the protection of historic resources would reduce potential adverse changes to historical resources within the Specific Plan Area. However, the Historic Preservation Ordinance and the General Plan objectives and policies do not prohibit the City from approving a proposed project which has a significant impact on a historical resource. Therefore, even with adherence to all federal, State, and local regulations, potential adverse impacts to historical resources are still considered potentially significant.

Additionally, implementation of the proposed project has the potential to adversely affect previously unidentified historic resources located below the surface. While the Specific Plan Area consists of largely developed and previously disturbed land, the potential for historic deposits to be uncovered during implementation of the proposed project remains.

Level of Significance Without Mitigation: Potentially Significant Impact Impac
t CUL‐1: Impl
ementation of the Specific Plan Update would cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.

Mitiga
tion Measure CUL‐1a
If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study. The qualified historical resources specialist shall make recommendations to the City of Fresno (City) on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the State CEQA Guidelines and the City’s Historic Preservation Ordinance.

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

No further grading shall occur in the area of the discovery until the City of Fresno approves the measures to protect these resources.

Any historical artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.

Mitiga
tion Measure CUL‐1b Pr
ior to approval of any discretionary project that could result in an adverse change to a potential historic and/or cultural resource, the City shall require a site-specific evaluation of historic and/or cultural resources by a professional who meets the Secretary of the 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)

4.3-22
Interior’s Qualifications. The evaluation shall provide recommendations to mitigate potential impacts to historic and/or cultural resources and shall be approved by the Director of Planning and Development.

Its significance shall be assessed and documented by a qualified architectural historian in accordance with the significance criteria set forth for historic resources under CEQA Guidelines Section 15064.5. The evaluation process shall include the development of appropriate historical background research as context for the assessment of the significance of the structure in the history of the City and the region. For buildings, structures, and other resources determined through this evaluation process not to meet the CEQA historical resource criteria, no further mitigation is required. For any building, structure, and or other resource that qualifies as a historic resource, the architectural historian and the future project-specific applicant shall consult to consider measures that would enable projects under the proposed plan to avoid direct or indirect impacts to the historic building or structure. These could include preserving the building on site, using it “as is,” or other measures that would not materially alter the historically significant components of the building or structure. If the project cannot feasibly avoid modifications to the historically significant features of the historic building or structure, the following measures shall be undertaken as appropriate:
• If the building or structure can be preserved on-site, but remodeling, renovation or other alterations are required, this work shall be conducted in compliance with The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings (NPS 2017).
• If a significant historic building or structure is proposed for major alteration or renovation, or to be moved and/or
demolished, the City shall ensure that a qualified architectural historian thoroughly documents the building and associated 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)

4.3-23
landscaping and setting. Documentation shall include still and video photography and a written documentary record of the building to the standards of the Historic American Building Survey or Historic American Engineering Record, including accurate scaled mapping, architectural descriptions, and scaled architectural plans, if available. A copy of the record shall be provided to the City. The record shall be accompanied by a report containing site-specific history and appropriate contextual information. This information shall be gathered through site specific and comparative archival research, and oral history collection as appropriate.
• If preservation and reuse at the site are not feasible, the historical building shall be documented as described in item (2) and, when physically and financially feasible, be moved and preserved or reused.

Level of Significance with Mitigation: Less Than Significant Impact Compliance with Mitigation Measures CUL-1a and CUL-1b would ensure that implementation of the Specific Plan Update would not cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5, and impacts associated with the proposed project would be less than significant.

CUL‐2 T
he project could result in a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Pre
historic archaeological resources are cultural resources which were deposited before Europeans established a Franciscan Mission in California (1769). Prehistoric archaeological resources include any deposits, features, or isolated artifacts. Historical archaeological resources are discussed in Impact CUL‐1 above. Under PRC 21083.2(h), prehistoric archaeological resources can be divided into two classes, unique and non‐unique. Unique resources must be treated as if they are significant and avoidance of those resources is the first choice, while non‐unique resources do not meet criteria established in 21083.2(g) and therefore need not be avoided under State CEQA Guidelines.

Based on the data sources reviewed for the Specific Plan Area and identified above in Section 4.5.2 and in the Constraints Assessment, there have been no prehistoric archaeological resources found within the Specific Plan Area. The absence of prehistoric resources previously documented within the Specific Plan Area, and severe disturbance associated with development, suggest that sensitivity for in situ pre-contact archaeological resources is low. However, the establishment of Fresno as a streetcar suburb in the early 20th century and the subsurface debris and associated trash within the Specific Plan Area indicate that the area retains some potential for archaeological resources which could be discovered during implementation of the proposed project, particularly in previously undisturbed areas. Therefore, the proposed project could result in a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

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)

4.3-24
Level of Significance Without Mitigation: Potentially Significant Impact Impac
t CUL‐2: The
project could cause a substantial adverse change in the significance of an archaeological resource as defined in Section 15064.5 of the State CEQA Guidelines.

Mitiga
tion Measure CUL‐2 Subs
equent to a preliminary City review of grading plans for future development projects facilitated by the Specific Plan Update, if there is evidence that a project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for prehistoric archaeological resources shall be conducted. The following procedures shall be followed. • If prehistoric resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that buried prehistoric archaeological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified archaeologist shall be consulted to determine whether the resource requires further study. The qualified archaeologist shall make
recommendations to the City of Fresno on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the State CEQA Guidelines. If the resources are determined to be unique prehistoric archaeological resources as defined under Section 15064.5 of the State CEQA Guidelines, mitigation measures shall be identified by the monitor and recommended to the City of Fresno. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any prehistoric
archaeological artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.
• If prehistoric resources are found during the field survey or literature review, the resources shall be inventoried using appropriate State record forms and submit the forms to the Southern San Joaquin Valley Information Center. The resources shall be evaluated for significance. If the resources are found to be significant, measures shall be identified by the qualified archaeologist. Appropriate mitigation measures for significant 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)

4.3-25
resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include an archaeological monitor. The monitoring period shall be determined by the qualified archaeologist. If additional prehistoric archaeological resources are found during
excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed.

