Fresno City Council
December 18, 2025

5 4
3 CONT
Sophia Pagoulatos
March 21, 2025

This is especially significant as the surrounding community is highly burdened by pollution.

According to CalEnviroScreen 4.02, CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project spans multiple census tracts ((6019005904 (Temperance south of Church Street extending east to McCall); 6019001413 (Temperance north of Church Street extending north to Belmont); and 6019001500 (Temperance between Jensen and North extending west to Peach)) that rank significantly worse than the rest of the state in overall pollution burden and specific factors that directly contribute to pollution applied to the socioeconomic factors of the population. Census tract 6019005904 ranks in the 77th percentile for overall pollution burden, census tract 6019001413 ranks in the 57th percentile, and census tract 6019001500 ranks in the 100th percentile, meaning that it is among the most highly polluted census tracts in the state.

The project census tracts rank highly for ozone burden (6019005904 and 6019001413: 89th percentile; 6019001500: 85th percentile), particulate matter (PM) 2.5 burden (6019005904: 95th percentile; 6019001413 and 6019001500: 96th percentile), and diesel PM burden (6019001500:
65th percentile). All of these environmental factors are typically attributed to heavy truck activity in the area. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure3. The very small particles of diesel PM can reach deep into the lung, where they can contribute to a range of health problems. These include irritation to the eyes, throat and nose, heart and lung disease, and lung cancer4.

The census tracts also bear more impacts from cleanup sites compared to the rest of the state (6019005904: 89th percentile; 6019001500: 98th percentile). Chemicals in the buildings, soil, or water at cleanup sites can move into nearby communities through the air or movement of water5.

The census tracts also rank highly for impacts from toxic releases (6019005904: 70th percentile; 6019001413: 74th percentile; 6019001500: 95th percentile). People living near facilities that emit toxic releases may breathe contaminated air regularly or if contaminants are released during an accident6.

The census tracts rank among the most severely impacted in several areas that impact water quality.

Census tract 6019001500 rank in the 94th percentile for groundwater threats. People who live near contaminated groundwater may be exposed to chemicals moving from the soil into the air 2 CalEnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 3 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone 4 OEHHA Diesel Particulate Matter https://oehha.ca.gov/calenviroscreen/indicator/diesel-particulatematter 5 OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites 6 OEHHA Toxic Releases https://oehha.ca.gov/calenviroscreen/indicator/toxic-releases-facilities GSEJA

5 CONT
Sophia Pagoulatos
March 21, 2025

inside their homes7. Additionally, the project census tracts rank highly for drinking water impacts (6019005904: 99th percentile; 6019001413: 94th percentile; 6019001500: 100th percentile), which indicates that the project site ranks with the worst quality drinking water in the state. Poor communities and people in rural areas are exposed to contaminants in their drinking water more often than people in other parts of the state8.

The census tracts also rank highly for solid waste facility impacts (6019005904: 70th percentile; 6019001500: 100th percentile), which can expose people to hazardous chemicals, release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations9. Census tract 6019001500 ranks in the 100th percentile for hazardous waste impacts. Hazardous waste generators and facilities contribute to the contamination of air, water and soil near waste generators and facilities can harm the environment as well as people10.

Further, the census tract is a diverse community including many Hispanic residents (6019005904:
32%; 6019001413: 46%; 6019001500: 75%), Asian-American residents (6019005904: 24%; 6019001413: 25%; 6019001500: 3%), and African-American residents (6019005904: 2%; 6019001413: 2%; 6019001500: 1%), whom are especially vulnerable to the impacts of pollution. The communities have a high rate of low educational attainment, meaning significant portions of the census tracts over age 25 has not attained a high school diploma (6019005904:
56%; 6019001413: 54%; 6019001500: 95%). The community also has a high rate of poverty, meaning significant portions of the households in the census tract have a total income before taxes that is less than the poverty level (6019001500: 94%). Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care11.

Poor communities are often located in areas with high levels of pollution12. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution13. Living in poverty and low education levels are also an indication that residents may lack health insurance or access to medical care. Medical care is vital for the project census tracts as they rank significantly for the incidence of cardiovascular disease (6019001413: 55th percentile; 7 OEHHA Groundwater Threats https://oehha.ca.gov/calenviroscreen/indicator/groundwater-threats 8 OEHHA Drinking Water https://oehha.ca.gov/calenviroscreen/drinking-water 9 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-andfacilities 10 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenviroscreen/indicator/hazardous-waste-generators-and-facilities 11 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 12 Ibid.
13 Ibid.

GSEJA

5 CONT
Sophia Pagoulatos
March 21, 2025

6019001500: 71st percentile) and the incidence of asthma (6019001413: 55th percentile; 6019001500: 93rd percentile). The communities also have a high rate of linguistic isolation, meaning significant portions of residents in the census tracts speak little to no English and faces further inequities as a result (6019005904: 49%; 6019001413: 50%; 6019001500: 70%).

Additionally, the proposed project’s census tracts (6019001413 and 6019001500) are identified as SB 535 Disadvantaged Communities14. This indicates that cumulative impacts of development and environmental impacts in the area are disproportionately impacting these communities. The EIR does not discuss that the project site and surrounding area are disadvantaged communities and does not utilize this information in its analysis. The EIR has not considered the project’s significant and unavoidable cumulatively considerable environmental impacts in relation to the SB 535 status of the project census tracts and surrounding area. The negative environmental, health, and quality of life impacts in the City have become distinctly inequitable. The severity of environmental impacts particularly on these Disadvantaged Communities must be included for analysis as part of a revised EIR.

The State of California lists three approved compliance modeling softwares15 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod and EMFAC are not listed as approved softwares. The CalEEMod/EMFAC and spreadsheet-based modeling does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the EIR did not accurately or adequately model the energy impacts in compliance with Title 24, a finding of significance must be made. A revised EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the EIR utilizes CalEEMod/EMFAC as sources in its methodology and analysis, which are clearly not approved softwares.

3.9 Hazards and Hazardous Materials
The EIR states that, “According to the Fresno Yosemite International Airport Safety Compatibility Zones Map, a small portion of the Plan Area is located within the 60 dB CNEL contour. A Larger portion of the Plan Area is located within the Traffic Pattern Zone.” The EIR concludes that, “The ALUC found the proposed project to be consistent with the ALUCP on August 7, 2023. Therefore, at the programmatic level, impacts to the Plan Area would be less than significant. Consistent with the General Plan and SEDA Specific Plan policies, individual development projects would be 14 OEHHA SB 535 Census Tracts https://oehha.ca.gov/calenviroscreen/sb535 15 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022- building-energy-efficiency-1
GSEJA

5 CONT
6 7
Sophia Pagoulatos
March 21, 2025

required to undergo project-specific environmental review, which may require additional sitespecific or project-specific airport land use compatibility measures to reduce any potential impacts and ensure that impacts remain less than significant.”
However, the EIR has not provided any meaningful evidence or analysis to support the claim that the impacts are less than significant. Notably, the Fresno County Airport Land Use Commission (FC ALUC) review document is not included as an attachment for public review in compliance with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the FC ALUC review document contributes directly to analysis of the problem at hand. The EIR must be revised to include the FC ALUC review document for review, analysis, and comment by the public and decision makers.

Additionally, based on the August 7, 2023 FC ALUC meeting agenda16, attachments17/ 18, and
minutes19 of the meeting, the FC ALUC only reviewed the SEDA Specific Plan. The FC ALUC did not explicitly review or take action on all aspects of the project, including the required General Plan Amendment and Development Code Change required to implement the proposed project.

The California Airport Land Use Planning Handbook20 states that Airport Land Use Commission review is required “Prior to the amendment of a general plan or specific plan, or the adoption of a zoning ordinance or building regulation within the ALUCP planning boundary, the ALUC shall review the plan, ordinance, or regulation for consistency with the ALUCP (PUC Section 21676(b)).” Given that the proposed project includes General Plan Amendment and Development Code Change to proceed, FC ALUC review of all associated actions is required. As stated above in the Project Description analysis, the EIR has not provided the new text or exhibits to be included in the revised General Plan associated with the 10 new land use designations created by the proposed project, or the new text of the development code. Therefore, the FC ALUC has not reviewed the required General Plan Amendment and a revised EIR must be prepared to include a finding of significance.
16 August 7, 2023 FC ALUC meeting agenda https://agendas2011-24.fresnocog.org/agenda/read/785 17 August 7, 2023 FC ALUC attachment for SEDA project https://agendas2011-

24.fresnocog.org/itemAttachments/785/SEDA_-_ALUC_Submittal_-_7.24_.23_.pdf 18 August 7, 2023 FC ALUC attachment for SEDA project https://agendas2011-

24.fresnocog.org/itemAttachments/785/SEDA_-_FAT_Influence_Areas.pdf 19 August 7, 2023 FC ALUC meeting minutes https://agendas2011-

24.fresnocog.org/itemAttachments/794/080723_ALUC_Action_Summary.pdf 20 California Airport Land Use Planning Handbook https://dot.ca.gov/-/media/dotmedia/programs/aeronautics/documents/californiaairportlanduseplanninghandbook-a11y.pdf GSEJA

7 CONT
Sophia Pagoulatos
March 21, 2025

3.11 Land Use and Planning
It must be noted that the EIR does not accurately characterize or analyze the permitted use types within each land use designation of the SEDA SP21. For example, SEDA SP Policy EO-2.1 states, “Promote industry clusters that build on Fresno’s local strengths. The SEDA Plan presents opportunities for each of the following clusters: Advanced Manufacturing, Clean Energy, Construction, Food Processing, Healthcare, Information Processing, Logistics & Distribution, Software Development, Tourism, and Water Technology. This list may evolve as Fresno grows and changes.” The EIR does not discuss or analyze the possibility of logistics and distribution uses in any of the proposed land use designations. The EIR is inadequate as an informational document and must be revised to accurately list all permitted/conditionally permitted uses within each land use designation and update all associated impact analysis.

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).

Additionally, the EIR does not provide adequate information to determine the project’s compliance or noncompliance with statutory requirements of the Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 33022/SB 823. The HCA/SB 330/SB 8 require replacement housing sites when land designated for housing development experience land use changes to ensure no net loss of housing capacity.
21 SEDA SP https://www.fresno.gov/wp-content/uploads/2023/07/Draft-SEDA-Specific-Plan.pdf 22 Housing Crisis Act of 2019/SB 330
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330 23 SB 8 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB8 GSEJA

8 9
Sophia Pagoulatos
March 21, 2025

Government Code Section 66300(b)(1)(A) requires that agencies shall not “change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances in effect at the time of the proposed change.” Under Government Code Section 66300(b)(1)(A), a “less intensive use” includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or any other action that would individually or cumulatively reduce residential development capacity. Pursuant to SB 330, replacement capacity for any displaced residential units must be provided concurrently at the time of project approval.

Government Code Section 66300 (h)(i)(1) states that, “this section does not prohibit an affected county or an affected city, including the local electorate acting through the initiative process, from changing a land use designation or zoning ordinance to a less intensive use, or reducing the intensity of land use, if the city or county concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity.” The EIR is inadequate in that it does not provide the acreage of each existing General Plan land use designation within the project area. The total acreage for each existing General Plan land use designation is necessary to calculate the existing total residential development capacity to ensure there is no net loss of capacity. The EIR must be revised to include this information for analysis.

3.14 Population and Housing
The EIR states that, “According to General Plan Tables 1-3 (Residential Development Capacity at General Plan Horizon) and 1-4 (Residential Development Capacity at General Plan Buildout, the proposed project would generate up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units, comprising approximately 31 percent of the total planned capacity for the City. Buildout of the proposed project is considered planned growth and would provide housing to meet the demand for new residential units.” However, this statement does not accurately reflect General Plan Tables 1-3 and 1-4. According to the General Plan, the project site is located within Development Areas (DA) DA-3 Southeast and DA-4 East. General Plan Tables 1-3 and 1-4 provide the following buildout information for DA-3 and DA-4:

Table 1-3: Residential Development Capacity Under General Plan Horizon (2035) DA-3 Southeast
Type of Dwelling Unit (DU)
Multi-Family/Townhouse: 2,500 DU
SFD: 3,500 DU
GSEJA

9 CONT
10 11
Sophia Pagoulatos
March 21, 2025

Total: 6,000 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 6,000 DU DA-4 East
Type of DU
MF/Townhouse: 5,100 DU
SFD: 3,800 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 8,900 DU Total General Plan Horizon (2035) = 14,900 DU
Table 1-4: Residential Development Capacity Under Buildout (2056) DA-3 Southeast
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 9,092 DU DA-4 East
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 35,008 DU Total General Plan Buildout (2056) = 44,100 DU
The EIR states that the General Plan provides for, “up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units.” However, the sum of 14,900 DU and 25,000 DU is 39,900 DU, which is 5,100 DU fewer than the proposed project. It must be noted that the General Plan excludes the specific date of total buildout, but the 2019 EIR for the General Plan Update24 clearly identifies the total buildout year as 2056.

As shown above, the General Plan accommodates a cumulative total of 44,100 DU on the project site from General Plan adoption through 2056. This is 900 DU fewer than the 45,000 DU proposed by the project. The proposed project exceeds the cumulative General Plan buildout scenario through 2056 and the EIR must be revised to disclose this with a finding of significance. 24 https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-GP-Public-Review-Draft-ProgramEIR.pdf GSEJA

11 CONT
Sophia Pagoulatos
March 21, 2025

A revised EIR must also provide a cumulative analysis of projects approved and “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed Fresno COG’s employment and population growth forecasts, and all projects approved since 2014 and projects “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed the City’s General Plan employment and population growth forecasts. For example, the General Plan includes Table 1-5: Population Estimate Under Horizon and Buildout that depicts the City will add 226,000 residents by horizon year 2035 and a cumulative total of 425,000 residents by General Plan buildout in 2056. The EIR’s estimated 134,550 residents accounts for

59.5% of horizon population buildout (2035), 31.6% of total General Plan population buildout (2056), and 67.5% of the population increase from 2035 to 2056. This is a significant amount of growth attributable to a single project. The EIR has not prepared an adequate cumulative analysis to determine the City’s progress towards these buildout scenarios and a revised EIR must be prepared with this information in order to provide an adequate and accurate environmental analysis.

The EIR states that, “new development would be required to address potential environmental impacts as part of individual project review. As such, cumulative development would not induce substantial unplanned population growth, either directly or indirectly. Because cumulative projects would comply with all applicable land use plans to provide adequate development within a jurisdiction, cumulative impacts would be less than significant.” This statement is misleading and erroneous as CEQA provides several options to exempt future projects from environmental review.

New development would not be required to address potential environmental impacts as part of individual project review. New residential development proposed pursuant to the SEDA SP is statutorily exempt from CEQA due to the adoption of a Program EIR. Specifically, CEQA Guidelines Section 15168 (c)(2) states regarding later activities that, “If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required.” CEQA Guidelines Section 15182 exempts “residential, commercial and mixed-use projects that are consistent with a specific plan.” CEQA Guidelines Section 15182 (c) exempts residential projects so long as no new information has been presented pursuant to Section 15162. Additionally, CEQA Guidelines Section 15168 (b)(2) provides a list of advantages for developing a Program EIR as, “Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis.” Therefore, the EIR’s reliance upon delayed/future CEQA review as part of individual project review is not adequate or accurate and does not support a less than significant finding. The EIR must be revised to remove these statements and provide a finding of significance.

GSEJA

12 Sophia Pagoulatos
March 21, 2025

3.17 Transportation and Traffic
The EIR has not provided any consistency analysis with the Fresno Council of Governments (COG) 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)25. Due to errors in modeling, modeling without supporting evidence, and the EIR’s conclusion the project will result in significant and unavoidable cumulatively considerable impacts to Air Quality, the proposed project has signifiant potential for inconsistency with Goal 2: Vibrant communities that are accessible by sustainable transportation options, Policy 4: Encourage alternatives to singleoccupancy vehicles that reduce vehicle miles traveled (VMT) and greenhouse gas emissions, and Policy 6: Encourage sustainable development that focuses growth near activity centers and mobility options that achieve greater location efficiency. Portions of the project site is also identified as an Environmental Justice area26 in Fresno COG’s 2022 RTP/SCS. Since the project requires a General Plan Amendment to the land use designations on the project site to proceed, it was clearly not accounted for or analyzed by the 2022 RTP/SCS. A revised EIR must be prepared to accurately analyze and disclose the inconsistency with the 2022 RTP/SCS document with a finding of significance.

Further, the EIR impact analysis 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 Plan27 (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.

4.2 Growth-Inducing Impacts
The EIR has excluded for discussion for the precedence setting action that approval of the required General Plan Amendment and Development Code Change set for future changes in the City. The EIR must be revised to include a finding of significance as the required GPA/Development Code Change to implement the project will result in significant and unavoidable cumulatively 25 Fresno COG 2022 RTP/SCS https://www.planfresno.com/sustainable-communities-strategies-falloutreach/ 26 Environmental Justice Chapter of 2022 Fresno COG RTP/SCS https://www.planfresno.com/planfresno/uploads/2022/06/Chapter-7-Environmental-Justice-Final-Draft.pdf 27 https://www.fresnocog.org/wp-content/uploads/2021/10/Fresno-County-Regional-Long-Range-TransitPlan-050519-RL-34.pdf GSEJA

13 14
15 Sophia Pagoulatos
March 21, 2025

considerable impacts to Aesthetics, Agricultural Resources, Air Quality, and Noise, and approval of the proposed project will set precedent for approval of other projects with significant and unavoidable impacts that require changes in land use designations and will encourage and facilitate other activities that will have significant negative impacts to the environment. The EIR must be revised to disclose this information and provide a finding of significance.

The EIR has excluded discussion of the precedence setting action that approval of the required General Plan Amendment and Development Code Change set for future changes in the City. The EIR does not analyze that the project will create 10 new General Plan land use designations that can be applied to any property in the City. The EIR must be revised to disclose this information and provide a finding of significance.

The EIR states that, “According to General Plan Tables 1-3 (Residential Development Capacity at General Plan Horizon) and 1-4 (Residential Development Capacity at General Plan Buildout, the proposed project would generate up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units, comprising approximately 31 percent of the total planned capacity for the City. Buildout of the proposed project is considered planned growth and would provide housing to meet the demand for new residential units.” However, this statement does not accurately reflect General Plan Tables 1-3 and 1-4. According to the General Plan, the project site is located within Development Areas (DA) DA-3 Southeast and DA-4 East. General Plan Tables 1-3 and 1-4 provide the following buildout information for DA-3 and DA-4:

Table 1-3: Residential Development Capacity Under General Plan Horizon (2035) DA-3 Southeast
Type of Dwelling Unit (DU)
Multi-Family/Townhouse: 2,500 DU
SFD: 3,500 DU
Total: 6,000 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 6,000 DU DA-4 East
Type of DU
MF/Townhouse: 5,100 DU
SFD: 3,800 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 8,900 DU GSEJA

15 CONT
Sophia Pagoulatos
March 21, 2025

Total General Plan Horizon (2035) = 14,900 DU
Table 1-4: Residential Development Capacity Under Buildout (2056) DA-3 Southeast
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 9,092 DU DA-4 East
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 35,008 DU Total General Plan Buildout (2056) = 44,100 DU
The EIR states that the General Plan provides for, “up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units.” However, the sum of 14,900 DU and 25,000 DU is 39,900 DU, which is 5,100 DU fewer than the proposed project. It must be noted that the General Plan excludes the specific date of total buildout, but the 2019 EIR for the General Plan Update28 clearly identifies the total buildout year as 2056.

As shown above, the General Plan accommodates a cumulative total of 44,100 DU on the project site from General Plan adoption through 2056. This is 900 DU fewer than the 45,000 DU proposed by the project. The proposed project exceeds the cumulative General Plan buildout scenario through 2056 and the EIR must be revised to disclose this with a finding of significance.

The EIR must also be
A revised EIR must also provide a cumulative analysis of projects approved and “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed Fresno COG’s employment and population growth forecasts, and all projects approved since 2014 and projects “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed the City’s General Plan employment and population growth forecasts. For example, the General Plan includes Table 1-5: Population Estimate Under Horizon and Buildout that depicts the City will add 226,000 residents by horizon year 2035 and a cumulative total of 425,000 residents by General Plan buildout in 2056. The EIR’s estimated 134,550 residents accounts for

59.5% of horizon population buildout (2035), 31.6% of total General Plan population buildout 28 https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-GP-Public-Review-Draft-ProgramEIR.pdf GSEJA

15 CONT
16 Sophia Pagoulatos
March 21, 2025

(2056), and 67.5% of the population increase from 2035 to 2056. This is a significant amount of growth attributable to a single project. The EIR has not prepared an adequate cumulative analysis to determine the City’s progress towards these buildout scenarios and a revised EIR must be prepared with this information in order to provide an adequate and accurate environmental analysis.

4.3 Mandatory Findings of Significance
The EIR concludes that the proposed project will have a less than significant impact regarding Mandatory Finding of Significance Threshold 3: “The environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.” The EIR states that, “Compliance with and implementation of mitigation measures, existing regulations, and the City’s standard permit conditions would ensure that the proposed project, and future development consistent with the proposed project, would not result in substantial adverse effects on human beings, including effects related to air pollution, seismic and geologic hazards, hazardous materials, flooding and natural disasters, or noise and vibration. Therefore, impacts associated with the proposed project would be less than significant.”
However, this analysis fails to account for the project’s significant and unavoidable cumulatively considerable impact for Threshold AIR-3: Project-level Sensitive Receptors Exposure to Pollutant Concentrations. Regarding this signifiant impact, the EIR states that proposed mitigation would reduce impacts to the extent feasible, but, “the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Further, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds. Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants, and thus a significant and unavoidable impact may result.” The EIR is internally inconsistent as it does not acknowledge this impact in the Mandatory Findings.

The EIR must be revised to include this information for analysis and provide a finding of significance.

GSEJA

16 CONT
17 Sophia Pagoulatos
March 21, 2025

5.0 Alternatives
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.) The alternatives chosen for analysis include the CEQA required “No Project/No Build” alternative and only two others - Consolidated Business Park Alternative and Farmland Conservation Alternative. The EIR does not evaluate a reasonable range of alternatives as only two alternatives beyond the required No Project alternative are analyzed. The EIR does not include an alternative eliminates any of the project’s significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6). This could include alternatives such as development of the site with a project that eliminates all of the proposed project’s significant and unavoidable impacts to less than significant levels while meeting all project objectives. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6).

Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance 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.

Sincerely,
Vashon Simien
Blum, Collins & Ho, LLP
Attachments:

1. SWAPE Technical Analysis
GSEJA

18 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 18, 2025
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the Fresno Southeast Development Area Specific Plan Project (SCH No. 2022020486)
Dear Mr. Ho,
We have reviewed the February 2025 Recirculated Draft Program Environmental Impact Report (“RDPEIR”) for the Fresno Southeast Development Area Specific Plan Project (“Specific Plan”) located in the City of Fresno. The Project proposes constructing complete communities and mixed-use centers, including up to 45,000 dwelling units, over a 9,000-acre plan area.

In our opinion, the RDPEIR does not sufficiently evaluate the Project’s air quality and greenhouse gas (“GHG”) impacts. Emissions associated with construction and operation of the proposed Project may therefore be inadequately addressed. A revised Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential air quality and greenhouse gas impacts that the project may have on the environment.

Air Quality
Failure to Implement All Feasible Mitigation Measures to Reduce ConstructionRelated and Operational Criteria Air Pollutant Emissions The RDPEIR relies on California Emissions Estimator Model (“CalEEMod”) to estimate emissions from construction and operation of future projects under the Specific Plan. Despite incorporating Mitigation Measures (“MM”) AIR-1a through AIR-1d, the RDPEIR concludes that construction-related and operational emissions of volatile organic compounds (“VOC”), nitrogen oxide (“NOx), carbon oxide (“CO”), particulate matter 10 (“PM₁₀”), and particulate matter 2.5 (“PM2.5”) would remain significant and unavoidable (pp. 3.3-48–51, Table 3.3-8, Table 3.3-9).

GSEJA

19 2
The RDPEIR, however, does not implement all feasible mitigation for reducing these emissions. The California Environmental Quality Act (“CEQA”) requires lead agencies to implement all feasible mitigation to reduce significant impacts to the maximum extent feasible. 1 The RDPEIR fails to evaluate
or adopt additional measures that could further reduce emissions. As outlined in the “Feasible Mitigation Measures Available to Reduce Emissions” section of this letter, we suggest further mitigation measures to be considered; a revised EIR should be prepared to further assess and incorporate all available mitigation before concluding that impacts are significant and unavoidable.

Greenhouse Gas
Failure to Implement All Feasible Mitigation Measures to Reduce Greenhouse Gas Impacts
The RDPEIR estimates that Project construction and operation would generate 2,316,578 and 510,791 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”), respectively (p. 3.8-42–43, Table

3.8-2, 2.8-3). The RDPEIR concludes that the Project’s GHG emissions would be less than significant based on consistency with the 2022 ARB Scoping Plan and the Fresno 2022 Regional Transportation Plant (“RTP”) and the Sustainable Communities Strategy (“SCS”) (p. 3.8-56).

In our opinion, however, the RDPEIR’s significant and unavoidable conclusion lacks sufficient support.

CEQA requires the RDPEIR to implement all feasible mitigation to minimize impacts to the maximum extent feasible.
2 An impact can only be deemed significant and unavoidable after considering all available feasible mitigation. The RDPEIR does not incorporate all feasible mitigation measures despite declaring compliance with the RTP and SCS plans.

A revised EIR should be prepared to include and provide evidence for the implementation of additional feasible mitigation measures which we recommend below in the section titled, “Feasible Mitigation Measures Available to Reduce Emissions.”
Mitigation
Feasible Mitigation Measures Available to Reduce Emissions The RDPEIR concludes that the construction and operation of future projects under the Specific Plan would lead to significant air quality and GHG impacts. Under CEQA, the RDPEIR is required to implement all feasible mitigation. We have provided a list of additional mitigation measures below for the Project Applicant to consider implementing as formal mitigation measures in a future EIR. 1 “Guidance on Frequently Questioned Topics in Roadway Analysis for the California Environmental Quality Act (CEQA).” CEQA, February 2018, available at: https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/roadway-ceqa-guidance_v10.pdf, p. 2. 2 Ibid.

GSEJA

19 CONT
3 To reduce the VOC emissions associated with the construction and operation of future projects, we recommend the RDPEIR consider incorporating the following mitigation measures used by other land use development projects to address VOC emissions: 3
• Recycle leftover paint. Take any leftover paint to a household hazardous waste center; do not mix leftover water-based and oil-based paints.
• Keep lids closed on all paint containers when not in use to prevent VOC emissions and excessive odors.
• For water-based paints, clean up with water only. Whenever possible, do not rinse the cleanup water down the drain or pour it directly into the ground or the storm drain • Use compliant low-VOC cleaning solvents to clean paint application equipment. • Keep all paint- and solvent-laden rags in sealed containers to prevent VOC emissions.

The United States Environmental Protection Agency recommends conducting calculations for coverage area and thinning ratios prior to purchasing paints. By applying these calculations, the appropriate quantity of paint can be acquired, helping to minimize waste and optimize resource use.4 To reduce construction VOC emissions, the California Department of Public Health (“CDPH”) recommends the use of:5

• Composite wood products that comply with the California Air Resources Board's (“CARB”) Airborne Toxic Control Measure for formaldehyde.
• Interior paints, coatings, adhesives, and sealants that comply with South Coast AQMD Rule 1168 or CARB’s Suggested Control Measure for Architectural Coatings. • Flooring materials that are certified as low emitting under the CDPH Standard Method v1.2 or equivalent.
• Sealer on the surface of spray-on fireproofing to reduce adsorption of VOCs using a low-VOC sealer, if necessary.

An additional mitigation measure that may reduce the impact from operational VOC emissions is to implement a mechanical ventilation system meeting the American Society of Heating, Refrigerating and Air-Conditioning Engineers Standards 62.1 and 62.2. 6 HVAC systems should include MERV 13 or higher filters to reduce indoor pollutant exposure. Prior to occupancy, the building should undergo a flush-out 3 “Banning Commerce Center Project.” Kimley-Horn and Associates, Inc., June 2024, available at:
https://ceqanet.opr.ca.gov/2022090102/2; Draft Environmental Impact Report, p. 1-7. 4 “Methods for Estimating Air Emissions from Paint, Ink, and Other Coating Manufacturing Facilities.” Emissions Inventory Improvement Program, February 2005, available at: https://www.epa.gov/sites/default/files/2015- 08/documents/ii08_feb2005.pdf, Volume II, Chapter 8, p. 8.3-1. 5 “Reducing occupant exposure to volatile organic compounds (VOCs) from indoor sources: Guidelines for building occupants.” California Department of Public Health, July 1996, available at:
https://www.cdph.ca.gov/Programs/CCDPHP/DEODC/EHLB/IAQ/CDPH%20Document%20Library/reducing_occupa nt_exposure_vocs_guidelines_ADA.pdf. 6 Ibid., p. xii.

GSEJA

19 CONT
4 period with HVAC systems operating at full capacity for at least 48 hours to remove residual VOCs and improve indoor air quality.

To reduce the NOx, PM10, and PM2.5 emissions from the construction and operation of future project, which commonly originate from mobile source engines and road dust, we recommend the DPEIR consider incorporating several mitigation measures (see list below).7,8 The Southern California Association of Governments (“SCAG”)’s 2020 RTP/SCS Program Environmental Impact Report recommends the followingAir Quality Project Level Mitigation Measures, which are applicable to future projects: 9
• Minimize land disturbance.
• Cover trucks when hauling dirt.
• Limit vehicular paths on unpaved surfaces and stabilize any temporary roads. • Minimize unnecessary vehicular and machinery activities. • Provide an operational water truck on-site at all times. Use watering trucks to minimize dust; watering should be sufficient to confine dust plumes to the project work areas. Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway.
• Develop a traffic plan to minimize community impacts as a result of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours. Minimize obstruction of through-traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. • Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project.
• Require residential area parking permit.

To reduce the CO emissions associated with the construction and operation of future projects under the Specific Plan, the Bay Area Air Quality Management District recommends implementing “reduction programs to reduce vehicle miles traveled (“VMT”), improving bicycle and pedestrian infrastructure and access; improving public transit service and access; designating truck routes and limiting heavy-duty 7 “Proposed Revisions to the National Ambient Air Quality Standards for Nitrogen Dioxide.” EPA, July 2009, available at: https://www.gpo.gov/fdsys/pkg/FR-2009-07-15/pdf/E9-15944.pdf. 8 “Particle Pollution and your Health.” EPA, September 2003, available at:
https://www.airnow.gov/publications/air-quality-andyour-health/partical-pollution-and-your-health/. 9 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/fileattachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4.0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” SCAG, May 2020, available at: https://scag.ca.gov/peir.

GSEJA

19 CONT
5 truck traffic during peak hours, and encouraging the use of cleaner fuel vehicles.”10 We recommend the following mitigation measures used by other land use development projects:
• All construction equipment shall be properly tuned and maintained in accordance with manufacturer specifications.
• The use of electrical or natural-gas-powered construction equipment shall be employed where feasible, including forklifts and other comparable equipment types.

To reduce the GHG emissions associated with future projects, we suggest several mitigation measures (see list below).

The SCAG’s 2020 RTP/SCS Program Environmental Impact Report Greenhouse Gas Project Level Mitigation Measures recommends:
• Incorporate bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; and planning for and building local bicycle projects that connect with the regional network.
• Improving transit access to rail and bus routes by incentives for construction and transit facilities within developments, and/or providing dedicated shuttle service to transit stations. • Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles.

In their 2022 Scoping Plan, CARB recommends that new residential projects “[use] all-electric appliances without any natural gas connections and [do] not use propane or other fossil fuels for space heating, water heating, or indoor cooking” in order to reduce Project-related GHG emissions. 11 CEQA Guidelines 15126.4 (c)(3) include “[o]ffsite measures, including offsets that are not otherwise required, to mitigate a project’s emissions” as viable options for GHG mitigation.12 While the use of local carbon offset programs to reduce a project's GHG impacts should be considered as a measure of last resort, around 5% of project have implemented such strategies to mitigate residual emissions.13 There are many instances of projects implementing similar strategies, one example is the Otay Ranch Village 10 “Mitigating Air Quality and Climate Impacts.” BAAQMD, 2022, available at:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines-2022/ceqa-guidelineschapter-8-mitigation_final-pdf.pdf?rev=5a4aa8d31c394498b8b4de4e9eb46edc, p. 8-2 and 3. 11 “2022 Scoping Plan For Achieving Carbon Neutrality” CARB, November 2022, available at:
https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf, Appendix D, p. 23, Table

3. 12 “Cal. Code Regs. tit. 14 § 15126.4.” CEQA Guidelines, May 2024, available at:
https://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6-resourcesagency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-ofenvironmental-impact-reports/section-151264-consideration-and-discussion-of-mitigation-measures-proposed-tominimize-significant-effects. 13 “Local CEQA Mitigation Best Practices and Lessons Learned.” CARB and California EPA, September 2023, available at: https://ww2.arb.ca.gov/sites/default/files/2023-11/CARB%2021STC001%20White%20Paper.pdf, p. ix,

46. GSEJA

19 CONT
6 13 Project in San Diego County which proposed the use of carbon offsets to mitigate its GHG emissions.14 Another example of this was in the case of the Oakland Sports and Mixed-Use Project, where off-site reduction measures in the neighboring communities were recommended.15 The California Air Pollution Control Officers Association recommends the establishment of community gardens as a method of mitigation for greenhouse gas.16 Community gardens can provide local food sources, potentially reducing VMT for grocery shopping and displacing carbon-intensive food production practices. The reduced VMT could minimize CO, NOx, PM10, and PM2.5 emissions from the operations of future projects under the Specific Plan.

The measures provided offer feasible ways to incorporate lower-emitting design features into the proposed Project, which can subsequently reduce emissions released during the construction and operation of the future projects.

We recommend a revised EIR be prepared to include all feasible mitigation measures, as well as updated air quality and GHG analyses to ensure that the necessary mitigation measures are implemented. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Specific Plan approval to ensure that the potentially significant emissions from future projects are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited documentation regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
14 “List Of Mitigation Measures and Environmental Design Considerations.” Otay Ranch Resort Village FEIR, County of San Diego, September 2020, available at:
https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/OtayRanchVillage13Resort/PreBoard/DFEIR/7.0%20 List%20of%20Mitigation%20Measures%20.pdf, Chapter 7.0, p. 7-50. 15 “Cal. Pub. Resources Code § 21168.6.7.” 2024, available at: https://casetext.com/statute/californiacodes/california-public-resources-code/division-13-environmental-quality/chapter-6-limitations/section-2116867- oakland-sports-and-mixed-use-project-conditions-for-approval-certification-of-project-for-streamlining. 16 “Quantifying Greenhouse Gas Mitigation Measures.” CAPCOA, August 2010, available at:
https://www.aqmd.gov/docs/default-source/ceqa/handbook/capcoa-quantifying-greenhouse-gas-mitigationmeasures.pdf, p. 448.

GSEJA

19 CONT
7 Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV
GSEJA

19 CONT
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigationand RemediationStrategies
LitigationSupport and Testifying Expert
IndustrialStormwaterCompliance
CEQAReview
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

ProfessionalCertifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
ProfessionalExperience:

Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2104, 2017; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); Attachment A
GSEJA

19 CONT
2 • Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vaporintrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications forlarge solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Seniorresearcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Seniorresearcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.

GSEJA

19 CONT
3 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted GSEJA

19 CONT
4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9.

Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific GSEJA

19 CONT
5 principles into the policy‐making process.
• Established national protocol for the peerreview of scientific documents.

Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

GSEJA

19 CONT
6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.

GSEJA

19 CONT
7 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.

Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting.

GSEJA

19 CONT
8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009‐2011.

GSEJA

19 CONT

SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 12 October 2022
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Focus on wastewater treatment.

Professional Experience
Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources.

Attachment B
GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 2 of 12 October 2022
Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113–125.

Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 3 of 12 October 2022
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.

Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 4 of 12 October 2022
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).

Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.

Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.

Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 5 of 12 October 2022
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 6 of 12 October 2022
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.

Lecture conducted from Phoenix Arizona.

Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 7 of 12 October 2022
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.

National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.

Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 8 of 12 October 2022
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
Deposition and/or Trial Testimony:

In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022
In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 9 of 12 October 2022
In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022
In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022

In the Circuit Court of the 4th Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 10 of 12 October 2022
In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021
In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021
In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021

In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al.cvs. Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021
In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.

Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021
In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2-23-2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019
GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 11 of 12 October 2022
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No. 2:17-cv-01624-ES-SCM
Rosenfeld Deposition 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.

Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. 1:16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. C12-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017
GSEJA

19 CONT
Paul E. Rosenfeld, Ph.D. Page 12 of 12 October 2022
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No. RG14711115
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case No. cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case No. 2:07CV1052
Rosenfeld Deposition July 2009
GSEJA

19 CONT

THIS PAGE INTENTIONALLY LEFT BLANK
NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
DRAFT
Program Environmental Impact Report
Fresno Southeast Development Area Specific Plan Project City of Fresno, Fresno County, California
State Clearinghouse Number 2022020486
Prepared for:

City of Fresno
Planning and Development Department
2600 Fresno Street, Room 3065
Fresno, CA 93721
559.907.5221
Contact: Sophia Pagoulatos, Planning Manager
Prepared by:

FirstCarbon Solutions
7726 N. First Street, No. 413
Fresno, CA 93720
Contact: Mary Bean, Project Director
Phil Ault, Project Director
Rachel Krusenoski, Project Manager
Date: July 14, 2023

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Table of Contents
FirstCarbon Solutions iii https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-01 TOC.docx Table of Contents
Acronyms and Abbreviations .........................................................................................................ix Executive Summary ....................................................................................................................... 1 Purpose...................................................................................................................................... 1 Project Summary ....................................................................................................................... 1 Significant Unavoidable Adverse Impacts ................................................................................. 4 Areas of Controversy ................................................................................................................. 8 Public Review of the Draft Program EIR .................................................................................... 9 Executive Summary Matrix...................................................................................................... 10 Chapter 1: Introduction............................................................................................................... 1-1

1.1 - Overview of the CEQA Process....................................................................................... 1-1

1.2 - Scope of the Draft Program EIR...................................................................................... 1-5

1.3 - Organization of the Draft Program EIR.........................................................................1-23

1.4 - Documents Incorporated by Reference........................................................................1-25

1.5 - Documents Prepared for the Proposed Project ...........................................................1-26

1.6 - Review of the Draft Program EIR..................................................................................1-26 Chapter 2: Project Description .................................................................................................... 2-1

2.1 - Specific Plan Approval Process....................................................................................... 2-1

2.2 - Existing ........................................................................................................................... 2-4

2.3 - Project Characteristics.................................................................................................... 2-5

2.4 - Project Objectives......................................................................................................... 2-10

2.5 - Intended Uses of this Draft Program EIR......................................................................2-12 Chapter 3: Environmental Impact Analysis.................................................................................. 3-1 Organization of Issue Areas.................................................................................................... 3-1 Issues Addressed in this Draft Program EIR............................................................................3-1 Level of Significance ............................................................................................................... 3-1 Impact Analysis and Mitigation Measure Format ..................................................................3-2

3.1 - Aesthetics, Light, and Glare.........................................................................................3.1-1

3.2 - Agricultural Resources and Forestry Resources ..........................................................3.2-1

3.3 - Air Quality.................................................................................................................... 3.3-1

3.4 - Biological Resources.................................................................................................... 3.4-1

3.5 - Cultural Resources and Tribal Cultural Resources.......................................................3.5-1

3.6 - Energy.......................................................................................................................... 3.6-1

3.7 - Geology, Soils, and Seismicity......................................................................................3.7-1

3.8 - Greenhouse Gas Emissions .........................................................................................3.8-1

3.9 - Hazards and Hazardous Materials...............................................................................3.9-1

3.10 - Hydrology and Water Quality..................................................................................3.10-1

3.11 - Land Use and Planning ............................................................................................3.11-1

3.12 - Mineral Resources...................................................................................................3.12-1

3.13 - Noise........................................................................................................................ 3.13-1

3.14 - Population and Housing ..........................................................................................3.14-1

3.15 - Public Services.........................................................................................................3.15-1

3.16 - Recreation ............................................................................................................... 3.16-1

3.17 - Transportation and Traffic .......................................................................................3.17-1

3.18 - Utilities and Service Systems...................................................................................3.18-1

3.19 - Wildfire.................................................................................................................... 3.19-1 City of Fresno—Fresno Southeast Development Area Specific Plan Project Table of Contents Draft Program EIR
iv FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-01 TOC.docx Chapter 4: Other CEQA Considerations........................................................................................ 4-1

4.1 - Significant Unavoidable Impacts.................................................................................... 4-1

4.2 - Growth-inducing Impacts .............................................................................................. 4-6

4.3 - Mandatory Findings of Significance............................................................................... 4-7 Chapter 5: Alternatives to the Proposed Project.......................................................................... 5-1

5.1 - Introduction ................................................................................................................... 5-1

5.2 - Project Objectives.......................................................................................................... 5-7

5.3 - Alternative 1—No Project Alternative ........................................................................... 5-9

5.4 - Alternative 2—Consolidated Business Park Alternative .............................................. 5-14

5.5 - Alternative 3—Farmland Conservation Alternative..................................................... 5-22

5.6 - Environmentally Superior Alternative.......................................................................... 5-28

5.7 - Alternatives Rejected From Further Consideration ..................................................... 5-29 Chapter 6: Persons and Organizations Consulted/List of Preparers.............................................. 6-1

6.1 - Lead Agency ................................................................................................................... 6-1

6.2 - List of Preparers............................................................................................................. 6-1 List of Appendices
Appendix A: EIR Noticing and Public Involvement
A.1 - Notice of Preparation
A.2 - NOP Public Scoping Comments
Appendix B: Air Quality, Greenhouse Gas Emissions Supporting Information Appendix C: Biological Resources Supporting Information C.1 - California Natural Diversity Database Results
C.2 - California Native Plant Society Inventory Results C.3 - Project Species List
Appendix D: Cultural and Tribal Cultural Resources Supporting Information D.1 - Record Search Maps
D.2 - California Historical Resources Information System Requests and Results D.3 - Native American Heritage Commission Requests and Results Appendix E: Energy Supporting Information
Appendix F: Hydrology and Water Quality Supporting Information Appendix G: Noise Supporting Information
Appendix H: Transportation Supporting Information
Appendix I: Utilities and Services Systems Supporting Information I.1 - Water Supply Assessment
I.2 - Utilities Technical Study
List of Tables
Table ES-1: Executive Summary Matrix.................................................................................................11 City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Table of Contents
FirstCarbon Solutions v https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-01 TOC.docx Table 1-1: NOP Comment Letters........................................................................................................ 1-5 Table 2-1: Proposed Specific Plan Acreages ........................................................................................ 2-6 Table 3.2-1: Description of Farmland Classifications........................................................................3.2-7 Table 3.3-1: Air Quality Monitoring Summary..................................................................................3.3-4 Table 3.3-2: Air Quality Index and Health Effects from Ozone .........................................................3.3-5 Table 3.3-3: Air Quality Index and Health Effects of Particulate Pollution .......................................3.3-6 Table 3.3-4: San Joaquin Valley Air Basin Attainment Status ...........................................................3.3-9 Table 3.3-5: Description of Air Pollutants.......................................................................................3.3-12 Table 3.3-6: San Joaquin Valley Air Pollution Control District Significance Thresholds..................3.3-41 Table 3.3-7: Screening Levels for Potential Odor Sources..............................................................3.3-43 Table 3.3-8: Annual Construction Regional Emissions—Unmitigated............................................3.3-53 Table 3.3-9: Project Net Annual Operational Emissions–Unmitigated (2050) ...............................3.3-55 Table 3.4-1: Vegetation Communities within the City......................................................................3.4-2 Table 3.4-2: Vegetation Community Types and Description.............................................................3.4-2 Table 3.4-3: Vegetation Communities within the Plan Area.............................................................3.4-7 Table 3.4-4: Special-status Plant Species within the Plan Area ......................................................3.4-13 Table 3.4-5: Special-status Wildlife Species within the Plan Area ..................................................3.4-14 Table 3.5-1: Cultural Resources Recorded within the Plan Area ....................................................3.5-20 Table 3.5-2: Previous Investigations within the Plan Area..............................................................3.5-21 Table 3.8-1: Description of Greenhouse Gases of California Concern..............................................3.8-4 Table 3.8-2: Construction Greenhouse Gas Emissions...................................................................3.8-44 Table 3.8-3: Operational GHG Emissions at Project Buildout.........................................................3.8-45 Table 3.8-4: Consistency with SB 32 2017 Scoping Plan Update ....................................................3.8-55 Table 3.9-1: Facilities Listed on the DTSC EnviroStor Database........................................................3.9-4 Table 3.9-2: Geotracker Sites in the Plan Area .................................................................................3.9-5 Table 3.10-1 Drainage Areas and Basin Capacities.......................................................................3.10-12 Table 3.10-2 General Plan and Specific Plan Anticipated Runoff Volume for Existing Basins Encompassed within SEDA Specific Plan Area ...............................................3.10-45 Table 3.10-3 General Plan and Specific Plan Anticipated Runoff Volume for Proposed Basins within SEDA Specific Plan Area ......................................................................3.10-45 Table 3.11-2: General Plan Consistency Analysis..........................................................................3.11-24 Table 3.13-1: Sound Terminology ...................................................................................................3.13-2 Table 3.13-2: Typical Construction Equipment Maximum Noise Levels.........................................3.13-4 Table 3.13-3: Vibration Levels of Construction Equipment............................................................3.13-6 City of Fresno—Fresno Southeast Development Area Specific Plan Project Table of Contents Draft Program EIR
vi FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-01 TOC.docx Table 3.13-4: Existing (Year 2019) Traffic Noise Levels................................................................... 3.13-9 Table 3.13-5: Federal Transit Administration Construction Vibration Impact Criteria................. 3.13-10 Table 3.13-6: Transportation (Non-Aircraft) Noise Source........................................................... 3.13-14 Table 3.13-7: Stationary Noise Sources........................................................................................ 3.13-15 Table 3.13-8: Year 2035 Forecast Traffic Noise Levels Without and With the Proposed Project ...................................................................................................................... 3.13-22 Table 3.14-1: Projected (2050) Jobs to Housing Ratio for the Planning Area .............................. 3.14-14 Table 3.15-1: Fresno Fire Stations.................................................................................................. 3.15-2 Table 3.15-2: Fire Facilities Impact Fee .......................................................................................... 3.15-4 Table 3.15-3: Street Facilities Fees................................................................................................. 3.15-5 Table 3.15-4: Police Facilities Impact Fee....................................................................................... 3.15-7 Table 3.15-5: School Districts and Schools in the Project Area...................................................... 3.15-8 Table 3.15-6: School District and School Enrollment by Grade...................................................... 3.15-8 Table 3.15-7: City of Fresno Park Types ......................................................................................... 3.15-9 Table 3.15-8: Park Facilities Fees.................................................................................................. 3.15-11 Table 3.15-9: City of Fresno Hospitals.......................................................................................... 3.15-12 Table 3.16-1: Existing Pocket, Neighborhood, and Community Parks........................................... 3.16-2 Table 3.16-2: Desirable Park Facility Standards.............................................................................. 3.16-3 Table 3.17-1: Existing Conditions Study Segment Traffic Volumes ................................................ 3.17-7 Table 3.17-2: Existing Conditions VMT........................................................................................... 3.17-8 Table 3.17-3: Roadway Functional Class and Peak-hour LOS Thresholds .................................... 3.17-25 Table 3.17-4: LOS Thresholds for Daily Segment Volumes based on V/C Ratios.......................... 3.17-26 Table 3.17-5: Proposed Project Trip Generation.......................................................................... 3.17-30 Table 3.17-6: Year 2035 No Project Conditions VMT ................................................................... 3.17-33 Table 3.17-7: Year 2035 With Project Conditions VMT................................................................ 3.17-33 Table 3.17-8: Year 2035 Baseline (No Project) Conditions Study Segment Traffic Volumes........ 3.17-35 Table 3.17-9: Year 2035 Baseline (No Project) Conditions Study Segment LOS........................... 3.17-36 Table 3.17-10: Year 2035 With Project Conditions Study Segment Traffic Volumes.................... 3.17-37 Table 3.17-11: Year 2035 With Project Conditions Study Segment LOS ...................................... 3.17-38 Table 3.18-1: Specific Plan Anticipated Water Demand per Land Use Classification................... 3.18-57 Table 3.18-2: Difference Between General Plan and Specific Plan Anticipated Water Demand .................................................................................................................... 3.18-58 Table 3.18-3 Comparison of General and Specific Plan Anticipated Wastewater Generation per Land Use Classification.................................................................... 3.18-61 City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Table of Contents
FirstCarbon Solutions vii https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-01 TOC.docx Table 3.18-4 General Plan and Specific Plan Anticipated Runoff Volume for Existing Basins Encompassed within SEDA Specific Plan Area ...............................................3.18-63 Table 3.18-5 General Plan and Specific Plan Anticipated Runoff Volume for Proposed Basins within SEDA Specific Plan Area ......................................................................3.18-63 Table 3.18-6 Multiple Dry Years Supply and Demand Comparisons (DWR 7-4R) (2020 UWMP Table 7-3)......................................................................................................3.18-67 Table 5-1: Summary of Alternatives .................................................................................................. 5-28 List of Exhibits
Exhibit 1-1: Specific Plan Map ............................................................................................................. 1-3 Exhibit 2-1: Regional Location Map................................................................................................... 2-15 Exhibit 2-2: Specific Plan Map ........................................................................................................... 2-17 Exhibit 2-3: Proposed Major Street Circulation Network..................................................................2-19 Exhibit 3.2-1: Important Farmland Map...........................................................................................3.2-5 Exhibit 3.2-2: Williamson Act Contract Parcels ..............................................................................3.2-21 Exhibit 3.4-1: Land Cover Types and Vegetation Communities........................................................3.4-5 Exhibit 3.4-2: CNDDB Special-status Species Occurrences.............................................................3.4-11 Exhibit 3.10-1: Flood Hazard Map ................................................................................................3.10-15 Exhibit 3.11-1: Existing General Plan Land Use Map....................................................................3.11-39 Exhibit 3.17-1: Proposed Major Street Circulation Network..........................................................3.17-3 Exhibit 5-1: Consolidated Business Park Alternative .........................................................................5-31 Exhibit 5-2: Farmland Conservation Alternative................................................................................5-33 List of Figures
Figure 3.8-1: Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019 ..........................3.8-8 Figure 3.8-2: Observed and Projected Temperatures for Climate Change in the City of Fresno Area ................................................................................................................. 3.8-11 Figure 3.8-3: California’s Path to Achieving the 2050 Target..........................................................3.8-52

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Acronyms and Abbreviations
FirstCarbon Solutions ix https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx

ACRONYMS AND ABBREVIATIONS
°C degrees Celsius (Centigrade)
°F degrees Fahrenheit
µg/m3 micrograms per cubic meter
AAQS Ambient Air Quality Standards
AB Assembly Bill
ABAG Association of Bay Area Governments
ACHP Advisory Council on Historic Preservation
ACLUP Airport Comprehensive Land Use Plan
ACM asbestos-containing material
ACP Alternative Compliance Plan
ADA Americans with Disabilities Act
ADL aerially deposited lead
ADT Average Daily Traffic
AEP Association of Environmental Professionals
AF acre-feet
AFY acre-feet/year
AIA Airport Influence Area
AIC Archaeological Information Center
AICUZ Air Installation Compatibility Use Zone
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plans
AMSL above mean sea level
APCD Air Pollution Control District
APE Area of Potential Effect
APN Assessor’s Parcel Number
APS Alternative Planning Strategy
AQI Air Quality Index
AQMD Air Quality Management District
AQMP Air Quality Management Plan
AQP Air Quality Plan
ARB California Air Resources Board
ARFF Airport Rescue Fire Fighting
AST aboveground storage tank
ATCM Airborne Toxic Control Measures
ATP Active Transportation Plan
City of Fresno—Fresno Southeast Development Area Specific Plan Project Acronyms and Abbreviations Draft Program EIR
x FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx BAAQMD Bay Area Air Quality Management District
BACT Best Available Control Technology
BART Bay Area Rapid Transit
BAU Business as Usual
BCF billion cubic feet
BCF/year billion cubic feet per year
BGS below ground surface
BMP Best Management Practice
BPS Best Performance Standards
BRT Bus Rapid Transit
BTU British Thermal Unit
BVOC biogenic volatile organic compound
C2ES Center for Climate and Energy Solution
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
CAGR compound annual growth rate
CAL FIRE California Department of Forestry and Fire Protection Cal/EPA California Environmental Protection Agency
Cal/OES California Governor’s Office of Emergency Services Cal/OSHA California Occupational Health and Safety Administration CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CAPCOA California Air Pollution Control Officers Association CARTS Cedar Avenue Recycling and Transfer Station
CBC California Building Standards Code
CBCP dibromochloropropane
CBCP dibromo-chloropropane
CBSC California Building Standards Commission
CCAA California Clean Air Act
CCCC California Climate Change Center
CCR California Code of Regulations
CDF California Department of Finance
CDFW California Department of Fish and Wildlife
CDMG California Division of Mines and Geology
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Acronyms and Abbreviations
FirstCarbon Solutions xi https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CESA California Endangered Species Act
CFC chlorofluorocarbon
CFR Code of Federal Regulations
CH4 methane
CHL California Historical Landmarks
CHRIS California Historical Resources Information System CMP Congestion Management Plan
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CNPSEI California Native Plant Society Electronic Inventory CNRA California Natural Resources Agency
CO carbon monoxide
CO2e carbon dioxide equivalent
COG Council of Governments
CPHI California Points of Historical Interest
CPTED Crime Prevention Through Environmental Design
CPUC California Public Utilities Commission
CRA Cultural Resources Assessment
CRHR California Register of Historical Resources
CSA Community Service Area
CTR California Toxics Rule
CUPA Certified Unified Program Agency
CVP Central Valley Project
CWA Clean Water Act
dB decibel
dBA A-weighted decibel
dBA/DD A-weighted decibel per each doubling of the distance DBCP dibromochloropropane
DBH diameter at breast height
DPM diesel particulate matter
DSP District Services Plan
DTSC California Department of Toxic Substances Control
du dwelling unit
du/acre dwelling unit per acre
City of Fresno—Fresno Southeast Development Area Specific Plan Project Acronyms and Abbreviations Draft Program EIR
xii FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx DWR California Department of Water Resources
EDB ethylene dibromide
EDD California Employment Development Department
EFF effective firefighting force
EIA United States Energy Information Administration
EIR Environmental Impact Report
EISA Energy Independence and Security Act
EMFAC Emission Factor
EOC Emergency Operations Center
EPA United States Environmental Protection Agency
EPO Emergency Preparedness Officer
ESMP Environmental Site Management Plan
ETWU Estimated Total Water Usage
EV electric vehicle
FAA Federal Aviation Administration
FAR floor area ratio
FAT Fresno Yosemite International Airport
FAX Fresno Area Express
FBO Fixed Base Operator
FCEHD Fresno County Environmental Health Division
FCMA Fresno-Clovis Metropolitan Area
FCS FirstCarbon Solutions
FEMA Federal Emergency Management Agency
FFD Fresno Fire Department
FGC Fish and Game Code
FGFPD Fig Garden Fire Protection District
FHSZ Fire Hazard Severity Zone
FHWA Federal Highway Administration
FID Fresno Irrigation District
FIP Flood Insurance Program
FIRM Flood Insurance Rate Map
FMC Fresno Municipal Code
FMFCD Fresno Metropolitan Flood Control District
FMMP Farmland Mapping and Monitoring Program
FPP Farmland Preservation Program
FPPA Farmland Protection and Policy Act
FresnoABM Activity Based Travel Demand Model
ft-L footlambert
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Acronyms and Abbreviations
FirstCarbon Solutions xiii https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx GAMAQI Guide for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
GIS Geographic Information Systems
GPCD gallons per capita per day
gpd/ad gallons per day per acre
gpm gallons per minute
GPS Global Positioning System
GSA Groundwater Sustainability Agency
GSP Groundwater Sustainability Plan
GWh gigawatt-hours
GWh/y gigawatt-hours per year
GWP global warming potential
HAP Hazardous Air Pollutants
HCD California Department of Housing and Community Development HCM Highway Capacity Manual
HCP Habitat Conservation Plan
HEPA high-efficiency particulate air
HFC hydrofluorocarbon
HHW household hazardous waste
HMRT Hazardous Materials Response Team
HOV/HOT High Occupancy Vehicle/High Occupancy Toll
HRA Health Risk Assessment
HRI California Historic Resources Inventory
HUD Department of Housing and Urban Development
HVAC heating, ventilation, and air conditioning
HWCL Hazardous Waste Control Law
I/I Infiltration and Inflow
IGSM Integrated Groundwater and Surface Water Model
IIJA Infrastructure Investment and Jobs Act
in/sec inches per second
IOU investor-owned utility
IPaC Information for Planning and Consultation
IPCC United Nations Intergovernmental Panel on Climate Change ISO Independent System Operator
ISTEA Intermodal Surface Transportation Efficiency Act
ITS Intelligent Transportation System
kBTU kilo-British Thermal Unit
kW kilowatts
City of Fresno—Fresno Southeast Development Area Specific Plan Project Acronyms and Abbreviations Draft Program EIR
xiv FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx LAFCo Local Agency Formation Commission
LBP lead-based paint
LCFS Low Carbon Fuel Standard
Ldn day/night average sound level
LED light-emitting diode
LEEDTM Leadership in Energy and Environmental Design
Leq equivalent sound level
LEV Low Emission Vehicle
Lmax maximum noise/sound level
LOS Level of Service
LRA Local Responsibility Area
LSE load-serving entities
LUST Leaking Underground Storage Tank
MBTA Migratory Bird Treaty Act
Metro Plan Metropolitan Water Resources Management Plan MFCP Model Farmland Conservation Program
mg/L milligrams per liter
mgd million gallons per day
MJHMP Multi-Jurisdictional Hazard Mitigation Plan
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
MOU Memorandum of Understanding
mph miles per hour
MPO Metropolitan Planning Organization
MRF Material Recovery Facilities
MRZ Mineral Resources Zone
MS4 Municipal Separate Storm Sewer System
MT metric tons
MTS Metropolitan Transportation System
MTT million metric tons
MW megawatt
MWD Metropolitan Water District of Southern California
MWELO Model Water Efficient Landscape Ordinance
MXD mixed-use development
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NAP-21 Moving Ahead for Progress in the 21st Century Act City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Acronyms and Abbreviations
FirstCarbon Solutions xv https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx NASA National Aeronautics and Space Administration
NCCP Natural Community Conservation Plan
NDC nationally determined contributions
NEHRP National Earthquake Hazards Reduction Program
NEPA National Environmental Policy Act
NESHAP National Emissions Standards for Hazardous Air Pollutants NESWTF Northeast Surface Water Treatment Facility
NEV Neighborhood Electrical Vehicle
NFIP National Flood Insurance Program
NFPA National Fire Protection Association
NFWRF North Fresno Wastewater Reclamation Facility
NHM Natural History Museum of Los Angeles County
NHPA National Historic Preservation Act
NHTSA National Highway Traffic Safety Administration
NIMS National Incident Management System
NO2 nitrogen dioxide
NOAA Fisheries National Marine Fisheries Service
NOC Notice of Completion
NOP Notice of Preparation
NOx nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NPPA Native Plant Protection Act
NRA Natural Resources Agency
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
NSR New Source Review
NTR National Toxics Rule
NWIC Northwest Information Center
O&M Operations and Maintenance
O3 ozone
OAL Office of Administrative Law
OEHHA California Office of Environmental Health Hazard Assessment OHWM ordinary high water mark
ONAC Federal Office of Noise Abatement and Control
OPR Governor’s Office of Planning and Research
OS Open Space
OSHA Occupational Safety and Health Administration
PCB polychlorinated biphenyl
City of Fresno—Fresno Southeast Development Area Specific Plan Project Acronyms and Abbreviations Draft Program EIR
xvi FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx PCE tetrachloroethylene
pCi/L picocuries per liter
PDWF Peak Dry Weather Flow
PEIR Program Environmental Impact Report
PFC perfluorocarbon
PG&E Pacific Gas and Electric Company
Phase I ESA Phase I Environmental Site Assessment
PM10 particulate matter, including dust, 10 micrometers or less in diameter PM2.5 particulate matter, including dust, 2.5 micrometers or less in diameter ppb parts per billion
ppm parts per million
ppt parts per trillion
PPV peak particle velocity
PRC Public Resources Code
PVC polyvinyl chloride
PWWF Peak Wet Weather Flow
RCRA Resource Conservation and Recovery Act
REC Recognized Environmental Condition
Recology Integrated Resource Recovery Company
RecycleSmart Central Contra Costa County Solid Waste Authority REL Reference Exposure Level
RHNA Regional Housing Needs Allocation
RMP Risk Management Plan
rms root mean square
ROG reactive organic gases
RPS Renewables Portfolio Standard
RTM Regional Transmission Main
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
RWRF Regional Wastewater Reclamation Facility
SARA Superfund Amendments and Reauthorization
SB Senate Bill
SCH State Clearinghouse
SCS Sustainable Communities Strategy
SEDA Southeast Development Area
SEGA Southeast Growth Area
SEMS Standardized Emergency Management System
SESWTF Southeast Surface Water Treatment Facility
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Acronyms and Abbreviations
FirstCarbon Solutions xvii https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx SF6 sulfur hexafluoride
SFHA Special Flood Hazard Area
SFPUC San Francisco Public Utilities Commission
SGMA Sustainable Groundwater Management Act
SIP State Implementation Plan
SJVAB San Joaquin Valley Air Basin
SMARA California Surface Mining and Reclamation Act
SO2 sulfur dioxide
SOI Sphere of Influence
South Coast AQMD South Coast Air Quality Management District SPCC Spill Prevention, Control, and Countermeasure
SR State Route
SRTP Short Range Transit Plan
SSJVIC Southern San Joaquin Valley Information Center
SSMP Sewer System Management Plan
SSO sanitary system overflow
State Water Board California State Water Resources Control Board SWIS Solid Waste Information System
SWPPP Storm Water Pollution Prevention Plan
SWTF Surface Water Treatment Facility
TAC toxic air contaminants
TAF Transportation Analysis Framework
TAM Transit Asset Management
T-BACT Best Available Control Technology for Toxics
TCE trichlorethylene
TCM transportation control measures
TCP trichloropropane
TDM Transportation Demand Management
TDS total dissolved solids
TDV Time Dependent Valuation
TEA-21 Transportation Equity Act for the 21st Century
Tg teragram
TGM Transmission Grid Main
therms/y therms per year
TIA Traffic Impact Analysis
TIP Transportation Improvement Program
TIS Traffic Impact Study
TMA Transportation Management Association
City of Fresno—Fresno Southeast Development Area Specific Plan Project Acronyms and Abbreviations Draft Program EIR
xviii FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-02 Acronyms.docx TMDL Total Maximum Daily Load
TOD Transit Oriented Development
TPM Transportation Performance Management
TSCA Toxic Substances Control Act
TSM Transportation Systems Management
UBC Uniform Building Code
UFC Uniform Fire Code
UNFCCC United Nations Framework Convention on Climate Change USACE United States Army Corps of Engineers
USAR Urban Search and Rescue
USBR United States Bureau of Reclamation
USC United States Code
USDA United States Department of Agriculture
USDOT United States Department of Transportation
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
UST underground storage tank
UWMP Urban Water Management Plan
UWMPA Urban Water Management Plan Act
V/C volume to capacity ratio
Valley Air District San Joaquin Valley Air Pollution Control District VCP vitrified clay pipe
VdB velocity in decibels
VDECS Verified Diesel Emission Control Strategies
VMT Vehicle Miles Traveled
VOC volatile organic compounds
WATERS Watershed Assessment, Tracking, and Environmental Results System WDR Waste Discharge Requirements
WQMP Water Quality Management Plan
WRI World Resources Institute
WSA Water Supply Assessment
WWTP Wastewater Treatment Plant
ZEV Zero-Emission Vehicle
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx

EXECUTIVE SUMMARY
Purpose
This Draft Program Environmental Impact Report (Draft PEIR) is prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental impacts associated with the implementation of the proposed Fresno Southeast Development Area (SEDA) Specific Plan Project (State Clearinghouse No. 2022020486). This document is prepared in conformance with CEQA (Public Resources Code [PRC] § 21000, et seq.) and the CEQA Guidelines (California Code of Regulations [CCR], Title 14, § 15000, et seq.).

The purpose of this Draft PEIR is to inform decision-makers, representatives of affected and responsible agencies, the public, and other interested parties of the potential environmental effects that may result from implementation of the proposed project. This Draft PEIR describes potential impacts relating to a wide variety of environmental issues and methods by which these impacts can be mitigated or avoided.

Project Summary
Project Location
The City of Fresno (City) is located in the Fresno County, California, within the San Joaquin Valley. The City is located approximately 200 miles north of Los Angeles and 170 miles south of Sacramento. The City is located on the State Route (SR) 99 corridor and bounded by Madera County to the north, the City of Clovis to the northeast, and unincorporated land and communities to the east, south, and west. The City encompasses approximately 115.18 square miles and has a population of approximately 542,000 people.

The location of the nearly 9,000-acre Plan Area is in the southeast portion of the City, in Fresno County, California as shown in Exhibit 2-1. The Plan Area is bounded on the north by the Gould Canal, on the east by McCall and Highland Avenues, on the south by Jensen and North Avenues, and on the west by Locan, Temperance, and Minnewawa Avenues.

Project Description
The proposed project is a Specific Plan for the SEDA that would provide for increased density and accelerate housing production throughout the Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels. 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 proposed project is framed with three interrelated goals: fiscal responsibility, social equity, and environmental sustainability. The proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. Additionally, the proposed project would include major transit lines, mixed-use centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Executive Summary Draft Program EIR
ES-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Project Objectives
The objectives of the proposed project are to:

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

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

Social Equity:
• Promote health by reducing harmful emissions from cars and industry. • Foster healthy physical activity and community interaction by providing easy, safe walking and bicycle access to parks, schools, and retail centers.
• Sustain the diversity of Fresno’s population by providing a wide variety of housing choices and business opportunities.
• Respect the major economic and cultural role of agriculture in the Central Valley by accommodating growth within the confines of a smaller urban footprint and directly integrating community-scale agriculture into the design of community centers, neighborhoods, and open spaces.

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx High Quality Transit Service:
• Provide convenient and frequent transit service to connect SEDA’s town centers to jobs and housing inside the Plan Area and across the region.

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

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

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

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

Community Farming and Agriculture:
• Integrate small farms, community gardens, and farmers’ markets into neighborhoods, schools, and town centers.
• Create a buffer that includes rural homes, organic farming, and open spaces to serve as a transition between the SEDA and commercial agriculture to the east.

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

Significant Unavoidable Adverse Impacts
The proposed project would result in the following significant unavoidable impacts:
• Impact AES-3 (Project-level Visual Character): The proposed project would, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site City of Fresno—Fresno Southeast Development Area Specific Plan Project Executive Summary Draft Program EIR
ES-4 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). Buildout of the SEDA Specific Plan would alter the existing visual character by increasing the intensity of development in many areas that are primarily agriculture. No feasible mitigation measures are available to mitigate the impact to a less than significant level.
• Impact AES-4 (Project-level Light and Glare): The proposed project would create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Intensified development in the Plan Area could increase the amount of light from streetlights, exterior lighting from buildings, and vehicle headlights. The increase in lighting within the Plan Area could result in light spillover onto adjacent areas and could substantially illuminate the sky during nighttime. This increase in illumination is considered a significant impact.

Implementation of Mitigation Measures (MM) AES-4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project by requiring shields, low-intensity fixtures, requirements for signs, and non-reflective materials. However, impacts would remain significant and unavoidable.
• Cumulative Aesthetics, Lights, and Glare Impacts: Implementation of the proposed project would increase intensify development of structures, which would create new sources of light and glare within the Plan Area and adjacent to the Plan Area. These new sources of glare could result from materials used on building façades, parking lots, signs, roadway surfaces, and motor vehicles. This increase in glare could result in cumulatively considerable significant glare impacts and illumination of the nighttime sky. Additionally, implementation of MM AES4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project. However, impacts would remain significant and unavoidable. • Impact AG-1 (Project-level Conversion of Farmland to Nonagricultural Uses): There are approximately 2,475 acres of land designated as Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and approximately 1,725 acres of land designated as Unique Farmland scattered throughout the Plan Area. Through its open space framework and land use objectives and policies, the Specific Plan would allow flexibility in the location, form, and function of diverse agricultural types within communities and would establish a buffer between the urban area of the City of Fresno and the surrounding agricultural land.

Consistent with Policy RC-9-c, incorporation of the General Plan MM AG-1.1, which requires future development to comply with the Farmland Preservation Program (FPP) once adopted for the SEDA would ensure that all future development would be required to mitigate the loss of farmland if Prime Farmland, Unique Farmland, or Farmland of Statewide Importance where such lands are proposed to be converted to urban uses within the Sphere of Influence (SOI) outside city limits. However, because the FPP has not yet been developed, the proposed project would implement project-specific MM AG-2, which requires all future development to mitigate the loss of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, on a project-by-project basis before the initiation of construction or ground-disturbing activities. However, while implementation of MM AG-2 would reduce some project specific impacts, loss of Prime Farmland would still occur with implementation of the proposed City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx project. Therefore, this impact would be significant and unavoidable even with implementation of available mitigation.
• Impact AG-2 (Project-level Conflict with Existing Zoning or Williamson Act Contract):

According to the General Plan, the City and its SOI includes lands under Williamson Act Contract for prime and non-prime agricultural land. According to the Williamson Act property map, the majority of Williamson Act properties within the City and SOI are located within the Plan Area. Therefore, the continued implementation of the approved General Plan and the proposed Specific Plan could conflict with existing Williamson Act Contracts because nonagricultural uses are allowed on the land under a Williamson Act Contract. As a result, the continued implementation of the General Plan and proposed Specific Plan could result in a significant impact on existing Williamson Act Contract land. While the policies included in the Specific Plan would directly limit farmland conversion and thereby help to preserve agriculture in the Plan Area and implementation of the FPP when established through General Plan MM AG-1.1 as a condition of approval, buildout of the proposed project would still result in the conversion of Williamson Act land to nonagricultural uses. Therefore, this impact would be significant and unavoidable without any available mitigation. • Cumulative Agricultural Resources and Forestry Resources Impacts: Although the proposed project would promote small farms, community gardens, and farmer’s markets, future development in areas outside of the Plan Area, in combination of the loss of prime farmland within the Plan Area, would result in the conversion of farmland to non-agriculture uses.

Therefore, the implementation of the proposed project would result in a significant and unavoidable impact on agricultural zoning and Williamson Act Contracts. The proposed project includes land use changes that would result in the conversion of farmland to nonagriculture uses, and no feasible mitigation measures are available. Therefore, this impact would be significant and unavoidable.
• Impact AIR-1 (Project-level Consistency with Air Quality Management Plan): The proposed project has the potential to exceed the San Joaquin Valley Air Pollution Control District (Valley Air District) significance thresholds during construction and operation. Implementation of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the Valley Air District regional significance thresholds and would therefore not be considered consistent with the existing Air Quality Plans (AQPs). No further measures are available beyond the applicable Valley Air District rules and regulations in addition to the proposed project’s policies and design guidelines. The various goals and policies of the proposed project would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, it would, it would have a significant and unavoidable impact.
• Impact AIR-2 (Project-level Cumulative Criteria Pollutant Emissions): While adherence to Rule 9510 would contribute to reducing exhaust nitrogen oxide (NOx) emissions, it would not be applicable to reducing volatile organic compound (VOC) emissions generated by operation of equipment and from off-gassing from asphalt and paints. Additionally, there is potential for multiple projects to be constructed at one time in the Plan Area, resulting in the generation of City of Fresno—Fresno Southeast Development Area Specific Plan Project Executive Summary Draft Program EIR
ES-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx cumulatively significant amounts of NOx emissions. Regional emissions generated by the proposed project would exceed applicable thresholds for cumulative criteria pollutant emissions after compliance with all rules, regulations, and mitigation measures during operation. While compliance with the Valley Air District rules and the policies of the proposed Specific Plan may contribute to reducing operation-related regional air quality impacts of individual projects envisioned under the proposed Specific Plan to less than significant levels, the projected cumulative emissions associated with future development projects would be in exceedance of the Valley Air District thresholds. Therefore, implementation of the proposed project would result in a significant impact because it would significantly contribute to the nonattainment designations of the San Joaquin Valley Air Basin (SJVAB). This impact would be significant and unavoidable.
• AIR-3 (Project-level Sensitive Receptors Exposure to Pollutant Concentrations): Compliance with existing regulatory programs, General Plan policies and mitigation measures, and MM AIR-1a through MM AIR-1f will serve to reduce the impacts of the proposed project to the extent feasible. However, the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Further, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds. Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants, and thus a significant and unavoidable impact may result.
• Cumulative Air Quality Impacts: While implementation of MM AIR-1a though MM AIR-1f, as well as General Plan PEIR Mitigation Measures, would serve to reduce criteria air pollutant and toxic air contaminants (TAC) emissions generated by the proposed project, there is currently not enough information to quantify emissions of specific project development that may occur under the proposed project. Without quantification to guarantee a less than significant finding, future development projects may still exceed the Valley Air District regional significance thresholds. Additionally, due to the size of the proposed project, there is not sufficient mitigation available to reduce the potential criteria pollutant emissions associated with the proposed project to levels that would not exceed the Valley Air District thresholds of significance. Therefore, cumulative impacts to air quality would be considered to remain significant and unavoidable.
• Impact GHG-1 (Project-level Greenhouse Gas Emissions): Implementation of the proposed project would contribute to global climate change through direct emissions of greenhouse gases (GHG) from on-site area sources and vehicle trips generated by the proposed project, and indirectly through off-site energy production required for on-site activities, water use, and City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx waste disposal. The operation of the proposed project would generate an increase in population and employment, and would contribute to an increase in wastewater generation, water demand, and vehicle trips. New buildings would be more energy efficient, but there would be an overall increase in energy usage due to the magnitude of new building space that would be constructed. Per the GHG Plan Update guidance, the environmental impact of the proposed project related to GHG emissions is significant, because the Plan Area is currently outside of the City boundaries, and the emissions included in the planning area were not included or considered by the City in the preparation of the GHG Plan Update, which demonstrates that the city would be in compliance with State mandated GHG emission reduction goals. As a result, the proposed project is not consistent with the GHG Plan Update, and the proposed project’s contribution to environmental impacts related to GHG emissions are significant.  The guiding principles, design guidelines, and proposed land use designations for the Plan Area would contribute to minimizing emissions to the extent feasible, however there is no mitigation feasible to reduce the GHG emissions of the proposed project to less than significant levels. The GHG impacts of the proposed project are significant and unavoidable
• Cumulative Greenhouse Gas Emissions Impacts: The proposed project would result in an expansion of the City of Fresno boundaries and would contribute to population growth in the region that was not included in the GHG Plan Update emissions projections, which demonstrate conformity with State GHG reduction goals. The proposed project would generate a significant net increase in GHG emissions and would have a “significant” GHG impact per the City of Fresno GHG Reduction Plan Update. As the proposed project would have a significant impact per the guidance included in the GHG Plan Update, the project has a potentially significant level of cumulative significance. There are no feasible mitigation measures available. As such, cumulative impacts with regard to GHG emissions are significant and unavoidable.
• Impact NOI-1 (Project-level Construction Noise): Short-term construction noise impacts associated with the project are an increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site and noise generated during site–preparation, grading, and construction activities. With implementation of MM NOI–1a and MM NOI–1b, construction noise impacts due to construction activities would be reduced to the extent feasible. However, given that details of individual development projects in the vicinity of the Plan Area are currently unknown, it is not possible to quantify the construction noise impacts at specific off-site or on-site sensitive receptors.

Because these construction activities may occur near noise-sensitive receptors and because noise disturbances may occur for prolonged periods of time, construction noise impacts would remain significant and unavoidable.
• Cumulative Construction Noise: Given that details of individual development projects adjacent to the Plan Area are currently unknown, it is not possible to quantify future cumulative construction noise impacts that could occur if multiple developments were to construct simultaneously, which could constitute a cumulative noise impact. Because construction activities associated with implementation of the Specific Plan could then also occur simultaneously and because noise disturbances could occur for prolonged periods of City of Fresno—Fresno Southeast Development Area Specific Plan Project Executive Summary Draft Program EIR
ES-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx time, there is the possibility for a cumulative construction noise impacts that would remain significant and unavoidable.

Areas of Controversy
Pursuant to CEQA Guidelines Section 15123(b), a summary section must address areas of controversy known to the Lead Agency, including issues raised by agencies and the public, and it must also address issues to be resolved, including the choice among alternatives and whether or how to mitigate the significant effects.

A Notice of Preparation (NOP) for the proposed project was issued on February 22, 2022. The NOP describing the original concept for the proposed project and issues to be addressed in the Draft PEIR was distributed to the State Clearinghouse, responsible agencies, and other interested parties for a 30-day public review period extending from February 22, 2022 through March 25, 2022. The NOP identified the potential for significant impacts on the environment related to the following topical areas:
• Aesthetics, Light, and Glare
• Agricultural Resources and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources and Tribal Cultural Resources
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Energy • Recreation
• Geology, Soils, and Seismicity • Transportation and Traffic • Greenhouse Gas Emissions • Utilities and Service Systems • Hazards and Hazardous Materials • Wildfire
• Hydrology and Water Quality • Mandatory Findings of Significance Disagreement Among Experts
This Draft PEIR contains substantial evidence to support all the conclusions presented herein. It is possible that there will be disagreement among various parties regarding these conclusions, although the City of Fresno is not aware of any disputed conclusions at the time of this writing. Both the CEQA Guidelines and case law clearly provide the standards for treating disagreement among experts. Where evidence and opinions conflict on an issue concerning the environment, and the Lead Agency knows of these controversies in advance, the EIR must acknowledge the controversies, summarize the conflicting opinions of the experts, and include sufficient information to allow the public and decision-makers to make an informed judgment about the environmental consequences of the proposed project.

Potentially Controversial Issues
Below is a list of potentially controversial issues that may be raised during the public review and hearing process of this Draft PEIR:

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx • Section 3.2, Agricultural Resources and Forestry
Resources
• Section 3.5, Cultural Resources and Tribal Cultural
Resources
• Section 3.7, Geology, Soils, and Seismicity
• Section 3.9, Hazards and Hazardous Materials
• Section 3.10, Hydrology and Water Quality
• Section 3.15, Public Services
• Section 3.17, Transportation and Traffic
• Section 3.18, Utilities and Service
Systems
It is also possible that evidence will be presented during the 45-day, statutory EIR public review period that may create disagreement. Decision-makers would consider this evidence during the public hearing process.

In rendering a decision on a project where there is disagreement among experts, the decisionmakers are not obligated to select the most environmentally preferable viewpoint. Decision-makers are vested with the ability to choose whatever viewpoint is preferable and need not resolve a dispute among experts. In their proceedings, decision-makers must consider comments received concerning the adequacy of the Draft PEIR and address any objections raised in these comments.

However, decision-makers are not obligated to follow any directives, recommendations, or suggestions presented in comments on the Draft PEIR, and can certify the Final EIR without needing to resolve disagreements among experts.

Public Review of the Draft Program EIR
Upon completion of the Draft PEIR, the City of Fresno filed a Notice of Completion (NOC) with the Governor’s Office of Planning and Research (OPR) to begin the public review period (PRC § 21161).

Concurrent with the NOC, this Draft PEIR has been distributed to responsible and trustee agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties requesting a copy of the Draft PEIR in accordance with Public Resources Code 21092(b)(3). During the public review period, the Draft PEIR, including the technical appendices, is available for review at the City of Fresno Planning and Development Department. The address for each location is provided below:

City of Fresno
Attn: Jennifer Clark, Director
Planning and Development Department
2600 Fresno Street, Room 3065
Fresno, California 93721
Agencies, organizations, and interested parties have the opportunity to comment on the Draft PEIR during the 45-day public review period. Written comments on this Draft PEIR should be addressed to:

Jennifer Clark, Director, Planning and Development Department c/o Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
[email protected]
[email protected]
City of Fresno—Fresno Southeast Development Area Specific Plan Project Executive Summary Draft Program EIR
ES-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Submittal of electronic comments in Microsoft Word or Adobe PDF format is encouraged. Upon completion of the public review period, written responses to all significant environmental issues raised will be prepared and made available for review by the commenting agencies at least 10 days prior to the public hearing before the City of Fresno on the proposed project, at which the certification of the Final EIR will be considered. Comments received and the responses to comments will be included as part of the record for consideration by decision-makers for the proposed project.

Executive Summary Matrix
Table ES-1 below summarizes the impacts, mitigation measures, and resulting level of significance after mitigation for the relevant environmental issue areas evaluated for the proposed project. The table is intended to provide an overview; narrative discussions for the issue areas are included in the corresponding section of this Draft PEIR. Table ES-1 is included in the Draft PEIR as required by CEQA Guidelines Section 15123(b)(1).

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Table ES-1: Executive Summary Matrix
Impacts Mitigation Measures Level of Significance After Mitigation Section 3.1—Aesthetics, Light, and Glare
Impact AES-1: The proposed project would not have a
substantial adverse effect on a scenic vista.

None required. N/A
Impact AES-2: The proposed project would not
substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway.

None required. N/A
Impact AES-3: The proposed project would in nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are
experienced from publicly accessible vantage point).

None. Significant and unavoidable
impact.

Impact AES-4: The proposed project would create a new
source of substantial light or glare which would
adversely affect day or nighttime views in the area.

MM AES-1: Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residences.

Significant and unavoidable
impact.

MM AES-2: Lighting systems for public facilities such as active play areas shall provide adequate illumination for the activity; however, low-intensity light fixtures and shields shall be used to minimize spillover light onto adjacent properties.

MM AES-3: Lighting systems for nonresidential uses, not including public facilities, shall provide shields on the light fixtures and orient the lighting system away from adjacent properties. Low-intensity light fixtures shall also be used if excessive spillover light onto adjacent properties will occur.

MM AES-4: Lighting systems for freestanding signs shall not exceed 100 footlambert (ft-L) when adjacent to streets which have an average light intensity of less than 2.0 horizontal footcandles and shall not exceed 500 ftL when adjacent to streets that have an average light intensity of 2.0 horizontal foot-candles or greater.

MM AES-5: Materials used on building façades shall be non-reflective.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-12 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Cumulative Impact: The project would result in
significant and unavoidable cumulative impacts to
aesthetics, light, and glare.

Implement MM AES-1 through MM AES-5. Significant and unavoidable impact.

Section 3.2—Agriculture Resources and Forest Resources
Impact AG-1: The proposed project would convert Prime
Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland) as shown on the maps prepared
pursuant to the Farmland Mapping and Monitoring
Program of the California Resources Agency, to
nonagricultural use.

