Exhibit D - Resolution Certifying SEDA EIR — Fresno City Council, December 18, 2025 (part 12 of 23)

City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Draft Program EIR
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4.2 - Growth-inducing Impacts
There are two types of growth-inducing impacts that a project may have: direct and indirect. To assess the potential for growth-inducing impacts, the project’s characteristics that may encourage and facilitate activities that individually or cumulatively may affect the environment must be evaluated (CEQA Guidelines § 15126.2(e)). CEQA Guidelines, as interpreted by the City, state that a significant growth-inducing impact may result if the project would:
• Induce substantial population growth in an area (for example, by proposing new homes and commercial or industrial businesses beyond the land use density/intensity envisioned in the general plan);
• Substantially alter the planned location, distribution, density, or growth rate of the population of an area; or
• Include extensions of roads or other infrastructure not assumed in the general plan or adopted capital improvements project list, when such infrastructure exceeds the needs of the project and could accommodate future developments.

Direct growth-inducing impacts occur when the development of a project imposes new burdens on a community by directly inducing unplanned population growth, or by leading to the construction of additional developments in the same area. Also included in this category are projects that remove physical obstacles to population growth (such as a new road into an undeveloped area or a wastewater treatment plant with excess capacity that could allow additional development in the service area). Construction of these types of infrastructure projects cannot be considered isolated from the development they facilitate and serve. Projects that physically remove obstacles to growth, or projects that indirectly induce growth may provide a catalyst for future unrelated development in an area such as a new residential community that requires additional commercial uses to support residents.

As discussed in Chapter 2, Project Description, buildout of the proposed project could generate up to approximately 45,000 homes and 37,000 jobs as well as 1,820 acres of employment-generating land uses such as office, research and development, and institutional uses by the year 2050. Based on the average household size in the City of 2.99 persons per household, this anticipated future development could accommodate up to 134,550 residents. The population potential for the Plan Area is within the population growth anticipated by the General Plan, which anticipates growth of up to 226,000 additional residents by 2035, consistent with the proposed project. Accordingly, implementation of the proposed project would not exceed the City’s anticipated population growth.

According to the General Plan, the City projects that the total additional residential development capacity by the General Plan’s horizon in 2035 would be approximately 76,000 additional dwelling units and by the General Plan’s buildout in 2050 would be approximately 145,000 additional dwelling City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Other CEQA Considerations
FirstCarbon Solutions 4-7 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec04-00 Other CEQA.docx units between both the infill and growth areas.1 These values constitute the planned growth anticipated by the City for residential units within its SOI. As the proposed project would generate approximately 45,000 new dwelling units by 2050, approximately 31 percent of the total planned capacity for the City, full buildout of the proposed project would be considered planned growth providing housing to meet the demand for new residential units, and would not be considered growth inducing.

4.3 - Mandatory Findings of Significance
Public Resources Code Section 21083 requires lead agencies to make a finding of a “significant effect on the environment” if one or more of the following conditions exist:
1) A proposed project has the potential to degrade the quality of environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife species to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare, or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory. 2) The possible effects of a project are individually limited but cumulatively considerable. 3) The environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.

Finding No. 1: Less than significant with mitigation incorporated.

Based on the analysis provided in Section 3.4, Biological Resources, the proposed project’s impacts related to special-status species and special-status natural communities and habitat would be less than significant with mitigation incorporated. Additionally, the proposed project’s impacts on riparian habitat, a special-status species associated with riparian or wetlands habitats, as well as federally protected wetlands, and wildlife corridors would be less than significant with mitigation incorporated. Therefore, implementation of General Plan PEIR MM BIO-1.1 through MM BIO-1.4 would reduce impacts on special-status species. General Plan PEIR MM BIO-2.1 through MM BIO-2.3 would reduce impacts to sensitive natural communities or riparian habitats. Implementation of General Plan PEIR MM BIO-3.1 and MM BIO-3.2 would reduce impacts to wetlands and jurisdictional features.

With implementation of General Plan PEIR MM BIO-1.1, MM BIO-1.2, MM BIO-1.3, MM BIO-1.4, MM BIO-2.1, MM BIO-2.2, MM BIO-2.3, MM BIO-3.1, and MM BIO-3.2, the proposed project would not substantially degrade the quality of the environment, reduce fish or wildlife habitat, reduce fish or wildlife populations below self-sustaining levels, eliminate a plant or animal community, or reduce the number or range of a rare or endangered plant or animal. 1 City of Fresno. 2014. General Plan, Table 1-2, Residential Development Capacity Under Horizon and Buildout, and Table 1-3, Residential Development Capacity Under General Plan Horizon. Website: https://cityoffresno.wpenginepowered.com/darm/wpcontent/uploads/sites/10/2022/12/upload_temp_Consolidated-GP-10-13-2022.pdf. Accessed January 20, 2023.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Draft Program EIR
4-8 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec04-00 Other CEQA.docx Based on the analysis provided in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to California history or prehistory would be less than significant with mitigation incorporated. Implementation of General Plan PEIR MM CUL-1.1 and MM CUL-1.2 would reduce impacts to historical, cultural resources, or tribal cultural resources encountered during ground-breaking activities. General Plan PEIR MM CUL-2 would reduce impacts to prehistoric resources encountered during excavation and/or construction activities. Implementation of General Plan PEIR MM CUL-3 would reduce impacts to human remains that could be unearthed during excavation or grading activities.

With implementation of General Plan PEIR MM CUL-1.1, MM CUL-1.2, MM CUL-2, and MM CUL-3, the proposed project would not substantially degrade the quality of the environment or eliminate important examples of the major periods of California history or prehistory.

Based on the discussion provided above, compliance with required guidelines and statutes and implementation of the mitigation measures, the project would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. Therefore, impacts would be less than significant with incorporation of General Plan PEIR MM BIO-1.1, MM BIO-1.2, MM BIO-1.3, MM BIO-1.4, MM BIO-2.1, MM BIO-2.2, MM BIO-2.3, MM BIO-3.1, MM BIO-3.2, MM CUL-1.1, MM CUL-1.2, MM CUL-2, and MM CUL-3.

Finding No. 2: Significant and unavoidable.

The analysis presented in this Draft PEIR includes a review of proposed project's potential impacts related to air quality, biological resources, cultural resources, noise, and transportation, among other environmental issue areas. As presented throughout this PEIR, the proposed project’s cumulative impacts would either be significant and unavoidable, less than significant with mitigation incorporated, less than significant, or there would be no impacts.

The proposed project is a document that provides a vision for growth and development in the SEDA over the next 20 to 30 years. This long-range planning document addresses a wide range of topics including affordable housing, jobs and economic development, transportation, parks and open space, and a healthy environment. As the proposed project is a policy-level document, it does not include any specific development proposals. The Specific Plan proposes changing land use designations for some of the Plan Area’s parcels, which would require an amendment to the General Plan Land Use map.

There would be less than significant cumulative impacts with regard to biological resources, cultural and tribal-cultural resources, energy, hazards and hazardous materials, land use and planning, mineral resources, population and housing, and public services. Mitigation measures to further reduce impacts related to these environmental impacts are MM HAZ-2a, MM HAZ-2b, MM HAZ-2c, MM HAZ-2e, MM HAZ-2f, MM HAZ-2g, and MM HAZ-2h.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Other CEQA Considerations
FirstCarbon Solutions 4-9 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec04-00 Other CEQA.docx Potentially significant impacts related to geology and soils, hydrology and water quality, recreation, transportation, and utilities would be mitigated to less than significant levels with the implementation of MM GEO-6.1, MM GEO-1, MM HYD-2a, MM HYD-2b, MM HYD-2c, MM HYD-2d, MM HYD-3a, MM HYD-3b, MM HYD-3c, MM REC-1, MM TRANS-1a, MM TRANS-1b, MM TRANS-1c, MM TRANS-1d, MM TRANS-1e, MM TRANS-4, MM UTIL-1a, MM UTIL-1b, MM UTIL-1c, MM UTIL-1d, MM UTIL-1e, MM UTIL-1f, MM UTIL-2a, MM UTIL-2b, MM UTIL-2c, and MM UTIL-4.1.

Significant and unavoidable impacts would occur related to aesthetics, agricultural resources, air quality, GHG emissions, noise, and geology. While implementation of MM AES-1, MM AES-2, MM AES-3, MM AES-4, MM AES-5, MM AG-1.1, MM AG-2, MM AIR-1a, MM AIR-1b, MM AIR-1c, MM AIR1d, MM AIR-1e, MM AIR-1f, MM NOI-1a, MM NOI-1b, MM NOI-2, MM NOI-3, and MM NOI-4 would reduce impacts to these topical sections, there is no feasible mitigation available that would fully bring these impacts to less than significant levels.

Overall, with implementation of the applicable General Plan PEIR and Project Specific mitigation measures, impacts associated with the proposed project would remain significant and unavoidable for aesthetics, agricultural resources, air quality, GHG emissions, noise, and geology and soils. The implementation of other projects in the City would be required to demonstrate regulatory compliance and implement similar mitigation measures, as applicable. Therefore, the proposed project would have some impacts that are individually limited, but cumulatively considerable.

Finding No. 3: Less than significant.

Compliance with and implementation of General Plan PEIR Mitigation Measures, project specific mitigation measures, existing regulations, and the City’s standard permit conditions would ensure that the proposed project, and future development consistent with the proposed project, would not result in substantial adverse effects on human beings, including effects related to air pollution, seismic and geologic hazards, hazardous materials, flooding and natural disasters, or noise and vibration. Therefore, impacts associated with the proposed project would be less than significant.

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx CHAPTER 5: ALTERNATIVES TO THE PROPOSED PROJECT

5.1 - Introduction
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this Draft Program Environmental Impact Report (Draft PEIR) contains a comparative impact assessment of alternatives to the proposed project. The primary purpose of this section is to provide decision makers and the general public with a reasonable number of feasible project alternatives that could attain most of the basic project objectives, while avoiding or reducing any of the project’s significant adverse environmental effects. Important considerations for these alternatives analyses are noted below (as stated in CEQA Guidelines § 15126.6).
• An EIR need not consider every conceivable alternative to a project; • An EIR should identify alternatives that were considered by the lead agency, but rejected as infeasible during the scoping process;
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives; - Infeasibility; or
- Inability to avoid significant environmental effects.

5.1.1 - Significant Unavoidable Impacts
The proposed project would result in the following significant unavoidable impacts:

Impact AES-3 Project-level Visual Character: The proposed project would, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). Buildout of the Fresno Southeast Development Area (SEDA) Specific Plan (Specific Plan) would alter the existing visual character by increasing the intensity of development in many areas that are primarily agriculture.

No feasible mitigation measures are available to mitigate the impact to a less than significant level.

Impact AES-4 Project-level Light and Glare: The proposed project would create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Intensified development in the SEDA Specific Plan Area (Plan Area) could increase the amount of light from streetlights, exterior lighting from buildings, and vehicle headlights. The increase in lighting within the Plan Area could result in light spillover onto adjacent areas and could substantially illuminate the sky during nighttime. This increase in illumination is considered a significant impact.

Implementation of Mitigation Measures (MM) AES-4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project by requiring City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx shields, low-intensity fixtures, requirements for signs, and non-reflective materials.

However, impacts would remain significant and unavoidable.

Cumulative Aesthetics, Lights, and Glare Impacts: Implementation of the proposed project would increase intensify development of structures, which would create new sources of light and glare within the Plan Area and adjacent to the Plan Area. These new sources of glare could result from materials used on building façades, parking lots, signs, roadway surfaces, and motor vehicles. This increase in glare could result in cumulatively considerable significant glare impacts and illumination of the nighttime sky. Additionally, implementation of MM AES-4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project. However, impacts would remain significant and unavoidable.

Impact AG-1 Project-level Conversion of Farmland to Nonagricultural Uses: There are approximately 2,475 acres of land designated as Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and approximately 1,725 acres of land designated as Unique Farmland scattered throughout the Plan Area. Through its open space framework and land use objectives and policies, the Specific Plan would allow flexibility in the location, form, and function of diverse agricultural types within communities and would establish a buffer between the urban area of the City of Fresno (City) and the surrounding agricultural land. Consistent with Policy RC-9-c, the Fresno General Plan (General Plan) Program Environmental Impact Report (PEIR) includes MM AG-1.1, which requires the development of a Farmland Preservation Program (FPP). The intent of the FPP would be that, when Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would be proposed for development and converted to urban uses within the Sphere of Influence (SOI) outside City limits, this program would require that the developer mitigate the loss of farmland. However, because the FPP has not yet been developed, the proposed project would implement project-specific MM AG-2, which requires all future development to mitigate the loss of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, on a project-by-project basis before the initiation of construction or ground-disturbing activities. However, while implementation of MM AG-2 would reduce some project specific impacts, loss of Prime Farmland would still occur with implementation of the proposed project. Therefore, this impact would be significant and unavoidable even with implementation of available mitigation.

Impact AG-2 Project-level Conflict with Existing Zoning or Williamson Act Contract: According to the General Plan, the City and its SOI includes lands under a Williamson Act Contract for prime and non-prime agricultural land. According to the Williamson Act property map, the majority of Williamson Act properties within the City and SOI are located within the Plan Area. Therefore, the continued implementation of the approved General Plan and the proposed Specific Plan could conflict with existing Williamson Act Contracts because nonagricultural uses are allowed on the land under a Williamson Act Contract. As a result, the continued implementation of the General City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Plan and proposed Specific Plan could result in a significant impact on existing Williamson Act Contract land. While Objective CF-1 and Policy CF-1.3 included in the Specific Plan would strongly discourage the conversion of strategic farmland, and thereby help to preserve agriculture in the Plan Area and implementation of the FPP when established through General Plan PEIR MM AG-1.1 as a condition of approval, buildout of the proposed project would still result in the conversion of Williamson Act land to nonagricultural uses. Therefore, this impact would be significant and unavoidable without any available mitigation.

Cumulative Agricultural Resources and Forestry Resources Impacts: Although the proposed project would promote small farms, community gardens, and farmer’s markets, as well as include a farmland buffer that helps transition new development to agricultural land outside of the SOI, future development in areas outside of the Plan Area, in combination of the loss of prime farmland within the Plan Area, would result in the conversion of farmland to non-agriculture uses. Therefore, the implementation of the proposed project would result in a significant and unavoidable impact on agricultural zoning and Williamson Act Contracts. The proposed project includes land use changes that would result in the conversion of farmland to non-agriculture uses, and no feasible mitigation measures are available.

Therefore, this impact would be significant and unavoidable.

Impact AIR-1 Project-Level Consistency with Air Quality Management Plan: The proposed project has the potential to exceed the San Joaquin Valley Air Pollution Control District (Valley Air District) significance thresholds during construction and operation.

Implementation of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the Valley Air District regional significance thresholds and would therefore not be considered consistent with the existing Air Quality Plans (AQPs). No further measures are available beyond the applicable Valley Air District rules and regulations in addition to the proposed project’s policies and design guidelines. The various goals and policies of the proposed project would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, it would have a significant and unavoidable impact.

Impact AIR-2 Project-level Cumulative Criteria Pollutant Emissions: While adherence to Rule 9510 would contribute to reducing exhaust nitrogen oxide (NOX) emissions, it would not be applicable to reducing volatile organic compound (VOC) emissions generated by operation of equipment and from off-gassing from asphalt and paints.

Additionally, there is potential for multiple projects to be constructed at one time in the Plan Area, resulting in the generation of cumulatively significant amounts of NOX emissions.  Regional emissions generated by the proposed project would exceed applicable thresholds for cumulative criteria pollutant emissions after compliance with all rules, regulations, and mitigation measures during operation. While compliance with the Valley Air District rules and the policies of the proposed Specific City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-4 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Plan may contribute to reducing operation-related regional air quality impacts of individual projects envisioned under the proposed Specific Plan to less than significant levels, the projected cumulative emissions associated with future development projects would be in exceedance of the Valley Air District thresholds.

Therefore, implementation of the proposed project would result in a significant impact because it would significantly contribute to the nonattainment designations of the San Joaquin Valley Air Basin (SJVAB). As such, impacts would be significant and unavoidable.

Impact AIR-3 Project-level Sensitive Receptors Exposure to Pollutant Concentrations:

Compliance with existing regulatory programs, General Plan policies and mitigation measures, and MM AIR-1a through MM AIR-1f would serve to reduce the impacts of the proposed project to the extent feasible. However, the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Further, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds. Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants and result in a significant and unavoidable impact.

Cumulative Air Quality Impacts: While implementation of MM AIR-1a though MM AIR-1f, as well as the applicable General Plan PEIR Mitigation Measures, would serve to reduce criteria air pollutant and TAC emissions generated by the proposed project, there is currently not enough information to quantify emissions of specific project development that may occur under the proposed project. Without quantification to guarantee a less than significant finding, future development projects may still exceed the Valley Air District regional significance thresholds.

Additionally, due to the size of the proposed project, there is not sufficient mitigation available to reduce the potential criteria pollutant emissions associated with the proposed project to levels that would not exceed the Valley Air District thresholds of significance. Therefore, cumulative impacts to air quality would be considered to remain significant and unavoidable.

Impact GHG-1 Project-level Greenhouse Gas Emissions: Implementation of the proposed project would contribute to global climate change through direct greenhouse gas (GHG) emissions from on-site area sources and vehicle trips generated by the proposed City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx project, and indirectly through off-site energy production required for on-site activities, water use, and waste disposal. The operation of the proposed project would generate an increase in population and employment, and would contribute to an increase in wastewater generation, water demand, and vehicle trips. New buildings would be more energy efficient, but there would be an overall increase in energy usage due to the magnitude of new building space that would be constructed. Per the GHG Plan Update guidance, the environmental impact of the proposed project related to GHG emissions is significant, because the Plan Area is currently outside of the City boundaries, and the emissions included in the planning area were not included or considered by the City in the preparation of the GHG Plan Update, which demonstrates that the city would be in compliance with State mandated GHG emission reduction goals. As a result, the proposed project is not consistent with the GHG Plan Update, and the proposed project’s contribution to environmental impacts related to GHG emissions are significant.  The guiding principles, design guidelines, and proposed land use designations for the Plan Area would contribute to minimizing emissions to the extent feasible, however there is no mitigation feasible to reduce the GHG emissions of the proposed project to less than significant levels. Thus, the GHG impacts of the proposed project would be significant and unavoidable.

Cumulative Greenhouse Gas Emissions Impacts: The proposed project would result in an expansion of the City’s boundaries and would contribute to population growth in the region that was not included in the City’s GHG Reduction Plan Update emissions projections, which demonstrate conformity with State GHG reduction goals. The proposed project would generate a significant net increase in GHG emissions and would have a significant GHG impact per the City’s GHG Reduction Plan Update. As the proposed project would have a significant impact per the guidance included in the City’s GHG Reduction Plan Update, the proposed project has a potentially significant level of cumulative significance. There are no feasible mitigation measures available. As such, cumulative impacts with regard to GHG emissions would be significant and unavoidable.

Impact NOI-1 Project-level Construction Noise: Short-term construction noise impacts associated with the proposed project are an increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site and noise generated during site preparation, grading, and construction activities.

With implementation of MM NOI-1a and MM NOI-1b, construction noise impacts due to construction activities would be reduced to the extent feasible. However, given that details of individual development projects in the vicinity of the Plan Area are currently unknown, it is not possible to quantify the construction noise impacts at specific off-site or on-site sensitive receptors. Because these construction activities may occur near noise-sensitive receptors and because noise disturbances may occur for prolonged periods of time, construction noise impacts would remain significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Cumulative Construction Noise: Given that details of individual development projects adjacent to the Plan Area are currently unknown, it is not possible to quantify future cumulative construction noise impacts that could occur if multiple developments were to construct simultaneously, which could constitute a cumulative noise impact. Because construction activities associated with implementation of the Specific Plan could then also occur simultaneously and because noise disturbances could occur for prolonged periods of time, there is the possibility for a cumulative construction noise impacts that would remain significant and unavoidable.

5.1.2 - Alternatives to the Proposed Project
The three alternatives to the proposed project analyzed in this section are as follows:

Alternative 1–No Project Alternative
Under this alternative, the Specific Plan would not be approved, and thus, the proposed Specific Plan policies would not be implemented, and no zoning or land use designation changes would occur in the Plan Area. Additionally, the areas within the Plan Area that are outside of the City’s SOI would not be annexed to the City. Future development in the Plan Area would be developed in accordance with the current land use and zoning maps identified in the General Plan. The buildout of the General Plan includes approximately 17,900 homes and approximately 29,600 jobs in the Plan Area.

Comparatively, the proposed Specific Plan would include approximately 45,000 homes and approximately 37,000 jobs. The existing Plan Area contains the following General Plan designations that would not change under Alternative 1: Residential-Low Density, Residential-Medium Density, Residential-Urban Neighborhood, Employment-Mixed Use, Employment-Office, Public Facilities, Open Space, and Buffer.

Alternative 2–Consolidated Business Park Alternative
Under the Consolidated Business Park Alternative, the Specific Plan would be developed as described in this Draft PEIR, except that this alternative would maintain the existing Research and Development land designations from the General Plan for the area south of Jensen Avenue. It would accommodate approximately 42,900 homes and approximately 36,000 jobs within the 9,000-acre planning area. The area identified in the Specific Plan as Flexible Research and Development to the east of Temperance Avenue and north of Jensen Avenue would be developed as Neighborhood Residential and Mixed Residential with two community centers and five neighborhood centers.

Additionally, this alternative would change the land use designations for the planned Mixed Residential and Neighborhood Residential, along with the Community and Neighborhood Centers south of Jensen Avenue. Under the Consolidated Business Park Alternative, that area would be designated as Flexible Research and Development and Offices. Please refer to Exhibit 5-1 for a visual representation of this alternative.

Alternative 3–Farmland Conservation Alternative
Under the Farmland Conservation Alternative, buildout of the Specific Plan would occur as proposed in this Draft PEIR; however, under this alternative, specific parcels of farmland located within the City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Plan Area would be desingated for conservation. No future development would be permitted on farmland designated for conservation. Under the proposed project, buildout of the Specific Plan would include a farmland buffer along the east side of the Plan Area. Under the proposed project this area is designated as Rural Cluster Residential which allows specific residential development to be developed on the important farmlands. However, under this alternative, farmland located within the portions of the Plan Area designated as Rural Cluster Residential would be conserved, disallowing development on identified Prime, Unique, and Statewide Importance Farmland within this portion of Plan Area. It would be compatible with the uses of the surrounding land since the farmland preserved will also be rural in nature. Please refer to Exhibit 5-2 for a visual representation of this alternative.

The three alternatives to the proposed project are analyzed below. These analyses compare the proposed project and each individual project alternative. In several cases, the description of the impact may be the same under each alternative when compared with the CEQA Thresholds of Significance (i.e., both the project and the alternative would result in a less than significant impact).

The actual degree of impact may be slightly different between the proposed project and each alternative, and this relative difference is the basis for a conclusion of greater or lesser impacts.

5.2 - Project Objectives
As stated in Chapter 2, Project Description, the objectives of the proposed project are to:

Quantified Objectives
• Accommodate between 40,000 and 45,000 dwelling units of varying types, sizes, densities, and affordability levels.
• Accommodate between 30,000 and 37,000 jobs.

Fiscal Responsibility
• Provide self-financing for the development and ongoing maintenance of the SEDA that does not reduce City of Fresno resources dedicated to other areas of the City or burden Fresno residents outside of the SEDA.
• Holistically coordinate infrastructure to integrate efficiencies that piecemeal planning cannot. • Invest in resource conserving techniques for stormwater systems, water supply, and trail and open space networks to save on infrastructure and mitigation costs.

Social Equity
• Promote health by reducing harmful emissions from cars and industry. • Foster healthy physical activity and community interaction by providing easy, safe walking and bicycle access to parks, schools, and retail centers.
• Sustain the diversity of Fresno’s population by providing a wide variety of housing choices and business opportunities.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx • Respect the major economic and cultural role of agriculture in the Central Valley by accommodating growth within the confines of a smaller urban footprint and directly integrating community-scale agriculture into the design of community centers, neighborhoods, and open spaces.

Environmental Sustainability
• Emphasize the efficient use of energy, water, and other resources in SEDA design and policies.