Level of Significance with Mitigation: Less Than Significant Impact Compliance with Mitigation Measure CUL-2 would ensure that implementation of the Specific Plan Update would not cause a substantial adverse change in the significance of an archaeological resource as defined in Section 15064.5 of the State CEQA Guidelines, and impacts associated with the proposed project would be less than significant.

CUL‐3 T
he project could disturb human remains, including those interred outside of formal cemeteries.

As des
cribed in Section 4.3.2 Existing Environmental Setting, there is currently no evidence that the Specific Plan Area contains prehistoric cemeteries or Native American cemeteries. Additionally, there are no formal cemeteries located within the Specific Plan Area. The proposed project would allow development and redevelopment of sites within the Specific Plan Area and although there is no record of isolated human remains or unknown cemeteries, there is always a possibility that ground‐disturbing activities associated with future development may uncover previously unknown buried human remains. Therefore, implementation of the proposed project would have the potential to disturb human remains and the impact is considered potentially significant.

Level of Significance Without Mitigation: Potentially Significant Impact.

Impac
t CUL‐3: The
project could disturb human remains, including those interred outside of formal cemeteries.

Mitiga
tion Measure CUL‐3 In
the event that human remains are unearthed during excavation and grading activities of any future development project, all activity shall cease immediately. Pursuant to Health and Safety Code (HSC) Section 7050.5, no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to Public Resources Code (PRC) Section 5097.98(a). If the remains are determined to be of Native American descent, the coroner shall within 24 hours notify the Native American Heritage Commission (NAHC). The NAHC shall then contact the most likely descendent of the deceased Native 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)

4.3-26
American, who shall then serve as the consultant on how to proceed with the remains. Pursuant to PRC Section 5097.98(b), upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the MLDs regarding their recommendations, if applicable, taking into account the possibility of multiple human remains. The landowner shall discuss and confer with the descendants all reasonable options regarding the descendants' preferences for treatment.

Level of Significance With Mitigation: Less Than Significant Impact Compliance with Mitigation Measure CUL-3 would ensure that implementation of the Specific Plan would not disturb human remains, including those interred outside of formal cemeteries, and the impact would be less than significant.

CUL‐4 Th
e project could result a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Sections, 21074, 5020.1(k), or 5024.1.

As pre
viously described in Section 4.3.2.2, a TCR is defined as a site, feature, place, cultural landscape (must be geographically defined in terms of size and scope), sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register, or included in a local register of historical resources, or if the City of Fresno, acting as the lead agency, supported by substantial evidence, chooses at its discretion to treat the resources as a TCR.

On July 15, 2025, compliant with AB 52 and SB 18, the City provided formal notification to interested Native American tribes that may be culturally or traditionally affiliated with the project area and vicinity to conduct consultation. Ten tribes were formally notified regarding AB 52 consultation and SB 18 consultation. A letter to the NAHC was sent by City staff requesting a sacred lands search. The NAHC identified that there were no known sacred lands that were located within the Specific Plan Area; however, the NAHC provided a list of 10 Native American tribes to consult, including:
• Amah Mutsun Tribal Band
• Kitanemuk & Yowlumne Tejon Indians
• Northern Valley Yokut/Ohlone Tribe
• Picayune Rancheria of the Chukchansi Indians
• Table Mountain Rancheria
• Tule River Indian Tribe
• Wuksachi Indian Tribe/Eschom Valley Band
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)

4.3-27
The City sent letters to each of the tribes in July 2025. Appendix J includes the Native American consultation information.

As discussed under impact discussions CUL-1a, CUL-1b, CUL-2, and CUL-3, impacts from future development within the Specific Plan Area could impact unknown archaeological resources including Native American artifacts and human remains. Impacts would be reduced to a less than significant level with implementation of Mitigation Measures CUL-1a, CUL-1b, CUL-2, and CUL-3.

Therefore, compliance with existing federal, State, and local laws and regulations, would protect unrecorded TCRs on the project site by providing for the early detection of potential conflicts between implementation of the proposed project and resource protection, and by preventing or minimizing the material impairment of the ability of archaeological deposits to convey their significance through excavation or preservation.

Level of Significance Without Mitigation: Potentially Significant Impact Impact CUL‐4: Implementation of the proposed project would have the potential to impact TCRs, the disturbance of which could result in a significant impact under CEQA.

Mitiga
tion Measures: Refer to Mitigation Measures CUL-1a, CU
L-1b, CUL-2, a
nd CUL-3.

Level
of Significance With Mitigation: Less Than Significant Impact Compliance with Mitigation Measures CUL-1a, CUL-1b, CUL-2, and CUL-3 would ensure that implementation of the Specific Plan Update would not have the potential to impact TCRs, the disturbance of which could result in a significant impact under CEQA, and impacts associated with the proposed project would be less than significant.

4.3.5.2 Cumulative Impacts
CUL‐5 Th
e project, in combination with past, present, and reasonably foreseeable projects, could result in significant cumulative impacts with respect to cultural resources.