MM AG-1.1: Consistent with Policy RC-9-c of the approved General Plan, the City, in coordination with regional partners or independently, shall establish a Farmland Preservation Program by 2025. The intent of the Farmland Preservation Program would be that, when Prime Farmland, Unique Farmland, or Farmland of Statewide Importance are proposed for development and converted to urban uses within the Sphere of Influence outside city limits, this program would require that the developer of such a project mitigate the loss of farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall establish thresholds of significance and provide several mitigation options that may include, but are not limited to, the following:
• Restrictive Covenants or Deeds
• In Lieu Fees
• Mitigation Banks
• Fee Title Acquisition
• Conservation Easements
• Land Use Regulations
The Farmland Preservation Program may be modeled after some or all of the programs described by the California Council of Land Trusts. Prior to the adoption of the Farmland Preservation Program, projects shall be required to comply with CEQA to address potential environmental impacts on an individual basis.

MM AG-2: Prime Farmland, Unique Farmland, and Farmland of Statewide Importance Impact Reduction Measure. Until the City’s Farmland Preservation Program is implemented consistent with the General Plan Program Environmental Impact Report Mitigation Measure (MM) AG-1.1 and the General Plan Policy RC-9-c, all development in the Fresno Southeast Development Area Specific Plan Area which would convert land designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance Significant and unavoidable
impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation to nonagricultural uses shall be analyzed on a project-by-project basis, consistent with the requirements of the California Environmental Quality Act (CEQA) at the time the project application is submitted. Where a specific development project site would include the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses, the project applicant shall identify feasible mitigation prior to project approval and implement such mitigation prior to any construction or ground-disturbing activities. Such mitigation may include but is not limited to siting project to avoid farmland; payment of in lieu fees; or, the acquisition and/or conservation of equivalent Prime Farmland, Unique Farmland, or Farmland at Statewide Importance at another location, where it is financially feasible to do so, in the form of agricultural conservation easements, or other feasible mitigation.

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

None. Significant and unavoidable
impact.

Impact AG-3: The proposed project would not conflict
with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as
defined by Government Code Section 51104(g)).

None required. No impact.

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

None required. No impact.

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

Implement MM AG-1.1 and MM AG-2. No impact.

Cumulative Impact: The project would result in
significant and unavoidable cumulative impacts to
agricultural and forestry resources.

Implement MM AG-1.1 and MM AG-2. Significant and unavoidable impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-14 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.3—Air Quality
Impact AIR-1: The proposed project would conflict with
or obstruct implementation of the applicable air quality plan.

MM AIR-1a: As part of a standard grading permit submittal, the project applicant shall submit documentation to the City of Fresno that demonstrates that all off-road construction equipment in excess of 50 horsepower is equipped with engines meeting the United States Environmental Protection Agency (EPA) Tier IV Final off-road engine emission standards or cleaner. The construction contractor shall maintain records concerning its efforts to comply with this requirement during construction, including equipment lists. Off-road equipment descriptions and information may include but are not limited to equipment type, equipment manufacturer, equipment identification number, engine model year, engine certification (tier rating), horsepower, and engine serial number. The project applicant and/or construction contractor shall submit the construction operations plan and records of compliance to the City of Fresno.

If engines that comply with Tier IV Final off-road emission standards are not commercially available, then the construction contractor shall use the next cleanest piece of off-road equipment (e.g., Tier IV Interim) available. For purposes of this mitigation measure, “commercially available” shall mean the availability of Tier IV Final engines taking into consideration factors such as (i) critical-path timing of construction; and (ii) geographic proximity to the project site of equipment. The contractor can maintain records for equipment that is not commercially available by providing letters from at least two rental companies for each piece of off-road equipment where the Tier IV Final engine is not available.

Significant and unavoidable
impact.

MM AIR-1b: Prior to the issuance of grading or building permits for each individual development proposal within the project site, the relevant applicant for each development shall provide the City with documentation demonstrating the use of “Super-Compliant” architectural coatings during construction of the proposed project. “Super-Compliant” architectural coatings, as defined by the South Coast AQMD, are paints which do not exceed 10 grams of reactive organic gas (ROG) per liter of paint.

All architectural coatings shall be applied either by (1) using a high-volume, low-pressure spray method operated at an air pressure between 0.1 and 10 City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation pounds per square inch gauge to achieve a 65 percent application efficiency; or (2) manual application using a paintbrush, hand-roller, trowel, spatula, dauber, rag, or sponge, to achieve a 100 percent application efficiency. The construction contractor shall also use precoated/natural colored building materials, where feasible.

MM AIR-1c: All nonresidential buildings shall be designed to provide infrastructure to support use of electric-powered forklifts and/or other interior vehicles.

All nonresidential buildings shall be designed to provide electric infrastructure to support use of exterior yard trucks and on-site vehicles.

The operation of yard trucks that are used to move trailers and on-site vehicles within the project site shall be powered by electricity unless the project applicant can reasonably demonstrate that specific equipment is not available for a task. Compliance with this mitigation measure shall be verified by the City of Fresno prior to the issuance of a building permit.

MM AIR-1d: Each implementing development project shall be required to implement, at a minimum, an increase in each building’s energy efficiency 15 percent beyond Title 24, and reduce indoor water use by 25 percent. All requirements will be documented through a checklist to be submitted to the City of Fresno prior to issuance of building permits for the implementing development project with building plans and calculations.

MM AIR-1e: Prior to issuance of building permits for non-single-family residential and mixed-use residential development projects in the Plan Area, the project applicant shall indicate on the building plans that the following features have been incorporated into the design of the building(s).

Proper installation of these features shall be verified by the City of Fresno prior to the issuance of a Certificate of Occupancy.
• 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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-16 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation MM AIR-1f: Prior to the issuance of building permits for nonresidential development projects in the Plan Area, project applicants shall indicate on the building plans that the following features have been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City of Fresno prior to the issuance of a Certificate of Occupancy.
• 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.
• 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 electric vehicle (EV) charging at each nonresidential building with 30 or more parking spaces.

Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code.

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

Implement MM AIR-1a through MM AIR-1f. Significant and unavoidable impact.

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

None. Significant and unavoidable
impact.

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

None. N/A
Cumulative Impact: The project would have significant
and unavoidable cumulative impacts to air quality.

Implement MM AIR-1a through MM AIR-1f. Significant and unavoidable impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.4—Biological Resources
Impact BIO-1: The proposed project would have a
substantial adverse effect, either directly or through
habitat modifications, on any species identified as a
candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or United
States Fish and Wildlife Service.

None. N/A
Impact BIO-2: The proposed project would have a
substantial adverse effect on any riparian habitat or
other sensitive natural community identified in local or regional plans, policies, and regulations, or by the
California Department of Fish and Wildlife or United
States Fish and Wildlife Service.

None. N/A
Impact BIO-3: The proposed project would have a
substantial adverse effect on State or federally
protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

None. N/A
Impact BIO-4: The proposed project would interfere
substantially with the movement of any native resident
or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of wildlife nursery sites.

None. N/A
Impact BIO-5: The proposed project would conflict with
any local policies or ordinances protecting biological
resources, such as a tree preservation policy or
ordinance.

None. N/A
Impact BIO-6: The proposed project would not conflict
with the provisions of an adopted Habitat Conservation
Plan, Natural Community Conservation Plan, or other
approved local, regional, or State habitat conservation plan.

None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-18 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Cumulative Impact: The project would have a less than
cumulative impact on biological resources.

None. N/A
Section 3.5—Cultural Resources and Tribal Cultural Resources Impact CUL-1: The proposed project would not cause a
substantial adverse change in the significance of a
historical resource pursuant to Section 15064.5.

None. N/A
Impact CUL-2: The proposed project would not cause a
substantial adverse change in the significance of an
archaeological resource pursuant to Section 15064.5.

None. N/A
Impact CUL-3: The proposed project would not disturb
human remains, including those interred outside of
formal cemeteries.

None. N/A
Impact CUL-4: The proposed project would not cause a
substantial adverse change in the significance of a Tribal Cultural Resource, defined in Public Resources Code
Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

None. N/A
Impact CUL-5: The proposed project would not cause a
substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code
Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

Cumulative Impact: The project would have a less than
significant cumulative impact on cultural and tribal
cultural resources.

None. N/A
Section 3.6—Energy
Impact ENER-1: The proposed project would not result
in potentially significant environmental impact due to
wasteful, inefficient, or unnecessary consumption of
energy resources, during project construction or
operation.

None. N/A
Impact ENER-2: The proposed project would not conflict
with or obstruct a State or local plan for renewable
energy or energy efficiency.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on energy.

None. N/A
Section 3.7—Geology and Soils
Impact GEO-1: The proposed project would not directly
or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving:
i) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault? Refer to Division of Mines and
Geology Special Publication 42.
ii) Strong seismic ground shaking.
iii) Seismic-related ground failure, including
liquefaction.
iv) Landslides.

None. N/A
Impact GEO-2: The proposed project would not result in
substantial soil erosion or the loss of topsoil.

None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-20 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Impact GEO-3: The proposed project would not be
located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.

None. N/A
Impact GEO-4: The proposed project would not be
located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial
direct or indirect risks to life or property.

None required. N/A
Impact GEO-5: The proposed project would not have
soils incapable of adequately supporting the use of
septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater.

None. N/A
Impact GEO-6: The proposed project would not directly
or indirectly destroy a unique paleontological resource or site or unique geologic feature.

MM GEO-6.1: Subsequent to a preliminary City review of the project grading plans, if there is evidence that a project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for unique paleontological/geological resources shall be conducted. The following procedures shall be followed:
• If unique paleontological/geological resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that unique
paleontological/geological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified Paleontologist shall be consulted to determine whether the resource requires further study. The qualified Paleontologist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to, excavation of the finds and evaluation of the finds. If the resources are determined to be significant, mitigation measures shall be identified by the monitor and recommended to the Lead Agency.

Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading Less than significant impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any paleontological/geological resources recovered as a result of mitigation shall be provided to a Cityapproved institution or person who is capable of providing long-term preservation to allow future scientific study.
• If unique paleontological/geological resources are found during the field survey or literature review, the resources shall be inventoried and evaluated for significance. If the resources are found to be significant, mitigation measures shall be identified by the qualified Paleontologist.

Similar to above, appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include a paleontological monitor. The monitoring period shall be determined by the qualified Paleontologist. If additional paleontological/geological resources are found during excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed.

MM GEO-1: Applicants, owners and/or sponsors of all future development or construction projects shall be required to perform or provide paleontological monitoring during ground-disturbing activities. Should significant paleontological resources (e.g., bones, teeth, well-preserved plant elements) be unearthed by the future project construction crew, the project activities shall be diverted at least 15 feet from the discovered paleontological resources until a professional Paleontologist has assessed such discovered resources and, if deemed significant, such resources shall be salvaged in a timely manner. The applicant/owner/sponsor of said project shall be responsible for diverting project work and providing the assessment including retaining a professional Paleontologist for such purpose. Collected fossils shall be deposited by the
applicant/owner/sponsor in an appropriate repository (e.g., University of California Museum of Paleontology (UCMP), California Academy of Sciences) where the collection shall be properly curated and made available for future research.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-22 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Cumulative Impact: The project would have a less than
significant cumulative impact with mitigation
incorporated on geology and soils.

None. Less than significant impact with
mitigation incorporated.

Section 3.8—Greenhouse Gas Emissions
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.

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.

No feasible mitigation available. Significant and unavoidable impact.

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

None available. Significant and unavoidable
impact.

Section 3.9—Hazards and Hazardous Materials
Impact HAZ-1: The proposed project would not create a
significant hazard to the public or the environment
through the routine transport, use, or disposal of
hazardous materials.

None required. N/A
Impact HAZ-2: The proposed project would not create a
significant hazard to the public or the environment
through reasonably foreseeable upset and accident
conditions involving the likely release of hazardous
materials into the environment.

MM HAZ-2a: Prior to the issuance of a grading permit, the property owners and/or developers of properties shall ensure that a Phase I Environmental Site Assessment (Phase I ESA) (performed in accordance with the current Airborne Toxic Control Measures [ATCM] Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process [E 1527]) shall be conducted for each individual property prior to development or redevelopment to ascertain the presence or absence of Recognized Environmental Conditions (RECs), Historical Recognized Environmental Conditions (HRECs), and Potential Environmental Concerns (PECs) relevant to the property under consideration. The findings and conclusions of the Phase I ESA shall become the basis for potential recommendations for follow-up investigation, if found to be warranted.

Less than significant impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation MM HAZ-2b: In the event that the findings and conclusions of the Phase I Environmental Site Assessment (Phase I ESA) for a property result in evidence of Recognized Environmental Conditions (RECs), Historical Recognized Environmental Conditions (HRECs) and/or Potential Environmental Concerns (PECs) warranting further investigation, the property owners and/or developers of properties shall ensure that a Phase II ESA shall be conducted to determine the presence or absence of a significant impact to the subject site from hazardous materials. The Phase II ESA may include but may not be limited to the following: (1) Collection and laboratory analysis of soils and/or groundwater samples to ascertain the presence or absence of significant concentrations of constituents of concern; (2) Collection and laboratory analysis of soil vapors and/or indoor air to ascertain the presence or absence of significant concentrations of volatile constituents of concern; and/or (3) Geophysical surveys to ascertain the presence or absence of subsurface features of concern such as underground storage tanks (USTs), drywells, drains, plumbing, and septic systems. The findings and conclusions of the Phase II ESA shall become the basis for potential recommendations for follow-up investigation, site characterization, and/or remedial activities, if found to be warranted.

MM HAZ-2c: In the event the findings and conclusions of the Phase II Environmental Site Assessment (Phase II ESA) reveal the presence of significant concentrations of hazardous materials warranting further investigation, the property owners and/or developers of properties shall ensure that site characterization shall be conducted in the form of additional Phase II ESAs in order to characterize the source and maximum extent of impacts from constituents of concern. The findings and conclusions of the site characterization shall become the basis for formation of a remedial action plan and/or risk assessment.

MM HAZ-2d: If the findings and conclusions of the Phase II Environmental Site Assessment (Phase II ESA), site characterization and/or risk assessment demonstrate the presence of concentrations of hazardous materials exceeding regulatory threshold levels, prior to the issuance of a grading permit, property owners and/or developers of properties shall complete site remediation and potential risk assessment with oversight from the applicable regulatory agency including, but not limited to, the California City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-24 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Environmental Protection Agency (Cal/EPA) Department of Toxic Substances Control (DTSC) or Regional Water Quality Control Board (RWQCB), and Fresno County Environmental Health Division (FCEHD).

Potential remediation could include the removal or treatment of water and/or soil. If removal occurs, hazardous materials shall be transported and disposed at a hazardous materials permitted facility.

MM HAZ-2e: Prior to the issuance of a building permit for an individual property within the Plan Area with residual environmental contamination, the agency with primary regulatory oversight of environmental conditions at such property ("Oversight Agency") shall have determined that the proposed land use for that property, including proposed development features and design, does not present an unacceptable risk to human health, if applicable, through the use of an Environmental Site Management Plan (ESMP) that could include institutional controls, site-specific mitigation measures, a risk management plan, and deed restrictions based upon applicable risk-based cleanup standards. Remedial action plans, risk management plans and health and safety plans shall be required as determined by the Oversight Agency for a given property under applicable environmental laws, if not already completed, to prevent an unacceptable risk to human health, including workers during and after construction, from exposure to residual contamination in soil and groundwater in connection with remediation and site development activities and the proposed land use.

MM HAZ-2f: For those sites with potential residual volatile organic compounds (VOCs) in soil, soil gas, or groundwater that are planned for redevelopment with an overlying occupied building, a vapor intrusion assessment shall be performed by a licensed environmental professional. If the results of the vapor intrusion assessment indicate the potential for significant vapor intrusion into the proposed building, the project design shall include vapor controls or source removal, as appropriate, in accordance with Regional Water Quality Control Board (RWQCB), the Department of Toxic Substances Control (DTSC) or the Fresno County Environmental Health Division (FCEHD) requirements. Soil vapor mitigations or controls could include passive venting and/or active venting. The vapor intrusion assessment as associated vapor controls or source removal can be City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-25 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation incorporated into the Environmental Site Management Plan (ESMP) (Mitigation Measure HAZ4-4e).

MM HAZ-2g: In the event of planned renovation or demolition of residential and/or commercial structures on the subject site, prior to the issuance of demolition permits, asbestos and lead-based paint (LBP) surveys shall be conducted in order to determine the presence or absence of asbestoscontaining materials (ACM) and/or LBP. Removal of friable ACM, and nonfriable ACMs that have the potential to become friable, during demolition and/or renovation shall conform to the standards set forth by the National Emissions Standards for Hazardous Air Pollutants (NESHAPs).

The San Joaquin Valley Air Pollution Control District (Valley Air District) is the responsible agency on the local level to enforce the NESHAPs and shall be notified by the property owners and/or developers of properties (or their designee(s)) prior to any demolition and/or renovation activities. If asbestos-containing materials are left in place, an Operations and Maintenance Program (O&M Program) shall be developed for the management of asbestos-containing materials (ACM).

MM HAZ-2h: Prior to the import of a soil to a particular property within the Plan Area as part of that property’s site development, such soils shall be sampled for toxic or hazardous materials to determine whether concentrations exceed applicable Environmental Screening Levels for the proposed land use at such a property, in accordance with Regional Water Quality Control Board (RWQCB), the Department of Toxic Substances Control (DTSC) or the Fresno County Environmental Health Division (FCEHD)requirements, prior to importing to such a property.

Impact HAZ-3: The proposed project could emit
hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within onequarter mile of an existing or proposed school.

Implement MM HAZ-2a through MM HAZ-2h. Less than significant impact.

Impact HAZ-4: The proposed project could be located on
a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section
Implement MM HAZ-2a through MM HAZ-2h. Less than significant impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-26 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation 65962.5 and, as a result, could create a significant
hazard to the public or the environment.

Impact HAZ-5: For a project located within an airport
land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, the proposed project would not result in a safety hazard or excessive noise for people residing or working the project area.

None required. N/A
Impact HAZ-6: The proposed project would not impair
implementation of or physically interfere with an
adopted emergency response plan or emergency
evacuation plan.

None required. N/A
Impact HAZ-7: The proposed project would not expose
people or structures, either directly or indirectly to a significant risk of loss, injury or death involving wildland fires.

None required. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on hazards and hazardous
materials.

None required. N/A
Section 3.10—Hydrology and Water Quality
Impact HYD-1: The proposed project could violate any
water quality standards or waste discharge
requirements or otherwise substantially degrade surface or ground water quality.

None. N/A
Impact HYD-2: The proposed project could substantially
decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may
impede sustainable groundwater management of the
basin.

MM HYD-2a: The City shall continue to be an active participant in the North Kings Groundwater Sustainability Agency (North Kings GSA) and the implementation of the North Kings Groundwater Sustainability Plan (North Kings GSP) in order to ensure that the Kings Subbasin has balanced levels of pumping and recharge. The City shall confirm that each project for future development in the Plan Area has incorporated any resulting standards prior to issuing approval for any development applications that require discretionary approval.

Less than significant with
mitigation incorporated.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-27 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation MM HYD-2b: Prior to exceeding existing water supply capacity, the City shall evaluate the water supply system and shall not approve development per the Specific Plan for the Plan Area until additional capacity is provided through water system improvements for the Specific Plan Area in accordance with the City Metropolitan Water Resources Management Plan (Metro Plan).

MM HYD-2c: Prior to exceeding existing water demands, the City shall pursue the provision of adequate water supplies by securing additional water sources and shall not approve development per the Specific Plan for the Plan Area until additional water supply is provided.

MM HYD-2d: The City shall develop new and expand existing groundwater recharge facilities to balance increased water demands resulting from the Project Area. New and expanded groundwater recharge facilities shall be in accordance with the City of Fresno General Plan and City Metro Plan,. The City shall complete these measures prior to approving any new project applications for future development in the Project Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

Impact HYD-3: The proposed project could substantially
alter the existing drainage pattern of the site or area, including through the alteration of the course of a
stream or river or through the addition of impervious
surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or offsite; ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding
on- or off-site;
iii) Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide substantial
additional sources of polluted runoff; or
iv) Impede or redirect flood flows?
MM HYD-3a: The City shall support the Fresno Metropolitan Flood Control District (FMFCD) in updating the Storm Drainage and Flood Control Master Plan for the Plan Area to include the proposed basins and the analysis necessary to provide adequate capacity for future stormwater runoff resulting from future development of the Southeast Development Area (SEDA) Specific Plan. The City shall complete these measures prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

Less than significant with
mitigation incorporated.

MM HYD-3b: The City shall support the Fresno Metropolitan Flood Control District (FMFCD) in implementing the Storm Drainage and Flood Control Master Plan improvements for the proposed drainage areas within the Plan Area. Any new proposed development in the Southeast Development Area (SEDA) shall be reviewed by the City and FMFCD to confirm that design and construction documents have incorporated the updated Storm Drainage City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-28 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation and Flood Control Master Plan improvements, prior to approving any such development.

MM HYD-3c: The City shall support the Fresno Metropolitan Flood Control District (FMFCD) in reevaluating proposed Basins DW and DX for available capacities, and shall expand these basins or construct additional basins to accommodate the future stormwater capacities from development in the Southeast Development Area (SEDA) in accordance with the SEDA Specific Plan. The City shall complete these measures prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

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

None. N/A
Impact HYD-5: The proposed project would not conflict
with or obstruct implementation of a water quality
control plan or sustainable groundwater management
plan.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact with mitigation
incorporated on hydrology and water quality.

Implement MM HYD-2a, MM HYD-2b, MM HYD-2c, MM HYD-2d, MM HYD3a, MM HYD-3b, and MM HYD-3c.Less than significant with mitigation incorporated.

Section 3.11—Land Use and Planning
Impact LAND-1: The proposed project would not
physically divide an established community.

None. N/A
Impact LAND-2: The proposed project would not cause a
significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on land use and planning.

None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-29 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.12—Mineral Resources
Impact MIN-1: The proposed project would not result in
the loss of availability of a known mineral resource that would be of value to the region and the residents of the State.

None. N/A
Impact MIN-2: The proposed project would not result in
the loss of availability of a locally important mineral resource recovery site delineated on a local general
plan, specific plan, or other land use plan.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on mineral resources.

None. N/A
Section 3.13—Noise
Impact NOI-1: The proposed project could generate a
substantial temporary or permanent increase in ambient
noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

MM NOI-1a: Construction Activity Hours Restriction
Construction activity which requires a permit issued by the City of Fresno shall be limited to the hours between 7:00 a.m. and 10:00 p.m. on weekdays and Saturdays. Any construction activity outside of these hours must comply with the City’s noise performance standards of Section

15.2506 of the Municipal Code.

Significant and unavoidable
impact.

MM NOI–1b: Construction Noise Mitigation Plan
Prior to the issuance of demolition, grading, and/or construction permits, applicants for individual development projects within 500 feet of noise– sensitive receptors (e.g., residences, hospitals, schools) shall conduct a project–level construction noise analysis to evaluate potential impacts on sensitive receptors. The analysis shall be conducted once the final construction equipment list that will be used for demolition and grading activities is determined. The project–level noise analysis shall be prepared, reviewed, and approved by the City of Fresno Planning Director. If the analysis determines that demolition and construction activities would result in an impact to identified noise-sensitive receptors, then specific measures to attenuate the noise impact shall be outlined in the analysis and reviewed and approved by the City of Fresno Planning Director. Specific measures may include but are not limited to the following Best Management Practices (BMPs):

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-30 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation • Post a construction site notice near the construction site access point or in an area that is clearly visible to the public. The notice shall include the following: job site address; permit number, name, and phone number of the contractor and owner; dates and duration of construction activities; construction hours allowed; and the City of Fresno Planning Director and construction contractor phone numbers where noise complaints can be reported and logged.
• Consider the installation of temporary sound barriers for construction activities immediately adjacent to occupied noise-sensitive structures. • Restrict haul routes and construction–related traffic to the least noisesensitive times of the day. • Reduce non-essential idling of construction equipment to no more than 5 minutes.
• Ensure that all construction equipment is monitored and properly maintained in accordance with the manufacturer’s recommendations to minimize noise.
• Fit all construction equipment with properly-operating mufflers, air intake silencers, and engine shrouds, no less effective than as originally equipped by the manufacturer, to minimize noise emissions. • If construction equipment is equipped with back-up alarm shut offs, switch off back-up alarms and replace with human spotters, as feasible. • Stationary equipment (such as generators and air compressors) and equipment maintenance and staging areas shall be located as far from existing noise-sensitive land uses, as feasible.
• To the extent feasible, use acoustic enclosures, shields, or shrouds for stationary equipment such as compressors and pumps.
• Shut off generators when generators are not needed.
• Coordinate deliveries to reduce the potential of trucks waiting to unload and idling for long periods of time.
• Grade surface irregularities on construction sites to prevent potholes from causing vehicular noise.
• Minimize the use of impact devices such as jackhammers, pavement breakers, and hoe rams. Where possible, use concrete crushers or pavement saws rather than hoe rams for tasks such as concrete or asphalt demolition and removal.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-31 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation • The final noise-reduction measures to be implemented and their associated details shall be determined by the construction-level noise analysis. The final noise-reduction measures shall be included on all construction and building documents and/or construction management plans and submitted for verification to the City; implemented by the construction contractor through the duration of the construction phase; and discussed at the pre-demolition, -grade, and/or -construction meetings.

MM NOI–2: Traffic Noise Reduction Plan
Prior to issuance of building permits, the property owner/developer shall be responsible to implement the following measures to limit potential traffic noise source impacts:
• Any proposed development project that would include noise sensitive land use development along noise impacted roadway segments identified in Table 3.13-8 shall demonstrate compliance with Municipal Code Section 15-2506 by submitting a final acoustical report. This report shall demonstrate that the proposed project incorporates sufficient noise attenuation features, if needed, to meet the City’s exterior/interior noise performance standards. The individual project owner/developer shall submit the acoustic study to the Planning Director for review and approval. Upon approval by the City of Fresno, the proposed acoustical design features shall be incorporated into the proposed development.

Noise reduction design features may include, but are not limited to, locating noise sensitive development on the site to be shielded by structures (buildings, enclosures, or sound walls) or by using upgraded wall and window assemblies to ensure that acceptable interior noise levels are maintained.

MM NOI–3: Stationary Source Noise Reduction Plan
Prior to issuance of building permits, the property owner/developer shall be responsible to implement the following measures to limit operational stationary noise source impacts:
• Any proposed development projects that include unshielded parking areas within 175 feet, or unshielded truck loading docks within 300 feet, or unshielded mechanical ventilation equipment systems within 35 feet of a noise sensitive receptor, shall demonstrate compliance with Municipal City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-32 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Code Section 15-2506 by submitting a site specific acoustic study. These reports shall demonstrate that the proposed project incorporates sufficient noise attenuation features, if needed, to meet the City of Fresno’s exterior/interior noise performance standards. The individual project owner/developer shall submit the acoustic study to the Planning Director for review and approval. Upon approval by the City, the proposed acoustical design features shall be incorporated into the proposed development. Noise reduction design features may include, but are not limited to, locating stationary noise sources on the site to be shielded by structures (buildings, enclosures, or sound walls) or by using equipment that has a quieter rating.

Impact NOI-2: The proposed project could result in
generation of excessive groundborne vibration or
groundborne noise levels.

MM NOI-4: Construction Vibration Reduction Plan
Prior to issuance of grading and/or building permits, a note shall be provided on grading and building plans indicating that during grading and construction the property owner/developer shall be responsible for requiring contractors to implement the following measures to limit construction-related vibration impacts:
• For any future development projects that would necessitate the use of pile driving within 200 feet of an off-site structure shall submit a Construction Vibration Reduction Plan that identifies specific techniques, such as the depth and location of temporary trenching, that would reduce potential vibration impacts to less than significant for the impacted structure.
• For any future development projects that would necessitate the use of large vibratory rollers within 30 feet of an off-site structure, or the use of other heavy construction equipment within 15 feet of an off-site structure, shall submit a Construction Vibration Reduction Plan that identifies specific techniques, such as the depth and location of temporary trenching, that would reduce potential vibration impacts to less than significant for the impacted structure.
• The individual project owner/developer shall submit the Construction Vibration Reduction Plan to the Planning Director for review and approval prior to issuance of building permits. Upon approval by the City, the construction vibration reduction measures shall be incorporated into the construction documents.

Less than significant impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-33 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Impact NOI-3: The proposed project would not expose
people residing or working in the project area to
excessive noise levels for a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport.

None. N/A
Cumulative Impact: The project would have a significant and unavoidable impact regarding construction noise.

The project would have a less than significant impact
with regard to all other noise and vibration impacts.

No mitigation is available that would reduce cumulative construction noise impacts to less than significant.

Significant and unavoidable
impact.

Section 3.14—Population and Housing
Impact POP-1: The proposed project would not induce
substantial unplanned population growth in an area,
either directly (for example, by proposing new homes
and businesses) or indirectly (for example, through
extension of roads or other infrastructure).

None. N/A
Impact POP-2: The proposed project would not displace
substantial numbers of existing people or housing,
necessitating the construction of replacement housing
elsewhere.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on population and
housing.

None. N/A
Section 3.15—Public Services
Impact PUB-1: The proposed project would not result in
substantial adverse physical impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or
other performance objectives for fire protection.

None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-34 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Impact PUB-2: The proposed project would not result in
substantial adverse physical impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or
other performance objectives for police protection.

None. N/A
Impact PUB-3: The proposed project would not result in
substantial adverse physical impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or
other performance objectives for schools.

None. N/A
Impact PUB-4: The proposed project would not result in
substantial adverse physical impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or
other performance objectives for parks.

None. N/A
Impact PUB-5: The proposed project would not result in
substantial adverse physical impacts associated with the provision of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or
other performance objectives for other public facilities.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on public services.

None. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-35 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.16—Recreation
Impact REC-1: The proposed project would not increase
the use of existing neighborhood and regional parks or
other recreational facilities such that substantial physical deterioration of the facility would occur or be
accelerated.

None. N/A
Impact REC-2: The proposed project could include
recreational facilities or require the construction or
expansion of recreational facilities which might have an adverse physical effect on the environment.

MM REC-1: As new development occurs in the Plan Area, the City shall periodically (every 5 years) monitor residential population growth compared to development of new parklands for the purpose of evaluating the strength of this Plan to meet the ratio of 3 acres of parkland per 1,000 population. If the ratio is not met, the City shall explore additional ways to increase the amount of dedicated parkland in the Plan Area, including but not limited to designating additional lands for parkland development.

Less than significant with
mitigation incorporated.

Cumulative Impact: The project would have a less than
significant cumulative impact with mitigation
incorporated on recreation.

Implement MM REC-1. Less than significant with
mitigation incorporated.

Section 3.17—Transportation and Traffic
Impact TRANS-1: The proposed project would not
conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway, bicycle and pedestrian facilities.

MM TRANS-1a: Provide more options for shorter trips by encouraging vertical mixed uses and locating residential uses in walking distance (0.5 mile) to retail and employment uses.

Less than significant impact with
mitigation incorporated.

MM TRANS-1b: Provide pedestrian and bicycle network improvements within the development connecting complementary uses (i.e., residential, employment, retail, and transit stops) internally and to existing off-site facilities.

MM TRANS-1c: Ensure that design of key intersections and roadways encourage the use of walking, biking, and transit.

MM TRANS-1d: Collaborate with Fresno Transit (FAX) to provide new transit services to the proposed project and within the proposed project area.

MM TRANS-1e: In addition, the following Transportation Demand Management (TDM) strategies may be applicable at the implementing project level:

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-36 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation • 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) • Pedestrian Network Improvements (maximum reduction: 2 percent) Impact TRANS-2: The proposed project would not
conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b).

None. N/A
Impact TRANS-3: The proposed project would not
substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

None. N/A
Impact TRANS-4: The proposed project would not result
in inadequate emergency access.

MM TRANS-4: At the time of planning application submittal, the project applicant shall prepare a Construction Management Plan that shall specify traffic controls required to maintain adequate circulation and access throughout the Southeast Development (SEDA) Specific Plan Area. At least one lane shall remain open in each direction during construction and access to all existing businesses shall be maintained. This plan shall be subject to approval by the jurisdictional police and fire departments prior to commencement of construction.

Less than significant impact with
mitigation incorporated.

Cumulative Impact: The project would have a less than
significant cumulative impact on transportation.

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

Less than significant impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-37 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.18—Utilities and Service Systems
Impact UTIL-1: The proposed project could require or
result in the relocation or construction of new or
expanded water, wastewater treatment or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects.

Implementation of all other mitigation measures in this Draft PEIR would be required for all construction activities. Therefore, construction of new utilities would cause less than significant impacts with mitigation incorporated, with regard to the other potential environmental impacts discussed in this Draft PEIR. See the Executive Summary for a summary of all mitigation measures. Mitigation measures for all resource topics in this Draft PEIR would be applicable to construction of new or expanded utility infrastructure.

Less than significant impact with
mitigation incorporated.

MM UTIL-1a: The City shall evaluate the water conveyance system at the time that discretionary projects are submitted for approval by the City, and the City shall not approve development that would demand additional water and exceed the capacity of a facility until additional capacity is provided. The City shall evaluate proposed water capacity and conveyance improvements provided in the City Metro Plan and General Plan for potential environmental impacts, and shall construct such improvements prior to exceedance of capacity to accommodate full buildout of the Specific Plan.

MM UTIL-1b: The City shall evaluate the water supply system at the time that discretionary projects are submitted for approval by the City, and the City shall not approve development that would demand additional water until additional sources are secured and provided for future development.

The City shall evaluate proposed water supply improvements for potential environmental impacts, and shall construct such improvements prior to exceedance of demand to accommodate full buildout of the Specific Plan.

MM UTIL-1c: The City shall evaluate the wastewater system at the time that discretionary projects are submitted for approval by the City, and the City shall not approve development that would contribute wastewater to the wastewater treatment system that would exceed capacity until additional capacity is provided. The City shall evaluate proposed wastewater treatment improvements provided in the City Wastewater Master Plan and General Plan for potential environmental impacts, and shall construct such improvements prior to exceedance of capacity to accommodate full buildout of the Specific Plan.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-38 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation MM UTIL-1d: Consistent with the Sewer System Management Plan, the City shall evaluate the wastewater collection system at the time that discretionary projects are submitted for approval by the City, the City shall not approve development that would generate additional wastewater and exceed the capacity of a facility until additional capacity is provided. The City shall evaluate proposed wastewater collection improvements provided in the City Wastewater Master Plan and General Plan for potential environmental impacts, and shall construct such improvements prior to exceedance of capacity to accommodate full buildout of the Specific Plan.

MM UTIL-1e: The City shall support the Fresno Metropolitan Flood Control District FMFCD in evaluating the storm water collection system and implementing the District Services Plan and Storm Drainage and Flood Control Master Plan, and in constructing such improvements to the storm drain system prior to exceedance of capacity to accommodate full buildout of the Specific Plan. The City shall complete these evaluations prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

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

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

Implement MM HYD-2b, MM HYD-2c, MM UTIL-1a, MM UTIL-1b, and the following:

Less than significant impact with
mitigation incorporated.

MM UTIL-2a: The City shall develop and implement water conservation measures to reduce the per capita water use, and continue to refine and implement water saving and conservation standards for new developments approved under the Specific Plan. The City shall complete these measures and standards prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated the refined measures and standards prior to issuing approval
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-39 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation MM UTIL-2b: The City shall continue to implement the City of Fresno Water Conservation Program, as may be updated, and periodically update restrictions on water uses, and evaluate the feasibility of the conservation target identified as part of the Fresno General Plan PEIR. The City shall complete these measures prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

MM UTIL-2c: The City shall refine landscape water conservation standards that will apply to new development installed landscapes, building on the State Model Water Efficient Landscape Ordinance (MWELO) and other state regulations. The City shall complete these standards prior to approving any new project applications for future development in the Plan Area that require a discretionary approval and shall confirm that each project has incorporated any resulting standards prior to issuing approval.

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

Implement MM UTIL-1c and MM UTIL-1d. Less than significant with mitigation incorporated.

Impact UTIL-4: The proposed project would not
generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals.

None required. N/A
Impact UTIL-5: The proposed project would comply with
federal, State, and local statutes and regulations related to solid waste.

None required. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact with mitigation
incorporated on utilities and service systems.

MM UTIL-4.1: The City shall evaluate additional landfill locations at the time discretionary projects are submitted, and shall not approve development that could contribute solid waste to a landfill that is at capacity until additional capacity is provided
Less than significant impact with
mitigation incorporated.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Executive Summary
FirstCarbon Solutions ES-40 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec00-03 Exec Summary.docx Impacts Mitigation Measures Level of Significance After Mitigation Section 3.19—Wildfire
Impact WILD-1: The proposed project would not
substantially impair an adopted emergency response
plan or emergency evacuation plan.

None. N/A
Impact WILD-2: The proposed project would not due to
slope, prevailing winds, and other factors, exacerbate
wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire.

None. N/A
Impact WILD-3: The proposed project would not require
the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

None. N/A
Impact WILD-4: The proposed project would not expose
people or structures to significant risks, including
downslope or downstream flooding or landslides, as a
result of runoff, post-fire slope instability, or drainage changes.

None. N/A
Cumulative Impact: The project would have a less than
significant cumulative impact on wildfires.

None required. N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx CHAPTER 1: INTRODUCTION

1.1 - Overview of the CEQA Process
This Draft Program Environmental Impact Report (Draft PEIR) is prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental impacts associated with the implementation of the proposed Fresno Southeast Development Area (SEDA) Specific Plan Project (proposed project) (State Clearinghouse No. 2022020486). This document is prepared in conformance with CEQA (California Public Resources Code [PRC], § 21000, et seq.) and the CEQA Guidelines (California Code of Regulations [CCR], Title 14, § 15000, et seq.). This Draft PEIR is intended to serve as an informational document for the public agency decision makers and the public regarding the proposed project.

1.1.1 - Overview
The proposed project is a Specific Plan for the SEDA that would provide for increased density and accelerate housing production throughout the approximately 9,000-acre Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels. It has the potential to accommodate approximately 45,000 homes and 37,000 jobs within the Plan Area by the year 2050. The proposed project is framed with three interrelated goals: fiscal responsibility, social equity, and environmental sustainability. The proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. Additionally, the proposed project would include major transit lines, mixed-use centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure. Exhibit 1-1 shows the proposed general land use designations of the Specific Plan.

1.1.2 - Purpose and Authority
This Draft PEIR provides a project-level analysis of the environmental effects of the proposed project.

The environmental impacts of the proposed project are analyzed in the Draft PEIR to the degree of specificity appropriate, in accordance with CEQA Guidelines Section 15146. This document addresses the potentially significant adverse environmental impacts that may be associated with the planning, construction, or operation of the project. It also identifies appropriate and feasible mitigation measures and alternatives that may be adopted to significantly reduce or avoid these impacts.

CEQA requires that an EIR contains, at a minimum, certain specific elements. These elements are contained in this Draft PEIR and include:
• Table of Contents
• Introduction
• Executive Summary
• Project Description
• Environmental Setting, Significant Environmental Impacts, and Mitigation Measures

THIS PAGE INTENTIONALLY LEFT BLANK
31680033 • 07/2023 | 1-1_specific_plan_map.cdr CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
Exhibit 1-1
Specific Plan Map
Source: City of Fresno, SEDA Regulating Districts, 07/2023.

I

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx • Cumulative Impacts
• Significant Unavoidable Adverse Impacts
• Alternatives to the Proposed Project
• Growth-Inducing Impacts
• Areas of Known Controversy

1.1.3 - Lead Agency Determination
The City of Fresno is designated as the lead agency for the project. CEQA Guidelines Section 15367 defines the lead agency as “. . . the public agency, which has the principal responsibility for carrying out or approving a project.” Other public agencies may use this Draft PEIR in the decision-making or permit process and consider the information in this Draft PEIR along with other information that may be presented during the CEQA process.

This Draft PEIR was prepared by FirstCarbon Solutions (FCS), an environmental consultant. Prior to public review, it was extensively reviewed and evaluated by the City of Fresno. This Draft PEIR reflects the independent judgment and analysis of the City of Fresno as required by CEQA. Lists of organizations and persons consulted and the report preparation personnel are provided in Chapter 6 of this Draft PEIR.

1.2 - Scope of the Draft Program EIR
This Draft PEIR addresses the potential environmental effects of the proposed project. The City of Fresno issued a Notice of Preparation (NOP) for the proposed project on February 22, 2022, which circulated between February 22, 2022, to March 25, 2022, for the statutory 30-day public review period. The scope of this Draft PEIR includes the potential environmental impacts identified in the NOP and issues raised by agencies and the public in response to the NOP. The NOP is contained in Appendix A of this Draft PEIR.

Fourteen comment letters were received in response to the NOP. They are listed in Table 1-1 and provided in Appendix A of this Draft PEIR.

