and out of control. Jurisdiction was a concern at that time, and it was further stated he had an issue with procedure and stated “stinks big time.” Brand said it was getting personal. Clearly, throughout the Minutes we see some major concerns here; has anyone completed an in-depth investigation regarding the initiation, involvement of the persons, and the development itself; or, addressed these past issues or will the City attempt to have this skirt by, sweep it under the rug, in hopes nothing is revealed. Page 157-44, Brand states he learned the City spends way too much money on consultants.
It’s now 2025, we have the same questions and concerns as reflected in the 2011 Minutes; the PEIR fails to fully and completely mitigate the issues raised in this current PEIR; and the past concerns of council. For reasons stated above, we oppose the PEIR dated 2/7/25 and believe we should look further into the concerns discussed in the 2011 hearing and if those concerns were in fact addressed, with or without public involvement; we believe it should be discussed in a public forum not private closed session. We further would like to see in a public forum, in an effort to be fully transparent, those donor contributions to the elected officials of that time as well as currently seated officials (e.g.
Statement of Economic Interests - Form 700, Gifts & Gratuities or any other forms required by the FPPC).
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We submitted PRA #R074526-030925 to the City requesting the names of persons or organizations the Planning Department, City Manager, Districts 1-7 and Mayors office have met with to discuss SEDA from 2022 to present. Of course the City requests an extension to March 31 in which to respond.
PAGE ES-1 (Executive Summary):
This document and lead agency states that the purpose of the subject PEIR is to inform of potential environmental effects as a result of implementing the SEDA project. It is further stated that this project is described as an “acceleration of housing production.” The CITY is requesting to speed up producing homes. They base this on meeting the need of “diverse housing types” and “affordability levels.” All to be completed by the year 2050. Has the revitalization of Downtown Fresno been completed? Have the vacant buildings in that location been restored, refurbished. Has new life as set forth in history when Downtown Fresno revitalization was introduced to the public been established? The honest answer is NO! The City web page states Downtown is following in the footsteps of Oakland and Sacramento. That more than 600 apartments have been recently added and the Mayor’s goal is to grow the neighborhood from 3,000 to 10,000 residents. How about the high speed rail, yet been completed? When the rail was presented by a group of past elected officials it was posed as prosperous (to who that’s unknown), and much needed; past elected officials believed a bullet-train from San Francisco to Los Angeles was needed (for who that is the unknown). Has the rail project been completed? The honest answer is NO! Look where we are at today in both projects, failure to complete (how many years later); failure to pay and/or have the money, and look at the environment.
Just like DOGE is involved in looking into the high speed rail maybe we need to have them look into this land grab and how the City is spending our money and who is benefiting from this money.
Maybe it’s time the City of Fresno’s waste and fraud be exposed. This PEIR of course states all in the name of being fiscally responsible, social equity, environmentally sustainable. I’m sure that is what was said for Downtown and the High Speed Rail. Downtown is littered with homelessness, businesses unable to stay afloat due to the increasing costs in rent, utilities, food, wages, and the inability to keep downtown Fresno safe, at its closest location to law enforcement. What this PEIR is introducing us to is Fresno 2.0. You’ve heard that term used by Gov. Newsom, after Southern Cal was devastated by wildfires (closest cities to the ocean); how interesting our government is now referring So Cal as a Smart City, to rebuild LA 2.0. Same thing with Lahaina (Maui wildfire), their government wanted a Smart City too.
The Fresno Housing Authority “manages diverse properties and programs;” they are designed and designated for “under-served populations, including farm laborers, migrant workers, seniors and those in need of support.” On their website I find over 70 properties in Fresno within a 35 mile radius. In 2024 and 2025, Fresno County developed new “affordable” housing such as Avalon Commons, The Arthur, Promesa Commons, Sarah’s Court apartments at Fancher Creek and Crossroads Village.
Population continues to be inconsistent as under this new current Federal administration, with the deportation of illegal immigrants, their need for housing will substantially decrease. In addition, the most cost effective remedy is not develop, develop, develop but how about pursuing these developers to lower the cost of their homes built to make them more affordable.
For this reason and many others as stated below is why we Southeast Property Owners strongly oppose the SEDA development and the recirculated Proposed EIR.
In addition, we have a mental health crisis, homeless problem involving substance abuse, mental health,; an illegal immigration problem, economy problem (groceries-eggs are $8 a dozen, rent, interest rates, tariffs), and the federal government is not inclined to continue writing checks. The lead agency states a population however how did they come up with the numbers on the population? You can no longer count those here illegally and therefore numbers must be adjusted. Who was included in your count, must be answered?
GV Wire article dated 12/17/24 by Edward Smith states: “A proposal would put 400-single family homes on the property occupied by the massive former IRS processing center in southeast Fresno.” This is not about housing, this is about a land grab to line the pockets of politicians and developers/ donors.
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PAGE ES-2&3:
The lead agency states this project would result in significant and unavoidable impacts. This right here should be enough and tells us all we need to know, but let’s continue.
PAGE ES-4/AES-3 and Reference 3.1:
The lead agency has confirmed this project will substantially degrade the visual character or quality of public views of both site and surroundings. Of course it will. As stated in 2011 and still true today, SEGA is a decline of Fresno farmland. The impact physically to land, air, aesthetics, birds, coyotes, will be obsolete/extinct as we are pushing the city further and deeper into rural territory that was not meant or intended for a city life or Smart City. The effects would be changing the view of green landscape, fruit trees, vineyards, to concrete buildings, cell towers, cars, lights, bus and change the sounds of birds, quiet, little to no traffic in exchange for cars, power equipment, talking, music; pollution from those vehicles and buildings. This affects not just a few but it affects 9,000 acres.
Adding a grassy knoll does not relieve these problems. You will still see those tall cement buildings, businesses and housing units, vehicles, lights whether it’s a public view (from the grassy knoll) or private view. In the cities, you hear or read about in the news sightings of coyotes, duh of course, you moved into their territory, whether coyotes, toads, skunks, all those animals don’t just up and walk to Squaw Valley to relocate, they will either die because we have removed their source of feeding or stay. Go outside in the morning, we hear birds singing; go out in the evening, you hear the toads, crickets. Under SEDA all will be lost and it will be traffic, smog, cell towers, homeless encampments.
The agency confirms there are no feasible mitigation measures available to mitigate the impact. For the reasons we stated, we oppose.
AES-4 Light & Glare:
Creates new source of light/glare adversely affecting day/night views.
The lead agency has confirmed this project will substantially degrade the visual character or quality of public views of both site and surroundings. As stated in 2011 and still true today, SEGA (SEDA) is a decline of Fresno farmland. The impact physically to land, air, aesthetics, birds, coyotes, will be obsolete or extinct as we are pushing the city further and deeper into rural territory that was not meant intended for a city, a Smart City. The effects would be changing the view of green landscape, fruit trees, vineyards, to concrete buildings, cars, lights, and change the sounds of birds, quiet, little to no traffic to cars, equipment, talking, music; pollution from those vehicles and buildings. This affects not just a few but it affects the 9,000 acres. Adding a grassy knoll does not relieve these problems. You will still see those tall cement buildings, businesses and housing units, vehicles, lights whether it’s a public view (from the grassy knoll) or private view. In the cities, you hear or read about in the news sightings of coyotes, well yes you moved into rural territory, coyotes, toads, skunks, all those animals don’t just up and walk to Squaw Valley immediately, they will either die because we have removed their source of feeding or stay. Go outside in the morning, we hear birds singing; go out in the evening, you hear the toads, crickets. In essence you are building a Smart City, just like your smart phone, laptop, the lighting, the cell towers all for public and private consumption.
The CITY has confirmed impacts remain significant and unavoidable. For the reasons stated, we oppose.
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CUMULATIVE LIGHTS/GLARE:
I refer you to my statements made under ES-4/AES-3 and 4. I reiterate same here. The impacts are significant and unavoidable. For this and all the reasons stated, we oppose.
PAGE ES-4, Impact AG-1 - Reference 3.2:
As we all know, the SEDA project will be a catastrophic loss of 9,000 acres of what we the property owners have stated from the beginning, Prime Farmland, and what the PEIR now confirms as (1) PRIME, (2) IMPORTANT STATE; (3) IMPORTANT LOCAL AND (4) UNIQUE FARMLANDS. Of that 9,000 acres, the PEIR classifies 6,741 total acres as designated Prime Farmland, Farmland of Statewide Importance, Farmland of Local Importance, AND Unique Farmland which is “scattered throughout the Plan Area.” Read that again, scattered throughout the Plan Area, scattered throughout, not a block, not a street.
Again, we are not talking one block, one street, one acre; the CITY is requesting to destroy, demolish more than half of what is designated as PRIME, OF GREAT IMPORTANCE TO THE STATE AND LOCALLY, AND UNIQUE FARMLAND. We argue that all 9,000 acres are Prime , Unique and of Importance to the State and Locally. At a time when groceries are at their highest in the store, you want to build units so a household can “hopefully” create and sustain a garden to feed “their household” but yet you are destroying farmland that feeds the state, our County and quite frankly my/ our households. They won’t even be the deed holders of this so-called housing, government and developers will be the ones to own the land, buildings, housing units. Our home sits next to the Briggs canal which is rare and unique in and of itself; the water flowing into that irrigation canal is from the Kings River. Our property along with many of my neighbors, we grow our own food, have our own farm animals and equipment and yet you want us to allow the government to take what we have paid for-worked for, and live off of, so that the government can create a Smart City/Fresno 2.0 to benefit and line their pockets under the guise of “hopefully” teaching people to have community gardens; the people work the land; the government or developers own the land, that’s your Smart City aka Fresno 2.0.
The PEIR states that loss of farmland still occurs with this Plan, the impact is significant and unavoidable EVEN WITH IMPLEMENTATION OF AVAILABLE MITIGATION. As stated back in 2011, SEGA is the decline of Fresno’s Farmland. Our communities depend on Ag; No Farmers, No Food!
For all the reasons stated in this letter and my neighbors’ letters, we strongly oppose the PEIR as well as SEDA.
PAGE ES-5/AG-2:
There are significant impacts on existing Williamson Act land. This PEIR states is unavoidable and no mitigation measures available. The California Land Conservation Act of 1965 helps preserve agricultural land and open space. It discourages premature conversion to urban uses; it further protects open space; and is supposed to keep land values relatively stable. By doing this, the value of our homes our properties declines substantially. There are supposed to be land use restrictions imposed upon the owners; however, what the City is doing is changing restrictions, better yet protections to property owners, to again line their pockets, the pockets of the developers as government deems appropriate. The California Department of Conservation’s homepage states in part:
…post World War II period. During that time California’s Agricultural and open space lands began to face dramatically increasing conversion pressures from population growth, new commercial enterprises, and rising property taxes. “Valuable farmland began disappearing at an alarming rate as conversion to urban uses became the only financially viable alternative of many landowners.” Page of 6 11
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The Williamson Act Program has remained stable and effective as a mechanism for protecting agricultural and open space land from premature and unnecessary urban development.
For all the reasons stated thus far, we oppose the PEIR and SEDA.
Impact AIR-1 - Reference 3.3:
Potential (which means to become or develop in the future) to exceed the San Joaquin Valley Air Pollution thresholds and not consistent with existing Air Quality Plans. To date, we are told when to burn our fireplace, what type of fireplace, when to burn green waste and yet here the City knowingly wants to implement a project and plan that will exceed thresholds and goes against the standards imposed upon the people of this County. The PEIR states that “due to the magnitude and intensity of development” it is unavoidable and a significant impact.
AIR-2:
Projected Cumulative emissions associated with future development projects exceeds Valley Air thresholds and is a significant and unavoidable impact.
AIR-3 Sensitive Receptors:
The lead agency can’t even respond, foresee, forecast this section. They state, “without such information” “it is not possible to conclude” and it is significant and an unavoidable impact.
For all the reasons stated, and their failure to provide a detailed or any response to include a cost, we oppose the PEIR AND SEDA.
Cumulative Air Quality:
“Not enough information to quantify” “future development projects may still exceed Valley Air District thresholds.” This is what this PEIR states. It further states that due to the size of the project no significant mitigation available to reduce the cumulative impacts to air quality. It remains significant and unavoidable.
The impacts during and post plan development will be great; again, the impacts will be great. You are adding to the vehicular traffic, the people, the businesses, the smog, the cell towers, the power grid.
People will be traveling not only for personal reasons but business. Of course there is a significant impact and it will not be avoided.
For all these reasons, we oppose the PEIR and SEDA.
References 3.4 - 3.8:
GHG-1:
Implementation of project contributes to global climate change through direct emissions of greenhouse gases not only from sources generated by project, indirectly, thru off-site energy. The project increases the population and employment which further contributes to increase in wastewater, water demand, and vehicle trips. Energy is increased due to the magnitude of new buildings constructed. The Environmental impact of the project related to GHG emissions is significant. “There is no mitigation feasible to reduce GHG emissions.” The impacts of this project are significant and unavoidable.
The Minutes dated 2/10/11, provided to me per a PRA request, states in Finding #2: “(Committee finds the SEGA region is known to have insufficient water, and cost estimates on proposed water infrastructure are extraordinarily high)”. This remains true to date. All the properties that would Page of 7 11
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remain have been informed by the City that we would be required to hook up to their water and sewer lines at our own expense. Yet the City has not provided a confirmed cost that would be assessed to property owners and stated that loans could be taken out with the City (now the City is a bank, lender) which would obviously line their pockets; and if property owners fail to be able to pay those loans a lien would be assessed on their home/property. We should not have to take a loan out for thousands, or have a lien placed on our property. What about these property owners who are of retirement years; they cannot just go back to work because of a land grab by the City? In addition, our home sits approximately 200 feet from the road, the cost would be beyond the minimum. Those of us not in prime health would be forced to choose and that is not something that should be posed to us by our government.
For all these reasons, we oppose the PEIR and SEDA.
Cumulative GHG ES-7:
I reiterate my statements here as set forth in paragraph GHG-1. It is reflected significant and unavoidable impacts.
For all these reasons, we oppose the PEIR and SEDA.
NOI-1/Reference 3.13:
The City/lead agency is unable to quantify the construction noise impacts. That’s because it is so extreme during project development and post. During, between several equipment and projects working in tandem vehicles added to the road, people, its beyond what we can imagine, quantify or explain As stated in the PEIR, the impacts are significant and unavoidable.
Cumulative Noise:
Details of individual development projects are currently unknown. It is not possible to quantify future cumulative construction noise impacts if multiple developments construct simultaneously creating a cumulative noise impact. Because they can occur simultaneously and noise can occur for prolonged periods of time, cumulative construction and noise impacts are possible and are significant and unavoidable.
For all the reasons stated throughout this opposition, we oppose the PEIR and SEDA.
Reference 3.13:
How is this fiscally responsible? There is no projected cost that’s been provided for SEDA construction nor monies allocated that we are aware of. We requested information, PRA #R073948-022625, asking for the City to identify by name/business and address all federal, state and local funding sources, grants, monies received by the City and requested by the City that will be applied to, and used for SEDA, include dates and amounts received and requested. You know the response we received from the City, they need an extension to March 24th (the deadline for public comment). This project has been in existence for over a decade, decade, and either they: (1) are lying; (2) playing hide the ball; (3) lack full transparency; or (4) abuse of power. Maybe all of the above.
This is evidence of the type of answers we the property owners receive from the City on a consistent basis as it relates to SEDA. The lead agency/city cannot confirm to current southeast property owners the cost to connect to the city’s water/sewer, which they state will be our financial responsibility to bear; they cannot confirm how much money a project of this size will cost the taxpayers, City and County citizens. This is a problem; maybe this is what the past council member meant by stinks big time? As done with the high speed rail any cost projection is a guess and can increase substantially after the project commences and you will have destroyed over 9,000 acres of farmland for what, a Smart City, you can revitalize downtown Fresno and have your Smart City, it’s already there, vacant.
Buildings exist downtown, drive throughout this City, you will find abandon buildings; and can be reconstructed by your developers for a confirmed cost. Are you receiving federal funding? If so, maybe we should get DOGE involved to see how fiscally responsible and cost effective this PEIR and Page of 8 11
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project Plan really is; or, maybe they will uncover waste and fraud at the expense of taxpayers and on this project, at the expense of the property owners.
How is this social equity? You are removing elders, our retired community, the vast majority of property owners in SEDA plan are retired, or farmers, and existing long-time property owners and families whose lives are according to their land, we grow our own food, have our own farm animals; you are forcing us from our PRIME, UNIQUE, AND GREATLY IMPORTANT TO THE STATE AND LOCAL FARMLAND, to create Fresno 2.0/Smart City under the guise of “affordable housing.” I have attached to this letter pictures of how fiscally responsible, socially equitable, and environmentally sustainable the City of Fresno, County of Fresno is currently. (See attached pictures). There is an existing development located on the northeast corner of “Kings Canyon” and Clovis Avenue, the City just added a Ross in that development, the old OSH building (because a second Ross store was needed—there is a Ross located on Kings Canyon just 2.1 miles from the new Ross, stupid right); because Southeast Property owners only shop at Ross. You have vacant buildings located within this same complex, a Smoke Shop (see attached), empty buildings, which is all a place for the homeless community and thugs to hangout, start fires to keep warm, drug interactions. SEDA monies can go towards the homeless, mental health, the west side existing property owners and your Downtown Revitalization.
Between the City and County, there have been new developments of new affordable housing. Look at the canal that runs along McKinley from Clovis Avenue to the 168 freeway, look at the homeless that camp there. If you can’t take care of that existing problem, how will you take on the homeless encampments in this new development, because if you build it they will come. This is the proof of what happens to the City of Fresno, they become a part of the have nots, they no longer receive the help that they need. The money for SEDA can be given to the homeless and provide the assistance they need. They don’t need a Smart City.
Hydrology & Water Quality - 3.10
The proposed project would have significant impact on the environment if the proposed project would:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. (PDF page 453)
c) Substantially alter the existing drainage pattern of 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 off-site; (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.
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
(e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
The above language from the PEIR I believe shows we will be violating the water quality standards and waste discharge; we will substantially decrease groundwater supplies or interfere; alter the Page of 9 11
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existing drainage; result in erosion … nothing good will come from SEDA. Now is not the time.
How much more money should you throw out the window?
Impact HYD-2 Groundwater Supply & Recharge:
The PEIR states:
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.
It further states that groundwater alone will not be sufficient to meet future City demands, including those for SEDA. (PDF Page 492)
If you recall, the City/lead agency states this is to be fiscally responsible, environmental sustainability and socially equitable. Approving this to move forward fails us in all capacities including the people outside of SEDA where water is an issue in general such as Cantua Creek, El Porvenir. There are outside areas not only within the City of Fresno but Fresno County who need dire attention and have government focused on their water issues; not government creating new water issues for the sake of Fresno 2.0 Smart city.
The Business Journal 12/10/24: It’s Horrible: Fresno’s Record-Breaking Settlement Highlights Region’s Larger Drinking Water Problem. This article states that a review of documents and interviews of key officials uncovers a decades-long environmental crisis enabled by both corporate greed and bureaucratic neglect. It goes on to state that a darker truth emerges—the money will vanish in less than a decade, covering filtration costs for roughly eight years, according to interviews with City officials Georgeanne White and Brock Buche. Once the settlement funds run dry, Fresno residents will be left to shoulder any remaining pollution cleanup, at a cost of millions each year.
PDF Page 492 of the PEIR states, “impacts to water supply and demand would be considered at the time of annexation for each specific parcel.” How stupid and reckless, environmentally and fiscally, to wait until the time of to determine the impacts to water supply and demand. Now we see how the high speed rail is in its current situation; let’s wait until we are knee deep in this, people have lost their homes and property, with no recourse. Is this what we teach our children, don’t think about the consequences now, just do it and we will deal with it later? We are doomed if this is the mentality of our government.
Cumulative significance before mitigation is significant impact, after mitigation less than significant with mitigation incorporated. The cost associated to mitigate will be astronomical and our outer communities will pay the price and be the ones to sacrifice once again. Fix other problems before creating new ones! This is fiscally, environmentally, and socially irreparable; ultimate damage is TBD and you have no right and its the least of our people who will be the sacrificial lambs. In closing, the lead agency is not accelerating housing, it is accelerating land grabs. You are to serve the interests of your constituents not your donors.
3.19 Wildfire
There is no longer a wildfire season, wildfires occur all year. This development in no way reduces wildfire risks, it enhances the risk as well as puts a further strain on already limited resources available to other communities during hard economic times. Wildfires in Maui, Southern California, Moss Landing battery facility.
Stanford University, Stanford Woods Institute for the Environment article: Wildfire News Releases Social and Economic Disparities Impact Wildfire Protection. This article states that low income communities in California are at a greater risk of suffering the consequences because they are less protected. Financial support, educational programs, wildfire preparedness? Page of 10 11
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Reference 4.3 - Mandatory Findings
When the farms are gone, remember, it’s forever!
For all the reasons stated in this letter, the attachments, and the other southeast property owners’ letters, we strongly oppose the PEIR as well as SEDA.
Sincerely,
Attachments (Pictures) to Ortiz Opposition Letter
Cc: Annalisa Perea, District 1 - [email protected] Mike Karbassi, District 2 - [email protected]
Miguel Ariaas, District 3 - [email protected]
Tyler Maxell, District 4 - [email protected]
District 5 - TBD Due to Special Election sent to City Clerk Nick Richardson, District 6 - [email protected] Nelson Esparza, District 7 - [email protected]
Todd Stermer, City Clerk - [email protected]
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David Ortiz & Natalie Ortiz
Elijah Ortiz
774
October 12, 2023
March 22, 2025
Via Email Transmission Only
City of Fresno, Council Members – Districts 1 thru 7
City of Fresno, Mayor, Jerry Dyer
City of Fresno Planning Department & Commissioners, Jennifer Clark & Janice Monroe Dear Council members, Mayor, Ms. Clark and Ms. Monroe:
This letter was previously submitted in October 23; however, we were informed the City failed to read it. Please accept this letter as our second submission. As a property owner living in the Southeast Development Area (SEDA), we are contacting you concerning Fresno City's Plan to develop 9,000 acres in this area. This letter follows and is in addition to the previous letter we submitted to your City. We are concerned that this development plan will be harmful to Fresno in numerous ways and, therefore, are asking you to oppose this plan. The plan failed to provide remedies to obvious problems; failed to provide direct answers regarding Air Pollution, Water, eminent domain, annexation, zoning, and full transparency. As you know, what the City is attempting to develop is a 15 minute city, a smart city under the guise of housing needed.
However, as you further know, with Hotel Fresno in development, the wide array of vacant buildings in downtown Fresno (all throughout the City of Fresno), as well as the vacant buildings located on the northeast corner of Kings Canyon and Clovis Avenue and vacant land and new development on Clovis and Tulare there are areas that you can develop, why you are choosing prime farmland is reckless. Furthermore, it was just in the news about the old UMC building being purchased, the city could have required that the purchaser use this building for low income housing.
The number one concern with this development is the lack of water. There are no concrete answers from Fresno's Planning Commission as to how they will provide water considering the magnitude of the population increase promoted.
We are also concerned with the loss of the best agriculture soil in the world. It is sandy loam soil making it prime soil for agriculture purposes. We request that the agriculture heritage of Fresno not be turned into housing.
We are also concerned with the loss of county residency, the inner city problems created with high density housing, the climate change concerns, the loss of personal property due to eminent domain, and the loss of property value.
775
Please let us know when an item related to SEDA will be on the City Council’s agenda.
Please help the Southeast Property Owners in opposing Fresno City's goal of developing the 9000 acres. We feel that the implementation of this proposal would have a negative effect on the property owners, the City of Fresno, and the production of food for the nation as well as the world. We request that this proposal not be implemented.
When the farmland is gone, it’s gone forever! Say NO to SEDA! Respectfully,
David & Natalie Ortiz
Elijah Ortiz
776
August 24, 2023
March 22, 2025
Adrienne Asadoorian, Planner
City of Fresno, City Clerk
Fresno City Council, Chairman and Council Members
2600 Fresno Street, Third Floor
Fresno, CA 93721
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
OPPOSE LETTER – EIR AND EDA/PROPOSED LAND USE/ANNEXATION/ BY THE CITY OF FRESNO Dear Chairman, Council Members, City Clerk, and Ms. Asadoorian:
This letter was submitted back in August 2023; it’s our understanding the City failed to read it. This is a second submission. Please accept this letter as our opposition to the City of Fresno’s EIR report and the SEDA development, annexation, proposed land use and the map thereto, which is an item that is expected to go before the City Council in or about October 2023.
Our specific property/land sits next to what is known as the Briggs Canal. It is our understanding that water in the Briggs comes from the Kings River. This water is what irrigates properties for the food that you and I to eat and serves a greater purpose. It is serviced and maintained by Fresno Irrigation District (FID). The District’s web page, under About Us, states as follows: The FID is a leader in California water, serving over 200,000 acres of prime agricultural farmland … Farmland sitting next to or that abuts a water structure such as ours is rare in Fresno County and not easily attainable. With our property adjacent to Briggs, it is irrecoverable and we would suffer a great loss. Therefore, we oppose the redevelopment and conversion of prime farmland to serve a purpose as Flexible Research and Development, which by the City’s definition means no residential uses will not be allowed. That would therefore leave eminent domain which the City has stated would not be used however if I do not sell and my neighbor does not sell then there is no other recourse but for the city to use eminent domain. We have all seen what has occurred with the Reedley lab and as stated by many of you council members the public is placed at risk and so many other factors such as disease, groundwater contamination were common concerns. If we in this area “Flexible Research and Development” please explain with specificity what occurs to the property/land/farm owners the process and procedures and confirm if our property will be taken from us through eminent domain?
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The City’s project and plan area consists of Prime Farmland. We own 2.49 acres of farmland in the proposed SEDA plan area. We house two tractors, chickens, apricot trees, as well as house pets on our land. We are current fosters for the county animal shelter and we are able to assist with fostering of more than one animal primarily due to the land we have. We work our land like most, if not all of the residents in this project area. Removing farmers who grow their own food; and/or who commercially feed this Community, County and State is reckless and negligent so that the City can expand. The City’s proposed land use map reflects for our parcel “Flexible Research & Development.” You want to take irrecoverable prime farmland for Flexible Research & Development when you can place Flexible Research & Development in the vacant Orchard Supply building (vacant for more than 5 years). Does that mean a lab such as that most recently found in Reedley, CA will go here. What does “Mixed Residential” mean on the City’s map? I specifically asked if that meant low income housing, please explain. Again, there are so many other vacant buildings within the City of Fresno that would allow you to do this that we do not need to remove, redevelop and destroy Prime Farmland or Farmland in general.
We have been told on numerous occasions that we would not be required to hook up to City services (water, sewage). We believe that to be incorrect. We were told that the City would not require us to; if not the City then who? If I am the only house that does not hook up, will I be forced to hook up? What will the cost be? Is there the potential for placement of a lien on my home due to the cost of these services? Please also confirm with past projects in this area or within the City (i.e. the area in and around north Jensen and Fowler to Kings Canyon etc.) how that land development was handled and if the landowners that were pre-existing were required to hook up to City of Fresno services (water/sewage).
If so, what were the services, what was the process, the cost, who was responsible to pay those charges or for those services; how many complaints did you receive from the landowners verbal and in writing, what was the remedy of said complaints; and if any of these homes resulted in liens being placed on landowners property/homes. Please also provide on current and past projects when property owners choose to stay and not sell, the city is therefore developed around their property, how many wells have gone dry due to the new development? Does this map become the zoning map for this area? Property owners were also told by the City representatives that eminent domain is not allowed or can or will not be used on property owners and their land located on the Land Use Map for this project, please confirm if this is an accurate statement? When I spoke to Jennifer Clark at the last in-person Drop In meeting she stated that should one homeowner decide not to sell or annex, they (property owner) will not be forced to annex; however, later she stated that they (City) cannot have one house one way while the rest of the area is annexed. Please clarify this statement by Ms. Clark. How will her stated change occur if one home cannot be different from the rest? Please explain who will impose and force the annexation of the land/property owners unwilling and opposing to said annexation? Please explain the process and the impacts to the landowners as well as the changes to zoning affecting the homeowner who did not willingly annex their land. Will I still be able to farm with all these houses around me? As you know, there is vacant land and buildings in or around Kings Canyon and Clovis Avenue; you have the Orchard Supply building that currently sits empty littered with homeless people. You have vacant land and buildings all throughout the City of Fresno and other cities within Fresno County and your plan is to destroy the Prime farmland of the SEPO (Fresno Southeast Property Owners). Destroy our farmland to build more homes, which thus creates more traffic, more congestion, more land and air pollution, more crime, and homelessness. With the Briggs Canal, if that waterway remains, with the increase in population and homelessness, our canals will turn into bathing facilities and used as restrooms. Please ask your homeless task force if that is a possibility that the homeless population uses waterways as bathing facilities and toilets? If this water is intended to feed the community, is it possible for fecal of 2 7
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matter, urine and other forms of illness to be in said water. Furthermore, take a drive around the City of Fresno, look at their canals and waterways, you currently have homelessness on your canal banks, tents, littered with trash (e.g. McKinley and Chestnut; in front of the Social Services building Phillip and Kings Canyon, the canal located east of Clovis Avenue--north of Kings Canyon by Orchard Supply). The City is unable to handle the demands of the current crisis and you want to spread it out. Your intent is to make a 15 minute city. We have seen the destruction of Paradise, Maui, when you began to impact the rural areas which are not intended to be within the city limits. We have water issues, we were just in a drought and there is no guarantee that we will be blessed with rain in the future. How will you control air pollution? Where will you get water from? How will you get the needed money to build the infrastructure for this plan?
The City of Fresno needs a boundary, do not grow it out here destroying the aesthetic rural southeast farmland.
The EIR REPORT:
Paragraph 1.2.1 lists the potential significant environmental issues that require further analysis.
Therefore, this is incomplete. In light of this statement, we oppose this EIR and request that you vote to deny/oppose/reject.
Paragraph located on PDF page number 762 titled (Wild-2) … Pollutant Concentrations from Wildfire impacts under this topic would be less than significant and there is no substantial change. However, we disagree and oppose that statement in that the City has a wide-ranging homeless population. What factors were considered as it relates to the ongoing homeless population within city limits when addressing this issue? We see many fires started due to homelessness. City streets are littered with trash, drugs and/or paraphernalia, and the homeless population utilizing fire in order to cook or stay warm during the winter months. Therefore, we disagree with this report and believe further studies should be done. As a reminder and as stated in paragraph 3.19.7, you would be converting prime ag land to residential and mixed-use land uses. Significant and unavoidable.
Chapter 4 Other CEQA Considerations – Bulletpoint AG-1 (… Conversion of Farmland to Non-ag Uses) states 2,475 acres of land designated as Prime Farmland, 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and 1,725 acres of land designated as Unique Farmland “scattered” throughout the plan area. The impact is significant. Based on this information contained in the EIR, we oppose and request that you vote to reject/deny/oppose and that this plan does not move forward. We further request that all maps be amended to identify the land properly in full transparency. Significant and unavoidable.
Bullet Ag-2 (… Conflict with Existing Zoning or Williamson Act Contract) – This paragraph states in part that according to the Williamson Act Property map, the majority of the Williamson Act properties within the SOI and City are located within the Plan Area. It further states that there is a significant impact on existing Williamson Act Contract land. Ultimately, you are still converting Williamson Act land to non-ag land. For this reason, we strongly oppose and request that you vote to oppose and/or deny on this basis. We further request that all maps be amended to identify the land properly in full transparency.
Significant and unavoidable.
Bullet Cumulative Ag Resources and Forestry Resources Impacts states and acknowledges that there is a loss of Prime Farmland within the plan area. Under your plan, you destroy existing Prime Farmland, Unique Farmland and small farms to build or develop community farming and small farms. The EIR of 3 7
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states that it will be a significant impact on Ag zoning and the Williams Act Contracts and there would be land use changes resulting in the conversion of farmland to non-ag uses and is unavoidable. We were told by the City at Drop-In meeting #1 on July 24, 2023 that we would not be rezoned should property owners choose not to sell. However, Jennifer Clark at the last in person drop-in meeting stated that we cannot have just one home not similarly zoned or annexed; therefore, please confirm what occurs based on Clark’s statement. Rezoning would only occur if a neighbor complained, which thus alters my land use. The City’s statement clearly is misleading and misrepresents what is occurring. I believe the impacts would be more than significant in that you are displacing property owners who are generational farmers, and farmers of their own land; how many of us current property owners would be physically displaced, and harmed financially. Based on this information we request that you strongly oppose and/ or deny based on this statement.
Impact Air-1 paragraph states this projects exceeds the San Joaquin Valley Air Pollution Control District another significant and unavoidable impact. Based on this paragraph we request you vote to oppose and/or deny based on this paragraph. Please note that we asked at the drop-in meetings why the Air Pollution District was not a part of these meetings to share in on the added pollution due to this development.
Air-3 states that since it cannot be foreseen the amount of construction occurring nor the exact location it cannot be determined if the emissions could be adequately controlled or reduced. Based on this statement, we believe the study is not complete as it must be looked at, precise and discussed. We are opposed based on this statement and request that you vote to oppose/deny.
Greenhouse Gas Emissions cumulative impacts are significant and unavoidable. Based on this statement we oppose and request that you vote to oppose/deny.
Impact NOI-1 – This statement states that impacts are significant and unavoidable. It also states that they are unable to quantify therefore there is no true, accurate impact identified and said report is incomplete. Based on this statement we oppose and request that you vote to oppose/deny. The Cumulative Noise impact is again noted as significant and unavoidable.
Exhibit 5-2 of the EIR shows just under 2,500 acres of Prime Farmland, and Farmland of Statewide and Local Importance, Unique Farmland of Importance, etc.
The EIR Table 5-1 under paragraph 5.7 states there is no location in the City where 45,000 homes (yes the Plan calls for 45,000) could be constructed while avoiding environmental impacts to ag land. Ag land would be impacted regardless. However, the land is not your basic ag land, it is Prime Farmland, it is land that sits next to the Briggs Irrigation Ditch which is rare, it’s farmland with statewide and local importance, it’s my backyard, small farming, however, we the property owners choose to define it, its our land that you want to dismantle, convert, and take so that you can build 45,000 homes, parks, and research and development.
The Orchard Supply Building on Clovis and Kings Canyon has sat empty for a number of years, that can be your research and development. You want to take our farmland, our livelihood, what feeds our families, our communities, for a bike trail, a park, a residential development to teach people to have a garden (who will teach them there is no guarantee that they will use it for such) all the while destroying the Prime Farmland we landowners have created destroying our way of life and country life. You will add 45,000 homes during a recession, a time when most cannot afford, thereby creating more empty houses.
You want to disrupt our way of life and destroy the farmland that we have just to build more homes that of 4 7
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most cannot afford. You want to help this community have your builders or developers lower the prices of their homes to sell those existing homes already built. Convert some of these developments/homes already in progress into mixed residential. Ag land should be the last thing we convert, land that currently feeds us. That salad you had for lunch, fruit, etc. came from one of us most likely.
We oppose the alternatives set forth in the EIR due to the type of land we are looking at as referred to in this report: Prime Farmland, Farmland of Statewide and Local Importance, Unique Farmland. Based on the impacts as listed above and based on viable alternatives, we request that you deny/oppose the EIR.
Furthermore, we oppose as this EIR shows that the plan is fiscally irresponsible and environmentally irresponsible. Finally, we request that the SEDA Plan be opposed and denied. If you review the Level of Significance as outlined in the EIR, we have listed below just a few that are classified as Significant and Unavoidable; therefore, for these reasons request you oppose and deny the City’s Plan and find another area or location in the City of Fresno for said projects. The impacts are significant and unavoidable.
Finally, we were informed and received in the mail, on July 21, 2023, the City’s flyer for the “Drop-In” meeting; the first meeting set for July 24, 2023, hosted by the City of Fresno. As you can see from the dates, this was three days before the first scheduled meeting. As I verbally stated and inquired about with the City during the July 24th meeting, what is a the meaning of a Drop-in meeting? Who decided to title this meeting as a Drop-In? To title it as such, is misleading and misrepresenting the intent of the City and purposes of said meeting. This title lacks transparency and is intended to misstate and mislead the purpose of an extremely important topic of discussion. It does little to ensure community/public attendance, involvement, participation and is a sure way to prevent and limit public input. This is an extremely important meeting that impacts the community of southeast Fresno, specifically the Fresno Southeast Property Owners (SEPO) and therefore, I believe was titled as such to limit the number of attendees and silence the opposition. Furthermore, Sontaya Rose from the Mayor’s office was in attendance and can confirm as well as other City representatives, the location picked for the first important meeting on July 24th lacked the capacity to hold the number of attendees, safely and comfortably, and posed a safety hazard in that it was about 105 degrees outside and there was no working AC inside said building thereby making it 110 degrees most likely inside with all the people in the building. As I stated on that date, I believe that was a safety hazard and put citizens at risk and compromised their health and well-being. Not one representative spoke to that and acknowledged that the first meeting should be rescheduled or some other remedy. The temperature inside the building added to the frustration felt by most of the members of the community. As I stated, this meeting labeled by the City is misleading, and a calculated manner in which to misrepresent, misstate, and divert the public’s attention to what it is in actuality and that is to take and change or convert land from the property owners. Should the meeting have been labeled annexation, eminent domain, town hall, any one of those trigger words the public at large would have a true understanding of what is occurring in the southeast area of Fresno and would understand the true discussions and importance of what is happening thereby enhancing attendance and opposition. Furthermore, I see no link for those to participate virtually due to a disability, medical necessity or some other personal reason. It was stated that the City would have one day assigned to a webinar. As you know, the topics of discussion can be convoluted and we the community would need time to research the Q&A dialogue that is provided to us therefore one day for those unable to physically attend is not enough. The public should not be limited to one day; we should all be afforded the same the ability to attend all meetings. Quite frankly, the information changes so frequently it would be in the best interest of the public to attend all meetings.
As such, in this regard, we strongly oppose. Furthermore, the meeting by the City on 7/24/23 was very unorganized and lacked structure and foundation as to the discussions and topics and the City ran out of comment cards in English—the space allowed for comments was minimal on such an important topic of discussion.
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I would also like to know why no representative of the County was in attendance at these meetings? A representative of the City was asked about annexing property and the City representative responded with the City would not annex. Please confirm the process for annexation and if not the City of Fresno, then please confirm the responsible agency. Please provide details on what grounds for annexation, the criteria or guidelines that must be met to annex property/land? If this response requires information from the County, I would ask that you direct City representatives to coordinate their response and work with the County of Fresno or any other agencies involved to get said information. I believe the City of Fresno when asked these types of questions it is their responsibility to answer in detail and they are required to be fully transparent and should be able to intelligently communicate if not their agency the appropriate agency involved and that would handle. To leave the response as simple as it’s not the City, is vague and intended to mislead the public. The City knows the answer to the question and to not provide a full response is intentional. It may not be the City’s responsibility to annex but if they know that it is the responsibility of another agency they should state as such.
I believe the SEDA homeowners/property owners have a right to know the following information. If there are costs associated with any of these requests, please confirm the amount or charges, in writing, prior to providing said information.
• Please provide the number of EIR’s that are submitted to the City of Fresno per calendar year; and how many are rejected or voted as unapproved; how many are submitted to LAFCo per calendar year, voted as unapproved or rejected and the bases/reason for said vote. • On April 25, 2023, an item went to the Fresno County Board of Supervisors, Agenda Item #8 regarding a variance application that falls within SEDA. During Mr. Assemi’s comments to the Board, he referred to having received a timeline from the Mayor on the project. Please confirm what that timeline was and if a copy can be provided electronically to the property owners should they wish to received; and please explain why a developer would have that information but not the property owners who would be negatively impacted by SEDA? When was the timeline (Assemi refers to in his comments) provided to him by the Mayor? When was this timeline provide to the property owners (SEPO) who will be impacted? If it has not been provided to the property owners, why? My household has not received a timeline from the Mayor nor was one provided to property owners at any drop-in meeting and to my knowledge a timeline has not been provided to property owners in any meeting thus far by the City of Fresno. Please confirm how many variances in the SEDA project area have gone through the process, what that process is, including how many have gone to the County of Fresno Board of Supervisors for vote and the vote result from the start of the project(s)/plan to present? • Please identify the land parcels, land and farmland in the SEDA project area that have been purchased by developers, date of purchase, names of builders, corporations, school district, water districts, and any other business organization, corporation or entity from the start of SEDA to present that have purchased. Please include the names, cross-streets, parcel numbers and any other identify factors of the land pending a sale, owned, purchased or sold. • Please provide the information on when the property sold or was purchased and include land, property that is pending sale/purchase.
• Please provide the members of our community, SEPO (Southeast Property Owners), with information on how much farmland/land is currently owned in Fresno County, CA by Darrius Assemi and/or Granville Homes and any other developers, builders or business organizations. of 6 7
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If this type of development continues, the lack of farmland to our community as well as the substantial loss of prime farmland is irrecoverable and factor in good farmland with irrigation resources such as ours, it is irrecoverable. Therefore, we strongly oppose the EIR and the SEDA development and ask that you deny and reject both in order to protect and preserve our homes and land.
The City of Fresno needs a boundary, do not grow it out here destroying the aesthetic rural southeast farmland.
Once the farmland is gone, it’s gone forever! Say NO to SEDA! Thank you.
David & Natalie Ortiz
Elijah Ortiz
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March 24, 2025
City of Fresno
Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, CA 93721
Sent by email: [email protected]
RE: Public Comment on 2025 Recirculated draft Program Environmental Impact Report for Southeast Development Area Plan
Dear Ms. Pagoulatos:
On behalf of the Fresno Madera Tulare and Kings Counties Central Labor Council and Regenerate California Innovation (RCI), I respectfully request the City incorporate the following comments, and attachments, regarding the Southeast Development Area Specific Plan and Recirculated draft Program Environmental Impact Report into the record of this matter. We look forward to substantive responses to these comments.
NOTE: Due to the fact that the infrastructure plan, budget, and public facilities financing plan have not yet been released for public review or comment, these commenters respectfully request an extension of 45 days from the date they are released for public comment on the SEDA Recirculated draft EIR. See section 7.e, infra.
1. The City’s contract with HCD does not require that the City Council adopt the SEDA Plan, nor that it approve the SEDA EIR.
The City’s application for the grant that funded the SEDA EIR1 includes Schedule F, which identifies Council adoption as a “deliverable” under the grant. The Grant Agreement itself,2 1 Attached hereto as Exhibit 1.
2 Attached hereto as Exhibit 2. See specifically, Exhibit D, Section 4 (Remedies of [sic] Non-performance), subsection E. Similarly, Senate Bill 2 Planning Grant Program Year 1 Guidelines (https://www.hcd.ca.gov/grants-funding/active-funding/planning-grants/docs/sb2-planning-grant784 Comment letter—SEDA Recirculated PEIR March 24, 2025 2
however, while requiring a “strong implementation component,” recognizes that the locality may only formally adopt the completed planning document “where appropriate.” In this case, for the reasons set out in this letter, adoption of the SEDA Plan and approval of the Recirculated Program Environmental Impact Report would not be an appropriate exercise of the City Council’s legislative discretion, nor can the SB2 grant award contract compel the City Council to exercise its sovereign legislative discretion in such a fashion.
2. If the language of Section 4 of the Grant Agreement were to be interpreted as requiring the City Council to adopt the SEDA Plan and associated documents, it would be null, void ab initio, and unenforceable.
At Section 17, the General Terms and Conditions applicable to the grant award contract provide for severability “[i]n the event that any provision of this Agreement is unenforceable or held to be unenforceable.” Standard Grant Conditions also provide for severability of unenforceable provisions, at Section 10.A.
However, “[t]he California Constitution provides that a county or city may make and enforce within its limits ‘all local, police, sanitary, and other ordinances and regulations not in conflict with general laws.’ (Cal. Const., art. XI, § 7.) From this police power, a California city derives its power to control land use and enact comprehensive land use and zoning laws.” Discovery Builders, Inc. v. City of Oakland, 92 Cal.App.5th 799, 810, 310 Cal.Rptr.3d 241, 249 (2023) [citations omitted].
Since land use regulations involve the exercise of police power (Summit Media LLC v. City of Los Angeles, 211 Cal.App.4th 921, 934, 150 Cal.Rptr.3d 574 (2012)), any agreement that functions to divest a municipality of its ability to exercise its police power with respect to land use laws is invalid. Discovery Builders, supra, 92 Cal.App.5th at 812. This responsibility extends to a city’s consideration of an environmental impact report: “CEQA confers the duty upon the local lead agency to produce an adequate EIR” and this “statutory obligation may not be the consideration for a contract or promise, nor may the County bargain away its constitutional duty to regulate development.” Mission Oaks Ranch, Ltd. v. County of Santa Barbara, 65 Cal.App.4th 713, 723 (1998), quoted in Discovery Builders, supra, 92 Cal.App.5th at 812.
Thus, the City of Fresno could not have obligated itself as a condition of grant approval to adopt the SEDA Plan, nor to approve the SEDA EIR. In this situation in particular, the EIR is so inadequate across multiple functions, chapters, and analyses that approval would constitute an abuse of discretion.
3. The City has violated material terms of its SB 2 agreement with HCD in the following respects:
guidelines.pdf) include plan adoption among Program Objectives (Section 101, subd. (a) and (b)), Eligible Uses for the funding (Section 302, subd. (a) and (b)). However, among Remedies of [sic] Nonperformance, Section 603(c) suggests only that “Localities that do not formally adopt the funded activity could be subject to repayment of the grant.” [emphasis added] 785
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a. The City has failed to produce a Public Review Draft of the Infrastructure Plan, Infrastructure Financing Plan, and Fee Nexus Study.
At Section C, subsection 3 of the City’s application for the planning grant that funded the SEDA Plan and PEIR, the City commits to using the funding in support of a State Priority Policy Area, specifically “Housing Related Infrastructure Financing and Fee Reduction Strategies.” Under Section D, Proposed Activities Checklist, the City commits to item 15, “infrastructure financing plans.” At Section E, Project Description, the City acknowledges that “an infrastructure assessment [and] fiscal nexus study must be completed prior to adoption [of a SEDA Specific Plan].” At Appendix A, the City recognizes explicitly that:
“To implement a large-scale master planned community including infrastructure improvements and annexation, an analysis of the currently existing infrastructure, the infrastructure necessary to support development, and the gap is required. Additionally, the General Plan of the City of Fresno requires that all new annexations are fiscally neutral expansions to the City’s General Fund budget. This requires a fiscal nexus study to show the anticipated costs and revenues associated with the annexation and mechanisms to fund any needed infrastructure gaps.”
The costs of preparing the Infrastructure Assessment, Financing Plan, and Fee Nexus Study were built into the grant application, at a cost of $87,500.3 The 2020 Consultant Services Agreement between the City and HCD incorporated these items as deliverables4. Nevertheless, as of the date of this writing, the studies, plans, budget, etc. are not available. In 2023, in response to requests for information from members of the public, the City admitted that it had such documents, but refused to make them public, claiming (without evidence or justification) that they were “privileged,” that the public interest in keeping them secret outweighed the public interest in disclosing them, because the studies were “ongoing” (even though the Plan and its PEIR had already been released for public comment), and that disclosure of infrastructure cost estimates would provide “incomplete information.” Given the complexity of the SEDA planning project, and the fact that an infrastructure analysis, budget, plan, nexus study, and financing mechanisms are integral components of the SEDA Specific Plan and have environmental impact ramifications, the City’s failure to release these documents with the Specific Plan and PEIR is a material breach of the City’s commitments to HCD in accepting SB2 grant funding.
b. The SEDA Plan and Recirculated DPEIR show the City’s grant application misrepresented that it would use SB 2 grant funding to “accelerate housing production.”
3 City SB2 Planning Grants Application, Schedule F.
4 Consultant Service Agreement between City of Fresno (City) and FirstCarbon Solutions (Consultant), Southeast Development Area Specific Plan, executed November 4, 2020, Scope of Services, Subtask 1.1.2,
1.1.3 – 1.1.7, 1.1.8 – 1.1.9, and Task 2.
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The City’s grant application, Section D, subsection 3, claimed the Plan would include “environmental analyses that eliminate the need for project-specific review.” At Section E, Project Description, the City promised to deliver a Program EIR under which “future development will also utilize an expanded exemption under Government Code Section 65457 that will apply to certain residential, commercial, and mixed-use projects that are consistent with a specific plan adopted pursuant to Government Code, Article 8, Chapter 3 and would be exempt from CEQA.”
The Government Code § 65457 exemption would create a no-new-EIR presumption for all projects within SEDA, unless somebody happens to become aware of and can make the case that the proposed development project requires “substantial changes” to the PEIR, that there have been “substantial changes” in circumstances requiring major revisions to the PEIR, and/or that there is new information unknown (and unknowable) at the time of PEIR certification.
Public Resources Code § 21166.
This is all well and good when the Plan-level PEIR has accurately analyzed the environmental impact data, and has created the Plan-level coordinated mitigation structures that will realistically minimize cumulative impacts, either through Plan-level design and land use decisions or through enforceable conditions of project approvals. But the SEDA Plan EIR does not deliver on the promised “environmental analyses that eliminate the need for project-specific review.”
Generally, the SEDA draft PEIR unlawfully abdicates its responsibility to calculate impacts, disclaiming capacity to calculate impacts of the SEDA Specific Plan because site- and projectlevel planning have not yet been done. The PEIR essentially takes the position that Plan-level mitigation is impossible, as exemplified by its approach to air quality impacts: “there is currently not enough information to quantify emissions of specific project development that may occur under the proposed project. … [D]ue to the size of the proposed {SEDA Plan] project, there is not sufficient feasible 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.” PEIR, p. ES-6 [emphasis added].
In fact, the PEIR appears indifferent to the concept of plan-level mitigation. As drafted, impact analysis and mitigation either would occur on a piecemeal basis, as discretionary projects within the SEDA footprint come up for approval, or would not occur at all, as future SEDA development projects get a pass, falsely claiming approval of the PEIR means impacts have already been considered and mitigated, and using § 65457 to “tier” off phantom environmental impact analyses and nonexistent mitigation measures. This approach defeats one of the essential functions of a Program EIR, to “ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis.” CEQA Guidelines, § 15168(b)(2).
Here, the Plan promotes case-by-case environmental impacts analyses, as each SEDA development project is proposed. Similarly, determination and application of missing mitigation measures are deferred to environmental reviews of discretionary projects (if such environmental reviews are ever done), again one by one. The result at the Specific Plan level is 787
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fatally deficient cumulative impact analyses, no (or illusory) mitigation to address cumulative impacts, and very few additional-analysis conditions on project-level entitlements. These failures of analysis show the City has failed to fulfill its commitment to create a Specific Plan that “accelerates housing production.”
c. The City has failed to produce the streamlining checklist promised in its grant application.
The City’s grant application, Section E, Project Description, promised that the Program EIR to be funded with SB2 grant monies “will include a detailed programmatic evaluation of activities to be carried out through [the] Specific Plan and will allow the City to incorporate feasible mitigation measures including a streamlining checklist to evaluate site specific operations within the scope of the program EIR. This use of streamlining will fast-track the production of much-needed housing for the City and the region.”
This concept of streamlining meshes well with a Specific Plan calling for tens of thousands of units over 9,000 acres, to be implemented in a largely greenfield geography ten miles from the city’s center. Such a checklist could incorporate many standard mitigation measures to reduce the massive environmental impacts that implementation of such a plan unavoidably entails. If the City had followed through on its commitment to include “environmental analyses that eliminate the need for project-specific review,” deploying those analyses in a checklist format would have been an excellent strategy for expediting new-home construction.
However, neither the SEDA Plan, nor any of the three versions of the draft PEIR released to date, provides any such “streamlining checklist.” Instead, both the Plan and the EIR repeatedly admit that the City will only evaluate “site specific” impacts within SEDA on a project-byproject basis, and will with each project start from scratch on whether there will be environmental review, whether there are impacts that meet the threshold of Public Resources Code 21166, and whether mitigation measures will be imposed, and if so which ones. (Please see comments, infra, regarding mitigation measures and the EIR as a tiering document.) This approach is the very opposite of a “fast-track” to production of new housing, building both delays and expensive environmental reviews into discretionary development projects within the SEDA footprint.
4. The City cannot approve the SEDA Plan and EIR until it has a valid General Plan.
In its now-invalidated5 2021 Greenhouse Gas Reduction Plan, the City acknowledged that its 2014 General Plan was no longer compliant with new laws and regulations.6 A general plan 5 South Fresno Community Alliance v. City of Fresno, 2024 WL 3663122, August 6, 2024. 6 City of Fresno GHG Reduction Plan Update, March 2021, pp. 1-1 (General Plan’s Greenhouse Gas Appendix must be updated to comply with SB 32, CARB’s Climate Change Scoping Plan, and the California Supreme Court’s Newhall Ranch decision); and 1-2 (General Plan update required in order to bring it into conformance with current local and State law. CLC and RCI join, and incorporate by this reference, the portions of the March 24, 2025, comment letter submitted by Douglas Carstens and 788
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must be reviewed and revised as circumstances warrant. Gov’t Code § 65103, subd. (a); DeVita v. County of Napa, 9 Cal.4th 763, 792 (1995) (“the [planning] agency … is required periodically to review and revise the general plan to ensure that its elements remain integrated and internally consistent.” [emphasis in original]). Above all, “the status of a general plan as the ‘constitution’ for the City's development requires that the plan be reasonably complete and current.” Camp v.
Board of Supervisors, 123 Cal.App.3d 334, 351, 176 Cal.Rptr. 620 (1981).
The level of housing need, and demand, is a crucial component of a city’s land use planning decisions, and flows directly from the rate at which the city’s population is growing. The City of Fresno’s 2014 General Plan was based on an average annual growth rate of 1.24%7. However, the city is no longer growing at that robust pace. The City’s March 2025 draft EIR for the West Area Neighborhood Specific Plan acknowledges this new reality, citing U.S. Census Bureau and California State Department of Finance data showing Fresno’s growth at one-sixth the 2014 rate—0.2%—as of 2024.8 Population growth out to 2035 for the whole City of Fresno is thus reduced from 2014 projections by approximately 184,000 residents9—well over the anticipated population of SEDA alone.
Approval of SEDA’s 45,000-unit plan based on the 2014 General Plan’s materially outdated and erroneous population projections and housing demand assumptions would be consistent with the 2014 General Plan, but also an abuse of discretion because contradicted by more recent and more accurate record evidence. This is the very reason a planning agency must keep its General Plan “reasonably complete and current.”
5. If the 2014 General Plan is not invalidated by failure to comply with State mandates, changed circumstances, and new information, the SEDA EIR would have to be consistent with that General Plan. It is not.
a. The SEDA Plan’s Consistency analysis is fatally flawed.
The Draft PEIR offers a General Plan Consistency Analysis at p. 3.11-24 to -37, Table 3.11-1.
However, many of the consistency determinations sound more like Orwellian double Michelle Black on behalf of the Sierra Club, Central Valley Partnership, and League of Women Voters that relate to the General Plan’s failures to comply with AB 170 (Gov’t. Code § 65302.1—General Plans must incorporate specified air pollution information) and SB 1000 (Gov’t. Code § 65302(h)(2)—General Plans must incorporate an Environmental Justice element).
7 City of Fresno 2014 General Plan, p. 1-24.
8 Recirculated Draft EIR – West Area Neighborhoods Specific Plan, p. 3.12-1, Table 3.12.1—Environmental Setting—Demographics--Population Trends.
9 The 2014 General Plan projects 226,000 new residents by 2035 (p. 1-23); Department of Finance growth projections would result in only about 22,877 new city residents during that period (calculated from Department of Finance’s predicted 41,594 County population growth, multiplied by historical City of Fresno 55% share of county population increases). See also, fn. 11, infra. 789
Comment letter—SEDA Recirculated PEIR March 24, 2025 7
speak10 than planning professionals’ analysis. A few examples (of many) follow. They have in common that they rely on unquantified assertions unsupported by record evidence, and/or in fact contradicted by the evidence in the record.
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 noncorridor infill areas, and vacant land. Consistency Determination: Consistent. The proposed project is consistent with the City’s strategy to focus on infill development within existing City limits. The proposed project would minimize the City’s outward expansion while promoting vibrant, sustainable communities.” SEDA EIR, p.
3.11-26.
IN FACT: Not consistent. Approval of SEDA would torpedo the General Plan’s goal of ensuring approximately one-half of future residential development would occur in infill areas. (See, UF-13, infra.) Moreover, the proposed project itself is the very antithesis of “infill,” since it is not located within the City limits and does not in any other way resemble infill. Its siting outside the very farthest southeast rim of the City maximizes outward expansion, and the massive additional infrastructure that must be built to serve it will create a growth-inducing dynamic far from the infill areas that are the focus of the 2014 General Plan. Finally, the expenditures on those SEDA-serving infrastructure projects will suck resources away from the billions of dollars in infrastructure construction, replacement, improvement, and repair that would “promot[e] vibrant, sustainable communities” within the City limits.
UF-13 “Locate roughly one-half of future residential development in the Growth Areas—defined as unincorporated land as of December 31, 2012 SOI—which are to be developed with Complete Neighborhoods that include housing, services, and recreation; mixed-use centers; or along future BRT corridors. Consistency Determination: Consistent. The proposed project is a comprehensive plan for the nearly 9,000-acre Southeast Growth Area. The proposed project concentrates residential development in Neighborhood Town Centers, consistent with the General Plan concept of complete neighborhoods.” SEDA EIR, p. 3.11-26.
IN FACT: Not consistent. Approval of SEDA would torpedo the General Plan’s goal of limiting development in Growth Areas to one-half of new residential construction. Due to reduced population projections, and concomitant reduced housing demand, the 10 “Doublespeak is language that deliberately obscures, disguises, distorts, or reverses the meaning of words. Doublespeak may take the form of euphemisms (e.g., ‘downsizing’ for layoffs and ‘servicing the target’ for bombing), in which case it is primarily meant to make the truth sound more palatable. It may also refer to intentional ambiguity in language or to actual inversions of meaning. In such cases, doublespeak disguises the nature of the truth. Doublespeak is most closely associated with political language used by large entities such as corporations and governments.” Wikipedia, https://en.wikipedia.org/wiki/Doublespeak, accessed March 19, 2025 [bolded emphasis in original; internal links and footnotes omitted].
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Comment letter—SEDA Recirculated PEIR March 24, 2025 8
whole city of Fresno will need only about 7,600 new housing units by 2035. The SEDA’s 2035 target is 14,900, almost twice the number needed11 for the entire city during that period, and perversely incentivizing suburban sprawl12 over the infill development the General Plan seeks to promote.
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. Consistency Determination: Consistent. The proposed project provides for the development of a range of housing types, building forms, and land uses to meet the needs of both existing and future residents.” SEDA EIR, p. 3.11-26.
IN FACT: Not consistent. As is apparent from the Project Description13, SEDA is a greenfield plan, not an infill plan. However well-planned they may be, SEDA’s 9,000 acres are located far from the portions of the City that could reasonably meet the 2014 General Plan’s definition of “infill” in UF-12, supra.
LU-4 “Enhance existing residential neighborhoods through regulations, code enforcement, and compatible infill development. Consistency Determination: Consistent. The proposed project would design and implement a vision that would allow new growth to occur without negatively affecting existing neighborhoods.
IN FACT: Not consistent. The SEDA Specific Plan and EIR include no analyses, policies, or provisions that could conceivably affect regulations, code enforcement, or infill development in existing neighborhoods in the City of Fresno, except negatively.
