Exhibit D - Resolution Certifying SEDA EIR — Fresno City Council, December 18, 2025 (part 7 of 23)

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12 investments? Why has the city not prioritized revitalizing and redeveloping existing underutilized or vacant areas within city limits?
Thank you for your attention to our concerns,
Brian Ruck and Candice Ruck
6 RUCK

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-777
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Brian and Candice Ruck (RUCK)
Response to RUCK-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Response to RUCK-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

As discussed in Section 3.18, Utilities and Service Systems, of the Recirculated Draft PEIR, solid waste collection in the Plan Area would continue as currently planned for City residents, and collection routes would be extended to the Plan Area. Solid waste generation would increase with the buildout of the Specific Plan Area, and thus solid waste collection systems would need to accommodate this increase in demand for service. All new developments would need to abide by the City’s Construction and Diversion Ordinance. New developments may also need to create a Waste Management Plan per CALGreen requirements for on-site sorting of construction debris to be submitted to the City for approval. No further response is required.

Response to RUCK-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-778 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Response to RUCK-4
The comment is noted. As described in Section 3.1, Aesthetics, Light, and Glare, of the Recirculated Draft PEIR, the proposed project would include increased development in the Plan Area, leading to increased light from streetlights, exterior lighting from buildings, and vehicle headlights, compared to the current rural and agricultural land uses. Although the proposed project would comply with applicable policies and requirements and implement MM AES-4a through MM AES-4e, which require shields to direct light away from light-sensitive uses and minimize spillover onto adjacent properties, as well as nonreflective building façades, impacts related to light and glare would remain significant and unavoidable. No further response is required.

Response to RUCK-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please also refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Additionally, please refer to the Executive Summary; Section 3.3, Air Quality; Section 3.8, Greenhouse Gas Emissions; Section 3.11, Noise; and Section 3.17, Transportation and Traffic, for a discussion of the mitigation measures that would be implemented by the proposed project. No further response is required.

Response to RUCK-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-779
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to RUCK-7
The comment is noted. Please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI-144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

Response to RUCK-8
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please also refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

Additionally, future development within the Plan Area would be required to comply with applicable school development fees in order to mitigate the impacts on school facilities caused by future development within the City. Payment of applicable development fees would offset the construction and acquisition costs of required school facility improvements and additional staff to meet acceptable service levels. The provisions in Government Code Section 65996, which require developers to pay developer fees to the applicable school district, are deemed to provide full and complete school facilities mitigation related to the school district’s ability to accommodate enrollment. With payment of applicable developer fees, impacts on school facilities related to the proposed project would be mitigated to less than significant levels. No further response is required.

Response to RUCK-9
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-780 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx As discussed in Section 3.18, Utilities and Service Systems, of the Recirculated Draft PEIR, the proposed project would implement MM UTIL-1a through MM UTIL-1f, MM UTIL-2a through MM UTIL-2c, and MM UTIL-4, which would require the City to evaluate utility facilities, capacities, and providers prior to approving discretionary projects associated with the implementation of the proposed project. The Recirculated Draft PEIR determined that impacts related to the need for the construction of new or expanded utilities would be less than significant with mitigation incorporated. No further response is required.

Response to RUCK-10
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR.

Please also refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

Response to RUCK-11
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Further, as described in Policy CF-2.2 of the proposed SEDA Specific Plan, rural cluster lands can be used for organic small-scale farming, equestrian activities, or other uses compatible with the nearby homes. The vast majority of the land is preserved as viable agricultural land or open space. No further response is required.

Response to RUCK-12
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses. Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI- City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-781
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx 144, which explicitly sates these requirements are triggered by annexation into the City. Compliance with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits.

Further, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

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From: Susie Rodriguez
To: LongRangePlanning
Subject: fresno annexation of existing propeties
Date: Monday, February 24, 2025 8:27:42 PM
External Email: Use caution with links and attachments
i/m a homeowner at 7827 E. Floradora Ave., Fresno, CA 93737. My husband and i moved here in 2015 and not one word mentioned regarding annexation, So we were shocked to hear about this horrible plan for annexation and very unfair. We are both retired and in no way able to afford the outrages mentioned cost to hook up to the city. if Fresno City wants established homeowners to belong to the City, i feel Fresno City needs to pay for all expenses. i understand new development needing to be hooked up to the City, but very unfair for established homeowners to be forced to hook up to the City, we already paid for our water pump and septic tank and having to pay to remove is unfair!!! We chose to live here with our acreage and beautiful trees, now our trees will all die due to lack of water because we will be metered and can’t afford to pay outrages prices. Please leave existing properties owners alone, people are going to be forced out of Fresno and less property taxes will be collected. A better solution would be to improve existing unoccupied properties in the City and make Fresno a better place to live!!! it makes sense to leave existing homeowners alone.

S. RODRIGUEZ 1

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-785
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Susie Rodriguez (First Letter) (S. RODRIGUEZ 1)
Response to S. RODRIGUEZ 1-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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From: Susie Rodriguez
To: LongRangePlanning
Subject: Re: fresno annexation of existing propeties
Date: Tuesday, March 18, 2025 8:08:05 PM
External Email: Use caution with links and attachments
On Feb 24, 2025, at 8:27 PM, Susie Rodriguez <[email protected]> wrote:
i’m a homeowner at 7827 E. Floradora Ave., Fresno, CA 93737. My husband and i moved here in 2015 and not one word mentioned regarding annexation, So we were shocked to hear about this horrible plan for annexation and very unfair. We are both retired and in no way able to afford the outrages mentioned cost to hook up to the city. if Fresno City wants established homeowners to belong to the City, i feel Fresno City needs to pay for all expenses. i understand new development needing to be hooked up to the City, but very unfair for established homeowners to be forced to hook up to the City, we already paid for our water pump and septic tank and having to pay to remove is unfair!!! We chose to live here with our acreage and beautiful trees, now our trees will all die due to lack of water because we will be metered and can’t afford to pay outrages prices. Please leave existing properties owners alone, people are going to be forced out of Fresno and less property taxes will be collected. A better solution would be to improve existing unoccupied properties in the City and make Fresno a better place to live!!! it makes sense to leave existing homeowners alone.

March 18, 2025
i’m resending this e-mail again, because i was told previous letters and e-mails were discarded, not a good idea, property owners concerns should be valid any time. By water being metered with this annexation, property owners could lose all their trees and bushes, etc. with lack of water which will be metered, who can afford to water 2 or more acres and think of the fire hazard it will create. Our beautiful properties will look like abandoned land, we could not even sell our properties and property taxes will go down, not good for Fresno!!! Who would want to buy dried up properties, an eye soar!!! Common sense will tell you this is wrong, wrong, wrong!!! More police and firefighters will be needed to police and put out fires and will probably need a new hospital, we are miles away to the closest hospital. Making a walkway next to the canal is a horrible idea, an accident waiting to happen!!! Fresno should concentrate on abandoned properties in the city limits, townhomes, condos, and houses could be built, water and sewer are already there!!! Make Fresno a beautiful city, not getting rid of historical sites, like the Fresno Courthouse, a huge misstate, lets improve not get rid of!!! There are a lot of abandoned businesses (buildings) in Fresno, why not put the new stores you are talking about so we could shop with more stores to choose from!!! Thank you for your time!!! Pease leave existing homeowners alone!!!
S. RODRIGUEZ 2

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-789
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Susie Rodriguez (Second Letter) (S. RODRIGUEZ 2)
Response to S. RODRIGUEZ 2-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Response to S. RODRIGUEZ 2-2
The comment is noted. Please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period. No further response is required.

Response to S. RODRIGUEZ 2-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Response to S. RODRIGUEZ 2-4
The comment is noted. Section 3.15, Public Services, provides a detailed analysis of the need for the construction of new or expanded fire protection or police protection facilities. Implementation of the proposed project would result in an increased demand for fire protection services. The Specific Plan includes a number of proposed policies related to fire protection, including Policy OS-11.2 which requires that fire services are provided in the Plan Area in accordance with the General Plan; and Policy OS-11.3 which requires that the City of Fresno Planning and Development Department City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-790 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx work with the Fire Department as appropriate to promote safe environments throughout the Plan Area and ensure that services can be provided in a manner that is sensitive and responsive to the needs of the community. Coordination with the FFD would address design features for safety, siting of fire stations, and facilitation of citizen involvement processes. Implementation of the proposed Specific Plan policies would ensure that fire protection services are expanded to meet the needs of the intensified development and population increase in the Plan Area. Additionally, future development within the Plan Area would be required to comply with development fees or other funding mechanisms adopted for the proposed project in order to mitigate the impacts on fire protection facilities caused by future development within the City. Payment of the applicable development fees would offset the construction and acquisition costs of required fire facility improvements.

The Specific Plan includes proposed policies related to police protection, including Policy OS-11.1 which requires that police services are provided in the Plan Area in accordance with the policies of the General Plan; and Policy OS-11.3 which requires that the City’s Planning and Development Department work with the Police Department as appropriate to promote safe environments throughout the Plan Area and ensure that services can be provided in a manner that is sensitive and responsive to the needs of the community. Coordination with FPD would address design features for safety and crime prevention, siting of police stations, and facilitation of citizen involvement processes. Implementation of these proposed Specific Plan policies would ensure that police services are expanded to meet the needs of the intensified development and population increase in the Plan Area. Additionally, future development within the Plan Area would be required to comply with development fees or other funding mechanisms adopted for the proposed project in order to mitigate the impacts on police protection facilities caused by future development within the City.

Payment of the applicable development fees would offset the construction and acquisition costs of required police facility improvements.

Payment of applicable development fees would also offset the construction and acquisition costs of any new or expanded hospital facilities in order to accommodate the proposed project. No further response is required.

Response to S. RODRIGUEZ 2-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to S. RODRIGUEZ 2-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-791
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

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From: Susie Rodriguez
To: LongRangePlanning
Subject: Re: annexation
Date: Monday, March 24, 2025 12:04:27 AM
External Email: Use caution with links and attachments
On Mar 23, 2025, at 11:52 PM, Susie Rodriguez <[email protected]> wrote:

3.1 Aesthetics, Light and Glare
Why would we want to look like Los Angeles with the addition of 44,000 new homes, the Valley is known for its beauty

3.2 Agricultural Resources and Forestry Resources
We provide the world with our agriculture products, building homes and eliminating precious land will harm the world. Not to mention the mountains and its precious resources

3.3 Air Quality
More housing and businesses will create more air pollution

3.4 Biological Resources
Natural resources will suffer by taking away farmland, animals and water resources

3.5 Cultural Resources and Tribel Cultural Resources
We need to keep our Cultural history resources, this is our past and present

3.6 Energy
Use our energy to improve what we already have, new is not always better

3.7 Geology, Soils and Seismicity
We have natural resources, mountains, rivers, lakes and fertile soil to grow our precious crops

3.8 Greenhouse Gas Emissions
More housing and businesses will contribute to greenhouse gases 1 S. RODRIGUEZ 3

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3.9 Hazards and Hazardous Materials
More construction, bigger chance of more hazardous materials being used and a risk to health, safety and property

3.10 Hydrology and Water Quality
Water quality in the city is awful, existing home owners who have great tasting well water are being asked to hook up with the city, This doesn’t make sense!!!

3.11 Land Use and Planning
Land west of Fresno is a better idea for this horrible plan, east side has more farm land, mountains, rivers and lakes

3.12 Mineral Resources
More housing, less mineral resources

3.13 Noise
More houses, more noise WHY???

3.14 Population and Housing
According to the report from one of our property owners, the findings don’t justify the new development of 44,000 homes. Within city limits, there are plenty of abandoned houses empty land where new houses, townhomes and condos could be built, water and sewer hookups are already there.

3.15 Public Services
Emergency services, local and state services will be less available.

3.16 Recreation
Money could be better spent on existing city recreation projects.

3.17 Transportation and Traffic
Fresno already has horrible traffic problems, adding more housing would only create more congestion. Public transportation is not used often.

3.18 Utilities and Service Systems
Would have to build new fire department, hospital and police to accommodate the population growth.

3.19 Wildfires
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S. RODRIGUEZ 3

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More population, more fires!!! City wants us to be metered for water, who can afford to water 2 or more acres, we would have to stop watering because of the cost and our properties would look like an abandoned dry land, a huge risk for fire. i feel Fresno city should pay our water bill since they wand us to hook up to meters. I understand new housing being hooked up to the city, but it doesn’t make sense to force established retired property owners with acreage to belong to the city. We have wells with great drinking water and our own septic tanks, the city wants us to pay $50,000 to remove our well and $50,000 to remove our septic tanks, city should pay that bill.
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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-797
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Susie Rodriguez (Third Letter) (S. RODRIGUEZ 3)
Response to S. RODRIGUEZ 3-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please also refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Response to S. RODRIGUEZ 3-2
The comment is noted. Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Additionally, please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to S. RODRIGUEZ 3-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please also refer to Master Response 4, Implications of Annexation, in Section 2, Master Responses.

Master Response 4 discusses which aspects of annexation are discussed and analyzed in the Recirculated Draft PEIR, including any future annexation requirements and the timeline of annexation. Please note that the City is aware of the requirements in the LAFCO Resolution USOI144, which explicitly sates these requirements are triggered by annexation into the City. Compliance City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-798 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx with these requirements is underway and will be completed prior to the City seeking annexation of any parcels into City limits. No further response is required.

From: Steve Sacks
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer Subject: SEDA Plan
Date: Tuesday, March 11, 2025 4:05:37 PM
External Email: Use caution with links and attachments
City of Fresno
Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
Ms Pagoulatos
This is to contest the SEDA EIR Report.

In Section 4-2 Growth-inducing Impacts, the revised EIR states: 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. This estimate is using obsolete data. The newest data from the California Department of Finance shows from 2025-2035, for the entire county of Fresno, growth at 48,641 with Fresno having

53.6% of the population. That means that the city of Fresno’s growth by 2035 is projected to be 26,071. Using the 2.99 figure per household, the projected need is for 8,719 units in Fresno by 2035. This shows no need for the SEDA Project as currently planned at all!
I live near Fig Garden Village and there are terrible streets in that area, particularly on Shaw Ave and terrible sidewalks in disrepair on Delno where my daughter’s family lives. I would like the city to fix the streets and sidewalks instead of putting our money at risk for SEDA! In the Air Quality Section 3.3.4 is this statement: The proposed project has the potential to exceed the Valley Air District’s significance thresholds during construction and operation. Implementation of the proposed project would result in the generation of substantial long-term SACKS

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3 criteria air pollutant emissions that would exceed the Valley Air District regional significance thresholds and would therefore not be considered consistent with the existing AQPs.

Fresno currently has some of the worst air quality in the country and Fresno County has the worst air quality of any large county (over 1 million) in the state of California.

Since there is no need for SEDA based on the revised population data and cleaner air is hugely important, we should skip the SEDA Project and put the money that would be spent into serving the needs of all the areas in Fresno that need low-income housing and infrastructure.

Stephen Sacks
SACKS

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-801
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Stephen Sacks (SACKS)
Response to SACKS-1
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to SACKS-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to SACKS-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Next, please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

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March 24, 2025
City of Fresno Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065, Fresno California 93721
Email: [email protected]
Re: Comments on Revised Draft Program Environmental Impact Report for Fresno Southeast Development Area (SEDA) Specific Plan Project City of Fresno, Fresno County, California State Clearinghouse Number 2022020486 dated February 7, 2025 Dear Ms. Pagoulatos,
I am submitting the following comments on the Fresno Southeast Development Area (SEDA) Specific Plan project Recirculated Draft EIR (RDEIR).

Comments on Recirculated Draft EIR (RDEIR)

3.2 - Agricultural Resources and Forestry Resources
Policy CF-3.1 Organic and Pesticide-Free Farming. Promote ecologically sensitive farming methods that are safe for farm workers, consumers, and residents by restricting pesticide use and promoting integrated pest management practices within the SEDA.

Comments:

Pesticide Use and Regulation is regulated and monitored by the California Department of Pesticide Regulation.

What law and regulation gives the City of Fresno the authority to restrict pesticide use within SEDA?
California Pesticide LawPesticide products include insecticides, herbicides, algicides (such as swimming pool products like chlorine), disinfectants and sanitizers, repellants, rodenticides, and fungicides.

The use of pool chlorine is quite extensive considering the number of pools in the City of Fresno.
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Toilet bowl cleaners that claim to sanitize or disinfect are also classified as pesticides.

Pool chlorine for swimming pools and toilet bowl cleaner both have the signal word DANGER.

Signal words are found on pesticide product labels, and they describe the acute (shortterm) toxicity of the formulated pesticide product. The signal word can be either:

DANGER, WARNING or CAUTION. Products with the DANGER signal word are the most toxic.

If SEDA is planning on restricting pesticide use for farming does SEDA also plan to restrict pesticide use for home owners, renters, or any other persons residing or working in SEDA?
What will SEDA say is organic farming as it may mean different things to different people.

This is the USDA definition of organic:

Produce can be called organic if it's certified to have grown on soil that had no prohibited substances applied for three years prior to harvest. Prohibited substances include most synthetic fertilizers and pesticides.

If the soil history is not known for the last three years the soil will need to be free of prohibited substances before it can be called organic by the USDA definition.