Table 1-1: NOP Comment Letters
Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
Public Agencies
California
Department of
Conservation
Monique Wilber,
Conservation
Program Support
Supervisor
March 14,
2022
• Recommendation to consider
agricultural conservation
easements as mitigation.
• Request for the Draft PEIR to
discuss the type, amount, and
location of farmland
conversion resulting from the
• Section 3.2,
Agricultural
Resources and
Forestry Resources
• Section 3.2,
Agricultural
Resources and
Forestry Resources
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
proposed project.
• Request for the Draft PEIR to
evaluate impacts on any
current or future agriculture
operations in the vicinity.
• Request for the Draft PEIR to
evaluate incremental impacts
leading to cumulative impacts
on agricultural land.
• Request for the Draft PEIR to
include mitigation measures
for impacts to agricultural
land.
• Request for the Draft PEIR to
evaluate the project’s
compatibility with any
agricultural land enrolled in a
Williams Act contract and
notify the Department of
Conservation of non-renewal
and/or cancellation of a
Williams Act contract.
• Section 3.2,
Agricultural
Resources and
Forestry Resources
• Section 3.2,
Agricultural
Resources and
Forestry Resources
• Section 3.2,
Agricultural
Resources and
Forestry Resources

• Section 3.2,
Agricultural
Resources and
Forestry Resources
California
Department of
Fish and
Wildlife
Julie A. Vance,
Regional Manager
March 25,
2022
• Acknowledgment that the
California Department of Fish
and Game (CDFW) is a trustee
and responsible agency for
the proposed project.
• Requests that the Draft PEIR
analyze potential impacts on
the special-status species
identified in the comment
letter and provides necessary
mitigation measures to
reduce impacts to a less than
significant level.
• N/A
• Section 3.4,
Biological Resources
California
Department of
Toxic
Substances
Control
Gavin McCreary,
Project Manager,
Site Evaluation
and Remediation
Unit
March 15,
2022
• Requests that the Draft PEIR
acknowledge the potential for
historic or future activities to
result in the release of
hazardous waste/substances.
• Recommends that all future
development under the
• Section 3.9, Hazards
and Hazardous
Materials
• Section 3.9, Hazards
and Hazardous
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
proposed project collect soil
samples for lead analysis prior
to performing any intrusive
activities.
• Recommends that all future
development under the
proposed project conduct
surveys for the presence of
lead-based paints, mercury,
asbestos containing materials,
and polychlorinated biphenyl
caulk before demolishing any
buildings.
• Requests that Draft PEIR
require any future
development under the
proposed project that
requires the importation of
soil to backfill any excavated
areas to conduct the proper
sampling to ensure that the
imported soil is free of
contamination.
• Requests that the Draft PEIR
requires any future
development under the
proposed project that is
developed on land containing
agricultural uses, weed
abatement activities, or
related activities to conduct a
proper investigation for
organochlorinated pesticides.
• Recommends that the current
and former agricultural lands
in the Plan Area be evaluated
in accordance with the
California Department of Toxic
Substances Control (DTSC)
2008 Interim Guidance for
Sampling Agricultural
Properties (Third Addition).

Materials; and Section

3.7, Geology, Soils,
and Seismicity
• Section 3.9, Hazards
and Hazardous
Materials
• Section 3.9, Hazards
and Hazardous
Materials; and
Section 3.7, Geology,
Soils, and Seismicity
• Section 3.9, Hazards
and Hazardous
Materials
• Section 3.9, Hazards
and Hazardous
Materials; and
Section 3.2,
Agricultural
Resources and
Forestry Resources
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
California
Department of
Transportation
David Padilla,
Branch Chief,
Transportation
Planning-North
March 18,
2022
• Recommends that a peakhour ramp queue analysis is
completed at each of the
following State Route (SR) 180
interchanges to determine
potential impacts: Clovis
Avenue, Fowler Avenue, and
Temperance Avenue.
• Recommends that a peakhour ramp queue analysis is
completed at each of the
following SR-180 intersections
to determine potential
impacts: De Wolf Avenue,
Highland Avenue, and McCall
Avenue.
• Requests all future
development proposals to
evaluate traffic safety impacts
on the State Highway Systems
due to new pedestrian and
bicyclist needs due to the
proposed project, specifically
SR-180 interchanges at Fowler
Avenue and Temperance
Avenue and intersections at
De Wolf Avenue, Highland
Avenue, and McCall Avenue.
• Requests that all future
development under the
proposed project should
conduct a Vehicles Miles
Traveled (VMT) analysis and
determine whether
development under the
proposed project would be
required to pay a VMT
Mitigation Impact Fee.
• Requests that project
proponents consider
allocating a portion of future
residential development as
affordable housing units.
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• 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.
• Recommends that the Draft
PEIR include implementation
guidelines for multimodal
strategies, such as those that
originate from Transit
Oriented Development (TOD),
in an effort to further reduce
future projects’ traffic related
impacts.
• Support of active
transportation plans and
smart growth efforts that
support 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.
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
Fresno County
Department of
Public Works
and Planning,
Development
Service and
Capital
Projects
Division
David Randall,
Senior Planner
March 24,
2022
• Identifies locations within the
Plan Area that are within
Special Flood Hazard Areas,
which would be subject to
Fresno County Ordinance
Code Title 15, Chapter 15.48
as well as Federal Emergency
Management Agency (FEMA)
flood elevation requirements
as applicable.
• States that any construction
within or near a stream will
require a clearance from
CDFW and Streambed
Alternation Agreement if
buildout would result in
• Section 3.7, Geology,
Soils, and Seismicity;
Section 3.10,
Hydrology and Water
Quality; and Section

3.19, Wildfire
• Section 3.4,
Biological Resources;
and Section 3.10,
Hydrology and Water
Quality
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
alteration or degradation.
• Recommends that any
improvements constructed
within or near a canal should
be coordinated with the
owners of the
canal/appropriate agency.
• Recommends that the Fresno
Metropolitan Flood Control
District be consulted
regarding future development
near flood drainage basins.
• Recommends that any
construction and/or
development within an
Agricultural Preserve consult
with/obtain approval from the
County Policy and Planning
Department.
• Identifies that any future
development under the
Specific Plan that would be
greater than 1 acre would be
required to obtain a National
Pollutant Discharge
Elimination System (NPDES)
permit and produce a Storm
Water Pollution Prevention
Plan (SWPPP).
• Recommends that a Traffic
Impact Study be prepared.
• States that any work done
within the County-road rightof-way to construct a new
driveway or improve an
existing driveway will require
an Encroachment Permit from
the Road Maintenance and
Operations Division.
• States that any encroachment
or access over the Southern
Pacific Railroad right-of-way
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.2,
Agricultural
Resources and
Forestry Resources
• Section 3.10,
Hydrology and Water
Quality
• Section 3.17,
Transportation and
Traffic
• Section 3.17,
Transportation and
Traffic
• N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
would require approval from
the owner.
• States that any grading will
require either an engineered
grading and drainage plan,
road improvement plan,
permit or voucher and must
comply with the City
standards/requirements.
• Requests that all engineered
grading and drainage plans,
road improvement plans,
permits, and vouchers also be
forwarded to the City of
Fresno.
• States that any future
development under the SEDA
Specific Plan that would use
or handle hazardous materials
would be required to meet
the requirements set forth in
the California Health and
Safety Code (HSC), Division
20, Chapter 6.95, and the
California Code of Regulations
Title 22, Division 4.5. Any
businesses handling
hazardous waste must submit
a Hazardous Materials
Business Plan pursuant to
HSC, Division 20, Chapter

6.95, Section 25507.
• States that an Underground
Storage Tank (UST) Removal
Permit from the Fresno
County Department of Public
Health, Environmental Health
Division must be obtained if
any petroleum USTs are
discovered during
construction.
• States that all water wells and
septic systems identified at a
future development site that
• Section 3.7, Geology,
Soils, and Seismicity;
Section 3.10,
Hydrology and Water
Quality; and Section

3.17, Transportation
and Traffic
• N/A
• Section 3.9, Hazards
and Hazardous
Materials
• Section 3.9, Hazards
and Hazardous
Materials
• Section 3.9, Hazards
and Hazardous
Materials
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
are not intended to be used
would be properly removed
by a licensed contractor.
• Requested that all
appropriate measures be
incorporated during the
construction phase of any
future development to
minimize potentially
significant short-term noise
impacts to noise-sensitive
receivers.
• Requests that all future
projects must conform with
applicable standards of the
Noise Element of the City of
Fresno General Plan.
• States that the County has a
water-providing Community
Service Area (CSA) (CSA 14)
which is interested in
connecting to the City’s water
system and that the County
has several road CSAs within
the Plan Area.
• Requests that the Design
Division be forwarded any
transportation studies
associated with SEDA.
• Section 3.13, Noise

• Section 3.13, Noise
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• N/A
Fresno County
Historical
Landmarks
and Records
Advisory
Commission
Bill Secrest,
Librarian,
Heritage Center,
Fresno County
Public Library
February 24,
2022
• Request to be notified of all
future development under
the proposed project that
may have impacts on cultural
and tribal cultural resources.
• Expressed concern that the
Plan Area may contain houses
and structures of historical
interest (in excess of 100
years of age) with an outside
possibility of Yokuts artifacts
present.
• Section 3.5, Cultural
Resources and Tribal
Cultural Resources
• Section 3.5, Cultural
Resources and Tribal
Cultural Resources
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
Fresno
Irrigation
District
Laurence Kimura,
PE, Chief Engineer
March 25,
2022
• Identifies the Flood Irrigation
District (FID) canals in the Plan
Area.
• States that many of the
existing facilities will need to
be upgraded to meet the
current urban standards or
relocated by the developer to
accommodate new urban
developments which will
require new pipelines and
new exclusive easements.
• Requires that all open
channels and existing
pipelines impacted by the
project area development to
be upgraded to meet FID’s
current standards for urban,
rural, and industrial areas.
• Requires that development
impacts to large canal
crossings to be designed to
protect the canal’s integrity
for an urban setting including
the need for access and full
right-of-way widths for FID’s
operations and maintenance
needs.
• Identifies that the FID
facilities within the Plan Area
carry irrigation water for FID
users, recharge water for the
City, and flood waters during
winter months.
• Provides provisions for public
roads used to access canals.
• Provides provisions for
construction on canal banks.
• Provides provisions for trails
that are master planned as
part of SEDA that occur along
canals.
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality
• N/A
• N/A
• N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• Requires that development
within the Plan Area will not
result in an increase in the
City’s surface water allocation
from FID.
• Requests that the Draft PEIR
evaluate whether the City’s
Water Master Plan needs to
be updated and how the
Cooperative Agreement
between the City and FID may
impact development within
the Plan Area.
• Requests that the Draft PEIR
evaluate whether previous
projects proposed under the
City’s Water Master Plan
resulted in the benefits
anticipated.
• Requests that the Draft PEIR
require that any future
development minimize water
demand and/or reduce
impacts to groundwater.
• Requires that any future
development under SEDA that
uses treated surface water
during a period where the
City has a deficit water supply
or groundwater levels
continue to drop then the City
must acquire additional water
from a water purveyor as to
not impact water supplies or
exacerbate the deficit.
• Identifies that groundwater
overdraft is an issue in the
City and requires that the
Draft PEIR evaluates the
Specific Plan’s impact on
groundwater resources.
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
• Section 3.10,
Hydrology and Water
Quality; and Section

3.18, Utilities and
Service Systems
Fresno
Metropolitan
Denise Wade,
Master Plan
March 25,
2022
• States that FMFCD intends to
work with the City to provide
• N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
Flood Control
District
(FMFCD)
Special Projects
Manager
Master Planned drainage area
systems to serve the Plan
Area.
• States that approximately
4,200 acres of the Plan Area is
outside the current FMFCD
boundary and thus the
FMFCD’s sphere of influence
will be adjusted to include the
Plan Area.
• Requires that all impacts to
stormwater runoff created by
increasing densities in
developed area that effect the
capacity of the existing
Master Planned storm
drainage system must be fully
mitigated.
• States that FMFCD has
studied the areas not
currently located within a
Master Planned area and has
located the tentative basin
facilities in an attached Exhibit
that must be incorporated in
the SEDA Proposed Land Use
plan.
• States that the City, FMFCD,
and the County are all
currently covered as CoPermittees for the Municipal
Separate Storm Sewer System
(MS4) discharges through
NPDES and discusses
procedure for future projects
under SEDA for permitting.
• Requests that all future CEQA
review within the City,
including the SEDA area,
utilize the Guidance for
Addressing Stormwater
Quality for CEQA Review
documents.
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• States that existing FMFCD
policy requires postdevelopment requirements
for areas not served by
stormwater basins or areas
that discharge to sensitive
waterbodies. Should future
development under SEDA
include sustainable
infrastructure, coordination
between the City and FMFCD
must take place to ensure
plans are suited to meet
stormwater quality regulatory
objectives and compatible
with drainage standards in the
Fresno area.
• Recommends that the Draft
EIR evaluate impacts related
to the construction of master
planned storm drainage
facilities to the extent feasible
to prevent duplicate CEQA
processing.
• Future development under
SEDA would be subject to
drainage fees pursuant to the
Drainage Fee Ordinance prior
to approval of any final maps
and/or issuance of building
permits at the rates in effect
at the time of such approval.
• Requires that the grading of
proposed development within
the Plan Area shall be
designed such that there are
not adverse impacts to the
passage of major storm flow
through that development.
• Requires that future
development provide any
surface flowage easements or
covenants for any portions of
the developing area that
cannot convey stormwater to
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
public right-of-way without
crossing private property.
• Requires that FMFCD review
and approve the final
improvement plans for all
development (i.e., grading,
street improvement and
storm drain facilities) within
the boundaries of the
proposed project to insure
consistency with the future
Storm Drainage Master Plan.
• Requires that a storm drain
easement is obtained
whenever storm drain
facilities are located on
private property. No
encroachments into the
easement will be permitted
including, but not limited to,
foundations, roof overhangs,
swimming pools, and trees.
• Requires that all future
development verify that
permanent drainage service is
available with FMFCD to
ensure that runoff can be
safely conveyed to existing
Master Plan facilities.
• Encourages but does not
require that roof drains from
nonresidential development
be constructed such that they
are directed onto and through
a landscaped grassy swale
area to filter out pollutants
from roof runoff.
• Requires that runoff from
areas where industrial
activities, product, or
merchandise come into
contact with and thus
contaminate stormwater must
be directed through
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
• Section 3.10,
Hydrology and Water
Quality
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
landscaped areas or
otherwise treated before
discharging it off-site or into a
storm drain.

Native
American
Heritage
Commission
Cameron Vela,
Cultural
Resources Analyst
February 23,
2022
• Requires that the preparation
of the Draft PEIR and Specific
Plan adhere to Assembly Bill
(AB) 52 and Senate Bill (SB)

18. • Section 3.5, Cultural
Resources and Tribal
Cultural Resources
San Joaquin
Valley Air
Pollution
Control
District
(SJVAPCD)
Brian Clements,
Director of Permit
Services
March 24,
2022
• Recommends that the Draft
PEIR demonstrates the
project’s compliance with all
applicable goals, policies, and
objectives outlined in CARB’s
Air Quality and Land Use
Handbook: A Community
Health Perspective and CARB’s
Freight Handbook Concept
Paper.
• Recommends that the Draft
PEIR include modeling to
assess, characterize, and
mitigate project-level
construction and operational
emissions and air quality
impacts.
• States that a health risk
assessment (HRA) should be
performed for future projects
within the SEDA.
• Offers availability to review
Health Risk Assessment (HRA)
protocols and analyses and
requires the following
components for analysis: HRA
AERMOD model files, HARP2
files, and a summary of
emission source location,
emission rates, and emission
factor calculations and
methodology.
• Suggests that development
projects resulting in toxic air
contaminant (TAC) emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality
• Section 3.3 Air
Quality
• Section 3.3, Air
Quality; and Section
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
should be located an
adequate distance from
residential areas and sensitive
receptors.
• Recommends that the Draft
PEIR require an Ambient Air
Quality Analysis (AAQA) to be
performed for any future
development project with
emissions that exceed 100
pounds per day of any
pollutant.
• Recommends the Draft PEIR
discuss the feasibility of
implementing a Voluntary
Emission Reduction
Agreement (VERA) for this
project.
• Recommends the Draft PEIR
analyze methods to reduce
VMT, GHG emissions, and air
quality impacts by reviewing
heavy-duty truck routing
patterns, reducing idling of
heavy-duty trucks, and using
the cleanest available heavy
heavy-duty (HHD) trucks and
vehicles.
• Recommends use of zeroemission technologies for all
on-site service equipment and
on-road equipment, as
feasible.
• Recommends that the Draft
PEIR include a measure
requiring the assessment and
potential installation, as
technologically feasible, of
particulate matter emission
control systems for new large
restaurants operating underfired charbroilers.

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; Section 3.8,
Greenhouse Gas
Emissions; and
Section 3.17,
Transportation and
Traffic
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-20 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• Describes incentive funding
for Valley businesses that
covers the cost of purchasing,
installing, and maintaining the
particulate matter emission
control system for up to two
years.
• Recommends the Draft PEIR
consider incorporating
vegetative barriers and urban
greening as a measure to
further reduce air pollution
exposure of sensitive
receptors.
• Suggests that the Draft PEIR
consider the feasibility of
incorporating solar power
systems as an emission
reduction strategy for future
projects within the SEDA.
• Explains that the District
offers incentives to public
agencies, businesses, and
property owners of multi-unit
dwellings to install electric
charging infrastructure.
• Suggests that the City and
project proponents install
electric vehicle chargers at
project sites and at strategic
locations throughout the
SEDA.
• Recommends that any project
proponent whose project is
determined to have a
potentially significant odor
impact should be required to
draft and maintain an Odor
Management Plan.
• Requests that the Draft PEIR
analyzes the proposed
project's compliance with
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.4, Biological
Resources
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality; Section 3.6,
Energy; and Section

3.8, Greenhouse Gas
Emissions
• Section 3.3, Air
Quality
• Section 3.3, Air
Quality; and Section

3.8, Greenhouse Gas
Emissions
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
applicable SJVAPCD rules and
regulations.

Sanger Unified
School District
Ryan Kilby, Chief
Operations Officer
March 25,
2022
• Request that the Draft PEIR
analyze whether the number
of schools shown is
appropriate to adequately
serve the SEDA buildout
population.
• States that a new high school
(Sanger West) and middle
schools serving 7-8 grades will
serve SEDA population.
• Recommends that at least one
additional high school and
one additional middle school
will be needed to serve the
buildout of SEDA.
• States that any future school
site locations designated as
part of the Specific Plan.
should be considered
conceptual rather than locked
into parcel location.
• States that, in order to obtain
a California Department of
Education site approval for a
school site, the District has to
go through a site-specific
CEQA process, a rigorous
hazardous materials testing
process under the oversight of
DTSC as well as other safety
studies.
• Section 3.15, Public
Services
• Section 3.15, Public
Services
• Section 3.15, Public
Services
• Section 3.15, Public
Services
• Comment noted;
topics fall outside the
scope of the EIR.

However, comment
letter will be
included in Appendix
A, NOP comments.

Organizations
Carpenters
Local 701,
United
Brotherhood
of Carpenters
and Joiners of
America
Travis Alexander March 25,
2022
• Requests that the Specific
Plan include mandatory
policies within the economic
development and
environmental justice
element that promotes
apprenticeships for
construction under the
proposed project.
• N/A
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-22 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• Requests that the Specific
Plan include a Local Hire
Policy, which requires each
construction contractor to
hire a minimum of 25 percent
of staff for each
apprenticeable craft job
classification with more than
four employees whose
primary residence is within
the Counties of Fresno, Kings,
Madera, or Tuolumne for at
least 180 days after the
project’s Notice to Proceed.
• Support of the benefits to the
community that would be
included as part of the
apprenticeship and local hire
policies.
• N/A
• N/A
Dunlap Band
of Mono
Indians
Dirk Charlie,
Dunlap Mono
Tribal Liaison
N/A • Suggest that the City contact
the following tribes to inquire
if they are aware of any
historical and/or cultural
resources in the Plan Area:

Table Mountain Ranch, Big
Sandy, and Traditional
Transundi Tribe.
• Section 3.5, Cultural
Resources and Tribal
Cultural Resources
Leadership
Counsel of
Justice and
Accountability
(LCJA), Fresno
Building
Healthy
Communities
(FBHC),
Central
California
Environmental
Justice
Network
(CCEJN), and
Fresno Barrios
Unidos (FBU)
Karla Martinez,
LCJA; Kimberly
McCoy, FBHC;
Nayamin
Martinez, CCEJN;
and Ruben
Espinoza, FBU
March 25,
2022
• Requests that the Draft PEIR
accurately captures and
analyzes baseline conditions
and potentially significant
project-specific and cumulative
impacts within and adjacent to
the planning area.
• Requests that the Draft PEIR
identifies plan alternatives,
which would mitigate
negative impacts of the plans.
• Requests that the Draft PEIR
identifies and adopts all
feasible and enforceable
mitigation measures that
avoid and reduce negative
impact.
• All topical sections
contained within the
Draft PEIR
• Chapter 5,
Alternatives
• All topical sections
contained within the
Draft PEIR
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx

1.2.1 - Potentially Significant Environmental Issues
The NOP found that the following topical areas may contain potentially significant environmental issues that require further analysis in the Draft PEIR. These sections are as follows:
• Aesthetics, Light, and Glare
• Agriculture Resources and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources and Tribal Cultural Resources
• Energy
• Geology, Soils, and Seismicity
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Utilities and Service Systems
• Wildfire
As identified in the NOP, there are no topical areas that were initially determined not to be significant, and thus, this Draft PEIR does not include a section for Effects Found not to be Significant.

1.3 - Organization of the Draft Program EIR
This Draft PEIR is organized into the following main sections:
• Chapter ES: Executive Summary. This Chapter includes a summary of the proposed project and alternatives to be addressed in the Draft PEIR. A brief description of the areas of controversy and issues to be resolved, and overview of the Mitigation Monitoring and Reporting Program (MMRP), in addition to a table that summarizes the impacts, mitigation measures, and level of significance after mitigation, are also included in this section.

Agency/
Organization Author Date
Comments/Topics Discussed in
Letter
Corresponding Draft PEIR
Section where Comments
are Addressed
• Requests that the Draft PEIR
analyzes and creates
mitigation measures
consistent with all applicable
laws, including state and
federal fair housing, civil
rights, and climate laws such
as SB 743.
• Requests that the City
meaningfully engage with the
public through a robust,
accessible, and responsive
process.
• All topical sections
contained within the
Draft PEIR
• Chapter 1,
Introduction; and
Chapter 2, Project
Description
Source: Compiled by FirstCarbon Solutions (FCS) 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-24 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx • Chapter 1: Introduction. This Chapter provides an introduction and overview describing the purpose of this Draft PEIR, its scope and components, and its review and certification process. • Chapter 2: Project Description. This Chapter includes a detailed description of the proposed project, including its location, site, and project characteristics. A discussion of the project objectives, intended uses of the Draft PEIR, responsible agencies, and approvals that are needed for the proposed project are also provided.
• Chapter 3: Environmental Impact Analysis. This chapter analyzes the environmental impacts of the proposed project. Impacts are organized into major topic areas. Each topic area includes a description of the environmental setting, methodology, significance criteria, impacts, mitigation measures, and significance after mitigation. The specific environmental topics that are addressed within Chapter 3 are as follows:
- Section 3.1—Aesthetics, Light, and Glare: Addresses the potential visual impacts of development intensification and the overall increase in illumination produced by the proposed project.
- Section 3.2—Agricultural Resources and Forestry Resources: Addresses the potential for conversion of Important Farmland to nonagricultural use and forest land to non-forest use. - Section 3.3—Air Quality: Addresses potential air quality impacts associated with project implementation and emissions of criteria pollutants. In addition, the section also evaluates project emissions of toxic air contaminants.
- Section 3.4—Biological Resources: Addresses potential impacts on habitat, vegetation, and wildlife; the potential degradation or elimination of important habitat; and impacts on listed, proposed, and candidate threatened and endangered species. - Section 3.5—Cultural Resources and Tribal Cultural Resources: Addresses potential impacts on historical resources, archaeological resources, paleontological resources, and burial sites, and additionally addresses potential project impacts related to tribal cultural resources. - Section 3.6—Energy: Addresses potential project impacts related to energy usage. - Section 3.7—Geology, Soils, and Seismicity: Addresses the potential impacts the project may have on soils and assesses the effects of project development in relation to geologic and seismic conditions.
- Section 3.8—Greenhouse Gas Emissions: Addresses potential project emissions of greenhouse gases.
- Section 3.9—Hazards and Hazardous Materials: Addresses potential for presence of hazardous materials or conditions on the project site and in the project area that may have the potential to impact human health.
- Section 3.10—Hydrology and Water Quality: Addresses the potential impacts of the project on local hydrological conditions, including drainage areas, and changes in the flow rates. - Section 3.11—Land Use and Planning: Addresses the potential land use impacts associated with division of an established community and consistency with the Specific Plan and Fresno General Plan.
- Section 3.12—Mineral Resources: Address potential impacts to mineral resources. - Section 3.13—Noise: Addresses potential noise impacts during construction and at project buildout from mobile and stationary sources. The section also addresses the impact of noise generation on neighboring uses.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-25 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx - Section 3.14—Population and Housing: Addresses the potential of the proposed project to induce direct or indirect population growth.
- Section 3.15—Public Services: Addresses potential impacts upon public services, including fire protection, law enforcement, schools, parks, and recreational facilities. - Section 3.16—Recreation: Addresses potential impacts related to parks and park usage. - Section 3.17—Transportation and Traffic: Addresses potential impacts related to the local and regional roadway system and public transportation, bicycle, and pedestrian access. - Section 3.18—Utilities and Services Systems: Addresses potential impacts related to service providers, including fire protection, law enforcement, water supply, wastewater, solid waste, and energy providers.
- Section 3-19—Wildfire: Addresses potential impacts related to wildfire including lands within State Responsibility Areas and lands classified as very high fire hazard severity zones. • Chapter 4: Other CEQA Considerations. This chapter provides a summary of significant environmental impacts, including unavoidable and growth-inducing impacts. This chapter discusses the cumulative impacts associated with the proposed project, including the impacts of past, present, and probable future projects. In addition, the proposed project’s energy demand is discussed.
• Chapter 5: Alternatives to the Proposed Project. This chapter compares the impacts of the proposed project with three land-use project alternatives: the No Project Alternative, the Consolidated Business Park Alternative, and the Farmland Conservation Alternative. An environmentally superior alternative is identified. In addition, alternatives initially considered but rejected from further consideration are discussed.
• Chapter 6: Persons and Organizations Consulted/List of Preparers. This chapter contains a full list of persons and organizations that were consulted during the preparation of this Draft PEIR. This Chapter also contains a full list of the authors who assisted in the preparation of the Draft PEIR, by name and affiliation.
• Appendices. The Draft PEIR appendices includes all notices and other procedural documents pertinent to the Draft PEIR, as well as all technical material prepared to support the analysis.

1.4 - Documents Incorporated by Reference
As permitted by CEQA Guidelines Section 15150, this Draft PEIR has referenced several technical studies, analyses, and previously certified environmental documentation. Information from the documents, which have been incorporated by reference, has been briefly summarized in the appropriate section(s). The relationship between the incorporated part of the referenced document and the Draft PEIR has also been described. The documents and other sources that have been used in the preparation of this Draft PEIR include but are not limited to:
• Southeast Development Area Specific Plan (Specific Plan) (2023) • Fresno General Plan 2014
• Fresno General Plan Final Program Environmental Impact Report (2021) (State Clearinghouse Number 2019050005, certified July 2021)
City of Fresno—Fresno Southeast Development Area Specific Plan Project Introduction Draft Program EIR
1-26 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx • Fresno Urban Water Management Plan (2021)
• Fresno Vehicle Miles Traveled Guidelines (2020)
• City of Fresno Active Transportation Plan (2016)
In accordance with CEQA Guidelines Section 15150(b), the Specific Plan, General Plan, and the above referenced documents and other sources used in the preparation of the Draft PEIR are available for review at the City of Fresno Planning and Development Department at the address shown in Section

1.6 below, during regular business hours.

1.5 - Documents Prepared for the Proposed Project
The following technical studies and analyses were prepared for the proposed project:
• Air Quality, Greenhouse Gas Emissions, and Energy Analyses • Biological Resources Assessment
• Cultural, Tribal Cultural, and Paleontological Resources Analyses • Noise Analysis
• Traffic Impact Analysis
• Water Technical Report
• Recycled Water Technical Report
• Wastewater Technical Report
• Storm Drainage Technical Report

1.6 - Review of the Draft Program EIR
Upon completion of the Draft PEIR, the City of Fresno filed a Notice of Completion (NOC) with the State Office of Planning and Research to begin the public review period (PRC § 21161). Concurrent with the NOC, this Draft PEIR has been distributed to responsible and trustee agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties requesting a copy of the Draft PEIR in accordance with Public Resources Code 21092(b)(3). During the public review period, the Draft PEIR, including the technical appendices, is available for review at the City of Fresno Planning and Development. The address is provided below:

City of Fresno
Attn: Jennifer Clark, Director
Planning and Development Department
2600 Fresno Street, Room 3065
Fresno, CA 93721
The Draft PEIR is also available for review at the following website: www.fresno.gov/SEDA Agencies, organizations, and interested parties have the opportunity to comment on the Draft PEIR during the 45-day public review period. Written comments on this Draft PEIR should be addressed to:

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Introduction
FirstCarbon Solutions 1-27 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec01-00 Introduction.docx Jennifer Clark, Director
Planning and Development Department
c/o Sophia Pagoulatos, Planning Manager
Planning and Development Department
2600 Fresno Street, Room 3065
Fresno, CA 93721
[email protected]
[email protected]
Submittal of electronic comments in Microsoft Word or Adobe PDF format is encouraged. Upon completion of the public review period, the lead agency will evaluate all comments received on the Draft PEIR and prepare written responses. Written responses to comments made by public agencies during the public review period will be prepared and made available for review by the commenting public agencies at least 10 days prior to the public hearing before the Fresno City Council on the project, at which time the certification of the Final EIR will be considered. Comments received and the responses to comments will be included as part of the record for consideration by decision makers for the project.

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx CHAPTER 2: PROJECT DESCRIPTION
This Draft Program Environmental Impact Report (Draft PEIR) analyzes the potential environmental effects of the proposed Fresno Southeast Development Area (SEDA) Specific Plan Project (proposed project) in the City of Fresno (City). This section of the Draft PEIR describes the key characteristics of the proposed project, including a general overview of the Specific Plan approval process; project location and planning area; and the characteristics of the proposed project, including required discretionary approvals. The following project description serves as the basis for the environmental analysis contained in this Draft PEIR. The City is the California Environmental Quality Act (CEQA) Lead Agency and has final authority to approve the proposed project and certify the Draft PEIR.

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

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

2.1.1 - Notice of Preparation and Public Scoping Meeting The Notice of Preparation (NOP) of the Draft PEIR for the proposed project was circulated from February 22, 2022, to March 25, 2022, to trustee and responsible agencies, the State Clearinghouse (SCH), and the public to share information about the proposed project and receive input on the scope of the environmental issues to be addressed in the Draft PEIR. A Scoping Meeting was held virtually, due to the COVID-19 restrictions, on March 3, 2022. Input obtained through the scoping process was incorporated into the environmental analysis and planning process.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx

2.1.2 - Public Outreach
In an effort to offer multiple opportunities for engagement with the public and stakeholders, the City hosted three in-person workshops on May 3, 17, and 31, 2022, to further facilitate discussion on the proposed project. City staff were also available to attend pop-up events, neighborhood meetings, religious gatherings, etc. Additionally, the City has maintained a web page devoted to informing the public about, and encouraging participation in, the Specific Plan process. The website includes public notices, meeting materials, presentations resources and reports, contact information, and other background materials. The web page is located at: www.fresno.gov/SEDA.

2.1.3 - Contents of the Specific Plan
The Specific Plan is organized into the following four sections and seven elements. A set of objectives and implementing policies are provided in each relevant section. The Specific Plan’s sections and elements are as follows:

1. Introduction. This section provides an overview of the vision, opportunities, and challenges for development of the Plan Area, the existing conditions and growth expected in the Plan Area, and the implementation of the proposed project.

2. Document Elements. This section contains the following seven elements for SEDA:
• Urban Form Element. This element contains a series of exhibits that showcase the Land Use vision, a description of the Land Use Districts that make up the map, and the associated standards for each Land Use District. The section also contains specific objectives and policies related to urban form.
• Housing Element. This element discusses the availability of housing in the City and the challenges associated with providing housing affordability. This element includes SEDA’s household demographics and discusses the diverse range of housing types to be developed as a result of the Specific Plan, from medium- and higher-density multi-family types to small- and medium-lot single-family options. This section also includes objectives and policies that reflect the priorities and vision for housing within the Plan Area. • Open Space Element. This element outlines the proposed project’s plan to provide a highquality, accessible open space system; provides standards for the location, accessibility, and design of key public facilities; and details design guidelines and standards for park development. This element also includes objectives and policies that define the variety of open spaces and public spaces envisioned for the Plan Area. • Community Farming and Agricultural Element. This element provides the proposed project’s policy framework to balance the needs of urban development with the need to conserve the economic, cultural, and historic value of agricultural land in the City’s metropolitan area. In addition to including the policies and objectives for agricultural uses in the Plan Area, this element also provides descriptions of the different types of community farming and agriculture uses.
• Conservation Element. This element describes the objectives and policies that are aimed at reducing greenhouse gases (GHGs), conserving water and energy, and diverting waste, which together reduce GHG emissions and conserve resources.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx • Economic Development Element. This element describes the City’s commitment to environmentally responsible economic development that creates shared prosperity. This element includes the goals of the proposed project to build on the City’s current strengths and to create more opportunity for current and future residents and businesses. The objectives and policies of this element serve to identify economic opportunities presented by the design and policies of the Plan Area.
• Cultural and Historical Resource Element. This element discusses the policies that support preservation of the historically significant buildings, districts, sites, landscapes, and other features that reveal the unique identity of the City and contribute to its sense of place.

3. Implementation. This section outlines the actions, studies, plans, and procedures that will assist in implementing the Specific Plan.

2.1.4 - Additional Project Components
The proposed project sets a vision for how the Plan Area would develop over time and is supported by several other documents and plans in addition to the Specific Plan. The following components are part of the planning process and will be necessary prior to construction of any subsequent development under the Specific Plan:

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

Infrastructure Financing Plan
The proposed project would include a Public Facilities Financing Plan to fund backbone infrastructure and public facilities, including roads, sewer, water, storm drainage, parks, and other public facilities. Backbone infrastructure and public facilities required for development would be funded through a combination of public and private funding. Costs associated with in-tract infrastructure costs such as interior roads and utility lines would be funded by private developer funding and will be excluded from the Financing Plan. The project Financing Plan would be developed through a review of the SEDA Specific Plan, infrastructure studies, and coordination with the City.

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.

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.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-4 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx

2.2 - Existing

2.2.1 - Regional Location
The City is located in Fresno County, California, within the San Joaquin Valley. The City is located approximately 200 miles north of Los Angeles and 170 miles south of Sacramento. The City is located on the State Route (SR) 99 corridor and bounded by Madera County to the north, the City of Clovis to the northeast, and unincorporated land and communities to the east, south, and west. The City encompasses approximately 115.18 square miles12 and has a population of approximately 542,000 people.3

2.2.2 - Plan Area Location
The location of the nearly 9,000-acre Plan Area is in the southeast portion of the City, in Fresno County, California as shown in Exhibit 2-1. The Plan Area is bounded on the north by the Gould Canal, on the east by McCall and Highland Avenues, on the south by Jensen and North Avenues, and on the west by Locan, Temperance, and Minnewawa Avenues.

2.2.3 - Existing Uses
Agricultural Uses
The predominant existing use in the Plan Area (approximately 5,000 acres) is agriculture, primarily vineyards, orchards, and vegetable farms. The average parcel size is approximately 25 acres and is typically used for growing a range of crops. The Plan Area also contains agriculture-related and commercial operations, such as plant nurseries, wineries, and other various agricultural businesses.

Rural Residential Uses
The second most predominant existing use is rural residential development, which is primarily concentrated in the area between SR-180 and McKinley Avenue but also scattered throughout the Plan Area. Currently, there are 700 residential parcels (approximately 2.6 acres on average) within the Plan Area, which accommodate 713 single-family homes and 13 mobile homes.

Institutional and Public Facilities Uses
A school, churches, and other public uses also occupy the Plan Area. The Plan Area includes land that falls within both the Sanger and Clovis Unified School Districts (Sanger Unified and Clovis Unified), with Fowler and Fresno Unified School Districts bordering the Plan Area. Presently, the Lone Star Elementary School, located in the southern portion of the Plan Area, is the only school in the Plan Area. However, Clovis Unified is constructing an educational center for middle and high school students in the northern portion of the Plan Area on a site along the Clinton Avenue alignment between Leonard and Highland Avenues, with phased opening expected in 2025. 1 City of Fresno. 2020. Fresno General Plan Program Environmental Impact Report. Website: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2020/03/Fresno-GP-Public-Review-Draft-Program-EIR.pdf. Accessed March 17, 2022. 2 United States Census Bureau. 2020. Fresno City, California QuickFacts. Website:
https://www.census.gov/quickfacts/fresnocitycalifornia. Accessed December 9, 2022. 3 United States Census Bureau. 2020. Fresno City, California QuickFacts. Website:
https://www.census.gov/quickfacts/fresnocitycalifornia. Accessed March 17, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx Natural Features
The Plan Area is traversed by several constructed drainage features and natural waterways: Gould Canal, Redbank Slough, Dry Creek Canal, Mill Ditch, Fancher Creek Canal, and Briggs Canal. Typically, canals in the Plan Area are mostly unvegetated and the banks are reinforced with rock or broken asphalt and concrete, with some portions fully concrete-lined. In addition, there are several small ponds and numerous lateral irrigation ditches that deliver water from the canals to agricultural fields.

2.2.4 - Existing General Plan Designations
According to the City’s General Plan, the existing Plan Area contains the following General Plan designations:
• Residential–Low Density (1-3.5 DU/acre)
• Residential–Medium Density (5.0–12 DU/acre)
• Residential–Urban Neighborhood (16–30 DU/acre)
• Employment–Mixed Use
• Employment–Office
• Public Facilities
• Open Space
• Buffer

2.2.5 - Circulation and Access
The current roadway network is mainly comprised of two-lane county roads at 0.5-mile intervals, interspersed with local streets. Major roadway access corridors include Temperance, Clovis, and Jensen Avenues. Each of these major roadway access corridors accommodates four lanes of traffic with a central turning lane. SR-180 has been extended eastward along the old Kings Canyon alignment from Temperance Avenue to Academy Avenue in Sanger. This route extension provides an east–west connection to SR-99, serving commuters and the movement of agricultural goods from eastern portion of the County. Temperance Avenue has been expanded to four lanes where needed to serve new development.

2.3 - Project Characteristics

2.3.1 - Proposed Project
The proposed project is a Specific Plan for the SEDA that would provide for increased density and accelerate housing production throughout the Plan Area. The proposed project would offer flexibility in meeting the evolving needs of households in the region through a multimodal transportation network and diverse housing types and affordability levels. 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 proposed project is framed with three interrelated goals: fiscal responsibility, social equity, and environmental sustainability. The proposed project would link a series of complete communities and mixed-use centers with a multimodal transportation network. Additionally, the proposed project City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx would include major transit lines, mixed-use centers, diverse residential districts, employment districts, open space, agriculture, and green infrastructure.

2.3.2 - Proposed Specific Plan Buildout
The Land Use Map defines the physical extent of Land Use Districts, as well as major roadway alignments which constitute the buildout of the proposed project as shown in Exhibit 2-2. It also identifies potential locations for certain open space and institutional features. These locations, as well as certain roadway configurations and specific transit alignments, are more closely specified in the Infrastructure Plan. The implementation of the Land Use Map is administered through the application of Land Use District Standards and Street and Circulation Standards. The proposed project land use categories by district are shown in Table 2-1 along with the total proposed acreage.

Descriptions of each of the associated land use categories are further discussed below.

Table 2-1: Proposed Specific Plan Acreages
Land Use Proposed Plan Acres Percentages
Mixed-Use Land Uses
Regional Town Center 310 3.5%
Community Town Center 290 3.3%
Neighborhood Town Center 520 5.9%
Mixed-Use Land Uses Total 1,120 12.7%
Residential Land Uses
Mixed Residential 1,090 12.4%
Neighborhood Residential 1,520 17.3%
Rural Residential 2,160 24.5%
Rural Cluster Residential 810 9.2%
Residential Land Uses Total 5,580 63.4%
Employment Land Uses
Office Center 160 1.8%
Flexible Research and Development 1,380 15.7%
Institutional 280 3.2%
Employment Land Uses Total 1,820 20.7%
Other Land Uses
Flood Control Basin 280 3.2%
Total 8,800 100%
Source: City of Fresno 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx Mixed-Use Land Uses
The proposed project is based upon a hierarchy of walkable, mixed-use Town Centers supported by a multimodal transportation network. Town Centers, which would serve as commercial and civic focal points for the Plan Area, are designed to include a rich mixture of uses with varying intensities. Town Centers are human-scaled and defined by quality design features. They incorporate living and working opportunities with entertainment, cultural activities, and shops serving the daily needs of residents and employees. There are three types of Town Centers, including Regional Town Centers, Community Town Centers, and Neighborhood Town Centers.

Regional Town Centers
The Regional Town Center is at the top of the mixed-use center hierarchy in the Plan Area. The commercial uses in Regional Town Centers would serve approximately 40,000 to 60,000 households across the Plan Area and within the surrounding communities outside of the Plan Area. The Regional Town Center features region-serving retail and office activity, as well as medium- and higher-density housing. The Regional Town Center will be located south of SR-180 along the realigned Kings Canyon Boulevard. The center will be focused around one or more major transit stations linked to the regional rapid transit network. The Regional Town Center will be given priority as the primary mixeduse employment center, retail destination, and host to major cultural attractions.

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

Neighborhood Town Centers
Neighborhood Town Centers would be dispersed throughout the Plan Area and would serve as focal points of adjacent residential areas. Neighborhood Centers include employment and residential uses and would provide access to civic services and amenities, including elementary schools, local parks, community gardens, and other services. Each Neighborhood Town Center would serve approximately 1,500 to 2,000 households in the Plan Area and surrounding communities outside of the Plan Area and include a range of housing options.