The pr
oposed project would have a significant effect on the environment if it, in combination with other projects, would contribute to a significant cumulative impact related to cultural resources. The study area for the analysis of cumulative cultural resources includes the Specific Plan Area and the surrounding areas within the City of Fresno, and the analysis is based on the summary of projections approach discussed in Section 15130(b)(1)(B) of the State CEQA Guidelines.

Future development within the Specific Plan Area as well as other cumulative development could result in impacts to known and unknown historical resources. All future development facilitated by the implementation of the Specific Plan Update would similarly require separate environmental review under CEQA to evaluate project-level potential impacts to historical resources and to identify any required mitigation. Implementation of Mitigation Measures CUL-1a, CUL-1b, CUL-2, and CUL-3 would ensure a historical resources assessment is prepared to identify any previously unrecorded historic resources and evaluate impacts of future development on such resources.

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)

4.3-28
Current Federal, State, and local regulations to preserve historical resources, including those discussed in Section 4.3.2, are expected to reduce potential impacts to known resources. While the City could implement all feasible measures to reduce impacts to known historical resources, impacts may remain significant. In addition, construction activities associated with implementation of the proposed project could result in potential significant impacts to unknown buried historical resources. Development both within and outside the Specific Plan Area could result in significant impacts to historical resources. Since implementation of the proposed project could result in significant impacts to historical resources, the project’s contribution to cumulative impacts would be cumulatively considerable and therefore cumulatively significant.

Due to the nominal amount of prehistoric archaeological information in the vicinity of the Specific Plan Area, future development in areas outside the Specific Plan Area as well as other cumulative development, could result in impacts to unknown prehistoric archaeological resources during excavation and/or construction activities. These potential impacts from cumulative development could be significant. Since future development within the Specific Plan Area could result in significant impacts to unknown prehistoric archaeological resources, the project’s contribution to cumulative impacts would be cumulatively considerable and therefore cumulatively significant.

Although no known prehistoric or Native American human remains have been identified within or in the vicinity of the Specific Plan Area, there is a possibility that ground‐disturbing activities associated with cumulative development may uncover previously unknown buried human remains. The uncovering of human remains is considered a significant impact. Since there is a possibility for implementation of the proposed project to uncover previously unknown buried human remains, the project’s contribution to cumulative impacts on human remains would be cumulatively considerable and therefore cumulatively significant.

Level of Significance Without Mitigation: Potentially Significant Impact Impac
t CUL‐5:

Implementation of the Specific Plan Update could result in cumulative impacts to cultural resources.

Mitiga
tion Measures: Refer to Mitigation Measures CUL-1a, CUL-1b, CUL-2, and CUL-3.

Level of Significance with Mitigation: Less Than Significant Impact Compliance with Mitigation Measures CUL-1a, CUL-1b, CUL-2, and CUL-3 would serve to ensure that the impacts associated with the implementation of the Specific Plan Update would reduce cumulative impacts to cultural resources to a less than significant level.

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)

4.4-1

4.4 GREENHOUSE GAS EMISSIONS

4.4.1 Introduction
This section provides a discussion of greenhouse gas emissions (GHG), existing regulations pertaining to GHGs, and an analysis of GHG emissions impacts associated with the construction and operation associated with implementation of the Tower District Specific Plan Update (proposed project or Specific Plan Update) for the City of Fresno (City). This analysis examines the short-te rm
construction and long-term o
perational impacts within the Tower District Specific Plan Area (Specific Plan Area) and evaluates the effectiveness of measures incorporated as part of the Specific Plan Update. 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.

4.4.2 Existing Environmental Setting
The following discussion describes existing GHG emissions in the city of Fresno and the San Joaquin Valley Air Basin (SJVAB), beginning with a discussion of typical GHG types and sources, impacts of global climate changes, and current emission levels.

The study area for project impacts regarding GHG is the Specific Plan Area because potential development under the implementation of the Specific Plan Update is limited to areas where the emissions are generated. It should be noted that GHG impacts are inherently cumulative impacts.

The study area for the analysis of cumulative GHG impacts is the State of California. This analysis will be based on a summary of projections approach as provided in Section 15130(b)(1)(B) of the State CEQA Guidelines. The applicable projections include those provided by the State pursuant to Assembly Bill (AB) 32 and the California Air Resources Board (CARB) Scoping Plan prepared to address AB 32 requirements.

4.4.2.1 Greenhouse Gas Emissions and Global Climate Change The following section provides background information on GHGs and global climate change.

Global Climate Change. Global climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans in recent decades. The Earth’s average near-surface atmospheric temperature rose 0.6 ± 0.2 degrees Celsius (°C) or 1.1 ± 0.4 degrees Fahrenheit (°F) in the 20
th century. The prevailing scientific opinion on climate change is that most of the warming observed over the last 50 years is attributable to human activities. The increased amounts of carbon dioxide (CO2) and other GHGs are the primary causes of the human-induced component of warming.

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)

4.4-2
GHGs are released by the burning of fossil fuels, land clearing, agriculture, and other activities, and lead to an increase in the greenhouse effect.1
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are:
• CO
2 • Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally occurring GHGs (e.g., CO 2, methane, and N2O), some gases (e.g.,
HFCs, PFCs, and SF6) are completely new to the atmosphere.

Certain gases (e.g., water vapor) are short-lived in the atmosphere. Others remain in the atmos- phere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. For the purposes of this air quality analysis, the term “GHGs” will refer collectively to the six gases listed above.

These gases vary considerably in terms of global warming potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The global warming potential is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to carbon dioxide, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO 2 over a specified time period.

GHG emissions are typically measured in terms of pounds or tons of CO2 equivalents (CO2e).