Policy CF-4.4 Strategic Plan for Agriculture. Encourage the long-term economic viability of Fresno County agriculture by creating a strategic plan that comprehensively addresses the needs of farmers and farmworkers. The plan should be developed in partnership with the County and private agricultural institutions. The plan should focus on, but is not limited to:
• Develop a pathway for protection of agricultural land at risk of conversion to nonagricultural uses through a review of why and to what extent agricultural land is being converted to other uses.
• Identify how to support agricultural land conservation and what economic, environmental, and public health co-benefits arise from conservation. • Analyze the existing agricultural land base and its function in the regional food system. 1 CONT
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• Recognize and protect environmental co-benefits of conserving agricultural lands and analyze how to reduce greenhouse gas emissions.
• Identify the benefit of agricultural land for priority populations such as beginning or Veteran farmers and ranchers; residents of disadvantaged or low-income communities; or California Native American Tribes.

Comments:

This Strategic Plan for Agriculture needs to be created and applied to SEDA before SEDA is approved and 6,741 acres of farmland are destroyed in SEDA. According to the Plan Area in the RDEIR there is approximately 2,475 acres of Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of Farmland of Local Importance, and approximately 1,725 ares of Unique Farmland. Further, the majority of land under Williamson Act Contract in the City and SOI is located in the Plan Area.

The destruction of farmland in SEDA would be significant and non reversible once it occurs. Agricultural Resources Impacts are Not Sufficiently Mitigated. Farmland must be protected and SEDA must account for farmland preservation.

The West Neighborhoods Specific Plan is to be considered for adoption by the Fresno City Council in Summer 2025. The West Neighborhoods Specific Plan encompasses approximately 7,077 acres in the City of Fresno city limits and unincorporated Fresno County. 62.7% of the plan area is already in City of Fresno city limits. Only 37.3% is in unincorporated Fresno County. Acreage of land zoned AL20: Limited Agriculture is 226.26 acres, acreage of land zoned AE20: Exclusive Agriculture is 66.68 acres, for a total of 292.94 acres. 9.96% of the 2,940 acres that is in the unincorporated area of Fresno County and only 4.17% of the total plan acreage of 7,077 acres. Contrast that to SEDA’s 6,741 acres of farmland which is 76.60% of SEDA’s total plan acreage of 8,800 acres.

The City of Fresno would be better served and farmland preserved by prioritizing the development of the West Neighborhoods Specific Plan. As stated earlier 62.7% of the plan area is already in the City of Fresno city limits and it also has City of Fresno infrastructure already in place.
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3.3 Air Quality
Impact AIR-1: The proposed project would conflict with or obstruct implementation of the applicable air quality plan.

Significant and unavoidable impact.

Impact AIR-2: The proposed project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non attainment under an applicable federal or State ambient air quality standard.

Significant and unavoidable impact.

Impact AIR-3: The proposed project would expose sensitive receptors to substantial pollutant concentrations.

Significant and unavoidable impact.

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

Less than significant impact with mitigation incorporated.

Cumulative Impact: The proposed project would have significant and unavoidable cumulative impacts to air quality.

Significant and unavoidable impact.

Comments:

Rankings by American Lung Association rank the air of Fresno-Madera-Hanford area as follows:

Ranked 4th worst for high ozone days out of 228 metropolitan areas.

Ranked 2nd worst for 24-hour particle pollution out of 223 metropolitan areas.

Ranked 3rd worst for annual particle pollution out of 204 metropolitan areas.

The metropolitan areas are from across the United States.

Air quality is a major problem and concern in Fresno and the San Joaquin Valley. 3

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There are serious health and environmental consequences that are not being addressed and need to be addressed in the RDEIR.

3.8 Greenhouse Gas Emissions
From Recirculated Draft EIR Executive Summary Matrix:

Impact GHG-1: The proposed project would not generate direct and indirect greenhouse gas emissions, and these emissions would result in a significant impact on the environment.

Impact GHG-2: The proposed project would not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.

Mitigation Measures:

None Required
Level of Significance After Mitigation:

N/A
Cumulative Impact: The proposed project would have a less than significant cumulative impact on greenhouse gas emissions.

Mitigation Measures:

None required
Level of Significance after Mitigation:

N/A
From Recirculated Draft Program EIR: Greenhouse Gas Emissions

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3.8.5 - Project Impacts and Mitigation Measures
Impact GHG-1: The proposed project could generate direct and indirect greenhouse gas emissions, and these emissions would result in a significant impact on the environment.
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Impact GHG-2: The proposed project could conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.

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3.8.6 - Cumulative Impacts
The geographic scope of the cumulative impact analysis for energy use is the Plan Area and portions of the City of Fresno, City of Clovis, and unincorporated Fresno County adjacent to the Plan Area. This analysis evaluates whether impacts of the proposed project, together with impacts of cumulative development, would result in a cumulatively significant impact with respect to GHG emissions. This analysis then considers whether incremental contribution of the impacts associated with implementation of the proposed project would be significant. Both conditions must apply for cumulative effects to rise to the level of significance. Based on this analysis, there is a potentially significant cumulative effect resulting from the proposed project.

As previously discussed, no single land use project could generate enough GHG emissions to noticeably change the global average temperature. Cumulative GHG emissions, however, contribute to global climate change and its significant adverse environmental impacts.

The proposed project would be consistent with relevant plans, policies, and regulations associated with GHGs, notably the most recent version 2022 version of ARB’s Scoping Plan, as well as the SJCOG’s 2022 RTP/SCS and the City’s General Plan. The proposed project would not impede upon the State’s ability to reach mandated GHG reduction targets in the future and will support State-level efforts to reduce GHG emissions. Therefore, development of the proposed project would have a less than significant cumulative impact relative to this environmental topic. In addition, the implementation of MM AIR-1b, MM AIR-1c, and MM AIR-1d would serve to further reduce GHG emissions along with criteria air pollutants and toxic air contaminants.

Accordingly, impacts related to GHG emissions would result in a less than cumulatively considerable contribution.

Level of Cumulative Significance Before Mitigation:

Less than significant impact.

Cumulative Mitigation Measures:
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None required.

From the 2023 Draft EIR Executive Summary Matrix:

Impact GHG-1: The proposed project would generate direct and indirect greenhouse gas emissions, and these emissions would result in a significant impact on the environment.

Mitigation Measures:

No feasible mitigation available.

Level of Significance After Mitigation:

Significant and unavoidable impact.

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

Mitigation Measures:

No feasible mitigation available.

Level of Significance After Mitigation:

Significant and unavoidable impact.

Cumulative Impact: The project would have a significant and unavoidable cumulative impact on greenhouse gas emissions.

Mitigation Measures:

None available.

Level of Significance After Mitigation:

Significant and unavoidable impact.

Comments:
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The RDEIR seems to be inconsistent regarding the findings of Impact GHG-1 and Impact GHG-2. Seems to be differing conclusions between the Recirculated Draft EIR Executive Summary Matrix and the Recirculated Draft Program EIR.

The 2023 Draft EIR concluded the level of significance was significant and unavoidable with no feasible mitigation available.

Was the data altered or different standards used for the 2023 Draft EIR and the 2025 Recirculated Draft EIR?
Common sense says the Level of Significance of Greenhouse Gas Emissions didn’t go away since the 2023 Draft EIR and are still significant and have an unavoidable impact and need to be addressed.

3.14 Population and Housing

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Sites Inventory
State law requires that jurisdictions demonstrate in the Housing Element that the land inventory is adequate ��to accommodate that jurisdiction’s share of the region’s projected growth�� (RHNA).

Fresno has many vacant residential development opportunities along with underutilized non-vacant sites with redevelopment potential with sufficient capacity to meet and exceed the identified housing need for 2023- 2031. The detailed sites inventory is contained in Section 1E-7 (Detailed Sites Inventory Tables), Table 1E- 7.1 and Table 1E-7.2. The opportunities shown in this inventory consist of vacant and non-vacant land in residential, mixed-use sites, and commercial districts that allow residential development. No identified constraints on these sites would prevent development or reuse during the Housing Element period.

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RHNA Summary
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Table 1E-2.15 provides a summary of Fresno’��s ability to meet the 2023-2031 RHNA of 36,866 housing units. Within the city limits, available vacant and underutilized sites are adequate to accommodate the RHNA for all income categories. The city has capacity for 18,783 lower-income units, which is 3,459 lower-income units in excess of the lower-income RHNA.

Comments:

The Sites Inventory states Fresno has sufficient capacity to meet and exceed the identified housing need for 2023-203. The RHNA Summary shows there is a surplus of 6,834 units for all income levels.

In 2023 the City of Fresno announced the state’s $250 million state fund to upgrade the city’s downtown. In a Fresnoland article dated May 12, 2023, Mayor Jerry Dyer announced the funding would include $80 million for infrastructure investments that promote building more housing and revitalizing neighborhoods. Mayor Dyer was quoted saying, “The city’s goal is to accelerate the building of 10,000 new homes downtown.

Great cities, have great downtowns. We can’t be a great city, without a great downtown.”
Resolution No 2023-292 was passed on November 16, 2023 by the Fresno CIty Council accepting the State funding of $250 million to the City of Fresno The West Neighborhoods Specific Plan is to be considered for adoption by the Fresno City Council in Summer 2025. The plan has estimated 50,800 new housing units consisting of 28,700 mixed use dwelling units and 22,100 residential dwelling units.

The West Neighborhoods Specific Plan encompasses approximately 7,077 acres in the City of Fresno city limits and unincorporated Fresno County. 62.7% of the plan area is already in City of Fresno city limits. Only 37.3% is in unincorporated Fresno County.

The citizens of Fresno and Fresno County would be better served by investing in the city limits of Fresno before they look to annexing 8,800 acres of land in unincorporated Fresno County into the City of Fresno.

5.2 - Project Objectives
Fiscal Responsibility
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• Provide self-financing for the development and on going 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.

Comments:

Until the analysis of infrastructure costs and funding are released to the public, the RDEIR is not complete. Public officials are unable to make an informed decision on the economic costs of the SEDA and the public is unable to comment before the close of the comment period. Estimates for infrastructure costs are upwards of $3-$4 billion dollars.

A public records request was made for the infrastructure costs on March 4, 2025. As of March 21, 2025 the documents have not been released. Fresnoland reporter Gregory Weaver in a March 3, 2025 article reported “Officials have yet to publicly disclose a cost estimate, despite consultants delivering one to City Manager Georgeanne White last December.”
Until the cost estimate is released and the public is able to make comments the comment period for the RDEIR should be extended 30 days from the release of the cost estimate of infrastructure to the public.

As reported in a Fresnoland article dated February 21, 2025, the City of Fresno is facing a projected budget deficit of at least $20 million. One potential strategy could be raising taxes on Fresno residents.

Officials with the Sanger School District have estimated Sanger would need to add 16 schools to handle the anticipated school age population. Money that they say they don’t have.

SEDA will also put an enormous financial burden on property owners of parcels zoned Rural Residential or Rural Cluster Residential for mandatory sewer and water connections required by the City of Fresno. Minimum estimates are $50,000 for sewer connection and $50,000 for water connection.

Fiscal responsibility of SEDA cannot be determined until the costs and funding of SEDA is released. Without that information the RDEIR is incomplete and the City of Fresno approval of the RDEIR should not even be considered.

Your consideration of the comments is appreciated.
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Sincerely,
Elizabeth Sandberg
SEDA area property owner
Member Southeast Property Owner’s Association
[email protected]
cc:

District 1: Annalisa Perea: [email protected]
District 2: Mike Karbassi: [email protected]
District 3: Miguel Arias: [email protected]
District 4: Tyler Maxwell: [email protected]
District 5: Special Election on March 18th
District 6: Nick Richardson: [email protected] District 7: Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Mayor Jerry Dyer: [email protected]

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-815
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Elizabeth Sandberg (SANDBERG)
Response to SANDBERG-1
The comment is noted. As discussed in Section 3.9, Hazards and Hazardous Materials, the use of pesticides is regulated under FIFRA. The Specific Plan contains proposed policies that would further minimize risk of contamination from pesticides. For example, Policy RC-5.2 aims to prevent contamination of the groundwater table and surface water resources and discourage all pesticide use for agricultural and landscaping uses within SEDA through the use of signage, provision of pollution prevention information to SEDA residents and remediation actions. Additionally, projectspecific pesticide use would be evaluated at the time of the project-specific CEQA analysis.

Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No environmental issues are raised, and no response is required.

Response to SANDBERG-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section 3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to SANDBERG-3
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to SANDBERG-4
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

As discussed in Section 3.8, Greenhouse Emissions, of the Recirculated Draft PEIR, the City utilizes the criteria in the CEQA Guidelines Appendix G Environmental Checklist to determine whether City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-816 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx greenhouse emissions impacts are significant environmental effects. The vast majority of individual projects do not generate sufficient GHG emissions to create a project specific impact through a direct influence to climate change; therefore, the issue of climate change typically involves an analysis of whether a project’s contribution toward an impact is cumulatively considerable. As defined in the CEQA Guidelines, Section 15355, “cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects. For future projects, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG Reduction Plan (such as a CAP).

The City of Fresno developed its first GHG Plan in 2014, which includes GHG reduction targets and emissions inventories for the years 2020 and 2035. An updated GHG Plan (the GHG Plan Update) was adopted on September 30, 2021, pursuant to a certified General Plan Program EIR (State Clearinghouse Number 2019050005). However, in 2024, following a legal challenge, the 5th District Appellate Court rejected the City’s PEIR and GHG Plan Update. Both were rescinded pursuant to a Court order. The City’s previously adopted GHG Reduction Plan (2014) has not been the subject of a legal challenge and has not been invalidated by the court. As stated, the 2014 GHG Reduction Plan includes reduction targets for 2035; however, the full 25 year buildout of the proposed project goes beyond the year 2035 and is anticipated to be fully operational in the year 2050. Therefore, this analysis evaluates the consistency of the proposed project with ARB’s latest 2022 Scoping Plan, including the proposed project’s consistency with relevant Scoping Plan measures and the latest RTP/SCS for the region within which the Plan is located. The 2022 Scoping Plan is consistent with the State’s longer-term AB 1279 GHG reduction targets of achieving carbon neutrality by 2045 and reducing GHG emissions to 85 percent below 1990 levels by 2045. Therefore, consistency with the 2022 Scoping Plan would also demonstrate consistency with the State’s long-term GHG reduction targets encapsulated by AB 1279.

The analysis contained within Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR provides a qualitative assessment of the proposed project’s compliance with the applicable plans, policies and regulations for the purposes of reducing GHG emissions to determine whether the proposed project would have a significant impact on the environment relative to GHGs.

As such, while the previously circulated Draft PEIR determined that impacts related to GHG emissions would be significant and unavoidable when evaluated against the City’s now decertified GHG Plan Update, the Recirculated Draft PEIR determined that impacts related to GHG emissions would be less than significant when evaluated for consistency with the 2022 Scoping Plan and the latest RTP/SCS for the region.

Furthermore, the Executive Summary and Section 3.8, Greenhouse Gas Emissions, have been edited in Section 4, Errata, of this document to clarify the impact findings.

The comment does not identify a legitimate basis for recirculation, and as such, no further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-817
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to SANDBERG-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

Please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses.

Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan.

Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to SANDBERG-6
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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From: Eric Schmidt
To: LongRangePlanning
Subject: SEDA opposition
Date: Wednesday, March 5, 2025 5:49:49 AM
External Email: Use caution with links and attachments
To City of Fresno,
I want to voice my opposition to the SEDA project, once called SEGA. Renaming to sound better (development) over (growth) is all smoke and mirrors. This project is very selfish by the city of Fresno to do nothing but a land grab. It still will not provide the money needed for City economics. There are ways to do infill around some projects such as Sanger West High School and Clovis South High School.

The biggest things in my mind are the land, water and air pollution. Pouring concrete over the most fertile soils in the world is the idea I have seen from the city of Fresno over the years.

You will never get that back.

The eastern edge of Fresno County is actually one of the most fertile and one with water. This does make it attractive for the city but at the cost of economics.

This is nothing but money/land grab for taxes the city wants for its unbalanced budgets in the coming years. Go after something else. Leave this area alone.

I farm in this area and DO NOT support this project. There are other ways.

Thank you - Concerned Farmer

SCHMIDT

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Response to SCHMIDT-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Additionally, please refer to Master Response 6, Infill Development Priorities, in Section 2, Master Responses. Master Response 6 provides additional information on the City’s infill priorities and how they relate to the goals of the Fresno General Plan. No further response is required.

Response to SCHMIDT-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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Hello Fresno City officials,
I am a homeowner in Fresno’s Historic Huntington District. My kids go to school at Jackson Elementary.

I am an associate professor of biology at Fresno Pacific University. Every day, I bike 3 miles to work through south Fresno.

I, along with the Jackson Neighborhood Association, oppose SEDA (Southeast Development Area Specific Plan) because it would take money away from maintenance of our existing streets and facilities, and instead SEDA would cause urban sprawl. I want Fresno to move toward healthier and less carbon intensive living, and restricting sprawl is an important way to lower the average fuel burn of residents of our city. We need to improve our existing business districts, parks, and roads rather than build sprawling new ones.

Respectfully, Dr. Andrew Sensenig, 3551 E Kerckhoff Av. , Fresno, CA, 93702, cell phone 240-320-7282, email: [email protected]
Date: March 23, 2025.