Residential Land Uses
The Plan Area includes a rich and complete fabric of residential communities that support mixed-use centers and include a variety of housing types and affordability levels. The proposed project would distribute a variety of housing types across the Plan Area to accommodate current and future housing needs. The range of housing types and densities throughout the communities would provide flexibility to meet the evolving needs of households in the region. There are four types of residential City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx land uses, including Mixed Residential, Neighborhood Residential, Rural Residential, and Rural Cluster Residential.

Mixed Residential
Mixed Residential districts support the Regional and Community Town Centers with a variety of medium- and higher-density housing, including a diverse mix of attached and detached single-family and multi-family homes. The average gross density within the Mixed Residential district will be approximately 20–30 units per acre. Residential buildings range in net density from 8–60 units per acre.

Neighborhood Residential
Neighborhood Residential districts surround Neighborhood Town Centers and support the retail, employment, and other services provided throughout the Plan Area. Neighborhood Residential areas include a variety of detached and attached single-family housing types, as well as multi-family housing options. The average gross density within the Mixed Residential district will be approximately 7–15 units per acre. Residential buildings range in net density from 6–30 units per acre.

Rural Residential
There are approximately 1,536 acres in the Plan Area currently developed as very-low-density rural residential homes and ranchettes. The proposed project designates these homes as Rural Residential. Upon annexation into the City, the existing land use on these parcels will remain protected under the Annexation Overlay Ordinance as approved by the City Council in Bill 2008-10 on March 4, 2008. Changes in land use would be subject to the process and regulations set forth in the SEDA Development Code Update.

Rural Cluster Residential
Rural Cluster districts, located along the eastern edge of the Plan Area, would concentrate residential lots within a small, clustered area of a larger parcel or groups of parcels. This clustering of homes preserves the continuity and viability surrounding land for agricultural uses and open space conservation. Rural Cluster districts serve as a transitional buffer between more intense urban uses within the Plan Area and the commercial agricultural operations outside of the Plan Area. The average gross density of Rural Cluster districts is 0.1–0.5 units per acre. A district may include 20–80 acres, with single-family homes clustered on lots 1 acre or smaller in a designated cluster.

Employment Land Uses
The proposed project would provide opportunities to attract diverse, high-quality employers and job opportunities while meeting the environmental challenges associated with growth in the City and the Central Valley. Many jobs would be located within a short distance to amenities in Regional and Community Town Centers, Office Centers, and in Flexible Research and Development districts. In these locations, employment opportunities can be closely linked to regional transit service and trail systems. The proposed project would put a significant portion of Plan Area residents within walking distance of major employment areas and high-capacity transit services that link to regional employment centers, including Downtown Fresno. Reducing reliance on automobiles for work trips City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx would significantly reduce GHG emissions, playing a significant role in meeting the proposed project’s sustainability goals.

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

Flexible Research and Development
Flexible Research and Development districts would be primarily located west of the Briggs Canal and/or south of Jensen Avenue and are intended for uses such as research and development, light manufacturing, product testing centers, and office development. The area may also include compatible commercial uses such as restaurants, coffee shops, cafés, printing and publishing, dry cleaners, and other supporting businesses. Access to regional transportation corridors (both road and rail) is critical. Residential uses are not allowed in Flexible Research and Development areas.

Institutional Uses
Institutional Land Use Districts would include the planned Clovis Unified School District Education Center and the existing Sanger Unified School District Education Center. The Institutional Land Use Districts would not include new SEDA high schools, middle schools, or elementary schools and other civic uses in the SEDA Plan. These uses are integrated into Neighborhood Town Centers and other districts.

2.3.3 - Circulation and Access
The proposed project’s multimodal circulation network would include a hierarchy of transportation options, ensuring that residents would have realistic choices for their daily travel needs. The proposed project would be served by high-capacity public transit and safe bicycle and pedestrian routes. Arterials, collectors, and local streets would provide safe, convenient access for local trips.

Exhibit 2-3 shows the proposed major street circulation network. Non-auto options are integrated throughout the plan, with dedicated bicycle/pedestrian trails and a network of bicycle-priority “Bicycle Boulevards.”
Transit Service
Transit Corridors and Arterials with high-capacity public transit would serve major town centers, while collectors and local streets would provide safe, convenient options for local trips. Transit service will be provided to and within the Plan Area via regional transit connections along Kings Canyon Boulevard. The Kings Canyon high frequency Q Bus Route would extend into the Regional Town Center and eventually terminate service in the Community Town Center located on South DeWolf Avenue. Local service would be provided along primary internal circulation corridors.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx Bicycle and Pedestrian Trails
A network of pedestrian and bicycle routes, including dedicated trails and multi-purpose paths, would serve work, school, and recreational trips. This extensive non-auto travel network would be coordinated with existing and proposed regional trails. Trail systems would connect regional and subregional destinations for bicyclists, pedestrians, and equestrians (where appropriate). Multiuse trails would be parallel to canals and other east–west open space networks within the Plan Area. There would also be a network of bicycle lanes reflective of the Fresno Active Transportation Plan (ATP).

This would consist of at least Class II Bike Lanes and other bicycle facilities as described in the California Department of Transportation (Caltrans) Bikeway Classification Guide.

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

2.3.4 - Open Spaces, Agriculture, and Green Infrastructure Parks and Open Spaces
The proposed project’s open space system would provide places for active and passive recreation and includes corridors for trails and paths that would connect many areas of the Plan Area.

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

Community Farming and Agriculture
The proposed project would integrate community-scale farming and agriculture into the urban fabric. Agricultural activities would range from neighborhood gardens to agricultural education and from small farming operations in green belts to those on the Rural Cluster edge.

2.4 - Project Objectives
The objectives of the proposed project are to:

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx Fiscal Responsibility:
• Provide self-financing for the development and ongoing maintenance of the SEDA that does not reduce City of Fresno resources dedicated to other areas of the City or burden Fresno residents outside of the SEDA.
• Holistically coordinate infrastructure to integrate efficiencies that piecemeal planning cannot.
• Invest in resource conserving techniques for stormwater systems, water supply, and trail and open space networks to save on infrastructure and mitigation costs.

Social Equity:
• Promote health by reducing harmful emissions from cars and industry. • Foster healthy physical activity and community interaction by providing easy, safe walking and bicycle access to parks, schools, and retail centers. • Sustain the diversity of Fresno’s population by providing a wide variety of housing choices and business opportunities.
• Respect the major economic and cultural role of agriculture in the Central Valley by accommodating growth within the confines of a smaller urban footprint and directly integrating community-scale agriculture into the design of community centers, neighborhoods, and open spaces.

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

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx Parks, Open Space, and Trails:
• Create a variety of natural open spaces and parks for recreation in all areas of the SEDA. • Create trail systems and bicycle paths that make traveling without a car safe and convenient.
• Ensure that schools and major town centers can be reached safely with or without a car.

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

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

Community Farming and Agriculture:
• Integrate small farms, community gardens, and farmers’ markets into neighborhoods, schools, and town centers.
• Create a buffer that includes rural homes, organic farming, and open spaces to serve as a transition between the SEDA and commercial agriculture to the east.

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

2.5 - Intended Uses of this Draft Program EIR
This Draft PEIR has been prepared by the City to assess the potential environmental impacts that may arise in connection with actions related to implementation of the proposed project. Pursuant to CEQA Guidelines Section 15367, the City is the Lead Agency for the proposed project and has discretionary authority over the proposed project and project approvals. The Draft PEIR is intended to address all public infrastructure improvements and all future developments that are within the parameters of the proposed project. This Draft PEIR is intended to evaluate the environmental impacts of the Fresno SEDA Specific Plan to the greatest extent possible and is used as the primary environmental document to evaluate subsequent planning and permitting actions associated with projects in the planning area. Once certified, the City intends for this analysis to be used consistent with all available streamlining provisions in CEQA, including, but not limited to, Guidelines Section 15162-15168, 15182 and 15183.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Project Description
FirstCarbon Solutions 2-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx

2.5.1 - Discretionary and Ministerial Actions
The proposed project is a policy-level document and does not include any specific development proposals and may not fully evaluate the impacts of other future specific, individual development that may be approved under implementation of the proposed project. The Planning Commission and other decision-making bodies would review the proposed project and make recommendations to City Council, who has approval authority for adoption of the SEDA Plan and related actions. Future projects may be tiered off this Draft PEIR, or be found consistent with this Draft PEIR pursuant to one or more of CEQA’s streamlining processes and may require additional, project-specific environmental analysis to secure the necessary discretionary development permits. Subsequent projects will be reviewed by the City for consistency with the General Plan, Specific Plan, Zoning Ordinance, and this Draft PEIR, and subsequent project-level environmental review will be conducted if required by CEQA.

Adoption of the proposed project would be enacted by a resolution of the City Council for the following discretionary actions:
• Adoption of the Fresno Southeast Development Area Specific Plan. • Amendment of the Fresno General Plan, including amendments to the Land Use Map and text.
• Approval of Annexation (this would probably occur after initial adoption of the Specific Plan and would probably occur in phases—unlikely that it will be part of the plan adoption actions.)
Adoption of the proposed project would be enacted by a City ordinance for the following discretionary actions:
• Rezoning of property for consistency with the General Plan Amendment and SEDA Specific Plan.
• Text Amendment of the Development Code to incorporate new zone districts and other provisions called for in the SEDA Plan.

As discussed further under Section 2.4.2, Responsible and Trustee Agencies, other agencies may be consulted during the adoption process, however, their approval is not required for adoption of the proposed project. Any subsequent development under the proposed project may require approval of State, federal and Responsible Trustee Agencies that may rely on the program-level analysis in this Draft PEIR.

2.5.2 - Responsible and Trustee Agencies
A number of other agencies in addition to the City will serve as Responsible and Trustee Agencies, pursuant to CEQA Guidelines Section 15381 and Section 15386, respectively. For the purposes of CEQA, the term “Responsible Agency” includes all public agencies other than the Lead Agency that have discretionary approval power over the proposed project. Discretionary approval may include such actions as issuance of a permit, authorization, or easement needed to complete some aspect of City of Fresno—Fresno Southeast Development Area Specific Plan Project Project Description Draft Program EIR
2-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec02-00 Project Description.docx the proposed project. This Draft PEIR will provide environmental information to these agencies and other public agencies, which may be coordinated with other agencies, as part of project implementation. These agencies may include, but are not limited to, the following:
• California Department of Transportation
• California State Water Resources Control Board (State Water Board) • California Department of Fish and Wildlife (CDFW)
• Central Valley Regional Water Quality Control Board (Central Valley RWQCB) • Fresno Local Agency Formation Commission
• San Joaquin Valley Air Pollution Control District (Valley Air District) • Fresno Municipal Flood Control District
• Fresno Irrigation District
99 201
180
41 168
Fresno County
Tulare County
Madera County
Fresno County
Millerton
Lake
Big Dry Creek
Reservoir
Hensley Lake
Sierra
National
Forest
Clovis
Fresno
Sanger
Reedley
Selma
Fowler
Exhibit 2-1
Regional Location Map
5 2.5 0 5
Miles
Text
Project Site
Source: Census 2000 Data, The California Spatial Information Library (CaSIL).

CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
31680033 • 04/2022 | 2-1_regional.mxd
Project Site

THIS PAGE INTENTIONALLY LEFT BLANK
31680033 • 07/2023 | 2-2_specific_plan_map.cdr CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
Exhibit 2-2
Specific Plan Map
Source: City of Fresno, SEDA Regulating Districts, 07/2023.

I

THIS PAGE INTENTIONALLY LEFT BLANK
31680033 • 07/2023 | 2-3_proposed_major_st_circ_network.cdr CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
Exhibit 2-3
Proposed Major Street Circulation Network
Source: City of Fresno
I

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Environmental Impact Analysis
FirstCarbon Solutions 3-1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec03-00 Env Impact Analysis.docx CHAPTER 3: ENVIRONMENTAL IMPACT ANALYSIS
Organization of Issue Areas
This Draft Program Environmental Impact Report (Draft PEIR) provides analysis of impacts for those environmental topics where it was determined in the Notice of Preparation (NOP), or through subsequent analysis, that the proposed project would result in “potentially significant impacts.” Sections 3.1 through 3.19 discuss the environmental impacts that may result with approval and implementation of the proposed project.

Issues Addressed in this Draft Program EIR
The following environmental issues are addressed in Chapter 3:
• Aesthetics, Light, and Glare
• Agricultural Resources and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources and Tribal Cultural Resources
• Energy
• Geology, Soils, and Seismicity
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Utilities and Service Systems
• Wildfire
Level of Significance
Determining the severity of potential project impacts is fundamental to achieving the objectives of the California Environmental Quality Act (CEQA). CEQA Guidelines Section 15091 requires that decision-makers mitigate, as completely as is feasible, the significant impacts identified in the Draft PEIR. If the Draft PEIR identifies any significant unmitigated impacts, CEQA Guidelines Section 15093 requires decision-makers, in approving a proposed project, to adopt a statement of overriding considerations that explains why the benefits of the proposed project outweigh the adverse environmental consequences identified in the Draft PEIR.

The level of significance for each impact examined in this Draft PEIR was determined by considering the predicted magnitude of the impact against the applicable threshold. Thresholds were developed using criteria from the CEQA Guidelines and checklist; State, federal, and local regulatory schemes; local/regional plans and ordinances; accepted practice; consultation with recognized experts; and other professional opinions. The level of significance for each impact can be determined as “No impact,” “Less than significant impact,” “Less than significant with mitigation incorporated,” or “Significant and unavoidable impact.” A “No impact” determination means the proposed project would not affect this impact area at all. A “Less than significant impact” determination means that the proposed project may have a minor effect on this impact area, but it would not exceed a City of Fresno—Fresno Southeast Development Area Specific Plan Project Environmental Impact Analysis Draft Program EIR
3-2 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec03-00 Env Impact Analysis.docx threshold requiring mitigation. A “Less than significant with mitigation incorporated” determination means that the proposed project could potentially have a significant impact, but there are measures that can be put in place to reduce the impact to a level that is not considered significant. A “Significant and unavoidable impact” determination means that the proposed project exceeds thresholds requiring mitigation, but there is no feasible mitigation available that would reduce the impact to a level that is less than significant.

Impact Analysis and Mitigation Measure Format
The format adopted in this Draft PEIR to present the evaluation of impacts is described and illustrated below.

Summary Heading of Impact
Impact AES-1: An impact summary heading appears immediately preceding the impact description (Summary Heading of Impact in this example). The impact number identifies the section of the report (AES for Aesthetics, Light, and Glare in this example) and the sequential order of the impact (1 in this example) within that section. To the right of the impact number is the impact statement, which identifies the potential impact.

Impact Analysis
A narrative analysis follows the impact statement.

Level of Significance Before Mitigation
This section identifies the level of significance of the impact before any mitigation is proposed.

General Plan PEIR Mitigation Measures
The City’s General Plan establishes a blueprint for future land development in the City. To evaluate impacts on the environment, the General Plan was approved in conjunction with a certified PEIR in December 2014. The SEDA Specific Plan is subject to the General Plan.

Accordingly, mitigation measures that were included in the General Plan PEIR apply to the proposed project and mitigation applicable to the proposed project is listed in each topical section throughout this EIR.

Mitigation Measures
In some cases, following the impact discussion, reference is made to State and federal regulations and agency policies that would fully or partially mitigate the impact. In addition, policies and programs from applicable local land use plans that partially or fully mitigate the impact may be cited.

Project-specific mitigation measures, beyond those contained in other documents, are set off with a summary heading and described using the format presented below:

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Environmental Impact Analysis
FirstCarbon Solutions 3-3 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/edit/31680033 Sec03-00 Env Impact Analysis.docx MM AES-1 Project-specific mitigation is identified that would reduce the impact to the lowest degree feasible. The mitigation number links the particular mitigation to the impact it is associated with (AES-1 in this example); mitigation measures are numbered sequentially.

Level of Significance After Mitigation
This section identifies the resulting level of significance of the impact following mitigation.

Abbreviations used in the mitigation measure numbering are:

Code Environmental Issue
AES Aesthetics, Light, and Glare
AG Agricultural Resources and Forest Resources
AIR Air Quality
BIO Biological Resources
CUL Cultural Resources and Tribal Cultural Resources
ENER Energy
GEO Geology, Soils, and Seismicity
GHG Greenhouse Gas Emissions
HAZ Hazards and Hazardous Materials
HYD Hydrology and Water Quality
LAND Land Use and Planning
MIN Mineral Resources
NOI Noise
POP Population and Housing
PUB Public Services
REC Recreation
TRANS Transportation and Traffic
UTIL Utilities and Service Systems
WILD Wildfire

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx

3.1 - Aesthetics, Light, and Glare

3.1.1 - Introduction
This section describes the existing aesthetics, light, and glare conditions in the Plan Area, as well as the relevant regulatory framework. This section also evaluates the possible impacts related to aesthetics that could result from implementation of the proposed project. Descriptions and analysis in this section are based, in part, on the Fresno General Plan (General Plan), Fresno Southeast Development Area (SEDA) Specific Plan (Specific Plan), aerial photos, and the California Department of Transportation (Caltrans) List of Eligible and Officially Designated State Scenic Highways. As further discussed in Chapter 1, Introduction, three public comments were received during the Draft Program Environmental Impact Report (Draft PEIR) scoping period related to aesthetics:
• Requests the Draft PEIR accurately captures and analyzes baseline conditions and potentially significant project-specific and cumulative impacts within and adjacent to the Planning Area. • Requests that the Draft PEIR identifies and adopts all feasible and enforceable mitigation measures that avoid and reduce negative impact.
• Requests that the Draft PEIR analyzes and creates mitigation measures consistent with all applicable laws, including State and federal fair housing, civil rights, and climate laws such as Senate Bill (SB) 743.

3.1.2 - Environmental Setting
Visual Character
City of Fresno
The visual quality and character of the City of Fresno (City) is characterized by various aesthetic attributes, generally located within the Downtown area, suburban and rural residential areas, industrial areas, agricultural areas, and along corridors of major thoroughfares. The Downtown area is the urban center of the City, comprised of high-rise buildings and a variety of land uses. Downtown buildings include mixed-use buildings, theaters, civic/institutional buildings, and industrial warehouses, many of which have historic design elements. The suburbs are characterized by low-rise neighborhood buildings that are primarily dominated by single-family residential uses. The primary industrial areas within the City include the areas south of Downtown, along State Route (SR) 99, and adjacent to the Fresno-Yosemite International Airport, which are characterized by low-rise buildings with manufacturing, processing, and warehouse uses.

Plan Area
The Plan Area is located in the southeastern portion of the City, which is primarily surrounded by agricultural land and single-family residential units. The primary crops in the Plan Area are vineyards, orchards, and vegetables. The Plan Area also contains agriculture-related and commercial operations such as plant nurseries, wineries, and other various agricultural businesses. The second most predominant existing use is rural residential development. There are several constructed drainage features and natural waterways throughout the Plan Area, including Gould Canal, Redbank Slough, City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Dry Creek Canal, Mill Ditch, Fancher Creek Canal, and Briggs Canal. Some canals in the Plan Area are mostly unvegetated and the banks are enforced with rock or broken asphalt and concrete, with some portions fully concrete-lined.

Scenic Resources and Corridors
Scenic resources are defined as natural or man-made elements that contribute to an area’s scenic value and are visually pleasing. Scenic resources include landforms, vegetation, water, or adjacent scenery.

Scenic corridors are channels that facilitate movement (primarily by automobile, transit, bicycle, or foot) from one location to another with expansive views of natural landscapes and visually attractive man-made development. Scenic corridors analyzed under the California Environmental Quality Act (CEQA) typically include State-designated Scenic Highways.

City of Fresno
Scenic resources within the City include landscaped open space areas such as parks and golf courses; areas along the San Joaquin River due to varying topography; and the river bluffs, which provide a unique geological feature in the San Joaquin Valley. Man-made scenic resources include historic buildings in Downtown Fresno, which provide a unique skyline. Corridors are developed with lowrise commercial, residential, and industrial uses that are located along major thoroughfares such as Herndon Avenue, Shaw Avenue, Ventura Avenue/Kings Canyon Road, Blackstone Avenue, and Clovis Avenue. Additionally, General Plan Policy MT-3-a: Scenic Corridors designates several scenic corridors within the City.

According to the Caltrans State Scenic Highway Mapping System, there are no eligible or officially designated State Scenic Highways within the City.1 However, the County has three eligible State Scenic Highways; the nearest eligible highways include a portion of SR-180 and a portion of SR-168.

These portions of eligible highway constitute the closest scenic corridors to the City.

Plan Area
The General Plan does not designate any scenic corridors within the Plan Area. Gateway route designation was contemplated in the General Plan for SR-180, Clinton Way, and Tulare Avenue, all of which run through the Plan Area.

Views
A scenic vista is viewpoint that provides expansive views of a highly valued landscape for the public’s benefit. It is usually viewed from some distance away. Aesthetic components of a scenic vista include (1) scenic quality; (2) sensitivity level; and (3) view access. A scenic vista can be impacted in two ways: a development project can have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view corridors or “vista” of the scenic resource. Important factors in determining whether a proposed project would block scenic vistas include the project’s proposed 1 California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map. Website:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed June 22, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx height, mass, and location relative to surrounding land uses and travel corridors. Typical scenic vistas are locations where views of rivers, hillsides, and open space areas are accessible from public vantage points.

City of Fresno
The approved General Plan does not identify or designate scenic vistas within the Planning Area.

Although no scenic vista has been designated, the City’s General Plan identifies six locations along the San Joaquin River bluffs as designated vista points from which views should be maintained.

Scenic vistas within the City could provide distant views of features such as the San Joaquin River to the north and the foothills of the Sierra Nevada mountains to the east. Distant views of the San Joaquin River and areas north of the river can be seen from the river bluffs. However, the majority of these views are from private property. Partially obstructed views of the San Joaquin River can be seen from Weber Avenue, Milburn Avenue, McCampbell Drive, Valentine Avenue, Palm Avenue, SR41, Friant Road, and Woodward Park. Additionally, there are several locations throughout the eastern portion of the City that provide distant views of the Sierra Nevada foothills. It should be noted that these distant views of the Sierra Nevada foothills are impeded many days during the year by the poor air quality in the San Joaquin Valley Air Basin.

Plan Area
Several areas within the Plan Area, along Kings Canyon Road, for example, provide distant views of the Sierra Nevada foothills. Furthermore, the Plan Area is traversed by several constructed drainage features and natural waterways: Gould Canal, Redbank Slough, Dry Creek Canal, Mill Ditch, Fancher Creek Canal, and Briggs Canal.

Light and Glare
City of Fresno
The majority of the City is urbanized. Significant sources of light and glare, including streetlights, lighting within parking lots, interior lights from Downtown buildings, lighting associated with recreational facilities, and light emitted from residential and non-residential buildings characterize the City. Conversely, rural residential and agricultural areas that are located within the southeastern and western portions of the City are not characterized by significant sources of light and glare.

Project Site
The Plan Area consists primarily of agricultural land, residential uses, which do not create significant sources of light and glare. Existing sources of light and glare include street and traffic lighting as well as car and truck headlights from vehicles traveling along major roads such as Kings Canyon Road.

Some light sources are emitted from residential buildings and public facilities throughout the Plan Area. These lighting sources as well as any buildings and structures made with glass, metal, and polished exterior or roofing materials that exist throughout the Plan Area could result in localized glare.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-4 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx

3.1.3 - Regulatory Framework
State
California Scenic Highway Program
The State Legislature created the California Scenic Highway Program, maintained by Caltrans, in 1963. The purpose of the State Scenic Highway Program is to protect and enhance the natural scenic beauty of California highways and adjacent corridors, through special conservation treatment. The State laws governing the Scenic Highway Program are found in the Streets and Highways Code, Sections 260 through 263. A highway may be designated scenic depending upon how much of the natural landscape can be seen by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the traveler’s enjoyment of the view. The State Scenic Highway System includes a list of highways that are either eligible for designation as scenic highways or have been officially designated. The status of a proposed State Scenic Highway changes from eligible to officially designated when the local governing body applies to Caltrans for scenic highway approval, adopts a Corridor Protection Program, and receives notification that the highway has been officially designated a State Scenic Highway.

Local
Fresno General Plan
The General Plan outlines a long-range vision for the physical development of the City that reflects the community’s vision to preserve the desirable qualities of the existing community while encouraging the aspirations of the community. The following policies relate to aesthetics, light, and glare:

Urban Form, Land Use and Design Element
Policy UF-1-c Identifiable City Structure. Focus integrated and ongoing planning efforts to achieve an identifiable City structure, comprised of a concentration of buildings, people, and pedestrian-oriented activity in Downtown; along a small number of prominent east-west and north-south transit-oriented, mixed-use corridors with distinctive and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi-purpose trails and tree lined bike lanes and streets.

Policy UF-1-e Unique Neighborhoods. Promote and protect unique neighborhoods and mixeduse areas throughout Fresno that respect and support various ethnic, cultural and historic enclaves; provide a range of housing options, including furthering affordable housing opportunities; and convey a unique character and lifestyle attractive to Fresnans. Support unique areas through more specific planning processes that directly engage community members in creative and innovative design efforts.

Policy UF-12-g Impacts on Surrounding Uses. Establish design standards and buffering requirements for high-intensity Activity Centers to protect surrounding residential uses from increased impacts from traffic noise and vehicle emissions, visual City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx intrusion, interruption of view and air movement, and encroachment upon solar access.

Policy UF-13-a Future Planning to Require Design Principles. Require future planning, such as Specific Plans, neighborhood plans or Concept Plans, for Development Areas designated by the General Plan to include urban design principles and standards consistent with the Urban Form, Land Use, and Design Element.

Policy UF-1-f Complete Neighborhoods, Densities, and Development Standards. Use Complete Neighborhood design concepts, development standards, and project reviews outside the Downtown Planning Area to achieve the development of Complete Neighborhoods and the residential density targets of the General Plan.

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

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

Objective LU-1 Establish a comprehensive citywide land use planning strategy to meet economic development objectives, achieve efficient and equitable use of resources and infrastructure, and create an attractive living environment.

Policy LU-2-e Neighborhood Preservation. Incorporate standards in the Citywide Development Code to preserve the existing small-scale residential quality of older neighborhoods.

Policy LU-3-b Mixed-Use Urban Corridors that Connect the Downtown Planning Area. Support the development of mixed-use urban corridors that connect the Downtown Planning Area with the greater Fresno-Clovis Metropolitan Area with functional, enduring, and desirable urban qualities along the Blackstone Avenue, Shaw Avenue, California Avenue, and Ventura Avenue/Kings Canyon Road corridors.

Policy LU-4-a Neighborhood Nuisance Abatement. Continue proactive and responsive code enforcement and nuisance abatement programs to improve the attractiveness of residential neighborhoods.

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

Policy LU-6-a Design of Commercial Development. Foster high quality design, diversity, and a mix of amenities in new development with uses through the consideration of guidelines, regulations and design review procedures.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Policy LU-6-b Commercial Development Guidelines. Consider adopting commercial development guidelines to assure high quality design and site planning for large commercial developments, consistent with the Urban Form policies of the General Plan.

Policy LU-6-d Neighborhood and Community Commercial Center Design. Plan for neighborhood mixed use and community commercial uses to implement the Urban Form concepts of the General Plan, promote the stability and identity of neighborhood and community shopping areas, and allow efficient access without compromising the operational effectiveness of the street system. • Neighborhoods will be anchored by community commercial centers with a mix of uses that meet the area’s needs and create a sense of place.

Policy LU-6-e Regional Center Planning and Design. Promote economic growth with regional commercial centers.
• Regional shopping centers will have internally-unified building design, landscaping, and signage standards.

Policy LU-6-f Auto-Oriented Commercial Uses. Direct highway-oriented and auto-serving commercial uses to locations that are compatible with the Urban Form policies of the General Plan. Ensure adequate buffering measures for adjacent residential uses noise, glare, odors, and dust.

Policy LU-9-e Downtown Sightline. Require new development to preserve existing sightlines to Downtown to the extent feasible.

Policy LU-9-f View Corridors. Promote new view corridors that highlight the Downtown skyline.

Objective D-1 Provide and maintain an urban image that creates a “sense of place” throughout Fresno.

Policy D-1-d Public Art. Continue to promote a citywide public art program that contributes to an awareness of the City’s history and culture.

Policy D-1-e Graphic Identity. Continue the preservation, promotion, procurement and strategic location of landmarks, monuments and artwork that provide orientation and represent Fresno’s cultural heritage and artistic values.

Objective D-2 Enhance the visual image of all “gateway” routes entering the Fresno Planning Area.

Policy D-2-a Design Requirements for Gateways. Consider unified design requirements for gateways to welcome travelers to the City’s Activity Centers.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Policy D-2-c Highway Beautification. Work with Caltrans, the Fresno Council of Governments, Tree Fresno, neighboring jurisdictions, and other organizations to obtain funding for highway beautification programs.

Objective D-3 Create unified plans for Green Streets, using distinctive features reflecting Fresno’s landscape heritage.

Policy D-3-a Green Street Tree Planting. Create a Green Street Tree Planting Program, with a well-balanced variety and spacing of trees to establish continuous shading and visual continuity for each streetscape. Strive to achieve coherent linkages between public and private spaces, prioritizing tree planting along tree-deficient Arterial and Collector Roadways in neighborhoods characterized by lower per capita rates of vehicle ownership.

Policy D-3-b Funding for Green Street Tree Planting Program. Pursue funding for the Green Street Tree Planting Program, including landscaping of median islands.

Policy D-3-c Local Streets as Urban Parkways. Develop local streets as “urban parkways,” where appropriate, with landscaping and pedestrian spaces.

Policy D-3-d Undergrounding Utilities. Partner with utility companies to continue to pursue the undergrounding of overhead utilities as feasible.

Objective D-4 Preserve and strengthen Fresno’s overall image through design review and create a safe, walkable and attractive urban environment for the current and future generations of residents.

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

Objective D-5 Maintain and improve community appearance through programs that prevent and abate blighting influences.

Policy D-5-a Code Enforcement. Continue enforcement of the Fresno Municipal Code to remove or abate public nuisances in a timely manner.

Policy D-5-b Clean Streets. Promote community partnerships and continued City efforts toward litter clean-up and abatement of trash stockpiles on public and private streets.

Policy D-5-c Facade Improvements. Pursue funding for, and support of, building facade improvement programs.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Policy D-5-d Graffiti Prevention and Abatement. Seek ways to end graffiti, continue and expand the City’s effective Graffiti Abatement Program.

Policy D-6-b Consider adopting and implementing incentives for, and support efforts by, private development to incorporate culturally-specific architectural elements in areas with a predominant ethnic population.

Mobility and Transportation Element
Objective MT-3 Identify, promote and preserve scenic or aesthetically unique corridors by application of appropriate policies and regulations.

Policy MT-3-a Scenic Corridors. Implement measures to preserve and enhance scenic qualities along scenic corridors or boulevards, including:
• Van Ness Boulevard–Weldon to Shaw Avenues
• Van Ness Extension–Shaw Avenue to the San Joaquin River Bluff–Kearney Boulevard–Fresno Street to Polk Avenue
• Van Ness-Fulton couplet–Weldon Avenue to Divisadero–Butler Avenue–Peach to Fowler Avenues
• Minnewawa Avenue–Belmont Avenue to Central Canal–Huntington Boulevard– First Street to Cedar Avenue
• Shepherd Avenue–Friant Road to Willow Avenue–Audubon Drive–Blackstone to Herndon Avenues
• Friant Road–Audubon to Millerton Roads
• Tulare Avenue–Sunnyside to Armstrong Avenues
• Ashlan Avenue–Palm to Maroa Avenues
Policy MT-3-b Preserve street trees lining designated scenic corridors or boulevards. Replace trees of the predominant type and in a comparable pattern to existing plantings if there is no detriment to public safety.

Fresno Southeast Development Area Specific Plan
The Fresno SEDA Specific Plan is framed within three significant and interrelated goals: fiscal responsibility, social equity, and environmental sustainability. The proposed Plan and policies that form its implementation framework are formulated and coordinated to meet the criteria of these overlapping goals. The proposed Specific Plan contains the following policies and programs related to aesthetics, light, and glare:

Urban Form Element
Objective UF-2 Provide a mix of Regional, Community, and Neighborhood Town Centers where individuals can live, work and play.

Policy UF-2.2 Development Code Update. The size, density, composition, and building character of Mixed-Use Districts will be consistent with the zone district standards set forth in the SEDA Development Code Update. In addition, the Plan will call upon the City of City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Fresno’s Department of Public Works Standards, the Active Transportation Plan and the Fresno Area Express (FAX) transit plans to implement streetscape design and non-auto circulation elements.

Policy UF-2.3 Design and Development Principles. The following principles are provided to guide the creation of public and private spaces within the Plan Area. More specific guidelines and regulations regarding many of these elements are found in the SEDA Development Code update section of this Chapter.
• Pattern of streets, blocks, and buildings: The centers will be designed with pedestrian oriented streets, blocks, buildings, and public spaces based on the block connectivity and size standards specified in the SEDA Development Code update, including a transportation network which will be based on a high-density grid system. Public spaces and civic buildings shall be arranged along streets in order to create a network of civic spaces of varying size and function. • Building character and orientation: The character, massing, and orientation of buildings will contribute to a cohesive urban fabric that reinforces public spaces, creates a sense of intimacy, and visually distinguishes the center from surrounding districts.

As shown in Figure 2.1 regarding building orientation, the front edges of buildings shall meet or approach front and side property lines according to the requirements of the SEDA Development Code update. Visual diversity will be created through variations in setback, massing, and architectural details. In addition, solar exposure and orientation shall be considered in the layout and design of all streets, blocks, and buildings to maximize energy and resource efficiency.
• Center core: Each town center will feature a core that provides a common gathering place for Southeast Fresno residents not only within the center, but surrounding districts as well. The core will accommodate the highest capacity for retail, employment, civic, and pedestrian activity of each center, and will design streets and buildings with pedestrian comfort and visual interest at the forefront. • Location and orientation of commercial activity: Commercial activity is permitted throughout Regional and Community Town Centers, but the highest-intensity commercial uses (and/or ground floor commercial) will be located along all Arterials and Collector Streets and in the core area of the town center. Small convenience retail establishments, such as corner stores, can also occupy a portion of the ground floors of residential and office buildings outside of the core of centers. Ideally, office uses should be clustered around public transit stations and squares.
• Location and orientation of large-format retail activity: Large-format retail establishments (i.e., “big box” retail) may be located in the Regional Town Center but are discouraged in Community or Neighborhood Town Centers in order to City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx preserve the local neighborhood character of those areas. The urban design and parking standards of large-format retail stores will be consistent with the standards and policies of these districts. Large-format retail establishments served by surface parking will be located at the edges of the Regional Town Center, preferably adjacent to major regional roadways or highways. • Character, location, and orientation of public spaces: Public gathering places that provide visual relief and passive recreation should be located in the Mixed-Use Districts and should be surrounded by civic buildings and any commercial or mixed-use buildings located in the town center.
• Location and orientation of civic buildings: Major civic buildings (e.g., libraries, schools, and government offices) will serve as focal points of public spaces within centers. Providing attention to distinctive building details, entry features and varying setbacks will allow civic buildings to stand out from other structures in the center. Wherever possible, civic buildings will be located in proximity to and open onto public spaces.

Objective UF-3 Foster a community of tight-knit residential districts.

Policy UF-3.2 Development Code Update. The size, density, composition, and building character of Residential Districts will be consistent with the SEDA zone district standards implemented through a Development Code update. Streets and non-auto circulation elements will be implemented according to the standards set in the Development Code.

Objective UF-4 Attract high-profile businesses to create bustling and desirable Employment Districts.

Policy UF-4.2 Development Code Update. The size, density, composition, and building character of Employment Districts will be consistent with the proposed SEDA zone district standards set forth in the SEDA Development Code update. In addition, the Plan will draw upon the City of Fresno’s Department of Public Works Standards, the Active Transportation Plan, and the Fresno Area Express (FAX) transit plans to implement streetscape design and non-auto circulation elements.

Objective UF-7 Create a parking strategy to address current and future needs.

Policy UF-7.3 Parking Design. Support vibrant, walkable, and accessible communities by successfully integrating and managing parking facilities within the urban fabric. • Surface lot Standards: Integrate a site design that is pleasant, convenient, and unobtrusive to the streetscape.
- Connecting walkways shall be provided to afford convenient pedestrian access from the interior of parking areas to nearby buildings or open spaces.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx - Landscaped setbacks with a minimum width of 10 feet shall be provided wherever a surface parking lot abuts a street; this may include the use of landscape material, land forms, rockeries, trellises, colonnades, and other elements.
- Landscaped islands shall be installed at the ends of all on-grade parking bays and shall contain one tree per adjacent stall.
- Landscaped medians shall have a minimum width of 8 feet from back of curb to back of curb.
- Paving and planting materials shall be approved by the Planning and Development and Public Works Directors.
• Structured Lot Standards: Enable structure design similar to the surface lot standards that is pleasant, convenient, and unobtrusive to the streetscape. - Residential parking structures should be shielded from the street on all sides by other uses.
○ Public parking structures within one block of the Super Arterials and Arterials of the Regional or Community Town Centers shall provide ground floor retail, commercial, office, or other pedestrian-compatible use for at least 70% of their street frontage (except to the extent that frontage minimums interfere with minimum access requirements).
○ Minimize heat island effect and urban stormwater runoff ○ Install planting, shading and paving techniques to minimize environmental impacts of parking facilities.
○ For vegetative shading, please refer to City of Fresno Performance Standards for Parking Lot Shading 9Fresno Development Code Section 15-2421). - Soil and planting materials on surface lots shall serve to:
○ Suppress sediment movement
○ Trap sediment-attached substances
○ Encourage infiltration
○ Encourage nutrient-fixing and absorption of flushed surface contaminants during detention and infiltration
- Paving in high0density and commercial areas should consist of pervious pavement systems or equivalent technology, achieving a reduction of not less than 50% net impervious cover, for at least 50% of total pavement areas as compared to a typical concrete or asphalt paving system. - Materials with a minimum solar reflectance index (SRI) of 29 should be used on at least 50% of all impervious parking surfaces (including roofing over covered parking stalls).
• Accessible Parking: The Plan Area will provide for accessible parking in accordance with the ADA standards and Title 24 California Building Code and onstreet in accordance with the best practices of the Pedestrian Rights of Way Accessibility Guidelines (PROWAG).
• Preferential Parking: Provide preferential parking to encourage more sustainable travel behavior.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx - Develop pro-rata requirements for the provision of preferential non-residential parking for, but not limited to, all of the following modes of transportation in order of importance (high to low):
○ Bicycles
○ Motorcycles
○ Carshare Vehicles
○ Electric Vehicles
○ Carpools/vanpools
Open Space Element
Objective OS-2 Create and maintain an open space network that serves multiple purposes, including recreation, stormwater management, community farming, and environmental preservation.

Policy OS-2.2 Passive Open Space. Support natural landscapes and wildlife habitat corridors by maintaining passive open spaces.
• Work with local land trusts to establish conservation easements that preserve land as part of the SEDA open space network.

Policy OS-4.1 Multi-Use Trails. Establish a planned network of multi-use greenway trails. These trails will serve bicyclists, pedestrians, and, where appropriate, equestrians. Cross sections and width requirements will be provided for specific conditions— including canal side, open space, streetside, and farm side trails.

Policy OS-4.3 Trail Standards. Trails shall be designed with features that encourage use, provide safety, and are resource-efficient. Trail standards shall address shading, low-water landscaping, fencing, paving and surface materials, lighting, seating and furniture, ADA access requirements, signage, and intersection treatments.

Community Farming and Agricultural Element
Objective CF-2 Create a long-term transition zone between urban uses in the City of Fresno and agricultural land in Fresno County. Buffering urban and adjoining agricultural land uses reduce conflicts that can arise due to noise, pollution, or traffic.

Policy CF-2.2 Passive Recreation. Encourage the creation of regional trails and open spaces in Rural Cluster Districts that connect urban uses to agricultural uses with trails for pedestrians, bicyclists, and equestrians.
• What is the role of rural cluster development?
- A transitional buffer. Urban areas and large agricultural operations cannot always sit side-by-side. Noise, dust, and pesticides from farms can pose health concerns for residents, while farmers need space to move machinery and goods. Rural clusters along the eastern edge of SEDA form a transition between the urban area and the agricultural lands beyond.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx - An attractive residential option. Rural clusters offer a rural lifestyle within an environmentally responsible land use framework that promotes active farming and open space preservation.
- A means to preserve land. Rural cluster lands can be used for organic smallscale 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.

Objective CF-3 Promote community farming to provide opportunities for entrepreneurs and families to grow food for commercial and household production. Community farming is intended, in part, to diversify agriculture and make residents of the Southeast Development Area stakeholders in the success of Fresno County agriculture.