Far more likely, adoption of the Plan would extinguish possibilities for new infill development, including by sapping resources needed for infill-supporting infrastructure 11 Assuming, based on state Department of Finance 2035 projections: Fresno County population increase of 41,594 people x 55% (historical City of Fresno share of population growth) = 22,877 people, ÷ 3 (average number of persons/dwelling unit) = 7,626, total dwelling units needed to accommodate population growth in the entire City of Fresno by 2035. 12 This dynamic has been well documented. See, e.g., Patterns of Sprawl in Fresno and the Central San Joaquin Valley, Freemark, Fu, Rosenow, Su, May 2024, p.8 (copy attached): “As sprawl redirects growth from one part of a metropolitan area to another, one additional consequence is that housing development becomes rare in jurisdictions and neighborhoods with low incomes and low demand, since developers can respond to demand for homes by building at the far edge of regions, where there are low land costs and high demand (Freemark 2022). This may lead to low-income neighborhoods experiencing disinvestment and decay, while high-income, suburban neighborhoods benefit from the majority of private and public investment.” Accord, Fresno Urban Decay Analysis, ECONorthwest, 2023 (copy attached).
13 “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.” SEDA Recirculated Draft PEIR, p. 2-4.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 9
improvements and for the repairs and maintenance that legacy neighborhoods need to avoid falling into blight and decay.
LU-5 “Plan for a diverse housing stock that will support balanced urban growth, and make efficient use of resources and public facilities. Consistency Determination: Consistent. The proposed project would design and implement a vision that would allow the City to grow in ways that equitably expand the economy and housing stock while protecting public health. The proposed project represents an opportunity to meet emerging market demands, provide muchneeded diversity in housing stock, and enrich communities with safe, walkable, and inspiring urban environments.”
IN FACT: Not consistent. The SEDA Plan, proposing intensive development of a 9,000- acre greenfields site, will require massive new construction of public facilities, whereas “efficient use” of resources and public facilities would dictate that the City satisfy its future housing needs in an area where such facilities already exist, such as the West Area Neighborhood Plan area, or the thousands of infill sites within the city limits. The effect of new growth into SEDA will not promote equity nor “enrich” existing neighborhoods (where Fresno’s low-income housing stock is located), but will deprive those neighborhoods of resources they need to fight blight and decay. The Plan does not impose conditions of entitlement on SEDA developments that would be at all likely to supplement the City’s stock of low-income housing. Finally, the public health protection claim here flies directly in the face of the air quality impacts data in the PEIR Appendix B, which show huge unmitigated increases in air pollutants, toxic air contaminants, and diesel particulate matter. Notwithstanding CEQA and California Supreme Court mandates, the EIR fails to calculate the ozone pollution that Plan development would generate, or to provide a human health impact analysis. A claim that the plan protects human health, on this record, is facially false.
LU-9 “Plan land uses, design, and development intensities to supplement and support, and not compete with, the Downtown. Consistency Determination: Consistent. The proposed project is a comprehensive plan for the nearly 9,000-acre Southeast Growth Area, located to the east of the Downtown. The proposed project concentrates residential development in Neighborhood Town Centers, consistent with the General Plan concept of complete neighborhoods. These uses would support the Downtown but would not compete with the Downtown.”
IN FACT: Not consistent. The SEDA Plan area is ten miles from Fresno’s Downtown. At best it will compete with Downtown, drawing away the private investments and public institutions that give an urban downtown core its crucial role in a city’s life. More likely, the SEDA development will make it impossible for the City to supplement state grants to ensure completion of downtown infrastructure upgrades, essential to a thriving downtown. b. The SEDA Specific Plan violates California’s Planning and Zoning Law in that its leapfrog approach to growth fundamentally contradicts the 2014 General Plan objectives, violating consistency requirements.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 10 California Government Code § 65454 provides that “[n]o specific plan may be adopted or amended unless the proposed plan or amendment is consistent with the general plan.” As of 2018, the Legislature’s amendment of Government Code § 65700 applied this consistency requirement also to charter cities such as Fresno. Kennedy Commission v. City of Huntington Beach, 91 Cal.App.5th 436, 443, 308 Cal.Rptr.3d 461, 468 (2023), reh’g denied (June 7, 2023), review denied (July 19, 2023).
Apart from and in addition to the many errors in the PEIR’s General Plan Consistency Analysis (see section 5.a., supra), the SEDA Plan is inconsistent in that it upends the 2014 General Plan’s proposed growth trajectory, which calls for SEDA development to occur last, after Development Areas 1 and 2. 14 The General Plan explains that “[t]he pace of new development in the Development Areas needs to be balanced with the City’s goals for achieving significant reinvestment within the 2012 City Limits.”15
In its 2014 General Plan, unusually for Fresno, the City Council purposefully declined to expand the City’s Sphere of Influence based on a reasoned analysis of the effects suburban sprawl had created and would create into the future if not curbed. The 2014 General Plan explicitly chose a different path:
Continued growth outwards creates transportation and air quality issues, as well. The continued siting of major retail and commercial uses, as well as jobs, at Fresno’s urban fringe is lengthening travel times and increasing traffic levels (and air pollution) disproportionately faster than the rate of population growth, due to inefficient location selection. Given the restrictions on and impacts of increasing Fresno’s land area, the Plan promotes the highest and best use of land within Fresno’s current city limits, phases growth into unincorporated areas of the SOI, and avoids de-investment in Downtown and established neighborhoods. Furthermore, certain patterns of land development can increase costs to the City in excess of related revenues and essentially reduce fiscal resources. The Plan seeks to discourage this type of development and, at the least, ensure that all development covers its fair share of public costs.16 The SEDA draft PEIR attempts to explain away its inconsistency with these goals and objectives, acknowledging that “SEDA was intended to be developed once other infill initiatives were given time to gain momentum,” and that “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).” But then the PEIR goes on to argue that “there is a 14 2014 General Plan, Figure I-3, Residential Capacity Allocation, which shows Development Areas (“DA”s) in order of priority; SEDA comprises DA-3 Southeast and DA-4 East, the City’s fifth- and sixthlevel development priorities. The West Area Neighborhoods Specific Plan Area is labeled DA-1 North, and is the first-level priority for new development.
15 Id. at p. 3-19.
16 2014 General Plan, Ch.7, Resource Conservation & Resilience—§7.2 Use of Infrastructure & Resources, p.7-7
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Comment letter—SEDA Recirculated PEIR March 24, 2025 11 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.”17
But the facts do not support a “sense of urgency”—population growth has plummeted, taking with it the demand for new housing, and the City is already on track to adopt the proposed West Area Neighborhoods Specific Plan sometime in summer 2025.18 The West Area Plan is likely to result in housing units long before SEDA, since the West Area Plan will be implemented upon a platform of already-existing (if still incomplete) infrastructure, whereas SEDA will require construction of all significant urban-supporting public improvements.19 The West Area Plan alone will accommodate over 50,000 new housing units; when added to the 43,512 units20 on parcels zoned and appropriate for housing within existing City limits, the City will not need SEDA to meet its housing needs for many decades.
To allow SEDA to jump the line into first place is antithetical to how the City has planned its growth. Such reorganizing of development priorities is inconsistent with the General Plan, and creates significant adverse fiscal and environmental consequences for the City and its existing neighborhoods that the 2014 General Plan specifically intends to avoid by its new-growth priorities hierarchy.
c. CLC and RCI incorporate comments submitted on behalf of County of Fresno.
In support of their comment that the draft PEIR cannot be adopted under the 2014 General Plan, CLC and RCI hereby join, and incorporate by this reference, the portion of the September 4, 2023 comment letter on the 2023 draft SEDA PEIR, submitted by Jeffrey Reid on behalf of the County of Fresno, Department of Public Works and Planning, at pages 5 through 6 (Section C).
6. The City cannot approve the SEDA Specific Plan until it has complied with the prerequisites imposed via LAFCO Resolution USOI-144.
CLC and RCI join, and hereby incorporate by this reference, the portions of the September 4, 2023 comment letter on the 2023 draft SEDA PEIR submitted by Jeffrey Reid, on behalf of the County of Fresno, Department of Public Works and Planning, pages 1 through 3 (Section A), 17 SEDA Recirculated Draft PEIR, p. 2-1. The PEIR neither documents nor otherwise refers to “inmigration,” anticipated or otherwise. 18 The West Area Plan was released for public comment on March 12, 2025, and is expected to go to the City Council during the summer. https://www.fresno.gov/planning/plans-projects-underreview/#west-area-neighborhoods-specific-plan. 19 One of the important reasons the 2014 Plan put SEDA area last in line as a site for new housing was precisely that the area lacks public infrastructure to support extensive residential and commercial development. 2014 General Plan, p. 1-19.
20 Fresno Multi-Jurisdictional Housing Element, December 2024, Table 1E-3.23: Housing Capacity by Community Plan/Specific Plan Area, p.1E-3-145.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 12 and pages 10-11 (Section H).
7. The SEDA Specific Plan violates California Planning and Zoning Law CEQA in that it omits components required by statute, and fails to meet standards for public involvement by failing to timely circulate for public comment an infrastructure plan and infrastructure financing plan.
a. Essential components are missing from the SEDA Plan documents.
California Government Code § 65451 mandates that every specific plan include certain “Required contents.” Subsection (a) of the statute requires that a specific plan “include a text and a diagram or diagrams which specify all of the following in detail … “(2) The proposed distribution, location, and extent and intensity of major components of public and private transportation, sewage, water, drainage, solid waste disposal, energy, and other essential facilities proposed to be located within the area covered by the plan and needed to support the land uses described in the plan.
…
“(4) A program of implementation measures including regulations, programs, public works projects, and financing measures necessary to carry out paragraphs (1), (2), and (3).” Neither the Specific Plan, nor the Recirculated Draft PEIR released for public comment on February 7, 2025 includes the text or diagrams specifying the “essential facilities proposed” for the Plan as required by § 65451(a)(2), nor the implementation and financing measures required by § 65451(a)(4).
b. The City has failed to release timely for public comment the missing components of the SEDA Plan proposal.
In adopting Title 7, Division 1, Chapter 3 of the Government Code, addressing Local Planning and Zoning, the California Legislature declared its intent “to provide an opportunity for each city and county to coordinate its local budget planning and local planning for federal and state program activities, such as community development, with the local land use planning process…” Cal. Gov’t Code § 65300.9.
The SB2 Planning Grants Application included, at Schedule F, a Project Timeline and Budget, which called for release of the Public Review Draft of the Infrastructure Financing Plan and the Nexus Study at least three months in advance of City Council consideration of the Plan and associated documents. Nevertheless, and notwithstanding the explicit strictures of the statute, and promises made throughout the Specific Plan and its PEIR, the City has failed to release either an infrastructure plan disclosing the details required by § 65451(a)(2), or an infrastructure budget, nexus study, and financing plan, as required by § 65451(a)(4).
Especially pertinent to the fiscal wisdom of City investment in SEDA infrastructure: the Consultant Service Agreement required a Qualitative Fiscal Review, but as of this writing, in the last few days of the public comment period for the Recirculated draft PEIR, no such review has been made public. Such a review should clarify “whether or not the existing targeted tax 795
Comment letter—SEDA Recirculated PEIR March 24, 2025 13 sharing parameters will remain feasible with the development of the SEDA Specific Plan.”21 Withholding from the public such critical information is inconsistent with provisions of both the Planning and Zoning Law, and of CEQA. See, e.g., Cal. Gov’t Code § 65351,22 Pub. Res. Code § 21000, et seq. (“If CEQA is scrupulously followed, the public will know the basis on which its responsible officials either approve or reject environmentally significant action, and the public, being duly informed, can respond accordingly to action with which it disagrees. The EIR process protects not only the environment but also informed self-government.” Golden Door Properties, LLC v. Superior Court of San Diego County, 53 Cal.App.5th 733, 763, 267 Cal.Rptr.3d 32, 55 (2020), as modified on denial of reh’g (Aug. 25, 2020) [citations omitted].) c. Failure to timely disclose documents related to SEDA infrastructure expenditures defeats CEQA’s requirement that all environmental impacts be disclosed, considered, and mitigated where possible.
i. Environmental impacts of construction and operation of infrastructure are neither disclosed nor mitigated.
Constructing utilities and other needed infrastructure for 9,000 acres’ worth of residences, schools, businesses, parks, etc., will require grading, excavating, paving, and other soildisturbing activities that beyond peradventure will generate air pollution and greenhouse gases, among other impacts. Operation of the infrastructure will entail still further impacts.
The PEIR simply claims that project-level construction mitigation measures will be adequate to mitigate all impacts. However, given that the PEIR fails to mitigate air quality impacts for noninfrastructure activities, the additional impacts infrastructure construction will have on air quality must be analyzed in terms of the extent to which they will cumulatively contribute to air pollution. Operational impacts must also be evaluated.
ii. The PEIR Project Description fails to include information now known about infrastructure needs, or to calculate the environmental effects of those parts of the project.
The PEIR Project Description represents that at the time of circulation the City had already done infrastructure analyses, referencing a “Public Facilities Financing Plan” (p.2-3), and an Infrastructure Plan with “more closely specified” details about types of infrastructure to be constructed in the Specific Plan area.23 But the Recirculated PEIR includes none of the descriptive information required by Government Code § 65451(a)(2), nor analysis either of the 21 Consultant Service Agreement between City of Fresno (City) and FirstCarbon Solutions (Consultant), Southeast Development Area Specific Plan, executed November 4, 2020, Exhibit A, Attachment A: Scope of Services, Task 1.2.
22 Addressing public involvement in proceedings related to a general plan, and made applicable to Specific Plan preparation, adoption, and amendment by Government Code § 65453(a). 23 See, p.2-8, roads; p.2-17, “sustainable infrastructure,” not otherwise specified; p.2-18, “holistically coordinated infrastructure,” not otherwise specified.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 14 construction or the operational impacts of supplying that infrastructure, violating CEQA’s express purpose that agencies “give ‘major consideration’ to preventing damage to the environment when conducting their regulatory functions. (Pub.Resources Code, § 21000(g).)” See, Santiago County Water Dist. v. County of Orange, 118 Cal.App.3d 818, 829-831, 173 Cal.Rptr. 602, 607-609 (1981) [failure to account for impacts related to project water delivery facilities].
See also, San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus, 27 Cal.App.4th 713, 730, 32 Cal.Rptr.2d 704 (1994), as modified (Sept. 12, 1994) [omission of reference to wastewater treatment plant recognized as necessary to the project resulted in an improperly “curtailed” and “distorted” project description.]
iii. The draft PEIR neither discloses nor mitigates environmental impacts of directing billions of dollars into SEDA infrastructure, forcing scarce city resources away from existing neighborhoods.
Although one of the claimed Project Objectives of the SEDA Plan is “fiscal responsibility,” including “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,”24 the Plan provides no evidence of such a “self-financing” approach to infrastructure. On the contrary, the Plan repeatedly promises that when infrastructure capacity falls short, the City will step in and pay.25 The as-yet-undisclosed documentation of infrastructure needs and funding mechanisms must either substantiate the fiscal responsibility of the Plan, or not. As of this moment, the public has no idea because there is no evidence in the record for the City’s claim that development and ongoing maintenance will be “self-financing.”
Unless there is proof of the “self-financing” claim, SEDA commits the City to massively expensive infrastructure that is not needed to accommodate Fresno’s housing needs, and that directly conflicts with the General Plan by privileging new growth over strengthening established neighborhoods. In addition, it foreseeably, substantially, contributes to physical blight and decay, with resulting economic decline, in all non-SEDA areas of the City.26 As in Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal.App.4th 1184, 1208, 22 Cal.Rptr.3d 203, 222 (2004), the SEDA PEIR has failed to comply with the information disclosure provisions of CEQA because it has omitted any meaningful consideration of the question whether the diversion of funding for infrastructure improvements could trigger a series of events that ultimately cause urban decay. Nor does the PEIR even contain a statement indicating that such a possibility had been considered, or reasons why it had been determined 24 SEDA Recirculated Draft EIR, passim, including pp. ES-2, 2-18. 25 For example, mitigation measures HYD-2b and HYD-2c require the City to “secure additional water supplies by securing additional water sources” where a proposed SEDA development would exceed existing water supply capacity.
26 See, Fresno Urban Decay Analysis, ECONorthwest, 2023 (copy attached); see also, Patterns of Sprawl in Fresno and the Central San Joaquin Valley, 2024, p.8 (copy attached). 797
Comment letter—SEDA Recirculated PEIR March 24, 2025 15 that urban decay was not a significant effect of the proposed project. d. CLC and RCI incorporate comments submitted on behalf of County of Fresno In support of their comment that the draft PEIR fails to include adequate planning details (including regarding public infrastructure) to permit a sufficient degree of analysis and public information regarding the environmental consequences of such a large greenfield development, CLC and RCI hereby join, and incorporate by this reference, the portions of the September 4, 2023 comment letter on the 2023 draft SEDA PEIR, submitted by Jeffrey on behalf of the County of Fresno, Department of Public Works and Planning, at pages 3 through 5 (Section B), and page 7 (Section D).
e. City must extend the public comment period on the SEDA Plan for 45 days after the infrastructure plan, infrastructure budget, nexus study, and financing plan have been released for review.
Failure to timely release the infrastructure-related studies and analyses for public comment deprives the public of a meaningful opportunity to comment upon substantial adverse environmental impacts of the proposed project or a feasible way to mitigate or avoid such an effect that the project’s proponents have declined to implement. CEQA Guidelines, § 15203, requires the lead agency to “provide adequate time for other public agencies and members of the public to review and comment on a draft EIR or negative declaration that it has prepared.” It may be that the disclosure of the infrastructure documents constitutes significant new information within the meaning of Pub. Res. Code § 21092.1 or CEQA Guidelines § 15088.5(a) that requires recirculation of the PEIR. Even if not, the infrastructure information is crucial to evaluation of SEDA’s environmental impacts. Therefore, the infrastructure documents are also subject to the 45-day public review period required by CEQA Guidelines, § 15105(a).
8. The SEDA Recirculated draft PEIR’s Existing Conditions description is fatally inaccurate.
In its Introduction chapter, the SEDA draft PEIR includes a current city population figure, but no population projections. (p. 2-3 – 2.21) Projected population growth data appears, instead, in an “Existing Conditions” segment of the Population and Housing chapter. There, the PEIR describes historical population increases in the City and the County, using 2022 Census Bureau Quick Facts figures. (SEDA PEIR, pp. 3.14-1 – 2, fn. 1, 2.) It relies on California Department of Finance for Fresno’s average household size. (Id., p.3.14-2, fn. 3.) However, on the crucial question of projected population growth, the Recirculated PEIR continues to rely on Fresno Council of Governments’ (FCOG) 2021 Fresno County growth projections to 2050, apparently last accessed May 20, 2022. (p.3.14-2, fn. 5.) The City’s use of the FCOG figures in 2022 may have been the best information available at the time; there is no way to know, as the PEIR does not explain its choice of data sources.
But the PEIR has now been recirculated twice since the July 2023 release of the first version of the draft, once in October of 2023, and again in February of 2025 (current version). Well prior to the October 3, 2023 partial recirculation of the draft PEIR, the City was aware that the SEDA 798
Comment letter—SEDA Recirculated PEIR March 24, 2025 16 EIR’s population assumptions were materially inaccurate.27 As of August 2023, the California Department of Finance (DOF) had issued updated data very different from that cited in the July 2023 draft EIR.28 However, the October 2023 Partial Recirculated draft PEIR did not incorporate any corrections to its population projections.
In August of 2024, the Fifth District’s South Fresno Community Alliance decision invalidated the City’s General Plan update and Greenhouse Gas plan, requiring the current recirculation of the SEDA PEIR. By September of 2024, DOF had again updated its data to incorporate a finergrained analysis, and as of October of 2024, FCOG had corrected its own data based on the new information issued by the state.
In December of 2024, the City paid First Carbon Solutions an additional $153,636 to author a second Recirculated draft PEIR; at that point, the accurate DOF and FCOG population data were readily available. In fact, when one now follows the link provided in the Recirculated PEIR at footnote 5 on page 3.14-2, one finds FCOG’s October 2024 updated data, which show a Fresno population in 2025 of 595,370 (not the PEIR’s 621,54029). FCOG’s updated data report a 2050 Fresno City population of 646,260 (not the PEIR’s 728,200). The accurate, FCOG, data show a Fresno City increase of 50,890 people between 2025 and 2050, not the almost 107,000 predicted in the PEIR. The accurate, FCOG, data yield only an additional 16,963 households by 2050, well under half of the 35,553 households the PEIR’s figures would project. 30 These errors in growth projections are fundamental: According to SEDA, its plans for 45,000 new housing units would comprise planned growth of only 31% percent of the total planned capacity for the City.31 However, using accurate, FCOG, growth figures, it is clear that SEDA development would amount to almost three times (265%) the actual housing needs for all of Fresno City by 2050. Such a glut of new homes on the market, and the public investment necessary to launch it, would shatter the General Plan’s goals for infill development and revitalization of Fresno City existing neighborhoods.
In its Reasons for Recirculation, the SEDA document describes South Fresno Community Alliance’s invalidation of prior planning documents as constituting “substantial changes to the environmental setting,” and therefore “significant new information” requiring recirculation (p.
ES-9); but the PEIR does not include corrected data nor otherwise respond to commenters’ 27 CLC and RCI hereby incorporate by this reference the comment letter submitted by Keith Bergthold, dated August 28, 2023, and those portions of the August 28, 2023, comment letter submitted by Patience Milrod on behalf of CLC, IAF, and RCI, at pages 3 through 5. (copies attached) 28 Please see Keith Bergthold August 28, 2023, comment letter. 29 SEDA PEIR, at p. 3.14-2.
30 At 3 persons per household, the SEDA PEIR Fresno City population growth figures would yield 35,553 new households.
31PEIR, p. 3.14-13 – Section 3.14.4 - Project Impacts and Mitigation Measures. 799
Comment letter—SEDA Recirculated PEIR March 24, 2025 17 critique of population projections.32 Nor does the Recirculated draft PEIR explain why it relies on outdated and inaccurate data, except to say (using circular reasoning) that “This approach is consistent with requirements to maintain consistency with the General Plan.” (p. 3.14-2.) This statement can only be read as an acknowledgement that the draft PEIR incorporates erroneous data into its environmental impact analyses—not only affecting calculations of housing demand, but also other impacts such as water quality, air quality, transportation, greenhouse gases, and infrastructure design, sequencing, and cost.
A knowing use of false data is antithetical to CEQA’s purpose of accurately informing decision makers and the public, especially when the plan in question creates such extensive unmitigated impacts on the environment as this one.
9. The SEDA draft PEIR fails to address Fresno’s documented housing needs, proposing instead a more than doubling of the oversupply of single-family detached units.
The Plan itself does not commit to any particular number of homes at any particular price point; nor does it require as a mitigation measure that developers build so as to ensure any proportion of affordable-to-market-rate homes. But based on the SEDA proposed zoning map33, and on the City’s application for the SEDA planning grant34, the SEDA Plan anticipates at most 9,000 potentially affordable multifamily units35 and 35,200 single-family units.
As it happens, the City’s own One Fresno Housing Strategy acknowledges that the City’s pressing needs are not for the single-family market-rate housing SEDA will supply, but for housing affordable to low-income residents: “Historic poor land use planning, inequitable fair housing practices and the basic imbalance of supply and demand have all led Fresno to its current state of needing approximately 15,000 new and converted affordable housing units between now and 2025 to meet our residents’ needs.” One Fresno Housing Strategy, April 2022, Mayor’s Message, p. 2.
The One Fresno Housing Strategy makes clear that “Fresno needs 21,001 units for households who can afford no more than $500 on monthly housing costs,” and “the City of Fresno has a glut of 28,310 single-family detached units over and above what Fresno households need based on household size.” Id. at p. 38. These are not housing needs that SEDA’s 35,200 additional 32 In the 2025 West Area Neighborhoods Specific Plan draft EIR, the City acknowledged the new population reality of 0.2% growth, a small fraction of the growth assumed in the SEDA PEIR. See, Recirculated Draft EIR – West Area Neighborhoods Specific Plan, p. 3.12-1, Table 3.12.1—Environmental Setting—Demographics—Population Trends.
33 Southeast Development Area Specific Plan, Map 2.5—SEDA Proposed Land Use, p. 22. 34 Fresno City SB 2 Planning Grants Application, Section E, Project Description, p. 6. 35 Based on HCD’s zoning standard of at least 16 units per acre (see, HCD By-Right Program Minimum Densities Table). However, density standards are only a rough proxy for affordability; at this point— since the PEIR includes no enforceable mitigation measures imposed as conditions of entitlement—it is possible that not a single unit to be built in SEDA will be affordable to low-income families. 800
Comment letter—SEDA Recirculated PEIR March 24, 2025 18 single-family market rate homes will meet.
The City’s own quantified assessment of Fresno’s housing needs36 over most of the next decade shows more than adequate inventory for that new housing; not a single parcel from SEDA is needed to meet those goals.37
The SEDA Specific Plan’s claim that “the acceleration of the current housing crisis has created a ‘substantial shortage’ of homes and therefore prioritized completion of the SEDA Plan”38 is demonstrably untrue. This claim cannot therefore be the basis for legitimate, evidence-based findings of overriding consideration.
10. The SEDA draft PEIR fails to analyze or to mitigate foreseeable and avoidable impacts on farmland.
CLC and RCI hereby join, and incorporate by this reference, the portions of the September 4, 2023, comment letter on the 2023 draft SEDA PEIR, submitted by Jeffrey Reid on behalf of the County of Fresno, Department of Public Works and Planning, found at pages 7 through 10 (Sections E, F, and G).
CLC and RCI hereby join, and incorporate by this reference, the portion of the March 24, 2025, comment letter submitted by Douglas Carstens and Michelle Black on behalf of the Sierra Club, Central Valley Partnership, and League of Women Voters entitled “Agricultural Resources and Forestry Resources Impacts are Not Sufficiently Mitigated.”
11. Traffic impacts
a. The Recirculated SEDA draft PEIR materially underestimates VMT by significantly overestimating trip capture within SEDA.
i. At the time of recirculation, the City was aware of the PEIR’s failure to accurately estimate VMT.
In support of their comment that the draft PEIR fails to accurately estimate VMT, CLC and RCI hereby incorporate by this reference the following comment letters submitted on the 2023 draft 36 See, FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT, July 2023: Figure 1E-2.2 Sites Inventory, Fresno 2023, p. 1E-2-33; and Table 1E-1.1, Summary of Quantified Objectives, 2023-2031, p. 1E1-35. 37 The SEDA PEIR admits as much at p. 2-1: “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.” The PEIR includes no evidence justifying this supposed “urgency,” and California Department of Finance population growth figures flatly contradict it.
Moreover, they do not reflect any “unanticipated in-migration occurring at this time,” and the EIR offers no evidence in support of this apparently fictitious phenomenon. 38 Draft SEDA Specific Plan, p. 9.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 19 SEDA PEIR:
• California Department of Transportation, David Padilla, submitted August 25, 2023. • California Department of Transportation, David Padilla, submitted November 17, 2023. • Victoria Transport Policy Institute, Todd Litman, submitted August 21, 2023. • Sunnyside Property Owners Association, Sue Williams, submitted August 25, 2023. • County of Fresno, Department of Public Works and Planning, Jeffrey Reid, submitted November 7, 2023.
• CLC, IAF, and RCI, Patience Milrod, submitted August 28, 2023. • CLC, IAF, and RCI, Patience Milrod, submitted November 6, 2023. ii. VMT figures must be recalculated.
Notwithstanding multiple comments submitted after the release of each of the two 2023 PEIR drafts, the Recirculated draft PEIR has failed to correct the counterfactual assumptions it makes about internal trip capture within SEDA, fails to provide VMT per service population data for years prior to 2035, and continues simply to assert that VMT per service population will drop from 45.72 to 5.07 without addressing or explaining omission of interim-years data. Moreover, it incorrectly identifies a 2035 buildout horizon—though such a timeline conflicts with the General Plan estimate of only new 14,900 units in SEDA by that date, is not physically feasible, and inaccurately reflects the Specific Plan’s buildout timeframe.39 Professionally adequate analysis would recognize that realistically only second-generation SEDA residents will be able to work, go to school, shop, and recreate within SEDA’s boundaries to the extent claimed, since commercial and employment centers will lag a decade or two behind housing development and occupancy. This serious analytic error in turn generates drastically underestimated traffic impacts, which in turn results in material undercounting of air quality impacts, which in turn would invalidate any human health impact analysis based on these data, if such an analysis had been done.
As Victoria Transport Policy Institute points out, “the Plan’s current analysis significantly underestimates vehicle traffic congestion, crash, emission and resulting air quality impacts.
Until more accurate travel modeling can be completed, and air quality impacts adjusted, this PEIR fails to predict the project’s significant social and environmental impacts and so fails to provide the information that policy makers, practitioners and the general public need to make informed decisions.” (August 25, 2023 comment letter, p.2.) CalTrans’ letter notes that SEDA will create a VMT impact because it cannot accurately claim trip capture for decades after the project begins to be built out, as residential uses (which produce trips) are followed, “slowly over time,” by commercial uses (trip attractors). CalTrans 39 See, e.g., Recirculated SEDA draft PEIR at p. ES-1, anticipating “approximately 45,000 homes and 37,000 jobs within the nearly 9,000-acre planning area by the year 2050.” 802
Comment letter—SEDA Recirculated PEIR March 24, 2025 20 quantifies the net VMT increase from No Project Conditions as 162% and contradicts the PEIR’s claimed VMT per service population claim.
CEQA Guidelines, § 15064.3(b)(4) allows a lead agency to choose a methodology by which to evaluate vehicle miles traveled but requires that “[a]ny assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project.” The PEIR’s choice of a 2035 horizon is unreasonable. In addition, the PEIR does not inform the reader how it calculates VMT either for the years between the project’s initiation and its 2035 horizon, nor provide any data out through the (more realistic) 2050 actual buildout period. The PEIR’s analysis is subject to Guidelines § 15151’s standard of adequacy: “An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible.” The missing calculations are reasonably feasible but have not been incorporated into the PEIR and their omission is unexplained. b. Traffic mitigation measures must be updated based on corrected data and analysis.
The 2025 PEIR does acknowledge, as the 2023 draft did not, that the Specific Plan “could conflict” with a program or policy related to transportation. (p. 3.17-31.) It claims the Specific Plan “is a comprehensive planning document” that “addresses wide-ranging infrastructure and community challenges” related to future growth. But, while noting that “[p]lanning at this scale allows design and phasing of infrastructure improvements that are more efficient, environmentally sensitive, and cost-effective,” the Plan in fact incorporates no such design or phasing information.
Notwithstanding the almost one million daily trips the project will generate,40 and commenters’ requests for quantifiable and enforceable mitigation measures, the Recirculated draft PEIR identifies exactly the same mitigation measures as the original draft PEIR. There is no evidence of effort to plan comprehensively, or at scale, to design and phase infrastructure so as to mitigate environmental impacts from VMTs. Instead, all mitigation measures defer mitigation to the implementing project level, except possibly MM TRANS-1d (bus service). The cumulative impacts analysis is likewise deferred to project-level approvals. (SEDA draft PEIR, pp.3.17-44 – 45.)
In its Executive Summary Matrix, the draft PEIR claims that the SEDA Specific Plan “would not conflict or be inconsistent with CEQA Guidelines, § 15064.3(b)” (Table ES-1, p.ES-51), and lists that Guideline’s criteria for assessing significance of transportation impacts at p.3.17-34.
However, the PEIR fails to provide sufficient accurate information to establish whether, or how, the rebuttable presumption of no significant transportation impacts would legitimately apply to the SEDA Specific Plan: The Plan imposes no enforceable mitigation measures as conditions of project-level approvals to ensure siting within 0.5 miles of transit; and, the claim that SEDA planning would reduce VMT below existing conditions is unsustainable on the evidence in the 40 Plan Area VMT with the project build out in 2035 is expected to be 974,369. SEDA Recirculated draft PEIR, p.3.17-32
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Comment letter—SEDA Recirculated PEIR March 24, 2025 21 draft PEIR.
What the draft PEIR does not give us is a reasoned explanation of why it has not adopted, at the Plan level, the many recommended mitigation measures that could make accurate the Plan’s claim to comprehensive planning. These include the mitigation measures suggested in CalTrans’ August 2023 letter, the Emission Reduction Clean Air Measures recommended by the San Joaquin Valley Air Pollution Control District (copy attached), and the City’s own 2020 VMT threshold guidelines document, which points out that “regional VMT mitigation is considered the most effective method for large-scale VMT reduction,” and provides multiple mitigation options for community and general plans.41 As required by Section 15126.4 of the State CEQA Guidelines, “Where several measures are available to mitigate an impact, each should be discussed and the basis for selecting a particular measure should be identified. Formulation of mitigation measures shall not be deferred until some future time.” [emphasis added]. This draft PEIR fails to fulfill this function.
12. The SEDA Recirculated draft PEIR fails to adequately analyze or mitigate greenhouse gas emissions from the SEDA project
CLC and RCI hereby join, and incorporate by this reference the portions of the March 24, 2025 comment letter submitted by Douglas Carstens and Michelle Black on behalf of the Sierra Club, Central Valley Partnership, and League of Women Voters that relate to the PEIR’s assessment, analysis, disclosure, and mitigation of greenhouse gas emissions due to SEDA projects’ construction and operation activities.
13. The SEDA Recirculated draft PEIR fails to adequately identify, quantify, or mitigate air quality impacts.
a. The draft PEIR must include ozone calculations.
The draft PEIR’s Air Pollution Description and Health Effects discussion lists criterion pollutants, generally describes their adverse effects on human health, and identifies the regulatory programs intended to curb air pollution, including the ozone reduction/prevention plans for the San Joaquin Valley Air Basin nonattainment area. However, there is no discussion of the human health impacts of the additional pollution load this project contributes to Fresno’s already-dirty air.
The PEIR does not calculate the anticipated parts per million (ppm) of ozone resulting from SEDA construction and operations; although NOx and ROG are estimated, the reader has no idea how much ozone will be produced (i.e., whether the amount of ozone resulting from the ROG and NOx pollution will bring the ozone ppm within the 0.10 to 0.40 range). Given that the measures for both the precursor pollutants exceed their respective thresholds of significance, 41 CEQA Guidelines for Vehicle Miles Traveled Thresholds (Fresno CEQA VMT Guide), adopted June 25, 2020, City of Fresno, p.40; for mitigation measures, see, Appendix C, Vehicle Miles Traveled Mitigation Measures for Community Plans and General Plans.
804
805
Comment letter—SEDA Recirculated PEIR March 24, 2025 23 approved for SEDA-adjacent South Central Fresno42: “Breathing ozone can trigger a variety of health problems, including chest pain, coughing, throat irritation, and congestion. It can reduce lung function and inflame the linings of the lungs. Repeated exposure may permanently scar lung tissue. Children are at a greater risk of experiencing negative health impacts because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, thus increasing their exposure. Studies have linked rising hospital admissions and emergency room visits to higher ozone levels.” Appendix G:
Health Impacts of Air Pollution, p. G-17.
Fresno State University’s Central Valley Health Policy Institute studied emergency room and hospital admissions in Fresno, Bakersfield, and Modesto on a daily basis for selected conditions, such as asthma and acute myocardial infarction (MI), that had been previously linked to air pollution in other studies. They determined that ozone was strongly linked to increased risk for asthma ER visits in children during the hottest summer months.
Moreover, asthma ER admissions are also strongly linked to increasing PM2.5 across the Valley, with a higher risk in children. Further, risk for asthma hospitalizations increased dramatically with PM2.5 in children and adults across the region. A moderate increase in risk of acute MI (heart attack) was also linked to PM2.5 levels regionally, as were pneumonia ER visits in children and acute bronchitis ER visits in adults.43 Dr. Emanuel Alcalá advised in his September 6, 2023, comment letter (copy attached and incorporated by this reference) that “incremental increases in ozone levels alone— independent of the other pollutants the project will create—will have the following human health impacts: decreased lung function, decreased lung function growth in children, increased asthma-related emergency visits and hospital admissions, and mortality among older adults.”
The PEIR is inadequate because, as in Bakersfield Citizens, “After reading the EIR[], the public would have no idea of the health consequences that result when more pollutants are added to a nonattainment basin.” (Bakersfield Citizens, supra, at p. 1220.) The PEIR does not explain why it includes no quantified health impact projections “to inform the public how its bare numbers translate to create potential adverse impacts,” nor to “explain what the agency does know and why, given existing scientific constraints, it cannot translate potential health impacts further.” (Friant Ranch, supra, 6 Cal.5th at p. 521 [emphasis in original].) The PEIR offers no “explanation why it was not feasible to provide an analysis that connected the air quality effects to human health consequences.” Id., 6 Cal.5th at p. 522.
In fact, such analysis is feasible, and should have been conducted here. In 2020, after the Friant Ranch decision, the Sacramento Metropolitan Air Quality Management District adopted 42 http://community.valleyair.org/selected-communities/south-central-fresno, incorporated by this reference.
43 Capitman & Tyner, The Impacts of Short-Term Changes in Air Quality on Emergency Room and Hospital Use in California's San Joaquin Valley, California State University, Fresno, June 2011. 806
Comment letter—SEDA Recirculated PEIR March 24, 2025 24 Guidance to Address the Friant Ranch Ruling for CEQA Projects in the Sacramento Metro Air District (copy attached), which sets out procedures for conducting a health effects analysis that would meet the Supreme Court’s standard for disclosure of adverse health effects resulting from a CEQA project. The procedures rely on the Benefits Mapping and Analysis Program (BenMAP), a U.S. Environmental Protection Agency (USEPA) tool that estimates health impacts from ozone and PM2.5. At Section 6 and Appendix A. the Guidance provides technical procedures and details; at Appendix G it correlates emissions levels and pollutants with “health endpoints”44 by geographic region and age range for strategic area projects.
As Dr. Alcalá pointed out to the City in September of 2023, “the tools with which to conduct [a human health effects analysis] are readily available. For example, the Environmental Benefits Mapping and Analysis Program – Community Edition (BenMAP-CE) – not only estimates health impacts but also estimates economic values associated with health morbidity events.” BenMAP, or some similar program, should and could have been used here to provide the information the public and decisionmakers need—including an assessment of ozone impacts on human health.
c. The PEIR is inconsistent with air quality attainment status, and conflicts with and obstructs implementation of the applicable air quality plan.
While the draft PEIR acknowledges as “a significant and unavoidable impact” that implementation of SEDA will conflict with and obstruct applicable air quality plans, it does not specify which plans, nor does it quantify the degree to which SEDA will obstruct their implementation. (See, p.3.3-42 – 43.)
A review however of the draft PEIR’s Appendix B can garner some idea of how SEDA air quality impacts will harm efforts to ensure healthy air in the Fresno Region. One example is comparing the PEIR’s air quality impacts analysis with the San Joaquin Valley Air Pollution Control District’s “Proposed 2023 Maintenance Plan and Redesignation Request for the Revoked 1-Hour Ozone Standard” (SJVAPCD Redesignation Request) adopted by the Air District Board on June 15, 2023.45 The purpose of that document is to persuade the federal Environmental Protection Agency to terminate anti-backsliding provisions for the revoked 1- hour ozone standard, including Section 185 nonattainment fees. Toward that end, the document includes both proofs of compliance and a maintenance plan. It clearly does not factor in the ozone contributions SEDA would make to the Valley’s pollution load.
Specifically, SJVAPCD’s Redesignation Request, Appendix A: Emissions Inventory (pp. A-1 through A-4), projects annual anticipated pollution levels for NOx through 2036. A layperson— including a member of the public, the Planning Commission, or the City Council—gets a 44 These include: hospital admissions, all respiratory; mortality, non-accidental; emergency room visits, asthma; hospital admissions, asthma; mortality, all cause; hospital admissions, all cardiovascular (less myocardial infarctions); acute myocardial infarction, nonfatal. 45 See, SJVAPCD 2023 Maintenance Plan and Redesignation Request for the Revoked 1-Hour Ozone Standard —see https://ww2.valleyair.org/rules-and-planning/air-quality-plans/ozone-plans/. 807
Comment letter—SEDA Recirculated PEIR March 24, 2025 25 graphic idea of SEDA’s impact just by comparing the Air District’s all-Valley numbers in identified years to the numbers this project alone will generate.
NOx —summer average in tons/day46
Year
Entire San Joaquin
Valley, per
SJVAPCD
SEDA, per PEIR SEDA % increase
over total SJV
2026 119.50 180.529 151.07%
2031 97.49 170.8218 175.22%
2036 84.13 168.2333 199.97%
This chart illustrates SEDA’s huge and negative effect on Valley air quality: by 2036, SEDA alone is projected to produce double the amount of NOx being produced across the entire rest of the San Joaquin Valley. The document provides changes in VOC over time and does not sum up ROG separately; it will therefore be important for an adequate SEDA ozone analysis to determine, and to include as a point of comparison, how SEDA ROG emissions will compare to regionwide ROG production during the identified years, in order to report accurately the extent to which SEDA will impede achievement of regionwide air quality improvement goals.
The PEIR must acknowledge these data, explain them in the context of the SEDA proposal, and provide fact-based analysis of the proposal’s air quality impacts that take these data into account. The draft PEIR’s passing confession that “Emissions of VOC and NOX that exceed the Valley Air District regional threshold would cumulatively contribute to the ozone nonattainment designation of the SJVAB” (p. 3.3-56) is inadequate. Exceedances at this scale require some effort beyond falling back on General Plan mitigation measures that never anticipated impacts of this magnitude.
d. Plan level and project level mitigation measures are inadequate, amounting to piecemealing of SEDA’s regional air quality impacts.
The draft PEIR fails to propose plan-level mitigation measures that will have any mitigating effect on air quality impacts, although many tools and other resources are available for this purpose. The PEIR takes the position that plan-scale mitigations are infeasible, but this is inaccurate: the City’s own 2020 VMT threshold guidelines document provides multiple mitigation options for community and general plans.47 It is objectively unreasonable, and an invitation to piecemealing that will defeat the whole purpose of a mitigation program, to 46 See, SJVAPCD Adopted 2023 Maintenance Plan and Redesignation Request for the Revoked 1-Hour Ozone Standard, Appendix A: Emissions Inventory, p. A-4. Copy attached; available at https://www.valleyair.org/Workshops/postings/2023/06-15-23/maintenance-plan.pdf; last accessed March 24, 2025.
47 See, e.g., Fresno CEQA VMT Guide, and SJVAPCD Emission Reduction Clean Air Measures—among many others.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 26 suggest that it is impossible to impose plan-scale mitigation measures as enforceable conditions of development in SEDA.
The draft PEIR falsely claims that it has adequately canvassed and incorporated available air quality mitigation measures, but that “due to the magnitude of emissions generated by the residential, office, and commercial land uses proposed as part of the proposed project, no mitigation measures are available that would reduce cumulative impacts below the Valley Air District’s thresholds.” That the PEIR cannot find measures to reduce (for example) 2026 NOx emissions from 180 tons per year to 10 does not mean there are no possible mitigations that would reduce NOx emissions to (for example) 50: “Mitigation measures need not include precise quantitative performance standards, but they must be at least partially effective, even if they cannot mitigate significant impacts to less than significant levels.” Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 404; §§ 21051, 21100; Guidelines, § 15370. It is not an option in 2025 to effectively abandon the effort, when air pollution from this project would so massively exceed the entire total NOx output for the rest of the San Joaquin Valley, creating avoidable illness and death, and dooming City efforts to reduce climate change impacts.
Such specific mitigation measures as the plan does include are to be implemented at the project level; only AIR-1a imposes use of low-VOC paints (“super-compliant architectural coatings”) as a condition of approval. The others (AIR-1b through AIR-4) do not impose mitigation obligations unless preconditions are met. For AIR-1b and -1c (respectively, construction- and operation-related air impacts), there is no need for air quality mitigation measures unless the project impacts exceed the Air District threshold of significance. By definition, project-level emissions will have (relative to the SEDA Plan as a whole) minimal potential impact on the environment.
For AIR-1d, mitigation for emission of Toxic Air Contaminants (TAC) or Diesel Particulate Matter (DPM) pollutants is only required at the project level, and only if both of two conditions are met: 1) if such emissions will occur within 1000 feet of a sensitive receptor; and 2) if a Health Risk Assessment shows incremental health risks for those sensitive receptors exceed Air District levels. Thus, a development project within SEDA could freely emit unmitigated TAC and/or DPM so long as it is not sited near a sensitive receptor. This is a perverse outcome, defeating the purpose of SEDA, increasing in an unmeasured and unmitigated manner the toxic contaminants to which the general public will be exposed, and putting even non-sensitive receptors at unnecessary risk.48
Not surprisingly, though the PEIR acknowledges significant cumulative air quality impacts, the 48 It is also contrary to best practices, according to the Air District. SJVAPCD comments on a Fresno community plan did not recommend limiting mitigation to uses near sensitive receptors, but rather prescribed one of two types of health impact analysis for every development project within the plan area.
See, comments on Recirculated Notice of Preparation of an Environmental Impact Report for Revisions to the Fresno South Central Specific Plan, May 14, 2021, p. 6, available at https://community.valleyair.org/media/1ywkdo1a/district-comments-20210313-nop-fresno-southcentral-specific-plan-5-14-21.pdf 809
Comment letter—SEDA Recirculated PEIR March 24, 2025 27 project-by-project approach to the issue would allow many projects to avoid air quality mitigation entirely, thus precluding effective mitigation of cumulative impacts. Thus, the Specific Plan’s cumulative air quality impacts remain, according to the PEIR, “significant and unavoidable.”
Piecemealing a project such as SEDA to avoid imposing mitigation is no more defensible than piecemealing to avoid environmental review. As the Fifth District pointed out in Los Angeles Dep’t of Water & Power v. Cnty. of Inyo, 67 Cal. App. 5th 1018, 1035, 283 Cal.Rptr. 3d 119, 130 (2021), “CEQA contemplates consideration of environmental consequences at the earliest possible stage, even though more detailed environmental review may be necessary later. [Citation.] Consistent with this view, CEQA’s requirements cannot be avoided by chopping a large project with significant adverse consequences into many little ones—each with a minimal potential impact on the environment. [Citation.] Piecemeal review is contrary to CEQA’s requirements.” The PEIR fails to demonstrate an honest effort to accurately calculate and to reduce VMTs, or an honest effort to apply any of the many available technologies, mechanisms, and strategies to mitigate air quality impacts. It fails as the informational document CEQA requires.
Moreover, the draft PEIR does not sufficiently account for its lack of specificity by assurances that a “Health Risk Assessment” (HRA) will be prepared later in the CEQA process, in connection with development-specific EIRs. (See, e.g., MM AIR-3.1, -3.2.) Sierra Club v. County of Fresno, supra, 6 Cal.5th at p. 521. For one thing, an HRA is required by the California Health & Safety Code, § 44306, only to evaluate and predict the dispersion of hazardous substances.
Secondly, a project-specific HRA is inadequate for assessing plan-scale impacts or for devising plan-scale mitigation measures—the very purpose of a Program Environmental Impact Report, but not remotely achieved by the SEDA draft PEIR.
The draft PEIR also fails to propose mitigation measures that will significantly reduce transportation impacts, including dangerous levels of air pollution. Although the project triples vehicle miles traveled to almost 1 million per day, mitigation measures are absent or illusory.
For the first two decades of the project’s operation, its transportation and consequent air quality impacts are huge, both as a result of the concept itself—a new city of 145,000 planted in rural Fresno, 10 miles from the city’s urban center—and of an apparent determination to impose no mitigation that might inconvenience or cost SEDA developers and builders.
14. The PEIR is inconsistent with the Housing Element of the City’s General Plan.
The draft PEIR undermines the Housing Element’s corrective approach to decades of poor planning. Fresno’s 6th cycle draft Housing Element acknowledges that “growth in the City of Fresno over the past few decades has traditionally been low density suburban development, which has resulted in conditions of sprawl in various areas of the city.” Fresno MultiJurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, p.1E-4-1.
The Housing Element therefore proposes to fill a perennial critical gap in the City’s capacity to provide and upgrade housing in legacy neighborhoods: “As part of the implementation of the 810
Comment letter—SEDA Recirculated PEIR March 24, 2025 28 Housing Element, programs are identified to upgrade the city’s infrastructure as needed in lowand moderate-income neighborhoods with the greatest needs. Priority for infrastructure projects will be given to serving established neighborhoods, including generally south of Herndon Avenue as shown in Figure 1E-3.41: Priority Areas for Development Incentives, along BRT and enhanced transit corridors, and in the Downtown Planning Area, consistent with General Plan policies.” Housing Element, p.1E-3-119 [emphasis added].
A City decision to invest billions of dollars in SEDA infrastructure is inconsistent with the Housing Element’s commitment to correct the City’s history of neglecting older neighborhoods.
In the zero-sum game of municipal finance, and especially in the absence of a SEDA infrastructure financing plan, there is no way to ensure adequate resources to fund “Priority Investments in Established Neighborhoods” as already identified in the General Plan.49 Again, consistently with the General Plan, the 6th Cycle Housing Element inventory does not identify parcels in SEDA as necessary to meet Regional Housing Needs between now and 2031.
See, Figure 1E-2.7 at p. 1E-2-67. Instead, the Housing Element identifies SEDA as Development Area 3, as does the General Plan—the last in priority for development on the fringe areas. See, Housing Element, Figure 1E-3.42, which shows Growth Area 2 to include SEDA, labeled “DA3” for Development Area 3. “Growth Area 2 has significantly less access to completed infrastructure. Any development in these areas would require all infrastructure costs to be borne by the new development.” 1E-3-121.
15. The SEDA draft PEIR fails to adequately analyze or mitigate project water impacts. a. Water impacts are badly underestimated.
It appears the City has not factored drought conditions or climate change projections into its water supply sustainability calculations. Figure ES-2, Projected Water Supplies50, shows an increase of almost 21,000 AFY in available groundwater between 2025 and 2045, plus another 6,500 AFY increase in surface water over the same period.
However, the draft PEIR recognizes that across California, climate change will effect a “reduction in the quality and supply of water from the Sierra snowpack,”51 a source on which the City of Fresno is heavily reliant for both surface water and groundwater recharge. The Draft PEIR reports that by 2050, such impacts in the Fresno area will reduce the average water supply from snowpack to two-thirds historical levels, and “If emissions reductions do not occur, water from snowpack could fall to less than one-third of historical levels by 2100.”52 Not only are these concerns not discussed in the Plan or the draft PEIR, but they are explicitly 49 See summary in December 2024 draft Housing Element, p. 1E-3-119. 50 Draft PEIR, Appx. F, p. ES-7.
51 Draft PEIR, p. 3.8-9 (warmer temperatures could reduce the Sierra Nevada spring snowpack “by as much as 70 to 90 percent.”)
52 Id., p. 3.8-10.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 29 minimized in the discussion of hydrology and water quality. There, the PEIR proposes a cheerful water outlook, repeating in multiple places the phrases “during normal water years” and “assuming groundwater characteristics are not altered due to climatic events or regulatory influences from SGMA.”53 These are objectively unreasonable assumptions, but there is no discussion of a fallback position in the (likely) event the PEIR’s sunny projections are inaccurate. b. Mitigations for hydrology impacts are inadequate; City taxpayers will bear the cost.
Not only are the projections unreasonably optimistic, but this is yet another place where the City’s failure to do the program-level work of infrastructure planning, accurate environmental assessment, and imposition of mandatory, system-wide, coordinated mitigation measures predictably exacerbates environmental impacts.
Mitigation measures HYD-2b and HYD-2c require the City to refuse to approve proposed SEDA developments that would exceed “existing water supply capacity,” and to “secure additional water supplies by securing additional water sources” prior to any such development approvals.
This post-facto proposed mitigation—the costs of which are scheduled to be borne by City taxpayers and not by SEDA’s developers or ultimate residents—is far inferior to plan-level mitigations prescribed in a Program EIR.
To achieve plan-level efficiencies and effectiveness, the City must disclose, and the draft PEIR must discuss, the “EIR-related water infrastructure planning tasks.”54 An intention to develop this vital information after SEDA approvals would violate CEQA. c. CLC and RCI incorporate comments submitted on behalf of County of Fresno.
In support of their comment that mitigations of water supply impacts are inadequate, CLC and RCI hereby join, and incorporate by this reference, the portions of the September 4, 2023, comment letter (copy attached) submitted by Jeffrey Reid on behalf of the County of Fresno, Department of Public Works and Planning, pages 11 through 12 (Section I).
16. The PEIR piecemeals assessments of environmental impacts, and mitigations.
The City’s 2020 application to HCD for the SEDA planning grant committed to project streamlining as one of the SEDA plan’s deliverables by incorporating “environmental analyses that eliminate the need for project-specific review.”55 This would have been a good idea, in light of the City’s claim that it needs SEDA in order to expedite thousands of urgently needed new homes.
If the City had conducted the environmental analyses it promised to do, it would also have been able to keep another of the promises it made to HCD: a Program EIR under which “future development will also utilize an expanded exemption under Government Code Section 65457 53 Id., p. 3.10-8.
54 SEDA Specific Plan, pp. 100-109, passim.
55 Fresno City SB 2 Planning Grants Application, Section D, Proposed Activities Checklist, item 3, p. 5. 812
Comment letter—SEDA Recirculated PEIR March 24, 2025 30 that will apply to certain residential, commercial, and mixed-use projects that are consistent with a specific plan adopted pursuant to Government Code, Article 8, Chapter 3 and would be exempt from CEQA.”56
The Plan pays lip service to streamlining, promising “Fiscal Responsibility” by “holistically coordinat[ing] infrastructure to integrate efficiencies that piecemeal planning cannot,” and otherwise coordinating systems and networks for efficiency and economy.57 But the Plan and the draft PEIR fail to provide either plan-scale impact analysis or plan-scale mitigation measures; the draft PEIR itself repeatedly prescribes both environmental assessment and imposition of mitigation measures only during the City’s approval process for subsequent discretionary projects within the SEDA footprint—for air quality impacts (see section 13.d, supra), transportation impacts, water supply impacts, etc. That is, if SEDA is approved as proposed, the City will need to subject every new project to environmental review in order to determine if its impacts are potentially significant, and what mitigation measures should be imposed—exactly the process streamlining is intended to avoid.
Statements by City officials have made this intention clear, most explicitly from City spokesman Brandon Johansen, whose email to a reporter admitted “As individual projects are filed within the Southeast Development Area, they will be evaluated under CEQA to determine project impacts and mitigation measures.”58 Such an approach makes streamlining impossible (unless the idea is to use the PEIR to evade environmental review and mitigation for follow-on projects, which has been known to happen in Fresno). Absent streamlining, the City cannot accomplish its claimed goal of expediting housing production.
As importantly, this approach renders impossible “holistic coordination of infrastructure to integrate efficiencies that piecemeal planning cannot,” much less creating systems and networks for efficiency and economy.
Finally, a project-by-project evaluation of air quality, water supply, and transportation impacts makes effective mitigation of SEDA’s large-scale environmental degradations illusory at best. A 9,000-acre project area, planted at such a remove from the city’s center, requires creative and transformative approaches to the environmental consequences of its placement and its population. Piecemealing precludes effective mitigation.
17. The SEDA draft PEIR’s alternatives analysis fails to satisfy CEQA requirements.
CEQA Guidelines, § 15126.6, provides guidance for conducting an adequate alternatives analysis. A reasonable alternative to a project may involve implementing it at a different 56 SB 2 Planning Grants Application, Section E, Project Description. 57 Draft PEIR at pp. ES-2, 2-18, and 5-11.
58 Greg Weaver, Another Clovis, but in southeast Fresno? City moves forward on mega-development plans, Fresnoland, August 25, 2023; https://fresnoland.org/2023/08/25/city-of-fresno-eyes-seda/; accessed August 27, 2023.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 31 location, as long as it “would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.” § 15126.6(a).
Subdivision (c) of the Guideline can make consideration of a different location mandatory:
“The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects.” [Emphasis added.]
Except for developers with inventory in the SEDA area, it should be a matter of indifference where exactly the City lawfully exercises its planning and zoning powers to incentivize adequate production of needed housing. Although “the housing crisis” is the putative justification for this Specific Plan at this time (see, fn. 37, supra), the Plan does not propose solutions to the housing crisis Fresno actually has: too few homes affordable to those at low and very low incomes, and an oversupply of detached single-family homes for above-moderate income buyers.59 Section 9, supra. While the SEDA Plan pays lip service to providing housing at all income levels, without question a plan serious about ensuring production of even some low-income housing must actively require and incentivize it, not just hope it appears if the plan is adopted; this plan makes no such provisions. Moreover, population growth has dropped significantly (see, section 8, supra); logically, housing demand is also dropping60 and will likely continue to drop.
This is the accurate description of the Environmental Setting/Existing Conditions within which SEDA is being proposed. Whether SEDA is wise public policy is not a CEQA question. But CEQA does require that decisionmakers seriously consider the tradeoffs even when acting foolishly, and that the public be fully aware of the costs of the choices their electeds are making for them.
Here, the Objectives of the Plan are set forth at pp. 5-11 – 5-12 of the EIR, a dreamy litany of smart-growth measures that conserve resources and foster community. Sadly, when subjected to comparative scrutiny, not one of these objectives can be better accomplished in a sprawlinducing greenfields project like SEDA than in an already-urban part of the city. It certainly appears to the lay observer that the Plan’s resource-oriented objectives (coordinated infrastructure, resource-conserving techniques for public facilities, efficient use of energy, water and other resources, and reduction of energy and water consumption) are more likely in a location where infrastructure has already been built, and which can be improved or converted 59 The office of Fresno Mayor Jerry Dyer issued in April of 2022 a report entitled One Fresno Housing Strategy, which concluded that, as of that date, “Fresno needs 21,001 units for households who can afford no more than $500 on monthly housing costs,” and “the City of Fresno has a glut of 28,310 single-family detached units over and above what Fresno households need based on household size.” Id. at p. 38. 60 Since the City has not responded to the Public Records Act request for the housing market study it apparently commissioned in connection with SEDA, these commenters are reduced to trawling the internet for pertinent data. According to one internet site, as of the end of February 2025, home sales had dropped 8.4% year over year, and were on average on the market 8 more days than for the same period last year. See, https://www.redfin.com/city/6904/CA/Fresno/housing-market, last accessed March 24, 2025.
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Comment letter—SEDA Recirculated PEIR March 24, 2025 32 to new uses depending on the project’s needs. The SEDA alternative, to the contrary, will require billions of dollars in new infrastructure—the very opposite of resource conservation, and incompatible with the Plan’s “fiscal responsibility” objective.
Other objectives, such as fostering healthy activity by providing walking and bicycling routes to activity centers, convenient transit service, walkable neighborhoods, mixed use town centers, and innovative employment areas, are geography-neutral: there is no need to create a new town on greenfields to provide these amenities for Fresno residents. In fact, the Housing Element commits the City “to upgrade the city’s infrastructure as needed in low- and moderateincome neighborhoods with the greatest needs. Priority for infrastructure projects will be given to serving established neighborhoods.” December 2024 draft Housing Element, p. 1E-3-119 [emphasis added].
The housing-related objectives are, likewise, geography-neutral—theoretically provision of housing affordable to all income levels and a wide variety of housing choices could be accomplished anywhere. However, unless the still-missing infrastructure financing plan calls for the City itself to fully absorb the expense, the massive cost of providing infrastructure to SEDA will make these objectives much harder to accomplish than they already are: these expenditures will inflate costs-per-square-foot; recouping those costs from SEDA homebuyers, renters, and business owners will create at least some drag on marketability, or will reduce the developers’ return on investment. The possibility that lower-income housing could emerge from such a scenario is wildly unrealistic.