Strive to produce a self-mitigating plan that deeply reduces the environmental impacts of growth and can sustain and even serve to improve or repair natural systems. • Reduce energy and water consumption through more efficient land use patterns, smarter building standards, and environmentally sensitive infrastructure to help Fresno meet standards for greenhouse gas emissions, and well as air pollution and water quality.

Housing Choice
• Offer a variety of housing choices to a mix of incomes, age groups, and lifestyles. • Ensure new housing units are affordable to households with varying levels of income through covenants and deed-restrictions or other affordability mechanisms.

High Quality Transit Service
• Provide convenient and frequent transit service to connect SEDA’s town centers to jobs and housing inside the Plan Area and across the region.

Walkable Neighborhoods
• Provide for nearly all homes to be located within walking distance of a Neighborhood Town Center with an elementary school, recreation areas, community gardens, and small shops.

Parks, Open Space, and Trails
• Create a variety of natural open spaces and parks for recreation in all areas of the SEDA. • Create trail systems and bicycle paths that make traveling without a car safe and convenient. • Ensure that schools and major town centers can be reached safely with or without a car.

Mixed Use Town Centers
• Mix shopping, housing, and jobs in vibrant Regional Town Centers and Community Town Centers that are easily accessible to most residents via a short walk, bike ride, drive, or transit trip.

Innovative Employment Areas
• Attract opportunities in green technology and energy systems, ag-related industries, modular housing, and other emerging fields to provide jobs for Fresno residents.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Community Farming and Agriculture
• Integrate small farms, community gardens, and farmers’ markets into neighborhoods, schools, and town centers.
• Create a buffer that includes rural homes, organic farming, and open spaces to serve as a transition between the SEDA and commercial agriculture to the east.

Implementation
• Develop the SEDA in an organized and phased manner based on housing needs, infrastructure availability, and minimization of impacts.
• Ensure amenities and infrastructure provision for each new phase prior to commencement of construction.

5.3 - Alternative 1—No Project Alternative
CEQA Guidelines Section 15126.6(e) requires an EIR to evaluate a ‘No Project Alternative,’ which is defined as what would be reasonably expected to occur in the foreseeable future, if the project were not approved. Under this alternative, the Specific Plan would not be approved with new policies and no zoning or land use designation changes would occur. Additionally, the General Plan would not be amended and the portions of the Plan Area that are not included within the City boundaries would not be annexed into the City. All future development in the Plan Area would be developed in accordance with the current land use and zoning maps identified in the General Plan.

The General Plan includes the development of approximately 17,900 homes and approximately 29,600 jobs in the Plan Area, while the proposed project includes approximately 45,000 homes and 37,000 jobs. The existing Plan Area contains the following General Plan designations: Residential-Low Density, Residential-Medium Density, Residential-Urban Neighborhood, Employment-Mixed Use, Employment-Office, Public Facilities, Open Space, and Buffer.

Overall, buildout under the No Project Alternative (Alternative 1) would be consistent with the General Plan, and thus, less dense and intense than under the proposed project.

5.3.1 - Impact Analysis
Aesthetics, Light, and Glare
As noted in Section 3.1, Aesthetics, Light and Glare, the proposed project’s impacts to aesthetics, light, and glare would be significant and unavoidable even with implementation of mitigation because the proposed project would add sources of light and glare and would increase urbanization, changing the rural character of the community. Under Alternative 1, the proposed project would not be approved and buildout of the Plan Area would be consistent with the General Plan. As stated in the General Plan PEIR, buildout under the General Plan includes approximately 17,900 homes and approximately 29,600 jobs in the Plan Area. Comparatively, the proposed Specific Plan would include approximately 45,000 homes and approximately 37,000 jobs. Because the Specific Plan proposes a greater intensity of development, it would have greater impacts than Alternative 1. The General Plan PEIR determined that there would be a significant and unavoidable impact related to visual character City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx as well as light and glare. Therefore, a significant and unavoidable impact on aesthetics, light, and glare would also occur under Alternative 1. However, because more existing open space would be retained under the General Plan, Alternative 1 would have the same, but reduced impacts as compared to the proposed project.

Agricultural Resources and Forestry Resources
As noted in Section 3.2, Agricultural Resources and Forestry Resources, the proposed project’s impacts to agricultural resources and forestry resources would be significant and unavoidable even with the implementation of mitigation. The proposed project includes the conversion of farmland to residential uses, community centers, flexible research and development, and neighborhood centers.

Under Alternative 1, the proposed project would not be approved and buildout of the Plan Area would be consistent with the General Plan. As stated in the General Plan PEIR, buildout under the General Plan includes approximately 17,900 homes and approximately 29,600 jobs in the Plan Area.

Comparatively, the proposed Specific Plan would include approximately 45,000 homes and approximately 37,000 jobs. Because the Specific Plan proposes a greater intensity of development, it would have greater impacts than Alternative 1. The General Plan PEIR determined that there would be a significant and unavoidable impact related to the conversion of farmland to non-agricultural use as well as conflicts with existing zoning for agricultural use or a Williamson Act Contract. Therefore, while Alternative 1 would have a lesser effect on farmland, it would still be significant and unavoidable.

Air Quality
As noted in Section 3.3, Air Quality, the proposed project’s impacts to air quality would be significant and unavoidable even with the implementation of mitigation. As described above, Alternative 1 would result in less intense development compared to the proposed project. The General Plan PIER concluded that with buildout envisioned by the General Plan there would be significant and unavoidable air quality impacts related to cumulatively considerable increases in criteria pollutants as well as exposure of sensitive receptors to substantial pollutant concentrations. Therefore, while it would result in less air quality effects than the proposed project, impacts resulting from Alternative 1 would remain significant and unavoidable.

Biological Resources
As noted in Section 3.4, Biological Resources, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of the Fresno General Plan PEIR Mitigation Measures, along with applicable regulations. As described above, buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. The General Plan PEIR concluded that there would be less than significant impacts related to biological resources. The same conclusion was made for the proposed project. Potential disturbance to biological resources would be similar, but less impactful, because of the decreased intensity in Alternative 1. The development under Alternative 1 would comply with mitigation measures specified in the Fresno General Plan PEIR that would reduce impacts to biological resources but would not have the benefit of enhancements identified in the proposed project. Impacts would be expected to be less than significant, similar to the proposed project.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Cultural Resources and Tribal Cultural Resources
As noted in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to cultural resources and tribal cultural resources would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary. Buildout under Alternative 1 would be less intense than under the proposed project and therefore is likely to have a smaller effect on cultural resources. However, similar to the proposed project, impacts would be less than significant.

Energy
As noted in Section 3.6, Energy, the proposed project’s impacts related to energy would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary. Buildout under Alternative 1 would have less intensity than the proposed project.

Therefore, Alternative 1would require a lower energy consumption than the proposed project.

Additionally, since all past, present, and future development projects would be required to comply with the Municipal Code, City ordinances, and County policies that address energy conservation and efficiency during construction, impacts would be less than significant, similar to the proposed project. Impacts would remain less than significant, similar to the proposed project, although slightly less intense due to the reduction in development intensity.

Geology, Soils, and Seismicity
As noted in Section 3.7, Geology, Soils, and Seismicity, the proposed project’s impacts related to geology, soils, and seismicity would be less than significant with the incorporation of the Fresno General Plan PEIR Mitigation Measures and project specific mitigation measures, along with applicable regulations. Buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. Therefore, less soil would be disturbed. Development under Alternative 1 would comply with mitigation measures specified in the Fresno General Plan PEIR that would reduce impacts to geology, soils, and seismicity. Impacts would be expected to be less than significant, similar to the proposed project.

Greenhouse Gas Emissions
As noted in Section 3.8, Greenhouse Gas Emissions, the proposed project’s impacts related to greenhouse gas (GHG) emissions would be significant and unavoidable even with the implementation of the Fresno General Plan PEIR Mitigation Measures and applicable policies and regulations. Alternative 1 would result in less intense development than the proposed project. The General Plan PEIR concluded that GHG impacts would be less than significant with mitigation incorporated. Therefore, Alternative 1 would have a reduced impact compared to the proposed project with regard to GHG emissions.

Hazards and Hazardous Materials
As noted in Section 3.9, Hazards and Hazardous Materials, the proposed project’s impacts related to hazards and hazardous materials would be less than significant with all mitigation incorporated, along with the implementation of applicable regulations. Buildout of the existing General Plan under Alternative 1 would be less intense than under the proposed project. Notably, because they are City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx policy level documents and do not approve any specific development activities, neither Alternative 1 nor the proposed project would result in physical changes, resulting in a significant environmental effect. Additionally, construction of future individual development projects consistent with the existing General Plan must comply with the California Code of Regulations and implement a Stormwater Pollution Prevention Plan to prevent hazardous material spills and protect public safety.

Therefore, while Alternative 1 would have a smaller effect on hazards and hazardous materials due to the smaller intensity of development, impacts would be less than significant, similar to the proposed project.

Hydrology and Water Quality
As noted in Section 3.10, Hydrology and Water Quality, the proposed project’s impacts related to hydrology and water quality would be less than significant with the incorporation of all applicable mitigation measures and regulations. As described above, Buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. Accordingly, potential disturbance to hydrology would be similar, but slightly less, because more open space would be retained. Therefore, the number of impervious surfaces created would be reduced. Impacts would be less than significant, but further reduced compared to the proposed project.

Land Use and Planning
As noted in Section 3.11, Land Use and Planning, the proposed project’s impacts related to land use and planning would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary. The General Plan PEIR determined that buildout of the General Plan would have a less than significant impact with respect to land use. Therefore, impacts resulting from Alternative 1 would be less than significant, similar to the proposed project.

Mineral Resources
As noted in Section 3.12, Mineral Resources, the proposed project’s impacts related to mineral resources would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

The General Plan PEIR found that there are mineral resources within the City, but only in the San Joaquin River Corridor, which is not part of the Plan Area. Therefore, Alternative 1 would have the same impact as the proposed project. A less than significant impact would occur.

The General Plan PEIR determined that impacts with respect to noise would be significant and unavoidable. Buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. As such, noise effects resulting from Alternative 1 would be less than those resulting from the proposed project, but would still be significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Population and Housing
As noted in Section 3.14, Population and Housing, the proposed project’s impacts related to population and housing would be less than significant with the implementation of applicable policies and regulations. Buildout of the General Plan under Alternative 1 would be less dense than under the proposed project. The General Plan provides for only 17,900 homes, whereas the proposed project would provide for approximately 45,000 homes. This alternative would result in a less than significant impact, similar to the proposed project.

Public Services
As noted in Section 3.15, Public Services, the proposed project’s impacts related to public services would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary. Alternative 1 would result in fewer residential units, less nonresidential square footage, and fewer jobs compared to the proposed project. This would result in less demand for public services and recreation than would occur under the proposed project. Since all projects for both this alternative and the proposed project would be required to comply with City ordinances and other policies that address public services, Alternative 1 would have a less than significant impact with respect to public services, similar to the proposed project.

Recreation
As noted in Section 3.16, Recreation, the proposed project’s impacts related to recreation would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations. Buildout of the General Plan under Alternative 1 would result in fewer residences, which would require fewer Pocket, Neighborhood, and Community parks to serve the residents of the proposed project. Therefore, Alternative 1 would have a less than significant impact with respect to public services, similar to the proposed project.

Transportation and Traffic
As noted in Section 3.17, Transportation and Traffic, the proposed project’s impacts related to transportation and traffic would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations. Buildout of the General Plan under Alternative 1 would be less intense and dense than under the proposed project. This alternative would not conflict with any applicable plans, and individual future developments would be reviewed for consistency with applicable regulations found within the General Plan. Alternative 1 would result in a similarly less than significant impact on transportation.

Utilities and Service Systems
As noted in Section 3.18, Utilities and Service Systems, the proposed project’s impacts related to utilities and service systems would be less than significant with the implementation of all applicable mitigation measures, policies and regulations.

The General Plan PEIR found that utilities and service systems impacts would be significant and unavoidable with respect to water, surface water treatment, wastewater treatment, wastewater collection, electric, natural gas, and telecommunications facilities because no project-specific design City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx details of the proposed infrastructure and utilities were available at the time the General Plan PEIR was published. Instead, the availability of utilities and service systems would be evaluated and determined on a project-by-project basis under the General Plan. Development under Alternative 1 would result in development at less intensity than the proposed project. The proposed project would have a less than significant impact with mitigation incorporated. As such, it can be assumed that Alternative 1 would be less than significant with mitigation incorporated.

Wildfire
As noted in Section 3.19, Wildfire, the proposed project’s impacts related to wildfire would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

Buildout of the General Plan under Alternative 1 would be less intense and dense than under the proposed project. However, the buildout under the General Plan would still convert primarily agricultural land to residential and mixed-use land uses, creating a higher intensity of development within the Plan Area. The reduced density of this alternative would expose less individuals to the potential threat of wildfires. This increased urbanization and increase in paved areas would reduce the threat of wildfires in the area. The Plan Area does not contain any lands classified as Very High Fire Hazard Severity Zone. Therefore, similar to the proposed project, impacts to wildfires would be similarly less than significant for Alternative 1.

5.3.2 - Conclusion
Alternative 1 would have similar, but slightly less, impacts than the proposed project for the following impact areas: biological resources; cultural and tribal cultural resources; energy; geology, soils, and seismicity; hazards and hazardous materials; hydrology and water quality; land use; public services; transportation; utilities and service systems; and wildfire, all of which would have a less than significant or no impact conclusion for the proposed project. Impacts resulting from the proposed project that would be significant and unavoidable, including those related to aesthetics, light, and glare; agricultural resources and forestry resources; air quality; GHG emissions; and noise, would also be significant and unavoidable under Alternative 1, but slightly less impactful.

5.4 - Alternative 2—Consolidated Business Park Alternative Under the Consolidated Business Park Alternative (Alternative 2), the SEDA Specific Plan would occur as planned, but this alternative maintains the Flexible Research and Development land designations from the General Plan for the area south of Jensen Avenue. It would accommodate approximately 42,900 homes and 36,000 jobs within the 9,000-acre planning area. This is approximately 2,100 fewer homes and 1,000 fewer jobs, when compared with the proposed project. Alternative 2 would have slightly less density of development than the proposed project. The area identified in the SEDA Specific Plan as Flexible Research and Development to the east of Temperance Avenue and north of Jensen Avenue would be developed as Neighborhood Residential and Mixed Residential with two community centers and five neighborhood centers. Additionally, this alternative would change the land use designations for the planned Mixed Residential and Neighborhood Residential, along with the Community and Neighborhood Centers south of Jensen Avenue. Under Alternative 2, that area City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx would be designated as Flexible Research and Development and Offices. Please refer to Exhibit 5-1 for a visual representation of this alternative.

5.4.1 - Impact Analysis
Aesthetics, Light, and Glare
As noted in Section 3.1, Aesthetics, Light and Glare, the proposed project’s impacts to aesthetics, light, and glare would be significant and unavoidable even with implementation of mitigation because the proposed project would add sources of light and glare and would increase urbanization, changing the rural character of the community.

Alternative 2 would consolidate the proposed Office Center and Flexible Research and Development land uses in the area south of Jensen Avenue and west of Temperance Avenue. As such, more undeveloped space would be preserved compared to the proposed project. Additionally, Alternative 2 is slightly less dense than the proposed project. However, Alternative 2 would still significantly change the visual character of the currently rural Plan Area. Therefore, impacts to visual character would be slightly less than the proposed project, but still significant and unavoidable.

Additionally, new sources of light and glare would still be created under this alternative, and the development would increase urbanization, changing the rural character of the community. Buildout under Alternative 2 would result in increased urbanization compared to the existing land uses.

Therefore, a significant and unavoidable impact on aesthetics, light, and glare would still be expected to occur, similar to, but slightly less than the proposed project.

Buildout consistent with Alternative 2 would be similar to the proposed project. Although the Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue, Alternative 2 would have a similar amount of development, although slightly less intense. Therefore, impacts to agricultural resources and forestry resources would be expected to be significant and unavoidable, similar to, but slightly less than the proposed project.

Air Quality
As noted in Section 3.3, Air Quality, the proposed project’s impacts to air quality would be significant and unavoidable even with the implementation of mitigation.

Buildout consistent with Alternative 2 would be similar to the proposed project. Although the Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue, both this alternative and the proposed project have the same footprint of approximately 9,000 acres. Alternative 2 would result in a similar amount of City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx development as the proposed project, although at a slightly lower intensity. Therefore, impacts to air quality would be expected to be significant and unavoidable, similar to, but slightly less than, the proposed project.

Buildout under Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both Alternative 2 and the proposed project have the same footprint of approximately 9,000 square acres, although Alternative 2 would be slightly less dense. Additionally, this alternative would comply with the General Plan policies and implement the existing mitigation measures included in the General Plan PEIR.

Therefore, impacts to biological resources would be expected to be less than significant, similar to, but slightly less than the proposed project.

Cultural Resources and Tribal Cultural Resources
As noted in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to cultural resources and tribal cultural resources would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

Buildout consistent with Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both Alternative 2 and the proposed project have the same footprint of approximately 9,000 acres, although Alternative 2 would be slightly less dense. Additionally, future development within the Plan Area could have significant impacts on known or previously unidentified cultural resources or Tribal Cultural Resources (TCRs). Development would be required to comply with federal, State, and local law and policies that protect cultural and TCRs. Therefore, impacts to cultural and TCRs would be expected to be less than less than significant, similar to, but slightly less than the proposed project.

Buildout consistent with Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both this alternative and the proposed project have the same footprint of approximately 9,000 acres, although Alternative 2 would be slightly less dense. Additionally, since all past, present, and future development projects would be required to comply with the Municipal Code, City ordinances, and City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx County policies that address energy conservation and efficiency during construction and operation, impacts would be less than significant, similar to, but slightly less than the proposed project.

Buildout consistent with Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project have the same footprint of approximately 9,000 acres.

However, Alternative 2 would have slightly less density than the proposed project. This alternative would still generate a significant net increase in GHG emissions and would have a significant GHG impact per the City of Fresno GHG Reduction Plan Update. Therefore, impacts to GHG emissions would be expected to be significant, similar to, but slightly less than the proposed project.

However, Alternative 2 would have slightly less density than the proposed project. Additionally, all projects under this alternative would be subject to the requirements and regulations set forth by the United States Environmental Protection Agency (EPA), Occupational Safety and Health City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Administration (OSHA), United States Department of Transportation (USDOT), California Department of Toxic Substances Control (DTSC), California Department of Transportation (Caltrans), California Highway Patrol (CHP), and the Valley Air District related to transport, use, and disposal of hazardous materials. Therefore, impacts to hazards and hazardous materials would be expected to be less than significant, similar to, but slightly less than the proposed project.

However, Alternative 2 would have slightly less density than the proposed project. Additionally, buildout of this alternative would increase the amount of paved impervious surfaces within the Plan Area and increase demands for groundwater pumping beyond existing conditions. All projects would be required to comply with the proposed Specific Plan policies, mitigation measures, and the MS4 Permit, which would reduce impacts to less than significant, similar to, but slightly less than the proposed project.

However, Alternative 2 would have slightly less density than the proposed project. Alternative 2 would not physically divide an established community. This alternative would allow for planned development and growth and would increase connectivity and support, strengthen, and connect new communities. However, this alternative might reduce impacts to land use by consolidating Office Center and Flexible Research and Development land uses to the area south of Jensen Avenue.

Therefore, impacts to land use would be expected to be less than significant, similar to but slightly less than the proposed project.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Buildout under Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project have the same footprint of approximately 9,000 acres. However, Alternative 2 would have slightly less density than the proposed project.

However, the remaining unincorporated lands adjacent to the Plan Area are subject to the land use plans, policies, and regulations of Fresno County. Development within adjacent planning areas and unincorporated Fresno County is unlikely to create significant loss of availability of a known mineral resources or loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

Additionally, no mining operations occur in the Plan Area, and thus, further development under either the proposed project or the Alternative 2 would not result in a loss of mineral resources.

Therefore, impacts to mineral resources would be expected to be less than significant, similar to the proposed project.

Alternative 2would result in similar noise and vibration impacts. However, since it is not possible to quantity future cumulative construction noise impacts that could occur if multiple developments were to construct simultaneously, this alternative would result in significant and unavoidable impacts with regard to construction noise. Other noise and vibration impacts under Alternative 2 would result in a less than significant impact, similar to, but slightly less than the proposed project.

Population and Housing
As noted in Section 3.14, Population and Housing, the proposed project’s impacts related to population and housing would be less than significant with the implementation of applicable policies and regulations.

Buildout under Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project would provide for a similar number of homes and jobs. This alternative would provide for approximately 42,900 homes and 36,000 jobs within the Plan Area, while the proposed City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-20 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx project would provide for approximately 45,000 homes and 37,000 jobs within the Plan Area. The Alternative 2would result in a less than significant impact, similar to, but slightly less than the proposed project.

Buildout consistent with Alternative 2 would be similar to the proposed project. Since the proposed project had a less than significant impact on public services, with regard to fire protection, police protection, school facilities, parks and recreational facilities, and other public facilities, this alternative would have a less than significant impact, since it would result in slightly less amount of land being developed. Since all projects for both this alternative and the proposed project would be required to comply with City ordinances and other policies that address public services, Alternative 2 would be similarly less than significant to the proposed project.

Buildout under Alternative 2 would be similar to the proposed project. Future development under both the proposed project and this alternative would include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment. Additionally, individual development projects would be required to comply with the Park Facilities Impact Fee, which would allow new parks to be constructed and adequately maintained at appropriate sites within the Plan Area. Both the proposed project and this alternative would result in the need for additional parkland, although slightly less parkland would be needed under Alternative 2MM REC-1 would ensure potential impacts would be addressed and mitigated to meet the parkland requirements. Alternative 2 would result in less than significant impacts to recreation, similar to, but slightly less than the proposed project.

Buildout under Alternative 2 would be similar to the proposed project. This alternative would not conflict with any applicable plans, and individual future developments would be reviewed for consistency with applicable regulations found within the General Plan. Alternative 2 would result in a similarly less than significant impact on transportation.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Utilities and Service Systems
As noted in Section 3.18, Utilities and Service Systems, the proposed project’s impacts related to utilities and service systems would be less than significant with the implementation of all applicable mitigation measures, policies and regulations.

Buildout under Alternative 2 would be similar to the proposed project. Since both this alternative and the proposed project would provide for a similar number of residential facilities, community centers, offices, and jobs, the requirements for water, wastewater, storm drainage, solid waste, and electricity, natural gas, and telecommunications would remain the same, although slightly less under Alternative 2. Mitigation measures for various resource topics in this Draft PEIR would reduce the cumulative impacts of construction of utility infrastructure to less than significant for both this alternative.

The buildout under this alternative would still convert primarily agricultural land to residential and mixed-use land uses, creating a higher intensity of development within the Plan Area. This increased urbanization and paved areas would reduce the threat of wildfires in the area. Additionally, the Plan Area does not contain any lands classified as Very High Fire Hazard Severity Zone. Therefore, impacts to wildfires would be similarly less than significant for Alternative 2.

5.4.2 - Conclusion
Alternative 2, the Consolidated Business Park Alternative, would have similar, but slightly less impacts to the proposed project’s less than significant or no impacts associated with biological resources; cultural and tribal cultural resources; energy; geology, soils, and seismicity; hazards and hazardous materials; hydrology and water quality; land use; mineral resources; public services; recreation; transportation; utilities and service systems; and wildfire. The significant and unavoidable impacts related to aesthetics, light, and glare; agricultural resources and forestry resources; air quality; GHG emissions; and noise would remain significant and unavoidable. The significant and unavoidable impacts related to a conflict with the Valley Air District regional significant thresholds and a cumulatively considerable net increase in criteria pollutants would remain significant and unavoidable under Alternative 2.

Additionally, Alternative 2 would not meet some of the project objectives. For example, Alternative 2 proposes 2,100 fewer homes and 1,000 fewer jobs than the proposed project.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-22 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx

5.5 - Alternative 3—Farmland Conservation Alternative
Under the Farmland Conservation Alternative (Alternative 3), buildout of the SEDA Specific Plan would occur as proposed in this Draft PEIR; however, under this alternative, specific parcels of farmland located south of Kings Canyon Road/California State Route (SR) 180 and north of Jensen Avenue would be conserved. No future development or ground disturbing activities would be permitted on farmland designated for conservation. This would conserve a total of 648.61 acres of farmland that would not be conserved under the proposed project (Exhibit 5-1). The Plan Area currently has 5,552 acres of farmland.

