Cities Index.
Exhibit P - Draft Program EIR

Fresno City Council
December 18, 2025

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Exhibit P - Draft Program EIR
Meeting
December 18, 2025
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Fresno City Council
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20.4 MB
Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

This chapter provides a discussion of other CEQA-mandated topics including significant unavoidable impacts, growth inducement, and significant irreversible environmental changes which would be involved in the proposed project should it be implemented. Chapter 5, Alternatives to the Proposed Project, discusses alternatives to the proposed project.

4.1 - Significant Unavoidable Impacts
CEQA Guidelines Section 15126.2(a)(c) requires an Environmental Impact Report (EIR) to identify and focus on the significant environmental effects of the proposed project, including effects that cannot be avoided if the proposed project were implemented.

This section describes significant impacts, including those that can be mitigated but not reduced to a level of less than significant. Where there are impacts that cannot be alleviated without imposing a project alternative, their implications, and the reason why the project is being proposed, notwithstanding their effect, is described. With implementation of the proposed project, several significant impacts that cannot be avoided would occur. Each significant unavoidable impact is discussed below.

Impact AES-3 (Project-level Visual Character)
The proposed project would, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). Buildout of the Southeast Development Area (SEDA) Specific Plan would alter the existing visual character by increasing the intensity of development in many areas that are primarily agriculture. No feasible mitigation measures are available to mitigate the impact to a less than significant level.

Impact AES-4 (Project-level Light and Glare)
The proposed project would create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Intensified development in the Plan Area could increase the amount of light from streetlights, exterior lighting from buildings, and vehicle headlights. The increase in lighting within the Plan Area could result in light spillover onto adjacent areas and could City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Recirculated Draft Program EIR

4-2 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx substantially illuminate the sky during nighttime. This increase in illumination is considered a significant impact. Implementation of Mitigation Measure (MM) AES-4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project by requiring shields, low- intensity fixtures, requirements for signs, and non-reflective materials. However, impacts would remain significant and unavoidable.

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

However, impacts would remain significant and unavoidable.

Impact AG-1 (Project-level Conversion of Farmland to Nonagricultural Uses) There are approximately 2,475 acres of land designated as Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and approximately 1,725 acres of land designated as Unique Farmland scattered throughout the Plan Area. Through its open space framework and land use objectives and policies, the Specific Plan would allow flexibility in the location, form, and function of diverse agricultural types within communities and would establish a buffer between the urban area of the City of Fresno and the surrounding agricultural land. The proposed project would implement MM AG-1, which requires future developments within the Plan Area to evaluate and mitigate the potential loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland by utilizing the Land Evaluation and Site Assessment (LESA) Model and 1:1 conservation easements, or other recorded instruments to mitigate the loss of farmland. If the City adopts a Farmland Preservation Program pursuant to Fresno General Plan Policy RC-9-c, MM AG-1 states that project proponents may compensate for the loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland by complying with the adopted Farmland Preservation Program. However, while implementation of MM AG-1 would reduce the degree of potential impacts associated with future development under the Specific Plan, the conversion of Farmland to nonagricultural uses would still occur. Therefore, this impact would be significant and unavoidable even with implementation of available mitigation.

Impact AG-2 (Project-level Conflict with Existing Zoning or Williamson Act Contract) According to the General Plan, the City and its Sphere of Influence (SOI) includes lands under Williamson Act Contract for prime and non-prime agricultural land. According to the Williamson Act property map, the majority of Williamson Act properties within the City and SOI are located within the Plan Area. Therefore, the continued implementation of the approved General Plan and the proposed Specific Plan could conflict with existing Williamson Act Contracts because non-agricultural uses are allowed on the land under a Williamson Act Contract. As a result, the continued implementation of the General Plan and proposed Specific Plan could result in a significant impact City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Other CEQA Considerations

FirstCarbon Solutions 4-3
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx on existing Williamson Act Contract land. While the policies included in the Specific Plan would directly limit farmland conversion and thereby help to preserve agriculture in the Plan Area and implementation of MM AG-1 would reduce impacts related to the conversion of Farmland to nonagricultural use, buildout of the proposed project would still result in the conversion of Williamson Act land to nonagricultural uses. Therefore, this impact would be significant and unavoidable without any available mitigation to reduce it to less than significant.

Cumulative Agricultural Resources and Forestry Resources Impacts Although the proposed project would promote small farms, community gardens, and farmer’s markets, future development in areas outside of the Plan Area, in combination of the loss of Prime Farmland within the Plan Area, would result in the conversion of farmland to nonagricultural uses despite the implementation of MM AG-1. Therefore, the implementation of the proposed project would result in a significant and unavoidable impact on agricultural zoning and Williamson Act Contracts. The proposed project includes land use changes that would result in the conversion of farmland to nonagricultural uses, and no feasible mitigation measures are available. Therefore, this impact would be significant and unavoidable.

Impact AIR-1 (Project-level Consistency with Air Quality Management Plan) The proposed project has the potential to exceed the San Joaquin Valley Air Pollution Control District (Valley Air District) significance thresholds during construction and operation. Implementation of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the Valley Air District regional significance thresholds and would therefore not be considered consistent with the existing Air Quality Plans (AQPs). MM AIR-1a through MM AIR-1d would serve to reduce emissions and exposures, however not to levels below the significance thresholds. No further measures are available beyond the applicable Valley Air District rules and regulations in addition to the proposed project’s policies and design guidelines.