Finally, even if the SEDA Plan could create the perfect new town at the southeast corner of Fresno’s sphere of influence, it would do so at a huge environmental cost to the region as a whole—including but not limited to the air quality, traffic, and water quality/access concerns itemized here and in other comment letters. It is unlikely that the SEDA Plan would be the environmentally superior alternative when compared to housing provision in existing urban areas of the city.
a. The City must consider an Infill/No-Project Alternative.
The City already has in hand a recent inventory of a sufficient number of suitable parcels to meet Fresno’s housing needs in its December 2024 Housing Element draft. Facilitating housing development using the Housing Element as a blueprint is likely to yield all of the benefits and significantly reduced environmental impacts from construction and especially from operation.
An Infill Alternative is far likelier to meet many of the Plan’s objectives, including creating housing affordable to the Fresnans who really need it. Recent state statutes privileging infill and low-income housing development, combined with a baseline of existing infrastructure, also create a pathway to expedited housing development—which is what you need in a crisis.
The SEDA draft PEIR must include an evaluation of this alternative, which could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects (§ 15126.6(a) [emphasis added]), to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed 815
Comment letter—SEDA Recirculated PEIR March 24, 2025 33 project. CEQA Guidelines, § 15126.6(e)(1).
b. The City must consider a West Area Neighborhood /No-Project Alternative.
On March 12, 2025, the City finally released a Recirculated Specific Plan draft EIR for the West Area Neighborhoods. Again, this Plan provides for over 50,000 new homes, in an area already at least partially built out, with at least a baseline of existing infrastructure, and where at least some development would qualify under state procedures for expediting affordable housing.
Again, the West Area Neighborhoods Alternative is far likelier than the SEDA Plan itself to meet all of its objectives, with significantly reduced environmental impacts from both construction and operation. Environmentally, this is a second-best alternative to the Infill Alternative, since the West Area is a new growth area and will be developed less-densely than housing under an Infill concept.
The SEDA draft PEIR must include an evaluation of this alternative, which could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects (§ 15126.6(a) [emphasis added]), to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. CEQA Guidelines, § 15126.6(e)(1).
18. On this record, a statement of overriding considerations to approve the PEIR would be an abuse of discretion.
On the basis of the current record, it will be impossible for the City Council to make evidencebased findings that “specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment” (Public Resources Code, § 21081 (b)), or that the “unmitigated effects are outweighed by the project’s benefits.” (Laurel Heights, supra, 47 Cal.3d at p. 391.)
Conclusion
There is no emergency requiring immediate approval of this development plan. The City’s own draft Housing Element establishes that there is more than adequate site inventory within the existing City to accommodate anticipated housing demand for at least eight years. More importantly, adoption of this plan at this time will utterly defeat its claimed principal purpose, to facilitate streamlined housing production by anticipating and mitigating at a program scale the environmental impacts of such development.
The City must correct erroneous population projections and otherwise gather corrected data, use the correct tools to assess impacts, identify effective and enforceable plan-scale mitigations, and fully disclose those facts and analyses. Given the size and scale of the SEDA proposal, and the need to bring the General Plan into conformity with statutory and judicial mandates, it may make most sense to roll its environmental assessment into a General Plan update.
Please include my clients (see cc’s, below) and me on the notification list for next steps in this process. Thanking you for your attention to these matters, I remain, 816
Comment letter—SEDA Recirculated PEIR March 24, 2025 34 Very truly yours,
PATIENCE MILROD
Attorney for Fresno Madera Tulare and Kings
Counties Central Labor Council, and Regenerate
California Innovation
cc: Dillon Savory, Fresno Madera Tulare and Kings Counties Central Labor Council, by email to [email protected]
Keith Bergthold, Regenerate California Innovation (RCI), by email to [email protected]
Jennifer Clark, Development Director, by email to [email protected] Sophia Pagoulatos, Manager of Long-Range Planning, by email to [email protected]
Andrew Janz, City Attorney, by email to [email protected] 817
GUIDANCE TO ADDRESS THE FRIANT RANCH RULING FOR
CEQA PROJECTS IN THE SAC METRO AIR DISTRICT
SACRAMENTO METROPOLITAN
AIR QUALITY MANAGEMENT DISTRICT
SACRAMENTO, CALIFORNIA
818
Prepared for
Sacramento Metropolitan Air Quality Management District Sacramento, California
Prepared by
Ramboll US Corporation
San Francisco, California
Project Number
1690012674
Date
Final October 2020
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Contents i Sac Metro Air District
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CONTENTS
1. INTRODUCTION 1
2. PURPOSE AND AUTHORITY 2
3. ORGANIZATION OF GUIDANCE 3
4. GUIDANCE FOR SCREENING HEALTH EFFECTS ANALYSIS 4
4.1 Thresholds of Significance 4
4.2 Overview of Health Effects Analysis 4
4.3 Screening Analysis for Projects at or Below Thresholds Levels 5
4.3.1 Definition of Hypothetical Project Sources for Screening Analysis 5
4.3.2 Screening Analysis Health Effects Modeling 6
4.3.3 Minor Project Health Effects Screening Tool 11
5. TREATMENT OF PROJECTS THAT EXCEED THRESHOLDS IN STRATEGIC AREAS 12
5.1 Strategic Area Project Screening Modeling 12
5.2 Strategic Area Project Health Effects Screening Tool 14
5.3 Recommendations for Using the Strategic Area Projects Health Effects Screening Tool 15
6. ANALYSIS OF INDIVIDUAL PROJECTS 16
6.1 Pollutants Evaluated 16
6.2 Technical Analysis 17
7. DISCLOSING MODELING RESULTS IN A PROJECT CEQA DOCUMENT 19
7.1 Discussing Health Effects on the Total Population 19
7.2 Discussing Health Effects in Population Subgroups 21
7.3 Identifying Vulnerable Populations 23
7.4 Consideration of Incidental Health Effects 23
Tables
Table 1. Operational thresholds of significance for the Sac Metro Air District and neighboring air districts ......................................................................................... 4 Table 2. Health effects for hypothetical project number 20 produced by EPA’s BenMAP program (see Appendix F for health effects of all 41 hypothetical projects). ............................................................................................................ 8 Table 3. Coordinates for 6 hypothetical strategic area projects. ............................................. 12 Table 4. Levels of emissions proposed for evaluating strategic area projects that are 2 and 8 times the maximum threshold of significance ......................................... 14 Table A-1. Definitions of the Northern California CCOS (Figure A-1) and reduced Sacramento (Figure B-2) 4-km grid resolution PGM modeling domains ........................ 5 Table A-2. Summary of recommended PM2.5 health endpoints .................................................. 13 Table A-3. Summary of recommended ozone health endpoints ................................................. 14 Table B-1. Thresholds of significance ...................................................................................... 3 820
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Table B-2. Health effects for hypothetical project number 20 produced by EPA’s BenMAP program. ................................................................................................ 11 Table B-3. Health effects for hypothetical project number 20 produced by the Python-based BenMAP simulator. .......................................................................... 13 Table C-1. Coordinates for 6 hypothetical strategic area projects. .............................................. 1 Table C-2. Emissions levels used for modeling strategic area projects at the six locations that are 2 and 8 times the threshold of significance. .................................... 3 Table D-1. Projects used to estimate the SO2 and CO emissions ratios ........................................ 2 Table D-2. Total emissions by project ..................................................................................... 3 Table D-3a. ROG - Percent of mitigated operational emissions attributed to each category by project ............................................................................................... 3 Table D-3b. NOx - Percent of mitigated operational emissions attributed to each category by development ...................................................................................... 4 Table D-3c. CO - Percent of mitigated operational emissions attributed to each category by development ...................................................................................... 4 Table D-3d. SO2 - Percent of mitigated operational emissions attributed to each category by development ...................................................................................... 5 Table D-3e. PM2.5- Percent of mitigated operational emissions attributed to each category by development ...................................................................................... 5 Table D-3f. Emissions summary for all pollutants for all projects with average percentages of emissions ...................................................................................... 6 Table D-4. Ratio of CO/NOx and SO2/NOx............................................................................... 6 Table E-1. Example SCCs frequently used to characterize CEQA Project emission source types ........................................................................................................ 1 Figures
Figure 1. Potential CEQA project locations (blue shading) in the five-air-district region along with locations of the 41 hypothetical project locations used in the screening modeling. ..................................................................................... 6 Figure 2. Premature deaths resulting from PM at 41 hypothetical project locations on a population base map with SFNA boundary outline. Location of hypothetical source number 20, whose results were presented in Table 2, is shown by the purple circle. ............................................................................ 10 Figure 3. Locations of six strategic area Projects I-VI used in the screening modeling, along with the 41 hypothetical projects used in the minor project analysis with boundary of the Five-Air-District Region (red) and the SFNA shaded grey. ......................................................................................... 13 Figure 4. Five main determinants that affect human health (Source: CDC). .............................. 22 Figure A-1. CCOS 4 km modeling domain for Northern California PGM modeling ........................... 6 821
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Figure B-1 Potential CEQA project locations (blue shading) in the 5-Air-District Region along with locations of the 41 hypothetical project sources used in the screening modeling. ..................................................................................... 2 Figure B-2. Sac Metro Air District CAMx 4-km domain (red box) used in the screening analysis embedded in the 4-km CCOS domain (black box) covering northern California. .................................................................................. 5 Figure B-3. Map of the incremental annual average PM2.5 concentrations (µg/m3) due to emissions from hypothetical source 20. ............................................................... 7 Figure B-4. Map of the incremental maximum 24-hour average PM2.5 concentrations (µg/m3) due to emissions from hypothetical source 20. ............................................. 8 Figure B-5. Map of the incremental highest MDA8 ozone concentrations (ppb) due to emissions from hypothetical source 20. ................................................................... 9 Figure B-6. Hypothetical project PM mortality health effects superimposed on population density with SFNA boundary outline. ...................................................... 15 Figure C-1. Locations of six projects I-VI used in the strategic area screening modeling, along with the 41 hypothetical Projects used in the minor project analysis and boundary of the Five-Air-District Region (red) with the SFNA shaded grey. .......................................................................................... 2 Figure C-2. Ranking of population in each 4-km grid cell within the 5-Air-District Region with magnified inset of highest population grid cells where the South Sacramento strategic area source is located. .................................................. 7
APPENDICES
Appendix A: Guidance for Conducting A Site-Specific Health Effects Analysis Appendix B: Screening Level Heath Effects Analysis
Appendix C: Strategic Area Project Health Effects Analysis Appendix D: Characterization of SO2 And CO Emissions
Appendix E: Sample SCC Codes Typically Used in CEQA Projects Appendix F: BenMAP Health Effects Results for 41 Hypothetical Minor Projects Appendix G: BenMAP Health Effects Results for Six Strategic Area Projects 822
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Acronyms and Abbreviations iv Sac Metro Air District
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ACRONYMS AND ABBREVIATIONS
AAQS: Ambient Air Quality Standards
APCA: Anthropogenic Precursor Culpability Assessment
AQMDs: Air Quality Management Districts
AQTSD: Air Quality Technical Support Document
ARB: California Air Resources Board
BAAQMD: Bay Area Air Quality Management District
BenMAP: Benefits Mapping and Analysis Program
CAMx: Comprehensive Air Quality Model with Extensions
CCOS: Central California Ozone Study
CEQA: California Environmental Quality Act
CMAQ: Community Multiscale Air Quality
CO: Carbon Monoxide
C-R: Concentration-Response
CSAPR: Cross-State Air Pollution Rule
DDM: Decoupled Direct Method
DPM: Diesel Particulate Matter
EC: Elemental Carbon
EIR: Environmental Impact Report
EMFAC: Emissions Factor (ARB’s on-road mobile source emissions model) EPA: United States Environmental Protection Agency
FF10: Flat File 2010
FPRM: Fine Particulate Matter
GHGs: Greenhouse Gases
GIS: Geographical Information System
HDDM: Higher Order Decoupled Direct Method
ISAM: Integrated Source Apportionment Method
ISORROPIA: Aerosol Thermodynamic Module
MERPs: Modeled Emission Rate Precursors
MRGUAM: Gridded merge program
NAAQS: National Ambient Air Quality Standard
NH4: Ammonium
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Acronyms and Abbreviations v Sac Metro Air District
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NH4NO3: Ammonium Nitrate
NO2: Nitrogen Dioxide
NO3: Nitrate
NOX: Oxides of Nitrogen
O3: Ozone
OA: Organic Aerosol
OC: Organic Carbon
OSAT: Ozone Source Apportionment Technology
PGM: Photochemical Grid Model
PM: Particulate Matter
PM2.5: Particulate Matter 2.5 micrometers or less in diameter PM10: Particulate Matter 10 micrometers or less in diameter POA: Primary Organic Aerosol
Project: CEQA project
PSAT: Particulate Source Apportionment Technology
QA: Quality Assurance
QC: Quality Control
ROG: Reactive Organic Gases
Sac Metro Air District: Sacramento Metropolitan Air Quality Management District SCC: Source Classification Code
SFNA: Sacramento Federal Ozone Nonattainment Area
SIPs: State Implementation Plans
SMOKE: Sparse Matrix Operator Kerner Emissions
SOx: Oxides of Sulfur
SO2: Sulfur Dioxide
SO4: Sulfate
TOS: Thresholds of Significance
USEPA: United States Environmental Protection Agency
VOCs: Volatile Organic Compounds
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Introduction 1 Sac Metro Air District
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1. INTRODUCTION
The California Environmental Quality Act (CEQA) is a state statute that requires state and local agencies to identify the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. A public agency must comply with CEQA when it undertakes an activity defined by CEQA as a "project." A project is an activity carried out by a public agency or a private activity that must receive some discretionary approval (meaning that the agency has the authority to deny the requested permit or approval) from a government agency, and that may cause either a direct physical change in the environment or a reasonably foreseeable indirect change in the environment. Air quality impacts of a proposed project are one of the environmental factors that are required to be evaluated under CEQA, and require mitigation unless the impacts can be shown to be insignificant. Air quality impacts typically include increases in criteria pollutants [e.g., ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), carbon monoxide (CO) and particulate matter (PM10 and PM2.5)], greenhouse gases (GHGs), air toxics (e.g., diesel particulate matter, DPM), and the resultant health effects of increases in air pollutants.
The California Supreme Court, in the case of Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, determined that the air quality analysis in the environmental impact report (EIR) prepared under CEQA for the Friant Ranch Project was inadequate because it did not make “a reasonable effort to substantively connect the project’s air quality impacts to likely health consequences.” The Court determined that “the EIR should be revised to relate the expected adverse air quality impacts to likely health consequences or explain in meaningful detail why it is not feasible at the time of drafting to provide such an analysis.” Lead agencies and practitioners preparing documents to comply with CEQA have requested guidance from the Sacramento Metropolitan Air Quality Management District (Sac Metro Air District) on implementing the Friant Ranch decision in the review and analysis of proposed projects in Sacramento County. On April 25, 2019, the Sac Metro Air District published an Interim Recommendation for addressing the Friant Ranch decision. The Interim Recommendation stated that agencies should follow the Court’s advice to explain in meaningful detail why an analysis of likely health consequences resulting from a development project is not yet feasible. This explanation should describe the background underlying air regulations, the regional nature of the regulatory approach, and why the approach is not amenable to project-level assessments.
The Interim Recommendation stated that an expanded discussion of health impacts resulting from specific air pollutants may also be warranted for projects with emissions exceeding the Sac Metro Air District’s thresholds of significance. The Interim Recommendation was put in place to assist lead agencies and practitioners with CEQA document preparation until the Sac Metro Air District developed a methodology that would provide a consistent, reliable and meaningful analysis to address the Court’s direction on correlating health impacts to a project’s emissions.
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Purpose and Authority 2 Sac Metro Air District
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2. PURPOSE AND AUTHORITY
The Sac Metro Air District is one of 35 air districts in California responsible for local air quality planning, monitoring, and stationary source permitting. Sac Metro Air District covers Sacramento County, including the cities of Sacramento, Citrus Heights, Folsom, Rancho Cordova, Elk Grove, Galt, and Isleton.
Under the CEQA review process, Sac Metro Air District may serve as the lead agency, a responsible agency with limited discretionary authority, or a reviewing agency providing comment on the air quality impacts of a proposed project or plan. CEQA requires that lead agencies identify significant environmental impacts and to avoid or mitigate those impacts if feasible. Lead agencies in the Sacramento Federal Nonattainment Area (SFNA) often look to the Sac Metro Air District for guidance on CEQA-related topics. In addition, the Sac Metro Air District partners on regional issues with nearby air districts including the following:
• Yolo-Solano Air Quality Management District;
• Placer County Air Pollution Control District;
• El Dorado County Air Quality Management District; and • Feather River Air Quality Management District.
Sac Metro Air District staff has developed this guidance with input from the other SFNA air districts since they share air quality issues and use the same growth assumptions, mobile source emissions, and modeling efforts to support ozone and PM attainment plans. The geographic area covered by the Sac Metro Air District and the four other neighboring Air Districts listed above is referred to as the Five-Air-District Region.
This guidance is intended for use in the Sac Metro Air District, however it contains information that can be used by the partner agencies to set guidance.
This guidance document:
1. Replaces the Interim Recommendation.
2. Provides insight on the health effects that may result from a project emitting at the maximum thresholds of significance (TOS) levels in the Five-Air-District Region for oxides of nitrogen (NOX), volatile organic compounds (VOCs), and PM, in addition to levels of CO and oxides of sulfur (SOX) calculated proportional to NOX (as described in Section 4.1). This information can be used in environmental documents to provide a conservative estimate of the health effects of criteria pollutant emissions at the significance thresholds or below.
3. Provides look-up tables for estimating health effects for strategic areas where growth exceeding thresholds of significance is anticipated.
4. Provides modeling guidance for CEQA projects that have emissions in excess of the significance thresholds and are located outside the strategic areas modeled.
5. Provides information on disclosing health effects in an overall health context in a CEQA document.
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Organization of Guidance 3 Sac Metro Air District
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3. ORGANIZATION OF GUIDANCE
This guidance document provides an overview of the Friant Ranch screening analyses, methods and results. Section 4 describes the screening analysis approach and methods for projects with emissions at or below the thresholds of significance. Section 5 describes the screening methods for projects located in strategic areas with emissions above the thresholds of significance. Section 6 provides a general description of the recommended analysis methods for projects above the thresholds of significance suitable for planners and the public should the screening methods in Section 4 and Section 5 not be applicable.
Section 7 provides information on incorporating health effects information into a CEQA document and discussing overall health context. Appendix A provides, for practitioners skilled in the art of photochemical grid modeling and health effects analyses, recommended procedures for conducting a health effects analysis that would be expected for larger projects and for projects that do not fit the requirements described for using the screening analyses.
The procedures used in conducting the health effects screening analysis for small projects are discussed in Appendix B. Appendix C discusses the screening analysis for strategic area projects. The treatment of SO2 and CO emissions that do not have significant emissions levels in the screening analysis and procedures for speciating ROG and PM emissions is discussed in Appendix D. Appendix E provides a list of commonly used Source Classification Codes (SCC) for source types from typical CEQA projects. Appendices F and G provide health effects output for the minor project and strategic area project screening modeling.
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Guidance for Screening Health Effects Analysis 5 Sac Metro Air District Ramboll
health impacts from ozone and PM2.5. More discussion of the procedures to conduct a health effects analysis are provided in Section 6 of this guidance, with technical details provided in Appendix A.
4.3 Screening Analysis for Projects at or Below Thresholds Levels A health effects screening analysis was conducted for hypothetical sources within the Sac Metro Air District and neighboring air districts (i.e., the Five-Air-District Region) using emission rates at the thresholds of significance (noted in Table 1). The hypothetical source locations were intended to be proxy locations for where real projects may be located.
4.3.1 Definition of Hypothetical Project Sources for Screening Analysis Each hypothetical source was assumed to have an emission rate for each pollutant at the threshold of significance, indicated by the red numbers in Table 1. This resulted in an emission rate of 82 lbs./day for NOX, ROG, PM2.5 and PM10. The hypothetical sources also included emission rates of CO and SO2 that were based on an analysis of the ratios of the emission rates of SO2 to NOX and CO to NOX for six recent CEQA projects in Sacramento County. This analysis is described in Appendix D.
Figure 1 shows the geographic areas in which the Sac Metro Air District expects CEQA projects to be located in Sacramento and neighboring counties (shaded blue), along with the locations of the 41 hypothetical projects. These expected growth areas are consistent with the Sacramento Area Council of Government’s 2050 Blueprint growth map. The 41 hypothetical projects were distributed across the potential growth areas to capture the differences in the dispersion regimes of the mountain/valley flow systems, photochemical regimes, areas which include high and low emissions levels, urban and rural atmospheres, and population densities of the urban versus remote areas. 830
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Guidance for Screening Health Effects Analysis 6 Sac Metro Air District Ramboll
Figure 1. Potential CEQA project locations (blue shading) in the five-air-district region along with locations of the 41 hypothetical project locations used in the screening modeling.
4.3.2 Screening Analysis Health Effects Modeling
For the screening analysis, the Comprehensive Air Quality Model with Extensions (CAMx) PGM was used with a 2012 annual 4-km grid resolution meteorological and emissions database for a domain covering Sacramento and nearby counties. The 2035 future year anthropogenic (i.e., human-made) emissions were used as the baseline. The ozone and PM impacts were estimated from each of the 41 hypothetical sources whose emissions were set at the 82 lbs./day TOS level for ROG, PM2.5 and NOX and corresponding levels of CO and SO2.
Health effects were estimated for each of the 41 hypothetical sources using a simulator of USEPA’s BenMAP health effects model with the concentration-response (C-R) functions, 2035 population, and procedures described in Appendix A (see Tables A-1 and A-2). This guidance recommends assessing mortality (all causes), hospital admissions (respiratory, asthma, cardiovascular), emergency room visits (asthma), and acute myocardial infarction (non-fatal) health effects for PM2.5, and assessing mortality, emergency room visits (respiratory) and hospital admissions (respiratory) health effects for ozone, consistent with 831
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the USEPA’s approach when establishing the National Ambient Air Quality Standards (NAAQS)1.
As an example, Table 2 displays the health effects for PM and ozone increases resulting from hypothetical source location number 20 (see Figure 1 for location map). The analysis estimates that a project at hypothetical source location number 20, emitting 82 lbs./day of NOX, ROG and PM and corresponding levels of CO and SO2, would have 2.3 premature deaths (mortality, all causes) per year across the modeling domain (see Appendix A, Table A-1 and Appendix B, Figure B-2 for the Reduced Sacramento 4-km Modeling Domain specifications and map) and 2.1 premature deaths per year within the Five-Air-District Region due to its increases in PM concentrations. To put this health effect into context, Table 2 also includes the increase over the background health incidence rate of each health effect endpoint within the Five-Air-District Region. For hypothetical source location number 20, the 2.1 premature deaths per year within the Five-Air-District Region due to the project’s PM impacts would result in a very small (0.005%) increase over the background incidence of premature deaths due to PM concentrations within the Five-Air-District Region, which is 44,766 deaths per year.
The PM and ozone health effects due to emissions from each of the 41 hypothetical source locations are provided in Appendix F.
1 https://www3.epa.gov/ttn/naaqs/standards/pm/data/PM_RA_FINAL_June_2010.pdf. 832
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4.3.3 Minor Project Health Effects Screening Tool
The health effects of the 41 hypothetical sources were interpolated to the 4-km modeling domain and imported into an interactive spreadsheet into which the user can input the project location and obtain the estimated health effects information for a source with TOS emission rates at that location. Projects with emissions lower than the TOS would have lower estimated health effects.
The Minor Project Health Effects Screening Tool is available on the Sac Metro Air District’s CEQA Guidance & Tools website.
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Figure 3. Locations of six strategic area Projects I-VI used in the screening modeling, along with the 41 hypothetical projects used in the minor project analysis with boundary of the Five-Air-District Region (red) and the SFNA shaded grey.
The screening modeling addressed hypothetical sources at each of the six strategic area project locations at emission levels that were two times (2x) and 8 times (8x) the maximum threshold of significance level (see Table 1). The strategic area projects also included CO and SO2 emissions and speciated ROG and PM emissions using the same approach as used in the 41 hypothetical minor project analysis (see Appendix D). The strategic area project screening modeling emissions rates used are shown in Table 4. 838
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5.3 Recommendations for Using the Strategic Area Projects Health Effects Screening Tool
The Strategic Area Health Effects Screening Tool can provide an estimate of the health effects for a CEQA project within the Sac Metro Air District and the 5-Air-District Region with 656 lbs/day or less of NOx, ROG and PM2.5 emissions. If the proposed CEQA project is within close proximity (e.g., within one 4-km grid cell) of one of the six strategic area source locations, a project proponent can discuss using the health effects from the Tool at that strategic area location with concurrence from the Sac Metro Air District, or applicable air district if the project is located outside of Sacramento County. If the project is located within the Sac Metro Air District, but is not in close proximity to one of the six strategic area source locations, then the project proponent may use the health effects results from the South Sacramento strategic area location as that will provide a conservative (i.e., upper bound) estimate of the potential health effects of the project, since the South Sacramento strategic area is located in the highest population area in the 5-Air-District Region. If a project is located outside of Sacramento County, the project proponent should confirm this approach with the applicable air district. Alternatively, the project proponent can conduct explicit photochemical grid and health effects modeling following the procedures in section 6 and Appendix A of this guidance. 840
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6. ANALYSIS OF INDIVIDUAL PROJECTS
For a practitioner skilled in the art of photochemical grid modeling and health effects analysis, Appendix A provides detailed guidance on how to conduct a health effects analysis for an individual project in Sacramento County, and potentially in the Five-Air-District Region, with input from the applicable air district. This section provides a layperson’s description of this approach. While the approach outlined in this section can be used for any project, this guidance document allows a screening approach for projects within Sacramento County and the Five-Air-District Region in which emissions of VOC, NOX and PM are equal to the maximum thresholds of significance or lower, and provides look-up tables for larger projects in designated strategic areas. Therefore, this individual project modeling guidance should only be used for larger projects outside the designated strategic areas to prepare a site-specific health effects analysis.
In order to estimate the health effects of the increases of criteria pollutants from a proposed project, practitioners should apply a photochemical grid model (PGM) to estimate the increases in concentrations of ozone and PM2.5 in the region as a result of the emissions of criteria and precursor pollutants from a project. Next, apply the U.S. Environmental Protection Agency (USEPA)-authored program, the Benefits Mapping and Analysis Program (BenMAP2), to estimate the resulting health effects from the increases in concentration. This process is described further below.
6.1 Pollutants Evaluated
This analysis estimates the health effects of criteria pollutants and their precursors, specifically those health effects that are evaluated by the USEPA in rulemaking setting the NAAQS: NOX, VOC [also known as reactive organic gases, or ROG, which are virtually the same as VOC with some slight differences]3, CO, ozone, SO2, PM2.5 and PM10. USEPA’s default health effects functions in BenMAP for PM use PM2.5 as the causal PM agent, so the health effects of PM10 are represented using PM2.5 as a surrogate. NOX and VOC are not criteria air pollutants but, in the presence of sunlight, they form ozone and contribute to the formation of secondary PM2.5 and thus are analyzed here. As a conservative measure, SO2 and CO are evaluated due to their small contribution to the formation of secondary PM2.5 and ozone, respectively.
This guidance recommends that the health effects from ozone and PM2.5 be evaluated, because the USEPA has determined that these criteria pollutants would have the greatest effect on human health. While ozone is not commonly emitted directly, some PM2.5 is emitted directly. Ozone and secondary PM2.5 are formed by the emissions of other pollutants to the atmosphere, including VOC, NOX, CO and SO2.
Additionally, SO2, NO2 and CO concentration changes due to a project are not evaluated individually. Each of these pollutants has NAAQS against which the presence or absence of health effects can be measured, and none of these pollutants are typically considered to be formed in the atmosphere as secondary pollutants, as are ozone and PM2.5. NAAQS are health-based thresholds and thus a direct comparison with them allows evaluation of
2 https://www.epa.gov/benmap/benmap-ce-manual-and-appendices. 3 ROG emissions are quantified and modeled as VOCs in this assessment. ROG means total organic gases minus ARB's "exempt" compounds (e.g., methane, ethane, CFCs, etc.). ROG is similar, but not identical, to USEPA's term "VOC", which is based on USEPA's exempt list, which is slightly different from ARB’s list. 841
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potential health effects. NO2 concentration changes are not individually evaluated as there are currently no NO2 non-attainment areas in the United States, even now that the 1-hour standard has been implemented. Similarly, SO2 concentration changes are also not individually evaluated as there are no current SO2 non-attainment areas in the state of California. Sac Metro Air District has been in attainment of the NAAQS and State CO standards since the early 1990s. Even so, as noted above, contributions of NOX, CO, and SO2 continue to be evaluated for their contributions to the formation of ozone and secondary PM2.5, the two criteria pollutants the USEPA has determined to have the greatest effect on human health.
6.2 Technical Analysis
The first step in the technical analysis is to run the PGM with appropriate information to assess the increases in ambient air concentrations of pollutants that the project’s emissions may cause. PGMs require a database of information, including meteorological fields and how emissions are distributed in the area to be modeled. This includes both existing emissions and project emissions. The latest publicly-available PGM database for Northern California should be used in this analysis.
The USEPA’s air quality modeling guidelines (Appendix W4) and ozone and PM2.5 modeling guidance5 recommend using a PGM to estimate ozone and secondary PM2.5 concentrations.
The USEPA’s modeling guidance does not recommend specific PGMs but provides procedures for determining an appropriate PGM on a case-by-case basis. Both the modeling guidelines and guidance note that the CAMx6 and the Community Multiscale Air Quality (CMAQ)7 PGMs have been used extensively in the past and would be acceptable PGMs. The USEPA has prepared a memorandum8 documenting the suitability of using CAMx and CMAQ for ozone and secondary PM2.5 modeling of a single-source or small group of sources.
To estimate the potential outcome of a proposed project’s emissions on ambient pollutant concentrations, add the project’s mitigated emissions to the existing emissions in the PGM database. Ensure that the project emissions that are analyzed present a maximum year.
Construction emissions could be included in the analysis if the lead agency determines the size, intensity, and duration of construction warrant review and disclosure. These maxima may occur in different years but may be conservatively analyzed in a single-year assessment. Consider when the maximum emissions year will have the greatest impact. It is recommended that maximum 24-hour emission rates be used, as some of the C-R health effects functions use daily concentration estimates. Account for seasonal changes in maximum 24-hour emissions when appropriate, such as when wood stoves or fireplaces are used for home heating in the cold months.
Each project’s emissions should be spatially distributed across the modeling area in a manner that reflects the actual distribution, considering where mobile source emissions may occur. Operational emissions may include area sources (architectural coatings, VOCs in
4 https://www3.epa.gov/ttn/scram/appendix_w/2016/AppendixW_2017.pdf. 5 https://www3.epa.gov/ttn/scram/guidance/guide/O3-PM-RH-Modeling_Guidance-2018.pdf. 6 http://www.camx.com/.
7 https://www.epa.gov/cmaq.
8 https://www3.epa.gov/ttn/scram/guidance/clarification/20170804- Photochemical_Grid_Model_Clarification_Memo.pdf.
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consumer products, and landscaping equipment), emergency generators, off-road equipment, and emissions associated with motor vehicle use. Construction emissions may include off-road equipment, paving, architectural coatings, fugitive dust, and emissions associated with hauling, vendor, and worker activity.
Following completion of the PGM modeling, use USEPA’s BenMAP9, 10 program to estimate the potential health effects of the project’s contribution to ozone and PM2.5 concentrations.
BenMAP uses the concentration estimates produced by the PGM along with population and health effect C-R functions to estimate various health effects of the concentration increases.
BenMAP has a wide history of applications by the USEPA and others, including for local-scale analyses11 as needed to assess the health effects of a project’s emissions. Use the USEPA default BenMAP health effects C-R functions that are typically used in national rulemaking, such as the health effects assessment12 for the 2012 PM2.5 NAAQS. The guidance recommends assessing the following health effects for PM2.5: mortality (all causes), hospital admissions (respiratory, asthma, cardiovascular), emergency room visits (asthma), and acute myocardial infarction (non-fatal). For ozone, the guidance recommends the following endpoints: mortality, emergency room visits (respiratory) and hospital admissions (respiratory).
The procedures outlined in Appendix A are designed to provide guidance to a practitioner with experience in PGM modeling to conduct a health effects analysis that satisfies the requirements of the Friant Ranch court decision. Consequently, the guidance assumes a level of knowledge of PGM and health effects modeling and is not designed for those not familiar with PGM and health effects modeling.
9 https://www.epa.gov/benmap/how-benmap-ce-estimates-health-and-economic-effects-air-pollution. 10 https://www.epa.gov/sites/production/files/2015-04/documents/benmap-ce_user_manual_march_2015.pdf. 11 https://www.epa.gov/benmap/benmap-ce-applications-articles-and-presentations#local. 12 https://www3.epa.gov/ttn/naaqs/standards/pm/data/PM_RA_FINAL_June_2010.pdf. 843
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7. DISCLOSING MODELING RESULTS IN A PROJECT
CEQA DOCUMENT
Now that photochemical grid modeling and BenMAP analyses have been conducted for minor projects at the maximum threshold levels at 41 locations in the five-air-district area, and for projects greater than threshold levels (2x and 8x) for 5 strategic growth areas, an analysis of the results must be developed for disclosure in a project CEQA document. Only the health effects of ozone and PM2.5 are addressed in this guidance, as those are the pollutants that USEPA uses in BenMAP to estimate the health effects of emissions of NOx, VOCs, CO, SO2, and PM2.5. Ozone and PM2.5 have the most critical health effects and thus are the emissions evaluated to determine the CEQA project’s health effects. A CEQA analysis should report the results generated by the Minor Project Health Effects Screening Tool, Strategic Area Project Health Effects Screening Tool (example output in Table 2), or project specific modeling, and qualitatively discuss how the health effects tool provides an average estimate across all populations. Note that CEQA “does not require technical perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at full disclosure.”13 To this end, the environmental document will be improved in its sufficiency as an informational document if it includes a qualitative discussion of influences on the outcomes of modeling the health effects of projects. These factors may apply universally to the health effects on the total population or be limited in application to population subgroups.
7.1 Discussing Health Effects on the Total Population
Present the applicable screening table for the project and frame the model’s outputs in terms of the wider context of current population health. Provide this wider context for the results by describing overall health conditions in the county. This can be done by using other data sources, which might include:
• Be Healthy Sacramento14, which provides a search of and comparisons of local health indicators.
• The California Department of Public Health, which provides County Health Status Profiles.15
• The California Air Resources Board’s lists of health tracking websites, which provide community health trends.16
As an example of how to use this data, Sacramento County’s Health Status Profile for 2019 reported an annual average of 11,551 deaths from all causes (2015-2017) in Sacramento County. This can be compared to a project with emissions at or below the thresholds of significance for which the screening tool indicates that the potential increase in mortality incidence is less than 3 in the Five-Air-District Region.
13 2020 CEQA Statute & Guidelines Handbook https://www.califaep.org/statute_and_guidelines.php, Association of Environmental Professionals, CEQA Guidelines Section 15003, Policy (i), p. 136. Accessed 4/28/20 14 Be Healthy Sacramento, Sacramento County, 2020, www.behealthysacramento.org. Accessed 3/9/2020 15 Vital Records Data and Statistics, California Department of Public Health, 2020, https://www.cdph.ca.gov/Programs/CHSI/Pages/County-Health-Status-Profiles.aspx. Accessed 3/9/2020 16 Understanding the Health of Our Communities, California Air Resources Board, 2020, https://ww2.arb.ca.gov/resources/documents/understanding-health-our-communities. Accessed 3/13/2020 844
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Also consider that overall, each model generates conservative estimates of health effects, for two reasons:
• The tools’ outputs are based on the simulation of a full year of exposure at the maximum daily average of the increases in air pollution concentrations. As a result, actual project-related health effects may be less than the estimates calculated by the tool. For more information on how the CAMx modeling was prepared to estimate ozone and PM2.5 emission concentration changes due to a project’s emissions, and the resulting conservative nature of the health effects modeling using the BenMAP model, please see Section A.4 of Appendix A.
• The health effects are calculated for emissions levels that are very high. For the Minor Projects Health Effects Tool, described in Section 4, emissions are assumed to be at the threshold of significance levels. The Minor Projects Health Effects Screening Tool estimates the mean incidence of health outcomes such as mortality, hospital admissions, emergency room visits and heart attacks (acute myocardial infarction) in the Five-AirDistrict Region that may result from emissions from a new project that emits 82 pounds/day of NOx, ROG or PM. For the Strategic Area Project Health Effects Tool, described in Section 5, inputted emissions are between two times and eight times the threshold of significance (up to 656 pounds/day). The Strategic Area Project Health Effects Screening Tool focuses the analysis in six locations where growth is expected from projects with emissions above thresholds levels. Most projects, except for large plans such as specific plans, will not have emissions at these high levels.
However, even with these conservative factors built in, the models’ outputs indicate low overall health effects. The mean health incidence for a project emitting at the threshold of significance levels at all 41 locations was less than 3 per year for mortality and less than 1.5 per year for other health outcomes evaluated. The modeling results support a conclusion that any one proposed project in the Five-Air-District Region with emissions at or below the maximum threshold levels does not on its own lead to sizeable health effects. At the strategic area locations, as expected, mean health incidences are higher than the Minor Projects Health Effects Screening Tool. The maximum reported mortality rate is 22 incidences per year and all other health outcomes evaluated are under 9 per year from a project emitting 656 pounds/day of NOx, ROG, and PM at the downtown Sacramento location.
On the other hand, projects may produce other health effects that are not evaluated in the models. These can be discussed as well. • The models’ outputs include only the effects that have been researched sufficiently so as to be quantifiable. Research has identified other health effects for both PM2.5 and ozone than those indicated in the models. – For PM2.5, modeled health outcomes include respiratory effects, cardiovascular effects, and premature mortality. But PM2.5 through various modes of action can alter not only respiratory and cardiovascular systems, but also metabolism, affecting weight gain and increasing diabetes rates; the nervous system, leading to cognitive decline, brain inflammation, and reduced brain volume; and gestation, resulting in 845
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low birthweight and preterm birth.17 These other effects have been documented but not been studied sufficiently to identify a dose-response relationship. – For ozone, the health consequences reported by these models include respiratory effects and premature mortality. In the screening models, project health effects resulting from ozone are considerably smaller than those of PM2.5. Ozone is primarily a respiratory system irritant, but at sufficient doses, ozone can increase lung permeability, increasing their susceptibility to toxins and microorganisms.18 Longterm exposure to ozone may cause permanent lung damage, such as abnormal lung development in children, and has also been linked to cardiovascular effects, but less is known than for PM2.5 about the concentrations at which these effects occur.19
7.2 Discussing Health Effects in Population Subgroups
The models estimate increases in the incidence of health effects in the entire population of the Five-Air-District Region. The model outputs are derived from the numbers of people who would be affected by a project due to their geographic proximity and based on an average population throughout the Five-Air-District Region. The models do not take into account population subgroups with greater vulnerabilities to air pollution, except for ages for certain endpoints. The health effects of increased air pollution emissions may occur disproportionately in areas where the population is more susceptible to health effects from air pollution.
The Centers for Disease Control and Prevention (CDC)20 reports human health being influenced by five main determinants: genetics, behavior, environmental and physical influences, medical care, and social factors. These five determinants of health are seen in Figure 4. BenMAP estimates the potential health effects from a change in air pollution concentrations, but does not fully account for other factors impacting health such as access to medical care, genetics, income levels, behavioral choices such as diet and exercise, and underlying health conditions. As an environmental factor, air pollutants have been linked to multiple health effects, with greater impacts on vulnerable populations.21 Vulnerable populations are those defined by environmental sensitivity factors such as age, race/ethnicity, levels of education and income, and linguistic isolation.22
17 Particulate Matter: Spotlight on Health Protection. Symposium Summary: Health Effects and Exposures and Risk.
October 29, 2019. Bay Area Air Quality Management District. https://www.baaqmd.gov/~/media/files/board-ofdirectors/advisory-council/2019/20191028-pm-symposium-summary-final-03062020-pdf.pdf?la=en. Accessed 4/28/20.
18 Facts About Ozone and Health, California Air Resources Board, 2016, https://ww3.arb.ca.gov/research/aaqs/caaqs/ozone/ozone-fs.pdf Accessed 4/17/20 19 Ozone and Oxidants, Health Effects Institute, https://www.healtheffects.org/air-pollution/ozone-and-oxidants, 2020. Accessed 4/9/2020
20 NCHHSTP Social Determinants of Health, U.S. Centers for Disease Control and Prevention, 2019, https://www.cdc.gov/nchhstp/socialdeterminants/faq.html#what-are-social-determinants . Accessed 4/13/2020 21 People at Risk, California Air Resources Board, 2020, https://ww2.arb.ca.gov/our-work/programs/peoplerisk/about. Accessed 4/14/2020 22 Climate Change and Health Vulnerability Indicators for California, California Department of Public Health, April 2020. https://www.cdph.ca.gov/Programs/OHE/Pages/CC-Health-Vulnerability-Indicators.aspx. Accessed 4/29/20
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community. On the other hand, primary PM2.5 emissions are more locally concentrated. For example, the people who experience the most health effects from roadway pollutant emissions are those who live within 1,000 feet of a freeway or major roadway.25 Projects that emit a great deal of PM2.5 are likely to have more impact locally in vulnerable communities than in communities more representative of the average population of the region.
7.3 Identifying Vulnerable Populations
To identify and discuss the population characteristics near a project site that may lead to increased risk of health effects from a project, a useful tool is the Healthy Places Index26 created by the Public Health Alliance of Southern California and derived from federal, state and local government data. The Healthy Places Index (HPI) offers indicators of local community conditions in California that contribute to life expectancy and a mapping tool for comparisons of selected areas with other areas across the region or the state. The HPI mapping tool can be used to compare specific characteristics of the population in the area of the proposed project – such as the proportion of the population living below 200% Federal Poverty Level – with other census tracts, cities, counties, Congressional districts, elementary school districts, or other geographic units in the area. It can also be used to compare the overall relative health vulnerability (the combined indicators) with those of other geographic units. The HPI mapping tool allows the user to compare local factors down to the census tract level, a degree of resolution that is useful for assessing project health effects. A geographic area that appears in a shade of blue on the HPI mapping tool has lower levels of health-promoting community conditions and could be reported in the CEQA analysis as likely to experience a disproportionate rate of health effects from a project than a community that appears in a shade of green. The HPI mapping tool provides comparisons only, showing how an area compares to other areas in the state or to other geographic regions selected, and not raw numbers.
7.4 Consideration of Incidental Health Effects
While this guidance is focused on the health effects of air pollution emitted by a single project, it should be considered that a project may influence health in other ways. New development creates changes in the built environment that can affect health through various pathways. A complete analysis might include a qualitative discussion of how the project’s changes to the built environment could have incidental health effects, and whether those incidental health effects will be experienced by project users and the broader community.
The following topics could be considered.
Vehicle Miles Traveled: Increasing vehicle miles traveled per capita (VMT/capita) in a region creates acute health impacts (injuries and deaths due to vehicle collisions) as well as chronic health impacts (obesity, hypertension, diabetes, and heart disease due to increased sedentary behaviors, such as driving).27 Conversely, reducing VMT/capita by increasing
25 Strategies to Reduce Air Pollution Exposure Near High Volume Roadways, California Air Resources Board, Technical Advisory April 2017. P. 12. https://ww2.arb.ca.gov/sites/default/files/2017- 10/rd_technical_advisory_final.pdf. Accessed 4/28/20.
26 https://healthyplacesindex.org/
27 Cutting Greenhouse Gas Emissions is Only the Beginning: A Literature Review of the Co-Benefits of Reducing Vehicle Miles Traveled, UC Davis National Center for Sustainable Transportation, 2017, 848
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density and land use mix, especially when combined with sidewalks or trails and public transit infrastructure, enables more people to live closer to daily destinations, making it practical to walk and bike instead of drive. This increases physical activity and reduces obesity, diabetes, high blood pressure, heart disease, and other chronic conditions associated with a sedentary lifestyle. Infill development provides support for transit operations, which offer people more options for accessing health-supportive services such as grocery stores, pharmacies, and medical facilities. Building housing near transit encourages people to walk to transit to get to where they need to go, and provides linkages to jobs, food, and health services for the one-third of adults who do not drive. More compact, connected street networks with fewer lanes on major roads are correlated with lower levels of obesity, diabetes, high blood pressure, and heart disease, as well as with the lowest levels of traffic deaths.28
Urban Greening: Greater neighborhood tree canopy has been correlated to improvement of overall human health, primarily healthier weight, social cohesion, and mental health.29 People make more walking trips to task destinations such as stores or coffee shops when they perceive that there are many natural features along the route, including street trees.
New trees planted on roadsides and medians and along sidewalks reduce crash rates on both urban arterial and highway sites.30 Trees and shrubs in thick vegetative barriers along freeway edges can also absorb and disperse traffic emissions and thus reduce exposure to pollutants for nearby populations. Shade trees on streets, in parking lots, and near driveways reduce emissions of volatile organic compounds from parked cars.
Heat Exposure: By the end of the century, average daily temperatures will increase by 10o F in the Sacramento region, with as many as 36 added days of extreme heat (greater than 103.9o F) per year in some areas. Extreme heat can lead to heat-related illnesses such as heat rash, heat exhaustion, and heatstroke. If left untreated, heat-related conditions can lead to death.31 The built environment can increase or decrease incidence of extreme heat and heat exposure. Projects that convert natural or agricultural lands to areas covered with concrete, asphalt, and rooftops increase the amount of solar radiation that is absorbed and re-radiated into the surrounding environment, creating an urban heat island effect. Projects that increase tree canopy and utilize high-albedo surfaces such as cool roofs and cool pavements can lower local temperatures and contribute to regional reductions. Combining these vegetation and cool-surface measures provides the greatest effect.32 Allostatic Load: Defined as the cost of chronic exposure to elevated or fluctuating stresshormone or neural responses resulting from chronic or repeated challenges that the
https://ncst.ucdavis.edu/research-product/cutting-greenhouse-gas-emissions-only-beginning-literature-reviewco-benefits. 28 Marshall WE et al (2014) Community design, street networks, and public health. J Transport and Health 1 (4), p. 326-340. Dec 2014. https://doi.org/10.1016/j.jth.2014.06.002 29 Ulmer JM et al. Multiple health benefits of urban tree canopy: The mounting evidence for a green prescription, Health and Place 42, 54-62. November 2016. https://doi.org/10.1016/j.healthplace.2016.08.011 30 Mok, J., et al. (2006) Landscape Improvement Impacts on Roadside Safety in Texas. Landscape and Urban Planning, Vol. 78, No. 3, pp 263-274. http://www.naturewithin.info/Roadside/RdsdSftyTexas_L&UP.pdf 31 Capital Region Climate Readiness Collaborative, Capital Region Transportation Sector Urban Heat Island Reduction Plan, May 2020. pp. 9-10. https://urbanheat-smaqmd.hub.arcgis.com/ 32 Capital Region Climate Readiness Collaborative, Capital Region Transportation Sector Urban Heat Island Reduction Plan Summary Report, May 2020, p. 16. https://urbanheat-smaqmd.hub.arcgis.com/ 849
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individual experiences as stressful, allostatic load can lead to development of heart disease, diabetes, chronic pain, fatigue, and other conditions.33 The built environment can increase or decrease the allostatic burden placed on individuals. Projects that expose people to chronic noise or odors increase the burden. Allostatic load also increases if people have difficulty fulfilling daily needs. Projects that support individuals of all incomes and ages and that include a mix of uses or amenities to facilitate daily life will reduce the sense of stress in peoples’ lives. Infill and compact development projects can increase community connectivity and social cohesion (trust), reducing stress and improving health resilience. Allostatic load is also decreased by projects that provide ample access to safe physical activity, whether through sidewalks and bike lanes that lead to daily destinations or networks of walking and biking trails. Projects that incorporate social cohesion can increase perceived safety, which also reduces stress and encourages use of active modes.
Once the health effects of a project are fully reviewed and described, including disclosure of outputs from one of the screening tools or project-specific modeling results and discussion of health effects in context, the lead agency can make an informed decision on a project with health effects information that meets the intent of the Friant ruling.
33 Allostatic Load, ScienceDirect, 2020. https://www.sciencedirect.com/topics/neuroscience/allostatic-load 850
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This Appendix provides documentation on how to conduct a site-specific health effects analysis for a project in Sacramento County (and potentially the Five-Air-District Region with input from the applicable air district) that does not qualify to use the minor project screening approach, or the larger project strategic area approach provided in this guidance.
The procedures outlined in this Appendix are designed to provide guidance to practitioners with experience in PGM modeling in conducting health effects analyses that satisfy the requirements of the Friant Ranch court decision. Consequently, this guidance assumes a level of knowledge related to PGM modeling and is not designed for those not familiar with PGM modeling. 852
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A.1 OVERVIEW OF TECHNICAL APPROACH
The first step in this process is to run a photochemical grid model (PGM) with appropriate information to assess the increases in ambient air concentrations of pollutants caused by the project’s emissions.
PGMs require a database of information, including meteorological fields and the spatial allocation of emissions in the area to be modeled, including both base (background/existing) emissions and emissions for the project being evaluated. A recommended modeling plan for conducting such a photochemical modeling study is provided in Section A.2.
Project emissions include oxides of nitrogen (NOX), respirable (PM10) and fine (PM2.5) primary particulate matter (PM), sulfur dioxide (SO2), carbon monoxide (CO) and volatile organic compounds (VOC, also called ROG). NOX and VOC are precursors to ozone and, along with SO2, are also precursors to secondary PM2.5. CO also plays a smaller role in the formation of ozone and should be considered for evaluation if emissions information is available.
To estimate the potential outcome of a proposed project’s emissions on ambient air concentrations, a project’s emissions are added to the 4-km annual PGM modeling database.34 For use in PGMs, each project emissions source must be spatially distributed across the modeling grid cells so that they can be incorporated into the gridded emission inventory. For projects with on-road mobile source emissions, the emissions will need to be spread across the roadway network.
Once project emissions are allocated to grid cells, emission estimates from the project are spatially gridded, temporally allocated (e.g., adjustments to account for season/month, day-of-week and hourof-day), and chemically speciated to be used for the PGM using the Sparse Matrix Operator Kerner Emissions (SMOKE35) emissions modeling system supported by the USEPA. More details on how to work with the emissions inventory, spatial allocation, and SMOKE inputs and outputs are described in Section A.3.
In order to be conservative, we recommend that future year emissions be used for the modeling database. Future years will feature larger populations and lower background emissions, which usually results in higher ozone and secondary PM from the incremental project emissions. Accordingly, the future year database provides the most conservative estimate of health effects. More details on preparing inputs for the PGM modeling are included in Section A.3.
Following completion of the PGM modeling, the USEPA’s BenMAP36, 37 program is used to estimate the potential health effects of the project’s contribution to ozone and PM2.5 concentrations. USEPA’s default health effect functions in BenMAP for PM use fine particulate (PM2.5) as the causal PM agent, so the health effects of PM10 are represented using PM2.5 as a surrogate. BenMAP uses the concentration
34 In this guidance we recommend that the currently available BAAQMD 2012 PGM modeling database be used for the CCOS Northern California domain or a reduced size domain that is focused on the SFNA. BAAQMD performed Weather Research and Forecasting (WRF) meteorological modeling for the 4-km domain and 2012 calendar year that has been processed by MCIP and WRFCAMx to generate CMAQ and CAMx 2012 4-km meteorological inputs for the domain. BAAQMD prepared 2012 emissions for the CMAQ model that have been converted to the format used by CAMx using the CMAQ2CAMx processor.
35 https://www.cmascenter.org/smoke/
36 https://www.epa.gov/benmap/how-benmap-ce-estimates-health-and-economic-effects-air-pollution. 37 https://www.epa.gov/sites/production/files/2015-04/documents/benmap-ce_user_manual_march_2015.pdf. 853
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estimates produced by CAMx, along with population and health effect concentration-response (C-R) functions, to estimate the various health effects of the concentration increases. BenMAP has a wide history of applications by the USEPA and others, including for local-scale analysis38 as needed for assessing the health effects of a project’s emissions. This guidance recommends using USEPA-default BenMAP health effects C-R functions that are typically used in national rulemaking, such as the health effects assessment39 for the 2012 PM2.5 NAAQS. The health effects for PM2.5 include mortality (all causes), hospital admissions (respiratory, asthma, cardiovascular), emergency room visits (asthma), and acute myocardial infarction (non-fatal). For ozone, the endpoints are mortality, emergency room visits (respiratory) and hospital admissions (respiratory). Details on the BenMAP inputs and outputs and definitions for the health effects are shown in Section A.4.
38 https://www.epa.gov/benmap/benmap-ce-applications-articles-and-presentations#local. 39 https://www3.epa.gov/ttn/naaqs/standards/pm/data/PM_RA_FINAL_June_2010.pdf. 854
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A.2 MODELING PLAN
Estimating the potential health impacts of criteria pollutants due to emissions from a proposed CEQA project involves the following activities:
• Selection of an air quality model and air quality modeling database for use in the analysis.
• Estimating the ozone and PM precursor emissions for the proposed CEQA project. • Processing of the CEQA project emissions for use in the selected air quality model. • Air quality modeling of the proposed CEQA project emissions to obtain the incremental ozone and PM concentrations due to the project’s emissions. • Processing of the incremental ozone and PM concentrations due to the project’s emissions by a health effects model to estimate the mortality, morbidity and other health effects.
• Documenting the health effects modeling and results with enough detail that the results could be duplicated.
A.2.1 Selection of an Air Quality Model
Proposed CEQA project emissions typically include, but are not limited to NOX, PM10, PM2.5, SO2, CO and VOC. NOX and VOCs are not criteria air pollutants40 but, in the presence of sunlight, they form ozone and contribute to the formation of secondary PM2.5 and thus are analyzed here. If SO2 and CO emissions are otherwise quantified in the environmental document, these can be conservatively included as they have contributions to the formation of secondary PM2.5 and/or ozone.
EPA’s air quality modeling guidelines (Appendix W41) and ozone and PM2.5 modeling guidance42 recommend using a photochemical model to estimate ozone and secondary PM2.5 concentrations. Most photochemical models for modeling ozone and secondary PM are photochemical grid models (PGMs).
EPA’s modeling guidance does not recommend specific PGMs but provides procedures for determining an appropriate PGM on a case-by-case basis. EPA’s air quality modeling guidelines and guidance does note that both the Comprehensive Air-quality Model with extensions (CAMx43) and the Community Multiscale Air Quality (CMAQ44) PGMs have been used extensively in the past and if applied correctly would be acceptable PGMs. In fact, EPA has prepared a Memorandum45 documenting the suitability of using CAMx and CMAQ for ozone and secondary PM2.5 modeling of single-sources or a small groups of sources.
40 The six criteria air pollutants are ozone (O3), particulate matter (PM), nitrogen dioxide (NO2), sulfur dioxide (SO2), carbon monoxide (CO) and lead (Pb).
41 https://www3.epa.gov/ttn/scram/appendix_w/2016/AppendixW_2017.pdf. 42 https://www3.epa.gov/ttn/scram/guidance/guide/O3-PM-RH-Modeling_Guidance-2018.pdf. 43 http://www.camx.com/.
44 https://www.epa.gov/cmaq.
45 https://www3.epa.gov/ttn/scram/guidance/clarification/20170804- Photochemical_Grid_Model_Clarification_Memo.pdf.
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Thus, for the Sac Metro Air District Friant Ranch analysis of the health effects of criteria pollutants from a proposed CEQA project, either the CAMx or CMAQ PGMs would be acceptable.
A.2.2 Selection of an Air Quality Modeling Platform
Because some of the health effect Concentration-Response (C-R) functions require annual PM concentrations, an annual PGM modeling platform is required. The development of an all-new annual PGM modeling platform from scratch is quite resource-intensive. Thus, it is more cost-effective to use an appropriate existing PGM modeling platform. The California Air Resources Board (ARB) and several air districts in California routinely develop PGM modeling databases to address ozone and PM2.5 attainment as part of State Implementation Plans (SIPs). We propose to use the latest publiclyavailable PGM database for Northern California, developed by the Bay Area Air Quality Management District (BAAQMD), and to adapt it for this analysis. The BAAQMD PGM database is tailored for California using California-specific input tools [e.g., the Emissions Factor (EMFAC46) mobile source emissions model] and uses a high-resolution 4-km horizontal grid resolution to better simulate meteorology and air quality in the complex terrain and coastal environment of California. This contrasts with EPA’s national modeling platforms47 used for national rulemakings [e.g., transport rules such as Cross-State Air Pollution Rule (CSAPR48) or defining new NAAQS] that use a coarser 12-km horizontal grid resolution. The BAAQMD 2012 annual PGM modeling database that uses the Central California Ozone Study (CCOS) modeling domain depicted in Figure A-1 would be appropriate for this analysis. For the hypothetical project screening analysis discussed in Appendix B, the BAAQMD 2012 annual CCOS domain PGM database was adapted for a reduced 4-km grid resolution domain covering the Sacramento and neighboring counties shown in Figure B-2 that would also be appropriate for this analysis. The CCOS and reduced 4-km PGM modeling domains use a Lambert Conformal Conic (LCC) projection with the domain definitions given in Table A-1. BAAQMD performed WRF meteorological and SMOKE emissions modeling for the CCOS 4-km domain and 2012 calendar year in generating the 2012 CCOS domain PGM modeling database. The 2012 CCOS PGM modeling database was originally developed for the CMAQ PGM but has been extended for the CAMx PGM as well. Descriptions of the WRF meteorological, SMOKE emissions and CMAQ and CAMx PGM models are available on the BAAQMD’s Research and Modeling website.49
46 https://www.arb.ca.gov/emfac/
47 https://www.epa.gov/air-emissions-modeling/2014-2016-version-7-air-emissions-modeling-platforms 48 https://www.epa.gov/csapr
49 http://www.baaqmd.gov/about-air-quality/research-and-data/research-and-modeling 856
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Figure A-1. CCOS 4 km modeling domain for Northern California PGM modeling A.2.3 Approaches for Estimating Incremental Project Contributions PGMs simulate emissions concentrations due to all sources, including all anthropogenic and natural emissions and transport from all upwind sources. There are several techniques that can be used to isolate the incremental contributions of emissions from a proposed CEQA project to ozone and PM concentrations:
1. Brute Force Method: In the Brute Force Method, the PGM is applied for a base case and a case where the project’s emissions are added to the base case and the project’s ozone and PM incremental impacts are obtained from the differences in the two simulations. 858
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2. Source Apportionment Tools: Some PGMs (including CAMx and CMAQ) come instrumented with a source apportionment tool that uses tagged species (reactive tracers) that run in parallel to the host model and keeps track of the ozone and PM contributions due to user-selected source groups (e.g., emission from a CEQA Project).
3. Sensitivity Tools: Some PGMs also come with sensitivity tools that can track the sensitivity of ozone and PM to user-selected source groups that can be post-processed to get the source contributions.
The Brute Force Method can be used with any air quality model and could be a viable method for obtaining the ozone and PM contributions from a proposed CEQA project. However, because the project’s incremental concentrations are obtained by calculating the difference between two PGM simulations, there is the potential to introduce model noise. Model noise in this case are changes in the two PGM simulations concentration estimates that are due to numerical artifacts not associated with the project’s emissions. The aerosol thermodynamic module (ISORROPIA) used in CAMx and CMAQ is particularly prone to producing model noise in particle ammonium nitrate (NH4NO3) concentrations due to its complicated parameterization that includes branching. Given the small concentrations expected from CEQA projects, model noise could be a significant issue.