Table 4.4.A shows the GWP for each type of GHG. For example, SF6 is 23,900 times more potent at contributing to global warming than CO2.

1 The temperature on Earth is regulated by a system commonly known as the “greenhouse effect.” Just as the glass in a greenhouse lets heat from sunlight in and reduces the heat escaping, greenhouse gases like carbon dioxide, methane, and nitrous oxide in the atmosphere keep the Earth at a relatively even temperature. Without the greenhouse effect, the Earth would be a frozen globe; thus, although an excess of greenhouse gas results in global warming, the naturally occurring greenhouse effect is necessary to keep our planet at a comfortable temperature.

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)

4.4-3
Table 4.4.A: Global Warming Potential of Greenhouse Gases Gas
Atmospheric Lifetime
(Years)
Global Warming Potential
(100-Year Time Horizon)
Carbon Dioxide 50-200 1
Methane 12 25
Nitrous Oxide 114 310
HFC-23 270 11,700
HFC-134a 14 140
HFC-152a 1.4 140
PFC: Tetrafluoromethane (CF4) 50,000 6,500
PFC: Hexafluoromethane (C2F6) 10,000 9,200
Sulfur Hexafluoride (SF6) 3,200 23,900
Source: Second Update to the Climate Change Scoping Plan: Building on the Framework (CARB 2017b). Website: www.arb.ca.gov/our- work/programs/ab-32-climate-change-scoping-plan/2017-scoping-plan-documents (accessed June 2025).

CARB = California Air Resources Board
HFC = hydrofluorocarbon
PFC = perfluorocarbon

The following discussion summarizes the characteristics of the six GHGs and black carbon.

Carbon Dioxide. In the atmosphere, carbon generally exists in its oxidized form, as CO2. Natural sources of CO2 include the respiration (i.e., breathing) of humans, animals and plants, volcanic out gassing, decomposition of organic matter, and evaporation from the oceans. Human-caused sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of manmade emissions of CO2 each year. Nevertheless, natural removal processes (e.g., photosynthesis by land- and ocean-dwelling plant species) cannot keep pace with this extra input of manmade CO2, and consequently, the gas is building up in the atmosphere.

In 2021, total annual CO2 accounted for approximately 81.2 percent of California’s overall GHG emissions.2 Transportation is the single largest source of CO2 in California, which is primarily comprised of on-road travel. Electricity production, industrial, and residential sources also make important contributions to CO2 emissions in California.

Methane. CH4 is produced when organic matter decomposes in environments lacking sufficient oxygen. Natural sources include wetlands, termites3, and oceans. Decomposition occurring in landfills accounts for the majority of human-generated CH4 emissions in California and in the United States as a whole. Agricultural processes such as intestinal fermentation, manure management, and rice cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted for approximately 9.8 percent of GHG emissions in California in 2021. 4

2 California Air Resources Board (CARB). 2022b. GHGs Descriptions & Sources in California. Website:
ww2.arb.ca.gov/ghg-descriptions-sources (accessed July 2025). 3 Termites are important decomposers of plant material. During digestion, microbes in their guts break down the plant material, producing methane.
4 California Air Resources Board (CARB). 2022b. Op. cit.

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)

4.4-4
Nitrous Oxide. N2O is produced naturally by a wide variety of biological sources, particularly microbial action in soils and water. Tropical soils and oceans account for the majority of natural source emissions. Nitrous oxide is a product of the reaction that occurs between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human-generated N
2O emissions in California. N2O emissions accounted
for approximately 3.4 percent of GHG emissions in California in 2021.5 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride. HFCs are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol.6 PFCs and SF6 are emitted from various industrial processes, including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; however, the rapid growth in the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF 6 accounted for about 5.6 percent of GHG
emissions in California in 2021.7
Black Carbon. Black carbon is the most strongly light-absorbing component of PM formed by burning fossil fuels such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of PM2.5 and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in the atmosphere, black carbon can absorb one million times more energy than CO2.8 Black carbon contributes to climate change both directly, such as absorbing sunlight, and indirectly, such as affecting cloud formation. However, because black carbon is short-lived in the atmosphere, it can be difficult to quantify its effect on global warming.

Most United States emissions of black carbon come from mobile sources (52 percent), particularly from diesel-fueled vehicles. The other major source of black carbon is open biomass burning, including wildfires, although residential heating and industry also contribute. The California Air Resources Board (CARB) estimates that the annual black carbon emissions in California will be reduced approximately 50 percent below 2013 levels by 2030. 9 5 Termites are important decomposers of plant material. During digestion, microbes in their guts break down the plant material, producing methane.
6 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was designated to protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be responsible for ozone depletion. 7 California Air Resources Board (CARB). 2022b. GHGs Descriptions & Sources in California. Website:
ww2.arb.ca.gov/ghg-descriptions-sources (accessed July 2025). 8 United States Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed July 2025).
9 California Air Resources Board (CARB). 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

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)

4.4-5

4.4.2.2 Emission Inventories
An em
issions inventory that identifies and quantifies the primary human-gener ated sources and
sinks of GHGs is a well-re
cognized and useful tool for addressing climate change. This section summarizes the latest information on global, United States, and California GHG emission inventories.