Policy CF-3.3 Community Farming. Create and expand a viable community farming program that promotes an appreciation of food and local ecology, instills a sense of stewardship and community, and provides a recreational activity. • Community/Neighborhood Gardens. Create and support neighborhood gardens within local communities. Neighborhood gardens, such as Yo’Ville Community Garden in Southwest Fresno, are woven into the fabric of centers and residential areas, providing households with opportunities to grow some of their own produce and meet with other members of the community.
- Location. Neighborhood gardens shall be integrated into Neighborhood Centers, open spaces, and other locations that place them within walking distance of most residents’ homes.
- Access. Access to community spaces can vary. Gardens can be open to the public, or only to designated users.
- Management. Management structures of community spaces shall be determined as appropriate. Neighborhood gardens can be owned by a city or county agency or by a private landowner, and operated by a neighborhood collective, community garden association, non-profit, or city/county parks and recreation department that leases small plots of the garden to community members. Some neighborhood gardens are independent entities, while some jurisdictions have neighborhood garden programs that oversee all the gardens in a jurisdiction.
- Funding and staff assistance. The City of Fresno shall encourage neighborhood organizations to seek funding for the neighborhood garden program and/ or facilitate assistance through the Fresno Parks, After School, Recreation, and Community Services Department or other
agency/organization.
• School Gardens. Support and foster the integration of school gardens within neighborhood schools, such as the school garden located at Kepler Neighborhood School in Downtown Fresno. School gardens can serve as outdoor City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx classrooms where students learn about soil, botany, natural cycles, nutrition, and basic gardening principles in a hands-on setting.
- Location. School gardens should be located on school grounds, or within a very short walk of a school. When possible, school gardens should be planned upon new school construction in order to maximize joint-use opportunities with the City of Fresno Parks, After School, Recreation, and Community Services Department.
- Access. Access should be controlled based on school district policies. - Management. Management structures shall be determined as appropriate.

School gardens are typically managed by at least one garden coordinator who works closely with school administration or one or more dedicated teachers. - School gardens working group. Create a working group of teachers, students, and residents to explore the development of school garden programs in the Clovis and Sanger Unified School Districts.
• Community Orchards. Support and preserve community orchards for both new and existing orchards within the SEDA. Community orchards can be integrated into the community’s open space network, serving as park-like features and enhancing connections to agriculture.
- Location. Community orchards can be integrated into public open spaces or associated with private development.
- Access. Community orchards should be unfenced, with high levels of public access.
- Management. Management structures shall be determined as appropriate. In a typical model, residents help to care for the orchards and pay fees to fund professional gardeners.

Conservation Element
Objective RC-1 Meet statewide targets set for greenhouse gas emissions reductions as set forth in the City’s updated GHG Reduction Plan, adopted in 2021.

Policy RC-1.7 Urban Forestry Program. Encouraging the integration and protection of new and existing mature trees within our communities can lead to significant reductions in the urban heat island effect and energy required for cooling. As another significant benefit, trees also store harmful carbon as they grow, in a process known as sequestration. As these trees continue to grow, mature and sequester carbon, it is also important for urban forestry projects to consider potential tree emissions that result from the maintenance and ultimate disposition of trees to ensure a net decrease in greenhouse gas emissions occurs.

Maintaining trees, vegetation and plants throughout City parks is important to the success and longevity of these publicly owned spaces. In addition, these areas provide opportunities for new tree planting and replacement of tree species that possess a low potential to store carbon, with tree species that possess higher carbon storage potential. To better understand how to achieve these City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx opportunities, there are many tools that communities can utilize. The Climate Action Reserve, Urban Forest Project Reporting Protocol (CAR 2019) provides criteria for generating greenhouse gas emission offsets with tree planting along with procedures for project monitoring.

Development of the SEDA will present many opportunities for the strategic planting of trees with high carbon storage potential, as noted below:
• Develop a tree palette for the SEDA that reinforces its sense of place, reflects native species, and includes tree species with high carbon storage potential. • Meet parks shading targets noted in the Parks Master Plan. • Plant shade trees to delineate corridors and the boundaries of urban areas, and to provide tree canopy for bike lanes, sidewalks, parking lots, trails and transit stops.

Cultural and Historic Resource Policies Element
Objective CR-3 Identify and protect significant structures, sites and landscapes within the Southeast Development Area.

Policy CR-3.6 Resource Protection. Incorporate historic sites, infrastructure and landscape features into new developments in order to conserve resources and preserve the area’s vernacular landscape and “sense of place.”
Fresno Municipal Code
Chapter 13 Article 3 of the Municipal Code outlines the Public Tree Policy, Tree Beautification policies, and Tree Preservation policies.2
Fresno Citywide Development Code
Chapter 15 of the Municipal Code outlines the Citywide Development Code, which implements the General Plan by providing a precise guide for the physical development of the City, to promote high quality architecture and sustainable design, to promote a safe and efficient traffic circulation system, including bicycle facilities and pedestrian amenities, and to support a multimodal transportation system, to facilitate the appropriate location of community facilities, institutions, parks, and recreational areas, and to safeguard and enhance the appearance of the City. The regulations in the Development Code vary for various zoning districts but include metrics such as density and massing, site design, façade design, and use regulations.
3 Article 23 of the Development Code outlines landscaping design regulations.4 2 City of Fresno. Fresno Municipal Code Chapter 13 – Sidewalks, Streets, Parkways, and Underground Utility Districts. Website:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH13SISTPAUNUTDI_ART3STTRPA. Accessed June 22, 2022. 3 City of Fresno. Fresno Municipal Code Chapter 15 – Citywide Development Code, Including Revisions. Website:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH15CIDECOINRE. Accessed March 22, 2023. 4 City of Fresno. Fresno Municipal Code Chapter 15 – Citywide Development Code, Including Revisions. Article 23 – Landscape.

Website:

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Article 24 of the Development Code outlines parking area development standards.5 Article 26 of the Development Code outlines regulations for signage.6 Fresno General Plan PEIR Mitigation Measures
The Fresno General Plan Program Environmental Impact Report (General Plan PEIR) contains the following mitigation measures that are applicable to the proposed project.

MM AES-4.1 Lighting for Street and Parking Areas
Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residences.

MM AES-4.2 Lighting for Public Facilities
Lighting systems for public facilities such as active play areas shall provide adequate illumination for the activity; however, low intensity light fixtures and shields shall be used to minimize spillover light onto adjacent properties.

MM AES-4.3 Lighting for Nonresidential Uses
Lighting systems for nonresidential uses, not including public facilities, shall provide shields on the light fixtures and orient the lighting system away from adjacent properties. Low intensity light fixtures shall also be used if excessive spillover light onto adjacent properties will occur.

MM AES-4.4 Signage Lighting
Lighting systems for freestanding signs shall not exceed 100 footlambert (ft-L) when adjacent to streets which have an average light intensity of less than 2.0 horizontal foot-candles and shall not exceed 500 ft-L when adjacent to streets which have an average light intensity of 2.0 horizontal foot-candles or greater.

MM AES-4.5 Use of Non-Reflective Materials
Materials used on building facades shall be non‐reflective. https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH15CIDECOINRE_PTIIIREAPSOALDI_ART23 LA. Accessed March 22, 2023. 5
City of Fresno. Fresno Municipal Code Chapter 15 – Citywide Development Code, Including Revisions. Article 24 – Parking and Loading. Website:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH15CIDECOINRE_PTIIIREAPSOALDI_ART24 PALO. Accessed March 22, 2023. 6
City of Fresno. Fresno Municipal Code Chapter 15 – Citywide Development Code, Including Revisions. Article 26 – Signs. Website:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH15CIDECOINRE_PTIIIREAPSOALDI_ART26 SI. Accessed March 22, 2023.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx

3.1.4 - Methodology
Impacts related to aesthetics resulting from implementation of the proposed project are discussed below. The impact analysis is based on the existing visual character of the Plan Area, including scenic vistas, highways, roadways, and existing sources of light and glare. Changes to aesthetic resources that may occur from implementation of the proposed project are identified and qualitatively evaluated based on potential modifications to the existing aesthetic setting.

3.1.5 - Thresholds of Significance
The lead agency utilizes the criteria in the CEQA Guidelines Appendix G Environmental Checklist as thresholds to determine whether impacts to aesthetics are significant environmental effects.

Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts to resources are significant. These questions reflect the input of planning and environmental professionals at the Governor’s Office of Planning and Research and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. Accordingly, the City has derived its significance criteria, based in part on the questions posed in Appendix G.

These significance criteria are as follows:

Would the project:

Except as provided in Public Resources Code Section 21099, the project would have a significant impact on the environment if it would:
a) Have a substantial adverse effect on a scenic vista. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway. c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality.
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

3.1.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the proposed project and provides mitigation measures where appropriate.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Impact Analysis
Future development under the proposed project would have significant impacts to scenic vistas and/or scenic corridors if new development blocks views from scenic vistas and/or scenic corridors.

Potential impacts could include obstructed views of a scenic vista or scenic corridor from public viewpoints or modification of the scenic vista or scenic corridor.

The General Plan does not identify any scenic vistas from within the City. Although the General Plan identifies six locations as publicly valued scenic features along the San Joaquin River bluffs, the river bluffs are not visible from the Plan Area due to the flat topography of the City. General Plan Policy MT-3 identifies scenic corridors in the City, none of which are located within the Plan Area. However, the General Plan contemplated gateway route designation for SR-180, Clinton Way, and Tulare Avenue, all of which run through the Plan Area. The existing General Plan policies and proposed Specific Plan policies identified below would guide the development of these gateways such that their aesthetic quality would be promoted and preserved.

The General Plan includes policies intended to protect scenic vistas and scenic corridors in the City.

Policy D-1-e requires the continued preservation, promotion, procurement, and strategic location of landmarks, monuments and artwork that provide orientation and represent Fresno’s cultural heritage and artistic values. Policy D-2-a considers unified design requirements for gateways to welcome travelers to the City’s Activity Centers. Policy D-2-c seeks out funding for highway beautification. Policy D-3-a requires the creation of a Green Street Tree Planting Program. Policy D-5- b promotes City efforts toward litter clean up and abatement. Policy MT-3-b requires that the preservation of street trees lining designated corridors or boulevards.

The Specific Plan also includes proposed policies intended to protect scenic vistas and scenic corridors in the City. Policy RC-1.7 encourages integration, protection, and maintenance of new and existing mature trees in the community as well as vegetation and plants throughout City parks.

Any future individual development projects would be reviewed by the City for compliance with the Development Code, which provides a precise guide for the physical development of the City, promotes high quality architecture and sustainable design, and aims to safeguard and enhance the appearance of the City. In addition, all future development would be required to comply with the objectives and policies of the General Plan and Specific Plan designed to protect scenic resources and natural features. At the programmatic level, aesthetic impacts to views would be reduced to a less than significant level. Consistent with the existing General Plan and proposed Specific Plan policies, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or project-specific measures to reduce any potential impacts and would ensure that impacts remain less than significant.

Level of Significance Before Mitigation
Less than significant impact.

Fresno General Plan PEIR Mitigation Measures
None.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Project Specific Mitigation Measures
None.

Scenic Highways
Impact AES-2: The proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway.

Impact Analysis
Scenic highways are California highways designated by a local governing body and protected by the State Scenic Highway Program for the purpose of protecting and enhancing the natural scenic beauty of California highways and adjacent corridors through special conservation treatment. There are no officially designated State Scenic Highways in the City and thus no view corridors in the Plan Area. 7 As a result, the proposed project would result in no impact to scenic highways.

Level of Significance Before Mitigation
No impact.

Fresno General Plan PEIR Mitigation Measures
None.

Project Specific Mitigation Measures
None.

Visual Character
Impact AES-3: The proposed project would in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point).

Impact Analysis
Future development allowed by the Specific Plan could degrade the visual character of the Plan Area if the form and appearance of new development deteriorate the quality of the existing setting. As described above, the Plan Area exhibits a predominantly agricultural and rural residential character.

Future development allowed by the Specific Plan would introduce intensified building development compared with what is currently characteristic of the Plan Area. However, some rural residential, open space, and agricultural land uses would be preserved.

The proposed project includes updates to the Development Code to implement the proposed land use and zoning updates. The Specific Plan also includes policies intended to guide the visual character of the Plan Area to ensure visually appealing and cohesive design. Policy UF-2.3 outlines 7 California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map. Website:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed June 22, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-20 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx design principles for the character of buildings, streets blocks, commercial uses, and town centers.

Policy UF-7.3 supports vibrant, walkable, and accessible communities by enabling parking lot design that is pleasant unobtrusive to the streetscape by adhering to listed standards. Policy OS-2.2 supports natural landscape and wildlife habitats by encouraging the maintenance of passive open spaces. Policy OS-4.1 encourages the establishment of a planned network of multiuse greenway trails. Policy CF-3.3 encourages the expansion of a viable community farming program, which would help preserve the agricultural character of the area. Lastly, Policy CR-3.6 requires the incorporation of historic sites, infrastructure, and landscape features into new developments to preserve the Plan Area’s sense of place.

The Specific Plan includes updates to the Development Code, which would require that the size, density, composition, and building character of residential districts be consistent with the SEDA Land Use District Standards set forth in the SEDA Development Code Update. These updates, along with Specific Plan policies, would guide the development of the area such that visual quality is maintained. Any future individual development projects would be reviewed by the City for compliance with the Development Code, which provides a precise guide for the physical development of the City, promotes high quality architecture and sustainable design, and aims to safeguard and enhance the appearance of the City. In addition, all future development would be required to comply with the policies and actions of the General Plan and Specific Plan designed to protect visual character and quality. Consistent with the General Plan and Specific Plan policies, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or project-specific measures to reduce any potential impacts.

However, buildout of the Specific Plan would alter the existing visual character by increasing the intensity of development in many areas that are primarily agricultural. No feasible mitigation measures are available to mitigate the impact to a less than significant level. Therefore, impacts are considered significant and unavoidable.

Level of Significance Before Mitigation
Potentially significant impact.

Fresno General Plan PEIR Mitigation Measures
None.

Project Specific Mitigation Measures
None.

Level of Significance After Mitigation
Significant and unavoidable impact.

Light and Glare
Impact AES-4: The proposed project would create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Impact Analysis
All future development in accordance with the Specific Plan would result in land use changes within the Plan Area. These land use changes include the development of new residential and nonresidential land uses.

Intensified development in the Plan Area could increase the amount of light from streetlights, exterior lighting from buildings, and vehicle headlights. The increase in lighting within the Plan Area could result in light spillover onto adjacent areas and could substantially illuminate the sky during nighttime. This increase in illumination is considered a significant impact.

Many areas directly adjacent to the Plan Area are exposed to a small amount of light due to the existing rural and agricultural setting. Intensified development in the Plan Area would considerably increase the amount of lighting systems within the Plan Area, which could result in an increase in light spillover to adjacent areas. Furthermore, increased nighttime traffic resulting from intensified development would create additional sources of light from car headlights. Therefore, development would increase the amount of light, causing spillover onto properties adjacent to the Plan Area and an increase in the nighttime sky illumination. This increase in light is considered a significant impact.

Development in accordance with the proposed Specific Plan and the Development Code would increase the number of new structures that could create new sources of glare within the Plan Area and directly adjacent to the Plan Area. These new sources of glare could result from materials used on building façades, parking lots, signs, roadway surfaces, and motor vehicles. Because of the amount of new building square footage planned for the Plan Area, new buildings would result in a substantial increase in glare. This increase could result in significant glare impacts.

Future development facilitated by implementation of the proposed project would be required to comply with the lighting standards established in the City Municipal Code (Article 25, Performance Standards). Future development would also comply with the proposed Specific Plan policies related to light and glare including Policy OS-4.3, which provides guidance on lighting standards for trails.

Further, the General Plan does not include any specific existing policies related to light and glare; however, the General Plan PEIR includes Mitigation Measure (MM) AES-1, which requires outdoor lighting to include shields; MM AES-2, which requires lighting in public locations to have enough light for activities but while minimizing light spill; MM AES-3, which requires light to be oriented away from other residential uses; MM AES-4, which requires freestanding signs to not exceed 100 footlambert (ft-L); and MM AES-5, which restricts use of reflective surfaces. These mitigation measures are applicable to the proposed project, and implementation of MM AES-1 through MM AES-5 would reduce impacts related to light and glare.

Consistent with the existing General Plan and proposed SEDA Specific Plan policies, individual development projects would be required to undergo project-specific environmental review, which may require additional site-specific or project-specific measures to reduce any potential impacts. For example, all future development would be required to comply with glare standards established City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-22 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Article 25 of the Municipal Code.8 Additionally, implementation of MM AES-1 through MM AES-5 would reduce potential glare impacts resulting from the proposed project. However, impacts would remain significant and unavoidable.

Level of Significance Before Mitigation
Potentially significant impact.

Fresno General Plan PEIR Mitigation Measures
As noted in the regulatory discussion, Section 3.1, the following mitigation measures from the General Plan PEIR are applicable to the proposed project.

MM AES-4.1 Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residences.

MM AES-4.2 Lighting systems for public facilities such as active play areas shall provide adequate illumination for the activity; however, low-intensity light fixtures and shields shall be used to minimize spillover light onto adjacent properties.

MM AES-4.3 Lighting systems for nonresidential uses, not including public facilities, shall provide shields on the light fixtures and orient the lighting system away from adjacent properties. Low-intensity light fixtures shall also be used if excessive spillover light onto adjacent properties will occur.

MM AES-4.4 Lighting systems for freestanding signs shall not exceed 100 footlambert (ft-L) when adjacent to streets which have an average light intensity of less than 2.0 horizontal foot-candles and shall not exceed 500 ft-L when adjacent to streets that have an average light intensity of 2.0 horizontal foot-candles or greater.

MM AES-4.5 Materials used on building façades shall be non-reflective.

Project Specific Mitigation Measures
None.

Level of Significance After Mitigation
Significant and unavoidable impact.

3.1.7 - Cumulative Impacts
The geographic scope of the cumulative impact analysis for aesthetics is the Plan Area and portions of the City of Fresno, City of Clovis, and unincorporated Fresno County located outside of the Plan Area that can be viewed from and have views of the Plan Area. This analysis evaluates whether 8 City of Fresno. Fresno Municipal Code Chapter 15 – Citywide Development Code. Website:
https://library.municode.com/ca/fresno/codes/code_of_ordinances?nodeId=MUCOFR_CH15CIDECOINRE_PTIIIREAPSOALDI_ART25 PEST. Accessed June 22, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Aesthetics, Light, and Glare
FirstCarbon Solutions 3.1-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx impacts of the Specific Plan, together with impacts of cumulative development, would result in a cumulatively significant impact with respect to aesthetics. This analysis then considers whether incremental contribution of the impacts associated with implementation of the Specific Plan would be significant. Both conditions must apply for cumulative effects to rise to the level of significance.

In general, potential visual impacts to the character of an area take into account the immediate surroundings; thus, the analysis of cumulative aesthetic impacts focus on areas that share a viewshed with the Plan Area. The Plan Area and most of the surrounding area is predominately rural and rural residential. Future development in the cumulative context would include new residential, commercial, and industrial development consistent with the General Plan or the applicable General Plans of each of the surrounding municipalities. Future development would be subject to the design review processes of the individual jurisdiction, and the applicable land use plans contain policies and implementing actions to preserve visual character, land use compatibility, and views in those jurisdictions. Cumulative projects within the City would be required to comply with applicable City General Plan policies and programs and adhere to development and design standards in the Municipal Code that address aesthetics, including lighting and glare, the alteration of scenic resources and natural features, the alteration of views of scenic resources and natural features.

However, consistent with the findings of the General Plan PEIR, continued buildout of the General Plan and nonagricultural development in the surrounding communities identified by the geographic scope would continue to significantly change the visual character of the area and amount of nighttime illumination, even with adherence to General Plan policies and project-specific design review. For these reasons, cumulative impacts to aesthetics or nighttime lighting and daytime glare would be significant.

As previously discussed above, there are no designated scenic vistas or State-designated Scenic Highways in the Plan Area or the City. The proposed project and cumulative development would be subject to specific regulations and guidelines related to building heights, setbacks, undergrounding of utilities, landscaping, signage, and permitted land uses. However, cumulative development is anticipated to contribute to the conversion of rural and agricultural uses to urban uses. This cumulative change is expected to result in a substantial alteration of the existing visual character of the area. Additionally, the project’s contribution to light and glare is also expected to generate new sources of light and glare, even with the implementation of MM AES-1 through MM AES-5. These new sources of glare could result from materials used on building façades, parking lots, signs, roadway surfaces, and motor vehicles. Therefore, the proposed project could result in cumulatively considerable visual character and light and glare impacts. Thus, overall, the project would result in significant and unavoidable cumulative impacts.

Level of Cumulative Significance Before Mitigation
Potentially significant impact.

Fresno General Plan PEIR Mitigation Measures
Implementation of MM AES-4.1 through MM AES-4.5.

City of Fresno—Fresno Southeast Development Area Specific Plan Aesthetics, Light, and Glare Draft Program EIR

3.1-24 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-01 Aesthetics.docx Project Specific Mitigation Measures
None.

Level of Cumulative Significance After Mitigation
Significant and unavoidable impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx

3.2 - Agricultural Resources and Forestry Resources

3.2.1 - Introduction
This section of the Administrative Draft Program Environmental Impact Report (Draft PEIR) describes the existing agricultural and forestry resources in the Plan Area as well as the relevant regulatory framework. This section also evaluates the possible impacts related to agricultural and forestry resources that could result from implementation of the project. Descriptions and analysis in this section are based, in part, upon existing site conditions, plans/exhibits of the Planning Area, the Fresno General Plan (General Plan), and the California Department of Conservation website as well as aerial photographs, topographical maps, and street maps.

Eleven public comments were received during the EIR scoping period related to Agricultural Resources and Forestry Resources:
• Request to consider whether agricultural conservation easements are feasible mitigation. • Request for the Draft PEIR to discuss the type, amount, and location of farmland conversion resulting from the proposed project.
• Request for the Draft PEIR to evaluate impacts on any current or future agriculture operations in the vicinity.
• Requests for the Draft PEIR to evaluate incremental impacts leading to cumulative impacts on agricultural land.
• Request for the Draft PEIR to include mitigation measures for impacts to agricultural land. • Requests for the Draft PEIR to evaluate the proposed project’s compatibility with any agricultural land enrolled in a Williams Act Contract and for the notification to the Department of Conservation of non-renewal and/or cancellation of a Williams Act Contract. • Recommendations that the current and former agricultural lands in the Plan Area be evaluated in accordance with Department of Toxic Substances Control (DTSC) 2008 Interim Guidance for Sampling Agricultural Properties (Third Addition). • Recommendations that any construction and/or development within an Agricultural Preserve consult with/obtain approval from the County Policy and Planning Department. • Requests that the Draft PEIR accurately captures and analyzes baseline conditions and potentially significant project-specific and cumulative impacts within and adjacent to the Plan Area.
• Requests that the Draft PEIR identify and adopt all feasible and enforceable mitigation measures that avoid and reduce negative impacts.
• Requests that the Draft PEIR analyze and create mitigation measures consistent with all applicable laws, including State and federal fair housing, civil rights, and climate laws such as Senate Bill (SB) 743.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx

3.2.2 - Environmental Setting
City of Fresno
According to the General Plan PEIR, the City of Fresno’s (City) Sphere of Influence (SOI) contains approximately 9,134 acres of Prime Farmland, approximately 3,224 acres of Unique Farmland, and approximately 2,269 acres of Farmland of Statewide Importance (totaling approximately 14,627 acres), as mapped by the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP).
1 Based on existing farmland data received from the Fresno County Assessor’s Office Land Use Codes that were provided by City staff, there is a total of approximately 11,495 acres in active agricultural production2
. According to the General Plan, much of the City’s agricultural uses within the City’s SOI are located outside the city limits; the Fresno Southeast Development Area (SEDA) contains approximately 5,000 acres in agricultural production, representing roughly 50 percent of the existing farming within the Planning Area of the General Plan.

While the General Plan includes a variety of land use designations, there is no land use designation that only allows for agriculture uses. The General Plan does include a Buffer designation, which allows for agricultural uses and other complementary uses, including environmental, habitat, water conveyance, retention and recharge, and preservation and preparation of gravel resources for beneficial uses related to permanent water resource facilities. The Buffer designation is intended to separate urban uses from long-term agricultural uses in order to preserve long-term viable agricultural production and intensive farming operations adjacent to the Planning Area. The Buffer designation is approximately one-quarter mile wide and is located along the eastern boundary of the City, within the Plan Area, encompassing approximately 715 acres. Additionally, the City and its SOI contains approximately 1,012 acres of prime agricultural land that are under a Williamson Act Contract as well as approximately 931 acres of non-prime agricultural land under a Williamson Act Contract (i.e., Statewide Importance, Unique, or Local Importance, and other lands).

The General Plan PEIR contemplated the conversion of this farmland to nonagricultural uses and determined the impact to be significant and unavoidable, even with the implementation of General Plan PEIR Mitigation Measure (MM) AG-1.1 in addition to Policies RC-9-a, RC-9-b, and RC-8-c under Objective RC-9 included in the General Plan.
3 Implementation of MM AG-1.1 would require a
program to be established to offset potential impacts from the loss of farmland; however, the loss would not be fully mitigated because the conversion of farmland to non-farmland uses is a permanent loss as such resources cannot likely be reversed.

Plan Area
The Plan Area is located in the City of Fresno. As discussed in Chapter 2 of this Draft PEIR, Project Description, the predominant existing use in the Plan Area (approximately 5,000 acres) is agriculture, with the primary crops being vineyards, fruit trees within orchards, and vegetables. The SEDA Specific Plan Area (Plan Area) also contains agriculture-related uses such as plant nurseries and 1 City of Fresno. 2020. Fresno General Plan Draft PEIR, Agriculture and Forestry. Accessed June 20, 2022. 2 It should be noted that agricultural operations are not necessarily occurring on all of the land designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and conversely agricultural operations are also occurring on parcels that are not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. 3 City of Fresno. 2020. Fresno General Plan Draft PEIR, Agriculture and Forestry. Accessed June 20, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx wineries. According to the FMMP data, the Plan Area contains a variety of soil types, including Prime Farmland, Unique Farmland, and Farmland of Statewide Importance.4 As shown in Exhibit 3.2-1, the Plan Area contains 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 acres of Unique Farmland. These uses are spread intermittently throughout the Plan Area. Further, the majority of land under Williamson Act Contract in the City and SOI is located in the Plan Area.

3.2.3 - Regulatory Framework
Federal
Farmland Protection Policy Act
The Farmland Protection and Policy Act (FPPA) was designed to minimize the impact federal programs have on the unnecessary and irreversible conversion of farmland to nonagricultural uses.

This Act assures that to the extent possible, federal programs are administered to be compatible with State, local units of government, and private programs and policies to protect farmland. Federal agencies are required to develop and review their policies and procedures to implement the FPPA every 2 years. This Act does not authorize the federal government to regulate the use of private or nonfederal land or, in any way, affect the property rights of owners. For the purposes of the Act, “farmland” includes Prime Farmland, Unique Farmland, and Farmland of Statewide or Local Importance. Farmland subject to FPPA requirements does not have to be currently used for cropland. It can be forest land, pastureland, cropland, or other land, but not water or urban/built-up land.

State
Farmland Mapping and Monitoring Program
The California Department of Conservation established the FMMP in 1982. The FMMP is a nonregulatory program that provides a consistent and impartial analysis of agricultural land use and land use changes throughout California. The FMMP produces maps and statistical data used for analyzing impacts on California’s agricultural resources. The maps are updated every 2 years with the use of aerial photographs, a computer mapping system, public review, and field reconnaissance. The program rates agricultural lands according to physical characteristics and other factors such as irrigation status. The best-quality farmland is land that contains a combination of physical and chemical features able to sustain long-term agricultural production and is classified as Prime Farmland. Additional classifications include Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance (Table 3.2-1).

The FMMP also inventories and maps a variety of other land use categories. For purposes of determining a proposed project’s significance under the California Environmental Quality Act (CEQA), only Prime Farmland, Unique Farmland, and Farmland of Statewide Importance are used to 4 California Department of Conservation. 2016. California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed April 28, 2022.

THIS PAGE INTENTIONALLY LEFT BLANK
31680033 • 07/2022 | 3.2-1_important_farmland.mxd
Exhibit 3.2-1
Important Farmland Map
Source: ESRI Aerial Imagery. CA Department of Conservation Fresno County 2018

CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN PROJECT

ENVIRONMENTAL IMPACT REPORT
180
Clovis Ave
Mckinley Ave
Belmont Ave
Mccall Ave
Jensen Ave
North Ave
Highland Ave
Shields Ave
Ashlan Ave
Church Ave
Fowler Ave
4,600 2,300 0 4,600
Feet
Legend
Fresno Southeast Development Area 8,769.57 acres
Important Farmland Categories
Prime Farmland 2,475.31 acres
Farmland of Statewide Importance 1,352.12 acres
Farmland of Local Importance 1,189.08 acres
Unique Farmland 1,724.99 acres
Urban and Built-Up Land 337.04 acres
Rural Residential Land 1,535.73 acres
Semi-Agricultural and Rural Commercial Land 60.54 acres Vacant or Disturbed Land 94.25 acres
Nonagricultural or Natural Vegetation 0.51 acre

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx determine impacts. Conversion to nonagricultural uses of lands falling under any of these classifications is considered a potentially significant impact under CEQA Guidelines.

Table 3.2-1 provides a description of the various farmland classifications from the United States Department of Agriculture.

Table 3.2-1: Description of Farmland Classifications
Farmland Category Description
Prime (P) Farmland with the best combination of physical and chemical features able to sustain longterm agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date.

Statewide
Importance (S)
Farmland similar to Prime Farmland but with minor shortcomings, such as greater slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the 4 years prior to the mapping date.

Unique (U) Farmland of lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated, but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Land must have been cropped at some time during the 4 years prior to the mapping date.

Local (L) Land of importance to the local agricultural economy as determined by each county’s board of supervisors and a local advisory committee. In some counties, Confined Animal Agriculture facilities are part of Farmland of Local Importance, but they are shown separately.

Grazing (G) Land on which the existing vegetation is suited to the grazing of livestock. This category was developed in cooperation with the California Cattlemen’s Association, University of California Cooperative Extension, and other groups interested in the extent of grazing activities.

Urban and BuiltUp Land (U)Land occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. This land is used for residential, industrial, commercial, construction, institutional, public administration, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes.

Other (X) Land not included in any other mapping category. Common examples include low density rural developments; brush, timber, wetland, and riparian areas not suitable for livestock grazing; confined livestock, poultry or aquaculture facilities; strip mines, borrow pits; and water bodies smaller than 40 acres. Vacant and nonagricultural land surrounded on all sides by urban development and greater than 40 acres is mapped as Other Land.

Water (W) Perennial water bodies with an extent of at least 40 acres.

California Land Conservation Act
The California Land Conservation Act, better known as the Williamson Act, was enacted by the State Legislature in 1965 to encourage the preservation of agricultural lands. Under the provisions of the act, landowners agreeing to keep their lands under agricultural production for a minimum of 10 years receive property tax adjustments. Williamson Act Contracts limit the use of the properties to City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx agricultural, open space, and other compatible uses. Williamson Act lands are assessed based on their agricultural value rather than their potential market value under nonagricultural uses.

Local
Fresno General Plan
Resource Conservation and Resilience Element
Objective RC-9 Preserve agricultural land outside of the area planned for urbanization under this General Plan.

Policy RC-9-a Regional Cooperation. Work to establish a cooperative research and planning program with the Counties of Fresno and Madera, the City of Clovis, and other public agencies to conserve agricultural land resources.

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

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

Healthy Communities Element
Policy HC-5-f Urban Agriculture. Promote a full range of urban agriculture activities, including farmers’ markets, farm stands, community gardens, on-site garden produce market stands, and urban farms. Support associations involved in these activities, which can be accomplished by a combination of the following:

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx • Amend the Fresno Municipal Code (FMC) to provide clear and concise permitting procedures regarding Community Gardens, On-site Garden Produce Market Stands, and Urban Farms that allow sale of foods grown locally. • Create a policy for reduced planning entitlements and plan check fees. • Make publicly available an inventory of City-owned surplus land that could be used for urban agriculture.
• Continue to allow and promote community gardens in City-owned parks. • Support the planning of community gardens within walking distance of highdensity residential areas to compensate for the reduced amount of open space in these areas.
• Emphasize opportunities for urban agriculture in all areas of the City, schools, parks, residential food deserts, and especially in areas of the City with a relatively high proportion of “food insecure” individuals.

Policy HC-5-g Commercial Agriculture. Continue to develop policies to allow agriculture on land greater than 50 acres in area.

Fresno Southeast Development Area Specific Plan
The Fresno SEDA Specific Plan is framed within three significant and interrelated goals: fiscal responsibility, social equity, and environmental sustainability. The proposed Specific Plan and policies that form its implementation framework are formulated and coordinated to meet the criteria of these overlapping goals. The proposed Specific Plan contains the following policies and programs related to agricultural resources:

Urban Form, Land Use and Design Element
Objective UF-1 Create complete neighborhoods in the Southeast Development Area that integrate housing, business and retail amenities. Implement a Southeast Development Area plan that balances and mixes housing, jobs, commercial businesses, services, and public facilities to help meet existing thresholds for lower vehicle miles traveled, reduced air pollution, and the efficient use of groundwater resources in compliance with the Sustainable Groundwater Management Act of 2014.

Policy UF-1.6 Right-to-Farm. Establish right-to-farm practices in accordance with the Fresno County Right-to-Farm Ordinance to allow the continued operation of agricultural activities which occur adjacent to new residential developments. Require buffers between new residential development and existing farmlands.

Housing Element
Objective HC-1 Mix housing types and designs throughout the Plan Area to respond to the needs of all household types. The Southeast Development Area Specific Plan accommodates a diverse range of household demographics and preferences with housing types that range from higher-density multi-family homes to medium-lot single-family homes.

Policy HC-1.6 Compatibility Between Uses. Provide for urban edge transitions that protect existing rural residential and agricultural uses from new development.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx Community Farming and Agricultural Element
Objective CF-1 Conserve strategic farmland outside the Southeast Development Area most likely to sustain economically viable agriculture over the long term. While the efficient, compact development pattern of the SEDA Specific Plan reduces development pressure on surrounding agricultural land, it must be bolstered by policies that directly limit farmland conversion. These policies require inter-governmental coordination between the cities of Fresno, Sanger, Clovis, Fresno County, and other neighboring cities.

Policy CF-1.1 Efficient Land Use. Reduce development pressure on farmland outside the City of Fresno Sphere of Influence (SOI) by adopting the compact, efficient land use pattern of the SEDA Specific Plan. The SEDA Plan clusters homes and jobs at more than twice the density of current trend development.

Policy CF-1.2 Future Growth Planning. Support planning efforts that channel new growth to areas already committed to urban uses inside the current SOIs of incorporated cities in Fresno County.

Policy CF-1.3 Conversion of Farmland to Nonagricultural Uses. The City of Fresno will strongly discourage the conversion of strategic farmland outside its current SOI. • Strategic Farmland Mapping Project. Support the Strategic Farmland Mapping Project conducted by the Fresno Council of Governments to identify the ‘best’ or most strategic locations to preserve farmland outside the current SOIs of incorporated cities in Fresno County.

Policy CF-1.4 Agricultural Farm Buffer. Establish an agricultural farm belt along the eastern edge of the SEDA. Farm belts provide opportunities to link agricultural land preservation and increased urban efficiency with local food production in ways that positively support local economies, farms, and farmers.

Objective CF-2 Create a long-term transition zone between urban uses in the City of Fresno and agricultural land in Fresno County. Buffering urban and adjoining agricultural land uses reduce conflicts that can arise due to noise, pollution, or traffic.

Policy CF-2.1 Rural Cluster Districts. Establish Rural Cluster Districts at the eastern edge of the site, as depicted in the SEDA Plan. Rural clusters consist of clustered residential development surrounded by common land held under easements for agricultural or recreational use.
• Rural cluster farming. Allow small-scale and community farming Rural Cluster Districts.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx Policy CF-2.2 Passive Recreation. Encourage the creation of regional trails and open spaces in Rural Cluster Districts that connect urban uses to agricultural uses with trails for pedestrians, bicyclists, and equestrians.
• What is the role of rural cluster development?
- A transitional buffer. Urban areas and large agricultural operations cannot always sit side-by-side. Noise, dust, and pesticides from farms can pose health concerns for residents, while farmers need space to move machinery and goods. Rural clusters along the eastern edge of SEDA form a transition between the urban area and the agricultural lands beyond. An attractive residential option. Rural clusters offer a rural lifestyle within an environmentally responsible land use framework that promotes active farming and open space preservation.
- A means to preserve land. Rural cluster lands can be used for organic smallscale 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.

Objective CF-3 Promote community farming to provide opportunities for entrepreneurs and families to grow food for commercial and household production. Community farming is intended, in part, to diversify agriculture and make the residents of the Southeast Development Area stakeholders in the success of Fresno County agriculture.

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.

Policy CF-3.2 Small Farms. Create opportunities for entrepreneurs to grow food for commercial production on small plots of land (2 to 20 acres) that can provide economic opportunities for current and future Fresno residents.
• Location. Small farms in the SEDA should be located adjacent to and within open space corridors and within Rural Cluster Districts. If located within a Planned Development or Multi-Family Residential Complex, the Homeowner’s Association and/or property management company shall be responsible for the site and shall designate a liaison between the property owner(s) and the City. (City of Fresno Development Code - 15-2720).
• Access. Public access to small farms should be limited or completely restricted; fencing may be required.
• Management. Management structures of small farms shall be determined as appropriate. Small farms may be privately owned or managed by non-profit organizations.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-12 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx Policy CF-3.3 Community Farming. Create and expand a viable community farming program that promotes an appreciation of food and local ecology, instills a sense of stewardship and community, and provides a recreational activity.
• Community/Neighborhood Gardens. Create and support neighborhood gardens within local communities. Neighborhood gardens, such as Yo’Ville Community Garden in Southwest Fresno, are woven into the fabric of centers and residential areas, providing households with opportunities to grow some of their own produce and meet with other members of the community.
- Location. Neighborhood gardens shall be integrated into Neighborhood Centers, open spaces, and other locations that place them within walking distance of most residents’ homes.
- Access. Access to community spaces can vary. Gardens can be open to the public, or only to designated users.
- Management. Management structures of community spaces shall be determined as appropriate. Neighborhood gardens can be owned by a city or county agency or by a private landowner, and operated by a neighborhood collective, community garden association, non-profit, or city/county parks and recreation department that leases small plots of the garden to community members. Some neighborhood gardens are independent entities, while some jurisdictions have neighborhood garden programs that oversee all the gardens in a jurisdiction.
- Funding and staff assistance. The City of Fresno shall encourage neighborhood organizations to seek funding for the neighborhood garden program and/or facilitate assistance through the Fresno Parks, After School, Recreation, and Community Services Department or other
agency/organization.
• School Gardens. Support and foster the integration of school gardens within neighborhood schools, such as the school garden located at Kepler Neighborhood School in Downtown Fresno. School gardens can serve as outdoor classrooms where students learn about soil, botany, natural cycles, nutrition, and basic gardening principles in a hands-on setting.
- Location. School gardens should be located on school grounds, or within a very short walk of a school. When possible, school gardens should be planned upon new school construction in order to maximize joint-use opportunities with the City of Fresno Parks, After School, Recreation, and Community Services Department.
- Access. Access should be controlled based on school district policies. - Management. Management structures shall be determined as appropriate.

School gardens are typically managed by at least one garden coordinator who works closely with school administration or one or more dedicated teachers.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx - School gardens working group. Create a working group of teachers, students, and residents to explore the development of school garden programs in the Clovis and Sanger Unified School Districts.
• Community Orchards. Support and preserve community orchards for both new and existing orchards within the SEDA. Community orchards can be integrated into the community’s open space network, serving as park-like features and enhancing connections to agriculture.
- Location. Community orchards can be integrated into public open spaces or associated with private development.
- Access. Community orchards should be unfenced, with high levels of public access.
- Management. Management structures shall be determined as appropriate. In a typical model, residents help to care for the orchards and pay fees to fund professional gardeners.

Objective CF-4 Support Fresno agriculture, agricultural industries, and farm employees through economic development, educational training, and social programs within the Southeast Development Area.

Policy CF-4.1 Economic Competitiveness. Support efforts to promote and market agricultural products to maintain the long-term viability of Fresno-area farmers. • Direct Marketing. Implement direct marketing of locally-grown produce from Fresno County and the Southeast Development Area through farmers markets, community-supported agricultural programs, farm-to-restaurant- programs, produce stands, and other mechanisms.
• Branding of local produce. Utilize the opportunities in SEDA to support and establish Fresno as a center for locally-grown produce serving the Central Valley and California. Establish a “Fresno Grown” brand and support the “California Grown” program to promote locally-grown produce.
• Agricultural Tourism. Encourage agricultural tourism in the SEDA to educate visitors and generate income and support for farms.
• Value-Added Process and Distribution. Provide the opportunity for area farmers to utilize Flexible Research and Development districts for agricultural processing and distribution.

Policy CF-4.2 Educational Training. Support education and technical assistance for farm employees and aspiring farm owners through direct relationships with educational and non-profit institutions.
• Public Institutions. Encourage public institutions, including Fresno State University, the State Center Community College District, and other educational institutions, to provide assistance and training to farm employees.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-14 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx • Non-Profit Institutions. Develop relations with non-profit agricultural training organizations and encourage those organizations to locate in the Southeast Development Area.

Policy CF-4.3 Farm Worker Housing and Social Services. Encourage the long-term economic viability of Fresno County agriculture by supporting the housing and social service needs of farm workers.
• Housing. Provide safe, affordable, efficient housing for farm workers, permitting housing on agricultural lands and other appropriate sites within the current Sphere of Influence (refer to the General Plan Housing Element). • Social Services. Encourage organizations that support farm workers through family assistance programs, translation assistance, financial literacy training, medical assistance, and other services, to locate within the Southeast Development Area.

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.
• 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.

Fresno Municipal Code
City of Fresno Zoning Ordinance
Chapter 15 of the Municipal Code outlines the City’s Zoning Ordinance, which provides a guide for the physical development of the City in order to achieve the arrangement of land uses depicted in the approved General Plan, as well as implement goals, objectives, and policies of the approved General Plan. There are zoning designations related to agricultural or forestry use in the City’s Zoning Ordinance, including Residential Single-Family District, (RE and RS-1 through RS-5) Residential MultiFamily (RM-1 through RM-3 and RM-MH), Light Industrial (IL), Heavy Industrial (IH), and Open Space (OS).