Source Apportionment methods alleviate the problem of model noise because only one simulation is performed. The CAMx Ozone and Particulate Source Apportionment Technology (OSAT/PSAT) tools have been used extensively by EPA and others, including in EPA’s CSAPR (CSAPR Update51), which estimated upwind state contributions to downwind state nonattainment with details on the CSAPR CAMx source apportionment modeling contained in the CSAPR Air Quality Technical Support Document (AQTSD).52 CAMx was also used by EPA to develop single-source or facility-level ozone and secondary PM2.5 Modeled Emission Rate Precursors (MERPs53) significance threshold emission rates, a use similar to modeling a CEQA project’s emissions ozone and PM2.5 impacts. The CMAQ has the Integrated Source Apportionment Method (ISAM54) source apportionment tool for ozone and PM.
Both CAMx and CMAQ have the Decoupled Direct Method (DDM) sensitivity tool. DDM operates similarly to the source apportionment tools, providing sensitivity coefficients only for user-selected source groups. However, DDM is much more computationally extensive than source apportionment.
And for a single project, the Brute Force Method, which is another sensitivity method, is also more efficient. Thus, we do not recommend using DDM for this analysis.
Either the Brute Force or Source Apportionment methods are viable tools for estimating the incremental ozone and PM impacts due to emissions of a proposed CEQA project’s emissions. Given that it is difficult to determine whether model noise will be a problem, the Source Apportionment method is a safer pathway so it is recommended in this guidance. If using CAMx, the Anthropogenic Precursor Culpability Assessment (APCA) version of the ozone source apportionment tool should be used.
51 https://www.govinfo.gov/content/pkg/FR-2016-10-26/pdf/2016-22240.pdf. 52 https://www.epa.gov/sites/production/files/2017-05/documents/aq_modeling_tsd_final_csapr_update.pdf. 53 https://www3.epa.gov/ttn/scram/appendix_w/2016/MERPs_WebinarPresentation_01192017.pdf. 54 https://github.com/USEPA/CMAQ/blob/master/DOCS/Users_Guide/CMAQ_UG_ch11_ISAM.md 859
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A.3 EMISSIONS AND AIR QUALITY MODELING
The following sections describe how the CEQA project emissions are processed and the air quality modeling conducted using either the BAAQMD Northern California CCOS 4-km modeling domain or the Sacramento reduced 4-km modeling domain in the 2012 PGM modeling database.
A.3.1 Project Emissions
For most projects, the maximum daily emissions of criteria pollutants and their precursors from operation and construction should be used. In cases where there are projects with large seasonal variations in maximum daily emissions (e.g., wood stoves or fireplace use), the seasonal variation in the maximum daily emissions should be accounted for. If maximum daily emissions are not otherwise quantified in the environmental document, average daily emissions should be provided. At a minimum, emissions of NOX, VOC, and PM2.5 are required, unless one or more of these did not increase due to the project. If quantified and available, project emissions for CO and SO2 should be provided as well. The development of detailed emissions inventories is an important component of any CEQA project analysis.
However, for PGM modeling, the project emissions inventories need to be converted into the hourly gridded speciated emission inputs in the format used by the PGM. This is typically accomplished using the Sparse Matrix Kernel Emissions (SMOKE55) modeling system.
A.3.2 SMOKE Emissions Modeling of Project Emissions
The first step in the SMOKE emissions processing is to convert the project emission inventory into the Flat File 2010 (FF10) format for input to SMOKE. The emissions for each process of the project’s emissions need to be assigned an appropriate Source Classification Code (SCC56) that is used to crossreference to that particular source sector’s typical chemical speciation and temporal allocation profile.
SCCs are a 10-digit numerical code that represents a hierarchical classification of the source sectors emissions type. In this case, chemical speciation is performed for the SAPRC07 chemical mechanism used in the 2012 4-km PGM modeling database. Temporal allocation takes annual emissions or maximum daily emissions and distributes them to month of year, day of week, and hour of day using typical temporal profiles for each source sector as defined by the SCC. In some cases, there are source sectors that only operate during part of a year (e.g., residential wood combustion, home heating using wood stoves and fireplaces). In this case, separate SMOKE modeling using the maximum daily emissions for the different seasons is appropriate. EPA has a detailed website describing SCCs57, although not all possible SCCs have a cross-reference to chemical speciation and temporal profiles in SMOKE. Appendix E presents several SCCs that are typically used to characterize source types in CEQA project emissions that are included in SMOKE’s cross-reference file and can be used in populating the FF10 SMOKE input files.
As part of the analysis, the project source emissions need to be spatially allocated to appropriate geographic locations (i.e., 4-km grid cells). The emissions can be allocated to modeling grid cells using gridding surrogates. To process the project emissions, a project area-based spatial surrogate needs to be developed. For many project sources the emission sources (e.g., construction) are allocated to the
55 https://www.cmascenter.org/smoke/
56 https://ofmpub.epa.gov/sccwebservices/sccsearch/docs/SCC-IntroToSCCs.pdf 57 https://ofmpub.epa.gov/sccwebservices/sccsearch/
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grid cell(s) containing the project. For more geographically complex project emission source categories (e.g., mobile source emissions associated with the project), the surrogate distributions can be developed using the USEPA’s Spatial Allocation Tool,58 which combines geographical information system (GIS)- based data (shapefiles) and modeling domain definitions to generate the appropriate gridded surrogate data set. In SMOKE, the project sources are assigned specific surrogates for gridding by crossreferencing the SCCs. All on-site project emissions are distributed in the modeling grid cell(s) where the project is located. On-road mobile sources are typically spatially distributed in the site’s grid cells and surrounding grid cells based on roadway locations that can be defined using GIS shapefiles and the EPA surrogate tool. In some cases, CEQA projects have used transportation models to characterize the project’s effects on mobile sources and to define the extent of the mobile source emissions spatial distribution.
The SMOKE system is then used to process emissions for the modeling domain, for example the CCOS 4-km modeling grid shown in Figure A-1. A representative week from each month (seven days a week for each month) is typically used to represent the entire month’s emissions and obtain the correct dayof-week emissions. Holidays are typically modeled separately as if they were a Sunday. SMOKE should be applied to perform the following tasks:
1. Chemical Speciation: Emissions estimates of criteria pollutant precursors should be speciated for the SAPRC07 photochemical and AERO6 aerosol chemical mechanisms employed by the PGM in SMOKE processing. The speciation profiles compatible with the SAPRC07-AERO6 mechanism for PM2.5 should be used to be consistent with the emissions used in the BAAQMD’s modeling system used in this analysis. SMOKE outputs PGM emission inputs in the CMAQ PGM format that can be converted into CAMx-ready formats using CMAQ2CAMx conversion program and species mapping if CAMx is the PGM used.
2. Temporal Allocation: SMOKE resolves the annual emissions to a monthly, day-of-week and hour-ofday timescale for PGM modeling. These allocations are determined from the particular source category specified by the SCC. Monthly, weekly, and diurnal profiles are cross‐referenced to SCC in the SMOKE processing to provide the appropriate temporal resolution.
3. Spatial Allocation: The project emissions estimates should be spatially resolved to the grid cells for modeling using spatial surrogates, as described above.
Standard quality assurance/quality control (QA/QC) of the emissions developed and SMOKE processing need to be conducted during all aspects of the SMOKE emissions processing. These steps should follow the approach recommended in the USEPA modeling guidance (USEPA, 2007). SMOKE includes quality assurance and reporting features to keep track of the adjustments at each processing stage and to ensure that data integrity is not compromised. The SMOKE log files should be carefully reviewed for error messages and ensured that appropriate source profiles were used. All error records reported during processing should be reviewed and any discrepancies resolved. This is important to ensure that source categories are correctly characterized. A key step in the QA/QC of the SMOKE emissions modeling is to compare SMOKE input and output emissions and to ensure that no emissions are dropped or added in the processing. As part of the documentation, summary tables of emissions should be generated to compare input inventory totals against model-ready output totals and to confirm
58 https://www.cmascenter.org/sa-tools/documentation/4.2/html/srgtool/SurrogateToolUserGuide_4_2.pdf 861
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consistency. Spatial plots should be generated to visually verify correct spatial allocation of the emissions.
The final step in the emissions processing is to merge the project’s gridded emissions with other regional components through the gridded merge program (MRGUAM) for CAMx. The daily emissions for CAMx should be merged in the time format required by CAMx. If CAMx v7.0 or newer is used, then the individual “pre-merged” emission inputs can be provided separately in the CAMx inputs, so the final merge is not necessary. CMAQ can also take separate emission file inputs, so it also does not need a final merged step.
A.3.3 PGM Modeling of Project Emissions
PGM modeling is conducted for a future-year emissions scenario to isolate the contributions of the project’s emissions to ozone and PM concentrations. As noted above, either the CAMx or CMAQ PGM models would be acceptable and the project’s contributions could be obtained in either model using either the Brute Force or Source Apportionment approaches, but this guidance recommends that the Source Apportionment approach be used to isolate the project’s ozone and PM2.5 contributions, as the Brute Force method can be susceptible to model noise.
With CAMx, the Anthropogenic Precursor Culpability Assessment (APCA) ozone and PSAT PM source apportionment tools should be used. For CMAQ, the ISAM ozone and PM source apportionment tool should be used. The project emissions need to be separately tagged for tracking by the CAMx APCA/PSAT or CMAQ ISAM source apportionment tools. The CAMx user’s guide59 describes how to tag sources for treatment by and how to invoke the APCA/PSAT source apportionment tools. A CAMx APCA/PSAT source apportionment simulation will generate two hourly average concentration files: (1) the standard model output of hourly gridded total surface layer concentrations; and (2) an hourly output file of surface layer gridded concentrations for each APCA/PSAT source group. The standard output file with elimination (subtraction) of the APCA/PSAT concentration contributions from the project source group is defined as the Base Case, and the standard output that includes the contributions of the project’s emissions is defined as the Project Case. Documentation on the CMAQ ISAM source apportionment tool is available on the CMAQ website.60
The PGM Base Case and Project Case gridded hourly concentration outputs are processed to generate annual (365 days) gridded files for the following two species and averaging times:
Daily average total PM2.5 concentrations; and
Maximum daily average 8-hour (MDA8) ozone concentrations.
It is recommended that spatial maps of the incremental PM2.5 and ozone concentrations due to project’s emissions be examined and reported as part of the QA/QC of the PGM modeling. At a minimum, the annual average and highest 24-hour average PM2.5 and highest MDA8 ozone incremental concentrations due to the project’s emissions be reported. Figures B-3, B-4 and B-5 show examples of these types of displays for source 20 from the hypothetical minor source screening modeling discussed in Appendix B.
The PGM gridded daily PM2.5 and MDA8 ozone concentrations are used as inputs to BenMAP to obtain the incremental health effects due to the emissions of the project, as described in the next section.
59 http://www.camx.com/files/camxusersguide_v6-50.pdf
60 https://www.airqualitymodeling.org/index.php/CMAQv5.0.2_Integrated_Source_Apportionment 862
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A.4 ESTIMATION OF HEALTH EFFECT IMPACTS
The potential health effects of ozone and PM2.5 concentrations due to the project’s emissions should be estimated using the Environmental Benefits Mapping and Analysis Program (BenMAP), Community Edition v1.5 (March 2019).61 BenMAP, originally developed by the USEPA, is a powerful and flexible tool that helps users estimate human health effects and economic benefits resulting from changes in air quality. BenMAP outputs include PM- and ozone-related health endpoints such as premature mortality, hospital admissions, and emergency room visits. BenMAP uses the following simplified formula to express changes in ambient air pollution to certain health endpoints (AAI, 2018)62:
Health Effect = Air Quality Change Health Effect Estimate Exposed Population Background Health Incidence
Air Quality Change: The difference between the starting air pollution concentration level (the Base Case) and the air pollution concentration level after some change, such as a new source (e.g., emissions from a proposed CEQA project in the Project Case). Health Effect Estimate: An estimate of the percentage change in an adverse health effect due to a one-unit change in ambient air pollution. Effect estimates, also referred to as concentration-response (C-R) functions, are obtained from epidemiological studies. Exposed Population: The number of people affected by the air quality change. The government census office is a good source for this information. As noted below, we recommend the use of data from PopGrid, which is an add-on program to BenMAP that allocates the block-level U.S. Census population to a user-defined grid.63 As new census data is collected, USEPA updates the BenMAP tool.
Background Health Incidence: An estimate of the average number of people that die (or suffer from some adverse health effect) in a given population over a given period of time.
For example, the health incidence rate might be the probability that a person will die in a given year. Health incidence rates and other health data are typically collected by the government as well as by the World Health Organization. The background incidence rates used here are obtained from BenMAP. Age-, cause-, and county-specific mortality rates are calculated by BenMAP using data from the Centers for Disease Control (CDC) WONDER database64. Hospitalization rates and emergency room visits are calculated using data from the Healthcare Cost and Utilization Project (HCUP). The relationship between shortterm PM exposure and heart attacks have been determined using epidemiological studies.
A.4.1 Application of BenMAP
The PGM output data are processed to generate aggregated daily average PM2.5 and MDA8 ozone concentrations appropriate for various health endpoints as described above. The PGM concentrations for a Base Case (i.e., without the project emissions) and a Project Case (i.e., the Base Case plus the contributions of the project emissions) are used as inputs to BenMAP, which internally takes the
61 http://www.epa.gov/air/benmap/
62 The common function used for calculating health effects is the following log-linear function: Health Effect = Background Health Incidence x [1 – exponential (Health Effect Estimate * Air Quality Change)] x Exposed Population
63 https://www.epa.gov/benmap/benmap-community-edition
64 http://wonder.cdc.gov
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difference between the Base and Project Cases in order to obtain the incremental ozone and PM contributions due to the project. The PGM simulation results from the full year (January to December) are used to estimate the health effects of PM2.5 and ozone. BenMAP translates increases in the pollutant concentrations due to the project emissions to changes in the incidence rate for each health effect using a C-R function derived from previously published epidemiological studies. BenMAP provides multiple C-R functions based on different epidemiological studies for a given health endpoint.
We recommend using the USEPA default C-R functions that are used in national rulemaking when evaluating health effects. We also recommend using more refined population data that uses population data from PopGrid, which allocates the census population to each modeled 4x4 kilometer (km) grid cell (e.g., Figure A-1).
The population used for both the quantified health effects and the calculation of background health incidence presented here is usually calculated for a future year that has maximum project emissions.65 Although there are a large number of potential health endpoints that could be included in the analysis, we recommend using the key health endpoints that have been the focus of recent USEPA risk assessments (e.g., USEPA, 2010; USEPA, 2014). For example, the USEPA notes that health endpoints were selected based on consideration of at-risk populations (e.g. people with asthma), endpoints that have public health significance, and endpoints for which information is sufficient to support a quantitative concentration-response relationship (USEPA, 2014).
The PM2.5 health endpoints and associated C-R functions that we recommend for use in this BenMAP analysis are presented in Table A-2. Each C-R function is based on a certain age range for the given health endpoint depending on the underlying epidemiological study on which it is based.
The increases in the BenMAP-estimated health effect incidences and the background and percent of background health incidence due to the project emissions should be presented for each health endpoint in Table A-2. These values reflect the total health effects across the modeling domain (e.g., CCOS domain in Figure A-1 or reduced 4-km Sacramento domain in Figure B-1) or across the FiveAir-District Region. Reporting the percent increase in each of the health effect endpoints across the Five-Air-District Region or other geographic region puts into context the incremental increase in health effects due to the project emissions.
65 For background incidence rates, BenMAP projects likely mortality rates for future years, but for other health effects, incidence rates are based on population changes only and may not reflect rates for future years. 864
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For both the PM2.5 and ozone health effects calculated, each of the pollutants may be a confounder of the other. Thus, while the C-R functions are derived from studies that evaluated the effects for each pollutant individually, both air pollutants could contribute to the health effect outcomes evaluated, and thus the overall impacts may be overstated.
Another uncertainty highlighted by the USEPA (2012) that applies to potential health effects from both PM2.5 and ozone is the assumption of a log-linear response between exposure and health effects, without consideration for a threshold below which effects may not be measurable. The issue of a threshold for PM2.5 and ozone is highly debatable and can have significant implications for health effects analyses as it requires consideration of current air pollution levels and calculating effects only for areas that exceed threshold levels. Without consideration of a threshold, any incremental contribution to existing ambient air pollution levels, whether below or above the applicable threshold for a given criteria pollutant, is assumed to adversely affect health. Although the USEPA traditionally does not consider thresholds in its cost-benefit analyses, the NAAQS itself is a health-based threshold level that the USEPA has developed, based on evaluating the most current evidence of health effects.
As noted above, the health effects estimation using this method presumes that effects seen at large concentration differences can be linearly scaled down to (i.e., correspond to) small increases in concentration, with no consideration of potential thresholds below which health effects may not occur.
This methodology of linearly scaling health effects is broadly accepted for use in regulatory evaluations and is considered as being health protective (USEPA, 2010), but potentially overstates the potential health effects. In summary, health effects presented using the procedures in this guidance are conservatively estimated, and the actual effects may be zero.
A.4.2 Documentation of Results
The results of the health effects assessment should be documented in a brief technical report in plain English that clearly describes how the project’s emissions of air pollutants are correlated to health effects. The report should include sufficient detail to enable those who are skilled in the art (and who did not participate in its preparation) to understand the procedures that were used and to consider meaningfully the issues the proposed project raises.
The technical reports should include the following sections: Introduction, Technical Approach, and Results. The technical report should include details on how the PGM was selected and the source of the database used in its operation. It should include details on the emissions used in the PGM as well as a rationale that includes information on the geographical distribution of emissions within the modeling domain. This is particularly important if offsite traffic comprises a significant part of the emissions. The technical report should include details on the speciation of emissions and how the individual emissions were allocated among various source groups. The technical report should include details on how the PGM was operated as well as the important technical choices made and include QA/QC procedures and displays (e.g., spatial maps like in Figures B-3, B-4 and B-5). While not recommended unless there is ample evidence to justify it, the user may have some rationale for using C-R responses that are different from the defaults found in BenMAP. Should those be used, the technical report should contain the justification for departure from default C-R responses, as well as details on the C-R responses that were used. The technical report should also contain information on uncertainties in the various steps of the process.
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The report should put the health effects into context by comparing them to background rates in the population at large, expressing them as a percent of the background health effects. This comparison can be done using data from the BenMAP model. For perspective, previous evaluations of large developments have shown that the estimated increases in those health effect incidences are fairly minor compared to the background values.
The report should also note that the health effects estimation using BenMAP presumes that effects seen at large concentration differences can be linearly scaled down to small increases in concentration. Accordingly, the report should note that the health effects are conservatively estimated.
Section 7 of the guidance provides additional health context and resources that should be included in the results documentation.
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A.5 REFERENCES
Abt Associates Inc. (AAI). “BenMAP Environmental Benefits Mapping and Analysis Program – Community Edition User’s Manual.” Prepared for US Environmental Protection Agency, 2018, Cambridge, MA.
Coats, C.J. Jr. High-performance Algorithms in the Sparse Matrix Operator Kernel Emissions (SMOKE) Modeling System. Proc. Ninth AMS Joint Conference of Air & Waste Management Association/American Meteorological Society, Atlanta, GA, 1996, pp. 584- 588.
Coats, C.J. Jr., and M.R. Houyoux. Fast Emissions Modeling with the Sparse Matrix Operator Kernel Emissions (SMOKE) Modeling System. Air & Waste Management Association Conference, New Orleans, LA, 1996.
Kelly, Frank J., and J.C. Fussell. “Particulate Toxicity Ranking Report: Report Number 2/07.” Environmental Research Group, Kings College, London, 2007.
Lippmann, M., and L.C. Chen. “Health Effects of Concentrated Ambient Air Particulate Matter (CAPs) and Its Components.” Critical Reviews in Toxicology, vol. 39, no. 10, 2009, pp. 865-913.
Rohr, Annette C., and Ronald E. Wyzga. “Attributing Health Effects to Individual Particulate Matter Constituents.” Atmospheric Environment, vol. 62, Dec 2012, pp. 130-152, doi:10.1016/j.atmosenv.07.036.
U.S. Environmental Protection Agency (USEPA). “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze.” Office of Air Quality Planning and Standards, EPA-454/B-07-002, 2007, Research Triangle Park, NC.
U.S. Environmental Protection Agency (USEPA). “Integrated Science Assessment (ISA) for Particulate Matter: Final Report.” EPA/600/R-08/139F, Dec, 2009, Washington, DC, https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=216546 U.S. Environmental Protection Agency (USEPA). “Quantitative Health Risk Assessment for Particulate Matter.” Office of Air Quality Planning and Standards, EPA-452/R-10-005m, June 2010, www3.epa.gov/ttn/naaqs/standards/pm/data/PM_RA_FINAL_June_2010.pdf U.S. Environmental Protection Agency (USEPA). “Regulatory Impact Analysis for the Final Revisions to the National Ambient Air Quality Standards for Particulate Matter.” EPA452/R-12-005, 2012, Washington, DC, www3.epa.gov/ttn/ecas/docs/ria/naaqspm_ria_final_2012-12.pdf.
U.S. Environmental Protection Agency (USEPA). “Health Risk and Exposure Assessment for Ozone Final Report.” Risk and Benefits Group, Health and Environmental Impacts Division, Office of Air Quality Planning and Standards, EPA-452/R-14-004a, 2014. 869
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APPENDIX B
SCREENING LEVEL HEATH EFFECTS ANALYSIS
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B.1 INTRODUCTION
A screening analysis using PGM and BenMAP modeling of hypothetical projects within the Sac Metro Air District and neighboring areas was conducted. The screening level health effects analysis was conducted by first identifying locations where potential new projects may be located within the FiveAir-District Region that also includes the entire Sacramento Federal Nonattainment Area (SFNA):
Sacramento, Placer, El Dorado, Feather River and Yolo Solano air districts.
Using the methods described in Appendix A, emissions equal to the CEQA thresholds of significance were assumed to occur in 41 representative project locations. The PGM modeling results were then put into BenMAP in order to estimate the health effects that may result from development in each of these locations. The resulting screening level health effects for each of the 41 hypothetical project locations were generated. In addition, Ramboll developed an interactive Minor Project Health Effects Screening Tool in an Excel spreadsheet that allows the user to input a specific proposed project location and the resultant health effects for a project at the maximum TOS emission rates are interpolated from the 41 representative project locations to the point of the proposed project location.
This tool is further described in this section.
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B.2 HYPOTHETICAL PROJECT DEFINITIONS
B.2.1 Hypothetical Project Locations
The potential project locations for the screening-level health effects analysis were determined by overlaying the 2050 Sacramento Area Council of Governments estimate of potential project development in the Five-Air-District Region on the 4-km gridded domain area, as shown in the blue shaded area in Figure B-1. A sufficient number of hypothetical project locations were selected in order to represent the different meteorological and transport conditions across the region, but not so many that the computational burden of the air quality model simulation became prohibitive. Based on this information, 41 hypothetical project source locations were chosen, shown in Figure B-1. Each hypothetical project site represents a source of precursor emissions for PM2.5 and ozone.
Figure B-1 Potential CEQA project locations (blue shading) in the 5-Air-District Region along with locations of the 41 hypothetical project sources used in the screening modeling.
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B.3 PGM SCREENING MODELING
B.3.1 Reduced 4-km Modeling Domain
The 2012 BAAQMD modeling platform for the CCOS domain shown in Figure A-1 was adapted for the health effects screening analysis. The CCOS domain covers large portions of northern California and western Nevada where we would expect there to be no significant health effects due to a CEQA project within the Five-Air-District Region. Thus, we reduced the size of the CCOS domain to the red domain embedded in the CCOS domain shown in Figure B-2. The boundary conditions for the smaller 4-km domain in Figure B-2 were based on a CAMx simulation of the larger CCOS domain (Figure A-1). As QA for the new 2012 reduced Sacramento modeling domain database, we performed a CAMx base case simulation using the reduced domain and found that it produced essentially the same ozone and PM results as the CAMx full CCOS domain simulation.
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Figure B-2. Sac Metro Air District CAMx 4-km domain (red box) used in the screening analysis embedded in the 4-km CCOS domain (black box) covering northern California.
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B.3.2 Emissions used in the Screening Analysis
The 2035 anthropogenic emissions for the reduced 4-km modeling domain (Figure B-2) were obtained by projecting the BAAQMD 2012 anthropogenic emissions to 2035 using the ARB CEPAM66 emission projections.
As discussed in Section B.1.2, each of the 41 hypothetical projects were assumed to have NOX, ROG and PM2.5 emissions of 82 lbs./day with SO2 and CO emissions of 0.98 lbs./day and 262 lbs./day, respectively. The hypothetical project ROG (also known as VOC) emissions were speciated into the VOC species used in the SAPRC07 chemical mechanism that is used by CAMx with speciation profiles based on the typical mix of sources types in a CEQA project as described in Appendix D. The emissions were assumed to be released near the surface (i.e., in layer 1), which is also typical for CEQA projects in the region.
B.3.3 PGM Modeling
The CAMx PGM was used to simulate the incremental ozone and PM concentrations due to emissions from each of the 41 hypothetical project sources. Emissions from each of the 41 hypothetical sources were separately tagged for treatment by the CAMx APCA/PSAT ozone/PM source apportionment tools.
The CAMx standard and source apportionment output was processed to generate Base Case concentrations that consisted of CAMx standard model output minus the contributions of all 41 hypothetical sources. Then, the contributions of each individual hypothetical project were separately added to the Base Case for each Project Case. The PGM estimated gridded daily 24-hour average PM2.5 and MDA8 ozone concentrations for the Base Case and Project Case that were then used in the health effects modeling.
Figures B-3, B-4 and B-5 display the incremental PM2.5 and ozone concentrations due to hypothetical source number 20, which is located near the intersection of I-80 and I-5 (see Figure B-1). For annual average PM2.5 concentrations, the maximum contribution due to hypothetical source 20 is 0.44 µg/m3 and occurs close to the source location (Figure B-3). The highest daily PM2.5 (Figure B-4) and MDA8 ozone (Figure B-5) concentrations due to hypothetical source 20 are, respectively, 1.69 µg/m3 and
0.38 ppb, and also occur close to the location of source 20.
66 https://www.arb.ca.gov/app/emsinv/fcemssumcat/fcemssumcat2016.php 876
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Figure B-4. Map of the incremental maximum 24-hour average PM2.5 concentrations (µg/m3) due to emissions from hypothetical source 20.
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Figure B-5. Map of the incremental highest MDA8 ozone concentrations (ppb) due to emissions from hypothetical source 20.
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B.4 HEALTH EFFECTS MODELING
B.4.1 BenMAP Simulator
EPA’s BenMAP air pollution health effects tool is a Windows-based program with the flexibility to use several alternative Concentration-Response (C-R) functions. The application of BenMAP for the 41 hypothetical projects would be quite time-consuming. Thus, a Python-based BenMAP simulator was developed that could efficiently estimate the health effect impacts of the 41 hypothetical projects using the CAMx source apportionment modeling results. The specific default C-R functions identified in Appendix A (Tables A-2 and A-3) were implemented in the Python-based BenMAP simulator.
The Python-based BenMAP simulator was run for the 41 hypothetical project locations shown in Figure B-1 using the CAMx Base Case and Project Case modeling results. We then ran BenMAP using the CAMx 2035 annual source apportionment modeling results for hypothetical project number 20, which, because it is in the City of Sacramento, represents one of the hypothetical sources with relatively higher health effects than others. Tables B-2 and B-3 display the resultant PM2.5 and ozone health effects from running the EPA BenMAP and Python-based BenMAP simulator on the CAMx source apportionment modeling results for hypothetical source number 20. To three significant digits, the results are identical. Because the Python-based simulator uses higher precision than BenMAP, the results are not identical when looking out to more significant decimal places. For example, to four significant digits the premature mortality due to PM across the entire modeling domain for hypothetical project number 20 is 2.289 per year using BenMAP and 2.287 per year using the Pythonbased BenMAP simulator. These less-than-0.1% differences do not change any aspects of the health effects assessment. Summaries of the potential health effects across the modeling, like those presented in Tables B-2 and B-3 for hypothetical source 20, are provided for each one of the 41 hypothetical sources in Appendix F. Note that in addition to the project’s incremental health effects, the percent increase of the health effects over the background health effects should also be presented.
For example, for hypothetical source 20, the increase of 2.06 premature mortalities per year within the Five-Air-District Region that is due to increased PM concentrations from the project’s emissions represents a 0.005% increase over the background value of the Five-Air-District Region; thus, this is a very small increase.
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Figure B-6. Hypothetical project PM mortality health effects superimposed on population density with SFNA boundary outline.
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B.4.3 Minor Project Health Effects Screening Tool
A simple screening health effects spreadsheet tool was developed by interpolating the health effects from the 41 hypothetical source locations to each 4-km grid in the Sac Metro Air District and neighboring air districts. The spatial interpolation was performed using python’s SciPy implementation of the radial basis function interpolation.67 Multiple basis functions were tested, but the linear function was selected because it provides higher values for the interpolated health effects and therefore was considered more conservative for the purposes of the screening tool implementation. The user can input the latitude/longitude location of a proposed project and the spreadsheet will generate a table of health effects corresponding to the threshold of significance emissions rate at the proposed project location.
67 https://docs.scipy.org/doc/scipy/reference/generated/scipy.interpolate.Rbf.html 886
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APPENDIX C
STRATEGIC AREA PROJECT HEALTH EFFECTS
ANALYSIS
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Figure C-1. Locations of six projects I-VI used in the strategic area screening modeling, along with the 41 hypothetical Projects used in the minor project analysis and boundary of the Five-Air-District Region (red) with the SFNA shaded grey.
The project screening modeling was run at each of the six locations at two levels of emissions, corresponding to two times (2x) and 8 times (8x) the threshold of significance level, which is 82 lbs./day for NOX, ROG, PM2.5 and PM10 (see Table 1). The six projects also included CO and SO2 emissions using the same approach as used for the 41 hypothetical minor project analysis (see Appendices B and D). The ROG and PM emissions for the six projects were also speciated following the same approach as the hypothetical minor project modeling (see Appendix D). Table C-2 displays the project emissions for the two levels of emissions used. Two levels of emissions were modeled in 889
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• PM2.5(NOx) = Nitrate (NO3) + Ammonium (NH4) + Sulfate (SO4) • PM2.5(ROG) = 0.0
• PM2.5(PM) = Elemental Carbon (EC) + Primary Organic Aerosol (POA) + Other Fine Particulate (FPRM) + Fine Crustal Particulate (FCRS)
Note that the PM2.5 associated with SO4 is assigned to the project NOX precursor emissions because the project SO2 emissions were derived as a ratio to the NOX emissions (see Appendix D). Particulate sulfate is expected to be a small component, as the SO2 emissions in the six projects are only 1.2% of the NOX emissions (see Table C-2).
The BenMAP results of the six strategic area project screening modeling at two emissions levels are provided in Appendix G.
C.1.2 Strategic Area Project Health Effects Screening Tool The strategic area project screening modeling health effects were used to develop a Strategic Area Projects Health Effects Screening Tool, which is a spreadsheet that can be used to estimate health effects for potential strategic area projects with emissions below the 8xTOS level. The Strategic Area Project Health Effects Screening Tool has two interactive components that need to be defined by the user:
1. Project Location: Select one of the six strategic area project locations (see Table C-1 and Figure C-1) from a dropdown menu, and the spreadsheet uses the strategic area project health effects screening modeling results for that location.
2. Project Emissions: Input the NOX, ROG and PM2.5 emissions in pounds/day for the potential strategic area project, and the tool linearly interpolates the ozone and PM health effects for the selected project location from the 2xTOS and 8xTOS CAMx/BenMAP modeling.
Note that if the user inputs NOX, ROG or PM emissions below the 2xTOS emissions rate, then the health effects for the 2xTOS emissions level are used to provide a conservative estimate of health effects. The assumption of linear interpolation of the ozone and PM health effects between the 2xTOS and 8xTOS CAMx/BenMAP modeling results could potentially introduce uncertainties in the results, if the linear assumption is invalid. The health effects concentration-response (C-R) functions used in BenMAP are most frequently expressed in log-linear relationships in concentration, so linear interpolation of the health effects between the 2xTOS and 8xTOS concentrations could introduce uncertainties. However, these are very low levels of concentrations, so the log-linear relationship of the C-R functions can be accurately represented by a linear relationship. The chemistry of ozone and secondary PM2.5 formation is non-linear, so the use of linear interpolation of the NOX and ROG health effects could introduce uncertainties in the results. Again, since we are analyzing very small changes in ozone and secondary PM2.5 concentrations, the non-linear terms are negligible and small changes in the non-linear models can be correctly analyzed as linear, consistent with Taylor’s theorem.68 Furthermore, because we are interpolating between the 2xTOS and 8xTOS modeling scenarios (rather than extrapolating from one scenario), any non-linear effects in either the C-R functions or chemistry are bounded.
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A CEQA project within the Sac Metro Air District or the 5-Air-District Region with 656 lbs/day or less of NOx, ROG and PM2.5 emissions may use the Strategic Area Health Effects Screening Tool to provide an estimate of the health effects of the project. If the proposed project is within close proximity (e.g., within one 4-km grid cell) of one of the six strategic area source locations the proponent can discuss using the health effects from the Tool at that location with concurrence from the Sac Metro Air District or other applicable air district in the 5-Air-District Region. 892
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C.1.3 Using the Strategic Area Projects Health Effects Screening Tool Outside Strategic Areas
The strategic area projects health effects screening tool can be used outside of the strategic areas to provide a conservative (i.e., upper bound) estimate of health effects if the South Sacramento strategic area source is used as a surrogate location. The South Sacramento strategic area source was selected as a surrogate location because it has the highest population density within the 5-Air-District Region.
Population density is the strongest driver of health effects. Consequently, the highest population density would be expected to have the largest population exposed and, as a result, the greatest number of health effects. The South Sacramento location is in the 4-km grid cell with the highest population and is also the grid cell centroid of a 3x3 array of 4-km grid cells with the highest population in the 5-Air-District Region; the 9-cells include the 4-km grid cells with the 1st, 2nd 3rd 4th 7 th and 9th highest population grid cells in the 5-Air-District Region (see Figure C-2).
Because of the high population density, the South Sacramento location has the highest total health effects of the locations analyzed, out of the six strategic area source locations. For example, for a source with 656 lbs/day of NOx, ROG and PM2.5, the premature mortality due to PM2.5 across the 5-AirDistrict Region for the South Sacramento location is 26 deaths compared to 11, 17, 20, 2 and 2 deaths for the West Roseville, Rancho Cordova, Downtown Sacramento, Woodland and Vacaville strategic area locations, respectively.
Alternatively, the project proponent can conduct explicit photochemical grid and health effects modeling following the procedures in section 6 and Appendix A of this guidance. 893
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APPENDIX D
CHARACTERIZATION OF SO2 AND CO
EMISSIONS AND ROG CHEMICAL SPECIATION
FOR TYPICAL PROJECT EMISSIONS
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D.1 ESTIMATE OF HYPOTHETICAL PROJECT SO2 AND CO
EMISSIONS
To characterize the approximate SO2 and CO emissions that may result from emissions at the significance thresholds for PM2.5, NOX and VOCs, we analyzed six historical projects from Sacramento County. The projects were chosen as they represented a diversity of sources and were not dependent on a specific type of source.
To conduct the analysis, the Sac Metro Air District provided criteria pollutant emissions inventory information for the six projects. The information was for the years spanning 2013-2018, and therefore reflected practices and emissions profiles that are current. The emissions inventories were created using CalEEMod to be consistent with past and future projects occurring within the Sac Metro Air District.
Descriptions of these projects can be found in Table D-1. Descriptions are from the project description section of the development’s CEQA document, which does not always match the CalEEMod land use inputs, also shown in Table D-1.
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The ratio of CO to NOX for mobile sources varied from a high of 6.07 to a low of 1.81, with many clustered between 2.5 and 3.2. We chose a ratio of 3.2 to be conservative and decided on a default value of 3.2 x 82, or 262 lbs. CO/day. The ratio of SO2 to NOX varies for mobile sources from a high of
0.0185 to a low of 0.0059, with most between 0.072 to 0.0090. We chose the second highest value of
0.012 to be conservative and decided on a default value of 0.012 times 82, or 0.98 lbs. SO2/day.
D.2 CHEMICAL SPECIATION FOR HYPOTHETICAL PROJECT
ROG AND PM EMISSIONS
In addition to specifying the hypothetical project primary PM2.5, PM10 and ROG emissions, the user needs to chemically speciate these emissions into the individual components used in the CAMx chemical mechanism. Primary PM2.5 and PM10 are chemically inert, and the concentration-response functions selected for use in the BenMAP health effects model use only the total PM2.5 mass concentrations and don’t differentiate health effects across different PM species (e.g., elemental carbon, organic aerosol and other fine particulate). Thus, it doesn’t matter how the hypothetical project PM emissions are speciated, and for this reason, all the hypothetical project PM2.5 emissions were speciated as the CAMx fine particulate matter (FPRM) species.
The speciation of the hypothetical project ROG emissions, however, is important, as the different ROG individual species in the SAPRC07 chemical mechanism used in the BAAQMD CAMx 2012 modeling database have different chemical reactivities and ozone formation potentials. The hypothetical project ROG emissions are speciated into the SAPRC07 chemical mechanism using the SMOKE emissions model that allocates the ROG emissions to SAPRC07 species using chemical speciation profiles from EPA’s SPECIATE database69. SMOKE cross-references SPECIATE chemical speciation profiles to source emission types using SCCs. To determine the types of sources with ROG emissions for a typical CEQA project in the Sac Metro Air District planning area, we examined the percent contribution of ROG emissions for the same six projects that are discussed above and shown in Table D-3a. Ignoring the Bilby Ridge Project, which is an outlier among the six projects, we found that the following three source categories contributed 95-99% of the ROG emissions, so we assumed the following ROG contributions for these three source categories, with the SCCs in parenthesis and the ranges across the five projects in brackets:
Consumer Products (2460000000) = 65% [53% - 70%]
Mobile Sources (220110111B) = 25% [14% - 33%]
Architectural Coatings (241001000) = 10% [7% - 11%]
The SMOKE emissions model was used with the SCC codes listed above to chemically speciate the hypothetical project ROG emissions into the SAPRC07 chemical species.
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APPENDIX E
SAMPLE SCC CODES TYPICALLY USED IN CEQA
PROJECTS
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APPENDIX F
BENMAP HEALTH EFFECTS RESULTS FOR THE 41
HYPOTHETICAL SOURCES USED IN THE MINOR PROJECTS
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APPENDIX G
BENMAP HEALTH EFFECTS RESULTS FOR SIX STRATEGIC AREA
PROJECTS
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www.vtpi.org
[email protected]
250-508-5150
1250 Rudlin Street
Victoria, BC, V8V 3R7, CANADA
Todd Litman, Executive Director
Specializing in
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Jennifer Clark ([email protected])
Director, City of Fresno Planning and Development Department 2600 Fresno Street
Fresno, CA 93721
21 August 2023
Re: Southeast Development Area Plan Impact Analysis
Dear Ms. Clark,
I am writing as a planning consultant who specializes in transportation impact evaluation concerning the Southeast Development Area Plan transportation impact analysis as described in the 14 July 2023 SEDA’s Draft Program Environmental Impact Report and related documents.
This plan’s predictions of vehicle miles traveled (VMT) are significantly flawed because it assumes an unrealistic internal trip capture rate that would reduce per capita VMT from 46 to 5 daily VMT, which is much lower than typical new developments.
The analysis assumes that the SEDA would be developed based on Smart Growth principles to create complete, multimodal neighborhoods where residents walk, bike and use public transit for most trips. These assumptions are unrealistic and not supported by the current proposal. For example, although the plan includes some mitigation strategies (p. 3.17-31-32), these are modest and unlikely to reduce vehicle travel 90% – significant VMT reductions require financial incentives such as cost-recovery pricing applied to all parking, plus grade-separated transit services – and complete communities typically take decades to fully develop and achieve their potential vehicle travel reductions.
New analysis tools and guidance documents are available that could provide more accurate predictions and guidance for achieving VMT reduction targets:
Caltrans (2020), Vehicle Miles Traveled-Focused Transportation Impact Study Guide, California Department of Transportation (https://dot.ca.gov); at https://bit.ly/3DDSm5H.
Also see SB 743 Implementation Resources
(https://dot.ca.gov/programs/sustainability/sb-743/sb743-resources).
CAPCOA (2021), Handbook for Analyzing Greenhouse Gas Emission Reductions, California Air Pollution Control Association (www.caleemod.com); at www.caleemod.com/handbook/index.html.
F&P (2022), Providing VMT: Getting Beyond LOS, Fehr & Peers (www.fehrandpeers.com); at www.fehrandpeers.com/vmt-impacts.
ITE SB 743 Task Force (2021), ITE Guide to SB 743: Transition from Level of Service to Vehicle Miles Traveled, Northern California ITE (www.norcalite.org); at https://bit.ly/3CU1DIe.
Todd Litman (2018), Land Use Impacts on Transportation, Victoria Transport Policy Institute (www.vtpi.org); at www.vtpi.org/landtravel.pdf. 952
Victoria Transport Policy Institute
Deborah Salon (2014), Quantifying the Effect of Local Government Actions on VMT, Institute of Transportation Studies (https://its.ucdavis.edu); at ww3.arb.ca.gov/research/apr/past/09-343.pdf.
Robert J. Schneider, Susan L. Handy and Kevan Shafizadeh (2014), “Trip Generation for Smart Growth Projects,” ACCESS 45, pp. 10-15; at http://tinyurl.com/oye8aqj. Also see the Smart Growth Trip-Generation Adjustment Tool (https://tinyurl.com/mtuhz4j8).
Most experts recommend that North American communities start growing upward instead of outward. Fresno is currently not very dense and most existing housing stock is moderate-density single-family. To implement Smart Growth and maximize sustainability and transportation efficiency, Fresno should support infill development within the existing urban boundaries rather than expand to new areas.
In my opinion, the Plan’s current analysis significantly underestimates vehicle traffic congestion, crash, emission and resulting air quality impacts. Until more accurate travel modeling can be completed, and air quality impacts adjusted, this PEIR fails to predict the project’s significant social and environmental impacts, and so fails to provide the information that policy makers, practitioners and the general public need to make informed decisions.
Thank you for your consideration.
Best wishes,
Todd Litman
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Adopted June 25, 2020
CEQA GUIDELINES FOR
VEHICLE MILES TRAVELED THRESHOLDS
Submitted to:
City of Fresno
2600 Fresno Street
Fresno, California 93721
Prepared by:
LSA Associates, Inc.
20 Executive Park, Suite 200
Irvine, California 92614
(949) 553‐0666
Project No. CFO1802
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i
EXECUTIVE SUMMARY
Senate Bill (SB) 743, signed in 2013, changes the way transportation studies are conducted in California Environmental Quality Act (CEQA) documents. Vehicle miles traveled (VMT) replaces motorist delay and level of service (LOS) as the metric for impact determination. As a result of the final rulemaking surrounding SB 743 and the implementation deadline of July 1, 2020, the City of Fresno is adopting the new VMT thresholds and guidelines to address the shift from delay‐based LOS CEQA traffic analyses to VMT CEQA traffic analyses.
This document discusses in further detail the following:
Definition of region for VMT analysis
Standardized screening methods for VMT threshold compliance data Recommendations for appropriate VMT significance thresholds for development projects, transportation projects, and plans
Feasible mitigation strategies applicable for development projects, transportation projects, and plans
For purposes of this analysis, the Fresno Council of Governments (COG) Activity‐Based Model (ABM)1 was used to develop screening maps. The Fresno COG ABM base year was updated from 2014 to 2019 based on consultation with Fresno COG staff. The appropriate use of the ABM for VMT calculations has been further elaborated in subsequent chapters of this document.
This document will serve as a detailed guideline for preparing VMT analysis consistent with SB 743 requirements for development projects, transportation projects, and plans. Project applicants will be required to follow the guidance provided in this document for preparation of CEQA VMT analysis.
1 Fresno COG ABM Update Report: https://www.fresnocog.org/wp‐content/uploads/2017/06/Fresno‐COG‐ ABM‐Report.pdf
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TABLE OF CONTENTS
EXECUTIVE SUMMARY............................................................................................................................. i TABLE OF CONTENTS ............................................................................................................................. iii FIGURES AND TABLES ............................................................................................................................. v LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................vii
1.0 INTRODUCTION................................................................................................... 1
2.0 DEFINITION OF REGION: VEHICLE MILES TRAVELED CONTEXT .............................. 5
3.0 PROJECT SCREENING ........................................................................................... 9
3.1 DEVELOPMENT PROJECTS.................................................................................................... 9
3.2 TRANSPORTATION PROJECTS............................................................................................. 19
4.0 SIGNIFICANCE THRESHOLDS FOR DEVELOPMENT PROJECTS............................... 23
4.1 GENERAL TRANSPORTATION ANALYSIS PROCEDURE ........................................................ 25
4.2 PROJECT SCREENING.......................................................................................................... 26
4.3 PROJECT VEHICLE MILES TRAVELED ANALYSIS .................................................................. 26
4.3.1 Small Project Vehicle Miles Traveled Analysis.....................................................................26
4.3.2 Large Project Vehicle Miles Traveled Analysis.....................................................................26
4.4 MITIGATION MEASURES .................................................................................................... 27
5.0 SIGNIFICANCE THRESHOLDS FOR TRANSPORTATION PROJECTS ......................... 31
6.0 SIGNIFICANCE THRESHOLDS FOR LAND USE PLANS ............................................ 37
7.0 MITIGATION STRATEGIES .................................................................................. 39
7.1 DEFINITION OF MITIGATION.............................................................................................. 39
7.2 MITIGATION MEASURES AND PROJECT ALTERNATIVES .................................................... 41
7.2.1 Development Projects and Community/General Plans.......................................................41
7.2.2 Transportation Projects.......................................................................................................42
7.3 FUNDING MECHANISMS .................................................................................................... 43
APPENDICES
A: VEHICLE MILES TRAVELED MITIGATION MEASURES FOR DEVELOPMENT PROJECTS (CAPCOA) B: VEHICLE MILES TRAVELED MITIGATION MEASURES FOR DEVELOPMENT PROJECTS (CARB
PAPERS)
C: VEHICLE MILES TRAVELED MITIGATION MEASURES FOR COMMUNITY PLANS AND GENERAL PLANS
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FIGURES AND TABLES
FIGURES
Figure 1: VMT Per Capita Compared to Population in California........................................................... 2 Figure 2: 2017 GHG Emissions in California by Scoping Plan Sector and Sub‐Sector Category ............. 3 Figure 3: Percentage of Total Tours Having Origins/Destinations within the City of Fresno and Terminating within the City of Fresno, within Fresno County, or outside the County .......... 6 Figure 4: High‐Quality Transit Area Within Fresno County .................................................................. 11 Figure 5: Average VMT per Capita (Population) and VMT per Employee for City of Fresno and Fresno County ............................................................................................................................. 14 Figure 6: City of Fresno ‐ Existing VMT per Capita ............................................................................... 15 Figure 7: City of Fresno ‐ Existing VMT per Employee ......................................................................... 17 Figure 8: SB 375 Regional Plan Climate Targets for the 18 California MPOs....................................... 24 Figure 9: VMT Analysis Process for Development Projects.................................................................. 29 Figure 10: Induced Travel – VMT Attributable to Project .................................................................... 32 Figure 11: Caltrans Induced Travel Calculator...................................................................................... 33 Figure 12: Conceptual Methodology for Calculating Induced Demand for Transportation Projects........................................................................................................................................ 36 Figure 13: VMT per Capita and VMT per Employee Comparisons – City of Fresno General Plan versus Fresno County under Existing Conditions................................................................ 38 TABLE
Table A: Representative VMT and GHG Emissions from CalEEMod..................................................... 13 962
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LIST OF ABBREVIATIONS AND ACRONYMS
ABM Activity‐Based Model
ADT average daily trips
CalEEMod California Emissions Estimator Model
Caltrans California Department of Transportation
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CEQA California Environmental Quality Act
City City of Fresno
CO2e carbon dioxide equivalent
COG Council of Governments
EIR Environmental Impact Report
EO Executive Order
FAR floor‐to‐area ratio
GHG greenhouse gas
GPA General Plan Amendment
GWP global warming potential
HOT high‐occupancy toll
HOV high‐occupancy vehicle
ITE Institute of Transportation Engineers
LOS level of service
mi mile
MT metric ton
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MPO Metropolitan Planning Organizations
OPR Governor’s Office of Planning and Research
PRC Public Resources Code
RTP Regional Transportation Plan
RTPA Regional Transportation Planning Agency
SB Senate Bill
SCS Sustainable Communities Strategy
sf Square foot/feet
SOC Statement of Overriding Considerations
TA Technical Advisory
TDM transportation demand management
VMT vehicle miles traveled
ZC Zone Change
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1 1.0 INTRODUCTION
Senate Bill (SB) 743, signed in 2013, changes the way transportation studies are conducted in California Environmental Quality Act (CEQA) documents. Vehicle miles traveled (VMT) replaces motorist delay and level of service (LOS) as the metric for impact determination. For development projects, VMT is simply the product of the daily trips generated by a new development and the distance those trips travel to their destinations. For capital projects, impacts are identified as the new VMT attributable to the added capital project, both from the installation of the facility and the induced growth—a new term in the CEQA lexicon—generated as a result of induced land use.
In January 2019, the Natural Resources Agency and the Governor’s Office of Planning and Research (OPR) codified SB 743 into the Public Resources Code (PRC) and the State CEQA Guidelines. State CEQA Guidelines Section 15064.3 subdivision (b) states:
1. Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one‐half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.
2. Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.
3. Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles traveled for the particular project being considered, a lead agency may analyze the project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate.
4. Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.
The OPR provides a Technical Advisory (TA) as a guidance document to establish thresholds for this new VMT metric. The laws and rules governing the CEQA process are contained in the CEQA statute 966
2 (PRC Section 21000 and following), the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 and following), published court decisions interpreting CEQA, and locally adopted CEQA procedures. The TA is intended as a reference document; it does not have the weight of law. Yet, deviating from the TA is best undertaken with substantial evidence to support the agency action.
The State of California is committed to reducing greenhouse gas (GHG) emissions and achieving long‐term climate change goals. To achieve these climate change goals, California needs to reduce VMT. As illustrated in Figure 1, over the last 40 years, with increase in statewide population, the overall VMT has also increased. As illustrated in Figure 2, transportation is the single largest sector contributing to the State’s GHG emissions. More than 40 percent of the GHG emissions come from the transportation sector, primarily passenger cars and light‐duty trucks. Reducing the number of vehicle trips and reducing the length of trips are expected to result in reduced VMT and reduced GHG emissions. The new State CEQA Guidelines and the establishment of VMT thresholds for CEQA analyses is linked to GHG reduction strategies and overall statewide climate change goals.
Source: https://ca50million.ca.gov/transportation/
Figure 1: VMT Per Capita Compared to Population in California 967
3 Source: California Greenhouse Gas Emissions for 2000 to 2017 Trends of Emissions and Other Indicators (California Air Resources Board Report) Figure 2: 2017 GHG Emissions in California by Scoping Plan Sector and Sub‐Sector Category This document establishes the City of Fresno’s (City) threshold of significance for CEQA transportation studies and provides substantial evidence as appropriate. It is divided into chapters, including:
Chapter 2 – Definition of Region: Here the document describes what the comparative is for analysis purposes. Each project will be compared to an existing regional average. The geographical area that defines the region is defined and described. Chapter 3 – Project Screening: OPR acknowledges that certain projects are either low VMT generators, or by virtue of their location would have a less than significant impact. The City should use these screening criteria and should offer substantial evidence for other circumstances that would lead to a less than significant impact. Chapter 4 – Significance Thresholds for Development Projects: In this chapter, the threshold that would define a significant CEQA impact is identified. This threshold is linked to a specific travel mode and a set of trip purposes. The actual VMT metric (either an efficiency rate or total VMT) is described.
Chapter 5 – Significant Thresholds for Transportation Projects: This chapter describes the method to evaluate significant CEQA impacts associated with transportation projects. Many non‐vehicular capital projects are presumed to have a less than significant impact. Capacity enhancing projects may have significant impacts and may be subject to a detailed analysis that will include measuring induced travel.
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4 Chapter 6 – Significance Thresholds for Land Use Plans: This chapter provides guidance and substantial evidence to support the City’s treatment of land use plans and their CEQA transportation analysis.
Chapter 7 – Mitigation Strategies: Potential mitigation strategies are indicated in this chapter. It is noted that this discussion is not intended as a full list of measures the City sanctions as feasible. As in previous CEQA practice, it is generally the practitioner who identifies mitigation measures to offset the specific project related impacts identified in individual environmental document. The discussion here is intended as a reference and guide for possible strategy for applicants who may wish to investigate to offset their specific project‐related significant impacts.
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5 2.0 DEFINITION OF REGION: VEHICLE MILES TRAVELED CONTEXT The question of context is the definition of the scope of the VMT analysis. The common term for this in previous delay‐based LOS analyses is project study area. In the delay‐based LOS analyses, a project study area is generally determined based on the incremental increase in traffic from the project and its potential to create a significant LOS impact. This generally includes intersections and roadway segments where the project would add a prescribed number of peak‐hour trips. Many times, lead agencies stop study area boundaries at their jurisdictional borders.
Unlike delay‐based LOS analyses, VMT is a regional effect not defined by roadway, intersection, or pathway. The OPR acknowledges this in its TA (page 6), which states, Lead agencies should not truncate any VMT analysis because of jurisdictional or other boundaries….
Furthermore, the recommendations for thresholds for the primary land use types (residential and office) are based on a comparison to a regional average. Region is not defined further in the TA.
Instead, the OPR offers the following suggestions:
1. In cases where the region is substantially larger than the geography over which most workers would be expected to live, it might be appropriate to refer to a smaller geography, such as county, that includes the area over which nearly all workers would be expected to live (page 16).
2. For residential projects in unincorporated county areas, the local agency can compare a residential project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate population weighted VMT per capita of all cities in the region (page 15).
LSA surveyed other large urbanized areas around the State to identify what region has been established for VMT thresholds. In most cases, the county boundary has been identified as the region selected for VMT analysis. Mobility can be studied using a trip‐based approach or a tour‐ based approach. The OPR TA states that “where available, tour‐based assessment is ideal because it captures travel behavior more comprehensively.” Since Fresno COG’s model is an ABM, a tour‐based approach has been followed. LSA used the Fresno COG ABM to examine the tours into and out of Fresno. As such, consistent with the OPR TA, only tours having origins or destinations or both within the City were considered. External pass‐through trips were not considered. As illustrated in Figure 3, out of the total tours, about 80 percent originate and are destined within the city. Another 16 percent of tours originate or are destined within other jurisdictions in Fresno County. The remaining 4 percent home‐based tours originate and are destined outside Fresno County.
Because the majority of the tours are contained within Fresno County, the county may be used to define the region. For residential projects, the TA states that “Existing VMT per capita may be measured as regional VMT per capita or as city VMT per capita. Proposed development referencing a threshold based on city VMT per capita (rather than regional VMT per capita) should not 970
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7 development proposed near the city’s northern boundary may include VMT from as far away as Madera, Tulare, or Kings Counties or other communities in the San Joaquin Valley. In that case, it would be the responsibility of the applicant and their traffic study preparer to include the project VMT regardless of geographical limit to the satisfaction of City staff. This project‐related VMT profile would be compared against the County of Fresno regional average. 972
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9 3.0 PROJECT SCREENING
The TA does acknowledge that certain activities and projects may result in a reduction in VMT and GHG emissions and therefore a less‐than‐significant impact to transportation and circulation. A variety of projects may be screened out of a complicated VMT analysis due to the presumption described in the TA regarding the occurrence of less‐than‐significant impacts.
3.1 DEVELOPMENT PROJECTS
The TA acknowledges that conditions may exist that would presume that a development project has a less than significant impact. These may be size, location, proximity to transit, or trip‐making potential. For example, development projects that have one or more of the following attributes may be presumed to create a less than significant impact:
The project is within 0.5 mile (mi) of a Transit Priority Area or a High‐Quality Transit Area unless the project is inconsistent with the Regional Transportation Plan (RTP)/SCS, has a floor area ratio (FAR) less than 0.75, provides an excessive amount of parking, or reduces the number of affordable residential units. In accordance with SB 743, “Transit priority areas” are defined as “an area within one‐half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program. A Major Transit Stop means: “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service of 15 minutes or less during the morning and afternoon peak commute periods.” A High‐Quality Transit Area or Corridor is a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.
Figure 4 depicts transit priority areas within Fresno including high‐quality transit areas (within 0.5 mile of a major transit stop) served by the Fresno Area Express (FAX) with service intervals of 15 minutes or less. Projects proposed in these areas may be presumed to have a less‐than‐significant transportation impact unless the project is inconsistent with the RTP/SCS, has an FAR less than
0.75, provides an excessive amount of parking, or reduces the number of affordable residential units.
The project involves local‐serving retail space of less than 50,000 square feet (sf). The project has a high level of affordable housing units. The afforable‐housing requirement to meet the screening criteria is to be determined by City staff. The project generates a low volume of daily traffic.
The TA recommends a volume of 110 average daily trips (ADT). This recommendation is not based on any analysis of GHG reduction but, rather, on a CEQA categorical exemption. This exemption criterion states that for existing facilities, including additions to existing structures of up to 10,000 sf, the project is exempted from CEQA as long as the project is in an area where public infrastructure is available to allow for maximum planned development and the project is not located in an environmentally sensible area (State CEQA Guidelines Section 15301, 974
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13 subdivision (e)(2). As stated in the OPR TA, for projects that have a linear increase in trip generation with respect to the building footprint, the daily trip generation is anticipated to be between 110 and 124 trips per 10,000 sf. Therefore, based on this assumption, the OPR recommends 110 ADT as the screening threshold. However, the California Emissions Estimator Model (CalEEMod) was used to characterize the effect of changes in project‐related ADT to the resulting GHG emissions. This model was selected because it is provided by the CARB to be used statewide for developing project‐level GHG emissions. CalEEMod was used with the built‐in default trip lengths and types to show the vehicular GHG emissions from incremental amounts of ADT. Table A shows the resulting annual VMT and GHG emissions from the incremental ADT.
Table A: Representative VMT and GHG Emissions from CalEEMod Average Daily Trips (ADT) Annual Vehicle Miles
Traveled (VMT)
GHG Emissions (Metric Tons
CO2e per year)
200 683,430 258
300 1,021,812 386
400 1,386,416 514
500 1.703,020 643
600 2,043,623 771
Source: CalEEMod version 2016.3.2.