Glob
al Emissions. Worldwide emissions of GHGs in 2022 were 36.8 billion tons of CO2e.10 United States Emissions. In 2022, the year for which the most recent data are available, the United States emitted about 6,343 million metric tons (MMT) CO2e. Overall, emissions in 2022 increased by 1 percent relative to the 2021 total GHG emissions. This increase in total GHG emissions was driven by fossil fuel combustion due primarily to increased energy use, due inpart to the continued rebound in economic activity after the height of the COVID-19 pandemic. However, GHG emissions in 2022 were 17 percent below those of 2005 levels. Of the five major sectors—residential and commercial, agricultural, industry, transportation, and electricity generation—transportation accounted for the highest amount of GHG emissions in 2022 (approximately 28 percent), with electricity generation second at 25 percent and emissions from industry third at 23 percent. 11 State of California Emissions. The State emitted 381.3 MMT CO2e emissions in 2021, 12.6 MMT CO2e higher than 2020 levels but 23.1 MMT CO2e below the 2019 levels.12 CARB estimates that transportation was the source of 38 percent of the State’s GHG emissions in 2021, which is

7.4 percent higher than the 2020 emissions. This increase was most likely from passenger vehicles whose activity and emissions rebounded after the COVID-19 pandemic. The next largest sources included industrial sources at approximately 19 percent and electricity generation at 16 percent.

The remaining sources of GHG emissions were commercial and residential activities at 10 percent, agriculture at 8 percent, high GWP at 6 percent, and waste at 2 percent. 13 City of Fresno Emissions. The City of Fresno baseline inventory year was 2010. The City has prepared an updated inventory for 2016 that accounts for regulations adopted to that point in time.

Therefore, 2016 provides the best available baseline for the GHG Plan and can be compared directly with State progress to date and targets. Table 4.4.B shows the baseline inventory.

10 International Energy Agency. CO2 Emissions in 2022. Website: https://www.iea.org/reports/co2- emissions-in-2022 (accessed July 2025).
11 United States Environmental Protection Agency (USEPA). 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).
12 California Air Resources Board (CARB). 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). 13 Ibid.

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)

4.4-6
Table 4.4.B: City of Fresno GHG Emissions by Sector for 2016 Sector 2016 (MT CO2e) Percent of Total Emissions
Motor Vehicles 1,520,052 52
Residential Energy 479,371 16
Commercial Energy 524,838 18
Fugitive Emissions 270,130 9
Solid Waste 119,167 4
Industrial Energy 10,055 <1
Agricultural Energy 20 <1
Total 2,923,633 100
Source: International Council for Local Environmental Initiatives (ICLEI) Local Governments for Sustainability, City of Fresno 2016 Inventory Update (City of Fresno 2018).

As shown in Table 4.4.B, motor vehicles were the largest source at approximately 52 percent of the city’s GHG emissions in 2016, followed by commercial and residential energy at 18 and 16 percent, respectively. The remaining sources included fugitive emissions at 9 percent and solid waste sources at 4 percent. Agriculture and industrial energy emissions each account for less than 1 percent of total emissions.

4.4.3 Regulatory Setting

4.4.3.1 Federal Policies and Regulations
The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to regulate CO
2 emissions under the federal Clean Air Act (CAA).

Although there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change, including the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the CAA, finding that seven GHGs (CO 2, CH4, N2O, HFCs,
NF3, PFCs, and SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards.

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

Assembly Bill 1493 (2002). In response to the transportation sector’s significant contribution to California’s CO
2 emissions, Assembly Bill (AB) 1493 was enacted on July 22, 2002. AB 1493 requires the CARB to set GHG emission standards (the Pavley Standards) for passenger vehicles and light duty trucks (and other vehicles whose primary use is noncommercial personal transportation in the State) manufactured in 2009 and all subsequent model years. These standards (starting in model years 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)

4.4-7
2009 to 2016) were approved by the CARB in 2004, but the needed waiver of California Clean Air Act (CCAA) Preemption was not granted by the USEPA until June 30, 2009. The CARB responded by amending its original regulation, now referred to as Low Emission Vehicle III, to take effect for model years starting in 2017 to 2025. The Trump administration revoked California’s waiver in 2019; however, the Biden administration restored California’s waiver in 2021.

Executive Order S-3-05 (2005). Governor Arnold Schwarzenegger signed Executive Order (EO) S-3-05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate change. To combat those concerns, the executive order established California’s GHG emissions reduction targets, which established the following goals:
• GHG emissions should be reduced to 2000 levels by 2010; • GHG emissions should be reduced to 1990 levels by 2020; and • GHG emissions should be reduced to 80 percent below 1990 levels by 2050.

The Secretary of the California Environmental Protection Agency (CalEPA) is required to coordinate efforts of various State agencies in order to collectively and efficiently reduce GHGs. A biannual progress report must be submitted to the Governor and State Legislature disclosing the progress made toward GHG emission reduction targets. In addition, another biannual report must be submitted illustrating the impacts of global warming on California’s water supply, public health, agriculture, the coastline, and forestry, and report possible mitigation and adaptation plans to address these impacts.

The Secretary of CalEPA leads this climate action team (CAT) made up of representatives from State agencies as well as numerous other boards and departments. The CAT members work to coordinate statewide efforts to implement global warming emission reduction programs and the State’s Climate Adaptation Strategy. The CAT is also responsible for reporting on the progress made toward meeting the statewide GHG targets that were established in the executive order and further defined under AB 32, the “Global Warming Solutions Act of 2006.” The first CAT Report to the Governor and the Legislature was released in March 2006, which it laid out 46 specific emission reduction strategies for reducing GHG emissions and reaching the targets established in the executive order.

The most recent report was released in December 2020.