SENSENIG

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-825
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Response to SENSENIG-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

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From: Shelly Spencer
To: LongRangePlanning; District5
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nelson Esparza; Nick Richardson; Sarah Boren; Georgeanne White; Jennifer Clark; Andrew Janz; District1; District2; District3; District7; District6; District4; Jerry Dyer
Subject: Concerns about SEDA Southeast Area Specific Plan Date: Monday, March 24, 2025 4:32:24 PM
External Email: Use caution with links and attachments
I am writing with concerns about the Southeast development Area Specific Plan. Although the City is doing its best to maintain and improve Southeast Fresno, sprawling out further will just stretch budgets & staff time too thin to be able to give attention to what already needs to be done!
Just a quick assessment of my neighborhood - within half of a mile of my house - shows:

Road and sidewalk repairs needed (photos)
Stoplight still not finished by Farber (photo)
Empty Lots / Unused buildings to be developed / cleaned / followed up on (multiple photos) Likely Lead pipes in city water supply in our neighborhood (a letter from the city said this is TBA???)
More police staffing to prevent / follow up on property damage (photo) I also work in southeast Fresno. There have been numerous HVAC thefts at businesses and churches. The officer who followed up on my report - two months later - said that their backlog of reports is MONTHS long. They can't follow up on crime reports or connect possible evidence quickly enough to prevent recurring thefts! The budget doesn't enough staffing focused on this; they are dependent on the rotation of the officers on injury though this department.

The bottom line: if a new development goes in, it will reduce city funds for existing neighborhoods that need attention. A new development might seem attractive initially but the problems that are happening will just sprawl there and then there will be an even larger problem to tackle than we have now!
Again, I appreciate the efforts the city makes to respond to Fresno GO reports and to respond to police reports, but the backlog of work still needing attention, and delays in some services seem that CEDA as it currently is envisioned is not good for southeast Fresno.

Thank you.

Shelly Spencer
District 5 resident
3620 E. Kerckhoff Ave
559-425-6726
Stoplight still not finished by Farber

SPENCER

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1 Police staffing needed - we've had 3 broken windows within a year...one was on Easter morning and one on Christmas morning. Arg!

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< Shelly Spencer $
Historic Huntington • 1d • ~
•••
Arg. Again in less than a month. Anyone else have a
broken window March 31?
Not gonna let this dampen the joy of Easter, tho. Life
wins in the end.

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Shelly Spencer (SPENCER)
Response to SPENCER-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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From: Sharon Bell Stevens
To: LongRangePlanning
Cc: Annalisa Perea; Mike Karbassi; Miguel Arias; Tyler Maxwell; Nick Richardson; Nelson Esparza; Todd Stermer Subject: Concerns About the SEDA Recirculated EIR
Date: Friday, March 21, 2025 6:48:00 PM
External Email: Use caution with links and attachments
David C. Stevens and
Sharon Bell Stevens
2672 E. Alluvial Ave
Fresno, CA 93720
[email protected]
March 21,2025
City of Fresno
Planning and Development Department
Attn.: Sophia Pagoulatos, Planning Manager
I'm writing to express my concerns about the SEDA Recirculated Environmental Impact Report (EIR) Below are just a few of the key areas that I find alarming:

3.17 Transportation & Traffic
"Per the Recirculated EIR" recommends that a peak -hour ramp queue be completed at each of the recommended SR 180 intersections and that all future development under the proposed project should conduct a Vehicle Miles Traveled (VMT) analysis. Recommends that the City 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. • Support of active transportation plans and smart growth efforts that aid the State’s 2050 Climate goals. • Requests early engagement on all future development under the proposed project that could affect the State right-of-way. • Recommends that a Traffic Impact Study be prepared. • Until the recommendations are complied with the cost of the proposed infrastructure cannot be determined. Before I buy anything, I know the price of the item being purchased. I expect the City of Fresno to know the price tag before agreeing to indebting the citizens of Fresno to this unnecessary project.

How is the proposed infrastructure to be paid for when the city is already facing a deficit budget?

3.15 Public Services
Schools. The project area will be served by Sanger Unified School District and Clovis Unified

STEVENS

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1 School District. Sanger Unified has already publicly declared they have no financial ability to build the schools for the projections for substantial student population growth by 2035.

Development impact fees will be insufficient to fund new or expanded school facilities. Each section of 3.15 Public Services (Fire Protection, Law enforcement, Emergency Medical Services, Parks) emphasizes the importance of development impact fees to address the growing demand for municipal services and infrastructure in the project. These fees are projected to be insufficient to cover the cost of new school facilities in the Fresno Southeast Development Area (SEDA). Ultimately, the taxpayers of Fresno will be burdened with covering the cost of funding these necessary Public Services due to the lack of careful planning and equitable implementation.

3.3.4 Air Quality
Fresno already has some of the worst air quality in the nation, and the SEDA plan admits it will create high levels of pollution.

My husband and daughter have developed asthma since moving to the Fresno area. We do not need to lead in the category of highest asthma rate in the nation also. invest in Fresno's Existing Communities.

I volunteer at a food pantry near Fulton and Divisadero Streets where homelessness is evident. I would like to see the city build shelters for the unhoused instead of putting our money at risk for the SEDA Plan.

Updating our city sewer and water system and providing affordable housing in existing neighborhoods should be the priority of the City of Fresno rather than expanding as suggested by the SEDA Plan.

Sincerely,
David C. Stevens
and
Sharon Bell Stevens
[email protected]
1(559) 871-1455
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STEVENS

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-843
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx David and Sharon Bell Stevens (STEVENS)
Response to STEVENS-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to STEVENS-2
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to STEVENS-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

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From: Laurie Tidyman-Jones
To: LongRangePlanning
Subject: SEDA
Date: Wednesday, March 12, 2025 7:29:16 AM
External Email: Use caution with links and attachments
According to the Fresno city planning Department, Tanning is to reflect citizens and that we are to receive a red carpet invite for input and change Is that why 400 letters of concern about Seda were tossed? Is it that why the demanded Revised EIR report is just a push for the project with the same illogical Assumptions based on inaccurate data?
Is that why it is attempting to avoid costly mitigation for the massive development’s environmental impacts, particularly regarding greenhouse gas emissions and vehicle miles traveled (VMT)? This affects every single citizen!
(“According to city documents, SEDA would increase Fresno’s annual carbon emissions by approximately 500,000 tons – effectively wiping out the city’s progress on climate goals for the next two decades. The project’s estimated emissions could carry a hefty $25.5 million annual price tag to clean up emissions, according to standard federal accounting measures.”) Is that whyFresno officials are making an extraordinary claim: due to the area’s planned 1-to-1 jobs-to-housing ratio, residents in this car-dependent suburban development will drive over 80% less than standard planning models predict — somehow making them even less car-dependent than downtown San Franciscans, according to official data from the state’s air resources board, and even New Yorkers”?
Is that why A plan that would cost one to $3 billion in infrastructure is more important to you than enhancing and taking care of a city that is already 22 million in the hole? Is this a red carpet two people already living in Fresno and the house?

TIDYMAN-JONES

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I worked at Reedley College for 16 years and Family lived in Sanger for 30 years. I know that area pretty well. The audacity to suggest that all those people in those 45,000 homes are going to be working in that area is absurd.

Employment there is extremely challenging and there are no new mega businesses that would hire all those high-end salary expecting folks.

SEDA is bad for South east Fresno, bad for the county and bad for current residents of Fresno.

It is only a good plan for developers and the planning commission needs to not be representing them as it appears they are!
Sincerely,
Laurie Tidyman-Jones
423 E. Muncie Ave.

Fresno, CA 93720
5592813588

TIDYMAN-JONES

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-847
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Laurie Tidyman-Jones (TIDYMAN-JONES)
Response to TIDYMAN-JONES-1
The comment is noted. Please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period. No further response is required.

Response to TIDYMAN-JONES-2
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Response to TIDYMAN-JONES-3
The comment is noted. Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR.

Additionally, as detailed in Section 3.8, Greenhouse Gas Emissions, of the Recirculated Draft PEIR, while implementation of the proposed project would generate an increase in GHG emissions, its guiding principles, design guidelines, and proposed land use designations for the Plan Area would contribute to minimizing emissions on a per capita basis to the extent feasible. Guiding principles and objectives of the proposed project include providing for a balanced mix of uses, boosting the economy, and promoting sustainable development. Additionally, objectives of the proposed project include encouraging a balanced mix of uses and promoting development that reduces VMT and encourages active transportation. Applicable General Plan policies support the installation of electric infrastructure to support electric vehicles at residential, commercial, and industrial land uses. Future developments consistent with the proposed project would be subject to myriad State regulations that will reduce emissions from project construction and operation, including Title 24 and CALGreen standards and the California Code of Regulations, which the City has adopted, as well as the California Energy Code, the Model Water Efficient Landscaping Ordinance, and State regulations on refrigerants and consumer products. In addition, as detailed in the Regulatory section, GHG emissions from mobile sources would be reduced by State regulations, including the Low Carbon Fuel Standard, the Pavley Standard, the Advanced Clean Car and Zero-Emission Vehicle (ZEV) programs, and the Heavy-Duty Vehicle GHG Emission Reduction Regulation. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-848 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to TIDYMAN-JONES-4
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

No further response is required.

Response to TIDYMAN-JONES-5
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR.

The comment is noted. Please refer to Master Response 11, Clarifying Information on VMT Projections, in Section 2, Master Responses. Master Response 11 provides additional clarifying information on the VMT projections and findings included within the PEIR. No further response is required.

Response to TIDYMAN-JONES-6
The comment is noted. Please refer to Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 2 provides a response to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

From: Sarah Valentine
To: LongRangePlanning
Subject: Protect Fresno’s Future: Stop SEDA Now
Date: Monday, March 24, 2025 4:43:56 PM
External Email: Use caution with links and attachments
To Whom It May Concern,
I hope this email finds you well. Today, I come to you wearing many hats—those of a wife, a mother, a nonprofit worker in my neighborhood, and a parent advocate for my children's elementary school. These roles allow me to see Fresno through many lenses, and I am compelled to speak out because I am tired of seeing the challenges we face every day.

The Southeast Development Area (SEDA) Specific Plan proposes adding 9,000 acres of urban sprawl to Fresno, a move that will have long-lasting consequences for our community. This plan will divert resources away from existing neighborhoods that desperately need attention, such as the Jackson and Historic Huntington neighborhoods.

These areas are already grappling with significant challenges, including high crime rates that threaten the safety and well-being of residents. Reports of property crimes, vandalism, and even violent incidents are far too common.

Families in these neighborhoods live with the daily reality of unsafe streets, inadequate lighting, and a lack of resources to address these issues. Expanding into new areas while neglecting these pressing concerns is not only irresponsible but also unjust.

Instead of expanding, Fresno should prioritize fixing the problems in the areas we have already developed. Our community deserves better. Generations are depending on us to address the pressing needs in established neighborhoods before considering expansion.

We cannot afford to let this plan move forward while our existing neighborhoods remain neglected. It’s time to put voters first and prioritize the needs of our community. Let’s work together to ensure a better future for Fresno.

Thank you for your attention to this critical matter. Please feel free to reach out if

VALENTINE

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1 you have any questions or would like to get involved further.

Best regards,
Sarah Valentine
Mom, Wife, Program Manager (Jackson CDC) & Jackson Elementary parent advocate
Cell# 559-725-0793
Email: [email protected]
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VALENTINE

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-851
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Sara Valentine (VALENTINE)
Response to VALENTINE-1
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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From: Daniel Vartan
To: LongRangePlanning
Subject: Support for SEDA plan
Date: Sunday, March 16, 2025 12:52:15 PM
External Email: Use caution with links and attachments
To Whom it May Concern,
I'm writing to voice my support for the current SEDA plan. The area it encompasses would make a great addition to the city if developed well and to high standards. Fresno has a lot to offer for people from other parts of the state who are looking for safe, clean, and reasonably affordable neighborhoods to raise families, but we have to provide them.

I hope the City staff persists in pursuing approval of this plan. Thank you, Daniel Vartan
Citizen
Sent from my iPhone
VARTAN

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-855
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Daniel Vartan (VARTAN)
Response to VARTAN-1
The comment is noted. This comment has been passed to the Lead Agency for their review and consideration of the proposed project as a whole. However, no environmental issues pursuant to CEQA are raised, and no response is required.

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From: Wes Bigham
To: LongRangePlanning
Subject: SEDA EIR
Date: Monday, March 24, 2025 4:36:56 PM
External Email: Use caution with links and attachments
EIR 3.2 AGRICULTURAL RESOURCES : FARMLAND IS THE BACKBONE OF FRESNO,CO. THE SOUTHEAST AREA IS PRIME LAND. HOW DOES THE CITY PLAN TO REPLACE THIS LAND.

EIR 3.3 AIR QUALITY:HOW WILL THE INCREASE IN TRAFFIC AND

CONSTRUCTION IMPACT THE AIR QUALITY AND HEALTH OF THE PUBLIC EIR 3.10 WATER QUALITY: WATER IS A COMMODITY IN THIS VALLEY. THIS PROJECT WILL CAUSE THE WATER TO DROP IN THE SEDA AREA.WHAT IS THE CITIES PLAN FOR THIS PROBLEM.

W. BIGHAM

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-859
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Wes Bigham (W. BIGHAM)
Response to W. BIGHAM-1
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR.

Additionally, please refer to Master Response 10, Clarifying Information on Agricultural Resources, in Section 2, Master Responses. Master Response 10 elaborates on the methodology used in Section

3.2, Agricultural Resources and Forestry Resources, of the Recirculated Draft PEIR. No further response is required.

Response to W. BIGHAM-2
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

Response to W. BIGHAM-3
The comment is noted. Please refer to Master Response 8, Clarifying Information on Water Supply and Water Quality, in Section 2, Master Responses. Master Response 8 further elaborates on the availability of water supply and potential impacts to water quality in the Plan Area as a result of the implementation of the proposed project. No further response is required.

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From: Randy White
To: LongRangePlanning
Subject: We oppose SEDA
Date: Monday, March 24, 2025 8:46:34 AM
External Email: Use caution with links and attachments
To Whom it may concern,
My wife and I are retired and live in the Jackson Neighborhood (near Jackson Elementary). We are invested in our community and local school. We are deeply concerned about the proposed SEDA development. Here are our concerns:

1. This massive investment in housing is based on old city growth data. Current growth is far below the growth of 15 years ago, the data of which is being used in the justification of SEDA. A development of this size is not necessary.

2. It will further sprawl in our city, which not only eats up more land, but over-taxes our city resources for water, fire, police, recreation, etc.

3. It reduces the incentive to do in-fill housing, which we need in the core of our city.

4. And just as important, it reduces the financial resources available for the maintenance and repair of our current neighborhoods, including the Jackson Neighborhood where we live. This neighborhood, like many others in our urban core, has been neglected. The streets and alleys need repair, the trees trimmed, the local greenspace needs development, and better maintenance.

We urge the city to reconsider this massive development.

Sincerely,
Randall & Tina White
3635 E Kerckhoff Ave
Fresno, CA 93701
559.285.9206
WHITE

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-863
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Randall and Tina White (WHITE)
Response to WHITE-1
The comment is noted. Please refer to Master Response 9, Clarifying Information on Population Projections, in Section 2, Master Responses. Master Response 9 discusses the Recirculated Draft PEIR’s methodology for the population projections contained within the Recirculated Draft PEIR. No further response is required.

Response to WHITE-2
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis. No further response is required.

Response to WHITE-3
The comment is noted. Please refer to Master Response 1, Non-CEQA Issues Not Addressed in Final PEIR, and Master Response 2, General Opposition Comments Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. These master responses provide additional information on the scope of CEQA, including any non-CEQA issues, and respond to comments that express general opposition to or disapproval of the proposed project or the environmental analysis.

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YOKOYAMA

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COMMENTS ON THE DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN PROJECT

CITY OF FRESNO, FRESNO COUNTY, CA
History
State Clearinghouse Number 2022020486
AUGUST 27, 2023
Submitted by Email and USPS to
City of Fresno
Jennifer Clark, Director
Planning & Development Dept.
2600 Fresno Street, Third Floor, Room 3065
Fresno, CA 93 721
[email protected]
RESUBMITTED MARCH 19, 2025
by email to [email protected]
c/o Sophia Pagoulatos, Planning Manager
Submitted by
VICTORIA Y. YOKOYAMA
8507 E OLIVE AVE
FRESNO, CA 93737
The author purchased a five-acre parcel in Southeast Fresno in 1994 from a well-known African American farmer, built a home on the lot in 1997, and moved to Southeast Fresno from northern Clovis. The author and family have enjoyed the benefits of a Southeast Fresno rural life style by living in the Rural Residential zone for more than 30 years. The author's land is bordered on the south side by Fancher Creek Canal, and the author has been a conservationist in protecting the wildlife associated with the natural waterway. In 2001, the author objected to the proposed construction of a linear park on the Fancher Creek Canal ditch bank. In 2008, the original SEGA plan included the linear park. The SEGA plan then made an abrupt transition to the SEDA Plan in 2022. The issuance of the SEDA plan EIR was then announced in 2023 without adequate public warning to impacted property owners, and members of the public.

In 2025, the City of Fresno created confusion by resubmitted the 2023 EIR to select individuals as a modified document. Those who responded to the 2023 EIR were not specifically informed by the city that 2023 public comments would be eliminated unless resubmitted by March 24.

Thereby, city government has effectively diminished public involvement in the SEDA Plan.

Comments on SEDA EIR:

A. Environmental Setting 3.4.2
Plants and Animals Have No Voice, and Are Heard Through Those Who Know They are There.

YOKOYAMA

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The EIR fails to identify the significant negative impact on biological resources in the SEDA specific plan. The EIR fails to identify the ecological damage caused by building a Neighborhood Town Center in the center of a SEDA block of Rural Residential zoned land bordered by E McKinley Ave on the north, N Fancher Ave on the east, E Tulare Ave on the south, and De Wolf Ave on the west. This block of land is now referred to as McKinley x Fancher x Tulare x De Wolf (MFTD ), and the biological resources in this area have been documented by the author. The primary features of the MFTD include the natural waterway of Fancher Creek Canal, an established community of homes on small to medium acreage parcels, a horticultural nursery, and a golf course (Exhibits 1-1 and 2-2). The MFTD is only about a tenth of the land that comprises the urban growth area in the SEDA specific plan, and serves as an example of the detrimental effects of urban development on wildlife, species diversity, and environmental habitat. Under the SEDA specific plan, agricultural farmlands and rural residential areas will suffer from unrecoverable losses of biodiversity, and abundance of animal and plant life through habitat destruction. The SEDA plan EIR fails to identify future ecological decline in the region, loss of community, and quality of life.