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx Fresno General Plan PEIR Mitigation Measures
The General Plan PEIR contains the following mitigation measures that are applicable to the proposed project:

MM AG-1.1 Consistent with Policy RC-9-c of the approved General Plan, the City, in coordination with regional partners or independently, shall establish a Farmland Preservation Program by 2025. The intent of the Farmland Preservation Program would be that, when Prime Farmland, Unique Farmland, or Farmland of Statewide Importance are proposed for development and converted to urban uses within the Sphere of Influence outside city limits, this program would require that the developer of such a project mitigate the loss of farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall establish thresholds of significance and provide several mitigation options that may include, but are not limited to, the following:
• Restrictive Covenants or Deeds
• In Lieu Fees
• Mitigation Banks
• Fee Title Acquisition
• Conservation Easements
• Land Use Regulations
The Farmland Preservation Program may be modeled after some or all of the programs described by the California Council of Land Trusts.

Prior to the adoption of the Farmland Preservation Program, projects shall be required to comply with CEQA to address potential environmental impacts on an individual basis.

3.2.4 - Methodology
The proposed project was evaluated for potential impacts on agriculture resources resulting from implementation of the proposed project through a review of applicable plans and policies.

FirstCarbon Solutions (FCS) personnel reviewed resources from the California Department of Conservation and also reviewed aerial photographs, topographical maps, and street maps to identify surrounding land uses and evaluate potential impacts from future development that may occur pursuant to the Fresno SEDA Specific Plan. The General Plan was reviewed to confirm applicable land use, zoning, and policies related to agricultural land uses.

3.2.5 - Impacts and Mitigation Measures
Significance Criteria
The City utilizes the criteria in CEQA Guidelines Appendix G, to determine whether impacts to agriculture and forestry resources are significant environmental effects.

Appendix G to the CEQA Guidelines is a sample Initial Study Checklist that includes questions for determining whether impacts to resources are significant. These questions reflect the input of City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-16 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx planning and environmental professionals at the Governor’s Office of Planning and Research and the California Natural Resources Agency, based on input from stakeholder groups and experts in various other governmental agencies, nonprofits, and leading environmental consulting firms. Accordingly, the City has derived its significance criteria, based in part, on the questions posed in Appendix G. These significance criteria are as follows:

The proposed project would have a significant effect on agriculture or forestry resources if the project would:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use. b) Conflict with existing zoning for agricultural use, or a Williamson Act Contract. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)).
d) Result in the loss of forest land or conversion of forest land to non-forest use. e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use.

Impact Evaluation
Convert Farmland to Nonagricultural Use
Impact AG-1: The proposed project would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use.

According to the FMMP California Important Farmland Finder, as shown in Exhibit 3.2-1, there are approximately 2,475 acres of land designated as Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and approximately 1,725 acres of land designated as Unique Farmland scattered throughout the Plan Area.5 The remainder of the Plan Area has a variety of designations, including approximately 337 acres of Urban Built-Up Land and approximately 1,536 acres of Rural Residential Land. As previously discussed, the Plan Area contains approximately 5,000 acres of agricultural uses, about half of the land in the Plan Area. Therefore, buildout of the Specific Plan would occur on land with soil types designated by the FMMP as farmland.

The Specific Plan does not contemplate or approve any specific development; however, agricultural preservation is a guiding principle behind the planning and design of the Specific Plan. Buildout of 5 California Department of Conservation. 2022. California Important Farmland Finder. Available:
https://maps.conservation.ca.gov/DLRP/CLIFF/. Accessed April 28, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx the Specific Plan would include components designed to preserve the continuity and viability surrounding land for agricultural uses and open space and to integrate community-scale farming and agriculture. Furthermore, the proposed project’s objectives include integrating small farms, community gardens, and farmers’ markets into neighborhoods, schools, and town centers and creating a buffer that includes rural homes, organic farming, and open spaces to serve as a transition between the Plan Area and commercial agriculture to the east. However, the proposed project would increase housing and, as a result, would result in the conversion of Prime Farmland, Farmland of Local Importance, and Unique Farmland to nonagricultural uses.

To counter the effects of agricultural conversion, the Specific Plan includes a policy framework to support the integration of agriculture within the urban sphere. Programs that would be integrated into the Specific Plan may include school and neighborhood gardens, community orchards, agricultural education centers, and small farming operations in green belts and on the buffer edge.

Furthermore, the Specific Plan includes policies to address land use compatibility through a Buffer District. Buffer Districts act as a transitional buffer between the urban areas of the Plan Area and larger-scale agricultural uses. Unlike the patchwork of rural ranchette development that is typically found at the rural outskirts of cities, the Buffer District would discourage outward sprawl by clearly delineating the urban-rural edge. Therefore, the policies included in the Specific Plan would directly limit farmland conversion and thereby help to preserve agriculture in the Plan Area.

Additionally, the proposed project would comply with the General Plan, which includes several policies intended to protect agricultural uses in the City. Policy RC-9-a directs the City to work with the Counties of Fresno and Madera, the City of Clovis, and other public agencies to conserve agricultural land resources. Additionally, Policy RC-9-b defines when residential and commercial development on unincorporated agricultural land should be prohibited, and Policy RC-9-c describes implementation of the Farmland Preservation Program (FPP). Consistent with Policy RC-9-c, incorporation of the General Plan MM AG-1.1, which requires future development to comply with the FPP once adopted for the SEDA would ensure that all future development would be required to mitigate the loss of farmland if Prime Farmland, Unique Farmland, or Farmland of Statewide Importance where such lands are proposed to be converted to urban uses within the SOI outside city limits. However, because the FPP has not yet been developed, the proposed project would implement project-specific MM AG-2, which requires all future development to mitigate the loss of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, on a project-by-project basis before the initiation of construction or ground-disturbing activities. However, while implementation of MM AG-2 would reduce some project-specific impacts, loss of Prime Farmland would still occur with implementation of the project. Therefore, this impact would be significant and unavoidable even with implementation of available mitigation.

Level of Significance Before Mitigation
Potentially significant impact.

Fresno General Plan PEIR Mitigation Measures
As noted in the regulatory discussion, Section 3.2, the following mitigation measures from the General Plan PEIR are applicable to the project.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx MM AG-1.1 Consistent with Policy RC-9-c of the approved General Plan, the City, in coordination with regional partners or independently, shall establish a Farmland Preservation Program by 2025. The intent of the Farmland Preservation Program would be that, when Prime Farmland, Unique Farmland, or Farmland of Statewide Importance are proposed for development and converted to urban uses within the Sphere of Influence outside city limits, this program would require that the developer of such a project mitigate the loss of farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall establish thresholds of significance and provide several mitigation options that may include, but are not limited to, the following:
• Restrictive Covenants or Deeds
• In Lieu Fees
• Mitigation Banks
• Fee Title Acquisition
• Conservation Easements
• Land Use Regulations
The Farmland Preservation Program may be modeled after some or all of the programs described by the California Council of Land Trusts. Prior to the adoption of the Farmland Preservation Program, projects shall be required to comply with CEQA to address potential environmental impacts on an individual basis.

Project Specific Mitigation Measures
The following project-specific mitigation measure applies to the proposed project:

MM AG-2 Prime Farmland, Unique Farmland, and Farmland of Statewide Importance Impact Reduction Measure. Until the City’s Farmland Preservation Program is implemented consistent with the General Plan Program Environmental Impact Report Mitigation Measure (MM) AG-1.1 and the General Plan Policy RC-9-c, all development in the Fresno Southeast Development Area Specific Plan Area which would convert land designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses shall be analyzed on a project-by-project basis, consistent with the requirements of the California Environmental Quality Act (CEQA) at the time the project application is submitted. Where a specific development project site would include the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses, the project applicant shall identify feasible mitigation prior to project approval and implement such mitigation prior to any construction or ground-disturbing activities. Such mitigation may include but is not limited to siting project to avoid farmland; payment of in lieu fees; or, the acquisition and/or conservation of equivalent Prime Farmland, Unique Farmland, or Farmland of Statewide Importance at another location, where it is financially feasible to do so, in the form of agricultural conservation easements, or other feasible mitigation.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx Level of Significance After Mitigation
Significant and unavoidable impact.

Conflict with Existing Zoning or Williamson Act Contract Impact AG-2: The proposed project would not conflict with existing zoning for agricultural use, or a Williamson Act Contract.

According to the General Plan, the City and its SOI includes lands under Williamson Act Contract, and the majority of these lands are located within the Plan Area. Exhibit 3.2-2 shows the locations of the Williamson Act Contract parcels within the Plan Area. Comparing these parcels to Exhibit 2-2, the majority of land within the Plan Area that is under Williamson Act Contract would be designated for non-agricultural land uses (such as various types of residential, regional and community center land uses) with implementation of the Specific Plan. The General Plan PEIR identifies that implementation of the approved General Plan would conflict with land under Williamson Act Contracts, which would result in a significant and unavoidable impact.

Therefore, the continued implementation of the approved General Plan as well as implementation of the proposed Specific Plan could conflict with existing Williamson Act Contracts because nonagricultural uses would be allowed on lands under a Williamson Act Contract. As a result, the continued implementation proposed Specific Plan could result in a significant impact on existing Williamson Act Contract land.

Therefore, project impacts would remain significant and unavoidable. No feasible mitigation measures are available.

Level of Significance Before Mitigation
Potentially significant impact.

Fresno General Plan PEIR Mitigation Measures
None.

Project Specific Mitigation Measures
No feasible mitigation measures are available.

Level of Significance After Mitigation
Significant and unavoidable impact.

Forest Land and Timberland
Impact AG-3: The proposed project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)).

As identified in the General Plan, no land within the City or SOI is used for forestry purposes and no land within the City or SOI is designated or zoned for forestry resources. Therefore, the Plan Area

THIS PAGE INTENTIONALLY LEFT BLANK
31680033 • 07/2022 | 3.2-2_WA_contract_parcels.mxd
Exhibit 3.2-2
Williamson Act Contract Parcels
Source: ESRI Aerial Imagery. City of Fresno (2019). LSA

CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN PROJECT

ENVIRONMENTAL IMPACT REPORT
180
Clovis Ave
Mckinley Ave
Belmont Ave
Mccall Ave
Jensen Ave
North Ave
Highland Ave
Shields Ave
Ashlan Ave
Church Ave
Fowler Ave
4,600 2,300 0 4,600
Feet
Legend
Fresno Southeast Development Area 8,769.57 acres
Williamson Act Parcels (2019)

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx does not contain any forestry uses or land designated or zoned for forestry resources. Therefore, the proposed project would not conflict with existing zoning for forest land uses or timberland zoned Timberland Production and would not conflict with any existing zoning for forest land or timberland.

No impacts are anticipated to occur. Therefore, the proposed project would have no impact on existing zoning of forest land.

Level of Significance Before Mitigation
No impact.

Fresno General Plan PEIR Mitigation Measures
None.

Project Specific Mitigation Measures
None.

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

The proposed project would not involve the conversion of forest land because the Plan Area does not contain any forest land. Additionally, the proposed amendments to the land use map, rezoning of properties, and annexation would not cause any conversion of forest land to a non-forest use in another location. The proposed project would provide for increased density and accelerate housing production throughout the Plan Area and would not have any direct or indirect impacts on forest lands. The Plan Area is not used for forest use and is not zoned for forest uses. Therefore, the proposed project would have no impact on forestry resources.

Level of Significance Before Mitigation
No impact.

Fresno General Plan PEIR Mitigation Measures
None.

Project Specific Mitigation Measures
None.

Existing Zoning—Forest Land
Impact AG-5: The proposed project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use.

As discussed above under Impact AG-1, future development under the proposed project would result in the conversion of farmland to nonagricultural use and those impacts would be less than significant with the incorporation of General Plan PEIR MM AG-1.1 and project-specific MM AG-2.

Except for direct conversion of farmland to nonagricultural uses, which would be mitigated on a City of Fresno—Fresno Southeast Development Area Specific Plan Project Agricultural Resources and Forestry Resources Draft Program EIR

3.2-24 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx project-by-project basis through the implementation of project-specific MM AG-2, until such time as the FPP is established, the implementation of the proposed project would not result in other changes in the existing environment that would impact agricultural land outside of the Plan Area.

Additionally, there is no designated forest land or Timberland in the Plan Area and therefore development in accordance with the proposed project would not impact forest land, as discussed in above under Impact AG-3 and Impact AG-4. Therefore, the proposed project would result in no impact on farmland or forest land involving other changes to the existing environment.

Level of Significance Before Mitigation
No impact.

Fresno General Plan PEIR Mitigation Measures
Implementation of MM AG-1.1.

Project Specific Mitigation Measures
Implementation of MM AG-2.

Level of Significance After Mitigation
No impact.

3.2.6 - Cumulative Impacts
The cumulative setting for agriculture and forestry resources includes the cities of Fresno, Clovis, and Sanger, and Counties of Fresno and Madera. This analysis evaluates whether impacts of the proposed Specific Plan, together with impacts of cumulative development, would result in a cumulatively significant impact with respect to agriculture and forestry resources. This analysis then considers whether incremental contribution of the impacts associated with implementation of the proposed Specific Plan would be significant. Both conditions must apply for cumulative effects to rise to level of significance.

Agriculture
Cumulative development is anticipated to convert agricultural uses to non-agricultural uses, as well as to conflict with existing agricultural zoning and Williamson Act Contracts. Development in accordance with the continued implementation of the approved General Plan would result in a significant impact on agricultural resources. To reduce potential cumulative impacts on agriculture uses, the approved General Plan includes Objective RC-9 and Policies RC-9-a through RC-9-c, which would reduce cumulative impacts to agricultural resources. In addition, the proposed project would incorporate General Plan MM AG-1.1 and project-specific MM AG-2, which requires all future development to mitigate the loss of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance on a project-by-project basis before construction or ground-disturbing activities, to address the conversion of farmland to non-farmland uses. However, even with incorporation of the approved General Plan mitigation and project-specific mitigation, cumulative impacts related to conversion of agricultural land would remain significant. For these reasons, cumulative impacts to agriculture are significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Agricultural Resources and Forestry Resources FirstCarbon Solutions 3.2-25 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-02 Ag Resources.docx In addition, as identified in Impact AG-2 discussion, development consistent with the proposed Specific Plan could conflict with existing agricultural zoning and land under Williamson Act Contracts, and there is no feasible mitigation that would reduce this impact to less than significant. Therefore, the proposed project’s incremental contribution to the conversion of farmland is cumulatively considerable. Thus, cumulative impacts related to the conversion of Williams Act Contract land would be significant and unavoidable.

Forestry
No cumulative impacts would occur to forestland because there is no identified or zoned forestland in the geographic scope of cumulative projects. Given the location of the proposed project and the surrounding area and the lack of any forestland or land zoned as forest, the proposed project would not contribute to any cumulative impact.

In conclusion, although the implementation of the above objective and policies would reduce cumulative impacts related to the conversion of farmland, cumulative impacts to farmland and land under Williamson Act Contracts would remain significant and unavoidable. No feasible mitigation measures are available.

Level of Cumulative Significance Before Mitigation
Significant and unavoidable impact.

Fresno General Plan PEIR Mitigation Measures
Implementation of MM AG-1.1.

Project Specific Mitigation Measures
Implementation of MM AG-2.

Level of Cumulative Significance After Mitigation
Significant and unavoidable impact.

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-1 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx

3.3 - Air Quality
This section describes existing air quality conditions regionally and locally as well as the relevant regulatory framework. This section also evaluates the possible impacts related to air quality that could result from implementation of the proposed project. Information included in this section is based on project-specific air quality modeling results utilizing California Emissions Estimator Model (CalEEMod) Version 2020.4.0. Complete modeling output is provided in Appendix B.

Two public comments were received during the Program Environmental Impact Report (PEIR) scoping period related to air quality.
• The San Joaquin Valley Air Pollution Control District (Valley Air District) made the following comments:
- Recommends that the PEIR incorporate strategies that reduce Vehicle Miles Traveled (VMTs) and require the cleanest available heavy-duty trucks and vehicles, including zero and nearzero technologies. - Recommends the incorporation of strategies that will advance implementation of the best practices related to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities.
- Provides general recommendations regarding disclosure of air quality impacts. - Provides health risk reduction strategies.
- Provides resources to assist with identifying mitigation measures. • A group letter from the Leadership Council for Justice & Accountability, the Central California Environmental Justice Network, the Fresno Building Healthy Communities, and Fresno Barrios Unidos recommended that the City of Fresno, as the lead agency:
- Thoroughly assess the impacts that the proposed project may have on air quality for Southeast Fresno residents; and
- Adopt enforceable mitigation measures to minimize those impacts to the fullest extent possible.

3.3.1 - Environmental Setting
The proposed project is located in unincorporated Fresno County, adjacent to the City of Fresno’s municipal boundaries, within the San Joaquin Valley Air Basin (SJVAB). The SJVAB consists of Kings, Madera, San Joaquin, Merced, Stanislaus, and Fresno counties, as well as a portion of Kern County.

The local agency with jurisdiction over air quality in the SJVAB is the Valley Air District. Regional and local air quality is impacted by topography, dominant airflows, atmospheric inversions, location, and season. The following section describes these conditions as they pertain to the SJVAB.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-2 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx San Joaquin Valley Air Basin
The information in this section is primarily from the Valley Air District’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI) and the accompanying technical document.1,2 Topography
The topography of a region is important for air quality because mountains can block airflow that would help to disperse pollutants and can channel air from upwind areas that transports pollutants to downwind areas. The Valley Air District covers the entirety of the SJVAB. The SJVAB is generally shaped like a bowl. It is open in the north and is surrounded by mountain ranges on all other sides.

The Sierra Nevada lies along the eastern boundary (8,000 to 14,000 feet in elevation), the Coast Ranges are along the western boundary (3,000 feet in elevation), and the Tehachapi Mountains are along the southern boundary (6,000 to 8,000 feet in elevation).

Climate
Climate is important for air quality because of differences in the atmosphere’s ability to trap pollutants close to the ground, creating adverse air quality or rapidly dispersing pollutants over a wide area, thus preventing high concentrations from accumulating under different climatic conditions. The SJVAB has an “inland Mediterranean” climate and is characterized by long, hot, dry summers and short, foggy winters. Mediterranean climates are defined by sparse rainfall, which occurs mainly in winter, while summers are hot and dry. Summertime temperatures in the SJVAB often exceed 100°F. The subtropical high-pressure cell is strongest during spring, summer, and fall and produces subsiding air, which can result in temperature inversions in the valley. A temperature inversion can act like a lid, inhibiting vertical mixing of the air mass at the surface. Any emissions of pollutants can be trapped below the inversion. Most of the surrounding mountains are above the normal height of summer inversions (1,500 to 3,000 feet). Wintertime high-pressure events can often last many weeks, with surface temperatures lowering to the 30°F (degrees Fahrenheit) range.

During these events, fog can be present and inversions are extremely strong. These wintertime inversions can inhibit vertical mixing of pollutants to a few hundred feet.3 Wind
Wind speed and direction play an important role in dispersion and transport of air pollutants. For example, wind at the surface and aloft can disperse pollution by mixing and transporting it to other locations.

Winds in the SJVAB most frequently blow from the northwest, and the region’s mountain ranges restrict air movement and channel the air mass toward the southeastern end of the valley. The general wind patterns in the SJVAB start with marine air from the San Francisco Bay that flow into the SJVAB from the San Joaquin River Delta and over the Altamont Pass and Pacheco Pass. Then, winds flow along the valley, over the Tehachapi Pass, and into the Southeast Desert Air Basin. This wind pattern contributes to transporting pollutants from the Sacramento Valley and the Bay Area 1 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. Guidance for Assessing and Mitigating Air Quality Impact. 2 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. 2015 Plan for the 1997 PM 2.5 Standard. 3 Ibid.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-3 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx into the SJVAB. During the winter, many days are marked by air stagnation events where winds are very weak, which can result in limited transport of pollutants.

Temperature
Sunlight can be a catalyst in the formation of some air pollutants (such as ozone). Solar radiation and high temperature are particularly important in the chemistry of ozone formation. Photochemical air pollution (primarily ozone) is produced by the atmospheric reaction of organic substances (such as volatile organic compounds [VOCs]) and nitrogen dioxide (NO2) under the influence of sunlight.

Ozone concentrations are very dependent on the amount of solar radiation, especially during late spring, summer, and early fall. Ozone levels typically peak in the afternoon as the temperatures are highest and the land has absorbed most of the solar radiation during the day. After the sun goes down, the chemical reaction between nitrous oxides and ozone begins to dominate. This reaction tends to scavenge and remove the ozone in the metropolitan areas through the early morning hours, resulting in the lowest ozone levels, possibly reaching zero, at sunrise in areas with high nitrogen oxides emissions. At sunrise, nitrogen oxides tend to peak, partly due to low levels of ozone at this time and also due to the morning commuter vehicle emissions of nitrogen oxides. Generally, the higher the temperature, the more ozone is formed, since reaction rates increase with temperature.

However, extremely hot temperatures can “lift” or “break” the inversion layer. Typically, if the inversion layer does not lift to allow the buildup of contaminants to be dispersed, the ozone levels will peak in the late afternoon. If the inversion layer breaks and the resultant afternoon winds occur, the ozone will peak in the early afternoon and decrease in the late afternoon as the contaminants are dispersed or transported out of the SJVAB. Ozone levels are low during winter periods when there is much less sunlight to drive the photochemical reaction.4 Precipitation
Precipitation and fog may reduce or limit some pollutant concentrations by cleansing the air of pollutants and depositing them on the surface. In addition, ozone formation requires sunlight, and clouds and fog can block the required solar radiation. However, atmospheric moisture can also increase pollution levels. In fog with less water content, the moisture acts to form secondary ammonium nitrate particulate matter. This ammonium nitrate is part of the valley’s particulate matter, including dust, 2.5 micrometers or less in diameter (PM2.5) and particulate matter, including dust, 10 micrometers or less in diameter (PM10) problem. Between winter storms, high pressure and light winds allow cold, moist air to pool on the SJVAB floor, which creates strong low-level temperature inversions and very stable air conditions leading to tule fog. Wintertime conditions favorable to fog formation are also conditions favorable to high concentrations of PM2.5 and PM10. 5 Existing Air Quality Conditions
The local air quality can be evaluated by reviewing relevant air pollution concentrations near the proposed project area. Table 3.3-1 summarizes published monitoring data from 2018 through 2020.

The table displays data from the nearest monitoring stations to the proposed project site with available data:
4 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. 2015 Plan for the 1997 PM 2.5 Standard. 5 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. Guidance for Assessing and Mitigating Air Quality Impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-4 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx • Fresno–Drummond Street Monitoring Station, 4706 East Drummond Avenue, Fresno, CA 93725
• Fresno–Foundry Park, 2482 Foundry Park Avenue, Fresno, CA 93706 The data shows that during the past few years, the project area has exceeded the standards for ozone (State and national), and PM10 (State), and PM2.5 (federal). The data in the table reflects the concentration of the pollutants in the air, measured using air monitoring equipment. This differs from emissions, which are calculations of a pollutant being emitted over a certain period. No recent monitoring data for the area was available for carbon monoxide (CO) or sulfur dioxide (SO2).

Generally, no monitoring is conducted for pollutants that are no longer likely to exceed Ambient Air Quality Standards (AAQS).

Table 3.3-1: Air Quality Monitoring Summary
Air Pollutant
Averaging
Time Item 2018 2019 2020
Ozone1 1 Hour Max 1 Hour (ppm) 0.119 0.099 0.123
Days > State Standard (0.09 ppm) 6 1 11
8 Hours Max 8 Hours (ppm) 0.097 0.080 0.091
Days > Standard (0.070 ppm) 32 10 27
Days > National Standard (0.075 ppm) 15 2 14
Carbon monoxide
(CO)
8 Hours Max 8 Hours (ppm) ND ND ND
Days > State Standard (9.0 ppm) ND ND ND
Days > National Standard (9 ppm) ND ND ND
Nitrogen dioxide
(NO2)
1 Annual Annual Average (ppm) 0.013 ND ND
1 Hour Max 1 Hour (ppm) 0.0759 0.0423 0.0668
Days > State Standard (0.18 ppm) 0 0 0
Sulfur dioxide (SO2) Annual Annual Average (ppm) ND ND ND 24 Hours Max 24 Hours (ppm) ND ND ND
Days > State Standard (0.04 ppm) ND ND ND
Inhalable coarse
particles (PM10)
1 Annual State Annual Average (µg/m3) 45.7 39.6 ND
24 Hours Highest Daily 24 Hours (µg/m3) 154.8 181.3 349.2 Days > State Standard (50 µg/m3) 19 13 25
Days > National Standard (150 µg/m3) 0 1 1
Fine particulate
matter (PM2.5)
2 Annual State Annual Average (µg/m3) ND ND 20.3
24 Hours Highest Daily 24 Hours (µg/m3) ND ND 157.2
Days > National Standard (35 µg/m3) ND ND 48
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-5 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Pollutant
Averaging
Time Item 2018 2019 2020
Notes:
> = exceed
µg/m3 = micrograms per cubic meter
Bold = exceedance
max = maximum
National Standard = National Ambient Air Quality Standard ND = no data
PM10 = particulate matter, including dust, 10 micrometers or less in diameter PM2.5 = particulate matter including dust, 2.5 micrometers or less in diameter ppm = parts per million
State Standard = California Ambient Air Quality Standard 1 Fresno–Drummond Street Monitoring Station, 4706 E. Drummond Ave., Fresno, CA 93725 2 Fresno–Foundry Park, 2482 Foundry Park Ave., Fresno, CA 93706 Sources: California Air Resources Board (ARB). 2020. Trends Summary. Website:
https://www.arb.ca.gov/adam/trends/trends1.php. Accessed May 25, 2022.

California Air Resources Board (ARB). 2020. Top Four Summary. Website:
https://www.arb.ca.gov/adam/topfour/topfour1.php. Accessed May 25, 2022.

Air Quality Index
The health impacts of the various air pollutants of concern can be presented in several ways. The clearest comparison is to the State and federal ozone standards. If concentrations are below the standard, it is safe to say that no health impact would occur to anyone. When concentrations exceed the standard, impacts will vary based on the amount by which the standard is exceeded. The United States Environmental Protection Agency (EPA) developed the Air Quality Index (AQI) as an easy-tounderstand measure of health impacts compared with concentrations in the air. Table 3.3-2 provides a description of the health impacts of ozone at different concentrations.

Table 3.3-2: Air Quality Index and Health Effects from Ozone Air Quality Index/
8-hour Ozone Concentration Health Effects Description
AQI (51-100)—Moderate Sensitive Groups: Children and people with asthma are the groups most at risk.

Concentration 55-70 ppb Health Effects Statements: Unusually sensitive individuals may experience respiratory symptoms.

Cautionary Statements: Unusually sensitive people should consider limiting prolonged outdoor exertion.

AQI (101-150)—Unhealthy
for Sensitive Groups
Sensitive Groups: Children and people with asthma are the groups most at risk.

Concentration 71-85 ppb Health Effects Statements: Increasing likelihood of respiratory symptoms and breathing discomfort in active children and adults and people with respiratory disease, such as asthma.

Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should limit prolonged outdoor exertion.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-6 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Quality Index/
8-hour Ozone Concentration Health Effects Description
AQI (151-200)—Unhealthy Sensitive Groups: Children and people with asthma are the groups most at risk.

Concentration 86-105 ppb Health Effects Statements: Greater likelihood of respiratory symptoms and breathing difficulty in active children and adults and people with respiratory disease, such as asthma; possible respiratory effects in general population.

Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should avoid prolonged outdoor exertion; everyone else, especially children, should limit prolonged outdoor exertion.

AQI (201-300)—Very
Unhealthy
Sensitive Groups: Children and people with asthma are the groups most at risk.

Concentration 106-200 ppb Health Effects Statements: Increasingly severe symptoms and impaired breathing likely in active children and adults and people with respiratory disease, such as asthma; increasing likelihood of respiratory effects in general population.

Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should avoid all outdoor exertion; everyone else, especially children, should limit outdoor exertion.

Notes:

AQI = Air Quality Index
ppb = parts per billion
Source: Air Now. 2015. AQI Calculator: AQI to Concentration. Website: https://www.airnow.gov/aqi/aqi-calculator/.

Accessed June 24, 2022.

Based on the AQI scale for the 8-hour ozone standard, the City of Fresno experienced no days in the last three years that would be categorized as Very Unhealthy (AQI 201-300) and as many as 15 days that were unhealthful for sensitive groups (AQI 150) or moderate (AQI 100) as measured at the Fresno–Drummond Street Station. The highest 1-hour maximum reading was 123 parts per billion (ppb) in 2020, compared with the 115-ppb cutoff point for unhealthy (AQI 200).

The other nonattainment pollutant of concern is PM2.5. An AQI of 100 or lower is considered moderate and would be triggered by a 24-hour average concentration of 35.4 µg/m3 , which is
considered an exceedance of the federal PM2.5 standard. The Fresno–Foundry Park Station exceeded the standard for 48 days in 2020 and no data was available for 2018 or 2019. The highest concentration recorded at the Fresno–Foundry Park Station was 157.2 µg/m3 in 2020. The relationship of the AQI to health effects is shown in Table 3.3-3.

Table 3.3-3: Air Quality Index and Health Effects of Particulate Pollution Air Quality Index/
24-hour PM2.5 Concentration Health Effects Description
AQI 51–100—Moderate Sensitive Groups: Some people who may be unusually sensitive to particulates.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-7 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Quality Index/
24-hour PM2.5 Concentration Health Effects Description
Concentration 12.1-35.4 µg/m3 Health Effects Statements: Unusually sensitive people should consider reducing prolonged or heavy exertion.

Cautionary Statements: Unusually sensitive people: Consider reducing prolonged or heavy exertion. Watch for symptoms such as coughing or shortness of breath. These are signs to take it easier.

AQI 101–150—Unhealthy for
Sensitive Groups
Sensitive Groups: Sensitive groups include people with heart or lung disease, older adults, children, and teenagers.

Concentration 35.5-55.4 µg/m3 Health Effects Statements: Increasing likelihood of respiratory symptoms in sensitive individuals, aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease and the elderly.

Cautionary Statements: Sensitive groups: Reduce prolonged or heavy exertion. It is OK to be active outside but take more breaks and do less intense activities. Watch for symptoms such as coughing or shortness of breath. People with asthma should follow their asthma action plans and keep quick relief medicine handy. If you have heart disease: Symptoms such as palpitations, shortness of breath, or unusual fatigue may indicate a serious problem. If you have any of these, contact your health care provider.

AQI 151–200—Unhealthy Sensitive Groups: Everyone
Concentration 55.5-150.4
µg/m3
Health Effects Statements: Increased aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease and the elderly; increased respiratory effects in general population.

Cautionary Statements: Sensitive groups: Avoid prolonged or heavy exertion. Consider moving activities indoors or rescheduling. Everyone else:

Reduce prolonged or heavy exertion. Take more breaks during outdoor activities.

AQI 201-300—Very Unhealthy Sensitive Groups: Everyone
Concentration 150.5-250.4
µg/m3
Health Effects Statements: Significant aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease and the elderly; significant increase in respiratory effects in general population.

Cautionary Statements: Sensitive groups: Avoid all physical activity outdoors. Move activities indoors or reschedule to a time when air quality is better. Everyone else: Avoid prolonged or heavy exertion. Consider moving activities indoors or rescheduling to a time when air quality is better.

Notes:
µg/m3 = micrograms per cubic meter
AQI = Air Quality Index
Source: Air Now. 2015. AQI Calculator: AQI to Concentration. Website: https://www.airnow.gov/aqi/aqi-calculator/.

Accessed June 24, 2022.

Sensitive Receptors
Some land uses are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardiorespiratory diseases.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-8 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Residential areas are considered sensitive receptors to air pollution because residents, including children and the elderly, tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Other sensitive receptors include retirement facilities, hospitals, and schools. Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, exercise places a high demand on respiratory functions, which can be impaired by air pollution. In addition, noticeable air pollution can detract from the enjoyment of recreation. Industrial, commercial, retail, and office areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent as the majority of the workers tend to stay indoors most of the time. In addition, the working population is generally the healthiest segment of the public.

Project Site and Vicinity
Sensitive receptors exist within and adjacent to the proposed project site. The majority of sensitive receptors would be residential land uses to the north and west located within the City of Fresno.

Specifically, the sensitive receptors located within the proposed project boundaries and closest to the proposed project site include:
• Lone Star Elementary School
• Sequoia Elementary School
• Sanger West High School
• Residential subdivisions located north of East Jensen Avenue and west of South Temperance Avenue
• Residential subdivisions located west of North Locan Avenue Existing Air Pollutant Emissions
Project Site Vicinity
In the proposed project vicinity, the primary sources of air pollutant emissions would be mobile vehicles traveling along local roadways and agricultural activity.

Project Site
Similar to the proposed project vicinity, the primary source of air pollutant emissions within the proposed Plan Area would be mobile vehicles traveling along local roadways and agricultural activity.

Attainment Status
The EPA and the California Air Resources Board (ARB) designate air basins where AAQS are exceeded as “nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data to make a definitive attainment designation, they are considered “unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards.

Each standard has a different definition, or “form,” of what constitutes attainment, based on specific air quality statistics. For example, the federal 8-hour CO standard is not to be exceeded more than once per City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-9 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air monitoring values exceeds the threshold per year. In contrast, the federal annual PM2.5 standard is met if the 3-year average of the annual average PM2.5 concentration is less than or equal to the standard.

The Air Quality Management Plans (AQMPs) prepared by the Valley Air District provide the framework for the SJVAB to achieve attainment of the State and federal AAQS through the State Implementation Plan (SIP). Areas are classified as attainment or nonattainment areas for particular pollutants depending on whether they meet the AAQS. Severity classifications for ozone nonattainment range in magnitude from marginal, moderate, and serious to severe and extreme.

The current attainment designations for the SJVAB are shown in Table 3.3-4 The SJVAB is currently classified as a federal and State nonattainment area for ozone, a federal nonattainment area for PM2.5, and a State nonattainment area for PM10.

Table 3.3-4: San Joaquin Valley Air Basin Attainment Status Pollutant State Status National Status1
Ozone (1-hour) a Nonattainment –
Ozone (8-hours) Nonattainment Nonattainment
Carbon monoxide Attainment Attainment
Nitrogen dioxide (annual) Attainment Unclassified
Nitrogen dioxide (1-hour) Attainment Attainment
Sulfur dioxide Attainment Attainment
PM10 Nonattainment Attainment
PM2.5 Nonattainment Nonattainment
Lead Attainment Attainment
Hydrogen Sulfide (H2S) Unclassified –
Sulfates Attainment –
Notes:

PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter 1 On June 15, 2005, the 1-Hour Ozone National Ambient Air Quality Standards (NAAQS) was revoked for all areas except the 8-Hour Ozone nonattainment Early Action Compact areas.

Source: California Air Resources Board (ARB). 2022. Maps of State and Federal Area Designations. Website:
https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations. Accessed July 6, 2022.

3.3.2 - Regulatory Framework
Air pollutants are regulated primarily to protect human health and for secondary effects such as visibility and property damage from pollutant deposition. The Clean Air Act (CAA) of 1970 tasks the EPA with setting air quality standards. The State of California also sets air quality standards that are in some cases more stringent than federal standards and address additional pollutants. The following City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-10 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx section describes these federal and State standards and the health effects of the regulated pollutants.

Clean Air Act
Congress established much of the basic structure of the CAA in 1970 and made major revisions in 1977 and 1990. Six common air pollutants (also known as criteria pollutants) are addressed in the CAA. These are particulate matter, ground level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead. The EPA calls these pollutants criteria air pollutants because it regulates them by developing human health-based and/or environmentally based criteria (science-based guidelines) for setting permissible levels. The set of limits based on human health are called primary standards.

Another set of limits intended to prevent environmental and property damage are called secondary standards.6 The federal standards are called National Ambient Air Quality Standards (NAAQS). The air quality standards provide benchmarks for determining whether air quality is healthy at specific locations and whether development activities will cause or contribute to a violation of the standards.

The criteria pollutants are:

Ozone Particulate matter (PM10 and PM2.5)
Nitrogen dioxide (NO2) Carbon monoxide (CO)
Lead (Pb) Sulfur dioxide (SO2)
The federal standards were set to protect public health, including that of sensitive individuals; thus, the EPA is tasked with updating the standards as more medical research is available regarding the health effects of the criteria pollutants. Primary federal standards are the levels of air quality necessary, with an adequate margin of safety, to protect the public health.

The CAA also requires each state to prepare an air quality control plan referred to as a SIP. The federal CAA amendments of 1990 added requirements for states with nonattainment areas to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins, as reported by their jurisdictional agencies.

California Clean Air Act
The California Legislature enacted the California Clean Air Act (CCAA) in 1988 to address air quality issues of concern not adequately addressed by the federal CAA at the time. California’s air quality problems were and continue to be some of the most severe in the nation and required additional actions beyond the federal mandates. The ARB administers the California Ambient Air Quality Standards (CAAQS) for the 10 air pollutants designated in the CCAA. The 10 State air pollutants are the six federal standards listed above as well as visibility-reducing particulates, hydrogen sulfide, sulfates, and vinyl chloride. The EPA authorized California to adopt its own regulations for motor vehicles and other sources that are more stringent than similar federal regulations implementing the 6 United States Environmental Protection Agency (EPA). 2021. NAAQS Table. Website: https://www.epa.gov/criteria-airpollutants/naaqs-table. Accessed June 24, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-11 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx CAA. Generally, the planning requirements of the federal CAA are less stringent than the CCAA; therefore, consistency with the CCAA will also demonstrate consistency with the federal CAA.

Air Pollutant Description and Health Effects
The federal and State AAQS, the most relevant effects, the properties, and sources of the pollutants are summarized in Table 3.3-5.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-12 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Table 3.3-5: Description of Air Pollutants
Air Pollutant
Averaging
Time
California
Standard
Federal
Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Ozone 1 Hour 0.09 ppm — Irritate respiratory system; reduce lung function; breathing pattern changes;
reduction of breathing capacity; inflame
and damage cells that line the lungs; make
lungs more susceptible to infection;
aggravate asthma; aggravate other chronic
lung diseases; cause permanent lung
damage; some immunological changes;
increased mortality risk; vegetation and
property damage.

Ozone is a photochemical
pollutant as it is not emitted
directly into the atmosphere but
is formed by a complex series of
chemical reactions between
reactive organic gases (ROG),
nitrous oxides (NOX), and
sunlight. Ozone is a regional
pollutant that is generated over a
large area and is transported and
spread by the wind.

Ozone is a secondary pollutant;
thus, it is not emitted directly
into the lower level of the
atmosphere. The primary sources
of ozone precursors (ROG and
NOX) are mobile sources (on-road
and off-road vehicle exhaust).
8 Hours 0.070 ppm 0.070 ppm
Carbon
monoxide
(CO)
1 Hour 20 ppm 35 ppm Ranges depending on exposure: slight headaches; nausea; aggravation of angina
pectoris (chest pain) and other aspects of
coronary heart disease; decreased exercise
tolerance in persons with peripheral
vascular disease and lung disease;
impairment of central nervous system
functions; possible increased risk to
fetuses; death.

CO is a colorless, odorless, toxic
gas. CO is somewhat soluble in
water; therefore, rainfall and fog
can suppress CO conditions. CO
enters the body through the
lungs, dissolves in the blood,
replaces oxygen as an attachment
to hemoglobin, and reduces
available oxygen in the blood.

CO is produced by incomplete
combustion of carbon-containing
fuels (e.g., gasoline, diesel fuel,
and biomass). Sources include
motor vehicle exhaust, industrial
processes (metals processing and
chemical manufacturing),
residential wood-burning, and
natural sources.
8 Hours 9.0 ppm 9 ppm
Nitrogen
dioxideb
(NO2)
1 Hour 0.18 ppm 0.100 ppm Potential to aggravate chronic respiratory disease and respiratory symptoms in
sensitive groups; risk to public health
implied by pulmonary and extra-pulmonary
biochemical and cellular changes and
pulmonary structural changes;
contributions to atmospheric discoloration;
increased visits to hospital for respiratory
illnesses.

During combustion of fossil fuels,
oxygen reacts with nitrogen to
produce nitrogen oxides—NOX
(NO, NO2, NO3, N2O, N2O3, N2O4,
and N2O5). NOX is a precursor to
ozone, PM10, and PM2.5
formation. NOX can react with
compounds to form nitric acid
and related small particles and
result in particulate matter (PM)
related health effects.

NOx is produced in motor vehicle
internal combustion engines and
fossil fuel-fired electric utility and
industrial boilers. Nitrogen
dioxide forms quickly from NOX
emissions. NO2 concentrations
near major roads can be 30 to
100 percent higher than those at
monitoring stations.

Annual 0.030 ppm 0.053 ppm
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-13 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Pollutant
Averaging
Time
California
Standard
Federal
Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Sulfur
dioxidec (SO2)
1 Hour 0.25 ppm 0.075 ppm Bronchoconstriction accompanied by symptoms which may include wheezing,
shortness of breath and chest tightness,
during exercise or physical activity in
persons with asthma. Some populationbased studies indicate that the mortality and morbidity effects associated with fine
particles show a similar association with
ambient sulfur dioxide levels. It is not clear
whether the two pollutants act
synergistically or one pollutant alone is the
predominant factor.