Assembly Bill 32 (2006), California Global Warming Solutions Act. California’s major initiative for reducing GHG emissions is AB 32, passed by the State legislature on August 31, 2006. This effort aims at reducing GHG emissions to 1990 levels by 2020. The CARB has established the level of GHG emissions in 1990 at 427 MMT CO
2e. The emissions target of 427 MMT CO2e requires the reduction of 169 MMT CO2e from the State’s projected business-as-usual (BAU) 2020 emissions of 596 MMT CO2e. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. The Scoping Plan was approved by the CARB on December 11, 2008, and contains the main strategies California will implement to achieve the reduction goals and includes CARB-recommended GHG reductions for each emissions sector of the State’s GHG inventory.

The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission 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)

4.4-8
reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020, and also sets the groundwork to reach long-term goals set forth in EOs S-3-05 and B-16-2012. The update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use.

CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, 14 to reflect the 2030
target set by EO B-30-15 and codified by Senate Bill (SB) 32.

The 2022 Scoping Plan15 was approved in December 2022 and assesses progress towards achieving the SB 32 2030 target and lay out a path to achieve carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

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 all new passenger vehicles sold in California to be zero-emission by 2035, all other existing fleets will need to be transitioned to zero-emission as fully possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.

Senate Bill 97 (2007). SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of 2007; PRC Sections 21083.05 and 21097), acknowledges climate change is a prominent environmental issue that requires analysis under the California Environmental Quality Act (CEQA). This bill directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the California Resources Agency guidelines for mitigating GHG emissions or the effects of GHG emissions, as required by CEQA.

The California Natural Resources Agency adopted the amendments to the State CEQA Guidelines in November 2018, which went into effect in December 2018. The amendments do not identify a threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitigation measures. The amendments encourage lead agencies to consider many factors in performing a CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making their own determinations based on substantial evidence. The amendments also encourage public

14 California Air Resources Board (CARB). 2017a. California’s 2017 Climate Change Scoping Plan. November. 15 California Air Resources Board (CARB). 2022a. 2022 Scoping Plan Update. May 10. Website: https://ww2. arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf (accessed July 2025).

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)

4.4-9
agencies to make use of programmatic mitigation plans and programs when they perform individual project analyses.

Senate Bill 375 (2008). Signed into law on October 1, 2008, SB 375 supplements GHG reductions from new vehicle technology and fuel standards with reductions from more efficient land use patterns and improved transportation. Under the law, CARB-approved GHG reduction targets in February 2011 for California’s 18 federally designated regional planning bodies, known as Metropolitan Planning Organizations (MPOs). CARB may update the targets every 4 years and must update them every 8 years. MPOs, in turn, must demonstrate how their plans, policies, and transportation investments meet the targets set by CARB through Sustainable Community Strategies (SCSs). The SCSs are included with the Regional Transportation Plan (RTP), a report required by State law. However, if an MPO finds that its SCS will not meet the GHG reduction targets, it may prepare an Alternative Planning Strategy. The Alternative Planning Strategy identifies the impediments to achieving the targets.

Senate Bill 743 (Steinberg, 2013). SB 743, which was signed into law in 2013, initiated an update to the CEQA Guidelines to change how lead agencies evaluate transportation impacts under CEQA, with the goal of better measuring the actual transportation-related environmental impacts of any given project. Starting on July 1, 2020, agencies analyzing the transportation impacts of new projects must now look at a metric known as vehicle miles traveled (VMT) instead of LOS. The goal of SB 743 is to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations.

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

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

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

The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission (CPUC) for the private utilities and by the California Energy Commission (CEC) for municipal utilities. Each utility must submit a procurement plan showing it will purchase clean 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)

4.4-10
energy to displace other non-renewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law. The addition made by this legislation requires State energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197. In summer 2016, the Legislature passed, and the Governor signed, SB 32, and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an Intergovernmental Panel on Climate Change (IPCC) analysis of the emissions trajectory that would stabilize atmospheric GHG concentrations at 450 parts per million CO 2e and reduce the likelihood of
catastrophic impacts from climate change.

The companion bill to SB 32, AB 197, provides additional direction to CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

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

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

Executive Order B-55-18. EO B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs CARB to work with relevant State agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO 2e from the atmosphere, including
through sequestration in forests, soils, and other natural landscapes.

Title 24, Part 11, Building Standards Code and CALGreen Code. In November 2008, the California Building Standards Code established the California Green Building Standards Code (CALGreen Code), which sets performance standards for residential and non-residential development to reduce environmental impacts and encourage sustainable construction practices. The CALGreen Code addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The CALGreen Code is updated every 3 years and was most recently updated in 2022 to include new mandatory measures for residential as well as non-residential uses; the new measures took effect on January 1, 2023. Energy efficient buildings require less electricity; 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)

4.4-11
therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

Title 24, Part 6, California Building Efficiency Standards. The California Building Standards Code, or Title 24 of the California Code of Regulations (CCR) contains the regulations that govern the construction of buildings in California. Part 6 is California’s Energy Efficiency Standards for Residential and Non-Residential Buildings. These standards were first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption and are updated on an approximately 3-year cycle to allow consideration and possible incorporation of new energy efficient technologies and methods. All buildings for which an application for a building permit is submitted on or after January 1, 2023, must follow the 2022 standards. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

Executive Order N-79-20, Executive Order B-48-18, Low Carbon Fuel Standard and the Advanced Clean Cars Program. EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible. EO B-48-18 requires all State entities to work with the private sector to have at least 5 million zero-emission vehicles (ZEVs) on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle (EV) charging stations by 2025. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. EO S-01-07 calls for a statewide goal to be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020, and that a Low Carbon Fuel Standard (LCFS) for transportation fuels be established for California. In 2018, CARB approved amendments to the LCFS regulation to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32. These amendments include opportunities to promote ZEV adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector. Furthermore, CARB adopted the Advanced Clean Cars program, which combines the control of GHG emissions and criteria air pollutants, as well as requirements for greater numbers of ZEVs, into a single package of regulatory standards for vehicle model years 2017 through 2025. The program’s ZEVs regulation requires battery, fuel cell, and/or plug-in hybrid electric vehicles to account for up to 15 percent of California’s new vehicle sales by 2025.