CalEEMod = California Emissions Estimator Model
CO2e = carbon dioxide equivalent
GHG = Greenhouse Gas
A common GHG emissions threshold is 3,000 metric tons (MT) of carbon dioxide equivalent2 (CO2e) per year.3 The vehicle emissions are typically more than 50 percent of the total project GHG emissions. Thus, a project with 500 ADT would generally have total project emissions that could be less than 1,300 MT CO2e/year (i.e., 50 percent or 643 MT CO2e/year coming from vehicle emissions and the other 50 percent coming from other project activities). As this level of GHG emissions would be less than 3,000 MT CO2e/year, the emissions of GHG from a project up to 500 ADT would typically be less than significant. Therefore, the City will allow screening out projects if the project would generate less than 500 ADT. The development of institutional/government and public service uses that support community health, safety and welfare may also be screened from subsequent CEQA VMT analysis. These facilities (e.g. police stations, fire stations, community centers, refuse stations) are already part of the community and, as a public service, the VMT is accounted for in the existing regional average. Many of these facilities generate fewer than 500 ADT and/or use vehicles other than passenger‐cars or light duty trucks. These other vehicle fleets are subject to regulation outside
2 Carbon dioxide equivalent (CO2e) is a concept developed to provide one metric that includes the effects of numerous GHGs. The global warming potential (GWP) of each GHG characterizes the ability of each GHG to trap heat in the atmosphere relative to another GHG. The GWPs of all GHGs are combined to derive the CO2e. 3
Source: http://www.aqmd.gov/home/rules‐compliance/ceqa/air‐quality‐analysis‐handbook/ghg‐ significance‐thresholds
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19 Based on the City’s traffic study guidelines or existing CEQA guidelines, other conditions may apply to screen out projects. Consistency with other plans to reduce GHG emissions may also reflect substantial evidence supporting a screening out. Or, the City may adopt the TA recommendations in total.
The Fresno COG VMT Screening Tool4 can be used to determine whether a development project may be screened from a detailed VMT analysis. It should be noted that if a project constitutes a General Plan Amendment (GPA) or a Zone Change (ZC), none of the above screening criteria may apply. The City will be required to evaluate such projects on a case‐by‐case basis to determine whether a VMT analysis would be required.
3.2 TRANSPORTATION PROJECTS
The primary attribute to consider with transportation projects is the potential to increase vehicle travel, sometimes referred to as “induced travel.” Based on the OPR TA, while the City has discretion to continue to use a delay‐based LOS analysis for CEQA disclosure of transportation projects, changes in vehicle travel must also be quantified. The City of Fresno will solely use VMT analysis for CEQA disclosure of transportation projects, but will also require a LOS analysis for design, traffic operations, and safety purposes. The TA lists a series of projects that would not likely lead to a substantial or measurable increase in vehicle travel and which would, therefore, not require an induced travel analysis. These include the following:
Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the condition of existing transportation assets (e.g., highways; roadways; bridges; culverts; Transportation Management System field elements such as cameras, message signs, detection, or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do not add additional motor vehicle capacity
Roadside safety devices or hardware installation such median barriers and guardrails Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used as automobile vehicle travel lanes
Addition of an auxiliary lane of less than 1 mi in length designed to improve roadway safety Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left‐, right‐, and U‐turn pockets, two‐way left‐turn lanes, or emergency breakdown lanes that are not utilized as through lanes
Addition of roadway capacity on local or collector streets, provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit Conversion of existing general‐purpose lanes (including ramps) to managed lanes or transit lanes, or changing lane management in a manner that would not substantially increase vehicle travel
4 Fresno COG VMT Screening Tool Link: https://www.fresnocog.org/project/sb743‐regional‐guidelines‐ development/
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20 Addition of a new lane that is permanently restricted to use only by transit vehicles Reduction in the number of through lanes
Grade separation to separate vehicles from rail, transit, pedestrians, or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., high‐occupancy vehicles [HOVs], high‐ occupancy toll [HOT] lane traffic, or trucks) from general vehicles Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority features
Installation of traffic metering systems, detection systems, cameras, changeable message signs, and other electronics designed to optimize vehicle, bicycle, or pedestrian flow Timing of signals to optimize vehicle, bicycle, or pedestrian flow Installation of roundabouts or traffic circles
Installation or reconfiguration of traffic calming devices Adoption of or increase in tolls
Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase Initiation of a new transit service
Conversion of streets from one‐way to two‐way operation with no net increase in the number of traffic lanes
Removal or relocation of off‐street or on‐street parking spaces Adoption or modification of on‐street parking or loading restrictions (including meters, time limits, accessible spaces, and preferential/reserved parking permit programs) Addition of traffic wayfinding signage
Rehabilitation and maintenance projects that do not add motor vehicle capacity Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within existing public rights‐of‐way
Addition of Class I bike paths, trails, multi‐use paths, or other off‐road facilities that serve nonmotorized travel
Installation of publicly available alternative fuel/charging infrastructure Addition of passing lanes, truck climbing lanes, or truck brake‐check lanes in rural areas that do not increase overall vehicle capacity along the corridor 985
21 Additionally, transit and active transportation projects generally reduce VMT and, therefore, may be presumed to cause a less than significant impact on transportation. This presumption may apply to all passenger rail projects, bus and bus rapid‐transit projects, and bicycle and pedestrian infrastructure projects. The City may use this CEQA presumption of less than significant impact to aid in the prioritization of capital projects, as the CEQA process for any of these project types would be more streamlined than other capacity‐enhancing capital projects. 986
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23 4.0 SIGNIFICANCE THRESHOLDS FOR DEVELOPMENT PROJECTS The TA states that SB 743 and all CEQA VMT transportation analyses refer to automobiles. Here, the term automobile refers to on‐road passenger vehicles, specifically cars and light duty trucks (page. 4). Heavy‐duty trucks can be addressed in other CEQA sections (air quality, greenhouse gas, noise, and health risk assessment analysis) and are subject to regulation in a separate collection of rules under CARB jurisdiction. This approach was amplified by Chris Ganson, Senior Advisor for Transportation at OPR, in a recent presentation at the Fresno COG (October 23, 2019) and by Ellen Greenberg, the California Department of Transportation (Caltrans) Deputy Director for Sustainability, at the San Joaquin Valley Regional Planning Agencies’ Directors’ Committee meeting (January 9, 2020).
The OPR has identified the subject of the thresholds as the primary trips in the home‐based typology: specifically, home‐based work tours. This includes residential uses, office uses, and retail uses. The home‐based work tour type is the primary tourmaking during the peak hours of commuter traffic in the morning and evening periods.
The impact of transportation has shifted from congestion to climate change, and the purpose of the CEQA analysis is to disclose and ultimately reduce GHG emissions by reducing the number and length of automobile trips. As part of the SB 375 land use/transportation integration process and the GHG goal setting, the State and Regional Transportation Planning Agencies (RTPA) have agreed to reduce GHG through integrated land use and transportation planning by a statewide average of approximately 15 percent by 2035. Figure 8 illustrates the SB 375 regional GHG emission reduction targets for all the 18 Metropolitan Planning Organizations (MPOs) in California that was established by the CARB in 2018. Furthermore, in its 2017 Scoping Plan‐Identified VMT Reductions and Relationship to State Climate Goals, the CARB recommends total VMT per capita rates approximately 15 percent below existing conditions.
The TA therefore recommends:
A proposed (residential) project exceeding a level of 15 percent below existing regional average VMT per capita may indicate a significant transportation impact.
A similar threshold would apply to office projects (15 percent below existing regional average VMT per employee).
VMT generated by retail projects would indicate a significant impact for any net increase in total VMT.
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25 Therefore, the City has established a threshold for land use developments, specifically residential and office, of 13 percent or more than the existing regional VMT per capita as indicative of a significant environmental impact.
No other discrete land use types are identified for threshold development. Mixed‐use projects should be evaluated for each component of the project independently, or the City may use the predominant land use type for the analysis. The City will make a determination of the predominant land use type on a case‐by‐case basis based on the project description. Credit for internal trip capture should be made. Internal trip capture may be calculated using the latest edition of the Institute of Transportation Engineers (ITE) Trip Generation Handbook (for smaller projects), the Fresno COG ABM (for larger projects), or other applicable sources approved by the City. The TA suggests that City may, but is not required to, develop thresholds for any other use.
One approach is to review the City’s General Plan and/or the Fresno COG RTP/SCS and identify whether the implementation of the plan would result in a reduction of VMT and GHGs. If it does, the City may conclude the implementation of the plan, including all the other land use types will achieve the regional climate change goals. Therefore, consistency with the plan and no net change in VMT per employee for the other land use types is a rational threshold. However, for projects seeking a GPA, a project exceeding a level of 13 percent than the existing County average VMT per employee would indicate a significant transportation impact.
This approach would require disclosure of substantial evidence, including the General Plan findings, and other supporting traffic and air quality forecasting support. Additionally, if the City wishes to establish some other threshold less stringent than the 13 percent recommended for residential and office projects, a body of substantial evidence would be necessary.
Figure 9 demonstrates the potential development entitlement process to comply with the State CEQA Guidelines related to VMT and transportation impacts. It provides the path from application filing through determination of impacts. It is presented as the standard process; each development application is considered unique and may create alternative or modified steps through the process.
Each step that diverges from this standard process should be accompanied with substantial evidence demonstrating compliance with other climate change and GHG emission reduction laws and regulations.
4.1 GENERAL TRANSPORTATION ANALYSIS PROCEDURE
This process will be refined as the new VMT analysis process is implemented. At the outset of the project development process, the applicant should seek a meeting with City staff to discuss the project description, the transportation study content, and the analysis methodology. Key elements to address include a description of the project in sufficient detail to generate trips and identify the potential catchment area (i.e., trip lengths if no modeling is undertaken), estimate project VMT, discuss project design features that may reduce the VMT from the project development, and discuss the project location and associated existing regional VMT percentages. As a result of the meeting, the applicant or their consultant shall prepare a transportation analysis scope of work for review and approval by the City.
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26 Projects that will influence Caltrans facilities may be subject to the Caltrans Local Development‐ Intergovernmental Review program. As part of the program, Caltrans may review the VMT analysis methodology, findings, and mitigation measures, with an eye toward statewide consistency.
4.2 PROJECT SCREENING
Once a development application is filed and the meeting is held, project screening is conducted as the initial step. If the project meets any one of the screening criteria, the project may be presumed to create a less than significant impact. No further VMT analysis is necessary. The CEQA document should enumerate the screening criteria and how the project meets or exceeds that threshold. If project screening does not apply, a VMT analysis may be required. The extent of this analysis may be a simple algebraic demonstration or a more sophisticated traffic modeling exercise. This distinction is addressed later.
4.3 PROJECT VEHICLE MILES TRAVELED ANALYSIS
The first step is to identify the project land use type and the appropriate metric to use, i.e., VMT per capita, VMT per employee, or total VMT. The metric should be VMT per capita for residential projects, VMT per employee for office projects, and total VMT for retail projects. For mixed‐use projects, after taking credit for internal trip capture, the project VMT can be estimated based on each component of the project independently, or the City may use the predominant land use type for the analysis. For all other uses, the metric used should be VMT per employee.
4.3.1 Small Project Vehicle Miles Traveled Analysis
Project VMT may be calculated using the Fresno COG VMT Calculation Tool6 for residential projects having less than or equal to 500 dwelling units or office projects having less than or equal to 375 employees. For all other projects, trip lengths can be determined using the Fresno COG ABM.
4.3.2 Large Project Vehicle Miles Traveled Analysis
For large or multi‐use projects, use of the Fresno COG ABM is required. For purposes of City review, all projects, other than residential uses with less than or equal to 500 dwelling units or offices with less than or equal to 375 employees, should use the Fresno COG ABM. At this level of trip generation, the probability of trip fulfilment expands to an area greater than the immediate project location and may include a greater regional attraction. The Fresno COG ABM can more accurately define the select links used and the total VMT generated by the project.
Next, the project generated VMT per capita/VMT per employee/total VMT is compared to the appropriate significance threshold. This is either equal to or more than 13 percent of the existing regional average per capita or employment for specific uses, or no net increase in total VMT for retail or other uses that are consistent with the General Plan. For those projects that require a GPA, a threshold of 13 percent or more than existing regional average is appropriate as the project has yet to be evaluated as part of the City’s ultimate development vision.
6 Fresno COG VMT Calculation Tool Link: https://www.fresnocog.org/project/sb743‐regional‐guidelines‐ development/
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27 If the project VMT metric is less than the significance threshold, the project is presumed to create a less than significant impact. No further VMT analysis is required. If the project is greater than the significance threshold, mitigation measures are required.
4.4 MITIGATION MEASURES
The applicant is required, per CEQA, to identify feasible offsets to completely mitigate the impact created by the project. These can come from the mitigation strategies provided by the City (Appendices A and B), or selected based on the applicant and their CEQA team experience. The City must approve and accept the ultimate mitigation ascribed to the project and the related VMT percentage reduction.
If the mitigation measures mitigate the project impact to less than the jurisdictional threshold, the project is presumed to have an impact mitigated to a less than significant level. No further VMT analysis is required. If the project’s VMT impact cannot be mitigated, the City may 1) request the project be redesigned, relocated or realigned to reduce the VMT impact, or 2) require the preparation of an Environmental Impact Report (EIR) with a Statement of Overriding Considerations (SOC) for the transportation impacts associated with the project. All feasible mitigation measures must be assigned to and carried out by the project even if an EIR/SOC is prepared. 992
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31 5.0 SIGNIFICANCE THRESHOLDS FOR TRANSPORTATION PROJECTS The 2020 CEQA Guidelines include Section 15064.3.b.(2) to address transportation projects. It reads:
For roadway capacity projects, agencies have the discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements.
The City may continue to use delay and LOS for transportation projects for design and traffic operation purposes as long as impacts related to “other applicable requirements” are disclosed. This has generally been interpreted as VMT impacts and other State climate change objectives. These other applicable requirements may be found in other parts of an environmental document (i.e., air quality, GHG), or may be provided in greater detail in the transportation section.
For projects on the State highway system, the Caltrans will use and will require sponsoring agencies to use VMT as the CEQA metric, and Caltrans will evaluate the VMT “attributable to the project” (Caltrans Draft VMT‐Focused Transportation Impact Study Guide 2020). Caltrans may review environmental documents for capacity‐enhancing projects for the City’s analysis of VMT change.
The assessment of a transportation project’s VMT should disclose the VMT without the project and the difference in VMT with the project. Any growth in VMT attributable to the transportation project would result in a significant impact.
The primary difference in these two scenarios to OPR is related to induced growth. Current traffic models have limited abilities to forecast induced growth, as their land use or socioeconomic databases are fixed to a horizon date. OPR refers to a limited set of reports that would indicate elasticities.
The most recent major study (Duranton & Turner 2011, p. 24), estimates an elasticity of 1.0, meaning that every 1 percent change in lane miles results in a 1 percent increase in VMT.
The TA presents one method to identify the induced growth, as follows.
To estimate VMT impacts from roadway expansion projects:
1. Determine the total lane‐miles over an area that fully captures travel behavior changes resulting from the project (generally the region, but for projects affecting interregional travel look at all affected regions).
2. Determine the percentage change in total lane miles that will result from the project.
3. Determine the total existing VMT over that same area. 996
32 4. Multiply the percentage increase in lane miles by the existing VMT, and then multiply that by the elasticity from the induced travel literature:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project]
Figure 10 provides a representative illustration of induced VMT attributable to a project.
Source: Presentation: Caltrans Transportation Analysis under CEQA or TAC: Significance Determinations for Induced Travel Analysis (SHCC Pre‐Release Session 2 Jeremy Ketchum, Division of Environmental Analysis, Caltrans; March 2, 2020)
Figure 10: Induced Travel – VMT Attributable to Project Caltrans has identified a computerized tool that estimates VMT generation from transportation projects. It was developed at University of California, Davis and is based on elasticities and the relationship of lane mile additions and growth in VMT. It uses Federal Highways Administration definitions of facility type and ascribes VMT increases to each facility. Output includes increases on million miles of VMT per year. Caltrans is investigating its use for all its VMT analyses of capital projects on the State Highway System. Figure 11 provides an illustration of that tool. 997
33 Source: https://blinktag.com/induced‐travel‐calculator/index.html Figure 11: Caltrans Induced Travel Calculator
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34 The TA provides other options to identify induced growth‐ and project‐related VMT. These include:
1. Employ an expert panel. An expert panel could assess changes to land use development that would likely result from the project. This assessment could then be analyzed by the travel demand model to assess effects on vehicle travel.
Induced vehicle travel assessed via this approach should be verified using elasticities found in the academic literature.
2. Adjust model results to align with the empirical research. If the travel demand model analysis is performed without incorporating projected land use changes resulting from the project, the assessed vehicle travel should be adjusted upward to account for those land use changes. The assessed VMT after adjustment should fall within the range found in the academic literature.
3. Employ a land use model, running it iteratively with a travel demand model. A land use model can be used to estimate the land use effects of a roadway capacity increase, and the traffic patterns that result from the land use change can then be fed back into the travel demand model. The land use model and travel demand model can be iterated to produce an accurate result.
The TA provides a final warning:
Whenever employing a travel demand model to assess induced vehicle travel, any limitation or known lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example, model insensitivity to one of the components of induced VMT described above) should be disclosed and characterized, and a description should be provided on how it could influence the analysis results. A discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis, such as greenhouse gas emissions, air quality, energy, and noise.
Fresno COG ran a few test scenarios of roadway widening projects using the Fresno COG ABM.
These results were compared with the results from the Caltrans Induced Travel Calculator. The comparison demonstrated substantial difference in results. As such, it was identified that the ABM was more sensitive to project location, roadway type, surrounding land uses, and localized trip characteristics. Therefore, for most transportation projects that are not under Caltrans jurisdiction, it is recommended that the Fresno COG ABM be utilized to calculate project related induced VMT.
As illustrated in Figure 10, VMT attributable to the project must be calculated by evaluating no project and with project conditions under the horizon year scenario using Fresno COG ABM. Net increase in induced VMT will result in a significant impact for the proposed project.
The concept of induced demand and the methodology to be followed is explained in greater detail in the Technical Appendices. Figure 12 illustrates a conceptual overview of the methodology to be followed to calculate induced demand. As illustrated in Figure 12, the effect of induced VMT will be required to be evaluated from both a land use and a travel demand modeling perspective. Fresno COG staff and the Resource Systems Group, Inc. (RSG) have prepared a detailed process that needs 999
35 to be conducted for this analysis. The methodology looks at induced VMT from new land uses generated by transportation capacity improvement projects by providing iterative and incremental feedback between the Fresno COG ABM and the land‐use growth allocation model such that changes in the traffic network are incorporated into land‐use allocation, and vice‐versa. The methodology then looks at the impact of increased roadway capacity on increased traffic volumes and congestion using DaySim, the activity‐based model component of the Fresno COG ABM. The methodology concludes that roadway capacity increase may lead to increased volumes, which results in increased congestion, which could be close to or the same as the congestion before the roadway capacity increase, albeit with more vehicles and an overall increase in utility. 1000
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37 6.0 SIGNIFICANCE THRESHOLDS FOR LAND USE PLANS
The OPR guidance has provided guidance on the treatment of CEQA traffic analyses for land use plans in the TA. The TA reiterates previous direction regarding individual land use assessments:
Analyze the VMT outcomes over the full area over which the plan may substantively affect travel patterns (the definition of region).
VMT should be counted in full rather than split between origins and destinations (the full impact of the project VMT).
The TA provides a single sentence as consideration for land use plans. It states, “A general plan, area plan, or community plan may have a significant impact on transportation if proposed new residential, office or retail land uses would in aggregate exceed the respective thresholds recommended above.” This recommendation refers to a threshold of 13 percent or more than the existing regional average for residential and office uses and no net gain for retail land uses.
To assess a land use plan, use of a traffic‐forecasting tool is recommended. Therefore, the City should use the ABM to assess VMT for land use plans. The total VMT for the plan should be identified for all tour types and all potential VMT contributors within the plan area. Model runs should be conducted for the existing base year and the horizon year with project (plan).
The SB 375 process establishes ambitious and achievable GHG reduction targets for the 18 MPOs in the State. The achievements of the targets are provided through the integration of land use planning and transportation planning, not solely through the imposition of regulation on passenger cars and light‐duty trucks. The CARB reviews the SCS and the strategies and programs that the regional agencies put in place in the SCS to achieve the GHG reduction. The CARB approved the new GHG reduction targets for all the 18 MPOs in the State in the spring of 2018. The 2018 targets are applicable to the third SCSes for the MPOs.
Other legislative mandates and State policies speak to GHG reduction targets. A sample of these include:
Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and continued reductions beyond 2020.
SB 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels by 2030.
Executive Order (EO) B‐30‐15 (2015) sets a GHG emissions reduction target of 40 percent below 1990 levels by 2030.
EO S‐3‐05 (2005) sets a GHG emissions reduction target of 80 percent below 1990 levels by 2050.
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39 7.0 MITIGATION STRATEGIES
When a lead agency identifies a significant CEQA impact according to the thresholds described above, the agency must identify feasible mitigation measures in order to avoid or substantially reduce that impact. Although previous LOS impacts could be mitigated with location‐specific LOS improvements, VMT impacts will require mitigation of regional impacts through more behavioral changes. Enforcement of mitigation measures will be still be subject to the mitigation monitoring requirements of CEQA, as well as the regular police powers of the agency. These measures can also be incorporated as a part of plans, policies, regulations, or project designs.
7.1 DEFINITION OF MITIGATION
Section 15370 of the 2020 State CEQA Guidelines defines mitigations as follows:
“Mitigation” includes:
a. Avoiding the impact altogether by not taking a certain action or parts of an action.
b. Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
c. Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.
d. Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
e. Compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.
Section 15097 of the State CEQA Guidelines states that “the public agency shall adopt a program for monitoring or reporting on the revisions which it has required in the project and the measures it has imposed to mitigate or avoid significant environmental effects.” VMT mitigations may not be physical improvements; rather, they are complex in nature and will significantly depend on changes in human behavior. Therefore, it will be important that the City develop a proper monitoring program to ensure the implementation of these mitigation measures, throughout the life of a project, in compliance with CEQA. The City must also coordinate with other responsible agencies as part of this monitoring program to determine the feasibility of the mitigations and whether they would last in perpetuity.
Historically, mitigation measures for LOS based transportation impacts have addressed either trip generation reductions or traffic‐flow‐capacity enhancements. LOS mitigation measures include adding capacity to intersections, roadways, ramps, and freeways. However, transportation demand 1004
40 management (TDM) actions, active transportation amenities, and other measures to reduce the number of trips creating an impact are also possible mitigation strategies.
LOS based mitigations are mostly physical improvements whose benefits are observable, measurable, and virtually perpetual. The addition of a left‐turn lane at an intersection will behave similarly regardless of location and will continue to perform as intended until the lane is removed or modified. A lane mile of roadway will carry a similar volume of traffic if designed consistently across most jurisdictions in California, and it will continue to do so as long as the lane exists.
The definition of VMT mitigation measures is somewhat different. Most VMT mitigations may seem feasible from a theoretical perspective, but practical implementation of these strategies as formal CEQA mitigation measures in perpetuity is yet to be tested. Several of these mitigations are contextual and behavioral in nature. Their success will depend on the size and location of the project as well as expected changes in human behavior. For example, a project providing a bike share program does not necessarily guarantee a behavioral change within the project’s population; the level of improvement may be uncertain and subject to the whim of the population affected.
LOS mitigations (such as addition of turn lanes) focus more on rectifying a physical CEQA impact (strategy “c” of State CEQA Guidelines Section 15370). On the contrary, the majority of VMT mitigations (such as commute trip‐reduction programs) will aim at reducing or eliminating an impact over time through preservation and monitoring over the life of the project (strategy “d” of State CEQA Guidelines Section 15370). Additionally, some VMT mitigations (such as those focused on land use/location‐based policies) will aim at minimizing impacts by reducing the number of trips generated by the projects (strategy “b” of State CEQA Guidelines Section 15370).
Furthermore, it may be that identified VMT impacts cannot be mitigated at the project‐specific level.
Most VMT impacts are in the context of the region of analysis. The incremental change in VMT associated with a project in the particular setting in which it may be located would suggest a greater VMT deficit than individual strategies can offset. Only a regional solution (e.g., completion of a transit system, purchase of more transit buses, or gap closure of an entire bicycle master plan system) may offer the incremental change necessary to reduce the VMT impact to a level of insignificance. Also, VMT, as a proxy for GHG emissions, may not require locational specificity. A project does not necessarily need to diminish the VMT at the project site to gain benefit in VMT and GHG reduction in the State. Offsets in an area where the benefit would be greater will have a more effective reduction in VMT and GHG and contribute to the State’s ultimate climate goals. This is the basis for the cap‐and‐trade strategies.
These issues of regional scale, partial participation, and geographic ambiguity confound the certainty of the City’s identification of VMT mitigation measures. Section 15126.4 of the State CEQA Guidelines states, “Where several measures are available to mitigate an impact, each should be discussed and the basis for selecting a particular measure should be identified. Formulation of mitigation measures shall not be deferred until some future time [emphasis added].” Certainty does not yet exist that partial participation in VMT mitigation measures is permissible. Regional VMT mitigation is considered the most effective method for large‐scale VMT reduction, yet the cost and implementation barriers are greater in most cases than one project can undertake. The only 1005
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44 As previously stated, VMT impacts are more regional in nature. Hence, there might be requirements for mitigations outside the control of the City, and without consent from the agency controlling the mitigations, the impacts might remain significant and unavoidable. Additionally, identification of regional improvements where projects can contribute their fair share to mitigate impacts might prove to be difficult. Therefore, LSA recommends that the City work collaboratively within its regions to ultimately establish fee programs, mitigation banks, and exchanges as the most efficient way to establish a regional mitigation pathway where the projects can contribute. Procedural flow charts for VMT banks, exchanges, and impact fees are illustrated at the end of this chapter.
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45 Source: VMT Mitigation Through Banks and Exchanges: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
Procedural Flow Chart – VMT Bank
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46 Source: VMT Mitigation Through Banks and Exchanges: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
Procedural Flow Chart – VMT Exchange
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47 Source: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
Procedural Flow Chart – VMT Impact Fee
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APPENDIX A
VEHICLE MILES TRAVELED MITIGATION MEASURES FOR
DEVELOPMENT PROJECTS (CAPCOA)
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# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes 1 Provide a Bus Rapid Transit System (Addition of a New Route) 0.02% – 3.20% 0.33% VMT reduction per 100 miles Y Y Y N N Y Notes: CAPCOA TST‐1 (Applicable in urban and suburban context; negligible in rural context;appropriate for specific or general plans). This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service.' 2 Provide a Bus Rapid Transit System (Substitution of an Existing Bus Route with a BRT Route) 0.02% – 3.20% 0.20% VMT reduction per 100 miles Y Y Y N N Y Notes: CAPCOA TST‐1 (Applicable in urban and suburban context; negligible in rural context;appropriate for specific or general plans). This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service.' 3 Subsidize vanpool 0.30% ‐ 13.40% commute VMT 0.60% Y Y N Y N Y Notes: Similar to CAPCOA TRT‐11 (Provide Employer‐Sponsored Vanpool/Shuttle: applicable in urban, suburban, and rural context; appropriate for office, industrial, and mixed‐use projects). The measure is included under the Technical Advisory Measure 'Provide incentives or subsidies that increase the use of modes other than single‐occupancy vehicle.'; City of San Jose [Applicable for employment uses only]
4 Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride‐matching or shuttle services
0.30% ‐ 13.40% commute VMT reduction (for CAPCOATRT‐11: Provide Employer‐Sponsored Vanpool/Shuttle);7.20% ‐ 15.80% school VMT reduction (for CAPCOA TRT‐10: Implement a School Pool Program)
0.60% (for vanpool); x% (for carpool) Y Y Y Y Y Y
Notes: Similar to CAPCOA TRT‐11 (Provide employer‐sponsored vanpool/shuttle) ‐ the measure is applicable for urban, suburban, and rural context, and is appropriate for office, industrial, and mixed‐use projects; Similar measure is CAPCOA TRT‐10 (Implement a School Pool Program: Applicable for urban, suburban, and rural context and appropriate for residential and mixed‐use projects); City of San Jose [School carpool program ‐ residential uses only)]; City of LA [School carpool program ‐ level of implementation (low, medium, high); Employer sponsored vanpool or shuttle (Degree of implementation (low, medium, high), employees eligible (%), employer size (small, medium, large)] 5 Expand transit network 0.10% – 8.20% 0.07% VMT reduction per 100 miles (for addition of a new transit line) YYYYYY Notes: CAPCOA TST‐3; Measure applicable in urban and suburban context, maybe applicable in rural context but no literature documentation available, appropriate for specific or general plans. This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service'; City of San Jose [Increase transit accessibility to improvelast‐mile transit connections; Improve network connectivity/design to make destinations and low‐carbon travel modes accessible; both applicable for both residential and employmentuses]; City of LA [Existing transit mode share (as a percent of total daily trips) (%), Lines withinproject site improved (<50%, >=50%)] 6 Incorporate bike lane street design (on‐site)
1% increase in share of workers commuting by
bicycle (for each additional mile of bike lanesper square mile) (Bicycle Commuting and Facilities in Major U.S. Cities: If You Build Them, Commuters Will Use Them – Another Look by Dill and Carr (2003)); 0.075%
increase in bicycle commuting with each mile of bikeway per 100,000 residents (If You Build Them, CommutersWill Use Them; Cross‐Sectional Analysis of Commuters and Bicycle Facilities by Nelson and Allen (1997))
0.30% VMT reduction per 100 miles
(for addition of new bike lane) Y YYYYY
Notes: CAPCOA SDT‐5 [Grouped strategy, benefits of Bike Lane Street Design are small and should be grouped with the LUT‐9 (Improve Design of Development) strategy to strengthen street network characteristics and enhance multi‐modal environments], the measure is applicable in urban and suburban contexts and is appropriate for residential, retail, office,industrial, and mixed‐use projects. This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service'; City of San Jose [Expand the reach of bike access with investment in infrastructure: applicable for both residential and employment uses]; City of LA [Provide bicycle facility along site (Yes/No)] 7 Improve or increase access to transit
CAPCOA TST‐2: Not quantified alone, grouped strategy
with TST‐3 'Expand transit network' and TST‐4 'Increase transit service frequency/speed'; CAPCOA LUT‐5: 0.50% ‐ 24.60%
N/A Y Y Y Y Y Y
Notes: CAPCOA TST‐2: Implement Transit Access Improvements (applicable in urban and suburban context, and appropriate for residential, retail, office, mixed use, and industrial projects); CAPCOA LUT‐5: Increase Transit Accessibility [May be grouped with CAPCOA measures LUT‐3 (mixed use development), SDT‐2 (traffic calmed streets with goodconnectivity), and PPT‐1 through PPT‐7 (parking management strategies); measures are applicable in urban and suburban contexts; appropriate in rural context if development site is adjacent to a commuter rail station with convenient rail service to a major employment center; appropriate for residential, retail, office, industrial, and mixed‐use projects]; City ofSan Jose [Increase transit accessibility to improve last‐mile transit connections; Improve network connectivity/design to make destinations and low‐carbon travel modes accessible; both applicable for both residential and employment uses]; City of LA [Existing transit mode share (as a percent of total daily trips) (%), Lines within project site improved (<50%, >=50%)] 8 Increase access to common goods and services, such as groceries, schools, and daycare Similar to CAPCOA LUT‐3 (Increase Diversity of Urbanand Suburban Developments (Mixed Use)): 9.00% ‐ 30.00% VMT reduction and CAPCOA LUT‐4 (Increase Destination Accessibility): 6.70% ‐ 20.00% VMT reduction
N/A Y Y Y Y N Y
Notes: Similar to CAPCOA LUT‐3 (Increase Diversity of Urban and Suburban Developments (Mixed Use) ‐ Applicable in urban and suburban context; negligible in rural context (unless the project is a master‐planned community; appropriate for mixed‐use projects) and CAPCOA LUT‐ 4 (Applicable in urban and suburban context, negligible in rural context, appropriate for residential, retail, office, industrial, and mixed‐use projects); City of San Jose [Access to Neighborhood Schools: Applicable for residential uses only]; City of San Jose [Very similar to measure 'Increase diversity of uses' ‐ Applicable for residential and employment uses] 9 Incorporate affordable housing into the project 0.04% ‐ 1.20% N/A Y Y Y Y N Y Notes: Similar measure is CAPCOA LUT‐6 [Integrate Affordable and Below Market Rate Housing] ‐ [Applicable in urban and suburban contexts; negligible impact in a rural context unless transit availability and proximity to jobs/services are existing characteristics; appropriate for residential and mixed‐use projects]; City of San Jose [Similar to measure 'Integrate affordable and market rate housing] ‐ Measure is applicable for residential uses only
Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1015
# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) 10 Incorporate neighborhood electric vehicle network 0.50% ‐ 12.70% N/A Y Y Y N N Y Notes: CAPCOA SDT‐3 [Neighborhood electric vehicles (NEV) would result in a mode shift and therefore reduce the traditional vehicle VMT and GHG emissions. Range depends on the available NEV network and support facilities, NEV ownership levels, and the degree of shift from traditional; measure is applicable in urban, suburban, and rural context, for small citywide or large multi‐use developments, and appropriate for mixed‐use projects] 11 Orient project towards transit, bicycle, and pedestrian facilities `1) 0.25% ‐ 0.5% (0.25% reduction is attributed for a
project oriented towards a planned corridor and 0.5%reduction is attributed for a project oriented towards an existing corridor) (as per the Sacramento MetropolitanAir Quality Management District (SMAQMD)Recommended Guidance for Land Use EmissionReductions ), 2) 0.5% reduction in VMT per 1% increase in transit frequency and per 10% increase in transit
ridership (as per the Center for Clean Air Policy (CCAP) Transportation Emission Guidebook )
N/A Y Y Y N N Y
Notes: CAPCOA LUT‐7 [Orient project toward non‐auto corridor]; Grouped strategy with LUT‐ 3 (Increase Diversity of Urban and Suburban Developments (Mixed Use) ; there is no sufficient evidence that the measures results in non‐negotiable trip reduction unless combined with other measures, including neighborhood design, density and diversity of development, transitaccessibility and pedestrian and bicycle network improvements; the measure is applicable for urban or suburban context (may be applicable in a master‐planned rural community) and isappropriate for residential, retail, office, industrial, and mixed use projects 12 Provide pedestrian network improvements 0.00% ‐ 2.00% N/A Y Y Y Y Y Y Notes: CAPCOA SDT‐1 [applicable in urban, suburban, and rural context; appropriate for residential, retail, office, industrial, and mixed‐use projects; reduction benefit only occurs if the project has both pedestrian network improvements on site and connections to the largeroff‐site network]. This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service'; City of San Jose [Provide pedestriannetwork improvements for active transportation: applicable for both residential andemployment uses]; City of LA [Included (within project and connecting off‐site/within project only)]
13 Increase transit service frequency/speed 0.02% – 2.50% N/A Y Y Y Y Y Y Notes: CAPCOA TST‐4, applicable in urban and suburban context, maybe applicable in rural context but no literature documentation available, appropriate for specific or general plans.This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service'; City of San Jose [Similar to measure 'Subsidize public transitservice upgrades']; City of LA [Reduction in headways (increase in frequency) (%)] 14 Required project contributions to transportation infrastructure improvement projects Not Quantified: Grouped strategy (with RPT‐2 and TST‐1 through 7) N/A Y Y Y Y Y Y Notes: CAPCOA RPT‐3 (Applicable in urban, suburban and rural context; appropriate forresidential, retail, office, mixed use, and industrial projects); measure similar to some of the measures discussed above. This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service.' 15 Increase destination accessibility 6.70% – 20.00% N/A Y Y Y Y Y Y Notes: CAPCOA LUT‐4 [Destination accessibility measured in terms of the number of jobs or other attractions reachable within a given travel time, which tends to be the highest at central locations and lowest at peripheral ones; the location of the project also increases thepotential for pedestrians to walk and bike to these destinations and therefore reduces VMT;applicable for urban and suburban contexts, negligible impact in a rural context; appropriatefor residential, retail, office, industrial, and mixed‐use projects]. This can be considered under Technical Advisory Measure 'Improve pedestrian or bicycle networks, or transit service'; City of San Jose [Increase transit availability to improve last‐mile transit connections; Improve network connectivity/design to make destinations and low‐carbon travel modes accessible; both applicable for both residential and employment uses]; City of LA [Lines within project site improved (<50%, >=50%)]
16 Provide traffic calming measures 0.25% – 1.00% N/A Y Y Y Y Y Y Notes: CAPCOA SDT‐2 [applicable in urban, suburban, and rural contexts; appropriate for residential, retail, office, industrial, and mixed‐use projects]; City of San Jose [Applicable for both residential and employment uses]; City of LA [Streets with traffic calming improvements (%), intersections with traffic calming improvements (%)] 17 Provide bike parking in non‐residential projects 0.625% (as per the Center for Clean Air Policy (CCAP) Transportation Emission Guidebook ) N/A Y Y Y Y Y Y Notes: CAPCOA SDT‐6 [Bike Parking in Non‐Residential projects has minimal impacts as a standalone strategy and should be grouped with the LUT‐9 (Improve Design of Development)strategy to encourage bicycling by providing strengthened street network characteristics and bicycle facilities]; the measure is applicable in urban, suburban, and rural contexts; appropriate for retail, office, industrial, and mixed‐use projects; City of San Jose [Provide bike parking and end‐of‐trip facilities such as bike parking, bicycle lockers, showers, and personal lockers (Applicable for both residential and employment uses)]; City of LA [Include bike parking/lockers, showers, & repair station (Y/N)]
18 Provide bike parking with multi‐unit residential projects Not Quantified N/A Y Y Y Y Y Y Notes: CAPCOA SDT‐7 [Grouped Strategy; the benefits of Bike Parking with Multi‐Unit Residential Projects have no quantified impacts and should be grouped with the LUT‐9 (Improve Design of Development) strategy to encourage bicycling by providing strengthenedstreet network characteristics and bicycle facilities. The measure is applicable in urban,suburban, or rural contexts. It is appropriate for residential projects.]; City of San Jose [Provide bike parking and end‐of‐trip facilities such as bike parking, bicycle lockers, showers, and personal lockers (Applicable for both residential and employment uses)]; City of LA [Include bike parking/lockers, showers, & repair station (Y/N)] R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1016
# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) 19 Limit or eliminate parking supply 5.00% ‐ 12.50% N/A Y Y Y Y Y Y Notes: CAPCOA PDT‐1 (applicable in urban and suburban context, negligible in rural context, appropriate for residential, retail, office, industrial, and mixed‐use projects); reduction can be counted only if spillover parking is controlled (via residential permits and on‐street market parking); follow multi‐faceted strategy including 1) elimination/reduction of minimum parking requirements, 2) creation of maximum parking requirements, and 3) provision of shared parking; City of San Jose [Decrease project parking supply at the project site to rates lower than the standard parking minimums where allowable in the San Jose Municipal Code(applicable for employment uses)]; City of LA [City code parking provision (spaces), actual parking provision (spaces)]
20 Unbundle parking costs from property costs 2.60% ‐ 13.00% N/A Y Y Y Y Y Y Notes: CAPCOA PDT‐2 (applicable in urban and suburban context, negligible in rural context, appropriate for residential, retail, office, industrial and mixed‐use projects; complimentary strategies include workplace parking pricing); City of San Jose [Unbundle On‐Site Parking Costs: Application for Residential Uses Only]; City of LA [Monthly cost for parking ($)] 21 Provide parking cash‐out programs 0.60% – 7.70% commute VMT N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐15 [Implement employee parking "cash‐out"; the term “cash out” is usedto describe the employer providing employees with a choice of forgoing their currentsubsidized/free parking for a cash payment equivalent to the cost of the parking space to theemployer. The measure is applicable in urban and suburban context; it is not applicable in rural context; it is appropriate for retail, office, industrial, and mixed‐use projects. Restrictions are applied only if complementary strategies are in place: a) Residential parking permits andmarket rate public on‐street parking to prevent spill over parking; b) Unbundled parking ‐ isnot required but provides a market signal to employers to forgo paying for parking spaces and“cash‐out” the employee instead. In addition, unbundling parking provides a price with which employers can utilize as a means of establishing “cash‐out” prices; City of San Jose [Parking cash‐out: Employment uses only]; City of LA [Parking cash‐out: Employees eligible (%)] 22 Implement or provide access to a commute reduction program ‐ Voluntary 1.00% ‐ 6.20% commute VMT N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐1: Commute Trip Reduction Program – Voluntary, is a multi‐strategy program that encompasses a combination of individual measures described CAPCOA measures TRT‐3 through TRT‐9. It is presented as a means of preventing double‐counting of reductions for individual measures that are included in this strategy. It does so by setting a maximum level of reductions that should be permitted for a combined set of strategies within a voluntary program. The main difference between a voluntary and a required program is: A) Monitoring and reporting is not required
B) No established performance standards (i.e. no trip reduction requirements). The measureis applicable in urban and suburban contexts, negligible in a rural context, unless large employers exist and suite of strategies implemented are relevant in rural settings. Themeasure is appropriate for retail, office, industrial, and mixed‐use projects; City of San Jose [Applicable for employment uses only]; City of LA [Employees and residents participating (%)] 23 Provide ride‐sharing program 1.00% – 15.00% commute VMT N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐3 [Provide Ride‐Sharing Programs: applicable in urban and suburban context; Negligible impact in many rural contexts, but can be effective when a large employer in a rural area draws from a workforce in an urban or suburban area, such as when a major employer moves from an urban location to a rural location; appropriate for residential, retail,office, industrial, and mixed‐use projects]; City of San Jose [Ride share for employment usesonly]; City of LA [Measured in terms of employees eligible (%)] 24 Implement car‐sharing program 0.40% – 0.70% N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐9 [urban and suburban context, negligible in rural context, and appropriate for residential, retail, office, industrial, and mixed‐use projects]; City of San Jose [Applicable for both residential and employment uses]; City of LA [Car share project setting(urban, suburban, all other)] 25 Implement bike‐sharing program
Taking evidence from the literature, a 135‐300%
increase in bicycling (of which roughly 7% are shifting from vehicle travel) results in a negligible impact (around0.03% VMT reduction)
N/A YYNYYY
Notes: CAPCOA TRT‐12 [This measure has minimal impacts when implemented alone. The strategy's effectiveness is heavily dependent on the location and context. Bike‐sharing programs have worked well in densely populated areas (examples in Barcelona, London, Lyon, and Paris) with existing infrastructure for bicycling. Bike sharing programs should becombined with Bike Lane Street Design (SDT‐5) and Improve Design of Development (LUT‐9).
The measure is applicable in urban and suburban‐center context only; it is negligible in a ruralcontext; appropriate for residential, retail, office, industrial, and mixed‐use projects; City of San Jose [Bike share for employment and residential uses]; City of LA [bike share ‐ within 600 feet of existing bike share station ‐ OR ‐implementing new bike share station (Y/N)] 26 Provide transit passes
Similar to CAPCOA TRT‐4 [Implement Subsidized or
Discounted Transit Program]; for TRT‐4, commute VMT
reduction is 0.30% ‐ 20.00%
N/A Y Y Y Y Y Y
Notes: Similar to CAPCOA TRT‐4 [Implement Subsidized or Discounted Transit Program]; City of San Jose [Implement Subsidized or Discounted Transit Program]; City of LA [Employees and residents eligible (%), amount of transit subsidy per daily passenger (daily equivalent) ($)] R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1017
# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) 27 Implement a school pool program 7.20% ‐ 15.80% school VMT reduction N/A Y Y N Y Y Y Notes: CAPCOA TRT‐10 [This project will create a ridesharing program for school children.
Most school districts provide bussing services to public schools only. School Pool helps match parents to transport students to private schools, or to schools where students cannot walk or bike but do not meet the requirements for bussing. The measure is applicable in urban,suburban, and rural context and is appropriate for residential and mixed‐use projects.]; City of San Jose [School carpool program ‐ residential uses only)]. This measure can be considered under the Technical Advisory Measure 'Shifting single occupancy vehicle trips to carpooling orvanpooling, for example providing ride matching services.'; City of LA [School carpool program ‐ level of implementation (low, medium, high)
28 Operate free direct shuttle service
CAPCOA TST‐6 (Provide Local Shuttles): Not Quantified;
0.30% ‐ 13.40% commute VMT reduction (for CAPCOATRT‐11: Provide Employer‐Sponsored Vanpool/Shuttle)
N/A YYNYYY
Notes: CAPCOA TST‐6 (Provide Local Shuttles ‐ grouped strategy with TST‐5 'Provide Bike Parking Near Transit' and TST‐4 'Increase Transit Service Frequency/Speed') ‐ Applicable in urban/suburban context; appropriate for large residential, retail, office, mixed use, and industrial projects; solves the "first mile/last mile" problem; CAPCOA TRT‐11 (Provideemployer‐sponsored vanpool/shuttle) ‐ the measure is applicable for urban, suburban, and rural context, and is appropriate for office, industrial, and mixed‐use projects. This measurecan be considered under the Technical Advisory Measure 'Shifting single occupancy vehicletrips to carpooling or vanpooling, for example providing ride matching services.'; City of San Jose [Employment uses only]; City of LA [Employer sponsored vanpool or shuttle (Degree ofimplementation (low, medium, high), employees eligible (%), employer size (small, medium,large)] 29 Provide teleworking options 0.07% ‐ 5.50% commute VMT N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐6 [Applicable in urban, rural, and suburban contexts; appropriate for retail, office, industrial, and mixed‐use projects]; City of San Jose [Alternative work schedulesand telecommute (employment land uses only)]; City of LA [Alternative work schedules and telecommute (employees participating (%), type of program)] 30 Subsidize public transit service upgrades Not Quantified N/A Y Y N Y N Y Notes: Similar to CAPCOA TST‐2 through TST‐4; City of San Jose [Subsidize transit service through contributions to the transit provider to improve transit service to the project (e.g. frequency and number of routes); applicable for both residential and employment uses]. Themeasure is included under the Technical Advisory Measure 'Provide incentives or subsidies that increase the use of modes other than single‐occupancy vehicle.' 31 Implement subsidized or discounted transit program 0.30% – 20.00% commute VMT N/A Y Y Y Y Y Y Notes: CAPCOA TRT‐4 [Implement subsidized or discounted transit program (the measure is applicable in urban and suburban context, negligible in a rural context, appropriate for residential, retail, office, industrial, and mixed‐use projects); The project will provide subsidized/discounted daily or monthly public transit passes. The project may also provide free transfers between all shuttles and transit to participants. These passes can be partially or wholly subsidized by the employer, school, or development. Many entities use revenue fromparking to offset the cost of such a project. The measure is included under the Technical Advisory Measure 'Provide incentives or subsidies that increase the use of modes other than single‐occupancy vehicle.'; City of San Jose [Implement Subsidized or Discounted Transit Program]; City of LA [Transit subsidies measured by employees and residents eligible (%), and amount of transit subsidy per passenger (daily equivalent) ($)] 32 Providing on‐site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms
22% increase in bicycle mode share (UK National TravelSurvey)/2%‐5% reduction in commute vehicle trips(Transportation Demand Management Encyclopedia )/0.625% reduction in VMT (Center for
Clean Air Policy (CCAP) Emission Guidebook )
N/A Y Y Y Y Y Y
Notes: CAPCOA TRT‐5 [Provide End of Trip Facilities]: End‐of‐trip facilities have minimal impacts when implemented alone. This strategy’s effectiveness in reducing vehicle miles traveled (VMT) depends heavily on the suite of other transit, pedestrian/bicycle, and demand management measures offered. End‐of trip facilities should be grouped with Commute Trip Reduction (CTR) Programs (TRT‐1: Implement Commute Trip Reduction Program ‐ Voluntary through TRT‐2: Implement Commute Trip Reduction Program – Required Implementation/Monitoring) and TRT‐3 (Provide Ride‐Sharing Programs); City of San Jose [Similar measures include 'Provide bike parking/end of trip bike facilities', 'Implement carsharing programs']; City of LA [Include bike parking/lockers, showers, & repair station (Y/N)] 33 Provide employee transportation coordinators at employment sites Not Quantified N/A Y Y Y N N Y Included as part of CAPCOA TRT‐1 (Implement Commute Trip Reduction Program ‐ Voluntary) 34 Provide a guaranteed ride home service to users of non‐auto modes Not Quantified N/A N Y Y N N Y 35 Locate project in an area of the region that already exhibits low VMT 10.00% ‐ 65.00% N/A Y Y Y N N Y Notes: CAPCOA LUT‐2 (Applicable in urban and suburban contexts; negligible in rural contexts; appropriate for residential, retail, office, industrial, and mixed‐use projects) 36 Locate project near transit 0.50% ‐ 24.60% N/A Y Y Y N N Y Notes: CAPCOA LUT‐5 [May be grouped with CAPCOA measures LUT‐3 (mixed use development), SDT‐2 (traffic calmed streets with good connectivity), and PPT‐1 through PPT‐7 (parking management strategies); measures are applicable in urban and suburban contexts; appropriate in rural context if development site is adjacent to a commuter rail station with convenient rail service to a major employment center; appropriate for residential, retail, office, industrial, and mixed‐use projects]
37 Increase project/development density 1.50% ‐ 30.00% N/A Y Y Y Y N Y Notes: CAPCOA LUT‐1 (Applicable in urban and suburban contexts only; negligible in rural context; appropriate for residential, retail, office, industrial, and mixed‐use projects); City of San Jose [Applicable for both residential and employment uses] 38 Increase the mix of uses within the project or within the project's surroundings 9.00% ‐ 30.00% N/A Y Y Y Y N Y Notes: CAPCOA LUT‐3: Increase Diversity of Urban and Suburban Developments (Mixed Use) [Applicable in urban and suburban context, negligible in rural context, and appropriate for mixed‐use projects]; City of San Jose [Applicable for both residential and employment uses] R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1018
# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) 39 Improve network connectivity and/or increase intersection density on the project site Similar measure is CAPCOA LUT‐9 [Improve Design of Development]: 3.0% ‐ 21.3% reduction in VMT N/A Y Y Y Y N Y Notes: Similar measure to CAPCOA LUT‐9 (Improve Design of Development); City of San Jose [Build new street connections and/or connect cul‐de‐sacs to provide pedestrian and bicycle access: applicable for both residential and employment uses] 40 Price workplace parking 0.10% ‐ 19.70% commute VMT N/A Y N N Y Y N Notes: CAPCOA TRT‐14 [Urban and suburban context; Negligible impact in a rural context; Appropriate for retail, office, industrial, and mixed‐use projects; Reductions applied only if complementary strategies are in place:o Residential parking permits and market rate public on‐street parking ‐ to prevent spill‐over parkingo Unbundled parking ‐ is not required but provides a market signal to employers to transferover the, now explicit, cost of parking to the employees. In addition, unbundling parking provides a price with which employers can utilize as a means of establishing workplaceparking prices; City of San Jose [Price On‐Site Workplace Parking (for employment uses only)]; City of LA [Daily parking charge ($), Employees subject to priced parking (%)] 41 Locate project near bike path/bike lane 0.625% N/A Y N Y N N N Notes: CAPCOA LUT‐8 (Grouped strategy with 'Increase Destination Accessibility'; themeasure is most effective when applied in combination of multiple design elements thatencourage this use; strategy should be grouped with 'Increase Destination Accessibility' strategy to increase the opportunities for multi‐modal travel; measure is applicable in urban or suburban context, may be applicable in a rural master planned community; appropriate for residential, retail, office, industrial, and mixed‐use projects 42 Implement Commute Trip Reduction Marketing 0.80% ‐ 4.00% commute VMT N/A Y N Y Y N N Notes: CAPCOA TRT‐7 (applicable in urban and suburban context; negligible in rural context;appropriate for residential, retail, office, industrial, and mixed‐use projects); City of San Jose [Employment uses only]
43 Education and encouragement ‐ Voluntary travel behavior change program 1.00% ‐ 6.20% commute VMT N/A YNNY YN Notes: Similar to CAPCOA TRT‐1 (Implement Commute Reduction Program ‐ Voluntary); City of San Jose [For both residential and employment uses]; City of LA [Employees and residents participating (%)]
44 Education and encouragement ‐ Promotions and marketing 0.80% ‐ 4.00% commute VMT N/A Y N N Y Y N Notes: Similar to CAPCOA TRT‐7 [Implement Commute Reduction Marketing]; City of San Jose [Similar measure might be 'Implement commute trip reduction marketing/educational campaign' (applicable for employment uses)]; City of LA [Employees and residents participating (%)]
45 Implement neighborhood shuttle Not Quantified N/A Y N N Y Y N Notes: CAPCOA TST‐6 (Provide Local Shuttles ‐ grouped strategy with TST‐5 'Provide Bike Parking Near Transit' and TST‐4 'Increase Transit Service Frequency/Speed') ‐ Applicable inurban/suburban context; appropriate for large residential, retail, office, mixed use, and industrial projects; solves the "first mile/last mile" problem; City of San Jose [Similar measure:
'Operate a free direct shuttle service' (applicable for employment uses only)]; City of LA[Degree of Implementation (low/medium/high), employees and residents eligible (%)] 46 Install park‐and‐ride lots
Two sources: 0.10% ‐ 0.50% VMT reduction (as per 2005
Federal Highway Administration (FHWA) study) and
0.50% VMT reduction per day (as per Washington StateDepartment of Transportation (WSDOT))
N/A Y N N N N N
Notes: CAPCOA RPT‐4 (Applicable in suburban and rural context; appropriate for residential, retail, office, mixed use, and industrial projects); Grouped strategy with RPT‐1, TRT‐11, TRT‐3, and TRT‐1 through 6
47 Electrify loading docks and/or require idling‐reduction systems 26% ‐ 71% reduction in Truck refrigeration units (TRU) idling GHG emissions N/A Y N N N N N Notes: CAPCOA VT‐1 (Measure applicability: Truck refrigeration units (TRU)) 48 Utilize alternative fueled vehicles Reduction in GHG emissions varies depending on vehicle type, year, and associated fuel economy N/A Y N N N N N Notes: CAPCOA VT‐2 (Measure applicability: vehicles) 49 Utilize electric or hybrid vehicles 0.40% ‐ 20.30% reduction in GHG emissions N/A Y N N N N N Notes: CAPCOA VT‐3 (Measure applicability: vehicles)50 Provide bike parking near transit Not Quantified N/A Y N N N N N Notes: CAPCOA TST‐5 (should be implemented with other two measures as mentioned to encourage multi‐modal use in the area and provide ease of access to nearby transit for bicyclists (measure applicable in urban and suburban context; appropriate for residential, retail, office, mixed use, and industrial projects); Grouped strategy (with measures TST‐3'Expand transit network' and TST‐4 'Increase transit service frequency/speed') 51 Improve design of development 3.00% ‐ 21.30% N/A Y N N N N N Notes: CAPCOA LUT‐9 (Include design elements to enhance walkability and connectivity; improved street network characteristics within a neighborhood such as street accessibility;design also measured in terms of sidewalk coverage, building setbacks, street widths, pedestrians crossings, presence of street trees, and a host of other physical variables that differentiate pedestrian‐oriented environments from auto‐oriented environments); measureis applicable in the urban and suburban contexts, negligible impact in rural context; appropriate for residential, retail, office, industrial, and mixed‐use projects 52 Provide electric vehicle parking Not Quantified N/A Y N N N N N Notes: CAPCOA SDT‐8 [This is a grouped strategy and the benefits of electric vehicle parking may be quantified when grouped with the use of electric vehicles and or SDT‐3 (Implement a Neighborhood Electric Vehicle (NEV) Network). This measure is applicable in urban orsuburban contexts and is appropriate for residential, retail, office, mixed use, and industrial projects.]
R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1019
# Mitigation Measure VMT Reduction1 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)2 CAPCOA3 OPR TA4 Los Angeles Metro5 City of San Jose6 City of Los Angeles7 San Diego Region8 Notes Table A ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CAPCOA) 53 Dedicated land for bike trails Not Quantified N/A Y N N N N N Notes: CAPCOA SDT‐9 [Larger projects may be required to provide for, contribute to, ordedicate land for the provision of off‐site bicycle trails linking the project to designated bicycle commuting routes in accordance with an adopted citywide or countywide bikeway plan. The benefits of Land Dedication for Bike Trails have not been quantified and should be grouped with the LUT‐9 (Improve Design of Development) strategy to strengthen streetnetwork characteristics and improve connectivity to off‐site bicycle networks. The measure is applicable in urban, suburban, or rural contexts and is appropriate for large residential, retail, office, mixed use, and industrial projects.]
54 Implement school bus program 38.00% ‐ 63.00% school VMT reduction N/A Y N N N N N Notes: CAPCOA TRT‐13 [Applicable in urban, suburban, and rural context; appropriate for residential and mixed‐use projects] 55 Implement preferential parking permit program Not Quantified N/A Y N N N N N Notes: CAPCOA TRT‐8 [The project will provide preferential parking in convenient locations (such as near public transportation or building front doors) in terms of free or reduced parking fees, priority parking, or reserved parking for commuters who carpool, vanpool, ride‐ share or use alternatively fueled vehicles. The project will provide wide parking spaces to accommodate vanpool vehicles. The impact of preferential parking permit programs has notbeen quantified by the literature and is likely to have negligible impacts when implemented alone. This strategy should be grouped with Commute Trip Reduction (CTR) Programs (TRT‐1 and TRT‐2) and TRT‐3 (Provide Ride‐Sharing Programs) as a complementary strategy for encouraging non‐single occupant vehicle travel. This measure is applicable in urban and suburban contexts and is appropriate for residential, retail, office, mixed use, and industrialprojects.] Notes:
VMT = Vehicle Miles Traveled; CAPCOA = California Air Pollution Control Officers Association; ; Fresno COG = Fresno Council of Governments; OPR = Office of Planning and Research; TA = Technical Advisory; HOV = High Occupancy Vehicle; HOT = High Occupancy Toll; ITS = Intelligent Transportation System CAPCOA Transportation Mitigation Categories (LU = Land Use/Location, SD = Neighborhood/Site Enhancements, PD = Parking Policy/Pricing, TR = Commute Trip Reduction Programs, TS = Transit System Improvements, RP = Road Pricing/Management; V = Vehicles) 1 VMT reduction numbers obtained from Quantifying Greenhouse Gas Mitigation Measures published by the California Air Pollution Control Officers Association in August 2010.2 Fresno COG VMT reduction recommendation for this measure obtained based on analysis conducted by Fresno COG staff and LSA using local data and/or the COG's Activity Based Model.3 Quantifying Greenhouse Gas Mitigation Measures published by the California Air Pollution Control Officers Association in August 2010.4 Technical Advisory on Evaluating Transportation Impacts in CEQA published by the Governor's Office of Planning and Research State of California in December 2018.5 Analysis of VMT Mitigation Measures Pursuant to SB 743 prepared by Iteris, Inc. in February 2018.6 City of San Jose Transportation Analysis Handbook (dated April 2018).7 City of Los Angeles VMT Calculator Version 1.28 Guidelines for Transportation Impact Studies in the San Diego Region developed by San Diego Section of the Institute of Transportation Engineers (ITE) and the San Diego Traffic Engineers Council (SANTEC) in January 2019. **Highlighted VMT Reduction Numbers are yet to be Finalized** R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Land Dev Proj (5/12/2020) 1020
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APPENDIX B
VEHICLE MILES TRAVELED MITIGATION MEASURES FOR
DEVELOPMENT PROJECTS (CARB PAPERS)
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# Mitigation Measure VMT Reduction2 Local VMT Reduction Calculations (Local Data/Fresno COG ABM)3 Notes 1 Provide Bicycling Network Improvements No effect on VMT 0.30% VMT reduction per 100 miles (for addition of new bike lane) 2 Implement Transit Improvements No effect on VMT 0.07% VMT reduction per 100 miles (for addition of a new transit line)3 Improve or increase access to transit 1.3% ‐ 5.8% N/A Variable: Various factors associated with proximity to transit stop (please refer to How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.)
4 Land Use Mix Elasticity: 0.02 ‐ 0.10 N/A Variable: Entropy ‐ variety and balance of land‐use types within a neighborhood 5 Regional Accessibility Elasticity: 0.05 ‐ 0.25 N/A
Variable: Various factors associated with job accessibility and distance to CBD (please refer to How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.)