1. Disagree with Table ES-1: Executive Summary Matrix; Section 3 .4 - Biological Resources.

No mitigation measures are proposed for Impact BIO-1, 2, 3, 4, and 5. MFTD includes legally protected and sensitive species of environmental concern, riparian habitat, wetlands, native resident species, and tree preservation measures.

2. Disagree with Exhibit 3.4-1. The Fancher Creek Canal lacustrine and riverine land cover types and vegetation communities are omitted in part in the MFTD. Exhibit 3.4-1 shows lacustrine, pasture, and private ponds on the southern border of the Neighborhood Town Center in the middle of the MFTD. The riverine habitat must be included from this location northeast to the eastern boundary of the SEDA.

3. Disagree with Table 3.4-3. Rural and existing urban vegetation provides good habitat for special-status species such as the San Joaquin Kit fox (Cypher and Van Hom Job, 2012) and Monarch butterflies. Pasture provides food for wildlife herbivores including birds and rodents, and prey for carnivores including foxes and raptors. Rural and urban gardens provide habitat for Monarch butterflies (Cutting and Tallamy 2015), bees and other pollinators.

4. Disagree with Table 3 .4-5: Special-status Wildlife Species within the Plan Area, and disagree with two text boxes in Exhibit 3.4-2 that reiterate information in Table 3.4-5 and Appendix C.

Additional special species with imperiled status known to in occur in MFTD from the California Natural Diversity Database (CNDDB) (2023) must be added to Table 3.4-5 as follows:

Fisher (Pekania pennanti) Comments - Observed 2013.

Bald eagle (Haliaeetus leucocephalus) Comments - Observed 2021 and a feature the ecological community (Snell Taylor et al. 2018).

Monarch (Danaus plexippus plexippus) Comments - Observed and Resident population (Davis 2021).

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Cooper's hawk (Accipiter cooperii) Comments-Annual Nesting Pairs Observed.

Gilded flicker (Colaptes chrysoides) Comments -Annual Nesting Pairs Observed.

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Western pond turtle (Emys marmorata) Comments - Observed egg laying near Fancher Creek Canal in the MFTD.

Great blue heron (Ardea herodias) Comments - Observed and a feature of the ecological community (Snell Taylor et al. 2018).

Great egret (Ardea alba) Comments-Observed and a feature of the ecological community (Snell Taylor et al. 2018).

Snowy egret (Egretta thula) Comments - Observed and a feature of the ecological community (Snell Taylor et al. 2018).

5. Disagree with Exhibit 3.4-2. The distribution of the San Joaquin kit fox, Vulpes macrotis mutica, is shown in a red circle limited to Sanger. The northern distribution of the San Joaquin kit fox into the MFTD is not addressed in the EIR. Movement of San Joaquin kit foxes into rural and urban populations has helped prevent its extinction (Cypher and Van Hom Job, 2012).

6. Disagree with Exhibit 3.4-2. Swainson's hawk, Buteo swainsoni, must be added inside the same red circle around the MFTD as the western yellow-billed cuckoo, Coccyzus americanus occidentalis. Nesting pairs of Swainson's hawks are found in the MFTD.

7. Disagree with Exhibit 3.4-2. The distribution ofleast Bell's vireo, Vireo bellii pusillu, would not be limited to the red circles around Tarpey Village, and Clovis, but would be found across the SEDA.

8. Disagree with Wetlands and Waters of the U.S. and State. Fancher Creek Canal provides unlimited opportunities for both vegetation and wildlife and is not a limited resource as described. Fancher Creek Canal is a natural waterway originating from the Kings River, and is the dominant natural feature in MFTD.
a. The EIR fails to identify that the SEDA is located near the Kings River. The EIR states that the plan is not located near the San Joaquin River.
b. The EIR fails to identify the negative impact on the fish species that are found in the natural waterway of the Fancher Creek Canal (University California 2014) and the fact that some fish are California native species.
c. The EIR fails to identify the negative impact of developed open space designated for a linear park on the Fancher Creek Canal Bank (Exhibit 3 .11-1 ). The Fresno Irrigation District has stated opposition to using its canals as urban trails (Fresno Irrigation District 2020). Any disturbance or human activity on the Fancher Creek Canal bank will disrupt the fragile environmental habitat which now supports a diversity of animal and plant life including protected species.

YOKOYAMA

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9. Disagree with Wildlife Movement Corridor statement that SEDA would not be expected to substantially degrade the existing conditions. The SEDA will substantially degrade existing conditions for native resident and migratory fish, wildlife species, wildlife corridors, and nursery sites in the MFTD. The natural stream bed of the Fancher Creek Canal flows with water throughout the year and is the habitat for fish including trout, ducks, frogs, toads, muskrats, weasels, and many aquatic insects including damselflies, dragonflies, and mayflies. The banks of Fancher Creek Canal are lined with established trees including native oaks that provide habitat for birds including raptors, mammals including foxes, racoons, rodents, amphibians, and reptiles including snakes and lizards.
a. The EIR fails to identify the California Department of Fish and Game agreement with the Fresno Metropolitan Flood Control District in preservation and management of wildlife habitats along Fancher Creek (Fresno Metropolitan Flood Control District 2003). b. The EIR fails to identify the negative impact on birds in the SEDA (Fresno Audubon Society 2019) and those species associated with the Fancher Creek Canal habitat. i. Raptors found in the MFTD that are protected under the California Department of Fish and Game Code, Sections 3503, 3503.5, 3505 and 3513, and California Code of Regulation, Title 14, Sections 251.1, 652 and 783-786.6 are as follows:

Red-tailed hawk (Buteo jamaicensis) Comments -Annual Nesting Pairs Observed.

Great-homed owl (Bubo virginianus) Comments-Observed and Nesting Pairs Highly Likely.

Barn owl (Tyto alba) Comments-Observed and Nesting Pairs Highly Likely.

Turkey vulture (Cathartes aura) Comments - Observed and a feature of the ecological community (Snell Taylor et al. 2018).

Red-Shouldered hawk (Buteo lineatus) Comments-Observed and a feature of the ecological community (Snell Taylor et al. 2018).
ii. Established populations of the California State Bird are found in the MFTD.

California quail ( Callipepla Californica) Comments - Annual Nesting Pairs Observed. iii. Species of birds found in the MFTD protected under the Migratory Bird Treaty Act (U.S.

Fish and Wildlife Service 2023) include the following:

Wood duck (Aix sponsa) Comments -Annual Nesting Pairs Observed.

Mallard duck (Anas platyrhynchos) Comments -Annual Nesting Pairs Observed.

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Swift sp. Comments -Annual Nesting Populations under Fancher Creek Canal bridges Observed.

Others species of protected birds observed include, but are not limited to the following:

Canada goose, Common merganser, Double crested cormorant, White tailed kite, Killdeer, California gull, Mourning dove, Bell's Vireo, Black phoebe, American pipet, many Warbler spp., White crowned sparrow, many Sparrow spp., Spotted towhee, Ruby-crowned Kinglet, Bushtit, Dark eyed junco, Brewer's blackbird, American Robin, Northern mockingbird, Woodpecker sp., Sapsucker sp., Magpie sp., Oak titmouse, Blue-gray gnat catcher, Western bluebird, House finch, Lesser goldfinch, Belted kingfisher, Black-headed grosbeak and more. c. The EIR fails to identify the negative impact on biodiversity in the SEDA. Small diversified farms in the MFTD grow specialty and vegetable crops, and raise farm animals including poultry, swine, sheep, cattle, and horses. Homes adjacent to Fancher Creek Canal have ponds (Exhibit 3.4-1) and others have extensive ornamental gardens. The rural residential area supports a diversity of plant species, some that are native to California and the US. Cultivated and natural vegetation includes established trees, shrubs, grasses, and flowers. The rural landscape supports a growing diversity of wildlife including mammals, marsupials, rodents, birds, reptiles, amphibians and insects.
i. Pollinators. The EIR fails to identify the negative impact of removing pollinator habitat from areas in the SEDA that would contribute to an agricultural disaster in the region. Pollinators including hummingbirds, butterflies, bats, and bees are in decline in California (Chrobak 2022), across the U.S., and globally (Rhodes 2018). Plants in agricultural margins have the potential to greatly enhance habitat connectivity for pollinating insects (Wolterbeek 2023; Dilts et al. 2023) and prevent biodiversity collapse while providing natural pollination services. A variety of plant types found in gardens attract a diversity of bees (Frankie 2019). Gardens are larger in the rural residential areas of the MFTD compared to the city helping to support pollinator diversity and survival, and restore habitat for the Monarch butterfly (Cutting and Tallamy 2015). ii. Horticultural Nursery. The EIR fails to identify the negative impact of replacing a large horticultural plant nursery with a Neighborhood Town Center in the MFTD (Exhibits 1-1, 2-2, 3 .11-1, and 5-1 ). The nursery is classified as unique farmland in the SEDA (Exhibit 3 .2-1 ), conducive to the rural residential landscape, and supports biodiversity (Liquete et al. 2016). iii. Golf Course. The EIR fails to identify the environmental value of a golf course located in the southern area of the MFTD. Golf courses support biodiversity and provide ecosystem services (Petrosillo et al. 2019). The golf course in Exhibit 5-2, Farmland Conservation Alternative, is replaced by urban development.

10. Disagree with Regulated Trees. The EIR fails to identify the negative impact on California native oaks that are found in the SEDA and along the Fancher Creek Canal banks in the MFTD including valley Oak (Quercus lobata) and California live Oak (Quercus agrifolia). One hundred-year-old eucalyptus trees grow from the banks of Fancher Creek Canal. Although these extremely tall trees are not protected, they are suitable habitats for nesting birds, especially raptors.

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a. EIR fails to identify the Fresno County oak woodland policy (UC Oaks 2022) and impact of the plan on oak trees in the SEDA.
b. EIR fails to identify the Oak Woodlands Conservation Act (2001) and impact of the plan on oak trees in the SEDA.

B. Regulatory Framework 3.4.3

1. The EIR fails to identify the significant negative impact of a Neighborhood Town Center in the MFTD community. The SEDA specific plan does not define the purpose of the MFTD Neighborhood Town Center. Therefore, the land can be used for an elementary school (two schools are already located nearby), a local park (residents already live in open spaces), community gardens (residents have their own gardens) or a range of housing options or retail shopping which is apparently the objective of a Neighborhood Town Center in the MFTD. a. The property designated as the Neighborhood Town Center in the MFTD is not owned by the current horticultural nursery operators according to Fresno County public records. The motive for Fresno City planners to designate this particular site for development is questionable, especially when a second Neighborhood Town Center is planned about 3000 ft to the west. b. The EIR fails to address the significant negative environmental impact of the Neighborhood Town Center on the Fancher Creek Canal habitat along the development's southern border (Exhibit 3.4-1).
i. Fresno General Plan PEIR Mitigation Measures BIO-1.1, -1.2, and -1.3 are avoidance measures that justify eliminating the Neighborhood Town Center from the MFTD in the SEDA specific plan (Exhibits 1-1 and 2-2) and in Alternative 2-Consolidated Business Park Alternative (Exhibit 5-1 ).

C. Thresholds of Significance 3.4.5

1. A Neighborhood Town Center in the MFTD of the SEDA specific plan would be significant because of the substantial adverse effect on the special-status species associated with the Fancher Creek Canal habitat (Impact Bio-1) by disrupting the environment that is currently a favorable habitat for the listed special-status species.

D. Level of Significant After Mitigation 3.4.6

1. Disagree with Impact BIO-1 determination that the level of significance before mitigation is less than a significant impact. The impact would be significant before mitigation on specialstatus species (Impact BIO-1) with a Neighborhood Town Center in the MFTD of the SEDA specific plan.

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a. Implementation of Mitigation Measures BIO-1.1, -1.2, -1.3 to eliminate a Neighborhood Town Center in the MFTD of the SEDA specific plan would result in a level of significance after mitigation of less than significant impact.

2. Disagree with Impact BIO-2 determination that the level of significance before mitigation is less than a significant impact. The impact would be significant before mitigation on the riparian habitat of the Fancher Creek Canal (Impact BIO-2) with a Neighborhood Town Center in the MFTD of the SEDA specific plan.
a. Eliminating the Neighborhood Town Center in the MFTD of the SEDA specific plan would result in a level of significance after mitigation of less than significant impact.

3. Disagree with Impact BIO-4 determination that the level of significance before mitigation is less than a significant impact. The impact would be significant before mitigation on fish, established protected species, and wildlife movement through the corridor of the Fancher Creek Canal (Impact BIO-4) with a Neighborhood Town Center in the MFTD of the SEDA specific plan.
a. Eliminating the Neighborhood Town Center in the MFTD of the SEDA specific plan would result in a level of significance after mitigation of less than significant impact.

4. Disagree with Impact BIO-5 determination that the level of significance before mitigation is less than a significant impact. The impact would be significant before mitigation on California native oak trees within the MFTD and SEDA specific plan. a. Fresno County has an oak woodland policy (UC Oaks 2022) and the Oak Woodlands Conservation Act (2001) applies to oak trees in the SEDA specific plan.

E. Alternatives 1, 2, and 3 to the SEDA
The results of the author's evaluation of the impact of the SEDA on biological resources in the MFTD would apply to the entire SEDA specific plan region. The SEDA specific plan and the adverse effects of a Neighborhood Town Center on biodiversity and environmental habitat in the MFTD would also affect the adjacent areas of Sanger. The SEDA is a plan that supports urban sprawl into established rural residential and agricultural areas, and will destroy biological resources. Environmentally conscious agricultural and rural practices can benefit wildlife, but urban development will cause the greatest threat to all wildlife species and their habitats (Kucera and Barrett 1995).

1. Acceptable: Alternative 1-No Project Alternative is the preferred alternative and would have no significant environmental (Table 5-1) effect on the existing biological resources in the MFTD and within the region of the SEDA boundaries.

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2. Not Acceptable: Alternative 2-Consolidated Business Park Alternative (Exhibit 5-1) would have the same unacceptable and significant environmental impact in the MFTD as the SEDA specific plan. In Alternative 2, the Neighborhood Town Center bordered by the Fancher Creek Canal on the south would remain in the MFTD. Alternative 2 will destroy farmland and cause habitat fragmentation and destruction that result in an unrecoverable loss of biological resources within the SEDA.
a. Disagree with Table 5-1 Biological Resources, Alternative 2 quantitative environmental effect is greater than or equal to (~) in part, and greater than (>) in part.

3. Acceptable: Alternative 3-Farmland Conservation Alternative (Exhibit 5-2) would eliminate the Neighborhood Town Center, and the golf course a source of habit in the MFTD, but the Fancher Creek Canal that supports environmental habitat and species diversity would be preserved. Alternative 3 would implement the MM AG-2 mitigation measure to preserve farmland, and prevent farmland conversion into nonagricultural uses. Alternative 3 limits urban sprawl into farmland and helps preserve biological resources, and conservation of the environmental and ecological integrity of the SEDA.

F. References
California Natural Diversity Database (CNDDB). July 2023. Special animals list. California Department of Fish and Wildlife. Sacramento, CA.

Chrobak, U. 2022. The plight of the pollinators. UC Davis Magazine, Agriculture, Environment, Fall/Winter 2021-22, Features.

Cypher, B. L. and C. L. Van Hom Job. 2012. Management and conservation of San Joaquin Kit coxes in urban environments. Proc. 25th Vertebr. Pest Conf. Univ. Calif. Davis. p. 347-352.

Cutting, B. T. and D. W. Tallamy. 2015. An evaluation of butterfly gardens for restoring habitat for the Monarch butterfly (Lepidoptera: Danaidae). 44 (5): 1328-1335.

Davis, A. K. 2022. Monarchs reared in winter in califomia are not large enough to be migrants.

Comment on James etal. First population study on winter breeding monarch butterflies, Danaus plexippus (Lepidoptera: Nymphalidae) in the urban south bay of San Francisco, California.

Insects 13 (1): 63.

Dilts T. E., S. H. Black, S. M. Hoyle, S. J. Jepsen, E. A. May, and M. L. Forister. 2023.

Agricultural margins could enhance landscape connectivity for pollinating insects across the Central Valley of California. U.S.A. PLoS ONE 18(2).

Frankie, G, J. Pawelek, M. H. Chase, C. C. Jadallah, I. Feng, M. Rizzardi and R. Thorp. 2019.

Native and non-native plants attract diverse bees to urban gardens in California. J. Pollinat.

Ecol. 25 (3): 16-23.

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Fresno Audubon Society. 2019. Checklist of the birds of Fresno and Madera Counties -August 2019.

Fresno Irrigation District. 2020. A century of excellence - Urban trails along FID's canals.

Fresno Irrigation District, Fresno, CA. p. 55-56.

Fresno Metropolitan Flood Control District. 2003. Fresno Metropolitan Flood Control District Service Plan. Notice of Determination. SCH Number 1984091707.

Kucera, T. E. and R.H. Barrett. 1995. Displaced by agriculture, urban growth: California wildlife faces uncertain future. California Agriculture 49 (6): 23-27.