California Integrated Waste Management Act. To minimize the amount of solid waste that must be disposed of in landfills, the State Legislature passed the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990. According to AB 939, all cities and counties were required to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. In 2011, AB 341 modified the California Integrated Waste Management Act and directed the California Department of Resources Recycling and Recovery (CalRecycle) to develop and adopt regulations for mandatory commercial recycling. AB 341 also established a statewide recycling goal of 75 percent; the 50 percent disposal reduction mandate still applies for cities and counties under AB 939. In April 2016, AB 1826 further modified the California 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)

4.4-12
Integrated Waste Management Act, requiring businesses that generate a specified amount of organic waste per week to arrange for recycling services for that organic waste in a specified manner.

4.4.3.3 Regional Policies and Regulations
San Joaquin Valley Air Pollution Control District. Fresno is within the SJVAB, which is under the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). The SJVAPCD has regulatory authority over certain stationary and industrial GHG emission sources and provides voluntary technical guidance on addressing GHGs for other emission sources in a CEQA context.

District initiatives related to GHGs are described below.

Climate Change Action Plan. The San Joaquin Valley Air Pollution Control District Climate Change Action Plan (CCAP) was adopted on August 21, 2008. The CCAP includes suggested best performance standards 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 2019 CALGreen Code) and the 2030 GHG targets, established in SB 32.

San Joaquin Valley Carbon Exchange and Rule 2301. The SJVAPCD initiated work on the San Joaquin Valley Carbon Exchange in November 2008. The carbon exchange was implemented with the adoption of Amendments to Rule 2301 Emission Reduction Credit Banking on January 19, 2012. The purpose of the carbon exchange is to quantify, verify, and track voluntary GHG emissions reductions generated within the San Joaquin Valley.

The SJVAPCD incorporated a method to register voluntary GHG emission reductions with amendments to Rule 2301. The purposes of the amendments to the rule include the following:
• Provide an administrative mechanism for sources to bank voluntary GHG emission reductions for later use.
• Provide an administrative mechanism for sources to transfer banked GHG emission reductions to others for any use.
• Define eligibility standards, quantitative procedures, and administrative practices to ensure that banked GHG emission reductions are real, permanent, quantifiable, surplus, and enforceable.

The SJVAPCD is participating in a new program developed by the California Air Pollution Control Officers Association (CAPCOA) to encourage banking and use of GHG reduction credits referred to as the CAPCOA Greenhouse Gas Reduction Exchange (GHGRx). The GHGRx provides information on GHG credit projects within participating air districts. The SJVAPCD is one of the first to have offsets available for trading on the GHGRx.

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)

4.4-13
Fresno Council of Governments. Fresno Council of Governments (FCOG) is responsible for regional transportation planning in Fresno County and participates in developing mobile source emission inventories used in air quality attainment plans.

Reg
ional Transportation Plan/Sustainable Communities Strategy. Regional Transportation Plans (RTPs) are State-mandated plans that identify long-term transportation needs for a region’s transportation network. FCOG’s 2022 RTP charts the long-ran ge vision of regional
transportation in Fresno county through the year 2046. The RTP identifies existing and future transportation related needs, while considering all modes of travel, analyzing alternative solutions, and identifying priorities for the anticipated available funding for the 1,100 projects and multiple programs included within it. SB 375, which went into effect in 2009, added statutes to the California Government Code to encourage planning practices that create sustainable communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every 4 years. The SCS is intended to show how integrated land use and transportation planning can lead to lower greenhouse gas emissions from automobiles and light trucks. FCOG has included the SCS in its 2022 RTP.

4.4.3 .4 Local Policies and Regulations
The following is a summary of the applicable policies included in the City’s General Plan that are related to GHGs and applicable to the proposed project.

City of Fresno General Plan. The City of Fresno General Plan provides goals, policies, and action items that work to meet or exceed all current and future state-mandated targets for reducing emissions of GHGs. The following policies from the General Plan would apply to the proposed project:

Mobility and Transportation Element.

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

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

Resource Conservation and Resilience Element.

Objective RC‐2: Promote land uses that conserve resources.

Poli
cy RC-2-a: Li
nk Land Use to Transportation. Promote mixed-use,
higher density infill
development in multi-moda
l corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher
-int
ensity development. Discourage investment in infrastructure that would not meet these criteria.

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)

4.4-14
Policy RC-2-b: Provide Infrastructure for Mixed-Use and Infill. Promote investment in the public infrastructure needed to allow mixed-use
and denser infill development to occur in
targeted locations, such as expanded water and wastewater conveyance systems, complete streetscapes, parks and open space amenities, and trails. Discourage investment in infrastructure that would not meet these criteria.

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

Polic
y RC-4-i: Me
thane Capture. Continue to pursue opportunities to reduce air pollution by using methane gas from the old City landfill and the City’s wastewater treatment process.

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

Pol
icy RC-5-a: S
upport State Goal to Reduce Statewide GHG Emissions. As is consistent with State law, strive to meet AB 32 goal to reduce greenhouse gas emissions to 1990 levels by 2020 and strive to meet a reduction of 80 percent below 1990 levels by 2050 as stated in Executive Order S-03-05
. As new statewide GHG reduction targets and dates are set by the State update the City’s Greenhouse Gas Reduction Plan to include a comprehensive strategy to achieve consistency with those targets by the dates established.