Under the proposed project, buildout of the Specific Plan would include a farmland buffer along the east side of the Plan Area, designated as Rural Cluster Residential which allows specific residential development to be developed on the important farmlands. This Alternative would include the Rural Cluster Residential Buffer; however, it would not permit developments on identified farmland within this portion of Plan Area. It would be compatible with the uses of the surrounding land since the farmland preserved will also be rural in nature. It is important to note that although development would not be allowed in identified farmland, ground disturbing activity consistent with agricultural uses would still be permited. Please refer to Exhibit 5-2 for a visual representation of this alternative.

5.5.1 - Impact Analysis
Aesthetics, Light, and Glare
As noted in Section 3.1, Aesthetics, Light and Glare, the proposed project’s impacts to aesthetics, light, and glare would be significant and unavoidable even with implementation of mitigation because the proposed project would add sources of light and glare and would increase urbanization, changing the rural character of the community.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would slightly reduce effects on visual character and light and glare in the Plan Area, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be significant and unavoidable.

As such, impacts under Alternative 3 would still be significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Air Quality
As noted in Section 3.3, Air Quality, the proposed project’s impacts to air quality would be significant and unavoidable even with the implementation of mitigation.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would slightly reduce the total development in the Plan Area, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be significant and unavoidable.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would disturb slightly fewer biological resources in the Plan Area due to development, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would result in slightly less ground disturbance due to development in the Plan Area, but agricultural ground disturbance could continue and the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would result in slightly less development and therefore, slightly less energy usage in the Plan Area, although the majority of the Plan Area would be developed as proposed. Impacts under Alternative 3 would still be less than significant.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-24 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Geology, Soils, and Seismicity
As noted in Section 3.7, Geology, Soils, and Seismicity, the proposed project’s impacts related to geology, soils, and seismicity would be less than significant with the incorporation of the Fresno General Plan PEIR Mitigation Measures and project specific mitigation measures, along with applicable regulations.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would result in slightly less ground disturbance due to development in the Plan Area, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would slightly reduce development, and therefore emissions, in the Plan Area, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be significant and unavoidable.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce the risk of releasing hazardous materials into the environment because less land would be disturbed for construction purposes, although the farmland could continue to be developed with agricultural uses and the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would result in slightly less development and therefore, slightly less disturbance of current hydrology patterns, the majority City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-25 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

As previously discussed, the proposed project would designate land on the eastern boundary of the Plan Area as Rural Cluster Residential, creating a buffer between the more intense development within the majority of the Plan Area and the agricultural land east of the Plan Area outside of the SOI. Alternative 3 would preserve farmland within land designated as Rural Cluster Residential under the proposed project, thereby reducing the transitional buffer. Thus, more intense uses to the west of this area could be located much closer to active agricultural land, reducing compatibility between the land uses. Thus, Alternative 3 would likely be in conflict with Specific Plan Policy UF-1.6, which requires buffers between new residential development and existing farmlands, and Policy HC-1.6, which requires urban edge transitions that protect existing rural residential and agricultural uses from new development. Therefore, the adoption of Alternative 3 into the proposed project would cause a significant environmental impact due to conflict with the Specific Plan policies, which would be adopted as part of the proposed project’s approval. As such land use effects would be significant and unavoidable, with less continuity of land uses, greater than the proposed project.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. There are no known resources within the Plan Area. As such, impacts under Alternative 3 would remain less than significant.

Noise
As noted in Section 3.13, Noise, the proposed project’s impacts related to noise would be significant and unavoidable for construction noise and less than significant for all other noise and vibration impacts. There is no mitigation available to reduce cumulative construction noise impacts to less than significant.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would slightly reduce construction and construction noise in the Plan Area, the area could still be used for agricultural purposes and the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-26 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Population and Housing
As noted in Section 3.14, Population and Housing, the proposed project’s impacts related to population and housing would be less than significant with the implementation of applicable policies and regulations.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce the number of residences and, therefore, population increase in the Plan Area, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce population growth and development in the Plan Area, slightly reducing the demand for public services, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce population growth and development in the Plan Area, slightly reducing the demand for recreational facilities, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce development in the Plan Area, which would reduce traffic and its impacts, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-27 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx Utilities and Service Systems
As noted in Section 3.18, Utilities and Service Systems, the proposed project’s impacts related to utilities and service systems would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce population growth and development in the Plan Area, slightly reducing the demand for utilities services, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. The Plan Area does not contain any lands classified as Very High Fire Hazard Severity Zone.

Generally, development of rural land results in a reduced risk for wildfire spread because vegetation is removed. Alternative 3 would result in slightly less development than what was originally proposed. However, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

5.5.2 - Conclusion
Alternative 3, the Farmland Conservation Alternative, would have similar, but slightly less impacts to the proposed project’s less than significant or no impacts associated with biological resources; cultural and tribal cultural resources; energy; geology, soils, and seismicity; hazards and hazardous materials; hydrology and water quality; land use; mineral resources; public services; recreation; transportation; utilities and service systems; and wildfire. The significant and unavoidable impacts related to aesthetics, light, and glare; agricultural resources and forestry resources; air quality; GHG emissions; and noise would remain significant and unavoidable. The significant and unavoidable impacts related to a conflict with the Valley Air District regional significant thresholds and a cumulatively considerable net increase in criteria pollutants would remain significant and unavoidable under Alternative 3.

For example, Alternative 3 would result in fewer homes than the proposed project, because land designated for residential uses would be conserved as farmland. However, although Alternative 3 would not fully reduce impacts to agriculture to below a level of significance, it would promote objectives related to Community Farming and Agriculture by preserving additional farmland to a greater degree than the proposed project.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Draft Program EIR
5-28 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx

5.6 - Environmentally Superior Alternative
CEQA Guidelines Section 15126(e)(2) requires identification of an environmentally superior alternative. If the No Project Alternative is environmentally superior, CEQA requires selection of the “environmentally superior alternative other than the No Project Alternative” among the project and the alternatives evaluated. The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 5-1.

Table 5-1: Summary of Alternatives
Environmental Topic Area
Alternative 1: No Build
Alternative
Alternative 2:

Consolidated Business
Park Alternative
Alternative 3: Farmland
Conservation Alternative
Aesthetics, Light, and Glare <= <= <=
Agricultural Resources and
Forestry Resources
<= <= <=
Air Quality <= <= <=
Biological Resources <= <= <=
Cultural Resources and Tribal
Cultural Resources
<= <= <=
Geology, Soils, and Seismicity <= <= <=
Greenhouse Gas Emissions <= <= <=
Hazards and Hazardous Materials <= <= <=
Hydrology and Water Quality <= <= <=
Land Use and Planning <= <= >
Mineral Resources <= <= <=
Noise <= <= <=
Population and Housing <= <= <=
Public Services <= <= <=
Transportation and Traffic <= <= <=
Utilities and Service Systems <= <= <=
Wildfire <= <= <=
Key:

Impact finding is the same as the proposed project: =
Impact finding is the same as the proposed project but slightly less impactful: <= Impact finding is the same as the proposed project but slightly more impactful: >= Impact finding is less than the proposed project: <
Impact finding is greater than the proposed project: >
Source: FirstCarbon Solutions (FCS) 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Alternatives to the Proposed Project
FirstCarbon Solutions 5-29 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec05-00 Alternatives.docx CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other alternatives.

None of the alternatives analyzed would reduce the significant and unavoidable impacts related to Aesthetics, Light, and Glare; Agricultural Resources and Forestry Resources; Greenhouse Gas Emissions, and Noise, to below a level of significance although they would be incrementally less than the proposed project. Most of the less than significant impacts in other resources areas would be substantially similar; although incrementally less than the proposed project (with the exception of land use impacts under Alternative 3, which would be incrementally greater than the proposed project).

Alternative 1, the No Project Alternative, would not meet the project objectives. Alternatives 2 and 3 would meet many of the project objectives. The Consolidated Business Park Alternative is the environmentally superior alternative because it has similar, but slightly less, impacts as compared to the proposed project and meets the project objectives.

5.7 - Alternatives Rejected From Further Consideration
Section 15126.6(c) of the CEQA Guidelines requires EIRs to identify any alternatives that were considered by the lead agency but were rejected as infeasible for detailed study, and briefly explain the reasons underlying the lead agency’s determination. Furthermore, Section 15126(f)(1) states that “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries. . . and whether the proponent can reasonably acquire or control or otherwise have access to the alternative site. No one of these factors established a fixed limit on the scope of reasonable alternatives.” An increased residential density alternative that increased residential uses by 45,000 units in a different project location than the proposed SEDA was considered and rejected because it would not lessen any of the proposed project’s impacts. There are no locations in the City where 45,000 homes could be constructed while avoiding environmetnal impacts to agricultural land. Agricultural land would be impacted regardless of where a large new residential development is located in the City.

Therefore, no Location Alternative in the City is capable of avoiding the project’s significant and unavoidable agriculture impact. For this reason, a location alternative is not considered further.

Additionally, in this case, an alternative location does not constitute a feasible alternative because the project in question consists of a comprehensive specific plan for a 9,000-acre planning area. An alternative location would not meet the City’s fundamental purpose of establishing a planning document that serves as the comprehensive land use planning document for the jurisdiction; as such, the geographical area encompassed by the plan is an immutable, fundamental characteristic.

Thus, it is not possible to evaluate an alternative location.

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31680033 • 07/2023 | 5-1_consolidated_business_park_alt.cdr CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
Exhibit 5-1
Consolidated Business Park Alternative
Source: City of Fresno
I

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31680033•06/2023| 5-2_farm lan d_con servation _alt.m xd Exhibit5-2
Farm lan dCon servation Altern ative
So urce:ESRIAerial Im agery.CADepartm en tofCon servation Fresn o Co un ty2018

CITYOFFRESNO

FRESNOSOUTHEASTDEV ELOPMENTAREASPECIFICPLANPROJECT

ENV IRONMENTALIMPACTREPORT
180
Clovis Ave
Mckinley Ave
Belmont Ave
Mccall Ave
Jensen Ave
North Ave
Highland Ave
Ashlan Ave
Church Ave
Fowler Ave
4,600 2,300 0 4,600
Feet
Legend
Fresno Southeast Development Area 8,769.57 acres
Agricultural Conservation Area 832.39 acres
Land Cover Categories Fresno SEDA Conservation Area
Prime Farmland 2,475.31 acres 302.09 acres
Farmland of Statewide Importance 1,352.12 acres 233.58 acres Farmland of Local Importance 1,189.08 acres 62.47 acres Unique Farmland 1,724.99 acres 112.94 acres
Urban and Built-Up Land 337.04 acres 1.08 acres
Rural Residential Land 1,535.73 acres 117.50 acres
Semi-Agricultural and Rural Commercial Land 60.54 acres 2.73 acres Vacant or Disturbed Land 94.25 acres 0.00 acre
Nonagricultural or Natural Vegetation 0.51 acre 0.00 acre

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Persons and Organizations Consulted/ Draft Program EIR List of Preparers
FirstCarbon Solutions 6-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec06-00 Preparers-Contributors.docx CHAPTER 6: PERSONS AND ORGANIZATIONS CONSULTED/LIST OF

PREPARERS

6.1 - Lead Agency

6.1.1 - City of Fresno
Planning and Development Department
Director............................................................................................................................... Jennifer Clark Long Range Planning Supervisor .................................................................................Sophia Pagoulatos Planning Supervisor..............................................................................................................Drew Wilson Specific Plan Project Manager............................................................................................. Shawn Monk GIS Specialist.................................................................................................................. Lachea Deamicis Fire Department
Fire Chief............................................................................................................................. Kerri L. Dorris Police Department
Police Chief ....................................................................................................................Paco Balderrama Public Works Department
Director........................................................................................................................... Scott Mozier, PE

6.2 - List of Preparers

6.2.1 - Lead Agency
City of Fresno
Director............................................................................................................................... Jennifer Clark Long Range Planning Supervisor .................................................................................Sophia Pagoulatos Planning Supervisor..............................................................................................................Drew Wilson Specific Plan Project Manager............................................................................................. Shawn Monk

6.2.2 - Lead Consultant
FirstCarbon Solutions
Project Director .......................................................................................................................Mary Bean Project Manager..........................................................................................................................Phil Ault Assistant Project Manager........................................................................................... Rachel Krusenoski Legal Counsel................................................................................................................... Megan Starr, JD Director of Cultural Resources.......................................................................... Dana DePietro, PhD, RPA Historian/Cultural Resources Specialist.......................................................................................... Ti Ngo Field Manager (Cultural)................................................................................................... Natalie Adame Director of Noise and Air Quality ................................................................................................Phil Ault Persons and Organizations Consulted/ City of Fresno—Fresno Southeast Development Area Specific Plan Project List of Preparers Draft Program EIR
6-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec06-00 Preparers-Contributors.docx Senior Air Quality Scientist................................................................................................... Jessica Coria Air Quality Associate ...................................................................................................... Spencer Pignotti Senior Biologist/Biology Lead ...................................................................................Bernhard Warzecha Biologist.............................................................................................................................. Robert Carroll Environmental Analyst............................................................................................... Stephanie Shepard Environmental Analyst..................................................................................................... Madelyn Dolan Environmental Analyst............................................................................................................ Kelly Evans Environmental Analyst....................................................................................................... Isobel Cooper Environmental Analyst..................................................................................................... Laura Campion Publications Manager ............................................................................................................Susie Harris Publications Coordinator ........................................................................................................ Alec Harris Document Specialist....................................................................................................... Melissa Ramirez GIS/Graphics ................................................................................................................Karlee McCracken

6.2.3 - Technical Subconsultants
Blair, Church & Flynn
Project Manager.......................................................................................................... Louis Gonzalez, PE Project Engineer................................................................................................................ Zach Smith, PE Economic & Planning Systems, Inc.

Principal ...................................................................................................................................Amy Lapin Senior Technical Associate ................................................................................................ Allison Shaffer Rose Strategic Communications
Founder/CEO.........................................................................................................................Darren Rose Chief Operations Officer and Project Manager...................................................................Nick Kennedy TJKM
Vice President .................................................................................................................. Chris Kinzel, PE Transportation Planner .........................................................................................................Arthur Chen City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR
FirstCarbon Solutions
Appendix A:

EIR Noticing and Public Involvement

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR
FirstCarbon Solutions
A.1 - Notice of Preparation

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City of Fresno
Southeast Development Area Specific Plan 1

NOTICE OF PREPARATION
Date: February 22, 2022
To: State Clearinghouse and Interested Public Agencies, Parties, and Organizations Subject: Notice of Preparation of a Program Environmental Impact Report for the Southeast Development Area Specific Plan, Fresno, California
Lead Agency: City of Fresno
Contact: Jennifer Clark, Director, Planning and Development Department c/o Shawn Monk, Planner, Planning and Development Department 2600 Fresno Street, Suite 3065
Fresno, CA 93721
559.621.8166
[email protected]
[email protected]
Comment Period: February 22, 2022, to March 25, 2022

PURPOSE OF NOTICE
The City of Fresno (Lead Agency and/or City) will prepare a Program Environmental Impact Report (Program EIR) for the proposed Southeast Development Area (SEDA) Specific Plan (proposed project), located in the City of Fresno. The Program EIR will address potential environmental and physical effects of the proposed project for each environmental topic listed in the California Environmental Quality Act (CEQA). The City of Fresno will use the Program EIR when considering approval of the proposed project. Pursuant to CEQA Guidelines Section 15082, the project history, description, location, and potential environmental effects of the project plan are described in the attached materials.

PUBLIC REVIEW PERIOD
The City is soliciting comments from public agencies, organizations, and members of the public regarding the scope and content of the Program EIR. In accordance with CEQA time regulations, the Notice of Preparation (NOP) 30-day period of public review will begin February 22, 2022, and will end on March 25, 2022. The City will hold a public scoping meeting to inform the public and interested agencies about the proposed project and solicit comments on the scope of the environmental factors addressed in the Program EIR, along with alternatives that are being considered. The meeting will be held on March 3, 2022, and will only be conducted electronically due to COVID-19 restrictions. Meeting details are as follows:

City of Fresno
2 Southeast Development Area Specific Plan
Notice of Preparation
Web link: https://zoom.us/j/ 92678285600 Call-in Information: [(669) 900-9128 Webinar ID: 926 7828 5600
Meeting Date: March 3, 2022
Meeting Time: 6:00 p.m. to 8:00 p.m.

Because of COVID-19 restrictions, copies of the NOP may be reviewed at the following locations:
 Online at: https://www.fresno.gov/cityclerk/notices-publications/ or  www.fresno.gov/SEDA
For information on additional viewing methods, contact Project Manager, Planning and Development Department, Summer Rooks, at [email protected].

Your views and comments on how the project may affect the environment are welcomed and encouraged.

PROJECT LOCATION
The regional location of the nearly 9,000-acre SEDA Specific Plan Area (Plan Area) is in the southeast portion of the City, in Fresno County (County), California as shown in Exhibit 1. The Plan Area with the proposed land use designations in the proposed project, are shown in Exhibit 2. The Plan Area is bounded on the north by the Gould Canal, on the east by McCall and Highland Avenues, on the south by Jensen and North Avenues, and on the West by Locan, Temperance, and Minnewawa Avenues.

PROJECT HISTORY
The SEDA, previously known as the Southeast Growth Area (SEGA), was approved for incorporation into the City in 2006 by the Local Agency Formation Commission (LAFCo) with several provisions that included preparation of a Specific Plan and associated environmental assessment before any annexations of land to the City could be approved. The City initiated the process of preparing a Specific Plan for SEGA but put it aside amid the uncertainty of the recession in 2008. Concepts from the SEGA planning process were rolled into the current Fresno General Plan that was adopted in 2014.

The Fresno General Plan includes the SEDA as one of several growth areas.

Located in Growth Area II, SEDA was conceived to be developed after other infill initiatives, to give those time to gain momentum. SEDA’s later time frame is reflected in the General Plan’s buildout numbers, which include one-third of SEDA’s residential capacity (approximately 15,000 dwelling units out of a total 45,000 dwelling unit capacity) to accommodate Fresno’s anticipated 2035 population. It is assumed that the remaining residential capacity of 30,000 dwelling units will not be developed until after 2035. While there is still ample residential capacity within the current city limits and in Growth Area I (which includes the Southwest Fresno and the West Area Neighborhoods Specific Plan areas), City of Fresno
Southeast Development Area Specific Plan 3
Notice of Preparation
there is a sense of urgency about the current housing crisis and the City’s ability to provide housing for existing population and its natural growth as well as the unanticipated in-migration occurring at this time.

EXISTING CONDITIONS
The predominant use in the Plan Area is agriculture, with the primary crops being vineyards, orchards, and vegetables. The Plan Area also contains agriculture-related and commercial operations, such as plant nurseries, wineries, and other various agricultural businesses. The second most predominant use is rural residential development, which is primarily concentrated in the area between State Route (SR) 180 and McKinley Avenues, but also scattered throughout the Plan Area.

In addition to these uses, schools, churches, and other uses also occupy the Plan Area. The Plan Area includes land that falls within both the Sanger and Clovis Unified School Districts, with Fowler and Fresno Unified School Districts bordering the Plan Area. Clovis Unified is constructing an educational center for middle and high school students in the northern portion of the Plan Area on a site along the Clinton Avenue alignment between Leonard and Highland Avenues, with phased opening expected in 2025.

The current roadway network is mainly comprised of two-lane county roads at 0.5-mile intervals, interspersed with local streets. Major roadway access corridors include Temperance, Clovis, and Jensen Avenues. Each accommodate four lanes of traffic with a central turning lane. The SR-180 has been extended eastward along the old Kings Canyon alignment from Temperance Avenue to Academy Avenue in Sanger. This route extension provides an east–west connection to Interstate 5 (I-5), serving commuters and the movement of agricultural goods from eastern portion of the County. Temperance Avenue has been expanded to four lanes where needed to serve new development.

The Plan Area is traversed by several constructed drainage features and natural waterways: Gould Canal, Redbank Slough, Dry Creek Canal, Mill Ditch, Fancher Creek Canal, and Briggs Canal. Some canals in the Plan Area are mostly unvegetated and the banks are enforced with rock or broken asphalt and concrete, with some portions fully concrete-lined. In addition, there are several small ponds and numerous lateral irrigation ditches present that deliver water from the canals to agricultural fields.

PROJECT DESCRIPTION
The proposed project is a Specific Plan for the SEDA that would provide for increased density and accelerate housing production throughout the Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels.

The proposed project land use categories are shown in Table 1 along with the total proposed acreage.

A description of the proposed project and these associated land use categories are provided in the discussion below.

City of Fresno
4 Southeast Development Area Specific Plan
Notice of Preparation
Table 1: Proposed Specific Plan Estimated Acreages
Land Use Proposed Plan Acres Percentages
Mixed-Use Land Uses
Regional Center 310 3.5%
Community Center 290 3.3%
Neighborhood Center 520 5.9%
Residential Land Uses
Mixed Residential 1,090 12.4%
Neighborhood Residential 1,520 17.3%
Rural Residential 2,160 24.5%
Rural Cluster Residential 810 9.2%
Employment Land Uses
Office Center 160 1.8%
Flexible Research and Development 1,380 15.7%
Institutional 280 3.2%
Other Land Uses
Flood Control Basin 280 3.2%
TOTAL 8,799 100%
Notes:
* Rounded to the nearest acre. Figures may not sum due to rounding.

The SEDA Specific Plan
The proposed project provides a vision and implementation mechanisms for a sustainable future for the Southeast Development Area. It has the potential to accommodate approximately 45,000 homes and 37,000 jobs within the nearly 9,000-acre planning area by the year 2050. Framed within three interrelated goals: fiscal responsibility, social equity, and environmental sustainability the proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. The proposed project would include major transit lines, mixed-use centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure.

Vibrant Mixed-Use Town Centers
The proposed project is based upon a hierarchy of walkable Mixed-Use Town Centers supported by a multimodal transportation network. Town Centers, which would serve as commercial and civic focal points for the Plan Area, are designed to include a mix and intensity of uses. Town Centers are humanscaled and defined by quality design features and a rich mixture of uses. They incorporate living and working opportunities with entertainment, cultural activities, and shops serving the daily needs of residents and employees.

City of Fresno
Southeast Development Area Specific Plan 5
Notice of Preparation
Regional Town Center
The Regional Town Center is at the top of the mixed-use center hierarchy in the Plan Area, serving 40,000 to 60,000 households across the site and within the surrounding communities. The Regional Town Center features region-serving retail and office activity, as well as medium- and higher-density housing. It is well served by a high-capacity transit service.

Community Town Centers
Seven Community Town Centers dispersed across the Plan Area would provide commercial, civic, and other services to meet the needs of Community Town Center residents and employees, as well as those of surrounding neighborhoods. Community Town Center services, including grocery stores, support between 5,000 and 10,000 households. Community Town Centers feature a variety of mediumdensity housing options. Some Community Town Centers are focused on major rapid transit stations.

Neighborhood Town Centers
Neighborhood Town Centers are dispersed throughout the Plan Area and would serve as focal points of adjacent residential areas. Neighborhood Centers include employment and residential uses, but primarily provide a majority of the Plan Area residents with essential walk, bike, transit, and short-drive access to civic services and amenities, including elementary schools, local parks, community gardens, and other services.

Each Neighborhood Town Center would serve approximately 1,500 to 2,000 households and include a range of housing options.

Diverse Residential Districts
The Plan Area includes a rich and complete fabric of residential communities that support mixed-use centers and include a variety of housing types and affordability levels. The proposed project would distribute a variety of housing across the Plan Area to accommodate current and future housing needs.

The range of housing types and densities throughout the communities would provide flexibility to meet the evolving needs of households in the region.

Mixed Residential
Mixed Residential districts support the Regional and Community Town Centers with a variety of medium- and higher-density housing, including a diverse mix of attached and detached single-family and multi-family homes.

Neighborhood Residential
Neighborhood Residential districts surround Neighborhood Town Centers and support the retail, employment, and other services provided throughout the Plan Area. Neighborhood Residential areas include a variety of detached and attached single-family housing types, as well as multi-family housing options.