Liquete, C., N. Cid, D. Lanzanova, B. Grizzetti, and A. Reynaud. 2016. Perspectives on the link between ecosystem services and biodiversity: The assessment of the nursery function.

Ecological Indicators 63: 249-257.

Oak Woodlands Conservation Act. 2001. Assembly Bill No. 242. Department of Fish and Wildlife. Sacramento, CA.

Petrosillo, I, D. Valente, M. R. Pasimeni, R. Aretano, T. Semeraro, and G. Zurlini. 2019. Can a golf course support biodiversity and ecosystem services? The landscape context matter.

Landscape Ecol. 34: 2213-2228.

Rhodes, C. J. 2018. Pollinator decline - an ecological calamity in the making? Science Progress 101 (2): 121-160.

Snell Taylor, S. J., B. S. Evans, E. P. White and A. H. Hurlbert. 2018. The prevalence and impact of transient species in ecological communities. Ecology 99 (8): 1825-1835.

UC Oaks. 2022. Oak Woodland Policies of 41 California Counties-Fresno. Univ. Calif.

Agricul. Nat. Res. Coop. Ext. Fall 2022.

U.S. Fish and Wildlife Service. 2023. Revised list of migratory birds protected by the Migratory Bird Treaty Act. Federal Register 88 (145): 49310-49355.

University of California. 2014. Fish species by location- 'Fancher Creek Canal180300090303'. California Fish Website, Feb. 26, 2014.

Wolterbeek, M. 2023. Connecting habitat in the Central Valley could help save California's pollinators. Nevada Today Science & Technology, Feb. 10, 2023.

The NOP and copies of comments received are included as Appendix A to the Draft PEIR. The City also hosted three workshops and one listening session in May 2022.

The previously circulated Draft PEIR was circulated for a public review period between July 14, 2023, and August 28, 2023 (45-day review period). The Draft PEIR was publicly available at the City of Fresno Planning and Development Department at 2600 Fresno Street, Room 3065, and the Fresno County Public Library at 2420 Mariposa Street. In addition, the Draft PEIR was posted on the City Planning and Development website at www.fresno.gov/SEDA here during the public review period.

On July 24, July 27, and August 12, 2023, three in-person public drop-in events were held at Hmong Alliance Church located at 8234 East Belmont Avenue, Sequoia Elementary School located at 1820 South Armstrong, and Young Elementary School located at 3140 North Locan Avenue, respectively.

Individuals and organizations/agency representatives were invited to provide written comments on the Draft PEIR and Specific Plan at these public drop-in events.

The Partial Recirculated Draft PEIR, which was limited to the Geology, Soils, and Seismicity and the Transportation and Traffic sections, was circulated for a public review period between October 3, 2023, and November 17, 2023.

The Recirculated Draft PEIR was then circulated for a public review period between February 7, 2025, and March 24, 2025.

Furthermore, please refer to Master Response 3, Clarification Regarding Previous Comments Received, in Section 2, Master Responses, of this document. Master Response 3 provides clarifying information related to the review of or response to any comments received on the previously circulated Draft PEIR and Partial Recirculated Draft PEIR, including comments incorporated by reference in the public comment period. No further response is required.

Response to YOKOYAMA-2
The comment is noted. Impacts to biological resources are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Recirculated Draft PEIR, subsequent development under the proposed project could result in the direct/indirect loss of natural vegetation communities that provide suitable habitat for 27 special-status plant and wildlife species that have the potential to occur or are known to occur within the Plan Area. Development within the Plan Area could also result in the loss or degradation of natural habitats, which may support special-status plant and wildlife species. However, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to biological resources, specifically within the Parks, Open Space, and Schools Element (POSS). Project-level implementation of the General Plan Policies POSS-5-a through POSS-5-f would reduce potential project impacts to special-status species and their associated habitats. Furthermore, implementation of MM BIO-1a through MM BIO1d would ensure that if one or more of these special-status species occur in the Plan Area, the City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-876 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx project area would be evaluated to determine whether species are present using survey methods applicable at the time of project application. The risk of mortality would be avoided to the maximum extent feasible. Additionally, all future development in the Plan Area would be required to comply with the proposed Specific Plan policies pertaining to biological resources, including Policy OS-2.2, which protects passive open space, and Policy OS-5.2, which protects habitat corridors.

Implementation of the City’s relevant General Plan policies pertaining to biological resources (POSS5-a through POSS-5-f); MM BIO-1a through MM BIO-1d; and Specific Plan Policies (OS-2.2 and OS5.2) would reduce impacts to special-status species to a less than significant level.

Additionally, all future development would be required to comply with the approved General Plan, including Policies (POSS-6-a through POSS-7-d) that would reduce impacts to wildlife movement corridors by providing buffer zones, control stormwater runoff, and providing periodic monitoring of the biological resource conditions. Additionally, MM BIO-2a through MM BIO-2c would require preconstruction clearance surveys and mitigation if necessary to protect special-status species. These policies and mitigation measures would reduce potential impacts to wildlife movement corridors to a less than significant level.

Additionally, all future development in the Plan Area resulting from the proposed project must comply with the proposed Specific Plan policies pertaining to biological resources, including Policy OS-2.2, which protects passive open space, and Policy OS-5.2, which protects habitat corridors. As such, potential project-related impacts would be less than significant.

Furthermore, the proposed project would implement MM AG-1, which would require individual projects to analyze impacts to Prime Farmland, Unique Farmland, and Farmland of Statewide Importance and require the implementation of feasible mitigation to reduce impacts to agricultural resources. No further response is required.

Response to YOKOYAMA-3
The comment is noted. Impacts to biological resources are discussed in Section 3.4, Biological Resources, of the Draft PEIR. As shown in Exhibit 3.4-1 of the Draft PEIR, the Land Cover Types and Vegetation Communities map is based on ESRI Aerial Imagery and the Fresno General Plan. Any project-level impact would adhere to applicable mitigation measures, such as MM BIO-1a and MM BIO-1c. Pre-construction clearance surveys would be conducted to determine whether riverine habitat is within the project site boundaries. If any critical habitat is present, the proposed project shall implement appropriate mitigation measures to reduce project-related impacts to less than significant levels.

Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area. Additionally, discretionary projects will be consistent with survey protocols and mitigation measures recommended by the agency at the time of consultation. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-877
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to YOKOYAMA-4
The comment is noted. Potential impacts to each of these species and their respective habitats within the Plan Area and surrounding area are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to biological resources. Project-level implementation of the General Plan Policies POSS-5a-a through POSS-5-f would reduce potential project impacts to special-status species and their associated habitats.

Furthermore, implementation of MM BIO-1a through MM BIO-1d would ensure that a future proposed project under the Specific Plan would not result in potentially significant impacts. If one or more of these special-status species occur in the Plan Area, the project area would be evaluated to determine whether species are present using survey methods applicable at the time of project application. Specific mitigation measures for direct or incidental impacts to natural communities and vegetation supporting special-status species shall be determined on a case-by-case basis through agency consultation during the review process for discretionary projects. Potential impacts to special-status species and critical habitat would be avoided to the maximum extent feasible or appropriate mitigation measures would be implemented.

Special-status species are protected by the CDFW, and in some cases, the USFWS Endangered Species Act, and the MBTA. Future projects proposed under the Specific Plan would be required to follow all applicable federal regulations to special-status species, and their critical habitat. Therefore, with implementation of MM BIO-1a through MM BIO-1d and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant. No further response is required.

Response to YOKOYAMA-5
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. The proposed project’s potential impacts on the Fancher Creek Canal are discussed in Section 3.4, Biological Resources, and Section 3.10, Hydrology and Water Quality. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following mitigation measures pertaining to biological resources: MM BIO-2b, MM BIO-3a, and MM BIO-3b. Pre-construction clearance surveys shall be conducted to determine whether streambeds or waterways are within project site boundaries. If any streambeds or waterways are present, the proposed project shall consult with partner agencies such as CDFW and the USACE to develop and implement appropriate mitigation measures regarding impacts on their respective jurisdictions, determination of mitigation strategy, and regulatory permitting, including alteration agreements, to reduce impacts, as required for projects that impact streambeds and/or waterways.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-878 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Response to YOKOYAMA-6
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. The proposed project’s impacts on the on the Kings and San Joaquin rivers, and the relative locations of the two rivers to project site, are discussed in Section 3.10, Hydrology and Water Quality. No further response is required.

Response to YOKOYAMA-7
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. The proposed project’s potential impacts on wildlife species are discussed in Section 3.4, Biological Resources. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following mitigation measures pertaining to biological resources: MM BIO-1b and MM BIO-1c, MM BIO-2a, and MM BIO-2c. Pre-construction clearance surveys shall be conducted to determine whether any critical habitat or potential wildlife species are present in Fancher Creek Canal within the project site boundaries. If any are present, the proposed project shall implement appropriate General Plan mitigation measures to reduce project-related impacts to less than significant levels.

Response to YOKOYAMA-8
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. The proposed project’s potential impacts on wildlife species are discussed in Section 3.4, Biological Resources. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following mitigation measures pertaining to biological resources: MM BIO-1b and MM BIO-1c. Preconstruction clearance surveys shall be conducted to determine whether critical habitat and/or special-status species are within the project site boundaries. If any critical habitat or potential wildlife species are present in the Fancher Creek Canal Bank, or adjacent areas, the proposed project shall implement appropriate mitigation measures to reduce project-related impacts to less than significant levels. Therefore, with implementation of mitigation, impacts would be less than significant.

Response to YOKOYAMA-9
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. Potential impacts to each of these species and their respective habitats within the Plan Area are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-879
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx biological resources. Project-level implementation of the General Plan Policies POSS-5a-a through POSS-5-f would reduce potential project impacts to special-status species and their associated habitats.

Additionally, special-status species are protected by the CDFW, and in some cases, the USFWS Endangered Species Act, and the MBTA. Future projects proposed under the Specific Plan would be required to follow all applicable federal regulations to special-status species, and their critical habitat. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area. No further response is required.

Response to YOKOYAMA-10
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. Potential impacts to each of these species and their respective habitats within the Plan Area are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to biological resources. Project-level implementation of the General Plan Policies POSS-5a-a through POSS-5-f would reduce potential project impacts to special-status species and their associated habitats.

Furthermore, implementation of MM BIO-1a through MM BIO-1d, MM BIO-2a, and MM BIO-2c would ensure that a future proposed project under the Specific Plan would not result in potentially significant impacts. If one or more of these special-status species occur in the Plan Area, the project area would be evaluated to determine whether species are present using survey methods applicable at the time of project application. Specific mitigation measures for direct or incidental impacts to natural communities and vegetation supporting special-status species shall be determined on a caseby-case basis through agency consultation during the review process for discretionary projects.

Potential impacts to special-status species and critical habitat would be avoided to the maximum extent feasible or appropriate mitigation measures would be implemented. Therefore, with City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-880 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx implementation of the above mitigation measures and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant.

Response to YOKOYAMA-11
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. Potential impacts to regulated trees within the Plan Area are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Recirculated Draft PEIR, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to biological resources. Project-level implementation of the General Plan Policies POSS-5a-a through POSS-5-f would reduce potential project impacts to special-status plant species and their associated habitats.

Furthermore, implementation of MM BIO-1a through MM BIO-1c and MM BIO-2a would ensure that a future proposed project under the Specific Plan would not result in potentially significant impacts.

If one or more of these special-status species, including protected oak and woodlands, occur in the Plan Area, the project area would be evaluated to determine whether species are present using survey methods applicable at the time of project application. Specific mitigation measures for direct or incidental impacts to natural communities and special-status plant species shall be determined on a case-by-case basis through agency consultation during the review process for discretionary projects. Potential impacts to special-status species and critical habitat would be avoided to the maximum extent feasible or appropriate mitigation measures would be implemented. Additionally special-status plant species are protected by the CDFW, and in some cases, the USFWS Endangered Species Act. Future projects proposed under the Specific Plan would be required to follow all applicable federal regulations to special-status species, and their critical habitat. Therefore, with implementation of the applicable mitigation measures and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant.

Response to YOKOYAMA-12
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. Please refer to Master Response 1, Non-CEQA City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-881
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Issues Not Addressed in Final PEIR, in Section 2, Master Responses, of this document. Master Response 1 provides additional information on the scope of CEQA and any non-CEQA issues not further discussed in the Final PEIR.

As discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR, the proposed project would comply with MM BIO-1a through MM BIO-1d and MM BIO-2a through MM BIO-2c.

These mitigation measures would require construction to avoid vegetation communities that provide suitable habitat for special-status species and mitigate if necessary to the greatest extent feasible.

The mitigation measures would also require a pre-construction clearance survey, following current CDFW protocols, to determine whether the proposed project would result in the removal or impact to any riparian habitat and/or a special-status natural community and develop appropriate mitigation as necessary. Therefore, with implementation of applicable mitigation measures and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant. No further response is required.

Response to YOKOYAMA-13
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

The proposed project is a programmatic document and does not propose site-specific development at this time. Future development associated with the proposed project, such as a Neighborhood Town Center, would complete site-specific environmental analysis pursuant to CEQA and provide mitigation as necessary. Additionally, as discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR, the proposed project would incorporate MM BIO-1a through MM BIO-1d, and MM BIO-2a through MM BIO-2c. These mitigation measures would require construction to avoid vegetation communities that provide suitable habitat for special-status species and mitigate if necessary to the greatest extent feasible. The mitigation measures would also require a preconstruction clearance survey, following current CDFW protocols, to determine whether the proposed project would result in the removal or impact to any riparian habitat and/or a specialstatus natural community and develop appropriate mitigation as necessary. Therefore, with implementation of the applicable mitigation measures and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant. No further response is required.

Response to YOKOYAMA-14
The comment is noted. Please refer to Master Response 5, Clarification of the Programmatic Document, in Section 2, Master Responses. Master Response 5 provides additional information on the level of review included in the Recirculated Draft PEIR and the subsequent environmental review that would be performed as the City receives specific development applications in the Plan Area.

The proposed project is a programmatic document and does not propose site-specific development at this time. Future development associated with the proposed project, such as a Neighborhood Town Center, would complete site-specific environmental analysis pursuant to CEQA and provide mitigation as necessary. Additionally, as discussed in Section 3.4, Biological Resources, of the City of Fresno—Fresno Southeast Development Area Specific Plan Project Responses to Written Comments Administrative Final Program EIR 1-882 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680037/EIR/2 - Final EIR/wp/31680037 Sec03-00 Responses to Written Comments.docx Recirculated Draft PEIR, the proposed project would incorporate MM BIO-1a through MM BIO-1d, and MM BIO-2a through MM BIO-2c. These mitigation measures would require construction to avoid vegetation communities that provide suitable habitat for special-status species and mitigate if necessary to the greatest extent feasible. The mitigation measures would also require a preconstruction clearance survey, following current CDFW protocols, to determine whether the proposed project would result in the removal or impact to any riparian habitat and/or a specialstatus natural community and develop appropriate mitigation as necessary. Therefore, with implementation of the applicable mitigation measures and policies found within the General Plan and proposed Specific Plan, impacts would be less than significant. No further response is required.

Response to YOKOYAMA-15
The comment is noted and is included in the record provided to the Lead Agency for further consideration. Potential impacts to each of these species and their respective habitats within the Plan Area and surrounding area are discussed in Section 3.4, Biological Resources, of the Recirculated Draft PEIR. As discussed in the Draft PEIR, future development in the Plan Area would be required to comply with the following General Plan policies pertaining to biological resources.

Project-level implementation of the General Plan Policies POSS-5a-a through POSS-5-f would reduce potential project impacts to special-status species and their associated habitats.

Future development under the proposed project would be required to comply with applicable federal regulations, State CEQA Guidelines, the City’s applicable General Plan and Specific Plan policies, and the Fresno Municipal Code, which would require that the site’s habitat, including the potential plants, animals, invertebrate, and fish species be identified and assessed for impacts under CEQA. When applicable, cumulative impacts related to biological resources would be analyzed and mitigation measures would be applied. No further response is required.

Response to YOKOYAMA-16
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. No further response is required.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Administrative Final Program EIR Responses to Written Comments FirstCarbon Solutions 1-883
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The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. As noted in Section 3.4, Biological Resources, of the Recirculated Draft PEIR, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of mitigation, along with applicable regulations. No further response is required.

Response to YOKOYAMA-18
The comment is noted and is included in the record provided to the Lead Agency for their review and consideration of the proposed project as a whole. As noted in Section 3.4, Biological Resources, of the Recirculated Draft PEIR, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of mitigation, along with applicable regulations. No further response is required.

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From: connie young
To: LongRangePlanning
Cc: District1
Subject: Concerns about the SEDA recirculated EIR
Date: Monday, March 24, 2025 4:48:19 PM
External Email: Use caution with links and attachments
Dear Ms. Pagoulatos,
I'm writing to express my concern about the following aspects of the SEDA Recirculated EIR:
4-2 Growth-iIduced Impacts
New data from the California Department of Finance shows much slower growth projections for the Fresno area than the EIR predicts. Let's not contribute to urban sprawl by building homes that will not be needed. Furthermore, let's prioritize increasing affordable housing and complete neighborhoods within existing city limits.

3.3.4 Air Quality
By increasing urban sprawl, this project will increase air pollution. Considering that our air basin already fails attainment standards for several criteria air pollutants, we must not increase the vehicular pollution in our air basin. Air pollution diminishes the quality and longevity of Fresno residents.

Fresno has many blighted areas. Sadly, it is known in other parts of the state as "the armpit of California". We can do better! Let's stop urban sprawl and inner city blight by focusing our resources on what we already have.