6 Job‐Housing Balance Elasticity: 0.06 ‐ 0.31 for commute VMT N/A Variable: Various factors associated with job accessibility (please refer to How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.)
7 Provide Pedestrian Network Improvements Elasticity: 0.00 ‐ 0.02 for sidewalk length, 0.19 for Pedestrian Environment Factor N/A 8 Voluntary Travel Behavior Change (VTBC) Program 5% ‐ 12% N/A 9 Implement Employer‐Based Trip Reduction (EBTR) Program 1.33% ‐ 6% of commute VMT N/A 10 Provide telecommuting options
Home‐based telecommuting: 48.1% for household VMT,
66.5% ‐ 76.6% for all personal VMT, and 90.3% forcommute VMT only; Center‐based telecommuting: 53.7% ‐ 64.8% for all personal VMT and 62.0% ‐ 77.2% forcommute VMT only N/A
11 Increase Project/Development Density Elasticity: <=0.07 ‐ 0.19 N/A Variable: residential density 12 Improve network connectivity and/or increase intersection density on the project site Elasticity: ‐0.46 ‐ 0.59 N/A Variable: Various factors associated with intersection or street density (please refer to How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.)
13 Implement Parking Cash‐out Programs or Workplace Parking Pricing 12% of commute VMT (parking cash out); 2.3% ‐ 2.9% for$3 per day workplace parking price; 2.8% for priceincrease equivalent to 60% hourly value of commutertravel time cost N/A
Notes:
VMT = Vehicle Miles Traveled
1 All mitigation measures have been obtained from How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.).2 All VMT reduction numbers have been obtained from How do Local Actions Affect CMT? A Critical Review of the Empirical Evidence (Salon, D., Boarnet, M.G., Handy, S., Spears, S., and Tal, G.).3 Fresno COG VMT reduction recommendation for this measure obtained based on analysis conducted by Fresno COG staff and LSA using local data and/or the COG's Activity Based Model.
Table B ‐ Vehicle Miles Traveled Mitigation Measures for Development Projects (CARB Papers)1 R:\FCG1901 FresnoCOG VMT\VMT Mitigations\VMT Mitigations_FresnoCOG.xlsx\Boarnet and Handy (5/12/2020) 1023
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APPENDIX C
VEHICLE MILES TRAVELED MITIGATION MEASURES FOR
COMMUNITY PLANS AND GENERAL PLANS
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San Joaquin Valley Air Pollution Control District June 15, 2023 2023 Maintenance Plan and Redesignation
Request for the Revoked 1-Hour Ozone Standard
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San Joaquin Valley Air Pollution Control District June 15, 2023 1 2023 Maintenance Plan and Redesignation
Request for the Revoked 1-Hour Ozone Standard
TABLE OF CONTENTS
A. Introduction........................................................................................................ 2 A.1 Background........................................................................................................ 2 B. Attainment of the Standard ................................................................................ 5 B.1 Continued Attainment of the 1-hour Ozone Standard (2020-2022).................... 5 C. State Implementation Plan (SIP) Approval....................................................... 13 D. Permanent and Enforceable Improvement in Air Quality ................................. 13 D.1 Enforceable Regulations Have Achieved Permanent Emission Reductions .... 13 D.2 Attainment is Not Due to Unusually Favorable Meteorology ............................ 25 D.3 Attainment is Not Due to Temporary Emissions Reductions............................ 34 D.4 Conclusion ....................................................................................................... 36 E. Section 110 and Part D Requirements............................................................. 36 F. Maintenance Plan ............................................................................................ 36 F.1 Attainment Inventory ........................................................................................ 37 F.2 Maintenance Demonstration ............................................................................ 40 F.3 Monitoring Network .......................................................................................... 41 F.4 Verification of Continued Attainment ................................................................ 45 F.5 Contingency Plan............................................................................................. 45 G. Federal Mobile Source Opportunities............................................................... 48 H. Summary Checklist.......................................................................................... 48 Appendix A Emissions Inventory................................................................................ A-1 Appendix B Analysis of Meteorology Affecting Ozone Levels .................................... B-1 1032
San Joaquin Valley Air Pollution Control District June 15, 2023 2 2023 Maintenance Plan and Redesignation
Request for the Revoked 1-Hour Ozone Standard
A. INTRODUCTION
Since 2014, the San Joaquin Valley Air Control District (District) has been in attainment for the revoked 1-hour ozone National Ambient Air Quality Standard (NAAQS) of 124 parts per billion (ppb). The District is the first and only region in the nation designated as an extreme nonattainment for an ozone standard to attain that standard, specifically for the 1-hour ozone NAAQS.
Since then, and through the efforts to continue to reduce emissions from stationary, area, and mobile sources, the San Joaquin Valley (Valley) has continued to experience dramatic progress in reducing ozone concentrations, keeping the region in attainment of the 1-hour ozone NAAQS, as well as progressing towards attaining the 8-hour ozone NAAQS.
In order to terminate anti-backsliding provisions for the revoked 1-hour ozone standard, including Section 185 nonattainment fees, the District must meet all five criteria of Section 107(d)(3)(E) of the CAA. This document, the 2023 Maintenance Plan and Redesignation Request for the Revoked 1-Hour Ozone Standard, includes such requirements as well as all provisions for a maintenance plan. This Maintenance Plan also includes a demonstration that would ensure the area remains in attainment of the 1-hour ozone NAAQS through 2036. Therefore, the Valley is requesting to be redesignated to attainment for the 1-hour ozone NAAQS and requesting termination of all anti-backsliding obligations.
A.1 BACKGROUND
EPA set the 1-hour ozone NAAQS at 124 ppb on February 8, 19791, and later revoked the standard in 2004 to be replaced by a more health-protective 8-hour ozone NAAQS in 1997 of 84 ppb. This standard was lowered again in 2008 to 75 ppb, and then once more in 2015 to 70 ppb.
2 When EPA revoked the 1-hour standard, it identified the revoked requirements applicable to implementation of the 1-hour standard, and those that remained in effect. EPA adopted anti-backsliding provisions to preserve existing 1- hour ozone control measures and emission reductions obligations; therefore, nonattainment areas were still obligated to meet Rate of Progress (ROP) emission reduction targets, adopt mandatory control measures, and meet any extant attainment demonstration obligations.
In October 2004, the District adopted its Extreme Ozone Attainment Demonstration Plan (2004 Ozone Plan) to address EPA’s 1-hour ozone standard. Because EPA had revoked the 1-hour ozone standard in 2004, it did not act on this plan until 2010, when EPA approved the plan and set an attainment deadline of November 15, 2010.3
1 44 FR 8202
2 Air Quality Designations for the 2015 Ozone National Ambient Air Quality Standards, 83 Fed. Reg. 25776-25848. (2018, June 4). (to be codified 40 CFR Part 81) https://www.govinfo.gov/content/pkg/FR2018-06-04/pdf/2018-11838.pdf 3 Approval and Promulgation of Implementation Plans: 1-Hour Ozone Extreme Area Plan for San Joaquin Valley, CA, 75 Fed. Reg. 44, pp. 10420-10438. (2010, March 8). (to be codified at 40 CFR Part 52) https://www.gpo.gov/fdsys/pkg/FR-2010-03-08/pdf/2010-4752.pdf 1033
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Subsequent litigation against EPA concerning the revocation of the 1-hour ozone standard resulted in court rulings clarifying specific anti-backsliding requirements to be imposed for revoked standards, including Section 185 nonattainment fees and other planning requirements. As a result of EPA’s nonattainment action in 2011, the District became subject to Section 185 fees of the CAA, and the District was required to develop and implement a second 1-hour ozone attainment plan.4 On September 19, 2013, the District submitted the 2013 Plan for the Revoked 1-Hour Ozone Standard (2013 Ozone Plan), which was approved by EPA on April 6, 2016.5 In 2013, the Valley recorded zero exceedances of the revoked 1-hour ozone NAAQS, which was a first for the region, and led to ongoing ozone improvements and further planning actions. Accordingly, on May 5, 2014, the District submitted an Attainment Determination Request to EPA based on 2011-2013 data.6 The District formally requested that EPA determine that the Valley has attained the federal revoked 1-hour ozone standard and included a clean data finding demonstrating that attainment was due to permanent and enforceable emissions reductions.
However, no action was taken by EPA and the District submitted a second Attainment Determination Request on July 13, 2015, based on 2012-2014 data.7 On July 18, 2016, EPA published a final action in the Federal Register to determine that the Valley had attained the 1-hour ozone standard.8 This determination was based on sufficient, quality-assured, and certified data for the period 2012-2014.
Historically, EPA would not formally redesignate nonattainment areas for revoked NAAQS. Additionally, due to legal challenges and updated court interpretations, extreme nonattainment regions have remained subject to anti-backsliding requirements under the revoked 1-hour ozone NAAQS, such as Section 185 fees. The 2008 ozone NAAQS Implementation Rule addressed how nonattainment areas should submit a redesignation substitute, which was an alternative approach to formal redesignation for lifting anti-backsliding obligations for the revoked standards. A redesignation substitute would allow an area to shift to contingency status requirements, such as penalty fee program requirements under Section 185 of the CAA, to current ozone standards.9
4 Approval and Promulgation of Air Quality Implementation Plans; California; Determinations of Failure to Attain the One-Hour Ozone Standard; Final Rule. 76 Fed. Reg. 10, pp. 82133-82146. (2011, December 30). (to be codified 40 CFR Part 52) https://www.gpo.gov/fdsys/pkg/FR-2011-12-30/pdf/2011-33475.pdf 5 Clean Air Plans; 1-Hour and 1997 8-Hour Ozone Nonattainment Area Requirements; San Joaquin Valley, California; Final Rule. 81 Fed. Reg. 65, pp. 19492-19495. (2016, April 5). https://www.gpo.gov/fdsys/pkg/FR-2016- 04-05/pdf/2016-07668.pdf
6 SJVAPCD. Request for EPA Finding that the San Joaquin Valley has Attained the Federal 1-hour Ozone Standard.
May 5, 2014. Retrieved from: http://www.valleyair.org/Air_Quality_Plans/docs/2013Attainment/Cover-Letter.pdf 7 SJVAPCD. Request for EPA Finding that the San Joaquin Valley has Attained the Federal 1-hour Ozone Standard. July 13, 2015. Retrieved from: http://valleyair.org/Air Quality Plans/1hr-OzoneAttainment-Request-2016/Coverletter.pdf 8 EPA. Determination of Attainment of the 1-Hour Ozone National Ambient Air Quality Standard in the San Joaquin Valley Nonattainment Area in California. July 18, 2016. Retrieved from:
https://www.govinfo.gov/content/pkg/FR-2016-07-18/pdf/2016-16792.pdf 9 EPA’s Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Final Rule (2008 ozone standard SIP requirements rule), was published in the Federal Register on March 6, 2015 (80 FR 12264).
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However, in South Coast Air Quality Management District v. EPA, 882 F.3d 1138 (D.C.
Cir. 2018), the court vacated certain parts of the 2008 ozone NAAQS SIP requirements rule, including the redesignation substitute, holding that the only appropriate method for requesting redesignation is to satisfy the elements of the CAA section 107(d)(3)(E).
Under the CAA per Section 185, the District has been required to impose and collect nonattainment penalty fees since the 2010 attainment deadline for the 1-hour ozone standard. In conformance with 2010 EPA guidance, the District adopted Rule 3170 (Federally Mandated Ozone Nonattainment Fee)10 to meet Section 185 requirements under the CAA. EPA approval of this Maintenance Plan would meet the findings necessary under the CAA to stop collection of Section 185 fees under Rule 3170.
Over the past decades, the District has implemented generations of emissions control measures for stationary and area sources under its jurisdiction. Similarly, the California Air Resources Board (CARB) has adopted regulations for mobile sources. Together, these efforts represent the nation’s toughest air pollution emissions controls. In addition to having the toughest air regulations in the nation, the District also operates the most effective and efficient incentive grants program, investing over $5 billion in public/private funding towards clean air projects to date that have replaced thousands of vehicles and equipment with the cleanest technologies and achieved over 240,000 tons of emissions reductions. Due to the significant investments made by Valley businesses and residents, the Valley’s ozone and PM2.5 precursor emissions are at historically low levels, and air quality has improved significantly, providing Valley residents with associated health benefits.
Ozone Air Quality in the Valley
Despite the significant air quality progress in the Valley, many challenges remain as the District develops new attainment plans to meet increasingly stringent federal standards.
The Valley’s natural environment (including topography, meteorology, drought and wildfires) favors the formation and retention of ozone air pollution in the Valley. The Valley tends to experience the highest ozone concentrations from June to September, due to the increase in solar radiation and heat during this time of the year, both components of ozone formation, as well as the increased frequency of high pressure systems that create poor atmospheric dispersion conditions across the region.
Emissions from wildfires, which often occur during the peak of the Valley’s ozone season, can further impact public health and exacerbate the region’s attainment challenges.
In addition to these challenges, the Valley is home to major transportation corridors for goods movement, resulting in significant emissions and air pollution impacts from freight activity. State and federal law limits the District’s ability to regulate emissions from mobile sources, which represents the vast majority of air pollutant emissions in the region.
10 SJVAPCD. Rule 3170 Federally Mandated Ozone Nonattainment Fee. Retrieved from:
https://www.valleyair.org/rules/currntrules/3-Rule3170-0511.pdf 1035
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Despite these challenges, the innovative control measures and strategies adopted by the District and CARB have resulted in substantial emissions reductions and corresponding ozone concentration improvements. Over the last 30 years, the District has observed tremendous reductions in ozone concentrations throughout the Valley.
Required Elements for Redesignation
Section 107(d)(3)(E) of the Federal CAA states that a nonattainment area can be redesignated to attainment if the following conditions are met:
1. EPA has determined that the NAAQS has been attained.
2. EPA has fully approved the applicable implementation plan under Section 110(k) of the Federal CAA.
3. EPA has determined that the improvement in air quality is due to permanent and enforceable emission reductions.
4. The state has met all applicable requirements for the area under Section 110 and Part D.
5. EPA has fully approved a maintenance plan, including a contingency plan, for the area under Section 175(A) of the Federal CAA.
B. ATTAINMENT OF THE STANDARD
As previously stated, EPA published a final action in the Federal Register to determine that the Valley had attained the 1-hour ozone NAAQS through the District’s clean data determination for the years 2012-2014. The District has continued to remain in attainment of the 1-hour ozone NAAQS in subsequent years, and is providing supplementary data for the years 2020-2022 to demonstrate continued attainment.
B.1 CONTINUED ATTAINMENT OF THE 1-HOUR OZONE STANDARD (2020-2022) Expected Number of Exceedances
To demonstrate continued attainment of the 1-hour ozone standard, the District calculated the expected exceedances at each site for 2020-2022. EPA has defined calculation procedures for calculating the expected number of exceedances in 40 CFR 50 Appendix H and in the 1979 document “Guideline for the Interpretation of Ozone Air Quality Standards.” 11,12 The average number of exceedances for three consecutive years is based on summing the number of exceedances each year and dividing by three. If a site has an average of 1.0 or fewer expected exceedance days per year (i.e., a site averages three or fewer exceedance days over three years), then that site meets the federal 1-hour ozone standard. This calculation is simple when the air monitoring site has 365 valid measurements for the year, i.e., one measurement for each day.
However, EPA recognizes that agencies do not collect 365 samples per year either due
11 40 CFR 50 Appendix H. Retrieved from: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part50/appendix-Appendix%20H%20to%20Part%2050 12 EPA. Guideline for the Interpretation of Ozone Air Quality Standards. Retrieved from:
https://archive.epa.gov/ttn/ozone/web/html/guide-o3.html 1036
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to less frequent sampling schedules or due to either routine maintenance, audits, occasional power outages, or other issues affecting data availability. EPA guidance thus clarifies the attainment test as:
# 𝑜𝑓 𝑒𝑥𝑐𝑒𝑒𝑑𝑎𝑛𝑐𝑒𝑠
# 𝑜𝑓 𝑣𝑎𝑙𝑖𝑑 𝑠𝑎𝑚𝑝𝑙𝑒 𝑑𝑎𝑦𝑠 ∗ (# 𝑜𝑓 𝑑𝑎𝑦𝑠 𝑖𝑛 𝑡ℎ𝑒 𝑦𝑒𝑎𝑟) = # 𝑜𝑓 𝑒𝑥𝑝𝑒𝑐𝑡𝑒𝑑 𝑒𝑥𝑐𝑒𝑒𝑑𝑎𝑛𝑐𝑒𝑠 The result of this calculation must be equal to or less than 1.0 days per year when averaged over three consecutive years. Table 1 shows the average number of expected exceedance days per year, per monitoring site in the Valley. This data shows that all Valley sites continue to meet the 1-hour ozone NAAQS based on 2020-2022 data. The 1-hour ozone NAAQS is 0.12 ppm rounded to the closest one hundredth.
Thus, 1-hour ozone concentrations at or greater than 0.125 ppm exceed the standard, and 1-hour ozone concentrations at or lower than 0.124 ppm meet the standard. If any hour in a day exceeds the standard, then that day is counted as one exceedance day.
The highest hourly concentration on a given day is recorded as the 1-hour ozone concentration for that day (though all hourly concentrations are kept on record and analyzed as well). The EPA’s Air Quality System (AQS) database serves as the official repository of ambient ozone data collected by the District’s air monitoring network.13 The expected number of exceedances are available on EPAs iADAM tool from 1973 through 2021.14 The 2022 expected exceedances are not yet available in the iADAM tool and were thus calculated based on the above formula.
13 U.S. Environmental Protection Agency: Technology Transfer Network (TTN), Air Quality System (AQS): AQS Web Application. (2013). Retrieved from: http://www.epa.gov/ttn/airs/airsaqs/aqsweb/ 14 EPA Air Quality Data Statistics tool iADAM. Retrieved from: https://www.arb.ca.gov/adam 1037
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Missing Data Analysis
The number of valid sample days must meet or exceed a completeness level established by EPA. The data completeness level for the 1-hour ozone standard is defined as collecting 75% of the hourly data between 9 AM and 9 PM during the ozone season. The Arvin-Di Giorgio site was non-operational from December 2019 to June 2020. The District is confident that this site did not exceed the 1-hour ozone standard during this time period because this site typically records its peak ozone concentrations in June through September each year and has only exceeded the 1-hour ozone standard one time (in August 2020) since the site was established in November 2009.
The District’s data capture rate exceeded the mandated levels for all other sites during 2020-2022.
Even when the data completeness requirements were met for the ozone monitors in the District’s network, there were some data unavailability periods that caused some hours or days to be missed. EPA recognizes that it is highly unlikely for an ozone measurement to be available for every day, and that there are many situations which may cause for a missing-value to occur.15 For example, an ozone analyzer could be taken offline for multiple days for extensive maintenance, typically performed when ozone levels are expected to be low. Additionally, the analyzer may malfunction, experience an extended power outage, or other events out of the District’s control. To accommodate these situations, EPA allows the clean data determination documentation to include a meteorological analysis and/or a missing data analysis that shows that no exceedances would have occurred during time periods when air monitoring data is not available.16
The District examined sites with missing days in order to show that exceedances would not have occurred on days when insufficient data was collected. The ozone season for California is defined from January to December, but for practical purposes, the District’s peak ozone readings are in the afternoon from May through October. When considering incomplete data, one scenario involves having an overall incomplete day while collecting enough afternoon data to either capture an exceedance or show that an exceedance did not happen on that day. Another likely possible scenario that must be considered is when data is not collected during the peak afternoon on a given day even though 75% of the data was collected during the hours between 9:00 AM and 9:00 PM.
These scenarios were considered when completing the following missing data analysis.
The District examined all ozone sites throughout the Valley for missing days to ensure that sites would have not exceeded the 1-hour ozone standard if the data was collected.
For 2020, various sites across multiple counties experienced outages during the May through October period. With the exception of Kings County, 2020 had at least one missing day in each county. Ozone levels remained low in each county and at individual sites on the day before and after the missing days. Due to the available data
15 EPA. Guideline for the Interpretation of Ozone Air Quality Standards. Retrieved from:
https://archive.epa.gov/ttn/ozone/web/html/guide-o3.html 16 Section 2.2, Guideline for the Interpretation of Ozone Air Quality Standards (EPA, 1979). Retrieved from:
https://archive.epa.gov/ttn/ozone/web/html/guide-o3.html 1039
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C. STATE IMPLEMENTATION PLAN (SIP) APPROVAL
On April 5, 2016, EPA approved a revision to the California state implementation plan (SIP) which consisted of the 2013 Ozone Plan. EPA approved the following plan elements, with the exception of the attainment contingency provision:
Reasonably available control measures (RACM) demonstration Rate-of-Progress (ROP) demonstration
Attainment demonstration
ROP contingency measures
Provisions for clean fuels or advanced control technologies for boilers Vehicle miles traveled (VMT) emissions offset demonstrations Thus, all applicable requirements have been approved under Section 110(k) for the purposes of redesignation in accordance with Section 107(d)(3)(E).
D. PERMANENT AND ENFORCEABLE IMPROVEMENT IN AIR
QUALITY
EPA maintenance plan requirements note that, “the state must be able to reasonably attribute the improvement in air quality to emission reductions which are permanent and enforceable” (Calcagni Memo). EPA further notes that attainment resulting from temporary emission reductions (such as a shutdown or economic downturn) or from “unusually favorable meteorology”, would not qualify as resulting from permanent and enforceable emission reductions. In the sections below, the District is providing supplemental information to demonstrate that emission reductions achieved for the Valley to meet the 1-hour ozone standard are permanent and enforceable.
D.1 ENFORCEABLE REGULATIONS HAVE ACHIEVED PERMANENT EMISSION REDUCTIONS To achieve the District’s mission of improving air quality and public health for all Valley residents, the District has developed and implemented several air quality plans to reduce emissions from stationary sources. The control strategies outlined in existing District attainment plans include the adoption of nearly 650 of the most stringent rules in the nation, and strong voluntary incentive programs that have invested more than $5 billion of combined public and private funds in clean-air projects.
Table 17 shows the latest iteration of the adopted rules, including EPA approval dates.
Similarly, CARB has adopted stringent regulations for area and mobile sources under their jurisdiction, which are summarized in Table 18. Together, these efforts represent the nation’s toughest air pollution control program, and have resulted in a significant reduction in ozone precursor emissions (Figure 1). Emissions will continue to be reduced under the District’s current and upcoming ozone and PM2.5 attainment planning efforts.
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Figure 1 Valley Summer NOx and VOC Emissions, 1990-2023 D.2 ATTAINMENT IS NOT DUE TO UNUSUALLY FAVORABLE METEOROLOGY Ozone formation is strongly driven by several factors, including horizontal and vertical ventilation, high pressure, temperature, and solar radiation. These factors contribute to high temperatures on the valley floor. High temperatures can be used as a metric that shows ozone forming potential for a given summer and can be used to compare one ozone season to another. The Valley has maintained attainment of the 1-hour ozone standard from 2013-2022. The analysis in this section shows that the average high temperatures over 2020-2022 were consistent or higher than averages over the 2012- 2019 period and that temperatures from 2012-2019 were higher than the temperatures from 1950-2011. Additionally, 2020-2022 did not have lower ozone-forming potential than prior years, and meteorology did not become unusually favorable causing for the Valley to maintain attainment. The Valley is in attainment of the 1-hour ozone standard due to significant investments in cleaner technologies and practices, not because of unusually favorable meteorology.
This section also demonstrates that peak temperature days at Stockton, Modesto, Fresno, and Bakersfield are evenly and normally distributed throughout the MayOctober ozone season across 2020-2022, similar to the longer 2012-2019 period as shown in the charts below. Furthermore, even when average high temperatures increased, the 1-hour ozone concentrations have decreased in some areas. These results demonstrate that the Valley’s improvement in ozone concentrations are not due to unusually favorable meteorology, and that the ozone forming potential during the 2020-2022 period was at least equal to or stronger than longer term averages. It is therefore reasonable to conclude that the reduced ozone concentrations of 2020-2022 0 50
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Drought in the San Joaquin Valley
Through daily forecasting and through longer-term analysis, the District tracks the ongoing drought and its impact on air quality across the Valley.17 In general, drought conditions often bring warmer temperatures and longer periods of poor dispersion, which can lead to higher concentrations of pollutants in the Valley.
Beginning in April 2021, the Governor of California signed a set of emergency proclamations directing state agencies to take immediate action to bolster drought resilience across the state, and declared a State of Emergency due to severe drought conditions.18,19,20
According to the National Oceanic and Atmospheric Administration (NOAA) National Centers for Environmental Information (NCEI) statewide climatological rankings21, the January 2022 to April 2022 period was the driest on record for California, with a -9.7 inch precipitation deficit. Further, the May 2020 to April 2022 period was the 2nd driest on record. Figure 6 depicts the worsening of the California drought between May 2020 and May 2022.
As drought conditions are often correlated with long periods of poor atmospheric dispersion and warmer temperatures, the District has continued to attain the 1-hour ozone standard through this extreme drought period. This is yet another example that these ongoing improvements are not due to unusually favorable meteorology, but are rather due to permanent emission reductions.
17 See, for example, the District’s April 21, 2022 “Report on the 2021-2022 Winter Residential Woodsmoke Reduction Strategy,” (pages A-7 through A-9). Retrieved from:
https://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2022/April/final/11.pdf 18 Executive Department, State of California. State of Emergency Proclamation. April 2021. Retrieved from:
https://www.gov.ca.gov/wp-content/uploads/2021/04/4.21.21-Emergency-Proclamation-1.pdf 19 Executive Department, State of California. State of Emergency Proclamation. May 2021. Retrieved from:
https://www.gov.ca.gov/wp-content/uploads/2021/05/5.10.2021-Drought-Proclamation.pdf 20 Executive Department, State of California. State of Emergency Proclamation. October 2021. Retrieved from:
https://www.gov.ca.gov/wp-content/uploads/2021/10/10.19.21-Drought-SOE-1.pdf 21 National Oceanic and Atmospheric Administration National Centers for Environmental Information. California Precipitation Rankings, April 2022. Retrieved from: https://www.ncdc.noaa.gov/cag/statewide/rankings/4/pcp/202204 1063
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Figure 6 Drought Extent and Severity in California22
22 National Drought Mitigation Center. U.S. Drought Monitor. Retrieved from:
https://droughtmonitor.unl.edu/CurrentMap/StateDroughtMonitor.aspx?CA 1064
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D.3 ATTAINMENT IS NOT DUE TO TEMPORARY EMISSIONS REDUCTIONS Since the Valley’s ozone precursor emissions are dominated by mobile sources which are a key component of economic activity in California, gasoline and diesel fuel sales were analyzed as indicators of economic activity.23 This analysis shows that the District has continued to maintain attainment since EPA determined the Valley had attained the 1-hour ozone standard in 2016 and that the improvement in ozone throughout 2020- 2022 was not due to a temporary economic downturn.
Analysis of California gasoline and diesel sales from May to October shows some variation from year to year, including slight decreases. Figure 7 demonstrates these variations as well as the vehicles miles traveled (VMT) for both gasoline and dieselfueled vehicles. Even though California gasoline sales and VMT over 2020-2022 were inconsistent as compared to previous years, diesel sales and VMT continued at a steady rate.
Gasoline sales decreased in 2020 as a result of the COVID-19 pandemic; however, it did not play a significant role in the District’s continued attainment of the 1-hour ozone standard. The District was in continual attainment of the 1-hour ozone standard in the years since EPA’s clean data determination (based on 2012-2014 data), as well as during and after the COVID-19 pandemic. In fact, the Valley experienced a higher number of exceedances in 2020/2021 as a result of California wildfires. Figure 8 displays acres burned statewide from 2013 to 2022.
The Valley’s ozone improvement is not attributable to a temporary economic downturn based on the provided analysis. The improvement in the Valley’s ozone levels can be attributed to the implementation of new rules in the years since the District attained the 1-hour ozone standard as well as enforcement of rules throughout the District over the past 10 years.
23 These were also the economic indicators used in analysis of Sacramento Metropolitan AQMD’s 1-hour ozone attainment request. See EPA’s proposed approval of their request at 76 FR 28696. Retrieved from:
http://www.gpo.gov/fdsys/pkg/FR-2011-05-18/pdf/2011-12063.pdf. 1065
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D.4 CONCLUSION
The District has continued to attain the 1-hour ozone standard through permanent and enforceable emission reductions. The Valley has achieved this through stringent District and CARB air quality rules and regulations. Despite the high temperature and drought in the Valley, the District has continued to attain the 1-hour ozone standard.
Additionally, attainment of the 1-hour ozone standard was not a result of temporary emission reductions such as an economic downturn. As previously mentioned, the District has continued to be in attainment despite the inconsistency in gasoline sales, VMT, the COVID-19 pandemic, and state-wide wildfires through the period. Therefore, attainment of the 1-hour ozone standard is due to permanent and enforceable emission reductions.
E. SECTION 110 AND PART D REQUIREMENTS
The District has met all 1-hour ozone SIP requirements for the purposes of redesignation under Section 110 of the CAA. In addition, EPA has approved the 2013 Ozone Plan as meeting Section 110 requirements and as meeting applicable requirements under Part D of Title I of CAA. No outstanding 1-hour ozone SIP submittals exist for the District.
F. MAINTENANCE PLAN
The EPA Office of Air Quality Planning and Standards (OAQPS) memorandum Procedures for Processing Requests to Redesignate Areas to Attainment24 (Calcagni Memo) also provides guidance of what is expected from a maintenance plan under existing policy. The core provisions of a maintenance plan are as follows:
Attainment Inventory
Identify the emission reductions sufficient to attain the NAAQS in the Valley. The inventory should be consistent with EPA’s most recent guidance on emission inventories for nonattainment areas available at the time and should include the emissions during the time period associated with the monitoring data showing attainment.
Maintenance Demonstration
Demonstrate maintenance of the NAAQS for another period of ten years following EPA redesignation to attainment by either:
o Showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory; or
o Modeling to show that the future mix of sources and emissions rates will not cause a violation of the NAAQS; and
24 Calcagni, John. Memorandum: Procedures for Processing Requests to Redesignate Areas to Attainment. (1992, September 8). United States Environmental Protection Agency Office of Air Quality Planning and Standards.
Retrieved from: https://www.epa.gov/ozone-pollution/procedures-processing-requests-redesignate-areas-attainment 1067
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o Show that emission rate projections are based on permanent, enforceable reductions.
Air Monitoring Network
Demonstrate that the state will continue to operate an appropriate air quality monitoring network to verify the attainment status of the area. Discuss provisions for continued operation of air quality monitors that will verify attainment.
Verification of Continued Attainment
Ensure that the state has the legal authority to implement and enforce all measures needed to maintain the NAAQS, including the acquisition of ambient and source emission data.
Show how continued maintenance of the standard will be tracked.
Contingency Plan
Verify implementation of emission control measures in the fully approved implementation plan.
Identify indicators and provisions to promptly correct any violation occurring after redesignation.
The maintenance plan constitutes a SIP revision. EPA has 18 months to act on the maintenance plan. For the purposes of the 2023 Maintenance Plan and Redesignation Request for the Revoked 1-Hour Ozone Standard, the District is assuming that EPA’s action would be complete sometime in the 2025/2026 timeframe. Since the maintenance plan must provide for continued attainment 10 years after designation, the District selected 2036 as the target maintenance year. The sections below address the District’s fulfillment of the maintenance plan requirements.
F.1 ATTAINMENT INVENTORY
An emissions inventory is a systematic listing of air pollution sources along with the amount of pollution emitted from each source or category over a given time period.
Emissions inventory data is used as a primary input to air quality modeling used in attainment demonstrations, developing control strategies, and provide a means to track progress in meeting the emission reduction commitments. Emissions inventories are an estimate of the air pollution emissions that are actually released into the environment— they are not measurements of ambient concentrations. The following are examples of pollution sources grouped by major industry sectors:
Industrial or stationary point sources – power plants and oil refineries Area-wide sources – consumer products and residential fuel combustion On-road sources – passenger vehicles and heavy-duty trucks Off-road mobile sources – aircraft, trains, ships, recreational boats, construction equipment and farm equipment
Non-anthropogenic (natural) sources – biogenic (or vegetation), geogenic (petroleum seeps), and wildfires
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Emissions Inventory
The emissions inventory for this maintenance plan was generated using the California Emission Projection Analysis Model (CEPAM) 2022, San Joaquin Valley PM2.5 Nonattainment Area - Version 1.00,
25 which is the most comprehensive and current
emission inventory for the Valley, and is consistent with EPA’s most recent guidance on emissions inventories.
CARB and the District have developed a comprehensive current emissions inventory consistent with the requirements set forth in Section 182(a)-(f) of the CAA26. CARB and District staff conducted a thorough review of the inventory to ensure that the emission estimates reflect accurate emissions reports for point sources and that estimates for mobile and areawide sources are based on the most recent approved models and methodologies. CARB also reviewed the growth profiles for point and areawide source categories and updated them as necessary to ensure that the emission projections are based on data that reflect historical trends, current conditions, and recent economic and demographic forecasts.
EPA regulations require that the emissions inventory contains emissions data for precursors; i.e. NOx and VOC27 for the formation of ozone. The inventory included substitutes VOC with reactive organic gases (ROG), which, in general, represent a slightly broader group of compounds than those in EPA’s list of VOCs.
CARB and the District are selecting 2017 as the planning inventory base year for this maintenance plan, and are using the California specific emissions inventory developed through CEPAM.
28 In selecting 2017 as the base year, CARB and the District relied on the Emission Inventory Guidance29, which allows agencies to consider the availability of data, the implementation of rule requirements, and consistency in the base year across planning and modeling inventories in choosing an appropriate baseline inventory year.
The Emission Inventory Guidance indicates that a common reason for choosing an alternate base year is the desire to have the base year for planning inventories be consistent with the base year for modeling inventories. For modeling purposes, 2019, 2020, and 2021 are not years with representative air quality suitable for modeling future air quality. Modeled attainment demonstrations are based on a five-year weighted design value centered around the base year inventory, giving the base year the most weight. To ensure the model is accurately predicting air quality, it is best to have the base year not be a year of extensive wildfires. Wildfires have become more intense in California. The two largest wildfire years on record occurred in 2020 and 2021. In the
25 Source: CEPAM 2022 – San Joaquin Valley PM2.5 Nonattainment Area - Version 1.00 26 Section 182(a)-(f) of the Act. https://www.govinfo.gov/content/pkg/USCODE-2013-title42/html/USCODE-2013- title42-chap85-subchapI-partD-subpart2-sec7511a.htm
27 Section 182(a)(1) of the Act. https://www.govinfo.gov/content/pkg/USCODE-2013-title42/html/USCODE-2013- title42-chap85-subchapI-partD-subpart2-sec7511a.htm
28 Criteria Pollutant and Emission Inventory Data. https://ww2.arb.ca.gov/criteria-pollutant-emission-inventory-data 29 EPA. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations. Retrieved from:
https://www.epa.gov/sites/default/files/2017-07/documents/ei guidance may 2017 final rev.pdf 1069
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Valley, these extensive wildfires impacted air quality throughout the Valley for months. 2020 and 2021 are also unusual, non-representative years due to COVID-19 impacts.
Furthermore, in 2020, Valley sites collected incomplete speciation data due to laboratory and monitoring site shutdowns because of the pandemic.
Additionally, CARB and the District prefer to use a National Emissions Inventory (NEI) year as the base year for the inventory, where the two most recent NEI years are 2020 and 2017. However, in 2020, the COVID-19 pandemic affected a range of industries economy-wide, making 2020 emissions atypical; therefore, 2020 is unsuitable for use as a base year for the inventory. Alternatively, the year 2017 did not experience any similar disruption and reflects typical emissions, while retaining the benefits of being an NEI year based on actual emissions data that has undergone quality assurance and quality control (QA/QC) evaluation by EPA.
Using 2017 as the base modeling year ensures that anthropogenic emissions are accurately reflected, speciation data are available and robust, and the model can more accurately reflect the impacts of control strategies; therefore, CARB and the District are using 2017 as the base modeling year. Selecting 2017 for the planning inventory base year would allow for more consistency across the planning and modeling inventories used in this maintenance plan.
Attainment Inventory
EPA requires maintenance plans to present the emissions inventory for the time period used to define attainment for a particular area (Calcagni Memo). As previously mentioned, EPA took final action to determine that the District attained the 1-hour ozone NAAQS through a clean data determination for the period 2012-2014. The final action in the Federal Register states that the District must also, “submit a demonstration that the area attained the revoked ozone NAAQS due to permanent and enforceable emission reductions and that the area will maintain the revoked NAAQS for 10 years.” Therefore, the District is submitting such a demonstration to fulfill these requirements for the 1-hour ozone NAAQS. Since the 2014 clean data determination, the District has continued to maintain the 1-hour ozone NAAQS as demonstrated in section B of the document.
The District has selected the year 2020 as its base year inventory for the 10 year maintenance demonstration (from the 2020-2022 attainment period), projected from the 2017 base year in CEPAM. Table 21 shows NOx emissions totaled 181.29 tons per day (tpd) in 2020, and the VOC emission inventory was 317.05 tpd, both of which are precursors to the formation of ozone. Notably, the emission inventory data reflects a “summer day” as required by EPA in the Calcagni Memo. Appendix A provides a detailed summary of the attainment inventory and projected inventory. 1070
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Figure 9 San Joaquin Valley NOx and VOC Trends
F.3 MONITORING NETWORK
Pursuant to Calcagni Memo requirements, the State shall continue to operate an appropriate air quality monitoring network, in accordance with 40 CFR 58, to verify the attainment status of the area. This maintenance plan contains provisions for continued operation of air quality monitors that will provide such verification.
The District operates and will continue to operate an extensive network of air quality monitors throughout the Valley to support its mission of improving and protecting public health. District staff uses the hourly readings from real-time monitors to communicate the state of the air quality to Valley residents. Through programs and venues such as the EPA AirNow tool, the daily air quality forecast, the District website, and Valley media, residents are able to obtain air quality information that can help them with their activity planning. The District also uses real-time air quality data to manage prescribed burning, agricultural burning, hazard reduction burning, and residential wood combustion to ensure these activities do not result in adverse air quality impacts.
As part of the District’s long-term efforts to improve public health, District staff rigorously analyze air monitoring data to ensure the data is of the highest quality. This air monitoring data determines the state of the Valley’s air quality and is fundamental in the Valley’s effort for continual improvement and to achieve attainment of EPA’s healthbased ambient air quality standards as quickly as possible. 1072
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As a part of this effort, the District and CARB manage the majority of the currently operating 37 air monitoring stations throughout the Valley, 25 of which measure ozone using EPA approved analyzers. The figure below provides a map of the ozone air monitoring stations operating in the Valley. Per requirements outlined in 40 CFR Part 58 Subpart B Section 58.10, the District conducts an assessment of its monitoring network every five years. The assessment includes reevaluating the effectiveness and efficiency of the District’s ozone air monitoring network.
Figure 10 Ozone Monitoring Sites within the Valley Air Basin 1073
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prompt correction of any post-redesignation NAAQS violations. As clarified in the Calcagni Memo, the contingency plan for a maintenance plan differs from that of an attainment plan. For the purposes of Section 175A, a State is not required to have fully adopted contingency measures that will take effect without further action by the State in order for the maintenance plan to be approved. The maintenance contingency plan should ensure that the contingency measures are adopted expediently once they are triggered. Maintenance plan contingencies should include specific triggers that will be used to determine when the contingency measures need to be implemented. Possible triggers are emissions inventory "action levels" or NAAQS violations (monitored or modeled) with a specific time limit for appropriate State actions, including a control measure adoption schedule and procedures for adoption and implementation.
The District is selecting an action level equivalent to the attainment test for the 1-hour ozone NAAQS of 124 ppb, where the action level would be triggered should any of the air monitoring sites average above 1.0 expected exceedances over a 3-year period of certified air monitoring data. Should the action level be reached, the District will evaluate the event and take appropriate action within 18 months following a monitored and certified violation of the NAAQS. Should this evaluation conclude that the ozone exceedances leading to a violation of the 1-hour ozone standard were due to impacts from exceptional events, the District will follow EPA’s Exceptional Events Initial Notification procedures to determine what documentation would need to be prepared for EPA review and approval.
However, if the air quality monitoring data indicates that the area has violated the 1-hour ozone NAAQS due to ozone readings not influenced by exceptional events as discussed above, the District and CARB commit to evaluating rules and adopting amendments where an opportunity is identified, including but not limited to the rules within Table 26 and Table 27. While EPA has not committed to reviewing federal mobile source measures as a component of contingency, the District and CARB will also continue to advocate for needed assistance and action from EPA to address federal mobile source emissions that contribute significant portions of Valley ozone precursor emissions (see Section G, below).
Since the implementation of potential contingency measures would not be expected to take place until well in the future, the identification of specific detailed measures is not practical. The most appropriate contingency measures may be significantly different from the measures mentioned below due to technological, economic, and other factors in the future.
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G. FEDERAL MOBILE SOURCE OPPORTUNITIES
The District has promulgated and implemented measures to reduce emissions from sources of air pollution under its regulatory authority. The District has also deployed innovative measures to reduce emissions from mobile and indirect sources of air pollution that fall outside its traditional regulatory authority with stationary sources.
CARB’s primary regulatory authority is the regulation of mobile sources of emissions.
Mobile sources are the largest contributor to criteria pollutant and air toxic emissions (e.g. diesel particulate matter) in the Valley and throughout the State. District and CARB efforts in developing and implementing emission reduction measures has contributed to the substantial improvements in Valley air quality, and will continue to do so in the future.
Although CARB has promulgated stringent mobile source measures for vehicles and fleets in California, emissions from interstate heavy-duty trucks, locomotives, and other federal mobile sources have not been reduced as significantly. To provide context on the make-up of the remaining sources of emissions in the Valley, mobile sources now account for over 80% of NOx emissions in the region, with statewide mobile source emissions under federal jurisdiction now surpassing those under California jurisdiction.
As the District and CARB’s ongoing efforts have significantly improved air quality in the San Joaquin Valley, it is becoming critically important for the EPA to be strong partners in reducing emissions in California and the Valley. The District and CARB are committed to continued partnership with EPA to identify opportunities to further reduce emissions from federal sources in the San Joaquin Valley.
H. SUMMARY CHECKLIST
As described in section B of the document, the air monitoring data provided demonstrates that the District continues to be in attainment of the 1-hour ozone NAAQS. Section C and E demonstrate that the District has met all applicable Section 110 requirements of the CAA. Additionally, the District shows in section D that the emission reductions achieved are permanent and enforceable.
Table 28 summarizes the status of the elements that need to be satisfied in order to meet CAA requirements for Section 175A as outlined in the Calcagni Memo. Sections F.1 and F.2 of the document demonstrates continued attainment of the 1-hr ozone NAAQS through 2036. Section F.3 commits the District to maintain the ongoing ozone air monitoring network. Section F.4 commits the District to verify continued attainment of the 1-hour ozone NAAQS by reviewing information and assumptions used for the emission inventory when new information becomes available. If the District finds that this information has changed significantly, the District will update the existing emissions inventory in coordination with CARB, evaluate the revised inventory against the inventories presented in this maintenance plan, and evaluate the potential impacts.
Section F.5 commits to establish a contingency plan that is triggered by a measured violation of the 1-hour ozone NAAQS.
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Emissions Inventory
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Analysis of Meteorology Affecting Ozone Levels
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1107
Fresno County 2023-2060
Growth Projections
Prepared by:
Fresno Council of Governments
Applied Development Economics, Inc
October 17, 2024
1108
1 TABLE OF CONTENTS
Executive Summary ..………………………………………………………………………..……. 3
2060 Growth Projection …………………………………………………….…………………….. 5 Introduction .…………..………………………………………………………………..……………. 5
Comparison to Prior Projections …………………………………………….…………………. 5 Population …………………………………………………………………….………………………. 6
Household .……………………………………………………………………………….………….. 7
Housing Units ……………………………………………………………………………..…………. 8
Age Group ……………………………………………………………………….……………………. 9
Ethnicity ………………………………………………………………………………………..…….. 10
School Enrollment …………………………………………………………..…………………….. 10 Household Income ……………………………………………………………………………….. 11
Employment …………………………………………………………………………………..…….. 12
Methodology …………………………………………………………………………………..…….….. 13
Detailed Projections ..…………………………………………………………………………..……14 Clovis and SOI ………………………………………………………………………………..…….. 14
Coalinga and SOI ..…..……………………………………………………………………..…….. 16 Firebaugh and SOI ...………………………………………………………………………..…….. 18 Fowler and SOI ……..………………………………………………………………………..…….. 20 Fresno and SOI ……….……………………………………………………………………..…….. 22
Huron and SOI ………………………………………………………………………………..…….. 24
Kerman and SOI ……………………………………………………………………………..…….. 26
Kingsburg and SOI …………………………………………………………………………..…….. 28 Mendota and SOI ……..……………………………………………………………………..…….. 30 Orange Cove and SOI ….…………………………………………………………………..…….. 32 Parlier and SOI ..……………………………………………………………………………..…….. 34 Reedley and SOI ……………………………………………………………………………..…….. 36
Sanger and SOI …………………….………………………………………………………..…….. 38
San Joaquin and SOI …..…………………………………………………………………..…….. 40 Selma and SOI ………………..……………………………………………………………..…….. 42
Unincorporated Areas (excl. SOIs) …...………………………………………………………. 44 1109
2 EXECUTIVE SUMMARY
INTRODUCTION
This report updates the growth projections for Fresno County and the spheres of influence of each of its cities previously published in 2020. The new projections utilize a base year of 2022.
This report developed by the Fresno Council of Governments (FCOG) is to assist with updating the Regional Transportation Plan (RTP) as well as the Sustainable Communities Strategies (SCS).
Applied Development Economics, Inc collaborated with Fresno COG staff to revise the county's projections to the 2022 to 2060 timeframe, using latest population estimation and projection from California Department of Finance(DOF), detailed demographics data from 2020 Census, and vital statistics in last decade.
In September 2024, the DOF Demographic Research Unit released the Population Projections, 2020-2070, indicating slower growth compared to earlier projections. The 2023 Baseline release (2024.09.23) suggests that Fresno County's population will be 7% lower in 2035 and 9% lower in 2050 than projected in 2019. FCOG staff has revised the county-level population projection to align with DOF’s most recent release.
The updated projection anticipate a population increase of 117,980 in Fresno County from 2022 to 2060, with the total population peaking at 1,131,120 in 2055 before declining to 1,128,530 by 2060.
Regarding job growth, the updated forecast predicts the addition of 77,170 wage and salary jobs in the county between 2022 and 2060, translating to an average annual growth of approximately 2,030 jobs over the 38-year period.
In addition to the population and employment projections, the report includes projections of demographic characteristics and housing demand, including the following:
• Households
• Average Household Size
• Group Quarters Population
• Average Income
• Housing
• House Unit Type
• Age Distribution
• Race/Ethnicity
• School Enrollment
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3 Table 1 – Population and Employment Projections by Jurisdiction Sphere of Influence Jurisdiction 2022 2025 2030 2035 2040 2045 2050 2055 2060 Total Population
County Total 1,010,550 1,017,950 1,041,670 1,066,610 1,090,820 1,111,570 1,125,490 1,131,120 1,128,530 Clovis SOI 126,960 129,050 136,500 142,490 148,310 153,300 156,650 158,000 157,380 Coalinga SOI 17,290 17,300 17,530 17,770 17,990 18,190 18,320 18,370 18,350 Firebaugh SOI 8,420 8,410 8,670 8,830 8,990 9,120 9,210 9,250 9,230 Fowler SOI 7,310 7,660 8,240 8,910 9,550 10,110 10,480 10,630 10,560 Fresno SOI (incl. county
islands) 592,280 595,370 605,800 617,840 629,520 639,540 646,260 648,980 647,730 Huron SOI 6,170 6,230 6,260 6,390 6,520 6,630 6,710 6,740 6,720 Kerman SOI 16,830 17,360 18,510 19,650 20,750 21,700 22,340 22,600 22,480 Kingsburg SOI 12,750 13,210 13,750 14,550 15,340 16,010 16,460 16,650 16,560 Mendota SOI 12,500 12,530 13,070 13,400 13,710 13,980 14,170 14,240 14,210 Orange Cove SOI 9,590 9,600 9,670 9,780 9,890 9,990 10,050 10,070 10,060 Parlier SOI 15,030 15,040 15,060 15,200 15,340 15,450 15,530 15,560 15,550 Reedley SOI 25,290 25,830 25,900 26,740 27,550 28,250 28,710 28,900 28,820 Sanger SOI 27,040 27,040 27,540 27,940 28,330 28,670 28,900 28,990 28,940 San Joaquin SOI 3,670 3,610 3,640 3,670 3,700 3,720 3,740 3,750 3,740 Selma SOI 26,540 26,650 28,250 29,150 30,030 30,790 31,290 31,490 31,400 Unincorporated Areas
(excl. SOIs) 102,880 103,050 103,280 104,290 105,280 106,120 106,680 106,910 106,800 Total Jobs
County Total 414,750 421,140 432,740 442,600 454,800 466,150 476,330 484,780 491,920 Clovis SOI 40,550 41,260 43,220 44,860 46,580 48,130 49,430 50,390 51,050 Coalinga SOI 5,010 5,020 5,100 5,170 5,250 5,320 5,380 5,420 5,460 Firebaugh SOI 2,230 2,160 2,320 2,450 2,590 2,720 2,840 2,950 3,050 Fowler SOI 3,990 4,190 4,390 4,680 5,000 5,290 5,590 5,810 6,010 Fresno SOI (incl. county
islands) 260,210 260,420 265,950 271,760 277,970 283,670 288,820 293,150 296,870 Huron SOI 1,080 1,140 1,170 1,230 1,280 1,340 1,390 1,430 1,460 Kerman SOI 4,320 4,560 4,860 5,160 5,470 5,760 5,990 6,170 6,280 Kingsburg SOI 5,240 5,320 5,580 5,880 6,210 6,500 6,760 6,970 7,140 Mendota SOI 1,830 1,820 1,960 2,060 2,160 2,250 2,330 2,390 2,430 Orange Cove SOI 960 970 990 1,020 1,050 1,080 1,100 1,120 1,130 Parlier SOI 2,550 2,540 2,610 2,700 2,790 2,880 2,970 3,040 3,100 Reedley SOI 8,120 8,400 8,520 8,800 9,100 9,370 9,610 9,800 9,940 Sanger SOI 9,800 9,720 10,050 10,340 10,660 10,960 11,240 11,480 11,700 San Joaquin SOI 650 630 640 650 660 670 680 690 690
Selma SOI 9,280 11,510 12,490 11,320 11,670 12,000 12,290 12,520 12,710 Unincorporated Areas
(excl. SOIs) 58,920 61,480 62,890 64,580 66,360 68,210 69,910 71,450 72,900 1111
4 1112
2060 GROWTH PROJECTIONS
POPULATION
Fresno County is projected to gain nearly 118,000 residents by 2060. The City of Fresno would experience the largest increase of 55,450 people, followed by Clovis with 30,420. In terms of growth rates, Fowler and Kerman are projected to see faster growth compared to other areas.
Jurisdiction 2022 2025 2030 2035 2040 2045 2050 2055 2060 2022-2060 change
2022-2060
annual
growth
rate
Fresno County 1,010,550 1,017,950 1,041,670 1,066,610 1,090,820 1,111,570 1,125,490 1,131,120 1,128,530 117,980 0.3% Clovis and SOI 126,960 129,050 136,500 142,490 148,310 153,300 156,650 158,000 157,380 30,420 0.6% Coalinga and SOI 17,290 17,300 17,530 17,770 17,990 18,190 18,320 18,370 18,350 1,050 0.2% Firebaugh and SOI 8,420 8,410 8,670 8,830 8,990 9,120 9,210 9,250 9,230 810 0.2% Fowler and SOI 7,310 7,660 8,240 8,910 9,550 10,110 10,480 10,630 10,560 3,250 1.0% Fresno and SOI (incl.
county islands) 592,280 595,370 605,800 617,840 629,520 639,540 646,260 648,980 647,730 55,450 0.2% Huron and SOI 6,170 6,230 6,260 6,390 6,520 6,630 6,710 6,740 6,720 560 0.2% Kerman and SOI 16,830 17,360 18,510 19,650 20,750 21,700 22,340 22,600 22,480 5,650 0.8% Kingsburg and SOI 12,750 13,210 13,750 14,550 15,340 16,010 16,460 16,650 16,560 3,810 0.7% Mendota and SOI 12,500 12,530 13,070 13,400 13,710 13,980 14,170 14,240 14,210 1,710 0.3% Orange Cove and SOI 9,590 9,600 9,670 9,780 9,890 9,990 10,050 10,070 10,060 470 0.1% Parlier and SOI 15,030 15,040 15,060 15,200 15,340 15,450 15,530 15,560 15,550 520 0.1% Reedley and SOI 25,290 25,830 25,900 26,740 27,550 28,250 28,710 28,900 28,820 3,520 0.3% Sanger and SOI 27,040 27,040 27,540 27,940 28,330 28,670 28,900 28,990 28,940 1,910 0.2% San Joaquin and SOI 3,670 3,610 3,640 3,670 3,700 3,720 3,740 3,750 3740 80 0.0% Selma and SOI 26,540 26,650 28,250 29,150 30,030 30,790 31,290 31,490 31,400 4,860 0.4% Unincorporated Areas
(excl. SOIs) 102,880 103,050 103,280 104,290 105,280 106,120 106,680 106,910 106,800 3,920 0.1% Table 2 – Total Population Projections by Jurisdiction, 2022-2060 1113
6 HOUSEHOLDS
As of 2022, there are 991,830 individuals living in households and 18,720 in group quarters, which include correctional facilities, dormitories, and nursing facilities. Fresno County had approximately 327,030 households in 2022, with an average household size of 3.03 people. The number of households in the county is expected to increase by 42,790, reaching a total of 369,820 by 2060. The average household size is projected to remain around 3.00.
Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household Size
2022 1,010,550 991,830 18,720 327,030 3.03
2025 1,017,950 999,150 18,800 331,990 3.01
2030 1,041,670 1,022,250 19,420 343,200 2.98
2035 1,066,610 1,047,050 19,560 351,590 2.98
2040 1,090,820 1,071,120 19,700 357,300 2.99
2045 1,111,570 1,091,630 19,940 362,970 3.00
2050 1,125,490 1,105,380 20,110 367,580 3.00
2055 1,131,120 1,110,930 20,190 370,670 2.99
2060 1,128,530 1,108,390 20,140 369,820 2.99
2022-2060 change 117,980 116,560 1,420 42,790
2022-2060 annual growth rate 0.3% 0.3% 0.2% 0.30%
Table 3 – Projections of Household and Group Quarters Populations Table 4 – Household Projections by Jurisdiction, 2022 - 2060 Jurisdiction 2022 2025 2030 2035 2040 2045 2050 2055 2060 2022-
2060
change
Fresno County 327,027 331,896 343,198 351,580 357,305 362,973 367,576 370,674 369,819 42,792 Clovis and SOI 45,318 46,841 49,705 51,888 53,645 55,264 56,470 57,149 56,924 11,607 Coalinga and SOI 4,304 4,372 4,517 4,660 4,760 4,812 4,859 4,890 4,883 579 Firebaugh and SOI 2,238 2,280 2,358 2,401 2,427 2,455 2,479 2,497 2,492 255 Fowler and SOI 2,271 2,421 2,614 2,825 3,009 3,173 3,289 3,348 3,326 1,055 Fresno and SOI (incl.
county islands) 195,577 197,366 203,870 207,914 210,426 213,059 215,297 216,928 216,511 20,934 Huron and SOI 1,588 1,635 1,647 1,682 1,705 1,728 1,747 1,761 1,757 169 Kerman and SOI 4,705 4,947 5,293 5,619 5,896 6,145 6,325 6,420 6,386 1,681 Kingsburg and SOI 4,441 4,692 4,899 5,187 5,430 5,650 5,809 5,893 5,863 1,422 Mendota and SOI 2,851 2,909 3,045 3,121 3,173 3,225 3,267 3,295 3,288 437 Orange Cove and SOI 2,439 2,480 2,506 2,535 2,546 2,562 2,578 2,593 2,590 151 Parlier and SOI 3,768 3,825 3,844 3,879 3,888 3,904 3,924 3,945 3,941 173 Reedley and SOI 7,244 7,506 7,549 7,793 7,976 8,150 8,285 8,368 8,343 1,099 Sanger and SOI 7,815 7,962 8,133 8,252 8,312 8,382 8,448 8,503 8,491 676 San Joaquin and SOI 902 913 922 929 930 934 938 943 942 39 Selma and SOI 7,614 7,809 8,303 8,569 8,768 8,958 9,104 9,195 9,167 1,553 Unincorporated Areas
(excl. SOIs) 33,951 33,938 33,992 34,324 34,414 34,573 34,756 34,947 34,913 962 1114
7 HOUSING UNITS
Considering population projections, household projections, vacant stock, and other factors such as healthy vacancy rates, overcrowding levels and residential replacement units, we anticipate a demand for 69,470 new residential units from 2022 to 2060. Based on statistics of new units constructed in the last decade, building permit information from the past 5 years , and the general plans of each city in Fresno County, we estimate that 49,900 (72 percent) will be single-family units, while the remaining 19,560 units (28 percent) will be multi-family dwellings.
Table 5 – Projected Market Demand for New Housing Units by Unit Building Type, 2022-2060
Jurisdiction New Units Demand
2022-2060
Single-family
Housing Units
Multi-family
Housing Units
County Total 69,470 49,900 19,560
Clovis SOI 12,700 10,740 1,960
Coalinga SOI 930 480 450
Firebaugh SOI 570 400 170
Fowler SOI 1,180 920 270
Fresno SOI (incl. county islands) 37,600 24,070 13,530
Huron SOI 620 240 390
Kerman SOI 2,620 2,330 290
Kingsburg SOI 1,630 1,200 440
Mendota SOI 1,350 1,190 160
Orange Cove SOI 580 330 240
Parlier SOI 650 500 150
Reedley SOI 1,990 1,250 740
Sanger SOI 1,620 1,140 480
San Joaquin SOI 220 210 10
Selma SOI 2,360 2,240 120
Unincorporated Areas (excl. SOIs) 2,850 2,690 160
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SCHOOL ENROLLMENT
In 2022, Fresno County is estimated to have approximately 220,496 school-aged children. This projection combines the school-aged youth population from Fresno COG’s estimates with the K-12 participation rate from the California Department of Finance (DOF). It anticipates that K-12 public school enrollment will decrease to 192,984 by 2050, which is 11,170 fewer than the 2022 enrollment figure of 204,154
Table 8 - Fresno County Public School Enrollment of School-Age Children Year Total School-Age Youth
(5 to 18)
K-12 Enrollment
Projections Participation Rate
2022 220,496 204,154 92.59%
2025 210,190 199,521 94.92%
2030 196,569 189,999 96.66%
2035 190,295 185,207 97.33%
2040 196,001 192,689 98.31%
2045 200,145 197,717 98.79%
2050 201,629 199,182 98.79%
2055 198,102 195,699 98.79%
2060 195,354 192,984 98.79%
2022-2060 change -25,141 -11,170
2022-2060 annual
growth rate
-0.32% -0.15%
HOUSEHOLD INCOME
The income projection indicates a steady increase in average household income over the coming decades. The projected average household incomes declines in 2022 to 2024, then recover in 2026. The growth accelerates in subsequent years, reaching approximately $102,970 by 2035. By 2060, the average household income is projected to reach $128,920, demonstrating consistent growth throughout the period. Overall, this projection suggests a positive economic outlook for households, with an overall increase of nearly $34,490 from 2022 to 2060.