Polic
y RC-5-b:

Greenhouse Gas Reduction Plan. As is consistent with State law, prepare and adopt a Greenhouse Gas Reduction Plan as part of the Master Environmental Impact Report to be concurrently Draft with the Fresno Specific Plan in order to achieve compliance with State mandates, assist development by streamlining the approval process, and focus on feasible actions the City can take to minimize the adverse impacts of growth and development on global climate change. The Greenhouse Gas Reduction Plan shall include, but not be limited to:
• A base
line inventory of all known or reasonably discoverable sources of GHGs that currently exist in the city and sources that existed in 1990. • A projected inventory of the GHGs that can reasonably be expected to be emitted from those sources in the year 2035 with implementation of this Specific Plan and foreseeable communitywide and municipal operations.
• A target for the reduction of emissions from those identified sources. • A list of feasible GHG reduction measures to meet the reduction target, including energy conservation and “green building” requirements in municipal buildings and private development.

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)

4.4-15
• Periodically update municipal and community-wide GHG emissions inventories to determine the efficacy of adopted measures and to guide future policy formulation needed to achieve and maintain GHG emissions reduction targets.

Polic
y RC-5-c:

GHG Reduction through Design and Operations. Increase efforts to incorporate requirements for GHG emission reductions in land use entitlement decisions, facility design, and operational measures subject to City regulation through the following measures and strategies:
• Pro
mote the expansion of incentive-bas
ed programs that involve certification of
projects for energy and water efficiency and resiliency. These certification programs and scoring systems may include public agency “Green” and conservation criteria, Energy Star™ certification, CALGreen Tier 1 or Tier 2, Leadership in Energy Efficient Design (LEED™) certification, etc.
• Pro
mote appropriate energy and water conservation standards and facilitate mixed-use

projects, new incentives for infill development, and the incorporation of mass transit, bicycle and pedestrian amenities into public and private projects. • Requ
ire energy and water audits and upgrades for water conservation, energy efficiency, and mass transit, pedestrian, and bicycle amenities at the time of renovation, change in use, change in occupancy, and change in ownership for major projects meeting review thresholds specified in an implementing ordinance. • Inco
rporate the City’s “Guidelines for Ponding Basin/Pond Construction and Management to Control Mosquito Breeding” as conditions of approval for any project using an on
-si
te stormwater basin to prevent possible increases in vector-bor ne illnesses
associated with global climate change.
• Per
iodically evaluate the City’s facility maintenance practices to determine whether there are additional opportunities to reduce GHGs through facility cleaning and painting, parks maintenance, road maintenance, and utility system maintenance. • Per
iodically evaluate standards and mitigation strategies for highly vehicle-dep endent
land uses and facilities, such as drive-thro
ugh facilities and auto-or
iented development.

Polic
y RC-5-d:

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

Polic
y RC-5-e:

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

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)

4.4-16
Policy RC-5-f: Toolkit. Provide residents and project applicants with a “toolkit” of generally feasible measures that can be used to reduce GHG emissions, including educational materials on energy-ef
ficient and “climate-fr
iendly” products.

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

Obj
ective RC‐8: Reduce the consumption of non-ren
ewable energy resources by requiring and
encouraging conservation measures and the use of alternative energy sources.

Polic
y RC-8-a:

Existing Standards and Programs. Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations.

Polic
y RC-8-b:

Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and non-resi
dential electricity use to 2,700 kWh per year per
capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost
-eff
ective savings.

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

Polic
y RC-8-d:

Incentives. Establish an incentive program for residential developers who commit to building all of their homes to ENERGY STAR performance guidelines.

Polic
y RC-8-e:

Energy Use Disclosure. Promote compliance with State law mandating disclosure of a building’s energy data and rating of the previous year to prospective buyers and lessees of the entire building or lenders financing the entire building.

Polic
y RC-8-f: C
ity Heating and Cooling. Reduce energy use at City facilities by updating heating and cooling equipment and installing “smart lighting” where feasible and economically viable.

Polic
y RC-8-g:

Revolving Energy Fund. Create a City Energy Fund which uses first year savings and rebates from completed City-own
ed energy efficiency projects to provide
resources for additional energy projects. Dedicate this revolving fund to the sole use of energy efficiency projects that will pay back into the fund.

Polic
y RC-8-h:

Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over-the-count er permitting for solar
installations meeting specified standards, which may include maximum size (in kV) of units that can be so Draft.

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)

4.4-17
Policy RC-8-j: Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

Pol
icy RC-8-k: E
nergy Efficiency Education. Provide long-term
and on-goin
g education of
homeowners and businesses as to the value of energy efficiency and the need to upgrade existing structures on the regular basis as technology improves and structures age.

Polic
y RC-11-a:

Waste Reduction Strategies. Maintain current targets for recycling and re- use o
f all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
• Cont
inue to require recyclable material collection and storage areas in all residential development.
• Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated.
• Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste.
• Provide recycling canisters and collection in public areas where trash cans are also provided.
• Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations.
• Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMAX (California Materials Exchange) program.
• Evaluate the feasibility of a residential, restaurant, and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material. • Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs.
• Expand yard waste collection to divert compostable waste from landfills. • Study t
he feasibility and cost-bene
fit analysis of a municipal composting program to
collect and compost food and yard waste, including institutional food and yard waste, using the resulting compost matter for City park and median maintenance.

Fresno City CouncilNovember 20, 2025

Fresno City Council
November 20, 2025