Sincerely,
Connie Young, RN (retired)
4442 N Van Dyke Ave
Fresno, CA 93705
[email protected]
YOUNG

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1 2

Response to YOUNG-2
The comment is noted. Please refer to Master Response 7, Clarifying Information on Significant and Unavoidable Impacts, in Section 2, Master Responses. Master Response 7 provides additional clarifying information on the significant and unavoidable impacts disclosed within the PEIR. No further response is required.

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ERRATA
The following are revisions to the Draft Program EIR for the Fresno Southeast Development Area (SEDA) Specific Plan Project. These revisions are minor modifications and clarifications to the document, and do not change the significance of any of the environmental issue conclusions within the Draft Program EIR. The revisions are listed by page number. All additions to the text are underlined (underlined) and all deletions from the text are stricken (stricken).

Changes in Response to Specific Comments
Executive Summary
Page ES-16 to ES-18, Impact AIR-1, “Mitigation Measures”, MM AIR-1c MM AIR-1c under Impact AIR-1 has been modified in response to consultation with the California Air Resources Board (CARB) as discussed in Response to CARB-2 in Section 2, Responses to Written Comments, in this Final PEIR.

MM AIR-1c Prior to future discretionary project approval in the Fresno Southeast Development Area Specific Plan Area (Plan Area), development project applicants shall prepare and submit to the Director of the Planning and Development Department, or designee, a technical assessment evaluating potential project operation-related air quality impacts. The evaluation shall be prepared in conformance with San Joaquin Valley Air Pollution Control District (Valley Air District) methodology in assessing air quality impacts. If operation-related air pollutants are determined to have the potential to exceed the Valley Air District adopted thresholds of significance, the project applicants for new development projects shall be required to incorporate mitigation measures to reduce air pollutant emissions during operational activities.

SECTION 4:

4.1-
City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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• Electric vehicle (EV) charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the California Green Building Standards Code (CALGreen) Code.
• Bicycle parking shall be provided as specified in Section A4.106.9 (Residential Voluntary Measures) of the CALGreen Code.
• Projects shall be required to implement, at a minimum, an increase in each building’s energy efficiency 15 percent beyond Title 24 and reduction of indoor water use by 25 percent.
• Maximize use of solar energy including solar panels; installing the maximum possible number of solar energy arrays on building roofs throughout the City to generate solar energy.
• Maximize the planting of trees in landscaping and parking lots. • Use light-colored paving and roofing materials.
• Require use of electric or alternatively fueled street-sweepers with HEPA filters. • Require use of electric lawn mowers and leaf blowers. • Utilize only Energy Star heating, cooling, and lighting devices, and appliances. • Use of water-based or low volatile organic compound (VOC) cleaning products. • For buildings with more than 10 tenant-occupants, changing/shower facilities shall be provided as specified in Section A5.106.4.3 (Nonresidential Voluntary Measures) of the California Green Building Standards Code (CALGreen) Code. • Long-term and short-term bicycle parking shall be provided as specified in Section A5.106.4 (Nonresidential Mandatory Measure) of the CALGreen Code. • Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code.

Facilities shall be installed to support future EV charging at each single-family, multifamily, commercial, and nonresidential building with 30 or more parking spaces uses. Installation EV charging infrastructure shall meet the most ambitious voluntary standard be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code.

Page ES-18 to ES-19, Impact AIR-1, “Mitigation Measures”, MM AIR-1d MM AIR-1d under Impact AIR-1 has been modified in response to consultation with the CARB as discussed in Responses to SJVAPCD-10 and SJVAPCD-11 in Section 2, Responses to Written Comments, in this Final PEIR.

MM AIR-1d: Prior to future discretionary project approval in the Fresno Southeast Development Area Specific Plan Area (Plan Area), development project applicants proposing a project with the potential to introduce sources of diesel particulate matter (DPM) and/or toxic air contaminants (TACs) (such as diesel backup generators or significant truck trips) within 1,000 feet 0.25 mile of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use, shall prepare and submit to City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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the Director of the Planning and Development Department, or a designee, a Prioritization (Screening HRA) and/or Health Risk Assessment (HRA). An analysis evaluating potential health risks to sensitive receptors farther than 0.25 mile from the proposed project site may also be required, depending on the size and scope of the project, the amount of air toxic emissions from project construction and operation sources (heavy heavy-duty [HHD] truck trips, stationary source emissions, etc.), the type of pollutants emitted, the proximity to the nearest sensitive receptor, and the expected duration of project construction. The Prioritization should be performed using Valley Air District-approved methods. If a project will result in a Prioritization score of 10 or greater, then an HRA shall be prepared in accordance with policies and procedures of the most current California Office of Environmental Health Hazard Assessment (OEHHA) and the San Joaquin Valley Air Pollution Control District (Valley Air District). If the HRA shows that the incremental health risks exceed their respective thresholds, as established by the Valley Air District at the time a project is considered, the project applicant shall be required to identify and demonstrate that Best Available Control Technologies for toxics (T-BACTs), including appropriate enforcement mechanisms to reduce risks to an acceptable level. T-BACTs may include, but are not limited to:
• Restricting idling on-site or electrifying warehousing docks to reduce DPM; • Requiring use of newer tier equipment and/or vehicles; • Providing charging infrastructure for: electric forklifts, electric yard trucks, local drayage trucks, last mile delivery trucks, electric and fuel-cell heavy-duty trucks; and/or
• Installing solar panels, zero-emission backup electricity generators, and energy storage to minimize emissions associated with electricity generation at the project site.

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

Page ES-34, Impact GHG-1, “Impacts”
This impact statement has been edited to clarify the potential impacts associated with the implementation of the proposed project.

Impact GHG-1 The proposed project could would not generate direct and indirect greenhouse gas emissions, and these emissions would not result in a significant impact on the environment.

Page ES-41, Impact HYD-3, “Mitigation Measures,” MM HYD-3e MM HYD-3e under Impact HYD-3 has been modified in response to the Fresno Municipal Flood Control District (FMFCD) comment letter as discussed in Response to FMFCD-15, and its numbering has been corrected. This mitigation measure has been revised to also include coordination with the Fresno Irrigation District (FID) when updated the Storm Drainage Master Plan.

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MM HYD-3d The City shall implement the following measures to reduce the impacts on the capacity of existing or planned storm drainage Master Plan retention basins within the Fresno Southeast Development Area Specific Plan Area (Plan Area) to less than significant:
• Prior to approval of development projects, support the Fresno Metropolitan Flood Control District (FMFCD) in coordination with the Fresno Irrigation District (FID) in updating the Storm Drainage and Flood Control Master Plan to analyze the impacts to existing and planned retention basins within the Plan Area to determine remedial measures required to reduce the impact on retention basin capacity to less than significant. Remedial measures would include:

Increase the size of the retention basin through the purchase of more land or deepening the basin or a combination for planned retention basins.

Increase the size of the emergency relief pump capacity required to pump excess runoff volume out of the basin and into adjacent canals that convey the stormwater to a disposal facility for existing retention basins.

Require developments that increase runoff volume to install, operate, and maintain Low Impact Development (LID) measures to reduce runoff volume to the runoff volume that will not exceed the capacity of the existing retention basins.

Page ES-41, Impact HYD-3, “Mitigation Measures,” MM HYD-3f MM HYD-3f under Impact HYD-3 has been modified in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

MM HYD-3f The City shall implement the following measures to reduce the impacts on the capacity of existing or planned storm drainage Master Plan urban detention (stormwater quality) basins within the Fresno Southeast Development Area Specific Plan Area (Plan Area) to less than significant:
• Prior to approval of development projects, support the Fresno Metropolitan Flood Control District (FMFCD) in updating the Storm Drainage and Flood Control Master Plan to determine the impacts to the urban detention weir overflow rates and determine remedial measures required to reduce the impact on the detention basin capacity to less than significant. Remedial measures would include:

Modify overflow weir to maintain the suspended solids removal rates adopted by the FMFCD Board of Directors.

Increase the size of the urban detention basin to increase residence time by purchasing more land.
• Require developments that increase runoff volume to install, operate, and maintain Low Impact Development (LID) measures to reduce peak runoff rates and runoff volume to the runoff rates and volumes that will not exceed the weir overflow rates of the existing urban detention basins.

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Page ES-42, Impact HYD-3, “Mitigation Measures,” MM HYD-3g MM HYD-3g under Impact HYD-3 has been removed in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

MM HYD-3g: The City shall implement the following measures to reduce the impacts on the capacity of existing or planned storm drainage Master Plan pump disposal systems within the Fresno Southeast Development Area Specific Plan Area (Plan Area) to less than significant:
• Prior to approval of development projects, support the Fresno Metropolitan Flood Control District (FMFCD) in updating the Storm Drainage and Flood Control Master Plan to determine the extent and degree to which the capacity of the existing pump system will be exceeded.
• Require new developments to install, operate, and maintain FMFCD design standard on-site detention facilities to reduce peak stormwater runoff rates to existing planned peak runoff rates.
• Provide additional pump system capacity to maximum allowed by existing permitting to increase the capacity to match or exceed the peak runoff rates determined by the Storm Drainage and Flood Control Master Plan update.

Page ES-43, Cumulative Impact, “Mitigation Measures”
MM HYD-3g has been removed in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

Implement MM UTIL-2a, MM UTIL-2b, MM UTIL-2c, MM HYD-2a, MM HYD-2b, MM HYD2c, MM HYD-2d, MM HYD-2e, MM HYD-3a, MM HYD 3b, MM HYD-3c, MM HYD-3d, MM HYD-3e, and MM HYD-3f, and MM HYD-3g.

Page ES-50, Impact TRANS-1, “Mitigation Measures”, MM TRANS-1d MM TRANS-1d under Impact TRANS-1 has been modified in response to consultation with the CARB as discussed in Response to CARB-5 in Section 2, Responses to Written Comments, in this Final PEIR.

MM TRANS-1d Collaborate with the Fresno Area Express (FAX) to provide new transit services, including the consideration of shuttle and micro-transit service, to the proposed project and within the proposed project area.

Page ES-50 to ES-51, Impact TRANS-1, “Mitigation Measures”, MM TRANS-1e MM TRANS-1e under Impact TRANS-1 has been modified in response to consultation with the CARB as discussed in Response to CARB-6 in Section 2, Responses to Written Comments, in this Final PEIR.

MM TRANS-1e In addition, the following Transportation Demand Management (TDM) strategies may be applicable at the implementing project level:
• Reduce Parking Supply for Retail Uses (maximum reduction: 12.5 percent) City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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• Add Transit Rerouting and Transit Stops (maximum reduction: 5 percent) • Implementation of Local Shuttle Service (grouped strategy with transit system improvements)
• Mandatory Travel Behavior Change Program, Promotions and Marketing (maximum reduction: 1 percent)
• Promotions and Marketing (maximum reduction: 1 percent) • Emergency Ride Home (ERH) Program (maximum reduction: 3 percent) • School Carpool Program (maximum reduction: 15 percent) • Bike Share (maximum reduction: 0.25 percent)
• Implement/Improve On-street Bicycle Facility (maximum reduction: 0.625 percent)
• Traffic Calming Improvements (maximum reduction: 1 percent) • Pedestrian Network Improvements (maximum reduction: 2 percent) • Unbundle the cost of parking from multi-family residential land uses.

Page ES-51, Impact TRANS-3, “Mitigation Measures”
These mitigation measures have been added in response to consultation with the California Department of Transportation (Caltrans) as discussed in Responses to CALTRANS-2 and CALTRANS-3 in Section 2, Responses to Written Comments, in this Final PEIR.

Implement MM TRANS-1a, MM TRANS-1b, MM TRANS-1c, MM TRANS-1d, and MM TRANS-1e.

MM TRANS-3a Lengthen the eastbound turning lane to 875 feet and the westbound turning lane to 1,150 feet for the De Wolf Avenue and State Route (SR) 180 intersection.

MM TRANS-3b Lengthen the westbound turning lane to 1,075 feet for the McCall Avenue and State Route (SR) 180 intersection.

MM TRANS-3c Prior to approval of individual development projects within the Fresno Southeast Development Area Specific Plan Area (Plan Area), the City of Fresno shall coordinate with the California Department of Transportation (Caltrans) to determine whether the project would result in a potential impact on queueing lengths at either the Clovis Avenue and State Route (SR) 180 eastbound off-ramp interchange or the Temperance Avenue and SR-180 eastbound off-ramp interchange. If the queueing extends into the auxiliary lane of either of these interchanges, the City shall implement mitigation consistent with the Caltrans Local Development Review Safety Review Practitioners Guidance in coordination with Caltrans. This mitigation includes, but is not limited to:
• Implementation of project-specific transportation demand management programs, such as rideshare programs, shared mobility facilities, or improvements to bicycle and pedestrian infrastructure;
• Improvements to existing site-specific active transportation infrastructure; or City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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• Improvements to ramp terminal operations such as lane reassignment, traffic signalization phasing or retiming, and turn lane extensions.

MM TRANS-3d Prior to approval of individual development projects within the Fresno Southeast Development Area Specific Plan Area (Plan Area), the City of Fresno shall establish a development fee program that shall collect fees from developers of individual development projects within the Plan Area to fund required safety improvements to transportation facilities.

Page ES-51, Cumulative Impact, “Mitigation Measures”
These mitigation measures have been added in response to consultation with Caltrans as discussed in Responses to CALTRANS-2 and CALTRANS-3 in Section 2, Responses to Written Comments, in this Final PEIR.

Implement MM TRANS-1a, MM TRANS-1b, MM TRANS-1c, MM TRANS-1d, MM TRANS-1e, MM TRANS-3a, MM TRANS-3b, MM TRANS-3c, MM TRANS-3d, and MM TRANS-4.

Page ES-53, Impact UTIL-1, “Mitigation Measures”, MM UTIL-1f This mitigation measure has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

MM UTIL-1f At the time discretionary projects are submitted, the City shall require projectspecific environmental evaluations for the expansion or relocation of electric, natural gas, or telecommunication facilities be completed prior to project approval.

Chapter 1, Introduction

Page 1 ends

This sentence has been edited to reflect the program-level analysis of the environmental effects of the proposed project as further discussed in Response to COUNTY-7.

This Recirculated Draft PEIR provides a programproject-level analysis of the environmental effects of the proposed project.

Chapter 2, Project Description

Page 2 ends

This paragraph has been edited to correctly reflect the name of the Public Facilities Financing Options Report.

The proposed project would include a Public Facilities Financing Plan Options Report to present a strategy and funding options for backbone infrastructure and public facilities, including roads, sewer, water, storm drainage, parks, and other public facilities. Backbone infrastructure and public facilities required for development couldwould be funded through a combination of public and private funding. The Public Facilities Financing Plan Options City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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Report has been developed through a review of the SEDA Specific Plan, infrastructure studies, and coordination with the City.

Section 3.3, Air Quality

Page 3 ends

MM AIR-1c under Impact AIR-1 has been modified in response to consultation with the CARB as discussed in Response to CARB-2 in Section 2, Responses to Written Comments, in this Final PEIR.

The identified measures shall be included as part of the Project Conditions of Approval. Possible mitigation measures to reduce long-term emissions include but are not limited to:
• For site-specific development that requires refrigerated vehicles, the construction documents shall demonstrate an adequate number of electrical service connections including the use of electric-powered forklifts and/or other interior vehicles at loading docks for plugging in the anticipated number of refrigerated trailers to reduce idling time and emissions. • Applicants for manufacturing and light industrial uses shall consider energy storage (i.e., battery) and combined heat and power (CHP, also known as cogeneration) in appropriate applications to optimize renewable energy generation systems and avoid peak energy use.
• Site-specific developments with truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/unloading in accordance with ARB Rule 2845 (13 California Code of Regulations [CCR] Chapter 10, § 2485). • Electric vehicle (EV) charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the California Green Building Standards Code (CALGreen) Code.
• Bicycle parking shall be provided as specified in Section A4.106.9 (Residential Voluntary Measures) of the CALGreen Code.
• Projects shall be required to implement, at a minimum, an increase in each building’s energy efficiency 15 percent beyond Title 24 and reduction of indoor water use by 25 percent.

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• Maximize use of solar energy including solar panels; installing the maximum possible number of solar energy arrays on building roofs throughout the City to generate solar energy.
• Maximize the planting of trees in landscaping and parking lots. • Use light-colored paving and roofing materials.
• Require use of electric or alternatively fueled street-sweepers with HEPA filters. • Require use of electric lawn mowers and leaf blowers. • Utilize only Energy Star heating, cooling, and lighting devices, and appliances. • Use of water-based or low volatile organic compound (VOC) cleaning products. • For buildings with more than 10 tenant-occupants, changing/shower facilities shall be provided as specified in Section A5.106.4.3 (Nonresidential Voluntary Measures) of the California Green Building Standards Code (CALGreen) Code. • Long-term and short-term bicycle parking shall be provided as specified in Section A5.106.4 (Nonresidential Mandatory Measure) of the CALGreen Code. • Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code.

Page 3 ends

MM AIR-1d under Impact AIR-1 has been modified in response to consultation with the CARB as discussed in Responses to SJVAPCD-10 and SJVAPCD-11 in Section 2, Responses to Written Comments, in this Final PEIR.