2022 2025 2030 2035 2040 2045 2050 2055 2060
Mean Household Income
(In 2022 Dollar) $94,430 $93,570 $97,840 $102,970 $108,650 $114,230 $119,440 $124,150 $128,920 Annual Growth Rate -0.30% 0.90% 1.03% 1.08% 1.01% 0.90% 0.78% 0.76% Table 9 - Fresno County Household Income Projection
1118
11 EMPLOYMENT
The total employment have recovered to the pre-pandemic level since fall of 2022. Total jobs in Fresno County are projected to increase by 77,170 jobs, from 414,750 in 2022 to 491,920 in 2060. This reflects a 0.45 percent compound annual growth rate (CAGR) over the entire period.
The industrial sector is projected to have the highest growth rate.
Table 10 - Fresno County Employment Projections by Sector, 2022-2060 Table 11 – Employment Projections by Jurisdiction, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 68,200 67,870 71,460 74,920 78,790 82,460 86,330 90,300 94,570 Retail 39,390 39,800 41,200 42,400 43,300 44,200 44,800 45,100 45,300 Office 50,350 50,800 52,400 54,200 56,200 58,000 59,700 61,300 62,800 Education 38,880 39,190 40,180 41,060 42,040 42,810 43,390 43,570 43,460 Health/Medical 75,170 75,780 76,960 78,250 79,540 80,630 81,420 81,810 81,800 Services 18,700 19,000 20,000 20,950 21,950 22,750 23,350 23,750 23,750 Food 32,360 32,710 33,420 34,380 35,090 35,800 36,320 36,630 36,740 Other 67,250 71,200 71,800 70,600 71,400 72,500 73,500 74,500 75,500 Government 24,450 24,800 25,300 25,900 26,500 27,000 27,500 27,800 28,000 Total 414,750 421,150 432,720 442,660 454,810 466,150 476,310 484,760 491,920 Total Annual
Growth Rate 0.51% 0.54% 0.46% 0.54% 0.49% 0.43% 0.35% 0.29% Jurisdiction 2022 2025 2030 2035 2040 2045 2050 2055 2060 2022 Share
2060
Share
County Total 414,750 421,140 432,740 442,600 454,800 466,150 476,330 484,780 491,920 100.00% 100.00% Clovis SOI 40,550 41,260 43,220 44,860 46,580 48,130 49,430 50,390 51,050 9.8% 9.8% Coalinga SOI 5,010 5,020 5,100 5,170 5,250 5,320 5,380 5,420 5,460 1.2% 1.2% Firebaugh SOI 2,230 2,160 2,320 2,450 2,590 2,720 2,840 2,950 3,050 0.5% 0.5% Fowler SOI 3,990 4,190 4,390 4,680 5,000 5,290 5,590 5,810 6,010 1.0% 1.0% Fresno SOI (incl.
county islands) 260,210 260,420 265,950 271,760 277,970 283,670 288,820 293,150 296,870 62.7% 61.8% Huron SOI 1,080 1,140 1,170 1,230 1,280 1,340 1,390 1,430 1,460 0.3% 0.3% Kerman SOI 4,320 4,560 4,860 5,160 5,470 5,760 5,990 6,170 6,280 1.0% 1.1% Kingsburg SOI 5,240 5,320 5,580 5,880 6,210 6,500 6,760 6,970 7,140 1.3% 1.3% Mendota SOI 1,830 1,820 1,960 2,060 2,160 2,250 2,330 2,390 2,430 0.4% 0.4% Orange Cove SOI 960 970 990 1,020 1,050 1,080 1,100 1,120 1,130 0.2% 0.2% Parlier SOI 2,550 2,540 2,610 2,700 2,790 2,880 2,970 3,040 3,100 0.6% 0.6% Reedley SOI 8,120 8,400 8,520 8,800 9,100 9,370 9,610 9,800 9,940 2.0% 2.0% Sanger SOI 9,800 9,720 10,050 10,340 10,660 10,960 11,240 11,480 11,700 2.4% 2.3% San Joaquin SOI 650 630 640 650 660 670 680 690 690 0.2% 0.1% Selma SOI 9,280 11,510 12,490 11,320 11,670 12,000 12,290 12,520 12,710 2.2% 2.7% Unincorporated
Areas (excl. SOIs) 58,920 61,480 62,890 64,580 66,360 68,210 69,910 71,450 72,900 14.2% 14.6% 1119
12 METHODOLOGY
The study process began by developing a range of total population and employment projections for the county as a whole, reflecting varying assumptions about Fresno County’s future share of regional growth as well as trends in industry growth. The employment projection methodology used an economic base approach, forecasting export industry sectors, while local serving business sectors follow growth in the economic base and in the population.
This report consulted a variety of data sources on employment, population and demographic data. A brief description of these sources is provided below. A more complete description of the underlying methodology may be found in the Fresno COG Projections 2015-2050 Report published in 2017.
CA Employment Development Department (EDD). Data includes historical labor force and wage and salary jobs by industry from the Census of Employment and Wages (CEW). This report used the 2022 countywide figures as the baseline for employment projections and the Fresno COG SOI data as the baseline for city projections.
CA Department of Finance (DOF). This report utilizes the total population estimates for 2022 and 2023 from the DOF as the baseline for our population projections. We adjusted our forecast to align with the most recent DOF projections(Sep. 2024) for Fresno county.
Additionally, we incorporated DOF’s historical estimates related to population and housing into our forecast.
Decennial Census & American Community Survey (ACS)
We gathered 2020 Census Decennial population data by age, sex and race at city-level. And information on vacancy rate and overcrowding rate was obtained from 2018-2022 5-year ACS, while average household income was sourced from 2022 1-year ACS.
Woods and Poole (W&P)
W&P is an independent economic forecasting firm that provides projections for all counties in the U.S. based on an econometric model that forecasts US economic conditions and creates state, regional and county forecasts based on changing conditions. The 2023 -2060 projections including population, employment by major industry and a number of other economic indicators. W&P uses the U.S. Bureau of Economic Analysis (BEA) definition of employment which includes self-employed and other non-employer jobs. The job figures therefore are always higher than wage and salary employment, but the growth rates provide a good basis for projected economic growth in the county.
Wide-ranging ONline Data for Epidemiologic Research (CDC WONDER).
An essential component of the population cohort survival model we applied for projecting future population was birth and death rate data. We derived race- and age-specific birth rates from the CDC WONDER database. For the mortality rates, we generated sex-, race-, and agespecific rates from the same database and adjusted them to reflect pre-COVID levels. 1120
13 DETAILED PROJECTIONS
The following sections provide the detailed projections for each jurisdiction. All data reflect the sphere of influence (SOI) for each jurisdiction.
14 Clovis and SOI
Table 12 – Population Projection for Clovis SOI, 2022-2060 Table 13 – Job Projection for Clovis SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 3,910 3,890 4,090 4,290 4,510 4,710 4,930 5,150 5,390 Retail 6,920 7,050 7,290 7,540 7,800 8,060 8,270 8,430 8,570 Office 4,170 4,280 4,950 5,260 5,600 5,830 5,960 5,960 5,850 Education 4,830 4,900 5,090 5,270 5,460 5,630 5,780 5,880 5,940 Health/Medical 7,390 7,510 7,720 7,950 8,180 8,390 8,580 8,720 8,830 Services 2,490 2,550 2,720 2,880 3,050 3,200 3,320 3,420 3,460 Food 5,710 5,810 6,000 6,220 6,430 6,630 6,810 6,950 7,050 Other 3,650 3,760 3,790 3,840 3,880 3,940 3,990 4,050 4,100 Government 1,480 1,510 1,560 1,620 1,670 1,730 1,780 1,820 1,860 Total 40,550 41,260 43,220 44,860 46,580 48,130 49,430 50,390 51,050 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 126,960 126,530 430 45,318 2.79
2025 129,050 128,620 430 46,841 2.78
2030 136,500 136,020 480 49,705 2.77
2035 142,490 142,000 490 51,888 2.76
2040 148,310 147,800 510 53,645 2.77
2045 153,300 152,770 530 55,264 2.78
2050 156,650 156,100 550 56,470 2.78
2055 158,000 157,450 550 57,149 2.76
2060 157,380 156,830 550 56,924 2.75
2022-2060 change 30,420 30,300 120 11,607
2022-2060 annual growth
rate 0.57% 0.57% 0.65% 0.60%
1121
15 Table 14 – Housing Unit Projection for Clovis SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 2,057 1,760 297
2022-2030 5,082 4,348 733
2022-2035 7,382 6,291 1,091
2022-2040 9,238 7,847 1,391
2022-2045 10,948 9,276 1,672
2022-2050 12,220 10,338 1,881
2022-2055 12,936 10,936 2,000
2022-2060 12,699 10,738 1,961
Table 15 – Population Projection for Clovis SOI by Age, 2022-2060 Table 16 – Population Projection for Clovis SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 126,960 129,054 136,500 142,494 148,314 153,303 156,648 158,002 157,381 30,420 0.6% 100.0% 100.0% 5 and below 9,330 9,401 9,974 10,590 11,157 11,226 10,921 10,688 10,634 1,304 0.3% 7.3% 6.8% 6 to 14 16,949 15,828 14,834 15,350 16,076 17,030 17,421 16,983 16,634 -315 0.0% 13.4% 10.6% 15 to 19 9,676 9,858 9,701 8,427 8,774 9,051 9,571 9,884 9,805 129 0.0% 7.6% 6.2% 20 to 24 8,284 9,132 10,212 9,955 8,656 9,000 9,227 9,662 9,757 1,473 0.4% 6.5% 6.2% 25 to 34 16,041 15,849 17,585 20,130 20,928 19,309 18,172 18,520 18,555 2,513 0.4% 12.6% 11.8% 35 to 44 17,535 17,495 16,996 16,694 18,371 21,018 21,680 19,685 18,975 1,440 0.2% 13.8% 12.1% 45 to 54 15,063 15,622 17,550 18,207 17,536 17,214 18,810 21,177 21,533 6,470 0.9% 11.9% 13.7% 55 to 64 14,130 14,080 14,450 15,724 17,524 18,159 17,346 16,758 16,814 2,684 0.5% 11.1% 10.7% 65 to 74 11,685 12,080 13,115 13,242 13,499 14,698 16,271 16,574 16,247 4,562 0.9% 9.2% 10.3% 75 and above 8,267 9,708 12,083 14,175 15,792 16,598 17,228 18,071 18,427 10,159 2.13% 6.51% 11.71% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 126,960 129,054 136,500 142,494 148,314 153,303 156,648 158,002 157,381 30,420 0.6% 100.0% 100.0% White alone, NH 62,082 62,150 63,958 64,834 65,465 65,691 65,308 64,268 63,450 1,368 0.1% 48.9% 40.3% Hispanic or Latino 38,395 39,807 43,611 47,197 50,861 54,297 57,138 59,186 59,533 21,138 1.2% 30.2% 37.8% Black or African
American alone, NH 2,981 3,017 3,173 3,293 3,407 3,497 3,557 3,588 3,577 596 0.5% 2.3% 2.3% Asian alone, NH 15,627 16,084 17,290 18,277 19,237 20,088 20,710 21,041 21,001 5,374 0.8% 12.3% 13.3% Native Hawaiian and
Other Pacific Islander
alone, NH
275 277 287 292 295 294 287 273 265 -11 -0.1% 0.2% 0.2% American Indian and
Alaska Native alone,
NH
793 803 843 870 886 893 889 872 860 66 0.2% 0.6% 0.5%
Some Other Race
alone, NH 698 706 739 773 815 850 868 866 857 159 0.5% 0.6% 0.5% Two or more races,
NH 6,108 6,210 6,600 6,957 7,347 7,693 7,891 7,908 7,838 1,730 0.7% 4.8% 5.0% 1122
16 Coalinga and SOI
Table 17 – Population Projection for Coalinga SOI, 2022-2060 Table 18 – Job Projection for Coalinga SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 260 260 270 280 300 310 330 340 360
Retail 320 320 330 330 340 340 340 340 340
Office 200 180 180 180 190 200 210 240 280
Education 1,140 1,150 1,170 1,180 1,200 1,210 1,210 1,210 1,190 Health/Medical 450 450 460 460 460 470 470 460 460
Services 40 40 40 40 50 50 50 50 50
Food 260 260 260 270 270 270 270 270 270
Other 250 260 260 270 270 270 280 280 290
Government 2,080 2,100 2,120 2,150 2,180 2,200 2,220 2,220 2,220 Total 5,010 5,020 5,100 5,170 5,250 5,320 5,380 5,420 5,460 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 17,290 12,780 4,510 4,304 2.97
2025 17,300 12,780 4,520 4,372 2.94
2030 17,530 13,160 4,370 4,517 2.93
2035 17,770 13,580 4,190 4,660 2.93
2040 17,990 13,960 4,030 4,760 2.95
2045 18,190 14,160 4,030 4,812 2.95
2050 18,320 14,300 4,020 4,859 2.95
2055 18,370 14,340 4,030 4,890 2.94
2060 18,350 14,320 4,030 4,883 2.93
2022-2060 change 1,060 1,550 -490 579
2022-2060 annual growth
rate 0.16% 0.30% -0.30% 0.33%
1123
17 Table 19 – Housing Unit Projection for Coalinga SOI, 2022-2060 Table 20 – Population Projection for Coalinga SOI by Age, 2022-2060 Table 21 – Population Projection for Coalinga SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 17,294 17,299 17,534 17,767 17,993 18,187 18,317 18,370 18,345 1,051 0.2% 100.0% 100.0% 5 and below 1,073 1,089 1,122 1,170 1,172 1,151 1,126 1,137 1,148 75 0.2% 6.2% 6.3% 6 to 14 1,977 1,757 1,614 1,646 1,727 1,785 1,782 1,750 1,738 -239 -0.3% 11.4% 9.5% 15 to 19 1,073 1,121 1,031 892 905 953 1,012 1,019 1,011 -63 -0.2% 6.2% 5.5% 20 to 24 1,209 1,095 1,112 1,027 895 914 967 1,027 1,035 -174 -0.4% 7.0% 5.6% 25 to 34 3,209 2,955 2,322 2,181 2,133 1,937 1,838 1,916 1,956 -1,253 -1.3% 18.6% 10.7% 35 to 44 2,908 3,041 3,246 2,883 2,295 2,189 2,165 1,976 1,886 -1,021 -1.1% 16.8% 10.3% 45 to 54 2,031 2,196 2,571 2,926 3,160 2,845 2,296 2,205 2,225 194 0.2% 11.7% 12.1% 55 to 64 2,060 1,923 1,867 2,039 2,412 2,780 3,037 2,742 2,497 437 0.5% 11.9% 13.6% 65 to 74 1,153 1,417 1,691 1,649 1,623 1,807 2,159 2,493 2,620 1,468 2.2% 6.7% 14.3% 75 and above 601 705 958 1,354 1,671 1,826 1,935 2,104 2,229 1,628 3.51% 3.47% 12.15% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 17,294 17,299 17,534 17,767 17,993 18,187 18,317 18,370 18,345 1,051 0.2% 100.0% 100.0% White alone, NH 4,717 4,615 4,481 4,325 4,160 3,989 3,810 3,631 3,557 -1,160 -0.7% 27.3% 19.4% Hispanic or Latino 11,069 11,200 11,604 12,033 12,474 12,883 13,236 13,513 13,581 2,512 0.5% 64.0% 74.0% Black or African
American alone, NH 607 592 563 533 503 474 446 420 409 -198 -1.0% 3.5% 2.2% Asian alone, NH 362 362 366 367 359 357 358 359 358 -4 0.0% 2.1% 2.0% Native Hawaiian and
Other Pacific Islander
alone, NH
24 24 23 22 21 20 19 18 17 -8 -1.0% 0.1% 0.1%
American Indian and
Alaska Native alone,
NH
110 106 100 94 87 81 72 64 61 -49 -1.6% 0.6% 0.3%
Some Other Race
alone, NH 65 63 60 56 53 50 47 44 42 -23 -1.1% 0.4% 0.2% Two or more races,
NH 340 338 338 337 336 334 329 323 320 -19 -0.2% 2.0% 1.7% Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 348 157 191
2022-2030 512 231 281
2022-2035 675 320 354
2022-2040 788 388 400
2022-2045 847 427 420
2022-2050 900 461 439
2022-2055 935 484 451
2022-2060 927 479 448
1124
18 Firebaugh and SOI
Table 22 – Population Projection for Firebaugh SOI, 2022-2060 Table 23 – Job Projection for Firebaugh SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 1,310 1,300 1,370 1,430 1,510 1,580 1,650 1,720 1,800 Retail 100 90 100 110 110 120 120 130 130
Office 60 10 30 50 80 100 110 110 100
Education 270 270 290 300 310 330 340 350 360
Health/Medical 130 130 140 150 150 160 160 170 170
Services 50 50 60 60 70 70 80 80 80
Food 100 100 110 110 120 120 130 130 140
Other 140 140 140 150 150 150 150 150 160
Government 80 70 80 80 90 90 100 100 100
Total 2,230 2,160 2,320 2,450 2,590 2,720 2,840 2,950 3,050 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 8,420 8,400 20 2,238 3.75
2025 8,410 8,400 10 2,280 3.71
2030 8,670 8,660 10 2,358 3.70
2035 8,830 8,820 10 2,401 3.69
2040 8,990 8,970 20 2,427 3.70
2045 9,120 9,100 20 2,455 3.72
2050 9,210 9,190 20 2,479 3.71
2055 9,250 9,230 20 2,497 3.70
2060 9,230 9,210 20 2,492 3.69
2022-2060 change 810 810 0 255
2022-2060 annual growth
rate 0.24% 0.24% 0.00% 0.28%
1125
19 Table 24 – Housing Unit Projection for Firebaugh SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 328 217 110
2022-2030 418 277 141
2022-2035 468 314 154
2022-2040 498 337 160
2022-2045 530 364 166
2022-2050 557 386 171
2022-2055 578 403 175
2022-2060 573 399 174
Table 25 – Population Projection for Firebaugh SOI by Age, 2022-2060 Table 26 – Population Projection for Firebaugh SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 8,417 8,413 8,671 8,831 8,987 9,120 9,209 9,246 9,229 812 0.2% 100.0% 100.0% 5 and below 692 676 727 773 777 747 707 679 679 -13 -0.1% 8.2% 7.4% 6 to 14 1,376 1,201 1,055 1,026 1,097 1,146 1,130 1,077 1,049 -327 -0.7% 16.3% 11.4% 15 to 19 762 779 685 595 542 579 627 631 624 -139 -0.5% 9.1% 6.8% 20 to 24 695 726 769 668 583 535 574 621 624 -71 -0.3% 8.3% 6.8% 25 to 34 1,206 1,253 1,334 1,445 1,387 1,218 1,096 1,089 1,119 -87 -0.2% 14.3% 12.1% 35 to 44 975 970 1,121 1,196 1,265 1,386 1,342 1,183 1,091 116 0.3% 11.6% 11.8% 45 to 54 916 903 900 916 1,051 1,133 1,210 1,330 1,357 441 1.0% 10.9% 14.7% 55 to 64 915 903 835 824 814 839 972 1,049 1,065 150 0.4% 10.9% 11.5% 65 to 74 527 629 769 771 710 709 705 731 781 254 1.0% 6.3% 8.5% 75 and above 353 373 477 618 761 829 846 856 840 487 2.31% 4.19% 9.10% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 8,417 8,413 8,671 8,831 8,987 9,120 9,209 9,246 9,229 812 0.2% 100.0% 100.0% White alone, NH 522 506 496 484 475 467 462 449 443 -79 -0.4% 6.2% 4.8% Hispanic or Latino 7,786 7,804 8,075 8,245 8,409 8,554 8,658 8,715 8,708 922 0.3% 92.5% 94.4% Black or African
American alone, NH 30 28 25 22 19 16 14 12 11 -19 -2.6% 0.4% 0.1% Asian alone, NH 16 15 14 13 12 10 9 7 7 -9 -2.3% 0.2% 0.1% Native Hawaiian and
Other Pacific Islander
alone, NH
3 3 3 2 2 2 2 1 1 -2 -2.2% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
3 3 3 2 2 2 1 1 0 -3 -5.4% 0.0% 0.0%
Some Other Race
alone, NH 27 26 30 38 46 49 47 46 45 17 1.3% 0.3% 0.5%
Two or more races,
NH 30 28 26 24 22 20 17 15 14 -16 -2.0% 0.4% 0.2%
1126
20 Fowler and SOI
Table 27 – Population Projection for Fowler SOI, 2022-2060 Table 28 – Job Projection for Fowler SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 1,260 1,320 1,380 1,500 1,640 1,780 1,920 2,060 2,200 Retail 130 140 150 160 170 180 200 210 220
Office 310 370 440 510 590 640 650 630 580
Education 330 340 350 360 370 380 390 400 410
Health/Medical 380 380 390 410 430 450 480 500 520
Services 70 80 80 90 100 110 120 130 140
Food 220 240 260 290 320 350 400 430 460
Other 1,240 1,270 1,280 1,300 1,310 1,330 1,350 1,370 1,390 Government 50 50 60 60 70 70 80 80 90
Total 3,990 4,190 4,390 4,680 5,000 5,290 5,590 5,810 6,010 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 7,310 7,250 60 2,271 3.19
2025 7,660 7,600 60 2,421 3.21
2030 8,240 8,180 60 2,614 3.18
2035 8,910 8,840 70 2,825 3.18
2040 9,550 9,480 70 3,009 3.19
2045 10,110 10,030 80 3,173 3.19
2050 10,480 10,400 80 3,289 3.18
2055 10,630 10,550 80 3,348 3.16
2060 10,560 10,480 80 3,326 3.15
2022-2060 change 3,250 3,230 20 1,055
2022-2060 annual growth
rate 0.97% 0.97% 0.76% 1.01%
1127
21 Table 29 – Housing Unit Projection for Fowler SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 215 206 10
2022-2030 422 403 19
2022-2035 647 578 69
2022-2040 844 714 130
2022-2045 1,019 819 200
2022-2050 1,143 893 250
2022-2055 1,205 931 275
2022-2060 1,182 917 266
Table 30 – Population Projection for Fowler SOI by Age, 2022-2060 Table 31 – Population Projection for Fowler SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 7,306 7,658 8,245 8,909 9,555 10,108 10,479 10,629 10,560 3,254 1.0% 100.0% 100.0% 5 and below 528 560 633 715 775 776 762 751 746 217 0.9% 7.2% 7.1% 6 to 14 1,013 948 859 974 1,086 1,198 1,225 1,182 1,155 142 0.3% 13.9% 10.9% 15 to 19 628 624 619 481 556 612 678 701 685 57 0.2% 8.6% 6.5% 20 to 24 518 628 652 650 504 579 630 685 696 178 0.8% 7.1% 6.6% 25 to 34 922 904 1,149 1,371 1,395 1,231 1,132 1,234 1,253 331 0.8% 12.6% 11.9% 35 to 44 987 1,045 1,011 985 1,253 1,483 1,480 1,266 1,168 182 0.4% 13.5% 11.1% 45 to 54 920 967 1,034 1,124 1,089 1,052 1,315 1,508 1,529 609 1.3% 12.6% 14.5% 55 to 64 798 823 925 1,005 1,078 1,162 1,102 1,035 1,096 299 0.8% 10.9% 10.4% 65 to 74 588 672 753 802 903 973 1,025 1,071 1,042 454 1.5% 8.1% 9.9% 75 and above 403 487 610 800 917 1,041 1,130 1,196 1,190 787 2.89% 5.52% 11.26% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 7,306 7,658 8,245 8,909 9,555 10,108 10,479 10,629 10,560 3,254 1.0% 100.0% 100.0% White alone, NH 1,246 1,268 1,297 1,335 1,371 1,393 1,393 1,354 1,323 77 0.2% 17.1% 12.5% Hispanic or Latino 4,881 5,161 5,645 6,192 6,731 7,205 7,543 7,731 7,712 2,831 1.2% 66.8% 73.0% Black or African
American alone, NH 94 98 104 113 121 128 134 138 137 43 1.0% 1.3% 1.3% Asian alone, NH 926 969 1,035 1,105 1,168 1,211 1,234 1,235 1,223 297 0.7% 12.7% 11.6% Native Hawaiian and
Other Pacific Islander
alone, NH
0 0 0 0 0 0 0 0 0 0 NA 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
28 29 30 31 31 31 31 29 28 0 0.0% 0.4% 0.3%
Some Other Race
alone, NH 41 42 42 42 41 39 36 33 31 -10 -0.8% 0.6% 0.3% Two or more races,
NH 89 91 92 92 91 100 106 109 105 16 0.4% 1.2% 1.0%
1128
22 Fresno and SOI
Table 32 – Population Projection for Fresno SOI, 2022-2060 Table 33 –Job Projection for Fresno SOI by Sector, 2022-2060 The projection for Fresno SOI contains approximately 38,000 population of county islands.
Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 40,480 40,240 42,380 44,400 46,650 48,790 51,040 53,360 55,850 Retail 25,660 25,820 26,240 26,650 27,050 27,440 27,640 27,650 27,600 Office 39,760 38,630 39,250 40,170 41,220 42,320 43,630 45,200 46,990 Education 23,700 23,810 24,260 24,640 25,080 25,390 25,580 25,530 25,310 Health/Medical 59,070 59,340 59,890 60,510 61,120 61,570 61,780 61,680 61,280 Services 13,400 13,560 14,180 14,730 15,330 15,790 16,100 16,270 16,170 Food 21,580 21,720 22,040 22,430 22,740 23,040 23,220 23,260 23,170 Other 18,950 19,500 19,670 19,900 20,120 20,430 20,710 20,990 21,280 Government 17,620 17,800 18,040 18,350 18,660 18,890 19,110 19,200 19,210 Total 260,210 260,420 265,950 271,760 277,970 283,670 288,820 293,150 296,870 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 592,280 581,180 11,100 195,577 2.97
2025 595,370 584,200 11,170 197,366 2.97
2030 605,800 594,040 11,760 203,870 2.93
2035 617,840 605,820 12,020 207,914 2.93
2040 629,520 617,280 12,240 210,426 2.94
2045 639,540 627,100 12,440 213,059 2.95
2050 646,260 633,690 12,570 215,297 2.95
2055 648,980 636,360 12,620 216,928 2.94
2060 647,730 635,130 12,600 216,511 2.93
2022-2060 change 55,450 53,960 1,490 20,934
2022-2060 annual growth
rate 0.24% 0.23% 0.33% 0.27%
1129
23 Table 34 – Housing Unit Projection for Fresno SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 16,282 11,704 4,578
2022-2030 23,527 16,912 6,615
2022-2035 28,025 19,546 8,478
2022-2040 30,823 20,999 9,824
2022-2045 33,758 22,328 11,430
2022-2050 36,247 23,454 12,793
2022-2055 38,062 24,276 13,786
2022-2060 37,598 24,066 13,532
Table 35 – Population Projection for Fresno SOI by Age, 2022-2060 Table 36 – Population Projection for Fresno SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 592,284 595,370 605,799 617,835 629,523 639,541 646,258 648,977 647,729 55,446 0.2% 100.0% 100.0% 5 and below 50,339 50,435 50,503 49,991 49,602 49,017 48,381 48,006 47,853 -2,485 -0.1% 8.5% 7.4% 6 to 14 83,674 78,940 74,001 74,963 74,735 74,451 73,722 72,455 71,815 -11,859 -0.4% 14.1% 11.1% 15 to 19 44,581 45,921 44,807 40,135 41,456 41,505 41,323 40,874 40,493 -4,088 -0.3% 7.5% 6.3% 20 to 24 43,761 42,490 45,072 44,337 39,906 41,321 41,314 40,976 40,705 -3,055 -0.2% 7.4% 6.3% 25 to 34 92,318 89,311 84,116 85,600 88,148 83,441 80,469 81,495 81,087 -11,231 -0.3% 15.6% 12.5% 35 to 44 78,821 83,345 87,265 85,896 81,952 84,005 86,589 81,535 79,576 755 0.0% 13.3% 12.3% 45 to 54 61,597 62,907 70,551 79,196 83,985 83,238 79,506 81,094 82,316 20,719 0.8% 10.4% 12.7% 55 to 64 59,394 57,861 55,726 57,763 65,689 74,233 78,777 77,603 75,365 15,971 0.6% 10.0% 11.6% 65 to 74 46,361 48,515 50,411 49,529 48,397 50,623 57,734 64,847 66,891 20,529 1.0% 7.8% 10.3% 75 and above 31,438 35,644 43,348 50,425 55,652 57,705 58,443 60,092 61,630 30,192 1.79% 5.31% 9.51% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 592,284 595,370 605,799 617,835 629,523 639,541 646,258 648,977 647,729 55,446 0.2% 100.0% 100.0% White alone, NH 142,319 138,680 133,694 128,622 123,246 117,925 112,940 108,406 106,482 -35,837 -0.8% 24.0% 16.4% Hispanic or Latino 303,595 309,286 322,138 336,621 351,117 364,132 374,287 381,156 382,314 78,718 0.6% 51.3% 59.0% Black or African
American alone, NH 38,479 38,450 38,679 39,067 39,529 39,977 40,293 40,404 40,318 1,839 0.1% 6.5% 6.2% Asian alone, NH 82,027 83,086 85,155 87,008 88,707 90,298 91,559 92,229 92,126 10,099 0.3% 13.8% 14.2% Native Hawaiian and
Other Pacific Islander
alone, NH
810 818 830 837 841 842 837 824 817 7 0.0% 0.1% 0.1%
American Indian and
Alaska Native alone,
NH
3,886 3,864 3,856 3,842 3,818 3,771 3,691 3,583 3,528 -358 -0.3% 0.7% 0.5% Some Other Race
alone, NH 3,183 3,200 3,248 3,309 3,374 3,436 3,473 3,466 3,445 262 0.2% 0.5% 0.5% Two or more races,
NH 17,984 17,985 18,198 18,529 18,892 19,161 19,179 18,910 18,699 715 0.1% 3.0% 2.9% 1130
24 Huron and SOI
Table 37 – Population Projection for Huron SOI, 2022-2060 Table 38 – Job Projection for Huron SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 250 250 260 270 290 300 310 330 340
Retail 90 90 100 110 120 130 140 150 160
Office 10 40 30 40 50 60 60 40 30
Education 20 20 20 20 20 20 20 30 30
Health/Medical 100 100 110 120 130 140 150 160 170
Services 10 10 10 10 10 10 20 20 20
Food 10 10 10 10 10 10 10 10 10
Other 570 580 590 600 600 610 620 630 640
Government 40 40 50 50 60 60 70 70 80
Total 1,080 1,140 1,170 1,230 1,280 1,340 1,390 1,430 1,460 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 6,170 6,170 0 1,588 3.89
2025 6,230 6,230 0 1,635 3.85
2030 6,260 6,260 0 1,647 3.81
2035 6,390 6,390 0 1,682 3.81
2040 6,520 6,520 0 1,705 3.84
2045 6,630 6,630 0 1,728 3.85
2050 6,710 6,710 0 1,747 3.85
2055 6,740 6,740 0 1,761 3.83
2060 6,720 6,720 0 1,757 3.82
2022-2060 change 550 550 0 169
2022-2060 annual growth
rate 0.22% 0.22% - 0.27%
1131
25 Table 39 – Housing Unit Projection for Huron SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 469 175 294
2022-2030 484 180 303
2022-2035 527 197 330
2022-2040 555 209 347
2022-2045 584 220 364
2022-2050 608 230 378
2022-2055 625 237 388
2022-2060 621 235 385
Table 40 – Population Projection for Huron SOI by Age, 2022-2060 Table 41 – Population Projection for Huron SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 6,167 6,235 6,258 6,392 6,521 6,632 6,707 6,737 6,723 556 0.2% 100.0% 100.0% 5 and below 601 523 528 584 614 608 555 516 507 -94 -0.4% 9.7% 7.5% 6 to 14 1,119 1,006 819 723 800 868 894 852 820 -299 -0.8% 18.1% 12.2% 15 to 19 578 661 562 496 373 412 461 487 489 -89 -0.4% 9.4% 7.3% 20 to 24 458 524 631 545 482 363 404 453 464 6 0.0% 7.4% 6.9% 25 to 34 865 826 893 1,096 1,122 984 816 746 778 -87 -0.3% 14.0% 11.6% 35 to 44 790 831 820 760 834 1,030 1,065 941 872 83 0.3% 12.8% 13.0% 45 to 54 642 658 672 755 757 705 783 974 988 346 1.1% 10.4% 14.7% 55 to 64 579 568 563 578 600 677 685 643 649 71 0.3% 9.4% 9.7% 65 to 74 355 417 485 464 471 487 510 578 596 241 1.4% 5.8% 8.9% 75 and above 182 222 285 391 468 499 533 548 559 377 3.00% 2.95% 8.32% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 6,167 6,235 6,258 6,392 6,521 6,632 6,707 6,737 6,723 556 0.2% 100.0% 100.0% White alone, NH 154 154 153 154 154 155 155 156 156 2 0.0% 2.5% 2.3% Hispanic or Latino 5,904 5,975 6,001 6,130 6,256 6,365 6,445 6,481 6,470 566 0.2% 95.7% 96.2% Black or African
American alone, NH 26 25 23 21 19 17 15 13 13 -14 -1.9% 0.4% 0.2% Asian alone, NH 44 43 46 53 60 66 63 60 59 15 0.8% 0.7% 0.9% Native Hawaiian and
Other Pacific Islander
alone, NH
0 0 0 0 0 0 0 0 0 0 NA 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
11 11 10 9 9 8 8 7 7 -4 -1.3% 0.2% 0.1%
Some Other Race
alone, NH 8 8 7 7 7 7 6 6 6 -2 -0.6% 0.1% 0.1%
Two or more races,
NH 20 20 19 18 16 15 14 13 13 -8 -1.2% 0.3% 0.2%
1132
26 Kerman and SOI
Table 42 – Population Projection for Kerman SOI, 2022-2060 Table 43 – Job Projection for Kerman SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 460 460 480 510 530 560 580 610 640
Retail 680 710 760 810 870 920 980 1,030 1,080
Office 230 350 440 510 590 630 620 560 460
Education 630 660 700 750 810 860 910 960 1,000
Health/Medical 460 480 510 540 570 610 640 670 700
Services 70 80 80 90 100 110 120 120 130
Food 350 360 380 410 440 470 490 520 550
Other 1,200 1,230 1,240 1,260 1,270 1,290 1,310 1,330 1,340 Government 240 250 260 280 300 320 340 360 380
Total 4,320 4,560 4,860 5,160 5,470 5,760 5,990 6,170 6,280 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 16,830 16,820 10 4,705 3.57
2025 17,360 17,350 10 4,947 3.57
2030 18,510 18,500 10 5,293 3.54
2035 19,650 19,640 10 5,619 3.54
2040 20,750 20,740 10 5,896 3.55
2045 21,700 21,690 10 6,145 3.56
2050 22,340 22,330 10 6,325 3.55
2055 22,600 22,590 10 6,420 3.53
2060 22,480 22,470 10 6,386 3.51
2022-2060 change 5,650 5,650 0 1,681
2022-2060 annual growth
rate 0.76% 0.77% 0.00% 0.81%
1133
27 Table 44 – Housing Unit Projection for Kerman SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 964 910 54
2022-2030 1,363 1,286 77
2022-2035 1,737 1,613 125
2022-2040 2,056 1,879 177
2022-2045 2,343 2,109 234
2022-2050 2,550 2,274 276
2022-2055 2,659 2,361 298
2022-2060 2,620 2,330 290
Table 45 – Population Projection for Kerman SOI by Age, 2022-2060 Table 46 – Population Projection for Kerman SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 16,826 17,356 18,507 19,647 20,754 21,703 22,340 22,597 22,479 5,653 0.8% 100.0% 100.0% 5 and below 1,403 1,432 1,573 1,743 1,832 1,800 1,708 1,664 1,658 255 0.4% 8.3% 7.4% 6 to 14 2,708 2,441 2,231 2,313 2,557 2,764 2,785 2,633 2,545 -164 -0.2% 16.1% 11.3% 15 to 19 1,575 1,659 1,475 1,281 1,270 1,394 1,531 1,564 1,534 -41 -0.1% 9.4% 6.8% 20 to 24 1,344 1,517 1,692 1,499 1,302 1,290 1,405 1,522 1,534 190 0.3% 8.0% 6.8% 25 to 34 2,243 2,331 2,733 3,283 3,261 2,860 2,623 2,681 2,742 499 0.5% 13.3% 12.2% 35 to 44 2,341 2,328 2,340 2,395 2,798 3,357 3,305 2,838 2,714 373 0.4% 13.9% 12.1% 45 to 54 1,837 1,985 2,276 2,364 2,368 2,420 2,806 3,295 3,203 1,367 1.5% 10.9% 14.3% 55 to 64 1,464 1,505 1,636 1,951 2,227 2,308 2,292 2,294 2,390 926 1.3% 8.7% 10.6% 65 to 74 1,241 1,328 1,403 1,386 1,504 1,791 2,026 2,052 2,012 771 1.3% 7.4% 8.9% 75 and above 671 831 1,149 1,432 1,634 1,721 1,859 2,054 2,148 1,477 3.11% 3.99% 9.56% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 16,826 17,356 18,507 19,647 20,754 21,703 22,340 22,597 22,479 5,653 0.8% 100.0% 100.0% White alone, NH 2,024 2,016 2,028 2,025 2,010 1,974 1,912 1,838 1,797 -227 -0.3% 12.0% 8.0% Hispanic or Latino 13,198 13,713 14,798 15,878 16,957 17,920 18,624 18,985 18,932 5,734 1.0% 78.4% 84.2% Black or African
American alone, NH 66 64 61 68 75 78 73 69 66 0 0.0% 0.4% 0.3% Asian alone, NH 1,217 1,241 1,290 1,333 1,358 1,368 1,361 1,334 1,316 99 0.2% 7.2% 5.9% Native Hawaiian and
Other Pacific Islander
alone, NH
1 1 1 1 1 1 1 1 1 0 0.1% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
42 41 40 38 36 34 31 28 26 -15 -1.2% 0.2% 0.1%
Some Other Race
alone, NH 90 89 90 97 103 109 115 119 120 29 0.7% 0.5% 0.5% Two or more races,
NH 189 191 199 206 214 219 222 223 221 32 0.4% 1.1% 1.0% 1134
28 Kingsburg and SOI
Table 47 – Population Projection for Kingsburg SOI, 2022-2060 Table 48 – Job Projection for Kingsburg SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 1,690 1,680 1,770 1,850 1,950 2,040 2,130 2,230 2,330 Retail 810 830 870 910 960 1,000 1,040 1,080 1,110
Office 450 450 480 560 650 710 740 730 690
Education 450 460 480 510 530 560 580 600 610
Health/Medical 520 530 550 570 600 620 650 670 680
Services 110 110 120 130 140 150 160 160 170
Food 510 520 550 570 600 630 650 680 700
Other 590 600 610 620 620 630 640 650 660
Government 130 130 140 150 150 160 170 170 180
Total 5,240 5,320 5,580 5,880 6,210 6,500 6,760 6,970 7,140 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 12,750 12,670 80 4,441 2.85
2025 13,210 13,110 100 4,692 2.85
2030 13,750 13,650 100 4,899 2.81
2035 14,550 14,450 100 5,187 2.82
2040 15,340 15,230 110 5,430 2.83
2045 16,010 15,900 110 5,650 2.84
2050 16,460 16,350 110 5,809 2.83
2055 16,650 16,530 120 5,893 2.81
2060 16,560 16,440 120 5,863 2.80
2022-2060 change 3,810 3,780 30 1,422
2022-2060 annual growth
rate 0.69% 0.69% 1.07% 0.74%
1135
29 Table 49 – Housing Unit Projection for Kingsburg SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 381 265 116
2022-2030 602 419 184
2022-2035 910 644 266
2022-2040 1,170 839 330
2022-2045 1,404 1,020 384
2022-2050 1,574 1,151 423
2022-2055 1,664 1,220 444
2022-2060 1,632 1,195 437
Table 50 – Population Projection for Kingsburg SOI by Age, 2022-2060 Table 51 – Population Projection for Kingsburg SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 12,754 13,206 13,746 14,555 15,340 16,013 16,464 16,647 16,563 3,809 0.7% 100.0% 100.0% 5 and below 913 956 1,025 1,102 1,161 1,160 1,145 1,144 1,145 232 0.6% 7.2% 6.9% 6 to 14 1,679 1,572 1,473 1,576 1,702 1,811 1,835 1,779 1,742 63 0.1% 13.2% 10.5% 15 to 19 974 1,005 947 852 903 973 1,031 1,052 1,034 60 0.2% 7.6% 6.2% 20 to 24 838 967 1,027 988 888 938 1,000 1,044 1,048 210 0.6% 6.6% 6.3% 25 to 34 1,575 1,614 1,800 2,096 2,141 1,987 1,907 1,983 2,004 428 0.6% 12.4% 12.1% 35 to 44 1,602 1,662 1,677 1,706 1,940 2,251 2,267 2,048 1,972 370 0.5% 12.6% 11.9% 45 to 54 1,442 1,502 1,606 1,735 1,786 1,810 2,032 2,293 2,299 856 1.2% 11.3% 13.9% 55 to 64 1,486 1,501 1,438 1,516 1,653 1,778 1,805 1,783 1,781 295 0.5% 11.6% 10.8% 65 to 74 1,285 1,336 1,401 1,418 1,387 1,457 1,566 1,640 1,639 354 0.6% 10.1% 9.9% 75 and above 960 1,090 1,351 1,566 1,780 1,848 1,876 1,881 1,899 939 1.81% 7.53% 11.46% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 12,754 13,206 13,746 14,555 15,340 16,013 16,464 16,647 16,563 3,809 0.7% 100.0% 100.0% White alone, NH 5,593 5,680 5,712 5,841 5,954 6,028 6,021 5,924 5,833 239 0.1% 43.9% 35.2% Hispanic or Latino 6,115 6,437 6,892 7,506 8,127 8,695 9,136 9,418 9,438 3,323 1.1% 47.9% 57.0% Black or African
American alone, NH 46 45 42 40 38 36 32 29 27 -20 -1.4% 0.4% 0.2% Asian alone, NH 409 431 464 499 526 542 555 564 564 155 0.8% 3.2% 3.4% Native Hawaiian and
Other Pacific Islander
alone, NH
12 12 12 12 12 12 12 12 11 -1 -0.2% 0.1% 0.1%
American Indian and
Alaska Native alone,
NH
47 47 45 43 41 38 35 31 29 -18 -1.3% 0.4% 0.2%
Some Other Race
alone, NH 89 96 107 119 132 135 138 144 144 55 1.3% 0.7% 0.9% Two or more races,
NH 442 458 473 494 510 527 535 526 517 74 0.4% 3.5% 3.1% 1136
30 Mendota and SOI
Table 52 – Population Projection for Mendota SOI, 2022-2060 Table 53 – Job Projection for Mendota SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 330 330 350 370 380 400 420 440 460
Retail 180 180 190 200 210 220 220 230 240
Office 30 10 50 70 90 100 90 90 70
Education 450 450 480 500 520 540 560 570 580
Health/Medical 180 180 190 190 200 210 210 220 220
Services 10 10 10 10 10 10 10 10 10
Food 130 130 140 140 150 150 160 160 170
Other 70 70 70 70 70 70 70 80 80
Government 450 460 480 500 520 540 560 580 600
Total 1,830 1,820 1,960 2,060 2,160 2,250 2,330 2,390 2,430 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 12,500 12,500 0 2,851 4.38
2025 12,530 12,530 0 2,909 4.34
2030 13,070 13,070 0 3,045 4.33
2035 13,400 13,400 0 3,121 4.31
2040 13,710 13,710 0 3,173 4.33
2045 13,980 13,980 0 3,225 4.35
2050 14,170 14,170 0 3,267 4.35
2055 14,240 14,240 0 3,295 4.33
2060 14,210 14,210 0 3,288 4.32
2022-2060 change 1,710 1,710 0 437
2022-2060 annual growth
rate 0.34% 0.34% - 0.38%
1137
31 Table 54 – Housing Unit Projection for Mendota SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 880 809 71
2022-2030 1,049 964 85
2022-2035 1,144 1,041 103
2022-2040 1,209 1,090 119
2022-2045 1,274 1,135 139
2022-2050 1,326 1,172 154
2022-2055 1,361 1,196 165
2022-2060 1,351 1,189 162
Table 55 – Population Projection for Mendota SOI by Age, 2022-2060 Table 56 – Population Projection for Mendota SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 12,497 12,529 13,069 13,396 13,712 13,984 14,166 14,239 14,206 1,709 0.3% 100.0% 100.0% 5 and below 1,285 1,092 1,116 1,191 1,250 1,237 1,160 1,086 1,065 -220 -0.5% 10.3% 7.5% 6 to 14 2,276 2,186 1,840 1,571 1,665 1,773 1,818 1,755 1,703 -572 -0.8% 18.2% 12.0% 15 to 19 1,123 1,172 1,230 1,121 828 873 939 989 991 -132 -0.3% 9.0% 7.0% 20 to 24 1,073 1,106 1,160 1,197 1,092 810 855 921 945 -128 -0.3% 8.6% 6.7% 25 to 34 1,883 1,824 2,024 2,188 2,259 2,200 1,834 1,613 1,648 -235 -0.4% 15.1% 11.6% 35 to 44 1,655 1,710 1,751 1,741 1,901 2,063 2,145 2,096 1,930 275 0.4% 13.2% 13.6% 45 to 54 1,269 1,345 1,511 1,614 1,625 1,623 1,784 1,943 1,959 690 1.1% 10.2% 13.8% 55 to 64 1,020 1,042 1,099 1,226 1,355 1,453 1,472 1,475 1,578 557 1.2% 8.2% 11.1% 65 to 74 591 674 836 887 923 1,036 1,151 1,240 1,210 619 1.9% 4.7% 8.5% 75 and above 322 377 501 659 813 916 1,007 1,122 1,176 855 3.47% 2.57% 8.28% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 12,497 12,529 13,069 13,396 13,712 13,984 14,166 14,239 14,206 1,709 0.3% 100.0% 100.0% White alone, NH 294 285 284 286 298 312 321 322 318 25 0.2% 2.4% 2.2% Hispanic or Latino 12,079 12,126 12,671 13,002 13,313 13,577 13,758 13,838 13,810 1,731 0.4% 96.7% 97.2% Black or African
American alone, NH 5 5 5 5 5 5 5 4 4 -1 -0.7% 0.0% 0.0% Asian alone, NH 14 13 13 12 10 9 8 7 6 -8 -2.0% 0.1% 0.0% Native Hawaiian and
Other Pacific Islander
alone, NH
1 1 1 1 1 1 1 1 1 0 -0.4% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
22 20 19 17 15 13 11 10 9 -12 -2.2% 0.2% 0.1%
Some Other Race
alone, NH 37 36 35 34 32 31 29 27 26 -11 -1.0% 0.3% 0.2% Two or more races,
NH 44 43 42 40 38 36 34 31 30 -14 -1.0% 0.4% 0.2%
1138
32 Orange Cove and SOI
Table 57 – Population Projection for Orange Cove SOI, 2022-2060 Table 58 – Job Projection for Orange Cove SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 50 50 50 60 60 60 60 70 70
Retail 130 130 130 140 140 140 150 150 150
Office 30 30 30 30 40 50 50 60 60
Education 220 220 230 230 240 250 250 250 250
Health/Medical 290 290 300 310 310 320 320 320 330
Services 0 0 0 0 0 0 0 0 0
Food 20 20 20 30 30 30 30 30 30
Other 120 120 120 120 120 130 130 130 130
Government 100 100 100 100 110 110 110 110 110
Total 960 970 990 1,020 1,050 1,080 1,100 1,120 1,130
Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 9,590 9,590 0 2,439 3.93
2025 9,600 9,600 0 2,480 3.89
2030 9,670 9,670 0 2,506 3.87
2035 9,780 9,780 0 2,535 3.87
2040 9,890 9,890 0 2,546 3.89
2045 9,990 9,990 0 2,562 3.90
2050 10,050 10,050 0 2,578 3.90
2055 10,070 10,070 0 2,593 3.89
2060 10,060 10,060 0 2,590 3.88
2022-2060 change 470 470 0 151
2022-2060 annual growth
rate 0.13% 0.13% - 0.16%
1139
33 Table 59 – Housing Unit Projection for Orange Cove SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 447 250 197
2022-2030 479 268 211
2022-2035 512 289 224
2022-2040 525 297 228
2022-2045 543 309 234
2022-2050 562 322 240
2022-2055 580 334 246
2022-2060 576 332 245
Table 60 – Population Projection for Orange Cove SOI by Age, 2022-2060 Table 61 – Population Projection for Orange Cove SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 9,589 9,601 9,672 9,784 9,892 9,985 10,047 10,073 10,061 472 0.1% 100.0% 100.0% 5 and below 900 835 886 928 918 860 802 770 765 -135 -0.4% 9.4% 7.6% 6 to 14 1,695 1,516 1,265 1,207 1,290 1,327 1,289 1,209 1,178 -517 -1.0% 17.7% 11.7% 15 to 19 986 997 843 709 618 674 715 712 697 -289 -0.9% 10.3% 6.9% 20 to 24 849 900 951 808 684 600 658 700 704 -144 -0.5% 8.8% 7.0% 25 to 34 1,277 1,392 1,555 1,731 1,653 1,416 1,231 1,214 1,255 -22 0.0% 13.3% 12.5% 35 to 44 1,183 1,129 1,150 1,262 1,425 1,605 1,553 1,340 1,256 73 0.2% 12.3% 12.5% 45 to 54 974 1,006 1,053 1,012 1,042 1,158 1,325 1,502 1,499 525 1.1% 10.2% 14.9% 55 to 64 812 849 841 873 922 896 936 1,047 1,094 282 0.8% 8.5% 10.9% 65 to 74 551 596 660 690 691 728 777 759 767 216 0.9% 5.7% 7.6% 75 and above 364 382 467 563 651 721 761 819 847 483 2.25% 3.80% 8.42% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 9,589 9,601 9,672 9,784 9,892 9,985 10,047 10,073 10,061 472 0.1% 100.0% 100.0% White alone, NH 323 309 290 275 261 245 233 224 220 -103 -1.0% 3.4% 2.2% Hispanic or Latino 9,112 9,147 9,253 9,394 9,531 9,652 9,737 9,781 9,776 664 0.2% 95.0% 97.2% Black or African
American alone, NH 23 21 17 14 11 10 8 6 6 -17 -3.5% 0.2% 0.1% Asian alone, NH 62 58 51 43 37 32 27 24 23 -39 -2.6% 0.6% 0.2% Native Hawaiian and
Other Pacific Islander
alone, NH
5 4 4 4 3 3 3 3 3 -2 -1.6% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
12 11 10 9 8 7 6 6 5 -6 -2.1% 0.1% 0.1%
Some Other Race
alone, NH 4 4 3 3 3 3 2 2 2 -2 -2.3% 0.0% 0.0%
Two or more races,
NH 49 47 44 41 37 34 31 28 27 -22 -1.6% 0.5% 0.3%
1140
34 Parlier and SOI
Table 62 – Population Projection for Parlier SOI, 2022-2060 Table 63 – Job Projection for Parlier SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 760 760 800 830 880 920 960 1,000 1,050
Retail 180 180 180 180 190 190 200 200 200
Office 130 100 90 110 130 150 160 180 190
Education 480 480 490 510 520 530 530 540 540
Health/Medical 390 390 400 400 410 420 420 420 420
Services 50 50 50 50 60 60 60 60 60
Food 120 120 120 120 120 130 130 130 130
Other 320 330 340 340 340 350 350 360 360
Government 140 140 140 150 150 150 150 160 160
Total 2,550 2,540 2,610 2,700 2,790 2,880 2,970 3,040 3,100 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 15,030 15,030 0 3,768 3.99
2025 15,040 15,040 0 3,825 3.95
2030 15,060 15,060 0 3,844 3.92
2035 15,200 15,200 0 3,879 3.93
2040 15,340 15,340 0 3,888 3.95
2045 15,450 15,450 0 3,904 3.96
2050 15,530 15,530 0 3,924 3.96
2055 15,560 15,560 0 3,945 3.95
2060 15,550 15,550 0 3,941 3.94
2022-2060 change 520 520 0 173
2022-2060 annual growth
rate 0.09% 0.09% - 0.12%
1141
35 Table 64 – Housing Unit Projection for Parlier SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 511 400 112
2022-2030 533 417 116
2022-2035 575 448 127
2022-2040 585 455 130
2022-2045 604 468 135
2022-2050 627 485 142
2022-2055 652 502 149
2022-2060 647 499 148
Table 65 – Population Projection for Parlier SOI by Age, 2022-2060 Table 66 – Population Projection for Parlier SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 15,029 15,038 15,062 15,202 15,337 15,454 15,532 15,563 15,549 520 0.1% 100.0% 100.0% 5 and below 1,359 1,291 1,319 1,357 1,356 1,292 1,222 1,179 1,174 -184 -0.4% 9.0% 7.6% 6 to 14 2,554 2,334 1,907 1,839 1,911 1,959 1,926 1,835 1,796 -758 -0.9% 17.0% 11.6% 15 to 19 1,494 1,432 1,341 1,051 959 1,010 1,056 1,064 1,047 -447 -0.9% 9.9% 6.7% 20 to 24 1,152 1,327 1,364 1,290 1,016 934 989 1,036 1,045 -107 -0.3% 7.7% 6.7% 25 to 34 2,089 2,165 2,303 2,520 2,507 2,197 1,878 1,863 1,903 -186 -0.2% 13.9% 12.2% 35 to 44 2,006 1,884 1,869 1,965 2,123 2,351 2,369 2,091 1,969 -38 0.0% 13.3% 12.7% 45 to 54 1,630 1,620 1,749 1,691 1,704 1,814 1,984 2,214 2,251 621 0.9% 10.8% 14.5% 55 to 64 1,381 1,453 1,378 1,406 1,541 1,506 1,539 1,649 1,682 301 0.5% 9.2% 10.8% 65 to 74 854 952 1,080 1,180 1,138 1,179 1,306 1,283 1,304 450 1.1% 5.7% 8.4% 75 and above 510 579 753 903 1,082 1,212 1,263 1,350 1,378 867 2.65% 3.39% 8.86% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 15,029 15,038 15,062 15,202 15,337 15,454 15,532 15,563 15,549 520 0.1% 100.0% 100.0% White alone, NH 210 204 196 189 182 176 170 165 163 -47 -0.7% 1.4% 1.1% Hispanic or Latino 14,675 14,701 14,748 14,908 15,063 15,195 15,286 15,329 15,320 644 0.1% 97.6% 98.5% Black or African
American alone, NH 33 31 27 24 22 20 19 17 17 -16 -1.8% 0.2% 0.1% Asian alone, NH 47 43 37 32 28 24 22 19 18 -29 -2.5% 0.3% 0.1% Native Hawaiian and
Other Pacific Islander
alone, NH
2 2 2 2 1 1 1 1 1 -1 -2.0% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
9 9 7 6 6 5 4 3 3 -6 -2.7% 0.1% 0.0%
Some Other Race
alone, NH 14 13 12 11 10 9 8 8 7 -7 -1.7% 0.1% 0.0%
Two or more races,
NH 39 37 32 29 26 23 21 20 19 -19 -1.8% 0.3% 0.1%
1142
36 Reedley and SOI
Table 67 – Population Projection for Reedley SOI, 2022-2060 Table 68 – Job Projection for Reedley SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 950 940 990 1,040 1,090 1,140 1,190 1,250 1,310 Retail 500 510 520 540 560 570 590 600 600
Office 260 420 300 350 410 450 480 490 490
Education 1,620 1,650 1,700 1,760 1,820 1,870 1,920 1,940 1,960 Health/Medical 1,900 1,920 1,970 2,020 2,080 2,130 2,170 2,200 2,220 Services 150 150 160 170 180 190 190 200 200
Food 510 520 530 550 570 580 600 610 620
Other 2,010 2,070 2,080 2,110 2,130 2,160 2,190 2,220 2,250 Government 240 240 250 260 270 270 280 290 290
Total 8,120 8,400 8,520 8,800 9,100 9,370 9,610 9,800 9,940 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 25,290 25,050 240 7,244 3.46
2025 25,830 25,580 250 7,506 3.45
2030 25,900 25,640 260 7,549 3.40
2035 26,740 26,470 270 7,793 3.42
2040 27,550 27,270 280 7,976 3.43
2045 28,250 27,960 290 8,150 3.45
2050 28,710 28,420 290 8,285 3.44
2055 28,900 28,610 290 8,368 3.43
2060 28,820 28,520 300 8,343 3.42
2022-2060 change 3,530 3,480 50 1,099
2022-2060 annual growth
rate 0.34% 0.34% 0.59% 0.37%
1143
37 Table 69 – Housing Unit Projection for Reedley SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 1,043 772 271
2022-2030 1,092 808 284
2022-2035 1,366 966 401
2022-2040 1,573 1,067 506
2022-2045 1,769 1,155 615
2022-2050 1,921 1,223 698
2022-2055 2,014 1,262 752
2022-2060 1,985 1,250 735
Table 70 – Population Projection for Reedley SOI by Age, 2022-2060 Table 71 – Population Projection for Reedley SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 25,293 25,831 25,902 26,739 27,551 28,248 28,715 28,904 28,817 3,524 0.3% 100.0% 100.0% 5 and below 1,929 2,030 2,159 2,318 2,362 2,277 2,164 2,114 2,117 188 0.2% 7.6% 7.3% 6 to 14 3,790 3,388 2,895 3,087 3,362 3,532 3,498 3,318 3,231 -560 -0.4% 15.0% 11.2% 15 to 19 2,222 2,270 2,026 1,585 1,651 1,819 1,952 1,968 1,928 -294 -0.4% 8.8% 6.7% 20 to 24 2,000 2,170 2,202 2,020 1,583 1,653 1,819 1,940 1,955 -45 -0.1% 7.9% 6.8% 25 to 34 3,366 3,599 3,942 4,279 4,195 3,592 3,227 3,439 3,539 173 0.1% 13.3% 12.3% 35 to 44 3,064 3,070 3,187 3,448 3,887 4,238 4,160 3,536 3,364 300 0.2% 12.1% 11.7% 45 to 54 2,833 2,925 2,868 2,907 3,107 3,376 3,810 4,124 4,070 1,237 1.0% 11.2% 14.1% 55 to 64 2,592 2,681 2,666 2,678 2,700 2,748 2,940 3,174 3,314 722 0.6% 10.2% 11.5% 65 to 74 1,820 1,968 2,115 2,302 2,353 2,380 2,397 2,421 2,414 594 0.7% 7.2% 8.4% 75 and above 1,676 1,730 1,841 2,115 2,352 2,633 2,747 2,868 2,885 1,209 1.44% 6.63% 10.01% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 25,293 25,831 25,902 26,739 27,551 28,248 28,715 28,904 28,817 3,524 0.3% 100.0% 100.0% White alone, NH 3,846 3,678 3,340 3,155 2,998 2,859 2,734 2,614 2,561 -1,286 -1.1% 15.2% 8.9% Hispanic or Latino 20,129 20,830 21,277 22,305 23,283 24,128 24,743 25,082 25,066 4,937 0.6% 79.6% 87.0% Black or African
American alone, NH 73 76 79 76 71 66 61 66 67 -6 -0.2% 0.3% 0.2% Asian alone, NH 653 645 610 593 573 551 524 505 496 -157 -0.7% 2.6% 1.7% Native Hawaiian and
Other Pacific Islander
alone, NH
4 4 3 3 2 2 1 1 1 -3 -4.2% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
45 45 43 42 40 38 36 33 32 -14 -0.9% 0.2% 0.1%
Some Other Race
alone, NH 172 176 176 187 202 216 229 230 228 56 0.7% 0.7% 0.8% Two or more races,
NH 370 377 373 378 383 387 386 374 367 -4 0.0% 1.5% 1.3% 1144
38 Sanger and SOI
Table 72 – Population Projection for Sanger SOI, 2022-2060 Table 73 – Job Projection for Sanger SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 2,730 2,710 2,850 2,990 3,140 3,290 3,440 3,590 3,760 Retail 750 750 770 780 800 810 820 820 820
Office 1,720 1,600 1,680 1,750 1,820 1,880 1,940 1,990 2,030 Education 1,100 1,110 1,130 1,160 1,180 1,200 1,210 1,210 1,210 Health/Medical 980 990 1,000 1,010 1,030 1,040 1,050 1,050 1,040 Services 140 140 140 150 160 160 170 170 170
Food 690 690 700 720 730 740 750 760 750
Other 950 980 990 1,000 1,010 1,030 1,040 1,060 1,070
Government 750 760 770 780 800 810 820 830 830
Total 9,800 9,720 10,050 10,340 10,660 10,960 11,240 11,480 11,700 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 27,040 26,890 150 7,815 3.44
2025 27,040 26,890 150 7,962 3.40
2030 27,540 27,380 160 8,133 3.38
2035 27,940 27,780 160 8,252 3.38
2040 28,330 28,170 160 8,312 3.39
2045 28,670 28,510 160 8,382 3.41
2050 28,900 28,730 170 8,448 3.41
2055 28,990 28,820 170 8,503 3.39
2060 28,940 28,780 160 8,491 3.39
2022-2060 change 1,900 1,890 10 676
2022-2060 annual growth
rate 0.18% 0.18% 0.17% 0.22%
1145
39 Table 74 – Housing Unit Projection for Sanger SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 1,023 702 321
2022-2030 1,216 835 381
2022-2035 1,351 933 418
2022-2040 1,418 984 435
2022-2045 1,498 1,045 453
2022-2050 1,573 1,102 470
2022-2055 1,635 1,150 485
2022-2060 1,621 1,139 481
Table 75 – Population Projection for Sanger SOI by Age, 2022-2060 Table 76 – Population Projection for Sanger SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 27,039 27,044 27,538 27,941 28,334 28,670 28,895 28,986 28,944 1,906 0.2% 100.0% 100.0% 5 and below 2,131 2,168 2,304 2,432 2,450 2,328 2,189 2,125 2,124 -7 0.0% 7.9% 7.3% 6 to 14 4,183 3,679 3,193 3,261 3,451 3,595 3,540 3,339 3,257 -926 -0.7% 15.5% 11.3% 15 to 19 2,430 2,432 2,171 1,720 1,730 1,835 1,958 1,982 1,944 -486 -0.6% 9.0% 6.7% 20 to 24 1,976 2,203 2,379 2,118 1,684 1,705 1,814 1,936 1,958 -18 0.0% 7.3% 6.8% 25 to 34 3,800 3,589 3,972 4,412 4,336 3,693 3,317 3,451 3,534 -265 -0.2% 14.1% 12.2% 35 to 44 3,612 3,768 3,577 3,396 3,763 4,222 4,188 3,578 3,385 -227 -0.2% 13.4% 11.7% 45 to 54 3,061 3,153 3,329 3,523 3,347 3,211 3,594 4,046 4,102 1,041 0.8% 11.3% 14.2% 55 to 64 2,589 2,532 2,675 2,851 3,013 3,218 3,082 2,971 3,074 485 0.5% 9.6% 10.6% 65 to 74 1,878 2,004 2,134 2,144 2,270 2,446 2,609 2,791 2,698 821 1.0% 6.9% 9.3% 75 and above 1,379 1,517 1,804 2,085 2,290 2,418 2,603 2,768 2,867 1,488 1.94% 5.10% 9.91% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 27,039 27,044 27,538 27,941 28,334 28,670 28,895 28,986 28,944 1,906 0.2% 100.0% 100.0% White alone, NH 3,200 3,092 2,962 2,823 2,704 2,603 2,507 2,413 2,372 -828 -0.8% 11.8% 8.2% Hispanic or Latino 22,370 22,506 23,141 23,698 24,216 24,663 25,002 25,220 25,236 2,866 0.3% 82.7% 87.2% Black or African
American alone, NH 174 170 169 167 165 164 163 162 160 -14 -0.2% 0.6% 0.6% Asian alone, NH 776 771 769 761 762 765 769 761 755 -22 -0.1% 2.9% 2.6% Native Hawaiian and
Other Pacific Islander
alone, NH
29 27 25 23 21 19 16 14 13 -16 -2.1% 0.1% 0.0%
American Indian and
Alaska Native alone,
NH
76 72 68 63 58 54 49 44 42 -34 -1.6% 0.3% 0.1%
Some Other Race
alone, NH 82 79 81 86 90 93 88 83 81 -1 0.0% 0.3% 0.3%
Two or more races,
NH 333 327 323 321 316 309 301 291 286 -47 -0.4% 1.2% 1.0% 1146
40 San Joaquin and SOI
Table 77 – Population Projection for San Joaquin SOI, 2022-2060 Table 78 – Job Projection for San Joaquin SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 50 50 60 60 60 70 70 70 70
Retail 40 40 40 40 40 40 40 40 40
Office 40 20 30 30 30 40 50 50 60
Education 120 120 120 120 120 120 120 120 120
Health/Medi
cal 320 320 320 320 320 320 320 320 310
Services 30 30 30 30 30 30 30 30 30
Food 10 10 10 10 10 10 10 10 10
Other 20 20 20 20 20 20 20 20 20
Government 30 30 30 30 30 30 30 30 30
Total 650 630 640 650 660 670 680 690 690
Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 3,670 3,670 0 902 4.07
2025 3,610 3,610 0 913 3.97
2030 3,640 3,640 0 922 3.96
2035 3,670 3,670 0 929 3.95
2040 3,700 3,700 0 930 3.98
2045 3,720 3,720 0 934 3.99
2050 3,740 3,740 0 938 3.99
2055 3,750 3,750 0 943 3.98
2060 3,740 3,740 0 942 3.97
2022-2060 change 70 70 0 39
2022-2060 annual growth
rate 0.05% 0.05% - 0.11%
1147
41 Table 79 – Housing Unit Projection for San Joaquin SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 182 182 -
2022-2030 193 193 -
2022-2035 202 199 3
2022-2040 203 200 3
2022-2045 207 202 5
2022-2050 212 204 8
2022-2055 218 207 11
2022-2060 217 206 11
Table 80 – Population Projection for San Joaquin SOI by Age, 2022-2060 Table 81 – Population Projection for San Joaquin SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 3,668 3,615 3,638 3,668 3,698 3,723 3,739 3,746 3,743 75 0.1% 100.0% 100.0% 5 and below 316 289 337 368 362 329 294 289 292 -24 -0.2% 8.6% 7.8% 6 to 14 659 579 450 443 496 520 499 453 434 -225 -1.1% 18.0% 11.6% 15 to 19 409 364 327 247 219 253 281 278 271 -138 -1.1% 11.2% 7.2% 20 to 24 336 391 346 310 237 212 247 275 278 -58 -0.5% 9.2% 7.4% 25 to 34 470 498 628 679 609 515 429 443 468 -3 0.0% 12.8% 12.5% 35 to 44 393 387 401 446 566 623 571 487 441 47 0.3% 10.7% 11.8% 45 to 54 447 405 366 343 358 404 524 582 580 133 0.7% 12.2% 15.5% 55 to 64 317 357 367 346 315 301 320 365 400 83 0.6% 8.6% 10.7% 65 to 74 217 223 242 286 296 285 264 256 262 45 0.5% 5.9% 7.0% 75 and above 103 122 175 201 241 280 309 320 318 215 3.00% 2.82% 8.50% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 3,668 3,615 3,638 3,668 3,698 3,723 3,739 3,746 3,743 75 0.1% 100.0% 100.0% White alone, NH 87 86 88 90 84 78 73 73 75 -12 -0.4% 2.4% 2.0% Hispanic or Latino 3,511 3,462 3,489 3,522 3,561 3,596 3,622 3,633 3,630 119 0.1% 95.7% 97.0% Black or African
American alone, NH 30 28 26 24 23 21 20 19 18 -12 -1.3% 0.8% 0.5% Asian alone, NH 7 7 6 5 5 4 3 2 2 -5 -3.3% 0.2% 0.1%
Native Hawaiian and
Other Pacific Islander
alone, NH
1 1 1 1 1 0 0 0 0 -1 -4.0% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
5 5 4 4 3 3 2 2 1 -3 -3.1% 0.1% 0.0%
Some Other Race
alone, NH 19 18 17 16 15 14 13 12 11 -8 -1.4% 0.5% 0.3% Two or more races,
NH 8 7 7 7 6 6 6 5 5 -2 -1.0% 0.2% 0.1%
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42 Selma and SOI
Table 82 – Population Projection for Selma SOI, 2022-2060 Table 83 – Job Projection for Selma SOI by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 1,260 1,250 1,320 1,380 1,450 1,520 1,590 1,660 1,740 Retail 1,780 1,820 2,390 2,770 2,840 2,920 2,990 3,040 3,090 Office 300 350 540 570 610 620 610 580 530
Education 800 820 850 890 920 960 990 1,010 1,020
Health/Medical 1,010 1,030 1,060 1,100 1,130 1,170 1,200 1,230 1,250 Services 150 160 170 230 240 250 260 270 270
Food 850 870 900 1,090 1,130 1,160 1,190 1,220 1,240
Other 2,880 4,960 4,990 3,020 3,050 3,100 3,140 3,190 3,230 Government 250 260 270 280 290 300 310 320 330
Total 9,280 11,510 12,490 11,320 11,670 12,000 12,290 12,520 12,710 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 26,540 26,350 190 7,614 3.46
2025 26,650 26,460 190 7,809 3.42
2030 28,250 28,030 220 8,303 3.42
2035 29,150 28,930 220 8,569 3.40
2040 30,030 29,800 230 8,768 3.41
2045 30,790 30,550 240 8,958 3.43
2050 31,290 31,050 240 9,104 3.42
2055 31,490 31,260 230 9,195 3.41
2060 31,400 31,160 240 9,167 3.40
2022-2060 change 4,860 4,820 40 1,553
2022-2060 annual growth
rate 0.44% 0.44% 0.62% 0.49%
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43 Table 84 – Housing Unit Projection for Selma SOI, 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 852 787 64
2022-2030 1,401 1,296 105
2022-2035 1,697 1,581 117
2022-2040 1,919 1,798 121
2022-2045 2,130 2,008 123
2022-2050 2,294 2,169 124
2022-2055 2,394 2,269 125
2022-2060 2,364 2,239 125
Table 85 – Population Projection for Selma SOI by Age, 2022-2060 Table 86 – Population Projection for Selma SOI by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 26,541 26,651 28,248 29,153 30,032 30,785 31,290 31,495 31,401 4,860 0.4% 100.0% 100.0% 5 and below 2,194 2,137 2,370 2,507 2,557 2,496 2,402 2,344 2,336 141 0.2% 8.3% 7.4% 6 to 14 3,932 3,669 3,355 3,415 3,660 3,817 3,801 3,649 3,569 -363 -0.3% 14.8% 11.4% 15 to 19 2,214 2,220 2,199 1,886 1,840 1,990 2,104 2,125 2,090 -124 -0.2% 8.3% 6.7% 20 to 24 2,091 2,138 2,264 2,189 1,883 1,841 1,986 2,087 2,103 12 0.0% 7.9% 6.7% 25 to 34 3,726 3,710 4,105 4,412 4,422 4,057 3,706 3,782 3,859 133 0.1% 14.0% 12.3% 35 to 44 3,355 3,477 3,686 3,734 4,044 4,366 4,375 3,981 3,779 424 0.3% 12.6% 12.0% 45 to 54 2,924 2,925 3,244 3,459 3,586 3,652 3,956 4,235 4,206 1,282 1.0% 11.0% 13.4% 55 to 64 2,682 2,693 2,668 2,815 3,053 3,270 3,384 3,421 3,524 842 0.7% 10.1% 11.2% 65 to 74 1,986 2,049 2,319 2,426 2,355 2,501 2,710 2,874 2,887 901 1.0% 7.5% 9.2% 75 and above 1,438 1,633 2,038 2,309 2,632 2,795 2,866 2,996 3,048 1,610 2.00% 5.42% 9.71% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 26,541 26,651 28,248 29,153 30,032 30,785 31,290 31,495 31,401 4,860 0.4% 100.0% 100.0% White alone, NH 2,964 2,820 2,726 2,564 2,425 2,306 2,195 2,086 2,038 -926 -1.0% 11.2% 6.5% Hispanic or Latino 21,638 21,909 23,539 24,609 25,644 26,548 27,204 27,571 27,553 5,915 0.6% 81.5% 87.7% Black or African
American alone, NH 156 152 153 151 150 149 149 149 148 -8 -0.1% 0.6% 0.5% Asian alone, NH 1,132 1,125 1,165 1,166 1,154 1,131 1,107 1,080 1,066 -66 -0.2% 4.3% 3.4% Native Hawaiian and
Other Pacific Islander
alone, NH
6 6 6 6 6 5 5 4 4 -2 -1.1% 0.0% 0.0%
American Indian and
Alaska Native alone,
NH
96 92 88 82 75 69 62 55 52 -45 -1.6% 0.4% 0.2%
Some Other Race
alone, NH 132 132 139 142 144 146 148 148 148 16 0.3% 0.5% 0.5% Two or more races,
NH 417 415 431 434 434 431 421 401 392 -25 -0.2% 1.6% 1.2% 1150
44 Unincorporated Areas (excl. SOIs)