Rural Cluster Residential
Rural Cluster districts, located along the eastern edge of the Plan Area, concentrate residential lots within a small, clustered area of a larger parcel or groups of parcels. This clustering of homes preserves City of Fresno
6 Southeast Development Area Specific Plan
Notice of Preparation
the continuity and viability surrounding land for agricultural uses and open space conservation. Rural Cluster districts serve as a transitional buffer between more intense urban uses within the Plan Area and the commercial agricultural operations outside of the Plan Area.

Rural Residential
There are approximately 1,700 acres in the Plan Area currently developed as very low-density rural residential homes and ranchettes. These homes are designated in the proposed project as Rural Residential.

Innovative Employment Districts
The proposed project provides opportunities to attract diverse high‑quality employers and job opportunities while meeting the environmental challenges associated with growth in the City and the Central Valley. Many jobs would be located within a short distance to amenities in Regional and Community Town Centers, Office Centers, and in Flexible Research and Development districts.

In these locations, they can be closely linked to regional transit service and trail systems. The proposed project would put a significant portion of Plan Area residents within walking distance of major employment areas and high‑capacity transit service that links to regional employment centers, including Downtown Fresno.

Reducing reliance on the automobiles for work trips would significantly reduce greenhouse gas (GHG) emissions, playing a significant role in meeting the proposed project’s sustainability goals.

Office Center
Office Center districts are located adjacent to Regional and Community Centers or along regionally significant transportation corridors (e.g., SR-180, Kings Canyon Boulevard, Clovis Avenue). Office Centers accommodate professional offices and compatible commercial uses such as restaurants, coffee shops, cafés, banks, and book shops. Some residential uses could be permitted in Office Centers.

Flexible Research and Development
Flexible Research and Development districts are primarily located west of the Briggs Canal and/or south of Jensen Avenue and are intended to contain uses such as research and development, light manufacturing, product testing centers, and office development. The area may also include compatible commercial uses such as restaurants, coffee shops, cafés, printing and publishing, dry cleaners, and other supporting businesses. Access to regional transportation corridors (both road and rail) is critical.

Residential uses are not allowed in Flexible Research and Development areas.

Transportation Choices
The multimodal circulation network in the proposed project includes a hierarchy of transportation options, ensuring that residents would have real choices for their daily travel needs.

Complete Streets
The Plan Area will be served by a network of Complete Streets as defined by City’s Complete Streets Policy adopted in 2019. A Complete Street is defined in the policy as a transportation facility that is City of Fresno
Southeast Development Area Specific Plan 7
Notice of Preparation
planned, designed, operated, and maintained to provide safe mobility for all users–including bicyclists, pedestrians, transit vehicles, trucks, and motorists–appropriate to the function and context of the facility while connecting to a larger transportation network.

Transit Service
Transit Corridors/arterials with high-capacity public transit would serve major town centers, while collectors and local streets provide safe, convenient options for local trips. The Kings Canyon high frequency Q Bus Route is planned to extend into the Regional Town Center and eventually terminate service in the Community Town Center located on South DeWolf Avenue.

Bicycle/Pedestrian Trails
A network of pedestrian and bicycle routes, including dedicated trails and multi-purpose paths will serve work, school, and recreational trips. This extensive non-auto travel network will be coordinated with existing and proposed regional trails. Trail systems connect regional and sub-regional destinations for bicyclists, pedestrians, and equestrians (where appropriate). Multiuse trails are parallel to canals and other east–west open space networks within the Plan Area.

There will also be a network of bicycle lanes reflective of the Fresno Active Transportation Plan (ATP).

This will consist of at least Class II Bike Lanes and other bicycle facilities as described in the Caltrans Bikeway Classification Guide.

Open Spaces, Agriculture, and Green Infrastructure
The proposed project features an integrated system of natural and developed open spaces that would serve many vital uses, from recreation to community farming and agriculture, to stormwater management. The open space system is designed to be a valuable amenity accessible to the entire community.

Parks and Open Spaces
The proposed project’s open space system provides places for active and passive recreation and includes corridors for trails and paths that connect many areas of the Plan Area.

Sustainable Infrastructure
Sustainable infrastructure components capture and retain runoff, then treat the water by allowing it to move slowly through natural systems, such as constructed wetlands and rock filters. Stormwater management systems help reduce impacts on the environment and regional infrastructure systems can also be designed as visual and active amenities for residents in the Plan Area.

Community Farming and Agriculture
The proposed project integrates community-scale farming and agriculture into the urban fabric.

Agricultural activities range from neighborhood gardens to agricultural education, and from small farming operations in green belts to those on the rural cluster edge.

City of Fresno
8 Southeast Development Area Specific Plan
Notice of Preparation
Setting the Stage for Implementation
The proposed project sets a vision for how the Plan Area would develop over time. It defines where Mixed-Use Town Centers, residential neighborhoods, and employment areas would be located, the types of travel options, and transit and roadway infrastructure that would serve and connect these areas. It also sets standards for how districts would be organized and how streets would be designed to enhance walkability and meet the needs of all users. The plan includes the targets established by State and federal policies that address water and energy conservation, reduced air quality and GHG emissions, available parks and open space, housing opportunities, and many other important elements.

The following components will be part of the planning process and will be required prior to construction:

1. Complete a phasing plan that would define the optimal sequence of development for various areas within SEDA.

2. Complete a comprehensive Infrastructure Plan. Working from the SEDA Land Use Plan as its starting point, the Infrastructure Plan will delineate the specific bounds and design of the Plan Area’s overall flood control and green infrastructure plan; identify bicycle and pedestrian trail alignments; specify the location of high schools, middle schools, and elementary schools; establish the specific alignments of arterial, and collector roadways, and identify the location of major transit stations along transit routes and corridors. The plan will also include new sewer and water infrastructure needed to serve new development. This plan must be accompanied by a comprehensive and detailed financing and implementation strategy that includes the phasing and financing of development and all major infrastructure. The City would convene all requisite agencies in the development of the Infrastructure Plan, including the following, and others as required:
• Fresno Municipal Flood Control District
• Fresno Irrigation District
• City of Fresno Department of Public Utilities Water Division, Wastewater Management Division, and Solid Waste Management Division • City of Fresno Department of Public Works Streets Division • City of Fresno Parks After School, Recreation, and Community Services Department • Clovis and Sanger Unified School Districts
• Fresno Council of Governments
• Fresno Area Express (FAX) transit agency
• California Department of Transportation
City of Fresno
Southeast Development Area Specific Plan 9
Notice of Preparation

3. Address Annexation with Fresno County, the Local Agency Formation Commission, and the State of California. This includes addressing all issues to allow strategic and proactive annexation into the City of designated portions of the Plan Area targeted for planned and financed extension of infrastructure development by the City. The typically fragmented annexations associated with incremental private development proposals, Memorandum of Understanding (MOU), and interjurisdictional competition would not promote the coherent, sustainable, and fiscally sound development of the proposed project.

4. General Plan Amendment and Development Code Change. Amend the General Plan and Development Code to implement the land use and zoning described in the proposed project.

RESPONSIBLE AGENCIES
For the purposes of CEQA, the term “Responsible Agency” includes all public agencies other than the Lead Agency (that have discretionary approval power over the proposed project) (State CEQA Guidelines § 15381).

Discretionary approval may include such actions as issuance of a permit, authorization, or easement needed to complete some aspect of the proposed project. Responsible agencies may include, but are notlimited to:
 California Department of Transportation (Caltrans)
 California State Water Resources Control Board (State Water Board)  California Department of Fish and Wildlife (CDFW)
 Central Valley Regional Water Quality Control Board (Central Valley RWQCB)  Fresno Local Agency Formation Commission (LAFCo)
 San Joaquin Valley Air Pollution Control District (Valley Air District)  Fresno Municipal Flood Control District
 Fresno Irrigation District

AREAS OF POTENTIAL ENVIRONMENTAL EFFECTS
The Program EIR will analyze the significant environmental effects associated with adoption and implementation of the proposed project. Specific areas of analysis would include the following topics based on Appendix G of the State CEQA Guidelines:
 Aesthetics  Land Use and Planning
 Agricultural and Forestry Services  Mineral Resources  Air Quality  Noise
 Biological Resources  Population and Housing
 Cultural/Tribal Cultural Resources  Public Services
City of Fresno
10 Southeast Development Area Specific Plan
Notice of Preparation
 Energy  Recreation
 Geology and Soils  Transportation
 Greenhouse Gas Emissions and Climate
Change
 Utilities and Service Systems
 Hazards and Hazardous Materials  Wildfire
 Hydrology and Water Quality  Mandatory Findings of Significance The Program EIR will also include a discussion of environmental justice issues and identify and evaluate a range of reasonable alternatives to the proposed project, including a No Project Alternative, pursuant to CEQA Guidelines.

SUBMITTING COMMENTS
Comments and suggestions as to the appropriate scope of analysis in the Program EIR are invited from all interested parties. Written comments or questions concerning the Program EIR for the proposed project should bedirected to the City’s Environmental Project Manager at the following address by 5:00 p.m. on March 25, 2022. Please include the commenter’s full name and address.

Jennifer Clark, Director, Planning and Development Department c/o Shawn Monk, Planner, Planning and Development Department 2600 Fresno Street, Suite 3065
Fresno, CA 93721
559.621.8031
[email protected]
[email protected]
99 201
180
41 168
Fresno County
Tulare County
Madera County
Fresno County
Millerton
Lake
Big Dry Creek
Reservoir
Hensley Lake
Sierra
National
Forest
Clovis
Fresno
Sanger
Reedley
Selma
Fowler
Exhibit 1
Regional Location Map
5 2.5 0 5
Miles
Text
Project Site
Source: Census 2000 Data, The California Spatial Information Library (CaSIL). City of Fresno, SEDA Regulating Districts.

CITY OF FRESNO

SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

NOTICE OF PREPARATION
31680033 • 09/2021 | 1_regional.mxd
Project Site
31680033 • 02/2022 | 2_specific_plan_map.cdr CITY OF FRESNO

SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

NOTICE OF PREPARATION
Exhibit 2
Specific Plan Map
Source: City of Fresno, SEDA Regulating Districts, 02/10/2022.

I
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR
FirstCarbon Solutions
A.2 - NOP Public Scoping Comments

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1 Rachel Krusenoski
From: Secrest Jr., William <[email protected]> Sent: Thursday, February 24, 2022 4:03 PM
To: Shawn Monk
Cc: Coletti, Karen
Subject: Notice of Preparation for SEDA EIR
Follow Up Flag: Follow up
Flag Status: Flagged
External Email: Use caution with links and attachments
On behalf of the Fresno County Historical Landmarks and Records Advisory Commission, I'm responding to your February 22 Notice of Preparation and Scoping Meeting for the above.

Please keep us informed of all developments related to the CEQA-mandated analysis of cultural/tribal cultural resources, as outlined on p. 9 of your Notice. The SEDA encompasses a large swath of area that might include houses and structures of historical interest, in excess of 100 years of age, with an outside possibility of Yokuts artifacts present.

We are also available to assist any individuals who compile the EIR itself.

Thank you for your consideration.

Bill Secrest, Librarian
Heritage Center
Fresno County Public Library
Gavin Newsom, Governor
David Shabazian, Director
State of California Natural Resources Agency | Department of Conservation 715 P Street, MS 1904, Sacramento, CA 95814
conservation.ca.gov | T: (916) 324-0850 | F: (916) 327-3430 MARCH 14, 2022
VIA EMAIL: [email protected]; [email protected] Jennifer Clark, Director, Planning and Development Department c/o Shawn Monk, Planner, Planning and Development Department 2600 Fresno Street, Suite 3065
Fresno, CA 93721
Dear Ms. Clark and Mr. Monk:

NOTICE OF PREPARATION OF THE ENVIRONMENTAL IMPACT REPORT FOR THE SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN PROJECT, SCH#2022020486
The Department of Conservation’s (Department) Division of Land Resource Protection (Division) has reviewed the Notice of Preparation of the Environmental Impact Report for the Southeast Development Area Specific Plan Project (Project). The Division monitors farmland conversion on a statewide basis, provides technical assistance regarding the Williamson Act, and administers various agricultural land conservation programs. We offer the following comments and recommendations with respect to the project’s potential impacts on agricultural land and resources.

Project Description
The proposed project is a Specific Plan for the Southeast Development Area (Plan Area) that would provide for increased density and accelerate housing production throughout the Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels. It has the potential to accommodate approximately 45,000 homes and 37,000 jobs within the nearly 9,000- acre planning area by the year 2050. Framed within three interrelated goals: fiscal responsibility, social equity, and environmental sustainability the proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. The proposed project would include major transit lines, mixeduse centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure.

Department Comments
The conversion of agricultural land represents a permanent reduction and significant impact to California’s agricultural land resources. CEQA requires that all feasible and

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reasonable mitigation be reviewed and applied to projects. Under CEQA, a lead agency should not approve a project if there are feasible alternatives or feasible mitigation measures available that would lessen the significant effects of the project.

All mitigation measures that are potentially feasible should be included in the project’s environmental review. A measure brought to the attention of the lead agency should not be left out unless it is infeasible based on its elements.

Consistent with CEQA Guidelines, the Department recommends the County consider agricultural conservation easements, among other measures, as potential mitigation. (See Cal. Code Regs., tit. 14, § 15370 [mitigation includes “compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.”]) Mitigation through agricultural easements can take at least two forms: the outright purchase of easements or the donation of mitigation fees to a local, regional, or statewide organization or agency whose purpose includes the acquisition and stewardship of agricultural easements. The conversion of agricultural land should be deemed an impact of at least regional significance. Hence, the search for replacement lands should not be limited strictly to lands within the project’s surrounding area.

A helpful source for regional and statewide agricultural mitigation banks is the California Council of Land Trusts. They provide helpful insight into farmland mitigation policies and implementation strategies, including a guidebook with model policies and a model local ordinance. The guidebook can be found at:

California Council of Land Trusts
Of course, the use of conservation easements is only one form of mitigation that should be considered. Any other feasible mitigation measures should also be considered.

Indeed, the recent judicial opinion in King and Gardiner Farms, LLC v. County of Kern (2020) 45 Cal.App.5th 814 (“KG Farms”) holds that agricultural conservation easements on a 1 to 1 ratio are not alone sufficient to adequately mitigate a project’s conversion of agricultural land. KG Farms does not stand for the proposition that agricultural conservation easements are irrelevant as mitigation. Rather, the holding suggests that to the extent they are considered, they may need to be applied at a greater than 1 to 1 ratio, or combined with other forms of mitigation (such as restoration of some land not currently used as farmland).

Conclusion
The Department recommends further discussion of the following issues:
• Type, amount, and location of farmland conversion resulting directly and indirectly from implementation of the proposed project.

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• Impacts on any current and future agricultural operations in the vicinity; e.g., land-use conflicts, increases in land values and taxes, loss of agricultural support infrastructure such as processing facilities, etc.
• Incremental impacts leading to cumulative impacts on agricultural land. This would include impacts from the proposed project, as well as impacts from past, current, and likely future projects.
• Proposed mitigation measures for all impacted agricultural lands within the proposed project area.
• Projects compatibility with lands within an agricultural preserve and/or enrolled in a Williamson Act contract.
• If applicable, notification of Williamson Act contract non-renewal and/or cancellation.

Thank you for giving us the opportunity to comment on the Notice of Preparation of the Environmental Impact Report for the Southeast Development Area Specific Plan Project. Please provide this Department with notices of any future hearing dates as well as any staff reports pertaining to this project. If you have any questions regarding our comments, please contact Farl Grundy, Associate Environmental Planner via email at [email protected].

Sincerely,
Monique Wilber
Conservation Program Support Supervisor
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Central Region
1234 East Shaw Avenue
Fresno, California 93710
(559) 243-4005
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
March 25, 2022
Shawn Monk, Planner
City of Fresno
2600 Fresno St, Room 3065
Fresno, California 93721
[email protected]
Subject: Southeast Development Area Specific Plan (Project) Notice of Preparation (NOP)
SCH No.: 2022020486
Dear Mr. Monk:

The California Department of Fish and Wildlife (CDFW) received a NOP from the City of Fresno for the above-referenced Project pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines.1
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, CDFW appreciates the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

DocuSign Envelope ID: 7EB6AFEE-6B04-4A06-B79A-94949170702E Shawn Monk
City of Fresno
March 25, 2022

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CDFW is also submitting comments as a Responsible Agency under CEQA (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), related authorization as provided by the Fish and Game Code may be required.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Fresno
Objective: The proposed project is a Specific Plan for the Southeast Development Area (SEDA) that would provide for increased density and accelerate housing production throughout the Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels. The proposed project land use categories are shown in Table 1 (below) along with the total proposed acreage.

Table 1: Proposed Specific Plan Estimated Acreages
Land Use Proposed Plan Acres Percentages
Mixed-Use Land Uses
Regional Center 310 3.5%
Community Center 290 3.3%
Neighborhood Center 520 5.9%
Residential Land Uses
Mixed Residential 1,090 12.4%
Neighborhood Residential 1,520 17.3%
Rural Residential 2,160 24.5%
Rural Cluster Residential 810 9.2%
Employment Land Uses
Office Center 160 1.8%
Flexible Research and
Development 1,380 15.7%
Institutional 280 3.2%
Other Land Uses
Flood Control Basin 280 3.2%
TOTAL 8,799 100%
Notes:
* Rounded to the nearest acre.

DocuSign Envelope ID: 7EB6AFEE-6B04-4A06-B79A-94949170702E Shawn Monk
City of Fresno
March 25, 2022

Page 3 ends

Figures may not sum due to
rounding.

The SEDA Specific Plan
The proposed project provides a vision and implementation mechanisms for a sustainable future for the SEDA. It has the potential to accommodate approximately 45,000 homes and 37,000 jobs within the nearly 9,000-acre planning area by the year 2050. Framed within three interrelated goals: fiscal responsibility, social equity, and environmental sustainability the proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. The proposed project would include major transit lines, mixed-use centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure.

Location: The regional location of the nearly 9,000-acre SEDA Specific Plan Area (Plan Area) is in the southeast portion of the City, in Fresno County (County), California.

The Plan Area is bounded on the north by the Gould Canal, on the east by McCall and Highland Avenues, on the south by Jensen and North Avenues, and on the West by Locan, Temperance, and Minnewawa Avenues.

Timeframe: The proposed project would be implemented over approximately 28 years, through the horizon year of 2050 per Project information.

COMMENTS AND RECOMMENDATIONS
After reviewing the NOP document, CDFW has concerns regarding potential Project impacts to the following.

CDFW is concerned regarding potential impacts to special-status species including, but not limited to, the State and federally endangered California jewelflower (Caulanthus californicus), San Joaquin adobe sunburst (Pseudobahia peirsonii), San Joaquin kit fox (Vulpes macrotis mutica), and least Bell’s vireo (Vireo bellii pusillus); the State endangered and federally threatened succulent owl’s clover (Castilleja campestris var. succulenta), western yellow-billed cuckoo (Coccyzus americanus occidentalis); the federally endangered valley elderberry longhorn beetle (Desmocerus californicus dimorphus); the federally threatened vernal pool fairy shrimp (Branchinecta lynchi); the State and federally threatened California tiger salamander (Ambystoma californiense); the State threatened Swainson’s hawk (Buteo swainsoni) and tricolored blackbird (Agelauis tricolor); the State species of special concern burrowing owl (Athene cunicularia), western spadefoot (Spea hammondii), western pond turtle (Emys marmorata), American badger (Taxidea taxus), and coast horned lizard (Phrynosoma blainvillii).

DocuSign Envelope ID: 7EB6AFEE-6B04-4A06-B79A-94949170702E Shawn Monk
City of Fresno
March 25, 2022

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Special-status species may occur in previously disturbed agricultural lands, orchards, pasture, and row and field crops as well as the undisturbed areas occurring within the Project area. Based on the information provided in the NOP, CDFW cannot determine the extent of impacts that are likely to occur to fish and wildlife resources, or what mitigation measures may be necessary to reduce impacts to less than significant and/or avoid unauthorized take of species listed pursuant to CESA. Therefore, CDFW recommends that the EIR prepared for the Project analyze potential impacts for all of the previous listed species and what, if any, mitigation measures are necessary to reduce impacts to less than significant.

CDFW appreciates the opportunity to comment on the Project to assist the City of Fresno in identifying and mitigating the Project’s impacts on biological resources. We are happy to meet with you to discuss the Project, our recommended mitigation measures, and/or consider alternative measures. If you have any questions, please contact Kelley Nelson, Environmental Scientist, at the address provided on this letterhead, or by electronic mail at [email protected].

Sincerely,
Julie A. Vance
Regional Manager
ec: Patricia Cole
United States Fish and Wildlife Service
[email protected]
DocuSign Envelope ID: 7EB6AFEE-6B04-4A06-B79A-94949170702E Printed on Recycled Paper
March 15, 2022
Mr. Shawn Monk
Planner
City of Fresno
2600 Fresno Street, Suite 3065
Fresno, CA 93721
[email protected]

NOTICE OF PREPARATION OF A PROGRAM ENVIRONMENTAL IMPACT REPORT FOR THE SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN – DATED FEBRUARY 22, 2022 (STATE CLEARINGHOUSE NUMBER: 2022020486) Dear Mr. Monk:

The Department of Toxic Substances Control (DTSC) received a Notice of Preparation of a Program Environmental Impact Report (EIR) for the Southeast Development Area Specific Plan (Project). The Lead Agency is receiving this notice from DTSC because the Project includes one or more of the following: groundbreaking activities, work in close proximity to a roadway, work in close proximity to mining or suspected mining or former mining activities, presence of site buildings that may require demolition or modifications, importation of backfill soil, and/or work on or in close proximity to an agricultural or former agricultural site.

DTSC recommends that the following issues be evaluated in the Hazards and Hazardous Materials section of the EIR:

1. The EIR should acknowledge the potential for historic or future activities on or near the project site to result in the release of hazardous wastes/substances on the project site. In instances in which releases have occurred or may occur, further studies should be carried out to delineate the nature and extent of the contamination, and the potential threat to public health and/or the environment should be evaluated. The EIR should also identify the mechanism(s) to initiate any required investigation and/or remediation and the government agency who will be responsible for providing appropriate regulatory oversight.

Mr. Shawn Monk
March 16, 2022

Page 2 ends

2. Refiners in the United States started adding lead compounds to gasoline in the 1920s in order to boost octane levels and improve engine performance.

This practice did not officially end until 1992 when lead was banned as a fuel additive in California. Tailpipe emissions from automobiles using leaded gasoline contained lead and resulted in aerially deposited lead (ADL) being deposited in and along roadways throughout the state. ADL-contaminated soils still exist along roadsides and medians and can also be found underneath some existing road surfaces due to past construction activities. Due to the potential for ADL-contaminated soil DTSC, recommends collecting soil samples for lead analysis prior to performing any intrusive activities for the project described in the EIR.

3. If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s 2006 Interim Guidance Evaluation of School Sites with Potential Contamination from Lead Based Paint, Termiticides, and Electrical Transformers.

4. If any projects initiated as part of the proposed project require the importation of soil to backfill any excavated areas, proper sampling should be conducted to ensure that the imported soil is free of contamination. DTSC recommends the imported materials be characterized according to DTSC’s 2001 Information Advisory Clean Imported Fill Material.

5. If any sites included as part of the proposed project have been used for agricultural, weed abatement or related activities, proper investigation for organochlorinated pesticides should be discussed in the EIR. DTSC recommends the current and former agricultural lands be evaluated in accordance with DTSC’s 2008 Interim Guidance for Sampling Agricultural Properties (Third Revision).

DTSC appreciates the opportunity to comment on the EIR. Should you need any assistance with an environmental investigation, please visit DTSC’s Site Mitigation and Restoration Program page to apply for lead agency oversight. Additional information regarding voluntary agreements with DTSC can be found at DTSC’s Brownfield website.

Mr. Shawn Monk
March 16, 2022

Page 3 ends

If you have any questions, please contact me at (916) 255-3710 or via email at [email protected].