MM AIR-1d Prior to future discretionary project approval in the Fresno Southeast Development Area Specific Plan Area (Plan Area), development project applicants proposing a project with the potential to introduce sources of diesel particulate matter (DPM) and/or toxic air contaminants (TACs) (such as diesel backup generators or significant truck trips) within 1,000 feet 0.25 mile of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use, shall prepare and submit to the Director of the Planning and Development Department, or a designee, a Prioritization (Screening HRA) and/or Health Risk Assessment (HRA). An analysis evaluating potential health risks to sensitive receptors farther than 0.25 mile from the proposed project site may also be required, depending on the size and scope of the project, the amount of air toxic emissions from project construction and operation sources (HHD truck trips, stationary source emissions, etc.), the type of pollutants emitted, the proximity to the nearest sensitive receptor, and the expected duration of project construction. The Prioritization should be performed using Valley City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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Air District-approved methods. If a project will result in a Prioritization score of 10 or greater, then an HRA shall be prepared in accordance with policies and procedures of the most current California Office of Environmental Health Hazard Assessment (OEHHA) and the San Joaquin Valley Air Pollution Control District (Valley Air District).

If the HRA shows that the incremental health risks exceed their respective thresholds, as established by the Valley Air District at the time a project is considered, the project applicant shall be required to identify and demonstrate that Best Available Control Technologies for toxics (T-BACTs), including appropriate enforcement mechanisms to reduce risks to an acceptable level. T-BACTs may include, but are not limited to:
• Restricting idling on-site or electrifying warehousing docks to reduce DPM; • Requiring use of newer tier equipment and/or vehicles; • Providing charging infrastructure for: electric forklifts, electric yard trucks, local drayage trucks, last mile delivery trucks, electric and fuel-cell heavy-duty trucks; and/or
• Installing solar panels, zero-emission backup electricity generators, and energy storage to minimize emissions associated with electricity generation at the project site.

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

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Energy sources would include electricity and natural gas combustion for space and water heating.

Section 3.6, Energy

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

The proposed project’s anticipated energy use was estimated, including natural gas, electricity, and fuel consumption (for vehicles traveling to and from the project), for project construction and operation.

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Energy resources that would be potentially impacted include electricity, natural gas, and petroleum-based fuel supplies and distribution systems.

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This paragraph has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Implementation of the proposed project may result in the development of approximately 45,000 homes, as well as the development of office centers, flexible research and development districts, and institutional uses within the nearly 9,000-acre Plan Area by the year 2050. Operation of future developments envisioned as a part of the proposed project would consume natural gas and electricity for building heating and power, lighting, and water conveyance, among other operational requirements. The electrical consumption and natural gas usage associated with the potential development have been calculated in the CalEEMod model, which estimates that the potential development would consume 500,083,800 kWh of electricity per year and 1,200,642,400 kilo-British Thermal Units (kBTU) of natural gas per year. All CalEEMod modeling output files and energy consumption estimates are contained in Appendix B.

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This paragraph has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Plans submitted for building permits of development projects in the project area would be required to include verification demonstrating compliance with the Building and Energy Efficiency Standards for Residential and Non-Residential Buildings in effect at the time building permits are issued. These standards are updated every 3 years, with the latest update (2022) having gone into effect on January 1, 2023. The proposed project would also be required to adhere to the provisions of CALGreen, which established planning and design standards for sustainable site development, energy efficiency (beyond the California Energy Code requirements), water conservation, material conservation, and internal air contaminants. Additionally, because developments that would be considered under the proposed project have not been designed or proposed at this time, potential improvements to the current energy and natural gas facilities would be identified at the time such projects are considered. Therefore, with adherence to Title 24 regulations and the objectives and policies included in the approved General Plan and the proposed Specific Plan, the proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation.

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Additionally, because developments that would be considered under the proposed project have not been designed or proposed at this time, potential improvements to the current energy and natural gas facilities would be identified at the time such projects are considered.

Section 3.8, Greenhouse Gas Emissions

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This impact statement has been edited to clarify the potential impacts associated with the implementation of the proposed project.

Impact GHG-1 The proposed project could generate direct and indirect greenhouse gas emissions, and these emissions would not result in a significant impact on the environment.

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This paragraph has been edited to clarify that future individual development projects would be required to comply with all applicable requirements and policies, such as demonstrating consistency with Table 3 of Appendix D of the 2022 Scoping Plan.

This is anticipated to substantially reduce the operational emissions associated with passenger vehicles (i.e., mobile emissions) further over time. In addition, the proposed project would be developed according to the latest State and federal regulatory requirements those associated with operational building energy efficiency. Therefore, the proposed project would be considered consistent with the 2022 Scoping Plan. Based on this, recognizing the ARB as an authoritative substantial evidence source in evaluating post-2020 GHG impacts, since the proposed project would be consistent with the ARB’s 2022 Scoping Plan, buildout of the proposed project would not interfere with the main programs the ARB has identified to support its conclusions that the State is on a trajectory to meet the 2045 GHG target. Furthermore, future development associated with the proposed project would be required to undergo CEQA analysis on a project-by-project basis as necessary, which would include complying with all applicable requirements, such as demonstrating consistency with Table 3 of Appendix D of the 2022 Scoping Plan. Overall, the proposed project would not impede the 2022 Scoping Plan and would help the State to progress toward this target.

Section 3.10, Hydrology and Water Quality

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MM HYD-3e under Impact HYD-3 has been modified in response to the FMFCD comment letter as discussed in Response to FMFCD-15. This mitigation measure has been revised to also include coordination with the FID when updated the Storm Drainage Master Plan MM HYD-3e The City shall implement the following measures to reduce the impacts on the capacity of existing or planned storm drainage Master Plan retention basins within City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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the Fresno Southeast Development Area Specific Plan Area (Plan Area) to less than significant:
• Prior to approval of development projects, support the Fresno Metropolitan Flood Control District (FMFCD) in coordination with the Fresno Irrigation District (FID) in updating the Storm Drainage and Flood Control Master Plan to analyze the impacts to existing and planned retention basins within the Plan Area to determine remedial measures required to reduce the impact on retention basin capacity to less than significant. Remedial measures would include:

Increase the size of the retention basin through the purchase of more land or deepening the basin or a combination for planned retention basins.

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MM HYD-3f under Impact HYD-3 has been modified in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

Modify overflow weir to maintain the suspended solids removal rates adopted by the FMFCD Board of Directors.

Increase the size of the urban detention basin to increase residence time by purchasing more land.

Require developments that increase runoff volume to install, operate, and maintain Low Impact Development (LID) measures to reduce peak runoff rates and runoff volume to the runoff rates and volumes that will not exceed the weir overflow rates of the existing urban detention basins.

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MM HYD-3g under Impact HYD-3 has been removed in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

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MM HYD-3g has been removed in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

Implement MM UTIL-2a, MM UTIL-2b, MM UTIL-2c, MM HYD-2a, MM HYD-2b, MM HYD-2c, MM HYD-2d, MM HYD-2e, MM HYD-3a, MM HYD-3b, MM HYD-3c, MM HYD-3d, MM HYD3e, and MM HYD 3f, and MM HYD-3g.

Section 3.15, Public Services

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This paragraph has been edited to correctly reflect the name of the Public Facilities Financing Options Report.

Development within the City creates demands on exisiting municipal facilities, improvements, and services. Thus, various development fees and charges are imposed on new development in order to mitigate such demands. Payment of those fees and charges is required at various stages of the development process. The Public Facilities Financing Plan Options Report describes potential funding mechanisms for infrastructure needed to support the proposed project. Payment of applicable development fees or other funding mechanisims would offset the construction and acquisition costs of required fire protection and emergency medical facility improvements or additional personnel required to meet acceptable service levels. The funding mechanisms ultimately adopted by the City Council would also support fire and emergency medical services by ensuring that roadways meet City standards and support FFD vehicles.

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This paragraph has been edited to correctly reflect the name of the Public Facilities Financing Options Report.

Development within the City creates demands on exisiting municipal facilities, improvements, and services. Thus, various development fees and charges are imposed on new development in order to mitigate such demands. Payment of those fees and charges is required at various stages of the development process. The Public Facilities Financing Plan Options Report describes potential funding mechanisms for infrastructure needed to support the proposed project. Payment of applicable development fees or other funding mechanisims would offset the construction and acquisition costs of required police protection facility improvements or additional personnel required to meet acceptable service levels. The funding mechanisms ultimately adopted by the City Council would also support police services by ensuring that police facilities meet City standards.

Section 3.17, Transportation and Traffic

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MM TRANS-1d under Impact TRANS-1 has been modified in response to consultation with the CARB as discussed in Response to CARB-5 in Section 2, Responses to Written Comments, in this Final PEIR.

MM TRANS-1d Collaborate with the Fresno Area Express (FAX) to provide new transit services to the, including the consideration of shuttle and micro-transit service, throughout the proposed project and within the proposed project area.

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MM TRANS-1e under Impact TRANS-1 has been modified in response to consultation with the CARB as discussed in Response to CARB-6 in Section 2, Responses to Written Comments, in this Final PEIR.

MM TRANS-1e In addition, the following Transportation Demand Management (TDM) strategies may be applicable at the implementing project level:
• Reduce Parking Supply for Retail Uses (maximum reduction: 12.5 percent) • Add Transit Rerouting and Transit Stops (maximum reduction: 5 percent) • Implementation of Local Shuttle Service (grouped strategy with transit system improvements)
• Mandatory Travel Behavior Change Program, Promotions and Marketing (maximum reduction: 1 percent)
• Promotions and Marketing (maximum reduction: 1 percent) • Emergency Ride Home (ERH) Program (maximum reduction: 3 percent) • School Carpool Program (maximum reduction: 15 percent) • Bike Share (maximum reduction: 0.25 percent)
• Implement/Improve On-street Bicycle Facility (maximum reduction: 0.625 percent)
• Traffic Calming Improvements (maximum reduction: 1 percent) City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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• Pedestrian Network Improvements (maximum reduction: 2 percent) • Unbundle the cost of parking from multi-family residential land uses.

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This paragraph has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Responses to Written Comments, in the Final PEIR.

However, Caltrans comments on the Notice of Preparation (NOP) and subsequent comment letters on the Draft PEIR for the proposed project requested that peak-hour ramp queue analyses be prepared for specific SR-180 interchanges and intersections at project buildout to determine potential impacts.

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Additionally, through coordination with Caltrans, TJKM updated the queueing analysis to reflect the use of auxiliary lanes for additional storage. All of the interchanges and intersections analyzed, and the results of the queueing analysis, are included in Table 3.17-8 below.

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Results
This table has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Responses to Written Comments, in the Final PEIR. Note that underlined, bolded numbers with no strikeout indicated that the number was not previously bolded in the Recirculated Draft PEIR, but have revised to be bolded to indicate queues extending beyond available storage.

Table 4.1-1: 2035 Project and No Project Queue Analyses Results #
Intersection/
Interchange Direction Lane Group Storage Peak
No Project
Conditions
(2035)
Proposed
Project
Conditions
(2035) Change
1 Clovis Avenue and
SR-180 EB Ramp
EB Left (pocket) 255 AM 79 9 -70
PM 335 375 40
Left (full lane) 1,270
1,550
AM 350 55 -295
PM 1,581 1,738 157
Right (full lane
plus aux lane)
2,990
1,680
AM 717 261 -456
PM 1,582 1706 124
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#
Intersection/
Interchange Direction Lane Group Storage Peak
No Project
Conditions
(2035)
Proposed
Project
Conditions
(2035) Change
Right (pocket) 885 AM 685 245 -440
PM 989 1,016 27
2 Clovis Avenue and
SR-180 WB Ramp
WB Left 440 AM 853 687 -166
PM 66 86 20
Right 1,090 AM 1,738 1,789 51
PM 139 124 -15
3 Fowler Avenue
and SR-180 EB
Ramp
EB Left (pocket) 400 AM 0 5 5
PM 0 0 0
Left (full lane) 1,260 AM 9 18 9
PM 15 20 5
Right (full lane
plus aux lane)
3,000 AM 111 118 7
PM 207 232 25
Right (pocket) 235 AM 91 102 11
PM 205 237 32
4 Fowler Avenue
and SR-180 WB
Ramp
WB Left 650 AM 31 78 47
PM 33 36 3
Right 1,420 AM 177 112 -65
PM 80 61 -19
5 Temperance
Avenue and SR180 EB Ramp
EB Left (pocket) 440 AM 0 0 0
PM 4 604 600
Left (full lane) 1,665
1,940
AM 23 27 4
PM 25 2,046 2,021
Right (full
lane)
3,500
2,070
AM 124 95 -29
PM 162 2,019 1,857
Right (pocket) 680 AM 112 78 -34
PM 155 946 791
6 Temperance
Avenue and SR180 WB Ramp
WB Left (pocket) 400 AM 82 42 -40
PM 46 41 -5
Left (full lane) 1,485 AM 112 69 -43
PM 90 63 -27
Right (pocket) 840 AM 0 159 159
PM 0 0 0
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#
Intersection/
Interchange Direction Lane Group Storage Peak
No Project
Conditions
(2035)
Proposed
Project
Conditions
(2035) Change
7 De Wolf Avenue
and SR-180
EB Left 725 AM 372 806 434
PM 212 663 451
Right 700 AM 482 1,110 628
PM 10 681 671
WB Left 690 AM 98 178 80
PM 67 209 142
Right 690 AM 21 43 22
PM 40 39 -1
8 Highland Avenue
and SR-180
EB Left/Right 965 AM 24 73 49
PM 19 150 131
WB Left 630 AM 11 17 6
PM 11 118 107
9 McCall Avenue
and SR-180
EB Left 555 AM 315 185 -130
PM 100 194 94
Right 510 AM 821 159 -662
PM 65 90 25
WB Left 550 AM 983 737 -246
PM 31 37 6
Right 630 AM 839 1,069 230
PM 47 88 41
Notes:

EB = eastbound
WB = westbound
Bold text indicates queues extending beyond available storage Source: TJKM. 2025.

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This paragraph has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Response to Written Comments, in the Final PEIR.

As shown in Table 3.17-8, above, the updated queueing analysis evaluated the potential queueing lengths under project conditions and identified two interchanges where projected queue lengths may extend into the auxiliary lanes: Interchange 1 (Clovis Avenue and SR-180 EB Ramp), which would extend approximately 335 feet into the auxiliary lane, and City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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Interchange 5 (Temperance Avenue and SR-180 EB Ramp), which would extend approximately 355 feet into the auxiliary lane. Based on consultation with Caltrans, neither restriping nor the use of the auxiliary lane for additional storage is an available mitigation measure to address the queueing lengths. using available storage from the SR 180 auxiliary lane means that the Clovis and SR-180 interchange would not require any mitigation for the future with project conditions. As noted in the Caltrans letter dated August 16, 2024, auxiliary lanes can be used for additional storage. Interchange 1 (Clovis Avenue and SR-180 eastbound ramp) queueing now does not indicate a deficit (not bold text).

Therefore, in accordance with the Caltrans Highway Design Manual and project-specific recommendations through consultation with Caltrans, the proposed project would implement MM TRANS-3c, which would require the close coordination between the City and Caltrans to determine at what point the queueing length would begin to extend into the auxiliary lanes identified above during implementation of the proposed project. If queue lengths would extend into the auxiliary lanes identified for the interchanges above, the City would coordinate with Caltrans to implement mitigation consistent with the Appendix B of the Caltrans Local Development Review Safety Review Practitioners Guidance. The proposed project would implement General Plan and Specific Plan policies that implement some of mitigation strategies identified in the Caltrans Local Development Review Safety Review Practitioners Guidance that may reduce vehicle queueing so that the available storage would not be exceeded during buildout of the proposed project. Specifically, both the Fresno General Plan and the SEDA Specific Plan include policies that support the preparation of the transportation demand management programs as called for in the Caltrans Local Development Review Safety Review Practitioners Guidance. General Plan Policy MT-2-g directs the City to pursue implementation of Transportation Demand Management and Transportation System strategies to reduce peak-hour vehicle traffic and supplement the capacity of the transportation system. SEDA Specific Plan Policy UF-8.1 directs the City to develop a SEDA Transportation Demand Management Program consistent with the City’s VMT policy. Policy UF-8.1 specified that this program should include physical design credits (i.e., bicycle storage, on-site showers, shared parking), lifestyle credits (i.e., on-site child care, telecommuting, flex hour programs), and credits for auto-alternative programs (i.e., shuttle service, subsidized transit, guaranteed ride home programs).

Similarly, both the General Plan and the SEDA Specific Plan contain policies related to active transportation and investments and improvements to the City’s and Plan Area’s transit and trail systems as specified in the second bullet above. General Plan Policies MT-1-j, MT-4-b, MT-4-c, MT-4-h, MT-4-l, MT-5-a through MT-5-d, and MT-8-a through MT-8c all direct the City to implement improvements and investments to bikeways, pedestrian walkways, existing and proposed transit systems, and other related features that support active transportation.

The Urban Form Chapter of the SEDA Specific Plan contains multiple policies that address active transportation and transit service improvements within the Plan Area in order to create a balanced transportation network accessible to all users. Similarly, the Open Space Chapter of the SEDA Specific Plan addresses the future development of a SEDA Parks and Trails Master Plan, as well as improvements to curb, gutter, and sidewalk infrastructure.

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Moreover, as discussed in Impact TRANS-1, the proposed project would implement MM TRANS-1a through MM TRANS-1e, which require transportation demand management strategies to be developed at the project level, implementation of additional transit services, and the inclusion of design elements and pedestrian and bicycle network improvements that encourage fewer vehicle trips.

Therefore, because the Recirculated Draft PEIR is a programmatic document and the timing of specific development proposals within the Plan Area and implementation of the General Plan and Specific Plan policies identified above are unknown, it is too speculative to determine whether and when the available storage will be met. Therefore, MM TRANS-3c is included in the proposed project to ensure that a significant safety hazard related to queueing would not occur. To support the implementation of MM TRANS-3c, the proposed project would also implement MM TRANS-3d, which requires the City to collect development fees from future development projects in the Plan Area to fund necessary traffic safety improvements.