Sulfur dioxide is a colorless,
pungent gas. At levels greater
than 0.5 ppm, the gas has a
strong odor similar to rotten
eggs. Sulfur oxides (SOx) include
sulfur dioxide and sulfur trioxide.

Sulfuric acid is formed from sulfur
dioxide, which can lead to acid
deposition and can harm natural
resources and materials.

Although sulfur dioxide
concentrations have been
reduced to levels well below
State and federal standards,
further reductions are desirable
because sulfur dioxide is a
precursor to sulfate and PM10.

Human caused sources include
fossil fuel combustion, mineral
ore processing, and chemical
manufacturing. Volcanic
emissions are a natural source of
sulfur dioxide. The gas can also
be produced in the air by
dimethylsulfide and hydrogen
sulfide. Sulfur dioxide is removed
from the air by dissolution in
water, chemical reactions, and
transfer to soils and ice caps. The
sulfur dioxide levels in the State
are well below the maximum
standards.
3 Hours — 0.5 ppm
24 Hours 0.04 ppm 0.14
(for certain
areas)
Annual — 0.030 ppm
(for certain
areas)
Particulate
matter (PM10)
24 Hours 50 µg/m3 150 µg/m3 - Short-term exposure (hours/days):
irritation of the eyes, nose, throat;
coughing; phlegm; chest tightness;
shortness of breath; aggravate existing
lung disease, causing asthma attacks
and acute bronchitis; those with heart
disease can suffer heart attacks and
arrhythmias.
- Long-term exposure: reduced lung
function; chronic bronchitis; changes in
lung morphology; death.

Suspended particulate matter is a
mixture of small particles that
consist of dry solid fragments,
droplets of water, or solid cores
with liquid coatings. The particles
vary in shape, size, and
composition. PM10 refers to
particulate matter that is
between 2.5 and 10 microns in
diameter, (one micron is onemillionth of a meter). PM2.5 refers to particulate matter that is 2.5
microns or less in diameter,
about one-thirtieth the size of the
average human hair.

Stationary sources include fuel or
wood combustion for electrical
utilities, residential space
heating, and industrial processes;
construction and demolition;
metals, minerals, and
petrochemicals; wood products
processing; mills and elevators
used in agriculture; erosion from
tilled lands; waste disposal, and
recycling. Mobile or
transportation related sources
are from vehicle exhaust and
road dust. Secondary particles
form from reactions in the
atmosphere.

Mean 20 µg/m3 —
Particulate
matter
(PM2.5)
24 Hours — 35 µg/m3
Annual 12 µg/m3 12.0 µg/m3
Visibilityreducing
particles
8 Hours See note belowd
Sulfates 24 Hours 25 µg/m3 — (a) Decrease in ventilatory function; (b) aggravation of asthmatic symptoms;
The sulfate ion is a polyatomic
anion with the empirical formula
Sulfates are particulates formed
through the photochemical
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-14 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Pollutant
Averaging
Time
California
Standard
Federal
Standarda Most Relevant Effects from Pollutant Exposure Properties Sources (c) aggravation of cardiopulmonary
disease;
(d) vegetation damage;
(e) degradation of visibility;
(f) property damage.

SO4
2−. Sulfates occur in
combination with metal and/or
hydrogen ions. Many sulfates are
soluble in water.
oxidation of sulfur dioxide. In
California, the main source of
sulfur compounds is combustion
of gasoline and diesel fuel.

Leade 30-days 1.5 µg/m3 — Lead accumulates in bones, soft tissue, and blood and can affect the kidneys, liver, and
nervous system. It can cause impairment of
blood formation and nerve conduction,
behavior disorders, mental retardation,
neurological impairment, learning
deficiencies, and low IQs.

Lead is a solid heavy metal that
can exist in air pollution as an
aerosol particle component.

Leaded gasoline was used in
motor vehicles until around 1970.

Lead concentrations have not
exceeded State or federal
standards at any monitoring
station since 1982.

Lead ore crushing, lead ore
smelting, and battery
manufacturing are currently the
largest sources of lead in the
atmosphere in the United States.

Other sources include dust from
soils contaminated with leadbased paint, solid waste disposal, and crustal physical weathering.

Quarter — 1.5 µg/m3
Rolling 3-
month
average
— 0.15 µg/m3
Vinyl
chloridee
24 Hours 0.01 ppm — Short-term exposure to high levels of vinyl chloride in the air causes central nervous
system effects, such as dizziness,
drowsiness, and headaches.

Epidemiological studies of occupationally
exposed workers have linked vinyl chloride
exposure to development of a rare cancer,
liver angiosarcoma, and have suggested a
relationship between exposure and lung
and brain cancers.

Vinyl chloride, or chloroethene, is
a chlorinated hydrocarbon and a
colorless gas with a mild, sweet
odor. In 1990, ARB identified vinyl
chloride as a toxic air
contaminant and estimated a
cancer unit risk factor.

Most vinyl chloride is used to
make polyvinyl chloride plastic
and vinyl products, including
pipes, wire and cable coatings,
and packaging materials. It can be
formed when plastics containing
these substances are left to
decompose in solid waste landfills.

Vinyl chloride has been detected
near landfills, sewage plants, and
hazardous waste sites.

Hydrogen
sulfide
1 Hour 0.03 ppm — High levels of hydrogen sulfide can cause immediate respiratory arrest. It can irritate
the eyes and respiratory tract and cause
headache, nausea, vomiting, and cough.

Long exposure can cause pulmonary
edema.

Hydrogen sulfide (H2S) is a
flammable, colorless, poisonous
gas that smells like rotten eggs.

Manure, storage tanks, ponds,
anaerobic lagoons, and land
application sites are the primary
sources of hydrogen sulfide.

Anthropogenic sources include
the combustion of sulfur
containing fuels (oil and coal).

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-15 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Pollutant
Averaging
Time
California
Standard
Federal
Standarda Most Relevant Effects from Pollutant Exposure Properties Sources Volatile organic compounds
(VOC)
There are no State or
federal standards for
VOCs because they are
not classified as criteria
pollutants.

Although health-based standards have not
been established for VOCs, health effects
can occur from exposures to high
concentrations because of interference
with oxygen uptake. In general,
concentrations of VOCs are suspected to
cause eye, nose, and throat irritation;
headaches; loss of coordination; nausea;
and damage to the liver, the kidneys, and
the central nervous system. Many VOCs
have been classified as toxic air
contaminants.

ROGs, or VOCs, are defined as
any compound of carbon—
excluding carbon monoxide,
carbon dioxide, carbonic acid,
metallic carbides or carbonates,
and ammonium carbonate—that
participates in atmospheric
photochemical reactions.

Although there are slight
differences in the definition of
ROGs and VOCs, the two terms
are often used interchangeably.

Indoor sources of VOCs include
paints, solvents, aerosol sprays,
cleansers, tobacco smoke, etc.

Outdoor sources of VOCs are from
combustion and fuel evaporation.

A reduction in VOC emissions
reduces certain chemical reactions
that contribute to the formulation
of ozone. VOCs are transformed
into organic aerosols in the
atmosphere, which contribute to
higher PM10 and lower visibility.

Benzene There are no ambient air
quality standards for
benzene.

Short-term (acute) exposure of high doses
from inhalation of benzene may cause
dizziness, drowsiness, headaches, eye
irritation, skin irritation, and respiratory
tract irritation, and at higher levels, loss of
consciousness can occur. Long-term
(chronic) occupational exposure of high
doses has caused blood disorders,
leukemia, and lymphatic cancer.

Benzene is VOC. It is a clear or
colorless light-yellow, volatile,
highly flammable liquid with a
gasoline-like odor. The EPA has
classified benzene as a “Group A”
carcinogen.

Benzene is emitted into the air
from fuel evaporation, motor
vehicle exhaust, tobacco smoke,
and from burning oil and coal.

Benzene is used as a solvent for
paints, inks, oils, waxes, plastic,
and rubber. Benzene occurs
naturally in gasoline at one to 2
percent by volume. The primary
route of human exposure is
through inhalation.

Diesel particulate matter
(DPM)
There are no ambient
air quality standards for
DPM.

Some short-term (acute) effects of DPM
exposure include eye, nose, throat, and
lung irritation, coughs, headaches,
lightheadedness, and nausea. Studies
have linked elevated particle levels in the
air to increased hospital admissions,
emergency room visits, asthma attacks,
and premature deaths among those
suffering from respiratory problems.

Human studies on the carcinogenicity of
DPM demonstrate an increased risk of
lung cancer, although the increased risk
Diesel PM is a source of PM2.5—
diesel particles are typically 2.5
microns and smaller. Diesel
exhaust is a complex mixture of
thousands of particles and gases
that is produced when an
engine burns diesel fuel.

Organic compounds account for
80 percent of the total
particulate matter mass, which
consists of compounds such as
hydrocarbons and their
Diesel exhaust is a major source
of ambient particulate matter
pollution in urban
environments. Typically, the
main source of DPM is from
combustion of diesel fuel in
diesel-powered engines. Such
engines are in on-road vehicles
such as diesel trucks, off-road
construction vehicles, diesel
electrical generators, and
City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-16 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Air Pollutant
Averaging
Time
California
Standard
Federal
Standarda Most Relevant Effects from Pollutant Exposure Properties Sources cannot be clearly attributed to diesel
exhaust exposure.
derivatives, and polycyclic
aromatic hydrocarbons and
their derivatives. Fifteen
polycyclic aromatic
hydrocarbons are confirmed
carcinogens, a number of which
are found in diesel exhaust.
various pieces of stationary
construction equipment.

Notes:
ppm = parts per million (concentration)
µg/m3 = micrograms per cubic meter
Annual = Annual Arithmetic Mean
30-day = 30-day average
Quarter = Calendar quarter
a Federal standard refers to the primary National Ambient Air Quality Standard (NAAQS), or the levels of air quality necessary, with an adequate margin of safety, to protect the public health. All standards listed are primary standards except for 3-Hour SO2, which is a secondary standard. A secondary standard is the level of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. b To attain the 1-hour nitrogen dioxide national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 parts per billion (0.100 ppm). c On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. d Visibility-reducing particles: In 1989, the California Air Resources Board (ARB) converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively. e The ARB has identified lead and vinyl chloride as “toxic air contaminants” with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

Sources:

California Air Resources Board (ARB). 2016. Ambient Air Quality Standards. May 4.

California Air Resources Board (ARB). 2022. Vinyl Chloride and Health. Website: https://ww2.arb.ca.gov/resources/vinyl-chloride-and-health. Accessed June 29, 2022.

California Office of Environmental Health Hazard Assessment (OEHHA). 2001. Health Effects of Diesel Exhaust.

National Archives and Records Administration. 2009. Part II, United States Environmental Protection Agency. 40 Code of Federal Regulations Parts 50 and 58, Primary National Ambient Air Quality Standard (NAAQS) for Nitrogen Dioxide; Proposed Rule. July 15.

National Toxicology Program. 2016. Report on Carcinogens, 14th Edition; U.S. Department of Health and Human Services, Public Health Service. Benzene. November 3.

National Toxicology Program. 2016. Report on Carcinogens, 14th Edition; U.S. Department of Health and Human Services, Public Health Service. Diesel Exhaust Particles. November 3.

South Coast Air Quality Management District (South Coast AQMD). 2007. Final 2007 Air Quality Management Plan. June.

United States Environmental Protection Agency (EPA). 2021. Nitrogen Dioxide (NO2) Pollution. Basic Information about NO2. Website: https://www.epa.gov/no2-pollution/basic-informationabout-no2#What%20is%20NO2. Accessed June 29, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-17 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Several pollutants listed in Table 3.3-5 are not addressed in this analysis. Visibility-reducing particles are not explicitly addressed in this analysis because particulate matter is addressed as PM10 and PM2.5 and thus evaluated accordingly (see below). In addition, given the nature of the proposed uses, no components of the proposed project would result in vinyl chloride or hydrogen sulfide emissions in any substantial quantity and thus are not addressed further.

Toxic Air Contaminants Health Effects
A toxic air contaminant (TAC) is defined as an air pollutant that may cause or contribute to an increase in mortality or serious illness or that may pose a hazard to human health. TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk may pose a threat to public health even at low concentrations. The California Almanac of Emissions and Air Quality presents the relevant concentration and cancer risk data for the 10 TACs that pose the most substantial health risk in California based on available data. The 10 TACs are acetaldehyde, benzene,

1.3-butadiene, carbon tetrachloride, hexavalent chromium, para-dichlorobenzene, formaldehyde, methylene chloride, perchloroethylene, and diesel particulate matter (DPM).

Some studies indicate that DPM poses the greatest health risk among the TACs listed above. A 10- year research program demonstrated that DPM from diesel-fueled engines is a human carcinogen and that chronic (long-term) inhalation exposure to DPM poses a chronic health risk.7 In addition to increasing the risk of lung cancer, exposure to diesel exhaust can have other health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. Diesel exhaust is a major source of fine particulate pollution as well, and studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems.

DPM differs from other TACs in that it is not a single substance but a complex mixture of hundreds of substances. Although DPM is emitted by diesel-fueled, internal combustion engines, the composition of the emissions varies depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emission control system is present. Unlike the other TACs, however, no ambient monitoring data are available for DPM because no routine measurement method currently exists. The ARB has made preliminary concentration estimates based on a DPM exposure method. This method uses the ARB emissions inventory’s PM10 database, ambient PM10 monitoring data, and the results from several studies to estimate concentrations of DPM.

Limited data on levels and health risks attributable to the top 10 TACs listed above is available from the ARB as part of its California Almanac of Emissions and Air Quality—2013 Edition.8 Risks associated with DPM emissions are only provided for the year 2000 and have not been updated in the Almanac. Although recent editions of the Almanac do not provide estimated risk, they do provide emission inventories for DPM for later years. The 2013 Almanac provides emission inventory 7 California Air Resources Board (ARB). 1998. Initial Statement of Reasons for Rulemaking, Staff Report, Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant. 8 California Air Resources Board (ARB). 2013. California Almanac of Emissions and Air Quality—2013 Edition. Website:
https://ww2.arb.ca.gov/our-work/programs/resource-center/technical-assistance/air-quality-and-emissions-data/almanac.

Accessed June 24, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-18 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx trends for DPM from 2000 through 2035. The 2013 Almanac reports that DPM emissions were reduced in the SJVAB from 16 tons per day in 2000 to 11 tons per day in 2010, a 31 percent decrease. DPM emissions in the San Joaquin Valley were projected to decrease to 6 tons per day by 2015, a 62 percent reduction from year 2000 levels. The ARB predicts a reduction to 3 tons per day by 2035, which would represent an 81 percent reduction from year 2000 levels. Continued implementation of the ARB’s Diesel Risk Reduction Plan is expected to provide continued reductions in DPM through 2020 and beyond through regulations on this source.9 Asbestos
Asbestos is the name given to a number of naturally occurring fibrous silicate minerals that have been mined for their useful properties such as thermal insulation, chemical and thermal stability, and high tensile strength. The three most common types of asbestos are chrysotile, amosite, and crocidolite. Chrysotile, also known as white asbestos, is the most common type of asbestos found in buildings. Chrysotile makes up approximately 90 to 95 percent of all asbestos contained in buildings in the United States.

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

Exposure to asbestos can occur during demolition or remodeling of buildings that were constructed prior to the 1977 ban on asbestos for use in buildings. Exposure to naturally occurring asbestos can occur during soil-disturbing activities in areas with deposits present.

Federal
Air pollutants are regulated at the national, state, and air basin or county level; each agency has a different level of regulatory responsibility. The EPA regulates at the national level. The ARB regulates at the State level. The Valley Air District regulates at the air basin level.

The EPA is responsible for national and interstate air pollution issues and policies. The EPA sets national vehicle and stationary source emission standards, oversees approval of all SIPs, provides research and guidance for air pollution programs, and sets the federal standards, or NAAQS, described earlier.

An SIP is a document prepared by each state describing existing air quality conditions and measures that will be followed to attain and maintain federal standards. The SIP for the State of California is administered by the ARB, which has overall responsibility for statewide air quality maintenance and air pollution prevention. California’s SIP incorporates individual federal attainment plans for regional air districts—an air district prepares their federal attainment plan, which is sent to ARB to be approved and incorporated into the California SIP. Federal attainment plans include the technical foundation for understanding air quality (e.g., emission inventories and air quality monitoring), control measures and strategies, and enforcement mechanisms. The most recent attainment plans 9 California Air Resources Board (ARB). 2013. California Almanac of Emissions and Air Quality – 2013 Edition. Website:
https://ww2.arb.ca.gov/our-work/programs/resource-center/technical-assistance/air-quality-and-emissions-data/almanac.

Accessed June 24, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-19 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx for the Valley Air District are the 2007 8-hour Ozone Attainment Plan and the 2012 PM2.5 Plan for the 2006 PM2.5 standard. The SJVAB is designated as an extreme ozone nonattainment area for the EPA’s 2008 8-hour ozone standard of 75 ppb. The EPA Administrator signed the Final Rule revising the 8- hour ozone standard to 70 ppm on October 1, 2015. Adoption of a new standard requires an implementation process that includes making attainment designations and the development of new plans to attain the standard based on each area’s designation.

Areas designated nonattainment must develop Air Quality Plans (AQPs) and regulations to achieve standards by specified dates, depending on the severity of the exceedances. For much of the country, implementation of federal motor vehicle standards and compliance with federal permitting requirements for industrial sources are adequate to attain air quality standards on schedule. For many areas of California, however, additional State and local regulation is required to achieve the standards. Regulations adopted by California are described below.

State
California Health and Safety Code Section 39655 and California Code of Regulations Title 17 Section 93000 (Substances Identified as Toxic Air Contaminants) The ARB identifies substances as TACs as defined in Health and Safety Code Section 39655 and listed in Title 17, Section 93000 of the California Code of Regulations, “Substances Identified as Toxic Air Contaminants.” A TAC is defined as an air pollutant that may cause or contribute to an increase in mortality or serious illness, or that may pose a hazard to human health. TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk may pose a threat to public health even at low concentrations. In general, for those TACs that may cause cancer, there are thresholds set by regulatory agencies below which adverse health impacts are not expected to occur.

This contrasts with the criteria pollutants for which acceptable levels of exposure can be determined and for which the state and federal governments have set AAQS. According to the California Almanac of Emissions and Air Quality, the majority of the estimated health risk from TACs for the State of California can be attributed to relatively few compounds, the most important of which is DPM from diesel-fueled engines.

California Low Emission Vehicle Program
The ARB first adopted Low Emission Vehicle (LEV) program standards in 1990. These first LEV standards ran from 1994 through 2003. LEV II regulations, running from 2004 through 2010, represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 SIP. In 2012, the ARB adopted the LEV III amendments to California’s LEV regulations. These amendments, also known as the Advanced Clean Car Program, include more stringent emission standards for model years 2017 through 2025 for both criteria pollutants and greenhouse gas (GHG) emissions for new passenger vehicles.10
10 California Air Resources Board (ARB). 2013. Advanced Clean Car Program. Website:
https://ww3.arb.ca.gov/cc/ccms/documents/ab1493.pdf?bay. Accessed June 24, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-20 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx California On-Road Heavy-Duty Vehicle Program
The ARB has adopted standards for emissions from various types of new on-road heavy-duty vehicles. Section 1956.8, Title 13, California Code of Regulations contains California’s emission standards for on-road heavy-duty engines and vehicles, and test procedures. The ARB has also adopted programs to reduce emissions from in-use heavy-duty vehicles including the Heavy-Duty Diesel Vehicle Idling Reduction Program, the Heavy-Duty Diesel In-Use Compliance Program, the Public Bus Fleet Rule and Engine Standards, the School Bus Program, and others.11 California In-Use Off-Road Diesel Vehicle Regulation
On July 26, 2007, the ARB adopted a regulation to reduce DPM and NOX emissions from in-use (existing) off-road heavy-duty diesel vehicles in California. Such vehicles are used in construction, mining, and industrial operations. The regulation limits idling to no more than five consecutive minutes, requires reporting and labeling, and requires disclosure of the regulation upon vehicle sale.

The ARB is enforcing that part of the rule with fines up to $10,000 per day for each vehicle in violation. Performance requirements of the rule are based on a fleet’s average NOX emissions, which can be met by replacing older vehicles with newer, cleaner vehicles or by applying exhaust retrofits.

The regulation was amended in 2010 to delay the original timeline of the performance requirements, making the first compliance deadline January 1, 2014, for large fleets (over 5,000 horsepower), 2017 for medium fleets (2,501-5,000 horsepower), and 2019 for small fleets (2,500 horsepower or less).

The latest amendments to the Truck and Bus regulation became effective on December 31, 2014. The amended regulation requires diesel trucks and buses that operate in California to be upgraded to reduce emissions. Newer heavier trucks and buses were required to meet PM filter requirements beginning January 1, 2012, while lighter and older heavier trucks required replacement starting January 1, 2015. By January 1, 2023, nearly all trucks and buses will need to have 2010 model year engines or equivalent.

The regulation applies to nearly all privately and federally owned diesel-fueled trucks and buses and to privately and publicly owned school buses with a gross vehicle weight rating greater than 14,000 pounds. The regulation provides a variety of flexibility options tailored to fleets operating low-use vehicles, fleets operating in selected vocations like agricultural and construction, and small fleets of three or fewer trucks.12
California Airborne Toxic Control Measures for Asbestos In July 2001, the ARB approved Airborne Toxic Control Measures (ATCM) for construction, grading, quarrying and surface mining operations to minimize emissions of naturally occurring asbestos. The regulation requires application of Best Management Practices (BMPs) to control fugitive dust in areas known to have naturally occurring asbestos and requires notification to the local air district prior to commencement of ground-disturbing activities. The measure establishes specific testing, notification, and engineering controls prior to grading, quarrying, or surface mining in construction 11 California Air Resources Board (ARB). 2013. The California Almanac of Air Quality and Emissions—2013 Edition. Website:
http://www.arb.ca.gov/aqd/almanac/almanac13/almanac13.htm. Accessed June 24, 2022. 12 California Air Resources Board (ARB). 2015. Truck and Bus Regulation. Website: http://ww2.arb.ca.gov/our-work/programs/truckand-bus-regulation. Accessed June 24, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-21 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx zones where naturally occurring asbestos is located on projects of any size. There are additional notification and engineering controls at work sites larger than one acre in size. These projects require the submittal of a “Dust Mitigation Plan” and approval by the air district prior to the start of a project.

Construction sometimes requires the demolition of existing buildings where construction occurs.

Asbestos is also found in a natural state, known as naturally occurring asbestos. Exposure and disturbance of rock and soil that naturally contain asbestos can result in the release of fibers into the air and consequent exposure to the public. Asbestos most commonly occurs in ultramafic rock that has undergone partial or complete alteration to serpentine rock (serpentinite) and often contains chrysotile asbestos. In addition, another form of asbestos, tremolite, can be found associated with ultramafic rock, particularly near faults. Sources of asbestos emissions include unpaved roads or driveways surfaced with ultramafic rock, construction activities in ultramafic rock deposits, or rock quarrying activities where ultramafic rock is present. Review of the Department of Conservation maps indicates that no ultramafic rock has been found near the proposed project site or in the City of Fresno.

Diesel Risk Reduction Plan
The ARB Diesel Risk Reduction Plan led to the adoption of new State regulatory standards for all new on-road, off-road, and stationary diesel-fueled engines and vehicles to reduce DPM emissions in 2020 by about 90 percent overall from year 2000 levels. The projected emission benefits associated with the full implementation of this plan, including federal measures, were reductions in DPM emissions and associated cancer risks of 75 percent by 2010 and 85 percent by 2020.13 Tanner Air Toxics Act and Air Toxics Hot Spots Information and Assessment Act TACs in California are primarily regulated through the Tanner Air Toxics Act (Assembly Bill [AB] 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588), also known as the Hot Spots Act. To date, the ARB has identified more than 21 TACs, and has adopted the EPA’s list of Hazardous Air Pollutants (HAPs) as TACs.

Carl Moyer Memorial Air Quality Standards Attainment Program The Carl Moyer Memorial Air Quality Standards Attainment Program (Carl Moyer Program), a partnership between the ARB and local air districts, issues grants to replace or retrofit older engines and equipment with engines and equipment that exceed current regulatory requirements to reduce air pollution. Money collected through the Carl Moyer Program complements California’s regulatory program by providing incentives to effect early or extra emission reductions, especially from emission sources in environmental justice communities and areas disproportionately affected by air pollution. The program has established guidelines and criteria for the funding of emissions reduction projects. Within the SJVAB, the Valley Air District administers the Carl Moyer Program. The program has established guidelines and criteria for the funding of emissions reduction projects and has 13 California Air Resources Board (ARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-fueled Engines and Vehicles.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-22 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx established cost-effectiveness criteria for funding emission reductions projects, which under the final 2017 Carl Moyer Program Guidelines are $30,000 per weighted ton of NOX, ROG, and PM.14 Regional
San Joaquin Valley Air Pollution Control District
The primary role of the Valley Air District is to develop plans and implement control measures in the SJVAB to control air pollution. These controls primarily affect stationary sources such as industry and power plants. Rules and regulations have been developed by the Valley Air District to control air pollution from a wide range of air pollution sources. The Valley Air District also provides uniform procedures for assessing potential air quality impacts of proposed projects and for preparing the air quality section of environmental documents.15
The following Valley Air District rules and regulations are relevant to this analysis:

Rule 2010–Permits Required. Rule 2010 requires operators of emission sources to obtain an authority to construct and permit to operate from the Valley Air District.

Rule 2201–New and Modified Stationary Source Review. This rule applies to any stationary/industrial equipment that emits regulated pollutants in amounts specified by the rule.

Rule 2201 requires stationary source projects that exceed certain thresholds to install Best Available Control Technology (BACT) and to obtain emission offsets to ensure that growth in stationary sources on a cumulative basis will not result in an increase in emissions.

Rule 4002–National Emissions Standards for Hazardous Air Pollutants. The purpose of the rule is to incorporate the National Emission Standards for Hazardous Air Pollutants from Part 61, Chapter I, Subchapter C, Title 40, Code of Federal Regulations and the National Emission Standards for Hazardous Air Pollutants for Source Categories from Part 63, Chapter I, Subchapter C, Title 40, Code of Federal Regulations to protect the health and safety of the public from hazardous air pollutants such as asbestos.

Rule 4102–Nuisance. The purpose of this rule is to protect the health and safety of the public and applies to any source operation that emits or may emit air contaminants or other materials.

Rule 4601–Architectural Coatings. The purpose of this rule is to limit volatile organic compounds (VOC) emissions from architectural coatings. Emissions are reduced by limits on VOC content and providing requirements on coatings storage, cleanup, and labeling.

Rule 4641–Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations. The purpose of this rule is to limit VOC emissions from asphalt paving and maintenance operations. If asphalt paving will be used, then the paving operations will be subject to Rule 4641. 14 California Air Resources Board (ARB). 2017. 2017 Carl Moyer Program Guidelines. April. 15 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. Guidance for Assessing and Mitigating Air Quality Impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-23 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Rule 4692–Commercial Charbroiling. The purpose of this rule is to limit VOC and PM-10 emissions from commercial charbroiling. New and existing businesses with charbroiling equipment are subject to this rule.

Rule 4901–Wood-Burning Fireplaces and Wood-Burning Heaters. The purposes of this rule are to limit emissions of carbon monoxide and particulate matter from wood-burning fireplaces, woodburning heaters, and outdoor wood-burning devices, and to establish a public education program to reduce wood-burning emissions. All development that includes wood-burning devices are subject to this rule.

Regulation VIII–Fugitive PM10 Prohibitions. Rules 8011-8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and trackout, etc. All development projects that involve soil disturbance are subject to at least one provision of the Regulation VIII series of rules.

Rule 9410–Employer Based Trip Reduction. The purpose of this rule is reduce VMT from private vehicles used by employees to commute to and from their worksites to reduce emissions of NOX, VOC and PM. The rule would require larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes. The rule uses a menu-based Employer Trip Reduction Implementation Plan and periodic reporting requirements to evaluate performance on a phased-in compliance schedule.

Rule 9510–Indirect Source Review. This rule reduces the impact of NOX and PM10 emissions from growth within the SJVAB. The rule places application and emission reduction requirements on development projects meeting applicability criteria in order to reduce emissions through on-site mitigation, off-site District-administered projects, or a combination of the two.

In addition to establishing control measures, the EPA requires states that have areas that do not meet the NAAQS to prepare and submit AQPs showing how the NAAQS will be met. If a state cannot show how the NAAQS will be met, then the state must show progress toward meeting the NAAQS in the SIP. The 2016 State Strategy for the State Implementation Plan was adopted by ARB in March 2017,16 and the State is currently in the process of developing the 2022 State SIP Strategy.17 In addition, ARB requires regions that do not meet CAAQS for ozone to submit AQPs that describe measures to attain the standard or show progress toward attainment. The following describes the air plans prepared by the Valley Air District which are incorporated by reference per California Environmental Quality Act (CEQA) Guidelines Section 15150.

Ozone Plans
The SJVAB is designated nonattainment of State and federal health-based air quality standards for ozone. Although the EPA revoked its 1979 1-hour ozone standard in June 2005, many planning 16 California Air Resources Board (ARB). 2022. Implementation of the State SIP Strategy. Website:
https://ww2.arb.ca.gov/resources/documents/implementation-state-sip-strategy. Accessed June 29, 2022. 17 California Air Resources Board (ARB). 2022. 2022 State Strategy for the State Implementation Plan (2022 State SIP Strategy).

Website: https://ww2.arb.ca.gov/resources/documents/2022-state-strategy-state-implementation-plan-2022-state-sip-strategy.

Accessed June 29, 2022.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-24 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx requirements remain in place and the Valley Air District must still attain this standard before it can rescind CAA Section 185 fees. The Valley Air District’s most recent 1-hour ozone plan, the 2013 Plan for the Revoked 1-hour Ozone Standard, demonstrated attainment of the 1-hour ozone standard by 2017. However, on July 18, 2016, the EPA published in the Federal Register a final action determining that SJVAB has attained the 1-hour ozone NAAQS based on the 2012 to 2014 3-year period, allowing nonattainment penalties to be lifted under federal CAA Section 179b.18 The EPA originally classified the SJVAB as serious nonattainment for the 1997 federal 8-hour ozone standard with an attainment date of 2013. On April 30, 2007, the Valley Air District’s Governing Board adopted the 2007 Ozone Plan, which contained analysis showing a 2013 attainment target to be infeasible. The 2007 Ozone Plan details the plan for achieving attainment on schedule with an “extreme nonattainment” deadline of 2024. At its adoption of the 2007 Ozone Plan, the Valley Air District also requested a reclassification to extreme nonattainment. ARB approved the plan in June 2007, and the EPA approved the request for reclassification to extreme nonattainment on April 15, 2010. The SJVAB is designated as an extreme ozone nonattainment area for the EPA’s 2008 8-hour ozone standard of 75 ppb. The plan to address this standard was developed for the region to attain EPA’s 2008 8-hour ozone standard by December 31, 2031. The District is currently in the process of developing a new attainment plan for the recently strengthened 2015 Ozone NAAQS of 70 ppb, with submittal required to EPA by August 2022.19
State ozone standards do not have an attainment deadline but require implementation of all feasible measures to achieve attainment at the earliest date possible. This is achieved through compliance with the federal deadlines and control measure requirements.

PM10 Plan
Based on PM10 measurements from 2003 to 2006, EPA found that the SJVAB has reached federal PM10 standards. On September 21, 2007, the Valley Air District’s Governing Board adopted the 2007 PM10 Maintenance Plan and Request for Redesignation. This plan demonstrates that the valley will continue to meet the PM10 standard. EPA approved the document and on September 25, 2008, the SJVAB was redesignated to attainment/maintenance.
20 PM2.5 Plan
The Valley Air District adopted the 2012 PM2.5 Plan on December 20, 2012. This plan was approved by ARB on January 24, 2013. This plan will assure that the SJVAB will attain the 2006 PM2.5 National AAQS. The plan uses control measures to reduce NOX, which also leads to fine particulate formation in the atmosphere. The plan incorporates measures to reduce direct emissions of PM2.5, including a strengthening of regulations for various SJVAB industries and the general public through new rules and amendments. On August 19, 2021, the District’s Governing Board approved the Attainment Plan 18 San Joaquin Valley Air Pollution Control District (Valley Air District). 2022. Ozone Plans. Website:
http://valleyair.org/Air_Quality_Plans/Ozone_Plans.htm. Accessed June 29, 2022. 19 Ibid. 20 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. Guidance for Assessing and Mitigating Air Quality Impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-25 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Revision for the 1997 Annual PM2.5 Standard to establish a new attainment target for the 1997 annual PM2.5 standard of 2023.21
On June 30, 2020, EPA approved portions of the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards and the San Joaquin Valley Supplement to the 2016 State Strategy for the State Implementation Plan related to the 2006 24-hour PM2.5 National AAQS of 35 μg/m³. Additionally, EPA granted an extension of the serious area attainment date for the 2006 PM2.5 NAAQS from December 31, 2019, to December 31, 2024. Federal review of portions of the plan that pertain to the other PM2.5 standards is ongoing.22
Fresno Council of Governments
Fresno Council of Governments (Fresno COG) is responsible for regional transportation planning in Fresno County and participates in developing mobile source emission inventories used in air quality attainment plans.

Regional Transportation Plans/Sustainable Communities Strategy Regional Transportation Plans (RTPs) address the mobility needed to keep the Fresno region moving and connected. Fresno COG 2018-2042 RTP charts the long-range vision of regional transportation in Fresno County through the year 2042. The RTP identifies existing and future transportation related needs while considering all modes of travel, analyzing alternative solutions, and identifying what can be completed with anticipated available funding for the projects and programs included within it.

Senate Bill (SB) 375, which went into effect in 2009, added statutes to the California Government Code to encourage planning practices that create sustainable communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every 4 years. The SCS is intended to show how integrated land use and transportation planning can lead to lower greenhouse gas (GHG) emissions from autos and light trucks in support of ARB’s GHG emission reduction targets.23 At the time of this writing, the draft Fresno COG 2022-2046 RTP/SCS has not been adopted and so was not considered as a part of this analysis.

Transportation Conformity
Fresno COG must ensure that transportation plans and projects comply with federal transportation conformity. Transportation conformity is a way to ensure that federal funding and approval are given to those transportation activities that are consistent with air quality goals. It ensures that these transportation activities do not worsen air quality or interfere with the “purpose” of the SIP, which is to meet the NAAQS. Meeting the NAAQS often requires emissions reductions from mobile sources.

According to the CAA, transportation plans, programs, and projects cannot:
• Create new NAAQS violations;
• Increase the frequency or severity of existing NAAQS violations; or • Delay attainment of the NAAQS.
21 San Joaquin Valley Air Pollution Control District (Valley Air District). 2022. 2018 PM2.5 Plan for the San Joaquin Valley. 22 Ibid. 23 Fresno Council of Governments (Fresno COG). 2022. Regional Transportation Plan, Chapter 1.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-26 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx In practice, AQPs include criteria pollutant emission budgets required for attainment of air quality standards by mandated deadlines. The budgets must not be exceeded considering projected growth in mobile source activity. Emissions from projected growth must not exceed the budgets in any year.

California Environmental Quality Act
The Valley Air District provides guidance and thresholds for (CEQA) air quality and GHG analyses. The result of this guidance, as well as State regulations to control air pollution, is an overall improvement in the SJVAB. In particular, the Valley Air District’s 2015 GAMAQI states the following:

The District’s Air Quality Attainment Plans include measures to promote air quality elements in county and city general plans as one of the primary indirect source programs. The general plan is the primary long range planning document used by cities and counties to direct development. Since air districts have no authority over land use decisions, it is up to cities and counties to ensure that their general plans help achieve air quality goals. Section 65302.1 of the California Government Code requires cities and counties in the San Joaquin Valley to amend appropriate elements of their general plans to include data, analysis, comprehensive goals, policies, and feasible implementation strategies to improve air quality in their next housing element revisions.

The Air Quality Guidelines for General Plans (AQGGP), adopted by the District in 1994 and amended in 2005, is a guidance document containing goals and policy examples that cities and counties may want to incorporate into their General Plans to satisfy Section 65302.1.

When adopted in a general plan and implemented, the suggestions in the AQGGP can reduce vehicle trips and miles traveled and improve air quality. The specific suggestions in the AQGGP are voluntary. The District strongly encourages cities and counties to use their land use and transportation planning authority to help achieve air quality goals by adopting the suggested policies and programs.24
Local
City of Fresno General Plan
The City of Fresno General Plan was adopted in 2014. The General Plan contains the following elements, objectives, and policies that relate to air quality:

Urban Form, Land Use, and Design Element
Policy UF-1-c Identifiable City Structure. Focus integrated and ongoing planning efforts to achieve an identifiable City structure, comprised of a concentration of buildings, people, and pedestrian-oriented activity in Downtown; along a small number of prominent eastwest and north-south transit-oriented, mixed-use corridors with distinctive and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi-purpose trails and tree lined bike lanes and streets.
24 San Joaquin Valley Air Pollution Control District (Valley Air District). 2015. Guidance for Assessing and Mitigating Air Quality Impact.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-27 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Objective UF-12 Locate roughly one-half of future residential development in infill areas – defined as being within the City on December 31, 2012 – including the Downtown core area and surrounding neighborhoods, mixed-use centers and transit-oriented development along major BRT corridors, and other non-corridor infill areas, and vacant land.

Policy UF-12-a BRT Corridors. Design land uses and integrate development site plans along BRT corridors, with transit-oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops.

Policy UF-12-b Activity Centers. Mixed-use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include commercial areas; employment centers; schools; compact residential development; religious institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place.

Policy UF-12-d Appropriate Mixed-Use. Facilitate the development of vertical and horizontal mixeduses to blend residential, commercial, and public land uses on one site or adjacent sites. Ensure land use compatibility between mixed-use districts in Activity Centers and the surrounding residential neighborhoods.

Policy UF-12e Access to Activity Centers. Promote adoptions and implementation of standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers.

Policy UF-12-f Mixed-Use in Activity Centers. Update the Development Code to include use regulations and standards to allow for mixed-uses and shared parking facilities, including multi-story and underground parking facilities, within Activity Centers.

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

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

Policy UF-14-b Local Street Connectivity. Design local roadways to connect throughout neighborhoods and large private developments with adjacent major streets and pathways of existing adjacent development. Create access for pedestrians and bicycles where a local street must dead end or be designed as a cul-de-sac to adjoining uses that provide services, shopping, and connecting pathways for access to the greater community area.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-28 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Policy LU-2-a Infill Development and Redevelopment. Promote development of vacant, underdeveloped, and re-developable land uses within the City Limit where urban services are available considering the establishment and implementation of supportive regulations and programs.

Policy LU-2-b Infill Development for Affordable Housing. Consider a priority infill incentive program for residential infill development of existing vacant lots and underutilized sites within the City as a strategy to help to meet the affordable housing needs of the community.

Policy LU-3-c Zoning for High Density on Major BRT Corridors. Consider the adoption of supportive zoning regulations for compact development along BRT corridors leading to the Downtown Core that will not diminish the long-term growth and development potential for Downtown.

Policy LU-5-f High Density Residential Uses. Promote high-density residential uses to support Activity Centers and BRT Corridors, affordable housing and walkable access to transit stops.

Policy LU-6-d Neighborhood and Community Commercial Center Design. Plan for neighborhood mixed use and community commercial uses to implement the Urban Form concepts of the General Plan, promote the stability and identity of neighborhood and community shopping areas, and allow efficient access without compromising the operational effectiveness of the street system. Neighborhoods will be anchored by community commercial centers with a mix of uses that meet the area’s needs and create a sense of place. Community commercial centers will be located within Activity Centers.

Policy LU-6-f Auto-Oriented Commercial Uses. Direct highway-oriented and auto-serving commercial uses to locations that are compatible with the Urban Form policies of the General Plan. Ensure adequate buffering measures for adjacent residential uses noise, glare, odors, and dust.

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

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

Policy RC-4-a Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and City of Fresno—Fresno Southeast Development Area Specific Plan Project Draft Program EIR Air Quality
FirstCarbon Solutions 3.3-29 https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx mobile sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan.

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

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

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

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

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Air Quality Draft Program EIR

3.3-30 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/3168/31680033/EIR/3 - Draft PEIR/31680033 Sec03-03 Air Quality.docx Policy RC-8-j Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

Healthy Communities Element
Policy HC-3-d Green Standards for Affordable Housing. Provide appropriate incentives for affordable housing providers, agencies, non-profit and market rate developers to use LEED® and CalGreen Tier 1 or Tier 2 standards or third party equivalents.

Policy HC-3-f New Drive-Through Facilities. Include in the Development Code design review to reduce vehicle emissions resulting from queued idling vehicles at drive-through facilities in proximity to residential neighborhoods.

Mobility and Transportation Element
Objective MT-3 Identify, promote and preserve scenic or aesthetically unique corridors by application of appropriate policies and regulations.

Policy MT-1-f Match Travel Demand with Transportation Facilities. Designate the types and intensities of land uses at locations such that related travel demands can be accommodated by a variety of viable transportation modes and support Complete Neighborhoods while avoiding the rerouting of excessive or incompatible traffic through local residential streets.

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

Policy MT-2-b Reduce Vehicle Miles Traveled and Trips. Partner with major employers and other responsible agencies, such the San Joaquin Valley Air Pollution Control District and the Fresno Council of Governments, to implement trip reduction strategies, such as eTRIP, to reduce total vehicle miles traveled and the total number of daily and peakhour vehicle trips, thereby making better use of the existing transportation system.

Policy MT-2-c Reduce VMT through Infill Development. Provide incentives for infill development that would provide jobs and services closer to housing and multimodal transportations corridors in order to reduce citywide Vehicle Miles Traveled (VMT).