Sincerely,
Gavin McCreary
Project Manager
Site Evaluation and Remediation Unit
Site Mitigation and Restoration Program
Department of Toxic Substances Control
cc: (via email)
Governor’s Office of Planning and Research
State Clearinghouse
[email protected]
Mr. Dave Kereazis
Office of Planning & Environmental Analysis
Department of Toxic Substances Control
[email protected]
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 6 OFFICE
1352 WEST OLIVE AVENUE |P.O. BOX 12616 |FRESNO, CA 93778-2616 (559) 981-1041 | FAX (559) 488-4195 | TTY 711
www.dot.ca.gov
March 18, 2022
FRE-180-R65.1

NOTICE OF PREPARATION, EIR
https://ld-igr-gts.dot.ca.gov/district/6/report/25659

SENT VIA EMAIL
Shawn Monk, Planner
City of Fresno
Long Range Planning Division
Office: 559-621-8031
[email protected]
Dear Mx. Monk,
Thank you for the opportunity to review the Notice of Preparation of a Program Environmental Impact Report for the Southeast Development Area Specific Plan. The proposed Southeast Development Area covers nearly 9,000 acres and has the potential to accommodate approximately 45,000 homes by the year 2050. The Plan Area is bounded on the north by the Gould Canal, on the east by McCall and Highland Avenues, on the south by Jensen and North Avenues, and on the West by Locan, Temperance, and Minnewawa Avenues.

Caltrans provides the following comments consistent with the State’s smart mobility goals that support a vibrant economy and sustainable communities:

1. Caltrans anticipates this development area would add substantial traffic to the State Route 180 interchanges at Clovis Avenue, Fowler Avenue, and Temperance Avenue. The result could be significant speed differentials between the off‐ramp queues and the mainline of the freeway. It is highly recommended that a peak hour ramp queue analysis is completed at each of these interchanges to determine potential impacts.

2. This development area would also be expected to add traffic to the State Route 180 intersections at De Wolf Avenue, Highland Avenue, and McCall Avenue. The result could be significant speed differentials between the turn lane queues and the through lane traffic caused by insufficient left turn lanes or intersection control. Therefore, it is also recommended that a peak hour queue analysis is completed at each of these intersections to determine potential impacts.

3. Future development(s) should also consider traffic safety impacts on the State Highway System due to new pedestrian and bicyclist needs based on new origins or destinations that intersect a State Route. Additionally, multimodal conflict points and change in traffic composition (such as an increase in bicyclists or pedestrians, where features such as shoulders or sidewalks may not exist or are inconsistent with facility design) should be included. The State Route 180 interchanges at Fowler Avenue and Temperance Avenue; and the State Route 180 intersections at De Wolf Avenue, Highland Avenue, and McCall Shawn Monk, Planner- NOTICE OF PREPARATION, EIR
March 18, 2022

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment” Avenue should be included in this analysis.

4. Future development(s) should conduct a Vehicle Miles Traveled (VMT) study for projects that may substantially induce Vehicle Miles Traveled (VMT). Pedestrian and bicycle facilities within the project site should be considered in this study. The project proponents should also consider coordinating with nearby planned bike networks for a larger active transportation network. The City should consider creating a VMT Mitigation Impact Fee to help reduce potential impacts on the State Highway System.

5. For future residential development, Caltrans recommends project proponents consider working with the City to convert a portion of the planned residential units to affordable housing units.

6. The City should establish policies for the installation of Level 2 Electric Vehicle (EV) charging for single- and multi-family residential units as well as DC Fast Charging EV charging stations for retail, commercial, park and public facilities.

7. Caltrans recommends the Project implement multimodal strategies, such as those that originate from Transit-oriented development (TOD), in an effort to further reduce future projects’ traffic related impacts.

8. Active Transportation Plans and Smart Growth efforts support the state’s 2050 Climate goals. Caltrans supports reducing VMT and GHG emissions in ways that increase the likelihood people will use and benefit from a multimodal transportation network.

9. Early engagement with Caltrans is highly requested for future projects that would impact state right-of-way. Furthermore, prior to initiating the traffic study, please include Caltrans in the scoping.

If you have any other questions, please call or email Edgar Hernandez at (559) 981-7436 or [email protected].

Sincerely,
David Padilla, Branch Chief
Transportation Planning – North

Voicemail left from 559-554-5433
From Dirk Charlie, Dunlap Mono Tribal Liaison
Dunlap Mono Tribe, Dunlap, CA
Voicemail transcript as follows: The Dunlap Mono Tribe has no comments for the SEDA area. There is no knowledge of historical or cultural resources for the Dunlap Mono Tribe in this area of the Central Valley, CA. I suggest you contact the following tribes and ask if they are aware of any Historical and/or Cultural resources in the SEDA area:
• Table Mountain Ranch
• Big Sandy
• Traditional Transundi Tribe

Fresno Metropolitan Flood Control District Capturing Stormwater since 1956 k:\letters\environmental impact report letters\nop eir se development area specific plan(dw).docx 5469 E. Olive Avenue • Fresno, CA 93727 • (559) 456-3292 • FAX (559) 456-3194 www.fresnofloodcontrol.org
File 310. “BG”, “BL”, “BM”,
.“CS”, “DS”, “DV”
410.214
March 25, 2022
Ms. Jennifer Clark, Director
c/o Mr. Shawn Monk, Planner
City of Fresno Planning and Development Department
2600 Fresno Street, Rm. 3065
Fresno, CA 93721
Dear Ms. Clark,
Fresno Metropolitan Flood Control District (FMFCD) Comments on the Notice of Preparation of a Program Environmental Impact Report for the Southeast Development Area Specific Plan, Fresno, California
Drainage Areas BG”, “BL”, “BM”, “CS”, “DS”, “DV”
FMFCD staff has reviewed the Notice of Preparation for the Southeast Development Area (SEDA) Specific Plan PEIR, and offers the following comments:

1. In all references to FMFCD, replace the word Municipal with Metropolitan.

2. Portions of the SEDA Specific Plan Area (Plan Area) are currently not located within a planned “drainage area” as shown on the attached Exhibit No. 1. It is FMFCD’s intention to work with the City of Fresno to provide Master Planned drainage area systems to serve the Plan Area.

3. FMFCD recognizes that this Plan Area was previously approved for incorporation into the City in 2006 for urban development by the Local Agency Formation Commission (LAFCo) with several provisions that included preparation of a Specific Plan. Approximately 4200 acres of the Plan Area is outside of the current FMFCD boundary. In conjunction with an adopted Plan Area, the FMFCD Sphere of Influence will also need to be adjusted and this same area annexed by FMFCD to include the Plan Area (see Exhibit No. 1) to ensure appropriate provisions of urban drainage and flood control services. FMFCD’s LAFCo annexation process will require CEQA.

4. All impacts to storm water runoff created by increasing densities in developed areas that effect the capacity of the existing Master Planned storm drainage system must be fully mitigated. The Plan Area encompasses existing Drainage Areas “DS”, “DV”, and portions of Drainage Areas “BG”, “BL”, “BM”, and “CS”. FMFCD is currently analyzing how proposed land use changes within the developed areas of the Plan Area will impact the capacity requirements of existing drainage systems due to increased density. In general, in areas where no drainage facilities have been constructed, the Master Plan can be revised to City of Fresno
Southeast Development Area Specific Plan
March 25, 2022

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k:\letters\environmental impact report letters\nop eir se development area specific plan(dw).docx accommodate new land uses and pipeline alignments proposed within the Plan Area, (i.e. street circulation plans and proposed street widths, open space concepts, and trailway alignments). FMFCD’s Basin “DS”, located at the northwest corner of Clinton and Leonard Avenues, was acquired in anticipation of Clinton Avenue not going through between Leonard and DeWolf Avenues. FMFCD requests the Plan Area maintain this same circulation plan for Clinton Avenue and it not go through west of Leonard Avenue.

5. FMFCD has studied the areas currently not located within a Master Planned area and has located the tentative basin facilities shown on Exhibit No. 1. The City shall incorporate the locations of the tentative basin facilities into the SEDA Proposed Land Use plan. The County of Fresno Business Industrial Campus is currently in the preliminary stages and once complete will be incorporated into FMFCD’s Master Plan; changes in size and/or location of the tentative basin locations shown on Exhibit No. 1 may be effected by this County Plan. The final basin locations will be determined by the on-going Storm Drainage and Flood Control Master Plan planning process. FMFCD will ensure conformance and consistency by providing drainage facilities appropriate to serve the proposed land uses, and develop residential design basins, which include provisions for recreational open spaces, in areas where the basin site is bordered on two or more sides by residential uses.

FMFCD shall be notified of any revisions to the SEDA Proposed Land Use plan as changes will effect the existing as well as new Master Plan drainage systems.

6. The City of Fresno, FMFCD, the County of Fresno, the City of Clovis, and the California State University, Fresno are currently covered as Co-Permittees for Municipal Separate Storm Sewer System (MS4) discharges through National Pollutant Discharge Elimination System (NPDES) General Order No. R5-2016-0040 and NPDES Permit No. CAS0085324 (Storm Water Permit) effective May 17, 2018. The previous Storm Water Permit adopted on May 31, 2013 required the adoption of Stormwater Quality Management Program (SWQMP) that describes the Storm Water Permit implementation actions and CoPermittee responsibilities. That SWQMP was approved by the Central Valley Regional Water Quality Control Board on April 17, 2015 and is effective until adoption of a new SWQMP, which is anticipated within the next two years.

It is FMFCD’s understanding that the City will adopt a Program EIR for the proposed SEDA Specific Plan and that the Program EIR may be used when considering approval of future discretionary actions. The Storm Water Permit requires that Co-Permittees update their CEQA process to incorporate procedures for considering potential stormwater quality impacts when preparing and reviewing CEQA documents. This requirement is found on Provision D.14 of the 2013 Storm Water Permit and in Section 7: Planning and Land Development Program – PLD 3 – Update CEQA Process. The District has created a guidance document that will meet this Storm Water Permit requirement entitled Guidance for Addressing Stormwater Quality for CEQA Review, which has been attached. In an effort to streamline future CEQA processing and maintain compliance with the Storm City of Fresno
Southeast Development Area Specific Plan
March 25, 2022

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k:\letters\environmental impact report letters\nop eir se development area specific plan(dw).docx Water Permit, FMFCD recommends that all future CEQA review within the City of Fresno, including the SEDA area, utilize the attached guidance document.

Additionally, the City’s authority as a land use agency gives the City responsibility to implement certain storm water quality measures. The SWQMP requires a Memorandum of Understanding (MOU) between the District and the City of Fresno that identify those activities best suited for the City to perform related to planning, inspection and enforcement of NPDES Permit requirements. The District has a current MOU adopted in 2014 and this MOU will need to be updated after adoption of the next SWQMP. Since the 2014 MOU was adopted, the following regulatory programs have been adopted by the State Water Resources Control Board that the City must coordinate with FMFCD to effectively implement:
• Amendment to the Water Quality Control Plan for Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California; and
• Amendment to the Water Quality Control Plan for the Sacramento and San Joaquin River Basins for the Control of Pyrethroid Pesticide Discharges.

These regulatory requirements, however, often coincide with other community planning goals. For example, it is noted in the NOP that the Specific Plan may include provisions for sustainable infrastructure, including capture and retention of rainfall and stormwater runoff. Such approaches, when coordinated, can assist in meeting the stormwater quality regulatory requirements listed above. Existing FMFCD Policy requires post-development requirements for areas not served by stormwater basins or areas that discharge to sensitive waterbodies, such as the San Joaquin River. Should the City desire to include sustainable infrastructure provisions in its Specific Plan, coordination between the City and FMFCD must take place to ensure plans are suited to meet stormwater quality regulatory objectives and compatible with drainage standards in the Fresno area.

7. As stated in the NOP, FMFCD is a Responsible Agency for the purposes of CEQA review and has discretionary approval over part of the proposed project. As future projects within the Specific Plan are approved, FMFCD may require project proponents to construct master planned storm drainage facilities. To prevent duplicate CEQA processing, the Program EIR should evaluate impacts related to the construction of master planned storm drainage facilities to the extent feasible.

Additional FMFCD General Comments
FMFCD bears responsibility for storm water management within the Fresno-Clovis metropolitan area, including portions of the area within the Plan Area. Within this area, the community has developed and adopted Storm Drainage and Flood Control Master Plans as shown in the attached City of Fresno
Southeast Development Area Specific Plan
March 25, 2022

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k:\letters\environmental impact report letters\nop eir se development area specific plan(dw).docx Exhibit No. 1. In general, each property contributes its pro-rata share to the cost of the public drainage system. All properties are required to participate in the community system for everyone.

It is this form of participation in the cost and/or construction of the drainage system that will mitigate the impact of development. The subject property shall pay drainage fees pursuant to the Drainage Fee Ordinance prior to approval of any final maps and/or issuance of building permits at the rates in effect at the time of such approval. Please contact FMFCD for a final fee obligation prior to issuance of the construction permits within the Plan Area. For areas located outside a Master Planned area, once these areas are adopted by the FMFCD Board of Directors’, drainage fee payment will be required per the criteria listed above.

The grading of proposed development within the Plan Area shall be designed such that there are not adverse impacts to the passage of major storm flow through that development. Additionally, the development shall provide any surface flowage easements or covenants for any portions of the developing area that cannot convey storm water to public right of way without crossing private property.

If there are to be storm water discharges from the private facilities to FMFCD’s storm drainage system, they shall consist only of storm water runoff and shall be free of solids and debris. Landscape and/or area drains are not allowed to connect directly onto FMFCD’s facilities.

FMFCD will need to review and approve the final improvement plans for all development (i.e. grading, street improvement and storm drain facilities) within the boundaries of the proposed project to insure consistency with the future Storm Drainage Master Plan.

Storm drain easement will be required whenever storm drain facilities are located on private property. No encroachments into the easement will be permitted including, but not limited to, foundations, roof overhangs, swimming pools, and trees.

Where permanent drainage service is available the developer shall verify to the satisfaction of the City and FMFCD that runoff can be safely conveyed to existing Master Plan facilities. Permanent drainage service will not be available if the downstream Master Plan facilities are not constructed or operational and in this instance FMFCD recommends the City require temporary drainage facilities until permanent drainage service is available. Prior to submitting any development proposal, it is recommended to contact FMFCD for information regarding the status of the Master Plan drainage facilities and the availability of permanent drainage service.

FMFCD may require the developer to construct certain storm drain facilities as described in the Storm Drain Master Plan. The cost of construction of Master Plan facilities excluding dedication of storm drainage easements is eligible for credit against the drainage fee of the drainage area served by the facilities. A development agreement shall be executed with FMFCD to affect such credit. Reimbursement provisions, in accordance with the Drainage Fee Ordinance, will be included to the extent that developer’s Master Plan costs for an individual drainage area exceed City of Fresno
Southeast Development Area Specific Plan
March 25, 2022

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k:\letters\environmental impact report letters\nop eir se development area specific plan(dw).docx the fee of said area. Should the facilities cost for such individual area total less than the fee of said area, the difference shall be paid upon demand to the City or FMFCD.

The individual properties may be located within a flood prone area as designated on the most current official Flood Insurance Rate Maps. The maps are available at the Federal Emergency Management Agency (FEMA) Flood Map Service Center.

In an effort to improve storm runoff quality, outdoor storage areas shall be constructed and maintained such that material that may generate contaminants will be prevented from contact with rainfall and runoff and thereby prevent the conveyance of contaminants in runoff into the storm drain system.

FMFCD encourages, but does not require that roof drains from non-residential development be constructed such that they are directed onto and through a landscaped grassy swale area to filter out pollutants from roof runoff.

Runoff from areas where industrial activities, product, or merchandise come into contact with and may contaminate storm water must be directed through landscaped areas or otherwise treated before discharging it off-site or into a storm drain. Roofs covering such areas are recommended. Cleaning of such areas by sweeping instead of washing is to be required unless such wash water can be directed to the sanitary sewer system. Storm drains receiving untreated runoff from such areas that directly connect to FMFCD’s system will not be permitted. Loading docks, depressed areas, and areas servicing or fueling vehicles are specifically subject to these requirements. FMFCD’s policy governing said industrial site NPDES program requirements are available. Contract FMFCD’s Environmental Department for further information regarding these policies related to industrial site requirements.

We look forward to working closely with the City on these items to successfully execute the EIR and Specific Plan for the Southeast Development Area.

If you have any questions or concerns regarding our comments, please feel free to contact the District at (559) 456-3292.

Respectfully,
Denise Wade
Master Plan Special Projects Manager
DW/lrl
Attachment(s)

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FRESNO METROPOLITAN

FLOOD CONTROL DISTRICT
EXHIBIT NO. 1
Prepared by: rebeccal
Date: 3/23/2022
Path: I:\Projects\Accounting\Maps\SoutheastDevelopment.mxd 1 O" = 4300 '
NOTE: THIS MAP IS SCHEMATIC.

DISTANCES, AMOUNT OF CREDITABLE

FACILITIES, AND LOCATION OF INLET
BOUNDARIES ARE APPROXIMATE.

FMFCD BOUNDARY

CITY OF FRESNO SPHERE OF INFLUENCE

DRAINAGE AREA

CITY LIMITS

SOUTHEAST DEVELOPMENT AREA

FMFCD ANNEXATION AREA
BASINS

EXISTING

PROPOSED

TENTATIVE
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Fresno Metropolitan Flood Control District
Guidance for Addressing Stormwater Quality for CEQA Review Stormwater Checklist for CEQA Review
a. Potential impact of project construction on stormwater runoff.

Stormwater runoff from construction activities can have a significant impact on water quality. To build on sites with over one acre of disturbed land, property owners must obtain coverage under the California Construction General Permit for Discharges of Stormwater (CGP). The CGP is issued by the State Water Resources Control Board (SWRCB). The CGP requires sites that do not qualify for an erosivity waiver to create a Stormwater Pollution Prevention Plan (SWPPP).

The SWPPP is a site-specific plan that is designed to control the discharge of pollutants from the construction site to local storm drains and waterways.
b. Potential impact of project post-construction activity on stormwater runoff.

FMFCD operates the Regional Stormwater Mitigation System, which consists of facilities to handle stormwater runoff and non-stormwater discharges in the FMFCD service area. However, river discharging drainage areas and drainage areas without basin service are subject to FMFCD Policy: Providing for Compliance with Post-Development and Industrial Storm Water Pollution Control Requirements (Policy).

Development and redevelopment projects can result in discharge of pollutants to receiving waters. Pollutants of concern for a project site depend on the following factors:
• Project location;
• Land use and activities that have occurred on the project site in the past; • Land use and activities that are likely to occur in the future; and • Receiving water impairments.

As land use activities and site design practices evolve, particularly with increased incorporation of stormwater quality BMPs, characteristic stormwater runoff concentrations and pollutants of concern from various land use types are also likely to change.

Typical Pollutants of Concern and Sources for Post-Development Areas Pollutant Potential Sources
Sediment (total suspended
solids and turbidity), trash and
debris (gross solids and
floatables)
Streets, landscaped areas, driveways, roads, construction activities, atmospheric deposition, soil erosion (channels and slopes)
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Pesticides and herbicides Residential lawns and gardens, roadsides, utility right-ofways, commercial and industrial landscaped areas, soil wash-off
Organic materials/oxygen
demanding substances
Residential laws and gardens, commercial landscaping,
animal waste
Metals Automobiles, bridges, atmospheric deposition, industrial areas, soil erosion, metal surfaces, combustion processes Oil and grease, organics
associated with petroleum
Roads, driveways, parking lots, vehicle maintenance areas, gas stations, illicit dumping to storm drains, automobile emissions, and fats, oils, and grease from restaurants
Bacteria and viruses Lawns, roads, leaking sanitary sewer lines, sanitary sewer cross-connections, animal waste (domestic and wild),
septic systems, homeless encampments,
sediments/biofilms in storm drain system
Nutrients Landscape fertilizers, atmospheric deposition, automobile exhaust, soil erosion, animal waste, detergents
Source: Adapted from USEPA, 1999 (Preliminary Data Summary of Urban Storm Water BMPs) FMFCD’s Post-Development Standards Technical Manual provides guidance for implementing stormwater quality Best Management Practices (BMPs) for drainage areas subject to the Policy, with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The Post-Development Standards Technical Manual addresses the following objectives and goals:
• Minimize impervious surfaces and directly connect impervious surfaces in areas of new development and redevelopment, and where feasible, to maximize on-site infiltration of stormwater runoff;
• Implement pollution prevention methods supplemented by pollutant source controls and treatment, and where practical, use strategies that control the sources of pollutants or constituents (i.e., where water initially meets the ground) to minimize the transport of runoff and pollutants offsite and into MS4s;
• Preserve, and where possible create or restore, areas that provide important water quality benefits, such as riparian corridors, wetlands, or buffer zones • Limit disturbances of natural water bodies and natural drainage systems by development, including roads, highways, and bridges;
• Identify and avoid development in areas that are particularly susceptible to erosion and sediment loss or establish guidance that protects areas from erosion and sediment loss; • Implement source and structural controls as necessary and appropriate to protect downstream receiving water quality from increased pollutant loadings and flows (hydromodification concepts) from new development and significant redevelopment; j:\environmental\swqmp implementation\7 planning and land development program\pld3 update to ceqa process\ceqa review guidance.docx

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• Control the post-development peak stormwater runoff discharge rates and velocities to maintain or reduce pre-development downstream erosion and to protect downstream habitat; and
• Consider integration of Low Impact Development (LID) principles into project design.

The Post-Development Standards Technical Manual describes the stormwater management requirements for Priority Projects, which are identified as meeting one or more of the following and discharge to the San Joaquin River or do not have basin service:
• Home subdivisions of 10 housing units or more;
• Commercial developments greater than 100,000 square feet; • Automotive repair shops;
• Restaurants;
• Parking lots 5,000 square feet or greater with 25 or more parking spaces and potentially exposed to urban runoff;
• Streets and roads;
• Retail gasoline outlets (RGOs); and
• Significant redevelopment projects, which are developments that result in creation or addition of at least 5,000 square feet of impervious surface on an already developed site.

Significant redevelopment includes, but is not limited to, expansion of a building footprint or addition or replacement of a structure, structural developing including an increase in gross floor area and/or exterior construction or remodeling, replacement of impervious surface that is not part of a routine maintenance activity, and land disturbing activities related with structural or impervious surfaces. Where significant redevelopment results in an increase of less than 50 percent of the impervious surfaces of a previously existing development and the existing development was not subject to Post-Construction Standards, only the proposed alteration must meet the requirements of the PostDevelopment Standards Technical Manual.

All Priority Projects must mitigate the Stormwater Quality Design Volume (SWQDV) or Stormwater Quality Design Flow (SWQDF) through LID- or treatment-based stormwater quality BMPs or a combination thereof.

For new development or significant redevelopment projects for restaurants with less than 5,000 square feet, the project applicant must meet all the requirements of the Post-Development Standards Technical Manual except for mitigating the SWQDV or SWQDF and implementing stormwater quality BMPs.

The Post-Development Standards Technical Manual can be found on FMFCD’s website here:
http://www.fresnofloodcontrol.org/wp-content/uploads/2014/11/Post-Development-StandardsTechnical-Manual.pdf j:\environmental\swqmp implementation\7 planning and land development program\pld3 update to ceqa process\ceqa review guidance.docx

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c. Potential for discharge of stormwater from areas from material storage, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas or loading docks, or other outdoor work areas.

Development projects may create potential impacts to stormwater from non-stormwater discharge from areas with material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas or loading docks, or other outdoor work area.

Some materials, such as those containing heavy metals or toxic compounds, are of more concern than other materials. Toxic and hazardous materials must be prevented from coming in contact with stormwater runoff. Non-toxic or non-hazardous materials, such as debris and sediment, can also have significant impacts on receiving waters. Contact between non-toxic or non-hazardous materials and stormwater runoff should be limited, and such materials prevented from being discharged with stormwater runoff. To help mitigate these potential impacts, BMPs should be included to prevent discharges from leaving the property.

Refer to FMFCD Post-Development Standards Technical Manual for more information or go to http://water.epa.gov/polwaste/nps/urban.cfm.
d. Potential for discharge of stormwater to impact the beneficial uses of the receiving waters or areas that provide water quality benefits.