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This paragraph has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Response to Written Comments, in the Final PEIR.

Table 3.17-8 also shows that Interchange 2 (Clovis Avenue and SR-180 westbound ramp), the proposed project already fails in the no project condition, so no mitigation is necessary for impacts related to the proposed project.

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This paragraph has been removed in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Responses to Written Comments, in the Final PEIR.

Interchange 5 (Temperance Avenue and SR-180 eastbound ramp), like Interchange 1, utilizes the auxiliary lane to provide enough storage for the left and right turn movements in the project buildout condition. The only mitigation measures needed are for Intersections 7 and 9, where the existing queue length is not enough to accommodate the increased project traffic.

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In addition, future development consistent with the proposed project would undergo individual planning review at the time of application and additional project-specific environmental review may be required. It is not anticipated that development would City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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substantially increase hazards due to a geometric design feature or incompatible uses because the City would require review proposed future developments for consistency with applicable regulations, including the policies in the General Plan, designed to ensure safety, during planning review to eliminate any such hazards. Thus, with implementation of MM TRANS-3a, and MM TRANS-3b, MM TRANS-3c, and MM TRANS-3d as well as MM TRANS-1a through MM TRANS-1e, impacts would be less than significant.

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The following mitigation measures shall be implemented as necessary through monitoring and coordination between Caltrans and the City of Fresno:

Implement MM TRANS-1a through MM TRANS-1e.

MM TRANS-3a Lengthen the eastbound turning lane to 875 feet and the westbound turning lane to 1,150 feet for the De Wolf Avenue and State Route (SR) 180 intersection.

MM TRANS-3b Lengthen the westbound turning lane to 1,075 feet for the McCall Avenue and State Route (SR) 180 intersection.

MM TRANS-3c Prior to approval of individual development projects within the Fresno Southeast Development Area Specific Plan Area (Plan Area), the City of Fresno shall coordinate with the California Department of Transportation (Caltrans) to determine whether the project would result in a potential impact on queueing lengths at either the Clovis Avenue and State Route (SR) 180 eastbound off-ramp interchange or the Temperance Avenue and SR-180 eastbound off-ramp interchange. If the queueing extends into the auxiliary lane of either of these interchanges, the City shall implement mitigation consistent with the Caltrans Local Development Review Safety Review Practitioners Guidance in coordination with Caltrans. This mitigation includes, but is not limited to:
• Implementation of project-specific transportation demand management programs, such as rideshare programs, shared mobility facilities, or improvements to bicycle and pedestrian infrastructure;
• Improvements to existing site-specific active transportation infrastructure; or
• Improvements to ramp terminal operations such as lane reassignment, traffic signalization phasing or retiming, and turn lane extensions.

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MM TRANS-3d Prior to approval of individual development projects within the Fresno Southeast Development Area Specific Plan Area (Plan Area), the City of Fresno shall establish a development fee program that shall collect fees from developers of individual development projects within the Plan Area to fund required safety improvements to transportation facilities.

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Proposed project development in combination with future cumulative development in the City could result in localized impacts on the transportation network in the City. It is anticipated that cumulative development would be required to implement similar mitigation measures as the proposed project to reduce potential impacts on the transportation system, although there may be residual significant and unavoidable impacts. MM TRANS-1a through MM TRANS-1e, MM TRANS-3a through MM TRANS-3d, MM TRANS-3b, and MM TRANS-4 would apply to the proposed project to reduce any project-level impacts to less than significant.

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This sentence has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Responses to Written Comments, in the Final PEIR.

Implement MM TRANS-1a through MM TRANS-1e, MM TRANS-3a through MM TRANS-3d, MM TRANS-3b, and MM TRANS 4.

Section 3.18, Utilities and Service Systems

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Electrical, natural gas, and telecommunications services willwould be extended to the Plan Area, and be served by the same suppliers.

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This objective has been edited to reflect the updated objective within the SEDA Specific Plan.

Provide electricity, natural gas, and telecommunications infrastructure necessary to serve development in the SEDA.

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This policy has been edited to reflect the updated policy within the SEDA Specific Plan.

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Policy OS-13.1 Provision of Electricity and Natural Gas Infrastructure. The City of Fresno shall work with Pacific Gas and Electric Company (PG&E) to provide the necessary electricity and gas infrastructure to serve development in the SEDA.

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This section has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Electricity, Natural Gas, and Telecommunications
The proposed project would not utilize natural gas, so there would be no impacts related to natural gas infrastructure. Electricity, natural gas, and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities.

Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical and natural gas service. As indicated in the 2021 Corporate Sustainability Report, PG&E has requested approval for 387 megawatts of additional energy storage from six projects slated for completion by August 2023. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” Telecommunications companies continually expand infrastructure to serve the growing population. These planning efforts take into account growth projections, including the growth under the proposed project. Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity, natural gas, or telecommunications facilities beyond those already planned. Impacts would be less than significant.

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This mitigation measure has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

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This section has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

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Electricity, Natural Gas, and Telecommunications
The geographic context for an analysis of cumulative impacts to electricity and natural gas is the PG&E service area. The context for telecommunications is the City of Fresno and the Specific Plan Area.

The proposed project would not utilize natural gas, and therefore, there would be no cumulative impacts related to natural gas infrastructure. Past and present development has resulted in increased demand for electricity, natural gas, and telecommunications services.

Electricity, natural gas, and telecommunications utilities respond to increased demands in various ways. These may include temporary stoppages or rolling blackouts, extension of existing infrastructure, or construction of new facilities. Each of these utility providers prepares long-range plans to accommodate projected growth in their service areas. For example, PG&E provides annual sustainability reports that outline strategies to accommodate future growth and ensure reliability of electrical and natural gas service. As indicated in the 2021 Corporate Sustainability Report, PG&E has requested approval for 387 megawatts of additional energy storage from six projects slated for completion by August 2023. These projects will provide “system reliability procurement that will help integrate increasing amounts of renewable energy and meet peak summer demand.” Telecommunications companies continually expand infrastructure to serve the growing population. These planning efforts take into account growth projections, including the growth under the proposed project. Past, present, and future development has been and will continue to be accounted for in the utility plans, which are updated regularly to ensure continuity of service.

Because the proposed project would not result in unplanned growth, the majority of growth would be infill, and because the utility providers take into consideration all future growth projections in their planning efforts, the proposed project would not be expected to require or result in new or expanded electricity, natural gas, or telecommunications facilities beyond those already planned. Cumulative projects would be included in planned growth, and impacts would be less than significant.

Section 3.19, Wildfire

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This objective has been edited to reflect the updated objective within the SEDA Specific Plan.

Provide electricity, natural gas, and telecommunications infrastructure necessary to serve development in the SEDA.

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This policy has been edited to reflect the updated policy within the SEDA Specific Plan.

Provision of Electricity and Natural Gas Infrastructure. The City of Fresno shall work with Pacific Gas and Electric Company (PG&E) to provide the necessary electricity and gas infrastructure to serve development in the SEDA.

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Specific Plan Policy OS-13.1 and OS-13.3 include the provision of electricity, natural gas, and telecommunications infrastructure, which may increase fire risks in the area.

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

As described above, Specific Plan Policy OS-13.1 and OS-13.3 include the provision of electricity, natural gas, and telecommunications infrastructure, which may increase fire risks in the area.

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This sentence has been edited to reflect the removal of natural gas from the proposed project in accordance with an updated policy within the SEDA Specific Plan.

Additionally, as described above, Specific Plan Policy OS-13.1 and OS-13.3 include the provision of electricity, natural gas, and telecommunications infrastructure, which may increase fire risks in the area.

Chapter 4, Other CEQA Considerations

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This paragraph has been revised in response to coordination with Caltrans, as further detailed in Responses to CALTRANS-2 and CALTRANS-3 in Section 3, Response to Written Comments, in the Final PEIR. MM HYD-3g has been removed in response to the FMFCD comment letter as discussed in Response to FMFCD-15.

Potentially significant cumulative impacts related to cultural and Tribal cultural resources, greenhouse gas (GHG) emissions, hydrology and water quality, transportation, and utilities would be mitigated to less than significant levels with the implementation of MM CUL-1, MM CUL-2, MM CUL-3, MM HYD-2a, MM HYD-2b, MM HYD-2c, MM HYD-2d, MM HYD-2e, MM HYD-3a, MM HYD-3b, MM HYD-3c, MM HYD-3d, MM HYD-3e, MM HYD-3f, MM HYD-3g, MM TRANS-1a, MM TRANS-1b, MM TRANS-1c, MM TRANS-1d, MM TRANS-1e, MM TRANS31,a through MM TRANS-3bd, 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.

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This section on significant irreversible environmental changes that would occur should the proposed project be implemented has been added pursuant to Section 15126 of the CEQA Guidelines.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Errata Final Program EIR
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4.4 - Significant Irreversible Environmental Changes
According to Sections 15126(c) and 15126.2(d) of the State CEQA Guidelines, the Lead Agency must address any significant irreversible environmental changes that would occur should the project be implemented. The proposed project would not result in any significant irreversible environmental changes, accordingly, the following discussion is provided for informational purposes only. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
• The project would involve a large commitment of nonrenewable resources; • The primary and secondary impacts of the project would generally commit future generations to similar uses;
• The project involves uses in which irreversible damage could result from any potential environmental accidents; or
• The proposed consumption of resources are not justified.

The Specific Plan is a planning level action that addresses plans and policies covering a planning area of 9,000 acres. Although the general location and type of development can be anticipated based on the guidance in the Specific Plan, until the City receives a development application, the exact location, type of development, and potential impacts are too speculative to be determined. Because there is no specific development project being proposed at this time, a project-level analysis cannot be prepared. Nonetheless, it is anticipated that nonrenewable resources would be used on-site during construction and operation of projects consistent with the Specific Plan, including fossil fuels, water, concrete, steel, and lumber.

Accordingly, implementation of the proposed project would result in the commitment of such resources. Sections 3.6 and 3.18 address the commitment of nonrenewable resources. As substantiated and described in Section 3.18, the utilities that service the City, the City itself, and future projects that would implement the Specific Plan are all subject to regulations that are working to reduce the amount of nonrenewable resources that are committed to development projects. The development implementing the Specific Plan would be required to meet or exceed the requirements of the California Building Code and California Title 24 in effect at the time individual applications are submitted. Compliance with these standards would include implementation of sustainable building features, including, but not limited to water conservation measures, energy and water efficient appliances, and energy-efficient heating and cooling systems. These features would reduce new energy demand to a level consistent with or better than other development within the City. Therefore, the commitment of these resources for project development has been planned for the proposed project is not anticipated to consume substantial amounts of nonrenewable resources, such as energy in a wasteful manner, and implementation of the proposed project would not result in significant impacts from consumption of utilities. Therefore, although irreversible environmental changes would result from the proposed project, such changes would not result in significant irreversible changes.

Irreversible changes may also occur if environmental damage would be incurred when development consistent with the Specific Plan was operational, such as exposure to asbestos City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR Errata
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or lead based paint, potential residual volatile organic compounds (VOCs) in soil, soil gas, or groundwater that are planned for redevelopment, spill or release of hazardous material or accidental fire resulting from mechanical or industrial failure. However, it is assumed that all development, redevelopment and use of hazardous materials would occur pursuant to applicable laws and regulations. In addition, individual development projects consistent with the Specific Plan would implement mitigation measures, including MM HAZ-2a through MM HAZ-2h, which would ensure impacts related to hazardous material exposure, releases or spills would be avoided. Therefore, this would not be considered a significant irreversible environmental effect or cause irreversible environmental damage.

Appendix E–Energy Supporting Information
Pages labeled 1, 7, and 8
These pages have been removed from Appendix E in accordance with updated Specific Plan policies regarding natural gas.

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR
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Appendix A:

Full CLC-RCI and GSEJA Letters

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A.1 - CLC-RCI Letter

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THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR
FirstCarbon Solutions
A.2 - GSEJA Letter

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BLUM, COLLINS & HO LLP ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017
(213) 572-0400
March 21, 2025
Sophia Pagoulatos Via Email to:

Planning Manager [email protected]
City of Fresno
Planning and Development Department
2600 Fresno Street, Third Floor, Room 3043
Fresno, CA 93721
Subject: Comments on Recirculated Fresno Southeast Development Area Specific Plan Project EIR (SCH NO. 2022020486)
Dear Ms. Pagoulatos,
Thank you for the opportunity to comment on the Recirculated Program Environmental Impact Report (EIR) for the proposed Recirculated Fresno Southeast Development Area Specific Plan Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The proposed project is a Specific Plan (SP) for the Southeast Development Area (SEDA) formerly known as the Southeast Growth Area (SEGA). The mixed-use SEDA SP would permit residential, commercial, and employment generating uses. 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.

The EIR lists the following items as additional components of the project:

1. Phasing Plan: The Phasing Plan defines the required sequence of development for various areas within SEDA.

2. Infrastructure Financing Plan: The proposed project would include a Public Facilities Financing Plan to present a strategy and funding options for backbone infrastructure and public facilities, including roads, sewer, water, storm drainage, parks, and other public facilities.

GSEJA

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1 Sophia Pagoulatos
March 21, 2025

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Backbone infrastructure and public facilities required for development would be funded through a combination of public and private funding. The Public Facilities Financing Plan has been developed through a review of the SEDA Specific Plan, infrastructure studies, and coordination with the City.

3. Annexation: The proposed project requires annexation of Fresno County (County) lands into the City. LAFCo is a Responsible Agency under CEQA for the proposed project. LAFCo will consider the analysis contained in this EIR when considering the annexation of the project site into the City. Annexation will be strategic and proactive to facilitate infrastructure development by the City.

4. General Plan Amendment and Development Code Change: The proposed project would also amend the General Plan and Development Code to implement the land use and zoning described in the proposed project.

1.4 Documents Incorporated by Reference
The EIR states that the Southeast Development Area Specific Plan (SEDA SP) document itself (2023) is incorporated by reference. The SEDA SP is the proposed project and excluding it as an attachment for public review does not comply with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the SEDA SP document contributes directly to analysis of the problem at hand. The EIR must be revised to include the SEDA SP document for review, analysis, and comment by the public and decision makers.

2.0 Project Description
The EIR is not clear regarding the proposed General Plan land use designations for the project site.

Specifically, the EIR only provides exhibits that depict the Existing General Plan land use designations and the proposed SEDA SP land use designations, leaving the reader to assume that the proposed SEDA land uses are the new General Plan land use designations. It must be noted that the City’s General Plan does not list any of the 10 proposed SEDA land use designations as existing land use designations. For example, SEDA’s employment-focused land use designations are “Office Center” and “Flexible Research and Development.” These land use designations do not exist in the City’s General Plan, and neither do any of the other eight proposed land use designations. The City’s General Plan also does not include a broad “Specific Plan” land use designation that would be applied to all parcels within any approved Specific Plan within the City.

Therefore, all 10 land use designations proposed in the SEDA SP will be new additions to the General Plan and the EIR must be revised to include all text and exhibits that will be part of the revised General Plan and Development Code in order to comply with CEQA’s requirements for meaningful disclosure and adequate informational documents (CEQA § 15121).

GSEJA

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Sophia Pagoulatos
March 21, 2025

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Further, the EIR impact analysis throughout the document relies on the notion that bus rapid transit (BRT) service will be expanded in Fresno to serve the project area (Kings Canyon), rendering several impact areas less than significant. However, the EIR does not provide any meaningful evidence to support the conclusion that the BRT expansion will actually be constructed. Most notably, the Fresno COG Long Range Transportation Plan1 (LRTP) (2019-2050) does not include service to the SEDA SP area as a specific project. Table 2 - LRTP Project List within the LRTP only includes, "Project 6: Extend the Kings Canyon BRT corridor to Fancher Creek,” and the Fancher Creek area is located north/west of the SEDA areas and not contiguous to it. Therefore, BRT service to the project area is not a funded commitment or project and is not planned to exist by 2050. The EIR must be revised to clarify this and update its impact analysis throughout the document.

Additionally, the EIR lists several items as “additional components” of the project that are not included for public review: Phasing Plan, Infrastructure Financing Plan, Annexation, and the above-mentioned General Plan Amendment and Development Code Change. These project components are necessary for the public to review as they directly inform the environmental analysis, such as Utilities and Service Systems, Hydrology and Water Quality, and Public Services.

Excluding these project components as attachments for public review does not comply with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as all project components contribute directly to analysis of the problem at hand.

The EIR must be revised to include all project components for review, analysis, and comment by the public and decision makers.

3.3 Air Quality, 3.6 Energy, and 3.8 Greenhouse Gas Emissions The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. The EIR provides general information about the census tract’s CalEnviroScreen scores but does not provide meaningful analysis regarding the health impacts and effects of severe pollution rates. This is in conflict with CEQA Guidelines Section 15131 (c), which requires that “Economic, social, and particularly housing factors shall be considered by public agencies together with technological and environmental factors in deciding whether changes in a project are feasible to reduce or avoid the significant effects on the environment identified in the EIR. If information on these factors is not contained in the EIR, the information must be added to the record in some other manner to allow the agency to consider the factors in reaching a decision on the project.” 1 https://www.fresnocog.org/wp-content/uploads/2021/10/Fresno-County-Regional-Long-Range-TransitPlan-050519-RL-34.pdf GSEJA

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Fresno City CouncilDecember 18, 2025

Fresno City Council
December 18, 2025