Table 87 – Population Projection for Unincorporated Areas (excl. SOIs) , 2022-2060 Table 88 – Job Projection for Unincorporated Areas (excl. SOIs) by Sector, 2022-2060 Job Sector 2022 2025 2030 2035 2040 2045 2050 2055 2060 Industrial 12,460 12,380 13,040 13,660 14,360 15,020 15,710 16,420 17,190 Retail 1,130 1,130 1,130 1,120 1,110 1,090 1,050 1,000 930 Office 2,660 4,010 3,870 3,980 4,100 4,250 4,340 4,380 4,390 Education 2,720 2,740 2,820 2,870 2,930 2,970 2,990 2,970 2,930 Health/Medical 1,600 1,740 1,960 2,190 2,410 2,630 2,830 3,010 3,170 Services 1,930 1,990 2,130 2,270 2,430 2,560 2,670 2,750 2,790 Food 1,330 1,350 1,380 1,420 1,440 1,460 1,470 1,470 1,450 Other 34,300 35,300 35,600 36,010 36,420 36,980 37,490 38,000 38,510 Government 790 850 950 1,050 1,160 1,260 1,360 1,450 1,530 Total 58,920 61,480 62,890 64,580 66,360 68,210 69,910 71,450 72,900 Year Total Population Household
Population
Group Quarter
Population
Number of
Households
Average
Household
Size
2022 102,880 100,970 1,910 33,951 2.98
2025 103,050 101,130 1,920 33,938 2.98
2030 103,280 101,300 1,980 33,992 2.98
2035 104,290 102,280 2,010 34,324 2.99
2040 105,280 103,250 2,030 34,414 3.00
2045 106,120 104,070 2,050 34,573 3.01
2050 106,680 104,620 2,060 34,756 3.01
2055 106,910 104,850 2,060 34,947 3.00
2060 106,800 104,740 2,060 34,913 3.00
2022-2060 change 3,920 3,770 150 962
2022-2060 annual growth
rate 0.10% 0.10% 0.20% 0.07%
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45 Table 89 – Housing Unit Projection for Unincorporated Areas (excl. SOIs), 2022-2060 Periods New Units Demand Single-family Housing
Units
Multi-family Housing
Units
2022-2025 1,715 1,604 111
2022-2030 1,779 1,663 116
2022-2035 2,165 2,029 135
2022-2040 2,270 2,130 140
2022-2045 2,455 2,307 148
2022-2050 2,669 2,512 157
2022-2055 2,892 2,726 166
2022-2060 2,852 2,688 164
Table 90 – Population Projection for Unincorporated Areas (excl. SOIs) by Age, 2022-2060 Table 91 – Population Projection for Unincorporated Areas (excl. SOIs) by Race and Ethnicity, 2022-2060 Year
22-60
Change
Annual
growth
rate
2022
share
2060
share
Age Group 2022 2025 2030 2035 2040 2045 2050 2055 2060
Total 102,882 103,050 103,285 104,295 105,275 106,116 106,679 106,907 106,803 3,921 0.1% 100.0% 100.0% 5 and below 6,340 6,185 6,949 7,874 8,375 8,153 7,685 7,480 7,498 1,158 0.4% 6.2% 7.0% 6 to 14 12,831 11,449 9,894 10,062 11,347 12,476 12,706 12,092 11,780 -1,052 -0.2% 12.5% 11.0% 15 to 19 8,176 8,116 6,852 5,793 5,435 6,132 6,899 7,252 7,175 -1,001 -0.3% 7.9% 6.7% 20 to 24 6,396 7,752 8,128 6,923 5,865 5,510 6,220 6,955 7,141 745 0.3% 6.2% 6.7% 25 to 34 10,369 10,828 13,414 15,933 15,173 12,976 11,593 11,890 12,375 2,007 0.5% 10.1% 11.6% 35 to 44 11,331 11,022 10,648 11,079 13,536 16,014 15,339 13,133 12,432 1,101 0.2% 11.0% 11.6% 45 to 54 11,721 11,436 11,219 10,835 10,656 11,146 13,547 15,890 15,834 4,112 0.8% 11.4% 14.8% 55 to 64 14,584 13,178 11,150 10,644 10,556 10,316 10,312 10,789 11,438 -3,146 -0.6% 14.2% 10.7% 65 to 74 12,156 12,941 13,059 11,443 9,770 9,364 9,363 9,208 9,133 -3,023 -0.7% 11.8% 8.6% 75 and above 8,977 10,144 11,971 13,709 14,562 14,029 13,015 12,218 11,997 3,020 0.77% 8.73% 11.23% Year 22-60
Change
Annual
growth
rate
2022
share
2060
Race/Ethnicity 2022 2025 2030 2035 2040 2045 2050 2055 2060 share Total 102,881 103,050 103,285 104,295 105,275 106,116 106,679 106,907 106,803 3,921 0.1% 100.0% 100.0% White alone, NH 37,641 35,625 31,670 28,116 24,724 21,640 19,002 16,884 16,250 -21,391 -2.2% 36.6% 15.2% Hispanic or Latino 51,927 53,804 57,695 62,111 66,444 70,306 73,384 75,632 76,182 24,255 1.0% 50.5% 71.3% Black or African
American alone, NH 1,433 1,564 1,798 1,947 2,060 2,181 2,314 2,407 2,421 988 1.4% 1.4% 2.3% Asian alone, NH 7,320 7,527 7,704 7,819 7,856 7,906 8,001 8,122 8,147 827 0.3% 7.1% 7.6% Native Hawaiian and
Other Pacific Islander
alone, NH
74 76 79 84 90 98 107 116 118 44 1.2% 0.1% 0.1%
American Indian and
Alaska Native alone,
NH
878 887 892 900 921 940 956 959 954 76 0.2% 0.9% 0.9%
Some Other Race
alone, NH 572 578 587 575 562 565 573 576 574 2 0.0% 0.6% 0.5% Two or more races,
NH 3,036 2,989 2,858 2,744 2,618 2,480 2,343 2,210 2,156 -880 -0.9% 3.0% 2.0% 1152
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RE S E AR C H RE P O R T
Patterns of Sprawl in Fresno and the
Central San Joaquin Valley
Confronting Past, Present, and Future Housing Development Trends Yonah Freemark Samantha Fu Annie Rosenow Yipeng Su
May 2024
R E S E A R C H T O A C T I O N L A B
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AB O U T T H E U R BA N I N S T I T U TE
The Urban Institute is a nonprofit research organization that provides data and evidence to help advance upward mobility and equity. We are a trusted source for changemakers who seek to strengthen decisionmaking, create inclusive economic growth, and improve the well-being of families and communities. For more than 50 years, Urban has delivered facts that inspire solutions—and this remains our charge today.
Copyright © May 2024. Urban Institute. Permission is granted for reproduction of this file, with attribution to the Urban Institute. Cover image by Jacob Boomsma/Shutterstock. 1174
Contents
Acknowledgments iv
Executive Summary v
Patterns of Sprawl in Fresno and the Central San Joaquin Valley 7 Measuring Patterns of Sprawl in the Central San Joaquin Valley 11 Research Questions 12
Data 12
Methods 13
Limitations 17
Decades of Unabated Sprawl in the Central San Joaquin Valley 18 Development Is More Common in Low-Density, Higher-Income Neighborhoods 27 Most of the Region Remains Natural in Character, but There Have Been Recent Losses to Agricultural and Developed Uses 28
Consequences of Sprawl and Lost Opportunities for Denser Development 32 Moving Beyond Sprawl 36
Appendix A. Alternative Density Measures 39
Appendix B. Regional Development Trends 44
Notes 45
References 47
About the Authors 49
Statement of Independence 50
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ST A T E M E N T O F IN D E P E N D E N C E
The Urban Institute strives to meet the highest standards of integrity and quality in its research and analyses and in the evidence-based policy recommendations offered by its researchers and experts. We believe that operating consistent with the values of independence, rigor, and transparency is essential to maintaining those standards. As an organization, the Urban Institute does not take positions on issues, but it does empower and support its experts in sharing their own evidence-based views and policy recommendations that have been shaped by scholarship.
Funders do not determine our research findings or the insights and recommendations of our experts. Urban scholars and experts are expected to be objective and follow the evidence wherever it may lead. 1222
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adverse effects on existing retail and the contribution to urban decay and consequent environmental impacts. CEQA does not define urban decay. However a prominent CEQA case involving an urban decay study, Bakersfield Citizens for Local Control v. City of Bakersfield, defined physical impacts of urban decay as long term vacancies, graffiti, weeds, and unsightly conditions.
In 2021, data scientists at Stanford University created a model to detect signs of urban decay in cities. They defined urban decay by eight visual indicators: potholes, graffiti, garbage, tents, barred or broken windows, discolored or dilapidated facades, weeds, and utility markers. They used the model to analyze photos for these eight indicators in three cities, San Francisco, Mexico City, and South Bend, Indiana. They found that these indicators closely matched the historical trends of decay for neighborhoods in these cities.
For this study, we utilized these physical indicators of urban decay while also considering the City of Fresno’s definition of blight.
From the Fresno Municipal Code (FMC), blight is defined as:
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of building including paint and finishes, Remove
trash within 72 hours, maintain building with all
state and city codes, regulations and permits take
all reasonable steps to prevent illegal or criminal
activity on premises, secure the property:
replacing broken windows or doors. Boarding up
is a “disfavored technique”; remove all Graffiti
within 48 hours. (FMC 10-603.C)
While urban decay and blight are not interchangeable, the City's definition of blight also highlights the physical and economic burdens placed on the community from dilapidated properties.
How is Urban Decay Measured?
Across these previous urban decay studies, the indicators of decay are physical elements that signal disinvestment in an area.
However, deteriorating economic conditions from disinvestment can both cause the physical decay and be an externality that creates a cycle that continues to degrade the quality of life for those residents still present in the community. For this study, we move beyond physical characteristics to also evaluate the indicators, symptoms, and potential causes of urban decay with respect to economic, social, and quality of life factors. 1228
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directed funding for the inadequate infrastructure, and understand the need especially in historically disinvested neighborhoods. The atmospheric river storms this past winter highlighted the worsening conditions of Fresno’s city streets; the Mayor has addressed this issue in his budget proposal this year by allocating $3 million more dollars to street maintenance this fiscal year.
In January 2023, Fresno's Public Works Director
estimated that the backlog of repair for Fresno
city streets is $500 million.
The State has also recognized the importance of upgrading the infrastructure in Downtown in order to support new residential development and the future of the city. Governor Newsom directed $250 million of the 2023-2024 state budget to fund infrastructure improvements in Downtown Fresno. This funding would support new wastewater and sewer systems, a stormwater drain basin, sidewalks, linear green space and pocket parks, an intermodal transit center, and two new parking structures to facilitate housing development in Downtown Fresno. These investments are
indicative of the barriers to private development and investments in these districts.
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Developers have expressed many concerns about the high costs of providing adequate water and sewer lines when building in certain neighborhoods. The infrastructure in the city can be 80-100 years old depending on the neighborhood, so private investors face uncertainty and greater risk, since they cannot know the condition of the infrastructure until construction begins. If the developer has already created a pro forma and secured debt for the project, and then the condition of the infrastructure is not as expected, it may not be feasible for developers to find additional capital–which may require mezzanine financing at higher interest rates.
This dynamic can make development projects more expensive than originally planned, such that the developer may not hit their needed returns. Thus, developers often prefer to build in locations outside of the city center, including land requiring annexation where they can accurately assess infrastructure costs, and in many cases, receive public investment to support off-site and systemwide infrastructure. 1236
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and large vacant parcels, there has been a lack of private investment in many areas of the city. When there are not comparable existing market-rate mixed-use development projects, developers expressed that it is hard to understand the rent/ unit mix and the demand for these projects, and it can be a challenge to access financing to build certain product types because developers cannot show financial institutions, who are deliberate about placing capital, that other similar buildings have been successful in the community.
The lack of private development is a symptom of decay because the private market relies on indicators in the real estate market to signal a healthy market that will provide the needed return on investment to the developer and the bank. If these return rates cannot be met in the local market, it will be hard for private development to invest in these decayed neighborhoods.
Source: CoStar, Developer Interviews
Quality of Life
Quality of life is also a significant component of understanding urban decay. Scroll through this section to see indicators in Fresno related to socioeconomic conditions, environmental quality, and education.
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Household Income
In 2021, the median household income in the City
of Fresno was $63,000 while the countywide
average was $65,000, indicating that higher
income households are migrating outside of the
city limits.
The City of Fresno has seen real income growth over the last 10 years. Real median household income increased by 7% between 2010 and 2021. During the 1990s and 2000s, real income decreased by 5% before rebounding in the 2010s. This trend mirrors the rest of the state due to the recessions in the early 1990s and 2000s.
Between 1980 and 1990, Fresno County and City of Fresno saw the largest increase in real median household income of approximately 22%. Fresno County has seen modest growth in median household income since the 1990s while the City of Fresno experienced a decrease in median household income between 1990 and 2010.
The map on the right shows the change in median household income between 1980-2020. The further from the central city a household is, the higher the median household income; households with higher incomes have more options and have moved north or out of the city, leaving behind lower income households and decaying conditions. The exodus of higher incomes leaving the city exacerbates urban decay, as these wealthier households move their spending power and tax
revenues out of the neighborhoods where they are needed the most.
Source: Community Survey and Decennial US Census
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Overcrowding
HUD defines a dwelling unit as overcrowded if there is are than one person per room. Notably, the persons per room (PPR) definition of overcrowding differs from that of persons per bedroom. This method of measuring overcrowding includes those living situations in which household members sleep in multi-use spaces, such as a living room. We use the persons per room definition of overcrowding due to data availability.
Using the HUD definition of overcrowding, in
2021 11% of households are overcrowded in the
City of Fresno.
Historically, the rate of overcrowding has been higher in Fresno County than the City of Fresno. However, in 2021, 11% of households in the City of Fresno were overcrowded while 10% were overcrowded within the county. Prevalence of overcrowding in the city and county was highest during the 1990s*, reaching 17% in 2000. Since the 2000s, the rates of overcrowding have decreased to approximately 10% across the city and county.
The map on the right shows the share of households with over 1 person per room between 1990-2020. Overcrowding is concentrated in Central, Southeast, and Southwest Fresno, while neighborhoods on the northern periphery of the city have the lowest rates of overcrowding. Some households may want to move out of a crowded housing unit, but Central and South Fresno have very low vacancy rates and very little new development because they are decaying neighborhoods,
which can leave people trapped in overcrowded units.
*Note: overcrowding data was unavailable prior to 1990.
Source: Community Survey and Decennial US Census
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Start Here: Fresno Corridors
This section of the map walks through five significant areas for understanding urban decay in Fresno, including Blackstone, Kings Canyon/Ventura, Hidalgo, Downtown, and Southwest… Blackstone Corridor
Blackstone Avenue is a major arterial that runs north-south in the City of Fresno. Until the current Highway 41was constructed in the 1980s, Blackstone Avenue was the primary route… Blackstone: High Commercial Vacancy
There are many vacancies along this corridor that contribute to blight, given that there are many large, big box vacancies, including the Sears. There are lifestyle centers that are vacan… Blackstone: Vacant Parcels
There are about 30 vacant parcels in this corridor that total just over 44 acres, or 1.9 million square feet, of vacant land. The average size of the vacant parcels is just under 1.5 acres. Of… Blackstone: Substandard Buildings
Between 2015-2022, Code Enforcement received 763 code violations along Blackstone Avenue: 33 commercial violations, 165 housing violations, 459 public nuisance violations, a… Blackstone: Lack of Private Investment
Blackstone Corridor has the potential to be a thriving mixed-use and transit-oriented community, but it has seen limited development in recent years. As part of the Citywide… Blackstone: High Injury Network
Blackstone Ave contains the most crashes out of any of the major streets in Fresno:
Kings Canyon/Ventura
The Ventura/Kings Canyon Corridor looks at the region between First and Chestnut, from Tulare to Butler. Along Ventura/Kings Canyon Road, the Q BRT runs every 10 minutes… KC/Ventura: Housing Stock
There are about 1200 multi-family units across 70 buildings in this corridor. There is a high d d f t l it i thi i hb h d d th t i tl 3% Th
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demand for rental units in this neighborhood and the vacancy rate is currently 3%. The… KC/Ventura: Public Transit Amenities
This is a corridor where many individuals rely on public transit and along the FAX Q BRT line; despite the frequent and high transit use, there is inadequate amenities for public transit… KC/Ventura: Vacant Parcels
There are about 10 acres of vacant land in this corridor, with the average vacant lot size of about 1/2 acre. The vacant parcels provide an opportunity for redevelopment, but the averag… KC/Ventura: Lack of Private Investment
This area has not seen significant private investment, despite its strong potential to serve as a mixed-use corridor. Since 2000, there have been a couple multi-family buildings that have… Hidalgo
The Hidalgo Community is a diverse neighborhood along Belmont Avenue, just east of Downtown Fresno. Hidalgo Elementary School reports that 79% of their students are Hispan… Hidalgo: Median Household Income
The median household income in the Hidalgo neighborhood has been roughly half of the city average since 1970. In 1970, median household income in Hidalgo was $32,600 and only… Hidalgo: Poverty Rate
In the 1970s, the Hidalgo neighborhood experienced approximately the same poverty rate as the city and the county. However, during the 1980s, the city -wide poverty rate decreased… Hidalgo: Tenure
Hidalgo has a higher share of renters than the city average (41%). In 2021, 68% of households in Hidalgo were renters.
Hidalgo: Housing Stock Age
Hidalgo has an older and aging housing stock. In the City of Fresno, 58% of homes were built before 1979 while in Hidalgo, 77% of homes were built before 1979. There has not been… Hidalgo: Overcrowding
In Hidalgo, 22% of households were experiencing overcrowding in 2021, while only 11% were 1257
experiencing overcrowding across the city. The degree of overcrowding has decreased over… Hidalgo: Cost-Burdened Renters
Households that spend more than 30 percent of their gross income on rent are defined by the Department of Housing and Urban Development (HUD) as cost-burdened, and Hidalgo has a… Hidalgo: Pedestrian & Transit Amenities
This community relies heavily on public transit and walking to get to where they need to be.
There are limited amenities for public transit users and pedestrians and many of the bus sto… Hidalgo: Vacant Lots
There are 14 acres of vacant land in this neighborhood, with the average lot size of just under 1 acre. These vacant lots signal a lack of investment in the community.
Downtown
Downtown Fresno was the original epicenter of Fresno as it was located next to the rail station. Fulton Street was a bustling place from the 1920s through 1950s, but in the1960s… Downtown: Office Market
In Downtown, there is over 5 million square feet of office space in over 130 buildings. The average office building was constructed in 1962, and 8% of buildings have been renovated… Downtown: Retail Vacancy
There is over 2 million square feet of retail space in Downtown. Along Fulton Street, there is a visibly high vacancy rate with the majority of spaces sitting empty or boarded up. The visibl… Downtown: Lack of Private Investment
There are concerns over the condition of water and sewer lines in Downtown as some of them are 80 to 100 years old, which can hinder new residential development because the develope… Downtown: Residential Market
Since 2000, multi-family development has rebounded in Downtown Fresno and 64% of the units in Downtown built since 2000 were located in the Mural District/Cultural Arts District.… Downtown: Events & Entertainment
Downtown Fresno serves as the Downtown and event hub for Fresno County and it hosts 1258
Downtown Fresno serves as the Downtown and event hub for Fresno County and it hosts many events that are well attended by people from throughout the region. In 2019, the… Downtown: Vacant Lots
Excluding land owned by the California High Speed Rail Authority, there is just over 11 acres of vacant land in the Downtown core. The average lot size is under 1/2 an acre. There is land… Downtown: Commute Patterns
Less than 1% of employees both work and live in Downtown Fresno and the majority of workers commute to Downtown Fresno from the surrounding neighborhoods. The mean trav… Downtown: Population Density
Downtown Fresno is historically denser than the city overall, and the population density has increased from 4,950 persons per square mile in 1970 to 6,880 persons per square mile in… Downtown: Employment Density
Downtown Fresno nonetheless remains the epicenter of employment in Fresno, with nearly three times as many jobs per square mile in comparison to the City of Fresno as a whole.
Southwest Fresno
Southwest Fresno comprises a large geographical area southwest of the 99 that has experienced historic disinvestment from racially discriminatory policies and redlining.… Southwest: Median Household Income
Residents of Southwest Fresno have only experienced modest gains in real income since the 1980s; between the 1980s and 1990s, the median household income in Southwest Fresno… Southwest: Poverty Rate
The poverty rate in Southwest Fresno has hovered between 28% and 42% since the 1970s.
Southwest Fresno residents were experiencing an increasing poverty rate since 1980; only… Southwest: Tenure
Southwest Fresno has a higher share of renters than the citywide average (41%). In 2021, 70% of households in SW Fresno were renters.
Southwest: Housing Stock
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Southwest Fresno has an older and aging housing stock than the city-wide average. In the City of Fresno, 58% of homes were built before 1979 and 65% of homes in Southwest Fresno were… Southwest: Substandard Housing
There are over 1600 units of multi-family housing in this neighborhood, and about 90% of the units are rent restricted or subsidized units. The average asking rent per unit per month of t… Southwest: Cost-Burdened Renters
Currently, over 55% of renters in Southwest Fresno are cost-burdened, which is higher than the average city and county cost-burdened rate. These households will have less disposable… Southwest: Overcrowding
Overcrowding in SW Fresno has decreased over time, but still lies above the city average. In 2021, 1% of households were overcrowded in SW Fresno. Notably, the percent of households… Southwest: Vacant Lots
In this neighborhood, there are 370 acres of vacant land, with the average lot size of 5 acres.
There is significant land available for residential development, however the private real esta… Southwest: Air Quality and Environment
Southwest Fresno has the highest CES score, indicating the highest levels of pollutants, as compared to the City and County.
Southwest: Extreme Food Hardship
Based on the USDA 2019 data, many of the census tracts in Southwest Fresno experience food hardships as residents have longer distances to go to reach a grocery store. This issue is… What Causes Urban Decay?
Inefficient Land Use (Sprawl)
Development in the City of Fresno originally moved from Downtown to the north, capping out at the San Joaquin River. 1260
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Since new migration to the City of Fresno has a lower income than the City and County median income, these new households are unable to rent or buy housing at the high end of the market; they would thus likely be seeking rents/sales prices in the City of Fresno at or below the Fresno market median.
The data on population and migration shows that the existing residents of Fresno have moved out of central areas of the City to the newly annexed land, and that new migration to the City of Fresno has lower household median income than the city average, and would likely be seeking more affordable units.
Therefore, new developments in annexation areas cannot
completely pay for themselves because, on average, they are not introducing new residents to the tax base but rather shifting residents around within the City. Also, as the City increases the number of square miles within its boundaries, it increases the miles of roads, infrastructure, and emergency services that it must finance, staff, and maintain. There is not data or studies that suggest these new communities are self-sufficient and pay for themselves over time.
Flight
There is a long history of racial segregation in the City of Fresno and there has been an exodus of white households from the city boundaries as the city has become more diverse overtime.
At the city’s inception, the railroad tracks were a divider; immigrants were forced to live west of the railroad tracks in West Fresno. Redlining from the 1930’s exacerbated the racial divide in Fresno, as neighborhoods with large minority populations, including West and Southwest Fresno, were demarcated in red and denied mortgages. In the north, neighborhoods like Fig Garden were primarily white; these buyers were approved for loans, and their deeds had race-restricted covenants excluding certain races, which perpetuated the segregation of neighborhoods by race. In 1262
1937, the city was comprised of 90% white residents; by 1970, Fresno had become a majority minority city. White residents continued to move even further from central Fresno, and by the 1970’s. the dividing line between white communities and minority communities moved from the railroad tracks to Shaw Avenue, showing white flight out of the central city.3 As of 2022, nonLatino white residents comprise only 30% of the population. As the demographics of the city have changed and became more diverse, and white residents have moved further north, they have left legacy neighborhoods behind and the geographic division between racial groups has become even clearer.
Higher-income households moving out of the legacy communities exacerbates decay, as there is a loss of property tax and sales tax revenue, and local spending, which in turn impacts local businesses and the level of services for these legacy communities.
When schools see negative impacts to their funding from a loss of tax revenue, families with more mobility and financial options typically seek a stronger performing school district and leave, causing further harm to these school districts.
Investment Patterns (Public and Private)
The pattern of public and private investment can
disproportionately impact the physical, economic, and social trajectory of a community in several ways. On the upside, investments in parks, streets, public safety, and infrastructure have placemaking value. These are amenities that drive market premiums and create a virtuous cycle of private investment and reinvestment. On the downside, deferred maintenance, deferred upgrades, and antiquated infrastructure have negative impacts by drawing down market premiums while also creating additional costs, greater uncertainty, and increased risk for capital markets in attracting private investment, perpetuating the decay of the neighborhoods left behind.
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positive and negative impacts on different communities. In Fresno, Freeway 99 was constructed in the 1950’s and created a physical barrier between east and west Fresno, further perpetuating the divide in the city and between racial groups. The construction of the freeway destroyed over 20 blocks of housing, as well as the Black community’s business district.4
Location/Relocation of Institutional Uses
Institutional uses like government facilities, hospitals, higher education, and social services can serve as anchors for neighborhoods and districts in a city. These uses provide employment opportunities, attract students and faculty, and provide services to local residents. Together these institutions create daytime employment, support commercial uses, and create demand for housing and other services.
However, Fresno has a history of large-scale public and governmental users leaving the central city to move further north in the city.
• In 1956, Fresno State College moved from its original location off McKinley Ave (in the Tower District west of Blackstone Ave) to its current location in Northeast Fresno, adjacent to Clovis. • Hospitals have also left the central city for locations farther north, which moves thousands of jobs to more suburban
locations and makes it harder for a subsect of the community, who are less likely to have a personal vehicle, to access medical care. Saint Agnes Medical Center opened in 1929 on Fruit and Floradora Avenues in Central Fresno.5 In the 1970s, the Medical Center moved north to its current location on Herndon Ave in Northeast Fresno. Saint Agnes is currently one of the top 25 employers in Fresno County.6
• Also, in 1952, Valley Children’s Hospital opened on Shields and Millbrook Avenues in Central Fresno but moved north to
Madera County in 1998.7 Today, the Valley Children's
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Healthcare System has 3,500 employees, which could have been Fresno jobs, and represents the loss of Central California’s only high-quality, comprehensive care exclusively for children to Madera County.8
• This trend of institutional uses leaving Central Fresno has continued into the 2000’s; in 2021, Fresno County Social Services moved 2,200 employees from 40 dispersed buildings in the City of Fresno into a centralized one-stop location at an office park in Clovis. This move represented a loss of jobs in the City of Fresno and means that for some residents in Southeast and Southwest Fresno, it can take longer to access social services.
Location of Uses with Negative Externalities
While uses that benefit the communities of central Fresno, including universities, hospitals, and social services, have moved north, the City has a history of allowing disruptive uses in the central city.
• In Southwest Fresno, land that was designated for agricultural uses has been approved for industrial uses, despite the neighborhood consisting primarily of residential uses and single-family homes.
• In 1937, the City bought 20 acres of land near West and Jensen Avenues, three miles southwest of the City of Fresno, for the Fresno Sanitary Landfill, which eventually grew to 140 acres.
The landfill accepted all types of waste, including waste that causes negative externalities on the community including municipal solid waste, pesticides and herbicides, battery acids, and petroleum products. In 1983, the City discovered methane gas onsite and in 1984, the California Department of Health Services conducted a preliminary inspection of the site because neighboring residents submitted numerous complaint letters.
Inspections of the groundwater determined that 20 hazardous substances in the water. The landfill closed in 1987.9
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• In 1947, Sierra Meat Co. (eventually owned by Darling International) opened a plant outside the city limits and the city eventually incorporated the area surrounding it. In recent decades, community residents have expressed heavy opposition to the rendering plant operations for its environmental impacts.
The plant processes animal products and creates a noxious smell for the community. The rendering factory will operate until its planned closure in December 31, 2023.10
• Currently, in the Southwest Fresno Focus Area there are over 300 acres of land occupied by industrial users, including food processing, manufacturing, warehousing, and distribution space (Source: CoStar, 2023).
References
[1] ABC 30, “Fresno City Council Approves Anti-Blight Ordinance,” ABC30 Fresno, May 15, 2015, https://abc30.com/blight-fresnocentral-home-owners/724786/. [2] Jason Oliviera, “Fires in Vacant Buildings Are Rising in Fresno,” ABC30 Fresno, December 4, 2019, https://abc30.com/fresnostructure-fire-vacant-building-homelsess-homeless/5734688/. [3] Reis Thebault, “Fresno’s Mason-Dixon Line,” The Atlantic, August 20, 2018, https://www.theatlantic.com/politics/
archive/2018/08/fresnos-segregation/567299/.
[4] Ibid.
[5] Saint Agnes Medical Center, “About Us,” www.samc.com, accessed July 20, 2023, https://www.samc.com/about-us/. [6] State of California, “Major Employers in California,” 2023, https://labormarketinfo.edd.ca.gov/majorer/countymajorer.asp? CountyCode=000019.
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[7] Valley Children's Healthcare, “Our History,” accessed July 20, 2023, https://www.valleychildrens.org/about-us/
history#:~:text=1952%3A%20Through%20fundraising%20efforts% 20by.
[8] Valley Children's Healthcare, “Why Choose Valley Children’s,” accessed July 20, 2023, https://www.valleychildrens.org/about-us/ why-choose-valley-childrens.
[9] City of Fresno, "2001 National Historic Landmark Nomination," https://www.fresno.gov/publicutilities/wp-content/uploads/ sites/16/2020/12/2001-National-Historic-Landmark-NominationFresno-Sanitary-Landfill.pdf. [10] Dom McAndrew, “Fresno Meat Rendering Operation to
Permanently Close,” Your Central Valley, April 21, 2020, https:// www.yourcentralvalley.com/news/local-news/fresno-meatrendering-operation-to-permanently-close/. 1267
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SB 2 Planning Grants Application
E. Project Description
Provide a description of the project and the scope of work to be performed below. Use Appendix A for additional information if necessary. Note: If partnering with another local government or entity, be sure to clarify the resconsibilities and deliverables of your locality cursuant to such 1Jartnershic.
The City of Fresno has completed an administrative draft of a Specific Plan which embodies a unique approach to planning in Fresno. Completion of the plan will require updates for new greenhouse gas emission reduction targets, the conversion from LOS to VMT, updated water conservation measures, completion of infrastructure assessment, fiscal nexus study and a Program EIR. At conclusion the package of Specific Plan, EIR and Nexus Study will increase density and accelerate housing production. The plan includes a commitment to sound public finance and fiscal accountability, a vision for complete neighborhoods and communities, and environmental responsibility at all levels.
The Plan is based upon a hierarchy of walkable mixed-use centers supported by a multi-modal transportation network. Centers which serve as commercial and civic focal points are designed to include a mix and intensity of uses and a diversity of housing types. The range of housing products integrated throughout the community offers flexibility in meeting the evolving needs of households in the region. Although Fresno's average housing costs are less than half those of the Bay Area and Southern California, its production has not kept up with demand. Providing lower cost housing in the center of the state will make Fresno a prime location for achieving the State's housing production goals.
The number of dwelling units and densities contemplated for the specific plan area are: a total of approximately 45,000 units broken down into six housing districts: Regional Center with 3500 units at 30-100 du/acre; Community Center with 5500 units at 25-80 du/acre; Neighborhood Center with 3200 units at 15-40 du/acre; Mixed Residential with 15,100 units at 8-60 du/acre; Neighborhood Residential with 16,800 units at 6-30 du/acre; and Rural Cluster with 100 units at 0.1-0.5 du/acre as an agricultural buffer zone. The Plan proposes to reduce annual household costs from transportation and utilities by 57% thereby increasing affordability for renters and homeowners.
In addition, the Plan proposes to reduce VMT by 57%, to reduce GHG emissions from cars and buildings by 60%, to reduce air pollution from cars and trucks by 83%, and to reduce water use by 59%.
To complete the Specific Plan, an EIR, an infrastructure assessment, and a fiscal nexus study must be completed prior to adoption. The City has not yet selected a consultant for this work but has current estimates based upon recent contracts. The City does not have funding to complete the work but has identified SB2 PGP as a uniquely compatible funding source.
The City proposes to prepare a Program EIR per CEQA Guidelines Section 15168. The proposed EIR will include a detailed programmatic evaluation of activities to be carried out through Specific Plan and will allow the City to incorporate feasible mitigation measures including a streamlining checklist to evaluate site specific operations within the scope of the program EIR. This use of streamlining will fast-track the production of much-needed housing for the City and the region.
Finally, since the Program EIR is for a Specific Plan, future development will also utilize an expanded exemption under Government Code Section 65457 that will apply to certain residential, commercial, and mixed-use projects that are consistent with a specific plan adopted pursuant to Government Code, Article 8, Chapter 3 and would be exempt from CEQA. This new exemption is outlined in the final text of Section 15182 of the CEQA Guidelines.
CA-HCD SB 2 PGP Page 6 of 15 2019 Year-1 Grant Application .
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Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
Public
March 19, 2025
Sophia Pagoulatos
Planning Manager
2600 Fresno Street
Fresno, CA 93721
Re: SEDA Specific Plan
Southeast Fresno Area. Fresno, County
Dear Sophia Pagoulatos,
Thank you for giving us the opportunity to review the subject plans. The proposed SEDA Specific Plan is within the same vicinity of PG&E’s existing facilities that impact this property.
The proposed project is within PG&E’s service area. The applicant is to ensure the development of the SEDA Specific plan within any PG&E easements complies with the existing easement language and the provided guidelines for projects near PG&E electric and gas facilities per the issued initial response letter sent on February 11, 2025. The applicant is to provide development plans and applicable tentative tract maps to PG&E’s Plan Review Team for comment once they are available. The applicant may contact PG&E’s Plan Review Team via email at [email protected].
Guidelines as it pertains to proposed vegetation and landscaping for the various PG&E facilities can be found here.
Please contact the Building and Renovation Center (BRSC) for facility map requests by calling and for any
modification or relocation requests, or for any additional services you may require.
As a reminder, before any digging or excavation occurs, please contact Underground Service Alert (USA) by dialing 811 a minimum of 2 working days prior to commencing any work. This free and independent service will ensure that all existing underground utilities are identified and marked on-site.
If you have any questions regarding our response, please contact me at Sincerely,
Alexa Boyd
Land Management
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PG&E Gas and Electric Facilities Page
2 Public
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From: Kathy Moua
To: LongRangePlanning
Subject: Public Comment on the SEDA Environmental Review Date: Monday, March 3, 2025 10:18:45 AM
External Email: Use caution with links and attachments
Hello,
I am writing to express serious concerns regarding the recent environmental review for the Southeast Development Area (SEDA). The City of Fresno claims that this project will reduce vehicle miles traveled (VMT) by 80% and be a model for sustainable, high-density development. However, there is no extraordinary evidence to support such an extraordinary claim. If SEDA is truly meant to serve the community, the burden of proof is on the developers to demonstrate—through transparent, independently verified data—how this project will avoid the well-documented consequences of unchecked urban sprawl.
SEDA threatens to:
Exacerbate Fresno’s air quality crisis by expanding development rather than investing in sustainable infill and transit solutions. The city's prior environmental review was already ruled inadequate, and yet the revised version still fails to address long-term pollution impacts.
Drain public resources from existing neighborhoods that desperately need infrastructure improvements, diverting attention and funding from long-standing communities.
Displace working-class residents by increasing the cost of living while failing to provide sufficient affordable housing.
Destroy valuable farmland in a region known for agriculture, further eroding local food security and economic sustainability.
Fresno residents deserve development that prioritizes them, not one that benefits developers and special interests at the expense of existing communities. If city officials truly believe in their claims, they must provide rigorous, independently verified evidence—not vague promises—before moving forward. Until then, this project appears to be yet another example of predatory expansion that benefits a select few while harming the people who call Southeast Fresno home.
I urge the City of Fresno to reconsider the approval of this project until real, transparent, and community-driven solutions are put in place. Please do not disregard the 400 pages of public feedback from 2023 and those that will be coming in.
Thank you,
Kathy Moua
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From: Kyle Lyman
To: LongRangePlanning
Subject: Public Comment: SEDA Environmental Review
Date: Monday, March 3, 2025 9:57:38 AM
External Email: Use caution with links and attachments
Hello,
I would like to leave a public comment for the recent SEDA environmental review and the new knowledge I’ve learned about this project.
After seeing this article:
https://fresnoland.org/2025/03/03/will-southeast-fresnos-proposed-mega-development-bedenser-than-new-york-city/?utm_medium=email I urge the city leaders and officials responsible for this project to reconsider the current plan as it has been presented. It is clear that this project will only contribute more to urban sprawl and devastate the environment. It is especially concerning to see a lack of transparency by the city for the data and numbers presented in terms of emissions, as well as urban density that has been misleadingly presented.
While I support the need for growth in our city, the plan presented will only cause more harm than good: for the environment, city traffic, and the overall health and safety of our city residents. There needs to be a much clearer understanding of what assurances will be provided to mitigate environmental impacts from this development. I’d like the city to actually provide how it got to its conclusion that this area will have more urban density than San Francisco based on job to people ratios, since it’s clear in the rest of Fresno this is far from the truth.
To make extraordinary claims, you need extraordinary evidence. The lack of substantial evidence for the city’s claims should give everyone pause and reconsideration for this project as it stands.
Thank you,
Kyle Lyman
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City of Fresno
City of Fresno Planning and Development Department
Sophia Pagoulatos, Planning Manager
2600 Fresno Street, Room 3065
Fresno, California 93721
[email protected]
Re: "Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486"
Dear Ms. Pagoulatos,
I contest the following areas of the Recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486:
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.” I disagree with this assumption because the plan specifies the addition of 45,000 housing units. This will increase the load placed on the electrical grid which is already stressed. For example, currently when we have extremely hot weather the power companies have implemented rolling blackouts to stretch energy as much as possible. This will only increase with the addition of 45,000 housing units and the estimated increase of 250,000 people in the plan area. This has to be addressed in the EIR. Where is all the necessary energy needed for this project to come from?
3.7 Geology, Soils, and Seismicity. Impact GEO-2: “The proposed project would not result in substantial soil erosion or the loss of topsoil.” I disagree with this statement for the following reasons. 1. The topsoil will be disturbed and impacted by the movement of soil to make the housing foundations and streets, disrupting the layers of soil then available for landscape around the houses. 2. The topsoil will be covered by houses and pavement so that it cannot be used for agricultural use including small family farms. 3. This essentially creates a loss of topsoil for use for vegetation which impacts the air quality and environment. This loss needs to be addressed as no mitigation measures are given and the level of impact is very significant.
3.9 Hazards and Hazardous Materials. 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.” I disagree with this statement, especially as we have seen this year, 2025, in the Los Angles area where “wildfires” = uncontrollable fires, have devastated housing and lives in many communities. Mitigation measures need to be taken so this does not happen in 1306
the planned area. With the planned increase in the density of houses, this plan is setting up Fresno for disaster. Alternate plan 1 will reduce this problem and should be used instead.
Impact HAZ-6: “The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.” I disagree with this statement as the way the housing developments are being made with limited access and concrete block walls completely surrounding neighborhoods will limit emergency evacuation, endangering many lives. Mitigation measures need to be stated as the liability and loss of lives is significant. Alternate plan 1 will reduce this problem and should be used instead.
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.” I disagree with the statement as we live in the planned area and the noise from aircraft approaching the airport is very disruptive when trying to hold conservations in person or on the phone, and while listening to audio entertainment. Even dual pane windows do not dampen the noise enough. Mitigation measures are required and the level of impact is Significant.
Section 3.8—Greenhouse Gas Emissions. Impact GHG-1: “The proposed project would not generate direct and indirect greenhouse gas emissions, and these emissions would result in a significant impact on the environment.” I disagree that no greenhouse gas emissions would be created or affected from the proposed plan. This plan will reduce vegetation which absorbs carbon dioxide, one of the leading greenhouse gases. Mitigation measures are required, none are stated and its impact level is significant. You even state in your impact statement that the project will not generate direct or indirect greenhouse gas emissions (I disagree and want to know what data and studies you have done to substantiate this statement), but add that there would be significant impact on the environment. Don’t use this plan, instead use Alternate 1 to keep greenhouse gas concentrations lower.
Section 3.11—Land Use and Planning. Impact LAND-1: “The proposed project would not physically divide an established community.” This plan will divide our established rural communities, disrupting the rural way of life that is healthy for us and our children and grandchildren. Mitigation measures are required as levels of impact are significant.
Cumulative Impact: “The project would have a less than significant cumulative impact on land use and planning.” This project will have a very large and significant cumulative impact on land use as it will take over 6,000 acres of farm land out of production, changing the landscape of the whole community, affecting air quality, and affecting the balance of greenhouse gases. No mitigation measures are stated, even though the impact of this project is significant. This is unacceptable and this Recirculated Program Environmental Impact Report should not be accepted.
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Section 3.12—Mineral Resources. Cumulative Impact: “The proposed project would have a less than significant cumulative impact on mineral resources.” The project would have a great impact on the mineral resources of the soil that crops are grown on. The project limits the availability of the soil for the production of food and fiber for people and animals. The soil is the greatest mineral resource we have available to us and if it is covered by houses and roads as desired by this plan, significant loss of natural resources will happen. This is unacceptable and this Recirculated Program Environmental Impact Report should not be accepted.
Section 3.13—Noise. Cumulative Impact: “The proposed project would have a significant and unavoidable impact regarding construction noise. The proposed project would have a less than significant impact with regard to all other noise and vibration impacts.” The analysis of noise is incomplete as it only addresses noise and vibration impacts during construction. The increase in noise after construction due to road noise and increased population noise is not considered and it would be significant. This makes this Recirculated Program Environmental Impact Report incomplete and it should be rejected until this issue has been addressed.
Based on these reasons, the recirculated Program Environmental Impact Report, Fresno Southeast Development Area Specific Plan Project, City of Fresno, Fresno County, California State Clearinghouse Number 2022020486 should not be accepted.
Please send me notices of any future hearing dates as well as any staff reports pertaining to this project.
Very truly yours,
Dr. David Ramming
Retired Research Horticulturist, USDA/ARS
SEDA area property owner
Member Southeast Property Owner's Association
Please send CC to all City Council Members as they will be voting on this. cc: Sophia Pagoulatos, Planning Manager: [email protected] District 1: Annalisa Pera: [email protected]
District 2: Mike Karbassi: [email protected]
District 3: Miguel Arias: [email protected]
District 4: Tyler Maxwell: [email protected]
District 5: Special Election on March 18th
District 6: Nick Richardson: [email protected] 1308
District 7 Nelson Esparza: [email protected]
City Clerk: Todd Stermer: [email protected]
Mayor Jerry Dyer: [email protected]
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From: art maldonado
To: Adrienne Asadoorian
Subject: Re: SEDA
Date: Tuesday, March 18, 2025 8:37:47 AM
External Email: Use caution with links and attachments
Let me know that you received this…thanks
3.17 Transportation and Traffic regarding SEDA
Concerns and Question: We have been heavily impacted by high levels of traffic in our area due to new neighborhoods, several churches and schools. How will the city address the serious damage to our roads, the high possibility of serious traffic accidents, the lack of adequate lighting for night drivers. Does the city have a financial plan to address these issues. We need to see something in place.
Sent from my iPad
On Mar 17, 2025, at 2:05 PM, Adrienne Asadoorian
<[email protected]> wrote:
Hi Art,
I am unable to view the attachment – can you paste your letter into the email? Thank you,
Adrienne Asadoorian-Gilbert | Supervising Planner
Long Range Planning | Planning & Development
City of Fresno | 2600 Fresno St | Fresno CA 93721
559.621.8339
[email protected]
<image001.jpg>
Resources: Long Range Plans | GIS Data Hub
Citywide Development Code | Plans & Projects Under
Review
From: art maldonado
Sent: Monday, March 17, 2025 1:34 PM
To: LongRangePlanning <[email protected]>
Subject: SEDA
External Email: Use caution with links and attachments
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Sent from my iPad
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“Provide a safe and reliable transportation network that serves all people and respects the environment.” DISTRICT 6 OFFICE
1352 WEST OLIVE AVENUE |P.O. BOX 12616 |FRESNO, CA 93778-2616 (559) 981-7284 | FAX (559) 488-4195 | TTY 711
www.dot.ca.gov
March 21, 2025
FRE-180-R64.104
Southeast Development Area Specific Plan
Recirculated Draft Environmental Impact Report
SCH #2022020486
GTS #: https://ld-igr-gts.dot.ca.gov/district/6/report/25659
SENT VIA EMAIL
Mx. Sophia Pagoulatos
c/o Mx. Adrienne Asadoorian
City of Fresno
2600 Fresno Street Ste. 3065
Fresno, CA 93721
[email protected]
Dear Mx. Asadoorian:
Caltrans District 6 has reviewed the Transportation Impact Analysis (TIA) dated January 30, 2025, for the Fresno Southeast Development Area (SEDA) Specific Plan and offers the following technical comments and recommendations. The TIA is part of the SEDA recirculated draft environmental impact report (DEIR). The proposed development area covers nearly 9,000 acres. It 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.
The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Local Development Review (LDR) process reviews land use projects and plans through the lenses of our mission and state planning priorities of infill, conservation, and travel‐efficient development. To ensure a safe and efficient transportation system, we encourage early consultation and coordination with local jurisdictions and project proponents on all development projects that utilize the multimodal transportation network.
Caltrans provides the following comments consistent with the State’s smart mobility goals that support a vibrant economy and sustainable communities:
1. Queuing and Mitigation Measures (these comments supersede our previous comments):
The TIA conducted a peak hour ramp queuing analysis at project buildout for the following State Route (SR) 180 interchange ramp intersections and SR 180 intersections to assess potential impacts:
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Mx. Adrienne Asadoorian– Southeast Development Area Specific Plan – Recirculated DEIR March 21, 2025