Identify receiving waters and describe activities that may impact the beneficial uses of the receiving waters or that project water quality benefits. Project that can impact beneficial uses or receiving waters may be mitigated by implementation of the FMFCD Post-Development Standards Technical Manual.
e. Potential for the discharge of stormwater to cause significant harm on the biological integrity of the water ways and water bodies.

Conservation of natural areas, soils, and vegetation helps to retain numerous functions of predevelopment hydrology, including rainfall interception, infiltration, and evapotranspiration. Each project site possesses unique topographic, hydrologic, and vegetative features, some of which are more suitable for development than others. Sensitive areas, such as streams and their buffers, floodplains, wetlands, steep slopes, and highly-permeable soils, should be protected and/or restored. Slopes can be a major source of sediment and should be properly protected and stabilized. Locating development in less sensitive areas of a project site and conserving naturally vegetated areas can minimize environmental impacts from stormwater runoff.

The evaluation of a project’s effect on sensitive natural communities should encompass aquatic and wetland habitats. Consider “aquatic and wetland habitat” as examples of sensitive habitat. j:\environmental\swqmp implementation\7 planning and land development program\pld3 update to ceqa process\ceqa review guidance.docx

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f. Potential for significant changes in the flow velocity or volume of stormwater runoff that can cause environmental harm.

The evaluation of a project’s effect on drainage patterns should refer to the FMFCD’s Storm Drainage and Flood Control Master Plan and have their project reviewed by FMFCD to assess the significance of altering existing drainage patterns and to develop any mitigation measures in addition to our stormwater mitigation system. The evaluation should also consider any potential for streambed or bank erosion downstream from the project. g. Potential for significant increases in erosion of the project site or surrounding areas.

Jennifer Clark c/o Shawn Monk
Planning and Development Department
2600 Fresno Street, Suite 3065
Fresno, CA 93721
March 25, 2022
Sent via Email
Dear Ms. Jennifer Clark and Mr.Shawn Monk,
We are writing to provide comments in response to the Notice of Preparation (“NOP”) of a Program Environmental Impact Report (“PEIR”) for the Southeast Development Area (SEDA) in the City of Fresno. The undersigned organizations work closely alongside community leaders throughout Southeast Fresno. We aim to support and elevate resident-identified priorities and solutions while also dismantling the systemic barriers that have historically excluded low-income communities and Black, Indigenous, and People of Color (BIPOC) communities.

First, given the significance of the SEDA to the future development of Southeast Fresno communities, it is of the utmost importance that the City proactively and meaningfully engage residents within and around the planning area. This means that the City must incorporate residents' input into the SEDA and EIR by revising land use designations to include community-led development like higher density housing, green space, affordable commercial and residential spaces, and so on. It must also have policies and implementation measures for active investment into Southeast Fresno neighborhoods by businesses and the City alike in essential infrastructure, services, amenities, and community greening. To do less is to perpetuate the long-held City practice of denying Southeast Fresno residents their rights to shape the future of their neighborhoods and access to opportunity on the same terms as other Fresno residents.

Below you will find additional comments in response to the Notice of Preparation:

I. The Proposed Land Use Map is Inconsistent with Local and State Climate, Housing, and Transportation Goals and Policies to Build Equitable Climate Resilient Communities
As previously noted, it is unclear and of significant concern to what extent authentic public participation took place during this process from over a decade ago. The former process took place at the tail end of the housing bubble when building single-family homes in the outskirts of the city limits was the priority and norm. This type of “leapfrog” development remains reflected in the SEDA land use map as a large portion of the 9,000 acres is zoned for low-density single-family housing. This is inconsistent with the current climate, housing, and transportation goals that aim to build communities with a variety of development and density to make them accessible to various incomes and for communities to get around by alternative modes of transportation.

Further, the second-largest land use is zoned for flexible research and development, which leaves space for more light industrial use, further industrializing south Fresno BIPOC communities. This current process is in stark contrast with other specific plans prepared and adopted by the City in recent years, which have emphasized resident self-determination in shaping their built environment, planning for complete and healthy communities, smart growth-promoting land use compatibility, and investment strategies and implementation measures designed to bring those plans’ vision to life. The City must not proceed with its efforts to further cement unjust and exclusive land-use patterns in City planning practices.

Fourteen years later, we have learned that this growth pattern is economically and environmentally unsustainable as the City now struggles to balance the need to build out the infrastructure and maintain public services in these communities while attending to decades of deferred maintenance in established neighborhoods. This is reflected in the 2015 General Plan praised for limiting unsustainable sprawl growth and focusing on efficient infill development . 1 II. The Draft SEDA Proposed Land Use Map Violates Fair Housing, and Civil Rights Laws
The Draft SEDA Proposed Land Use Map lacks community input from the populations and people most affected by the SEDA. Nearby communities and residents have not had any meaningful engagement to develop the proposed land use map. And we have yet to see any evidence for community engagement or a community-guided land use map. The City should not proceed with an EIR for the SEDA until it corrects these failings.

Government Code section 8899.50(b) requires public agencies in California to affirmatively further fair housing in all policies and programs relating to housing and community development and “take no action that is materially inconsistent” with this obligation. Affirmatively further fair housing means:

Taking ‘meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict 1 Defined as being within the city limits by December 31, 2012. City of Fresno General Plan 2015, Objective UF-12.
access to opportunity based on a protected characteristic. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights laws and fair housing laws. Gov. Code § 8899.50(a)
As drafted, the land use map will mostly exclusively allow for medium to low-density single-family housing. Since the 1910s, this type of housing was promoted by local and federal agencies to further segregate low-income families from living in the more affluent neighborhoods as was known that these families would not be able to afford to purchase a home. These exclusive practices are even more evident as rankings from The Urban Institute ranked Fresno 253rd of 274 cities in overall inclusion, meaning we are one of the country's largest, most exclusive cities.

Rather than learning from history, the City perpetuates these same exclusionary land-use practices by not including relatively more affordable higher-density housing. Thus, ensuring lower-income populations cannot live in this community.

Additionally, the City exposes residents to environmental hazards by applying industrial and business park land-use designations to a thousand acres within the SEDA area. It conflicts with the City’s duty to avoid actions materially inconsistent with the City’s duty to AFFH. See California Housing and Community Development’s, Affirmatively Furthering Fair Housing:

Guidance for All Public Entities and For Housing Elements, p. 16 (citing “zoning or siting toxic or polluting land uses or projects near a disadvantaged community” and “lack of investment in concentrated areas of poverty” as actions which are materially inconsistent with an agency’s duty to AFFH).

III. Comments Relating to EIR Content
Should the City choose to proceed to develop a PEIR based on the Proposed Land Use Map, the City of Fresno must thoroughly assess the numerous significant impacts the SEDA will have on the environment, public health, air quality, economic feasibility, and housing for Southeast Fresno residents. The PEIR must adopt enforceable mitigation measures to avoid and minimize those impacts to the fullest extent possible. Further, the City must assess alternatives to the proposed project, including alternative land use designations that protect communities from developing new industrial land uses near sensitive land uses and provide a variety of housing opportunities for all incomes and populations. Specifically, the City must ensure the SEDA PEIR:
● Accurately captures and analyzes baseline conditions and potentially significant project-specific and cumulative impacts within and adjacent to the planning area; ● Identifies plan alternatives, which would mitigate negative impacts of plan implementation and promote positive outcomes aligned with community members’ expressed vision and priorities;
● Identifies and adopts all feasible and enforceable mitigation measures that avoid and reduce negative impacts;
● Analyzes and creates mitigation measures consistent with all applicable laws, including but not limited to state and federal fair housing, civil rights, and climate laws like Senate Bill 743 and;
● Meaningfully engages the public through a robust, accessible, and responsive process.

IV. Conclusion:

We urge City leaders and decision-makers to postpone developing the SEDA and instead reallocate Staff’s limited capacity to finalize the Central Southeast Specific Plan and South Central Specific Plan, and, more notably, prepare to update the Housing Element on December 31, 2023, as required by California law . City leaders should also be motivated to implement 2 already adopted plans to avoid wasting City resources by having these documents, which take hundreds of thousands of dollars and countless staff hours to develop, “sit on the shelf.” In jumping over other projects in line, SEDA will only facilitate “leapfrog” development perpetuating Fresno’s unsustainable exclusive development patterns to the detriment of established neighborhoods.

Thank you for your consideration of these comments. Please contact us should you wish to find a time to discuss them.

Sincerely,
Karla Martinez
Leadership Counsel for Justice and Accountability
Nayamin Martinez
CCEJN
Kimberly McCoy
Fresno Building Healthy Communities
Ruben Espinoza
Fresno Barrios Unidos
2 As required by California Government Section Code 65588.

March 24, 2022
Jennifer Clark
c/o Shawn Monk
City of Fresno
Planning and Development Department
2600 Fresno Street, Suite 3065
Fresno, CA 93721
Project: Notice of Preparation of a Program Environmental Impact Report for the Southeast Development Area Specific Plan
District CEQA Reference No: 20220202
Dear Ms. Clark:

The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the City of Fresno’s (City) Notice of Preparation (NOP) of a Program Environmental Impact Report (PEIR) for the Southeast Development Area Specific Plan (SEDA) (Project). Per the NOP, the proposed Project would designate land uses, establish a planning framework, and development standards to facilitate and guide future development within the approximately 9,000-acre planning area through the year 2050. The Project is located in the southeast portion of the City. The Project proposes revised land use and zoning designations, specific design guidelines, and process improvements. Future development would be required to comply with the proposed specific plan land use designations, development standards, and policy framework.

The District offers the following comments:
1) Land Use Planning
Nearly all development projects within the San Joaquin Valley Air Basin, from Specific Plans to individual projects have the potential to generate air pollutants, making it more difficult to attain state and federal ambient air quality standards. Land use decisions are critical to improving air quality within the San Joaquin Valley Air Basin because land use patterns greatly influence transportation needs, and motor vehicle emissions are the largest source of air pollution in the Valley. Land use decisions and project design elements such as preventing urban sprawl, encouraging mix-use development, and project design elements that reduce vehicle miles traveled (VMT) have proven to be beneficial for air quality.

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The District recommends that the PEIR incorporate strategies that reduce VMTs and require the cleanest available heavy heavy-duty trucks (HHD) and vehicles, including zero and near-zero technologies. VMTs can be reduced through encouragement of mix-use development, walkable communities, etc. Additional design element options can be found at: http://www.valleyair.org/transportation/Mitigation-Measures.pdf In addition, the District recommends that the PEIR incorporate strategies that will advance implementation of the best practices listed in Tables 5 and 6 of California Air Resource Board’s (CARB’s) Freight Handbook Concept Paper, to the extent feasible.

This document compiles best practices designed to address air pollution impacts as “practices” which may apply to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities. The concept paper is available at:
https://ww2.arb.ca.gov/sites/default/files/2020-03/2019.12.12%20- %20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf 2) Project Siting
The SEDA is the blueprint for future growth and provides guidance for the community’s development. Without appropriate mitigation and associated policy, future development projects within the City may contribute to negative impacts on air quality due to increased traffic and ongoing operational emissions. Appropriate project siting helps ensure there is adequate distance between differing land uses, which can prevent or reduce localized and cumulative air pollution impacts from business operations that are in close proximity to receptors (e.g. residences, schools, health care facilities, etc.). SEDA siting-related goals, policies, and objectives should include measures and concepts outlined in the following resources:
 CARB’s Air Quality and Land Use Handbook: A Community Health Perspective. The document includes tables with recommended buffer distances associated with various types of common sources (e.g. distribution centers, chrome platers, gasoline dispensing facilities, etc.), and can be found at: https://ww3.arb.ca.gov/ch/handbook.pdf
 CARB’s Freight Handbook Concept Paper: This document compiles best practices designed to address air pollution impacts, which may apply to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities, and can be found at:
https://ww2.arb.ca.gov/sites/default/files/2020-03/2019.12.12%20- %20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf San Joaquin Valley Air Pollution Control District Page 3 District Reference No. 202220202
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3) Criteria Pollutant Emissions
At the federal level under the National Ambient Air Quality Standards (NAAQS), the District is designated as extreme nonattainment for the 8-hour ozone standards and serious nonattainment for the particulate matter less than 2.5 microns in size (PM2.5) standards. At the state level under California Ambient Air Quality Standards (CAAQS), the District is designated as nonattainment for the 8-hour ozone, PM10, PM2.5 standards.

As such, the District recommends that the PEIR stipulate that future development projects within the SEDA identify and characterize project construction and operational air emissions. The District recommends the air emissions be compared to the following California Environmental Quality Act (CEQA) significance thresholds for annual emissions of criteria pollutants: 100 tons per year of carbon monoxide (CO), 10 tons per year of oxides of nitrogen (NOx), 10 tons per year of reactive organic gases (ROG), 27 tons per year of oxides of sulfur (SOx), 15 tons per year of particulate matter with an aerodynamic diameter less than or equal to a nominal 10 or 2.5 microns (PM10 or PM2.5). The District recommends that future proposed projects be mitigated to the extent feasible, and that future proposed projects with air emissions above the aforementioned thresholds be mitigated to below these thresholds.

The District understands that the SEDA is a program-level Project where future individual project-specific data may not be available at this time. As such, the PEIR should include a discussion of policies, which when implemented, will require assessment and characterization of project-level emissions, and subsequently require mitigation of air quality impacts to the extent feasible at the individual project-specific level. Environmental reviews of potential impacts on air quality should incorporate the following items:
3a) Construction Emissions
Construction air emissions are short-term emissions generated from construction activities such as mobile heavy-duty diesel off-road equipment, and should be evaluated separately from operational emissions. If air emissions from ongoing operational activities occur within the same year as construction emissions, those emissions should be combined.

Recommended Measure: To reduce impacts from construction-related diesel exhaust emissions, the Project should utilize clean off-road construction equipment, including the latest tier equipment as feasible.

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3b) Operational Emissions
Operational (ongoing) air emissions from mobile sources and stationary sources should be analyzed separately. For reference, the District’s annual criteria thresholds of significance are listed above.

Recommended Mitigation Measure: At a minimum, project related impacts on air quality should be reduced to levels of significance through incorporation of design elements such as the use of cleaner heavy-duty trucks and vehicles, measures that reduce VMTs, and measures that increase energy efficiency. More information on transportation mitigation measures can be found at:
http://www.valleyair.org/transportation/Mitigation-Measures.pdf. 3c) Recommended Model for Quantifying Air Emissions
Project related criteria pollutant emissions from construction and operational sources should be identified and quantified. Emissions analysis should be performed using CalEEMod (California Emission Estimator Model), which uses the most recent approved version of relevant Air Resources Board (ARB) emissions models and emission factors. CalEEMod is available to the public and can be downloaded from the CalEEMod website at: www.caleemod.com. 4) Health Risk Screening/Assessment
To determine potential health impacts on surrounding receptors (residences, businesses, hospitals, day-care facilities, health care facilities, etc.) a Prioritization and/or a health risk assessment (HRA) should be performed for future projects within the SEDA. These health risk determinations should quantify and characterize potential Toxic Air Contaminant (TAC) air pollutants identified by the Office of Environmental Health Hazard Assessment (OEHHA) and CARB (that pose a present or potential hazard to human health.

Health risk analyses should include all potential air emissions from the project, which include emissions from construction of the facility, including multi-year construction, as well as ongoing operational activities of the facility. Note, two common sources of TACs can be attributed to diesel exhaust emitted from heavy-duty off-road earth moving equipment during construction, and from ongoing operation of heavy-duty onroad trucks. A list of TACs identified by OEHHA and CARB can be found at:
https://ww2.arb.ca.gov/resources/documents/carb-identified-toxic-air-contaminants San Joaquin Valley Air Pollution Control District Page 5 District Reference No. 202220202
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Prioritization (Screening Health Risk Assessment):

A “Prioritization” is the recommended method for a conservative screening-level health risk assessment. The Prioritization should be performed using the California Air Pollution Control Officers Association’s (CAPCOA) methodology. The District recommends that a more refined analysis, in the form of an HRA, be performed for any project resulting in a Prioritization score of 10 or greater. This is because the prioritization results are a conservative health risk representation, while the detailed HRA provides a more accurate health risk evaluation.

To assist land use agencies and project proponents with Prioritization analyses, the District has created a prioritization calculator based on the aforementioned CAPCOA guidelines, which can be found here:
http:www.valleyair.org/busind/pto/emission_factors/Criteria/Toxics/Utilities/PRIORITI ZATION%20RMR%202016.XLS
Health Risk Assessment:

Prior to performing an HRA, it is strongly recommended that land use agencies/development project proponents contact the District to review the proposed health risk modeling protocol. A development project would be considered to have a potentially significant health risk if the HRA demonstrates that the project-related health impacts would exceed the Districts significance threshold of 20 in a million for carcinogenic risk, or 1.0 for either the Acute or Chronic Hazard Indices. A project with a significant health risk would trigger all feasible mitigation measures. The District strongly recommends that development projects that result in a significant health risk not be approved by the land use agency.

The District is available to review HRA protocols and analyses. For HRA submittals please provide the following information electronically to the District for review:
 HRA AERMOD model files
 HARP2 files
 Summary of emissions source locations, emissions rates, and emission factor calculations and methodology.

For assistance, please contact the District’s Technical Services Department by:
 E-Mailing inquiries to: [email protected]
 Calling (559) 230-5900
Recommended Measure: Development projects resulting in toxic air contaminant emissions should be located an adequate distance from residential areas and other San Joaquin Valley Air Pollution Control District Page 6 District Reference No. 202220202
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sensitive receptors in accordance to CARB's Air Quality and Land Use Handbook: A Community Health Perspective located at https://ww3.arb.ca.gov/ch/handbook.pdf. 5) Ambient Air Quality Analysis
An Ambient Air Quality Analysis (AAQA) uses air dispersion modeling to determine if emissions increases from a project will cause or contribute to a violation of State or National Ambient Air Quality Standards. The District recommends that the EIR requires an AAQA to be performed for any future development project with emissions that exceed 100 pounds per day of any pollutant.

An acceptable analysis would include emissions from both project-specific permitted and non-permitted equipment and activities. The District recommends consultation with District staff to determine the appropriate model and input data to use in the analysis.

Specific information for assessing significance, including screening tools and modeling guidance, is available online at the District’s website:
www.valleyair.org/ceqa.
6) Voluntary Emission Reduction Agreement
Future development projects within the SEDA could have a significant impact on air quality. The District recommends the PEIR also include a discussion on the feasibility of implementing a Voluntary Emission Reduction Agreement (VERA) for this Project.

A VERA is a mitigation measure by which the project proponent provides pound-forpound mitigation of emissions increases through a process that develops, funds, and implements emission reduction projects, with the District serving a role of administrator of the emissions reduction projects and verifier of the successful mitigation effort. To implement a VERA, the project proponent and the District enter into a contractual agreement in which the project proponent agrees to mitigate Project specific emissions by providing funds for the District’s incentives programs. The funds are disbursed by the District in the form of grants for projects that achieve emission reductions. Thus, project-related impacts on air quality can be mitigated. Types of emission reduction projects that have been funded in the past include electrification of stationary internal combustion engines (such as agricultural irrigation pumps), replacing old heavy-duty trucks with new, cleaner, more efficient heavy-duty trucks, and replacement of old farm tractors.

In implementing a VERA, the District verifies the actual emission reductions that have been achieved as a result of completed grant contracts, monitors the emission San Joaquin Valley Air Pollution Control District Page 7 District Reference No. 202220202
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reduction projects, and ensures the enforceability of achieved reductions. After the project is mitigated, the District certifies to the Lead Agency that the mitigation is completed, providing the Lead Agency with an enforceable mitigation measure demonstrating that project-specific regional emissions have been mitigated to less than significant. To assist the Lead Agency and project proponent in ensuring that the environmental document is compliant with CEQA, the District recommends the Draft PEIR includes an assessment of the feasibility of implementing a VERA. 7) Truck Routing
Truck routing involves the path/roads heavy-duty trucks take to and from their destination. The air emissions from heavy-duty trucks can impact residential communities and sensitive receptors.

The District recommends the City evaluate heavy-duty truck routing patterns as they consider the detailed zoning changes within the scope of the Project, with the aim of limiting emission exposure to residential communities and sensitive receptors. This evaluation would consider the current truck routes, the quantity and type of each truck (Medium Heavy Duty (MHD), (HHD), etc.), the destination and origin of each trip, traffic volume correlation with the time of day or the day of the week, overall VMT, and associated exhaust emissions. The truck routing evaluation would also identify alternative truck routes and their impacts on VMT, GHG emissions, and air quality. 8) Cleanest Available Truck
The San Joaquin Valley will not be able to attain stringent health-based federal air quality standards without significant reductions in emissions from HHD Trucks, the single largest source of NOx emissions in the San Joaquin Valley. The District recently adopted the 2018 PM2.5 Plan, which includes significant new reductions from HHD Trucks, including emissions reductions by 2023 through the implementation of the CARB Statewide Truck and Bus Regulation, which requires truck fleets operating in California to meet the 2010 0.2 g/bhp-hr NOx standard by 2023. Additionally, to meet the federal air quality standards by the 2020 to 2024 attainment deadlines, the District’s Plan relies on a significant and immediate transition of heavy-duty truck fleets to zero or near-zero emissions technologies, including the near-zero truck standard of

0.02 g/bhp-hr NOx established by the CARB.

If future development projects include Industrial (e.g. warehouse, distribution)which typically generate a high volume of heavy duty truck traffic traveling to-and-from the project location at longer trip length distances for potential distribution, the District recommends that the following mitigation measures be considered by the City for inclusion in the PEIR for project related operational emissions.

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 Recommended Measure: Fleets associated with project operational activities utilize the cleanest available HHD truck technologies, including zero and nearzero (0.02 g/bhp-hr NOx) technologies as feasible.  Recommended Measure: All on-site service equipment (cargo handling, yard hostlers, forklifts, pallet jacks, etc.) utilize zero-emissions technologies as feasible.

In addition, the District recommends that the City include mitigation measures to reduce project related operational impacts through incorporation of design elements, for example, increased energy efficiency, reducing vehicle miles traveled, etc. More information on mitigation measures can be found on the District’s website at: http://www.valleyair.org/transportation/ceqa_idx.htm. 9) Reduce Idling of Heavy-Duty Trucks
The goal of this strategy is to limit the potential for localized PM2.5 and toxic air quality impacts associated with failure to comply with the state’s Heavy Duty anti-idling regulation (e.g limiting vehicle idling to specific time limits). The diesel exhaust from excessive idling has the potential to impose significant adverse health and environmental impacts. Therefore, efforts to ensure compliance of the anti-idling regulation, especially near sensitive receptors, is important to limit the amount of idling, which will result in air quality benefits.
10)Electric On-Site Off-Road and On-Road Equipment
Future development may have the potential to result in increased use of off-road equipment (i.e. forklifts) and/or on-road equipment (i.e. mobile yard trucks with the ability to move materials). The District recommends the City advise the project proponent to utilize electric or zero emission off-road and on-road equipment used onsite for this Project. 11) Under-fired Charbroilers
Future development projects for restaurants with under-fired charbroilers may pose the potential for immediate health risk, particularly when located in densely developed locations near sensitive receptors. Since the cooking of meat can release carcinogenic PM2.5 species like polycyclic aromatic hydrocarbons, controlling emissions from new under-fired charbroilers will have a substantial positive impact on public health. The air quality impacts on neighborhoods near restaurants with underfired charbroilers can be significant on days when meteorological conditions are San Joaquin Valley Air Pollution Control District Page 9 District Reference No. 202220202
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stable, when dispersion is limited and emissions are trapped near the surface within the surrounding neighborhoods. This potential for neighborhood-level concentration of emissions during evening or multi-day stagnation events raises air quality concerns.

Furthermore, reducing commercial charbroiling emissions is essential to achieving attainment of multiple federal PM2.5 standards and associated health benefits in the Valley. Therefore, the District recommends that the PEIR include a measure requiring the assessment and potential installation, as technologically feasible, of particulate matter emission control systems for new large restaurants operating under-fired charbroilers. The District is available to assist the City and project proponents with this assessment. Additionally, to ease the financial burden for Valley businesses, the District is currently offering substantial incentive funding that covers the full cost of purchasing, installing, and maintaining the system for up to two years. Please contact the District at (559) 230-5800 or [email protected] for more information. 12)Health Impact Discussion
As required by the recent decision in Sierra Club v. County of Fresno (2018) 6 Cal.4th 502, a reasonable effort to discuss relevant specifics regarding the connection between potential adverse air quality impacts from the Project with the likely nature and magnitude of potential health impacts may be required. If the potential health impacts from the Project cannot be specifically correlated, explain what is known and why, given scientific constraints, potential health impacts cannot be translated. 13)Vegetative Barriers and Urban Greening
For future development projects within the SEDA, and at strategic locations throughout the SEDA in general, the District suggests the City consider incorporating vegetative barriers and urban greening as a measure to further reduce air pollution exposure on sensitive receptors (i.e. residences, schools, healthcare facilities).

While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, vegetative barriers have been shown to be an additional measure to potentially reduce a population’s exposure to air pollution through the interception of airborne particles and the update of gaseous pollutants. Examples of vegetative barriers include, but not limited to the following:
trees, bushes, shrubs, or a mix of these. Generally, a higher and thicker vegetative barrier with full coverage will result in greater reductions in downwind pollutant concentrations. In the same manner, urban greening is also a way to help improve air quality and public health in addition to enhancing the overall beautification of a project with drought resistant low maintenance greenery.

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14)On-site Solar Deployment
It is the policy of the State of California that renewable energy resources and zerocarbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045. While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, the production of solar energy is contributing to improving air quality and public health.

The District suggests that the City consider the feasibility of incorporating solar power systems, as an emission reduction strategy for future development projects within the SEDA.
15)Electric Vehicle Charger
To support and accelerate the installation of electric vehicle charging equipment and development of required infrastructure, the District offers incentives to public agencies, businesses, and property owners of multi-unit dwellings to install electric charging infrastructure (Level 2 and 3 chargers). The purpose of this incentive program is to promote clean air alternative-fuel technologies and the use of low or zero-emission vehicles. The District suggests that the City and project proponents install electric vehicle chargers at project sites, and at strategic locations throughout the SEDA.

Please visit www.valleyair.org/grants/chargeup.htm for more information. 16)Nuisance Odors
While offensive odors rarely cause any physical harm, they can be unpleasant, leading to considerable distress among the public and often resulting in citizen complaints.

The City should consider all available pertinent information to determine if future development projects could have a significant impact related to nuisance odors.

Nuisance odors may be assessed qualitatively taking into consideration the proposed business or industry type and its potential to create odors, as well as proximity to offsite receptors that potentially would be exposed to objectionable odors. The intensity of an odor source’s operations and its proximity to receptors influences the potential significance of malodorous emissions. Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.

According to the District Guidance for Assessing and Mitigating air Quality Impacts (GAMAQI), a significant odor impact is defined as more than one confirmed complaint per year averaged over a three-year period, or three unconfirmed complaints per year San Joaquin Valley Air Pollution Control District Page 11 District Reference No. 202220202
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averaged over a three-year period. An unconfirmed complaint means that either the odor or air contaminant release could not be detected, or the source of the odor could not be determined.

As the future development projects that will fall within the SEDA do not yet exist and cannot be evaluated against the above complaint-driven odor significance criteria, the City should determine which business or industry types have historically triggered the significance criteria, and stipulate odor mitigation measures in the PEIR as conditions of approval for those business and industry types. The District recommends that any project proponent whose project is determined to have a potentially significant odor impact should be required to draft and maintain an Odor Management Plan (OMP) as a mitigation measure in the PEIR.
17)District Rules and Regulations
The District issues permits for many types of air pollution sources and regulates some activities not requiring permits. A project subject to District rules and regulation would reduce its impacts on air quality through compliance with regulatory requirements. In general, a regulation is a collection of rules, each of which deals with a specific topic.

Here are a couple of example, Regulation II (Permits) deals with permitting emission sources and includes rules such as District permit requirements (Rule 2010), New and Modified Stationary Source Review (Rule 2201), and implementation of Emission Reduction Credit Banking (Rule 2301).

The list of rules below is neither exhaustive nor exclusive. Current District rules can be found online at: www.valleyair.org/rules/1ruleslist.htm. To identify other District rules or regulations that apply to this Project or to obtain information about District permit requirements, the applicant is strongly encouraged to contact the District’s Small Business Assistance (SBA) Office at (559) 230-5888. 17a) District Rules 2010 and 2201 - Air Quality Permitting for Stationary Sources Stationary Source emissions include any building, structure, facility, or installation which emits or may emit any affected pollutant directly or as a fugitive emission.

District Rule 2010 requires operators of emission sources to obtain an Authority to Construct (ATC) and Permit to Operate (PTO) from the District. District Rule 2201 requires that new and modified stationary sources of emissions mitigate their emissions using best available control technology (BACT).

Future development projects may be subject to District Rule 2010 (Permits Required) and Rule 2201 (New and Modified Stationary Source Review) and may San Joaquin Valley Air Pollution Control District Page 12 District Reference No. 202220202
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require District permits. Prior to construction, the project proponents should submit to the District an application for an Authority to Construct (ATC).

Recommended Mitigation Measure: For projects subject to permitting by the San Joaquin Valley Air Pollution Control District, demonstration of compliance with District Rule 2201 shall be provided to the City before issuance of the first building permit.

For further information or assistance, the project proponent may contact the District’s Small Business Assistance (SBA) Office at (559) 230-5888. 17b) District Rule 9510 (Indirect Source Review)
The purpose of District Rule 9510 is to reduce the growth in both NOx and PM10 emissions associated with development and transportation projects from mobile and area sources associated with construction and operation of development projects. The rule encourages clean air design elements to be incorporated into development projects. In case the proposed development project clean air design elements are insufficient to meet the targeted emission reductions, the rule requires developers to pay a fee used to fund projects to achieve off-site emissions reductions.

Accordingly, future development project(s) within the SEDA would be subject to District Rule 9510 if upon full buildout, the project would equal or exceed any of the following applicability thresholds, depending on the type of development and the public agency approval mechanism:

Table 1: ISR Applicability Thresholds
Development
Type
Discretionary
Approval Threshold
Ministerial Approval /
Allowed Use / By Right
Thresholds
Residential 50 dwelling units 250 dwelling units
Commercial 2,000 square feet 10,000 square feet
Light Industrial 25,000 square feet 125,000 square feet Heavy Industrial 100,000 square feet 500,000 square feet Medical Office 20,000 square feet 100,000 square feet
General Office 39,000 square feet 195,000 square feet
Educational Office 9,000 square feet 45,000 square feet Government 10,00 square feet 50,000 square feet
Recreational 20,000 square feet 100,000 square feet
Other 9,000 square feet 45,000 square feet
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District Rule 9510 also applies to any transportation or transit development projects where construction exhaust emissions equal or exceed two (2.0) tons of NOx or two (2.0) tons of PM10.

In the case the future development project(s) are subject to District Rule 9510, an Air Impact Assessment (AIA) application is required and the District recommends that demonstration of compliance with District Rule 9510, before issuance of the first building permit, be made a condition of Project approval.

Information about how to comply with District Rule 9510 can be found online at:
http://www.valleyair.org/ISR/ISRHome.htm.

The AIA application form can be found online at:
http://www.valleyair.org/ISR/ISRFormsAndApplications.htm.

District staff is available to provide assistance with determining if future development projects will be subject to Rule 9510, and can be reached by phone at (559) 230-6000 or by email at [email protected].
17c) District Rule 9410 (Employer Based Trip Reduction) Future development projects may be subject to District Rule 9410 (Employer Based Trip Reduction) if the Project would result in employment of 100 or more “eligible” employees. District Rule 9410 requires employers with 100 or more “eligible” employees at a worksite to establish an Employer Trip Reduction Implementation Plan (eTRIP) that encourages employees to reduce singleoccupancy vehicle trips, thus reducing pollutant emissions associated with work commutes. Under an eTRIP plan, employers have the flexibility to select the options that work best for their worksites and their employees.

Information about how District Rule 9410 can be found online at:
www.valleyair.org/tripreduction.htm.

For additional information, you can contact the District by phone at 559-230-6000 or by e-mail at [email protected]
17d) District Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) The purpose of this rule is to limit emissions of carbon monoxide and particulate matter from wood burning fireplaces, wood burning heaters, and outdoor wood burning devices. This rule establishes limitations on the installation of new wood burning fireplaces and wood burning heaters. Specifically, at elevations below San Joaquin Valley Air Pollution Control District Page 14 District Reference No. 202220202
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3,000 feet in areas with natural gas service, no person shall install a wood burning fireplace, low mass fireplace, masonry heater, or wood burning heater.

Information about District Rule 4901 can be found online at:
http://valleyair.org/rule4901/
17e) District Regulation VII – Fugitive PM10 Prohibitions The project proponent may be required to submit a Construction Notification Form or submit and receive approval of a Dust Control Plan prior to commencing any earthmoving activities as described in Regulation VIII, specifically Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities.

The application for both the Construction Notification and Dust Control Plan can be found online at:
https://www.valleyair.org/busind/comply/PM10/forms/DCP-Form.docx Information about District Regulation VIII can be found online at:
http://www.valleyair.org/busind/comply/pm10/compliance_pm10.htm 17f) Other District Rules and Regulations
Future development projects may also be subject to the following District rules:

Rule 4102 (Nuisance), Rule 4601 (Architectural Coatings), and Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations). In the event an existing building will be renovated, partially demolished or removed, the project may be subject to District Rule 4002 (National Emission Standards for Hazardous Air Pollutants).
18)Future Projects / Land Use Agency Referral Documents Future development projects may require an environmental review and air emissions mitigation. Referral documents and environmental review documents for these projects should include a project summary, the land use designation, project size, air emissions quantifications and impacts, and proximity to sensitive receptors and existing emission sources, and air emissions mitigation measures. For reference and guidance, more information can be found in the District’s Guidance for Assessing and Mitigating Air Quality Impacts at: https://www.valleyair.org/transportation/GAMAQI.pdf San Joaquin Valley Air Pollution Control District Page 15 District Reference No. 202220202
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If you have any questions or require further information, please contact Cherie Clark by e-mail at [email protected] or by phone at (559) 230-5940.

Sincerely,
Brian Clements
Director of Permit Services
For Mark Montelongo
Program Manager
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR
FirstCarbon Solutions
Appendix B:

Air Quality, Greenhouse Gas Emissions Supporting Information

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Appendix B: Air Quality, Greenhouse Gases Emissions and Supporting Information
Table of Contents
Project Construction Air Pollutants Emissions Summary ......................................................... 1 Project Operational Air Pollutants Emissions Summary .......................................................... 2 Project Operational GHG Emissions Summary ......................................................................... 3 Project Existing Operational CalEEMod Output File ................................................................ 4 Project Proposed Construction and Operational CalEEMod Output File ................................ 40 Project Construction Emissions Summary
Model File: Fresno SEDA EIR Project ‐ Fresno County, Annual Timestamp: Date: 6/22/2022 9:53 AM
ROG NOX CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio‐ CO2 NBio‐ CO2 Total CO2 CH4 N2O CO2e Year
2024 1770.5964 201.5825 340.2451 1.6208 129.3799 2.1115 131.4914 35.2252 1.9855 37.2107 0 151683.704 151683.704 3.2035 12.9239 155615.12025 668.3045 188.8548 285.1465 1.4749 117.1887 1.7204 118.9091 31.761 1.6238 33.3848 0 138266.822 138266.822 2.4773 12.3046 141995.52026 30.4544 180.529 251.5594 1.3802 110.2011 1.4874 111.6886 29.8676 1.4089 31.2765 0 129564.913 129564.913 1.9166 11.8712 133150.42027 28.7114 178.017 239.1028 1.3455 110.2011 1.46 111.6611 29.8676 1.3833 31.2509 0 126314.12 126314.12 1.7689 11.5651 129804.82028 27.0101 175.3334 227.9141 1.3084 109.779 1.4266 111.2056 29.7532 1.3522 31.1054 0 122839.698 122839.698 1.6365 11.2392 126229.92029 25.5933 174.0968 219.8407 1.2838 110.2012 1.4042 111.6054 29.8677 1.3314 31.1991 0 120532.5 120532.5 1.5317 11.0196 123854.62030 24.1589 171.9972 212.3085 1.2576 110.2013 1.3298 111.5311 29.8677 1.2629 31.1306 0 118074.578 118074.578 1.3778 10.7859 121323.22031 22.8046 170.8218 205.8132 1.234 110.2014 1.3075 111.5089 29.8677 1.2422 31.1099 0 115855.553 115855.553 1.2921 10.582 119041.32032 21.6999 170.5107 201.1399 1.2178 110.6236 1.2918 111.9154 29.9822 1.2277 31.2099 0 114335.927 114335.927 1.2224 10.4461 117479.42033 20.472 168.4612 195.0109 1.1902 109.7792 1.2633 111.0426 29.7533 1.2011 30.9544 0 111750.226 111750.226 1.149 10.2156 114823.22034 19.5487 167.7409 191.0233 1.1739 109.7793 1.2452 111.0245 29.7533 1.1843 30.9376 0 110224.391 110224.391 1.092 10.0823 113256.22035 18.7751 167.5912 188.3113 1.164 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0 109299.305 109299.305 1.0457 10.0046 112306.82036 18.8471 168.2333 189.0328 1.1685 110.6238 1.23 111.8537 29.9822 1.1698 31.152 0 109718.076 109718.076 1.0497 10.0429 112737.12037 18.7751 167.5912 188.3113 1.164 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0 109299.305 109299.305 1.0457 10.0046 112306.82038 18.7751 167.5912 188.3113 1.164 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0 109299.305 109299.305 1.0457 10.0046 112306.82039 18.7032 166.9491 187.5898 1.1596 109.7793 1.2206 110.9999 29.7533 1.1609 30.9142 0 108880.533 108880.533 1.0417 9.9662 111876.52040 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.368 29.8679 1.1103 30.9782 0 104777.37 104777.37 0.8787 9.6159 107664.92041 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.368 29.8679 1.1103 30.9782 0 104777.37 104777.37 0.8787 9.6159 107664.92042 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.368 29.8679 1.1103 30.9782 0 104777.37 104777.37 0.8787 9.6159 107664.92043 5.1879 54.5964 58.3767 0.3677 36.3117 0.3843 36.696 9.8415 0.3659 10.2074 0 34524.344 34524.344 0.2895 3.1684 35475.8 Maximum 1770.5964 201.5825 340.2451 1.6208 129.3799 2.1115 131.4914 35.2252 1.9855 37.2107 0 151683.704 151683.704 3.2035 12.9239 155615.1 Total 2805.6515 3337.5785 4100.5374 24.0226 2155.4605 26.0571 2181.5177 584.3506 24.7267 609.0773 0 2254795.41 2254795.41 26.8219 205.0745 2316578.1 Amortized 77219.3
tons/yr MT/yr
Appendix
B Page 1
Model File: Fresno SEDA EIR Project ‐ Fresno County, Annual Timestamp: Date:  6/22/2022 9:53 AM
Model File: Fresno SEDA Baseline ‐ Existing Land Uses ‐ Fresno County, Annual Timestamp: Date: 6/24/2022 11:31 AM
ROG NOx CO SOx
PM10
(Total)
PM2.5
(Total)
Area 1,100.19 19.43 320.23 0.12 3.02 3.02
Energy 6.47 56.24 30.23 0.35 4.47 4.47
Mobile 166.63 311.03 1,798.71 4.59 644.30 173.88
Waste 0.00 0.00 0.00 0.00 0.00 0.00
Water 0.00 0.00 0.00 0.00 0.00 0.00
Total 1,273.29 386.69 2,149.17 5.06 651.79              181.37 Existing Emissions 178.12 83.42 462.80 0.87 71.17 29.72 Net Total 1,095.17 303.27 1,686.37 4.19 580.62 151.65
SJVAPCD Significance Thresholds 10 10 100 27 15 15
Exceeds Threshold? Yes Yes Yes No Yes Yes
Tons per Year
Project Operational Emissions Summary
Emissions Source
Appendix B Page 2
Construction ‐ GHG Emissions
Fresno SEDA EIR Project ‐ Fresno County, Annual
Date:  6/22/2022 9:53 AM
Operations ‐ GHG Emissions
Fresno SEDA Baseline ‐ Existing Land Uses ‐ Fresno County, Annual Date: 6/24/2022 11:31 AM
Area
Energy
Mobile
Waste
Water
Total
Existing Emissions
NET Emissions
18,945
91,121
601,912
14,233
510,791
111,179
432,219
25,336
Project Operational GHG Emissions Summary
Emissions Source
2050
CO2e (Metric Tons per Year)
Appendix B Page 3
Fresno SEDA Baseline - Existing Land Uses
Fresno County, Annual

1.0 Project Characteristics

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Government (Civic Center) 233.67 1000sqft 5.36 233,670.00 0 Elementary School 1,254.22 1000sqft 28.79 1,254,220.00 0 Industrial Park 5,481.88 1000sqft 125.85 5,481,880.00 0 Other Non-Asphalt Surfaces 21,488.92 1000sqft 493.32 21,488,920.00 0 Parking Lot 536.18 Acre 536.18 23,356,000.80 0
City Park 6,171.71 Acre 6,171.71 268,839,687.60 0
Single Family Housing 1,390.00 Dwelling Unit 1,436.00 2,502,000.00 3975 Strip Mall 91.34 1000sqft 2.10 91,340.00 0

1.2 Other Project Characteristics
Urbanization Urban Wind Speed (m/s) 2.2 Precipitation Freq (Days) 45 Climate Zone 3 Operational Year 2019
Utility Company Pacific Gas and Electric Company
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity
(lb/MWhr)

0.033 N2O Intensity
(lb/MWhr)

0.004

1.3 User Entered Comments & Non-Default Data
Project Characteristics -
Land Use - Note 1
Construction Phase - Adjusted to represent operational emissions only Grading -
Area Mitigation
Appendix
- Per SJVAPCD Rule 4601
B Page 4
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 11,000.00 0.00
tblConstructionPhase NumDays 155,000.00 0.00
tblConstructionPhase NumDays 10,000.00 0.00
tblConstructionPhase NumDays 15,500.00 0.00
tblConstructionPhase NumDays 11,000.00 0.00
tblConstructionPhase NumDays 6,000.00 0.00
tblConstructionPhase PhaseEndDate 11/3/2817 9/5/2775
tblConstructionPhase PhaseEndDate 7/7/2733 5/22/2139
tblConstructionPhase PhaseEndDate 12/22/2056 8/26/2018
tblConstructionPhase PhaseEndDate 5/22/2139 12/22/2079
tblConstructionPhase PhaseEndDate 9/5/2775 7/7/2733
tblConstructionPhase PhaseEndDate 12/22/2079 12/22/2056 tblLandUse LandUseSquareFeet 21,488,900.00 21,488,920.00 tblLandUse LotAcreage 451.30 1,436.00

2.0 Emissions Summary

2.1 Overall Construction
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2018 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2056 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 5
2079 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2139 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2733 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2775 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 6
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2018 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2056 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2079 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2139 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2733 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2775 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) Highest

2.2 Overall Operational
Unmitigated Operational
Appendix B Page 7
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 137.1176 1.6166 105.4965 0.1537 13.0547 13.0547 13.0547 13.0547 1,154.8420 619.6473 1,774.4893 0.0298 0.1129 1,808.8896 Energy 0.7518 6.7366 5.0206 0.0410 0.5195 0.5195 0.5195 0.5195 0.0000 14,753.2870 14,753.2870 1.3257 0.2798 14,869.8123 Mobile 40.2554 75.0704 352.2783 0.6713 56.5246 1.0695 57.5940 15.1339 1.0125 16.1464 0.0000 62,072.8969 62,072.8969 4.3208 3.8617 63,331.7086 Waste 0.0000 0.0000 0.0000 0.0000 2,398.8701 0.0000 2,398.8701 141.7692 0.0000 5,943.0990 Water 0.0000 0.0000 0.0000 0.0000 459.3214 3,165.4677 3,624.7891 47.6888 1.1760 5,167.4632 Total 178.1248 83.4236 462.7954 0.8659 56.5246 14.6436 71.1681 15.1339 14.5866 29.7205 4,013.0334 80,611.2989 84,624.3323 195.1342 5.4305 91,120.9727 Appendix B Page 8
Mitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 137.1176 1.6166 105.4965 0.1537 13.0547 13.0547 13.0547 13.0547 1,154.8420 619.6473 1,774.4893 0.0298 0.1129 1,808.8896 Energy 0.7518 6.7366 5.0206 0.0410 0.5195 0.5195 0.5195 0.5195 0.0000 14,753.2870 14,753.2870 1.3257 0.2798 14,869.8123 Mobile 40.2554 75.0704 352.2783 0.6713 56.5246 1.0695 57.5940 15.1339 1.0125 16.1464 0.0000 62,072.8969 62,072.8969 4.3208 3.8617 63,331.7086 Waste 0.0000 0.0000 0.0000 0.0000 2,398.8701 0.0000 2,398.8701 141.7692 0.0000 5,943.0990 Water 0.0000 0.0000 0.0000 0.0000 459.3214 3,165.4677 3,624.7891 47.6888 1.1760 5,167.4632 Total 178.1248 83.4236 462.7954 0.8659 56.5246 14.6436 71.1681 15.1339 14.5866 29.7205 4,013.0334 80,611.2989 84,624.3323 195.1342 5.4305 91,120.9727 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 8/27/2018 8/26/2018 5 0
2 Site Preparation Site Preparation 12/23/2056 12/22/2056 5 0 3 Grading Grading 12/23/2079 12/22/2079 5 0
Appendix B Page 9
4 Building Construction Building Construction 5/23/2139 5/22/2139 5 0 5 Paving Paving 7/8/2733 7/7/2733 5 0
6 Architectural Coating Architectural Coating 9/6/2775 9/5/2775 5 0 Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 1029.5
Residential Indoor: 5,066,550; Residential Outdoor: 1,688,850; Non-Residential Indoor: 10,591,667; Non-Residential Outdoor: 3,530,556; Striped Parking Area: 2,690,695 (Architectural Coating – sqft) OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Appendix B Page 10
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 135,181.00 52,719.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 27,036.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

3.1 Mitigation Measures Construction

3.2 Demolition - 2018
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 11
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 12
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

3.3 Site Preparation - 2056
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 13
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 14
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

3.4 Grading - 2079
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 15
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 16
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

3.5 Building Construction - 2139
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 17
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 18
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

3.6 Paving - 2733
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 19
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 20
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

3.7 Architectural Coating - 2775
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 21
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Appendix B Page 22
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 40.2554 75.0704 352.2783 0.6713 56.5246 1.0695 57.5940 15.1339 1.0125 16.1464 0.0000 62,072.8969 62,072.8969 4.3208 3.8617 63,331.7086 Appendix B Page 23
Unmitigated 40.2554 75.0704 352.2783 0.6713 56.5246 1.0695 57.5940 15.1339 1.0125 16.1464 0.0000 62,072.8969 62,072.8969 4.3208 3.8617 63,331.7086

4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
City Park 4,813.93 12,096.55 13516.04 15,152,046 15,152,046 Elementary School 24,482.37 0.00 0.00 38,558,675 38,558,675 Government (Civic Center) 7,940.11 0.00 0.00 10,841,858 10,841,858 Industrial Park 18,473.94 13,923.98 6797.53 42,357,953 42,357,953 Other Non-Asphalt Surfaces 0.00 0.00 0.00
Parking Lot 0.00 0.00 0.00
Single Family Housing 13,121.60 13,260.60 11884.50 37,982,369 37,982,369 Strip Mall 4,048.19 3,839.93 1866.08 5,708,452 5,708,452 Total 72,880.14 43,121.06 34,064.15 150,601,353 150,601,353

4.3 Trip Type Information
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by City Park 9.50 7.30 7.30 33.00 48.00 19.00 66 28 6
Elementary School 9.50 7.30 7.30 65.00 30.00 5.00 63 25 12 Government (Civic Center) 9.50 7.30 7.30 75.00 20.00 5.00 50 34 16 Appendix B Page 24
Industrial Park 9.50 7.30 7.30 59.00 28.00 13.00 79 19 2 Other Non-Asphalt Surfaces 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0 Parking Lot 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0
Single Family Housing 10.80 7.30 7.50 48.40 15.90 35.70 86 11 3 Strip Mall 9.50 7.30 7.30 16.60 64.40 19.00 45 40 15

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH City Park 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Elementary School 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Government (Civic Center) 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Industrial Park 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Other Non-Asphalt Surfaces 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Parking Lot 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Single Family Housing 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625 Strip Mall 0.482772 0.053013 0.177201 0.181386 0.030694 0.007689 0.014311 0.021176 0.000804 0.000296 0.025348 0.001685 0.003625

5.0 Energy Detail
Historical Energy Use: N

5.1 Mitigation Measures Energy
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 7,312.7066 7,312.7066 1.1831 0.1434 7,385.0162 Appendix B Page 25
Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 7,312.7066 7,312.7066 1.1831 0.1434 7,385.0162 NaturalGas
Mitigated

0.7518 6.7366 5.0206 0.0410 0.5195 0.5195 0.5195 0.5195 0.0000 7,440.5804 7,440.5804 0.1426 0.1364 7,484.7961 NaturalGas
Unmitigated

0.7518 6.7366 5.0206 0.0410 0.5195 0.5195 0.5195 0.5195 0.0000 7,440.5804 7,440.5804 0.1426 0.1364 7,484.7961 Appendix B Page 26

5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGas
Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
City Park 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Elementary
School

3.1205e+007 0.1683 1.5297 1.2849 9.1800e0030.1163 0.1163 0.1163 0.1163 0.0000 1,665.2173 1,665.2173 0.0319 0.0305 1,675.1129 Government
(Civic Center)

3.01902e+006 0.0163 0.1480 0.1243 8.9000e0040.0113 0.0113 0.0113 0.0113 0.0000 161.1062 161.1062 3.0900e0032.9500e003162.0636 Industrial Park 7.08259e+007 0.3819 3.4719 2.9164 0.0208 0.2639 0.2639 0.2639 0.2639 0.0000 3,779.5392 3,779.5392 0.0724 0.0693 3,801.9991 Other NonAsphalt Surfaces0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Single Family
Housing

3.34122e+007 0.1802 1.5396 0.6551 9.8300e0030.1245 0.1245 0.1245 0.1245 0.0000 1,783.0019 1,783.0019 0.0342 0.0327 1,793.5974 Strip Mall 969117 5.2300e0030.0475 0.0399 2.9000e0043.6100e0033.6100e0033.6100e0033.6100e0030.0000 51.7158 51.7158 9.9000e0049.5000e00452.0231 Total 0.7518 6.7366 5.0206 0.0410 0.5195 0.5195 0.5195 0.5195 0.0000 7,440.5804 7,440.5804 0.1426 0.1364 7,484.7961 Appendix B Page 27
Mitigated
NaturalGas
Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
City Park 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Elementary
School

3.1205e+007 0.1683 1.5297 1.2849 9.1800e0030.1163 0.1163 0.1163 0.1163 0.0000 1,665.2173 1,665.2173 0.0319 0.0305 1,675.1129 Government
(Civic Center)

5.3 Energy by Land Use - Electricity
Unmitigated
Electricity Use Total CO2 CH4 N2O CO2e
Land Use kWh/yr tons/yr MT/yr
City Park 0 0.0000 0.0000 0.0000 0.0000
Elementary
School

8.5287e+006 789.1071 0.1277 0.0155 796.9100
Government
(Civic
Center)

2.06564e+006 191.1211 0.0309 3.7500e003193.0109
Industrial
Park

4.84598e+007 4,483.6853 0.7254 0.0879 4,528.0209
Other NonAsphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Parking Lot 8.1746e+006 756.3449 0.1224 0.0148 763.8238 Single
Family
Housing

1.10838e+007 1,025.5154 0.1659 0.0201 1,035.6559
Strip Mall 723413 66.9329 0.0108 1.3100e00367.5947
Total 7,312.7066 1.1831 0.1434 7,385.0162
Appendix B Page 29
Mitigated
Electricity Use Total CO2 CH4 N2O CO2e
Land Use kWh/yr tons/yr MT/yr
City Park 0 0.0000 0.0000 0.0000 0.0000
Elementary
School

8.5287e+006 789.1071 0.1277 0.0155 796.9100
Government
(Civic
Center)

2.06564e+006 191.1211 0.0309 3.7500e003193.0109
Industrial
Park

4.84598e+007 4,483.6853 0.7254 0.0879 4,528.0209
Other NonAsphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Parking Lot 8.1746e+006 756.3449 0.1224 0.0148 763.8238 Single
Family
Housing

1.10838e+007 1,025.5154 0.1659 0.0201 1,035.6559
Strip Mall 723413 66.9329 0.0108 1.3100e00367.5947
Total 7,312.7066 1.1831 0.1434 7,385.0162

6.0 Area Detail

6.1 Mitigation Measures Area
Use Low VOC Paint - Residential Interior
Use Low VOC Paint - Residential Exterior
Appendix B Page 30
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 137.1176 1.6166 105.4965 0.1537 13.0547 13.0547 13.0547 13.0547 1,154.8420 619.6473 1,774.4893 0.0298 0.1129 1,808.8896 Unmitigated 137.1176 1.6166 105.4965 0.1537 13.0547 13.0547 13.0547 13.0547 1,154.8420 619.6473 1,774.4893 0.0298 0.1129 1,808.8896

6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

8.1929 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

42.7753 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 85.8008 1.4934 94.7973 0.1531 12.9966 12.9966 12.9966 12.9966 1,154.8420 602.1583 1,757.0002 0.0115 0.1129 1,790.9441 Landscaping 0.3485 0.1232 10.6992 5.7000e0040.0580 0.0580 0.0580 0.0580 0.0000 17.4890 17.4890 0.0183 0.0000 17.9454 Total 137.1176 1.6166 105.4965 0.1537 13.0547 13.0547 13.0547 13.0547 1,154.8420 619.6473 1,774.4893 0.0298 0.1129 1,808.8896 Appendix B Page 31
Mitigated
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

8.1929 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

7.0 Water Detail

7.1 Mitigation Measures Water
Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 3,624.7891 47.6888 1.1760 5,167.4632
Appendix B Page 32
Unmitigated 3,624.7891 47.6888 1.1760 5,167.4632
Appendix B Page 33

7.2 Water by Land Use
Unmitigated
Indoor/Outdoor
Use
Total CO2 CH4 N2O CO2e
Land Use Mgal tons/yr MT/yr
City Park 0 / 7353.48 2,381.3001 0.3853 0.0467 2,404.8469 Elementary
School

36.3685 /

93.519

60.0304 1.1929 0.0289 98.4752
Government
(Civic
Center)

46.4208 /

28.4515

47.1811 1.5179 0.0364 95.9610
Industrial
Park
1267.68 / 0 1,036.8394 41.4102 0.9878 2,366.4605
Other NonAsphalt
Surfaces
0 / 0 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 / 0 0.0000 0.0000 0.0000 0.0000
Single
Family
Housing

90.5641 /

57.0948

92.5616 2.9614 0.0709 187.7332
Strip Mall 6.76578 /

4.14677

6.8766 0.2212 5.3000e00313.9862
Total 3,624.7891 47.6888 1.1760 5,167.4632
Appendix B Page 34
Mitigated
Indoor/Outdoor
Use
Total CO2 CH4 N2O CO2e
Land Use Mgal tons/yr MT/yr
City Park 0 / 7353.48 2,381.3001 0.3853 0.0467 2,404.8469 Elementary
School

36.3685 /

93.519

60.0304 1.1929 0.0289 98.4752
Government
(Civic
Center)

46.4208 /

28.4515

90.5641 /

57.0948

92.5616 2.9614 0.0709 187.7332
Strip Mall 6.76578 /

4.14677

6.8766 0.2212 5.3000e00313.9862
Total 3,624.7891 47.6888 1.1760 5,167.4632

8.0 Waste Detail

8.1 Mitigation Measures Waste
Category/Year
Appendix B Page 35
Total CO2 CH4 N2O CO2e
tons/yr MT/yr
Mitigated 2,398.8701 141.7692 0.0000 5,943.0990
Unmitigated 2,398.8701 141.7692 0.0000 5,943.0990
Appendix B Page 36

8.2 Waste by Land Use
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons tons/yr MT/yr
City Park 530.77 107.7415 6.3673 0.0000 266.9250
Elementary
School
1630.49 330.9747 19.5601 0.0000 819.9759
Government
(Civic Center)
1331.92 270.3677 15.9783 0.0000 669.8246
Industrial Park 6797.53 1,379.8372 81.5460 0.0000 3,418.4882 Other NonAsphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Single Family
Housing
1431 290.4801 17.1669 0.0000 719.6521
Strip Mall 95.91 19.4689 1.1506 0.0000 48.2333
Total 2,398.8701 141.7692 0.0000 5,943.0990
Appendix B Page 37
Mitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons tons/yr MT/yr
City Park 530.77 107.7415 6.3673 0.0000 266.9250
Elementary
School
1630.49 330.9747 19.5601 0.0000 819.9759
Government
(Civic Center)
1331.92 270.3677 15.9783 0.0000 669.8246
Industrial Park 6797.53 1,379.8372 81.5460 0.0000 3,418.4882 Other NonAsphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Single Family
Housing
1431 290.4801 17.1669 0.0000 719.6521
Strip Mall 95.91 19.4689 1.1506 0.0000 48.2333
Total 2,398.8701 141.7692 0.0000 5,943.0990

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Appendix B Page 38
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number

11.0 Vegetation
Appendix B Page 39
Fresno SEDA EIR Project
Fresno County, Annual

1.0 Project Characteristics

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Government Office Building 7,946.52 1000sqft 182.43 7,946,520.00 0 Office Park 4,423.32 1000sqft 101.55 4,423,320.00 0
Research & Development 2,897.96 1000sqft 66.53 2,897,960.00 0 Parking Lot 96,337.08 1000sqft 2,211.60 96,337,080.00 0 City Park 744.00 Acre 744.00 32,408,640.00 0
Condo/Townhouse 16,906.00 Dwelling Unit 2,153.96 93,826,497.60 48351 Single Family Housing 25,358.00 Dwelling Unit 3,230.94 140,739,746.40 72524 Regional Shopping Center 4,482.52 1000sqft 102.90 4,482,520.00 0

1.2 Other Project Characteristics
Urbanization Urban Wind Speed (m/s) 2.2 Precipitation Freq (Days) 45 Climate Zone 3 Operational Year 2050
Utility Company Pacific Gas and Electric Company
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity
(lb/MWhr)

0.033 N2O Intensity
(lb/MWhr)

0.004

1.3 User Entered Comments & Non-Default Data
Project Characteristics -
Land Use - Note 1
Construction Phase - Based on CalEEMod default and normalized to an 25-year buildout. Assumes overlap of all phases.

Grading -
Vehicle Trips -
Appendix B Page 40
Woodstoves - Per SJVAPCD Rule 4901
Area Coating - Per SJVAPCD Rule 4601
Construction Off-road Equipment Mitigation - SJVAPCD Reg. VIII Area Mitigation - SJVAPCD Rule 4601
Energy Mitigation -
Table Name Column Name Default Value New Value
tblAreaMitigation UseLowVOCPaintResidentialExteriorValue 150 50 tblAreaMitigation UseLowVOCPaintResidentialInteriorValue 150 50 tblConstDustMitigation WaterUnpavedRoadVehicleSpeed 0 15 tblConstructionPhase NumDays 11,000.00 358.00
tblConstructionPhase NumDays 155,000.00 5,044.00
tblConstructionPhase NumDays 10,000.00 325.00
tblConstructionPhase NumDays 15,500.00 504.00
tblConstructionPhase NumDays 11,000.00 358.00
tblConstructionPhase NumDays 6,000.00 195.00
tblConstructionPhase PhaseEndDate 3/10/2823 5/14/2025
tblConstructionPhase PhaseEndDate 11/11/2738 4/30/2043
tblConstructionPhase PhaseEndDate 4/28/2062 3/28/2025
tblConstructionPhase PhaseEndDate 9/25/2144 12/4/2025
tblConstructionPhase PhaseEndDate 1/9/2781 5/14/2025
tblConstructionPhase PhaseEndDate 4/27/2085 9/27/2024
tblConstructionPhase PhaseStartDate 1/10/2781 1/1/2024
tblConstructionPhase PhaseStartDate 9/26/2144 1/1/2024
tblConstructionPhase PhaseStartDate 4/28/2085 1/1/2024
tblConstructionPhase PhaseStartDate 11/12/2738 1/1/2024 tblConstructionPhase PhaseStartDate 4/29/2062 1/1/2024
tblFireplaces FireplaceWoodMass 3,078.40 0.00
tblFireplaces
Appendix B
FireplaceWoodMass 3,078.40 0.00

Page 41 ends

tblLandUse LandUseSquareFeet 96,337,100.00 96,337,080.00 tblLandUse LandUseSquareFeet 16,906,000.00 93,826,497.60 tblLandUse LandUseSquareFeet 45,644,400.00 140,739,746.40 tblLandUse LotAcreage 1,056.63 2,153.96
tblLandUse LotAcreage 8,233.12 3,230.94
tblWoodstoves NumberCatalytic 2,153.96 0.00
tblWoodstoves NumberCatalytic 3,230.94 0.00
tblWoodstoves NumberNoncatalytic 2,153.96 0.00
tblWoodstoves NumberNoncatalytic 3,230.94 0.00
tblWoodstoves WoodstoveWoodMass 3,019.20 0.00
tblWoodstoves WoodstoveWoodMass 3,019.20 0.00

2.0 Emissions Summary

2.1 Overall Construction
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2024 1,770.5964 201.5825 340.2451 1.6208 131.3088 2.1115 133.4203 36.0531 1.9855 38.0386 0.0000 151,683.7064 151,683.7064 3.2035 12.9239 155,615.1139 2025 668.3045 188.8548 285.1465 1.4749 118.0304 1.7204 119.7508 32.0289 1.6238 33.6527 0.0000 138,266.8233 138,266.8233 2.4773 12.3046 141,995.5364 2026 30.4544 180.5290 251.5594 1.3802 110.2011 1.4874 111.6886 29.8676 1.4089 31.2765 0.0000 129,564.9134 129,564.9134 1.9166 11.8712 133,150.4377 2027 28.7114 178.0170 239.1028 1.3455 110.2011 1.4600 111.6611 29.8676 1.3833 31.2509 0.0000 126,314.1201 126,314.1201 1.7689 11.5651 129,804.7546 2028 27.0101 175.3334 227.9141 1.3084 109.7790 1.4266 111.2056 29.7532 1.3522 31.1054 0.0000 122,839.6980 122,839.6980 1.6365 11.2392 126,229.8897 2029
Appendix

25.5933
B
174.0968 219.8407 1.2838 110.2012 1.4042 111.6054 29.8677 1.3314 31.1991 0.0000 120,532.5005 120,532.5005 1.5317 11.0196 123,854.6432

Page 42 ends

2030 24.1589 171.9972 212.3085 1.2576 110.2013 1.3298 111.5311 29.8677 1.2629 31.1306 0.0000 118,074.5788 118,074.5788 1.3778 10.7859 121,323.2355 2031 22.8046 170.8218 205.8133 1.2340 110.2014 1.3075 111.5089 29.8677 1.2422 31.1099 0.0000 115,855.5534 115,855.5534 1.2921 10.5820 119,041.2833 2032 21.6999 170.5107 201.1399 1.2178 110.6236 1.2918 111.9154 29.9822 1.2277 31.2099 0.0000 114,335.9273 114,335.9273 1.2224 10.4461 117,479.4260 2033 20.4720 168.4612 195.0109 1.1902 109.7792 1.2633 111.0426 29.7533 1.2011 30.9544 0.0000 111,750.2265 111,750.2265 1.1490 10.2156 114,823.2000 2034 19.5487 167.7409 191.0233 1.1739 109.7793 1.2452 111.0245 29.7533 1.1843 30.9376 0.0000 110,224.3912 110,224.3912 1.0920 10.0823 113,256.2062 2035 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3051 109,299.3051 1.0457 10.0046 112,306.8108 2036 18.8471 168.2333 189.0328 1.1685 110.6238 1.2300 111.8537 29.9822 1.1698 31.1520 0.0000 109,718.0764 109,718.0764 1.0497 10.0429 112,737.1051 2037 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3051 109,299.3051 1.0457 10.0046 112,306.8108 2038 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3051 109,299.3051 1.0457 10.0046 112,306.8108 2039 18.7032 166.9491 187.5898 1.1596 109.7793 1.2206 110.9999 29.7533 1.1609 30.9142 0.0000 108,880.5338 108,880.5338 1.0417 9.9662 111,876.5165 2040 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3701 104,777.3701 0.8787 9.6159 107,664.8600 2041 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3701 104,777.3701 0.8787 9.6159 107,664.8600 2042 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3701 104,777.3701 0.8787 9.6159 107,664.8600 2043 5.1879 54.5964 58.3767 0.3677 36.3117 0.3843 36.6960 9.8415 0.3659 10.2074 0.0000 34,524.3442 34,524.3442 0.2895 3.1684 35,475.7776 Maximum 1,770.5964 201.5825 340.2451 1.6208 131.3088 2.1115 133.4203 36.0531 1.9855 38.0386 0.0000 151,683.7064 151,683.7064 3.2035 12.9239 155,615.1139 Appendix B Page 43
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2024 1,770.5964 201.5825 340.2451 1.6208 129.3799 2.1115 131.4914 35.2252 1.9855 37.2107 0.0000 151,683.7039 151,683.7039 3.2035 12.9239 155,615.1114 2025 668.3045 188.8548 285.1465 1.4749 117.1887 1.7204 118.9091 31.7610 1.6238 33.3848 0.0000 138,266.8219 138,266.8219 2.4773 12.3046 141,995.5350 2026 30.4544 180.5290 251.5594 1.3802 110.2011 1.4874 111.6886 29.8676 1.4089 31.2765 0.0000 129,564.9131 129,564.9131 1.9166 11.8712 133,150.4373 2027 28.7114 178.0170 239.1028 1.3455 110.2011 1.4600 111.6611 29.8676 1.3833 31.2509 0.0000 126,314.1197 126,314.1197 1.7689 11.5651 129,804.7542 2028 27.0101 175.3334 227.9141 1.3084 109.7790 1.4266 111.2056 29.7532 1.3522 31.1054 0.0000 122,839.6976 122,839.6976 1.6365 11.2392 126,229.8893 2029 25.5933 174.0968 219.8407 1.2838 110.2012 1.4042 111.6054 29.8677 1.3314 31.1991 0.0000 120,532.5002 120,532.5002 1.5317 11.0196 123,854.6428 2030 24.1589 171.9972 212.3085 1.2576 110.2013 1.3298 111.5311 29.8677 1.2629 31.1306 0.0000 118,074.5784 118,074.5784 1.3778 10.7859 121,323.2351 2031 22.8046 170.8218 205.8132 1.2340 110.2014 1.3075 111.5089 29.8677 1.2422 31.1099 0.0000 115,855.5530 115,855.5530 1.2921 10.5820 119,041.2829 2032 21.6999 170.5107 201.1399 1.2178 110.6236 1.2918 111.9154 29.9822 1.2277 31.2099 0.0000 114,335.9269 114,335.9269 1.2224 10.4461 117,479.4255 2033 20.4720 168.4612 195.0109 1.1902 109.7792 1.2633 111.0426 29.7533 1.2011 30.9544 0.0000 111,750.2261 111,750.2261 1.1490 10.2156 114,823.1996 2034 19.5487 167.7409 191.0233 1.1739 109.7793 1.2452 111.0245 29.7533 1.1843 30.9376 0.0000 110,224.3908 110,224.3908 1.0920 10.0823 113,256.2058 2035 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3047 109,299.3047 1.0457 10.0046 112,306.8104 2036 18.8471 168.2333 189.0328 1.1685 110.6238 1.2300 111.8537 29.9822 1.1698 31.1520 0.0000 109,718.0760 109,718.0760 1.0497 10.0429 112,737.1047 2037 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3047 109,299.3047 1.0457 10.0046 112,306.8104 2038 18.7751 167.5912 188.3113 1.1640 110.2015 1.2253 111.4268 29.8678 1.1653 31.0331 0.0000 109,299.3047 109,299.3047 1.0457 10.0046 112,306.8104 2039 18.7032 166.9491 187.5898 1.1596 109.7793 1.2206 110.9999 29.7533 1.1609 30.9142 0.0000 108,880.5334 108,880.5334 1.0417 9.9662 111,876.5161 Appendix B Page 44
2040 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3697 104,777.3697 0.8787 9.6159 107,664.8596 2041 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3697 104,777.3697 0.8787 9.6159 107,664.8596 2042 15.7446 165.6936 177.1666 1.1159 110.2018 1.1662 111.3680 29.8679 1.1103 30.9782 0.0000 104,777.3697 104,777.3697 0.8787 9.6159 107,664.8596 2043 5.1879 54.5964 58.3767 0.3677 36.3117 0.3843 36.6960 9.8415 0.3659 10.2074 0.0000 34,524.3440 34,524.3440 0.2895 3.1684 35,475.7775 Maximum 1,770.5964 201.5825 340.2451 1.6208 129.3799 2.1115 131.4914 35.2252 1.9855 37.2107 0.0000 151,683.7039 151,683.7039 3.2035 12.9239 155,615.1114 Appendix B Page 45
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.13 0.00 0.13 0.19 0.00 0.18 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 1-1-2024 3-31-2024 491.2599 491.2599
2 4-1-2024 6-30-2024 488.8237 488.8237
3 7-1-2024 9-30-2024 494.1633 494.1633
4 10-1-2024 12-31-2024 495.6751 495.6751
5 1-1-2025 3-31-2025 483.0868 483.0868
6 4-1-2025 6-30-2025 262.4402 262.4402
7 7-1-2025 9-30-2025 54.3448 54.3448
8 10-1-2025 12-31-2025 56.5432 56.5432
9 1-1-2026 3-31-2026 53.4410 53.4410
10 4-1-2026 6-30-2026 51.5708 51.5708
11 7-1-2026 9-30-2026 52.1376 52.1376
12 10-1-2026 12-31-2026 54.6286 54.6286
13 1-1-2027 3-31-2027 52.3503 52.3503
14 4-1-2027 6-30-2027 50.4753 50.4753
15 7-1-2027 9-30-2027 51.0299 51.0299
16 10-1-2027 12-31-2027 53.5136 53.5136
17 1-1-2028 3-31-2028 51.9960 51.9960
18 4-1-2028 6-30-2028 49.5423 49.5423
19 7-1-2028 9-30-2028 50.0867 50.0867
20 10-1-2028 12-31-2028 52.5674 52.5674
21 1-1-2029 3-31-2029 50.5457 50.5457
22 Appendix
4-1
B-2029 6-30-2029 48.6536 48.6536Page 46
23 7-1-20299-30-2029 49.1883 49.1883
24 10-1-2029 12-31-2029 51.6690 51.6690
251-1-20303-31-2030 49.6464 49.6464
264-1-20306-30-2030 47.7370 47.7370
277-1-20309-30-2030 48.2616 48.2616
28 10-1-2030 12-31-2030 50.7497 50.7497
291-1-20313-31-2031 48.9981 48.9981
304-1-20316-30-2031 47.0698 47.0698
317-1-20319-30-2031 47.5870 47.5870
32 10-1-2031 12-31-2031 50.0869 50.0869
331-1-20323-31-2032 48.9870 48.9870
344-1-20326-30-2032 46.4996 46.4996
357-1-20329-30-2032 47.0105 47.0105
36 10-1-2032 12-31-2032 49.5253 49.5253
371-1-20333-31-2033 47.9853 47.9853
384-1-20336-30-2033 46.0132 46.0132
397-1-20339-30-2033 46.5188 46.5188
40 10-1-2033 12-31-2033 49.0517 49.0517
411-1-20343-31-2034 47.5674 47.5674
424-1-20346-30-2034 45.5705 45.5705
437-1-20349-30-2034 46.0713 46.0713
44 10-1-2034 12-31-2034 48.6244 48.6244
451-1-20353-31-2035 47.1531 47.1531
464-1-20356-30-2035 45.1325 45.1325
477-1-20359-30-2035 45.6284 45.6284
48 10-1-2035 12-31-2035 48.2009 48.2009
49 Appendix
1-1
B
-20363-31-2036 47.6770 47.6770

Page 47 ends

Fresno City CouncilDecember 18, 2025

Fresno City Council
December 18, 2025