The various goals and policies of the proposed project would contribute to reducing long-term criteria air pollutant emissions to the extent feasible. However, due to the magnitude and intensity of development accommodated by the proposed project, it would have a significant and unavoidable impact.

Impact AIR-2 (Project-level Cumulative Criteria Pollutant Emissions) Compliance with existing regulatory programs, General Plan policies, and MM AIR-1a through MM AIR-1d would serve to reduce the impacts of the proposed project to the extent feasible. While adherence to Rule 9510 would contribute to reducing exhaust nitrogen oxide (NOx) emissions, it would not be applicable to reducing volatile organic compound (VOC) emissions generated by operation of equipment and from off-gassing from asphalt and paints. Additionally, there is potential for multiple projects to be constructed at one time in the Plan Area, resulting in the generation of cumulatively significant amounts of NO
x emissions. Regional emissions generated by the proposed project would exceed applicable thresholds for cumulative criteria pollutant emissions after compliance with all rules, regulations, and mitigation measures during operation. While compliance with the Valley Air District rules and the policies of the proposed Specific Plan may contribute to reducing operation-related regional air quality impacts of individual projects envisioned under the City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Recirculated Draft Program EIR

4-4 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx proposed Specific Plan to less than significant levels, the projected cumulative emissions associated with future development projects would be in exceedance of the Valley Air District thresholds.

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

Impact AIR-3 (Project-level Sensitive Receptors Exposure to Pollutant Concentrations)
Compliance with existing regulatory programs, General Plan policies, and MM AIR-1a through MM AIR-1d would serve to reduce the impacts of the proposed project to the extent feasible. However, the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Further, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds.

Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants, and thus a significant and unavoidable impact may result.

Cumulative Air Quality Impacts
While implementation of MM AIR-1a through MM AIR-1d would serve to reduce criteria air pollutant and toxic air contaminants (TAC) emissions generated by the proposed project, there is currently not enough information to quantify emissions of specific project development that may occur under the proposed project. Without quantification to guarantee a less than significant finding, future development projects may still exceed the Valley Air District regional significance thresholds.

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

Impact NOI-1 (Project-level Construction Noise)
Short-term construction noise impacts associated with the project are an increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site and noise generated during site-preparation, grading, and construction activities. With implementation of MM NOI-1a and MM NOI-1b, construction noise impacts due to construction activities would be reduced to the extent feasible. However, given that details of individual development projects in the vicinity of the Plan Area are currently unknown, it is not possible to quantify the construction noise impacts at specific off-site or on-site sensitive receptors. Because City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Other CEQA Considerations

FirstCarbon Solutions 4-5
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx these construction activities may occur near noise-sensitive receptors and because noise disturbances may occur for prolonged periods of time, construction noise impacts would remain significant and unavoidable.

Cumulative Construction Noise
Given that details of individual development projects adjacent to the Plan Area are currently unknown, it is not possible to quantify future cumulative construction noise impacts that could occur if multiple developments were to be constructed simultaneously, which could constitute a cumulative noise impact. Because construction activities associated with implementation of the Specific Plan could then also occur simultaneously and because noise disturbances could occur for prolonged periods of time, there is the possibility for a cumulative construction noise impacts that would remain significant and unavoidable.

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

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

As discussed in Chapter 2, Project Description, buildout of the proposed project could generate up to approximately 45,000 homes and 37,000 jobs as well as 1,820 acres of employment-generating land uses such as office, research and development, and institutional uses by the year 2050. Based on the City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Recirculated Draft Program EIR

4-6 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx average household size in the City of 2.99 persons per household, this anticipated future development could accommodate up to 134,550 residents. The population potential for the Plan Area is within the population growth anticipated by the General Plan, which anticipates growth of up to 226,000 additional residents by 2035, consistent with the proposed project. Accordingly, implementation of the proposed project would not exceed the City’s anticipated population growth.

The population projections described above are consistent with the population projections and methodology found within the City’s General Plan and utilize the best data available at the time this analysis was prepared. This approach is consistent with requirements to maintain consistency with the General Plan. By evaluating the proposed project within the context of the General Plan, the City is able to comprehensively assess future demand for resources such as water and energy as well as public services, such as police, fire, and education. Utilizing projections for the proposed project that are consistent with the General Plan allows for the development of Specific Plan Policies and Programs that are reflective of the City’s planned for and approved growth identified in the General Plan.

According to the General Plan, the City projects that the total additional residential development capacity by the General Plan’s horizon in 2035 would be approximately 76,000 additional dwelling units and by the General Plan’s buildout in 2050 would be approximately 145,000 additional dwelling units between both the infill and growth areas.
1 These values constitute the planned growth
anticipated by the City for residential units within its SOI. As the proposed project would generate approximately 45,000 new dwelling units by 2050, approximately 31 percent of the total planned capacity for the City, full buildout of the proposed project would be considered planned growth providing housing to meet the demand for new residential units and would not be considered growth inducing.

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

1 City of Fresno. 2014. General Plan, Table 1-2, Residential Development Capacity Under Horizon and Buildout, and Table 1-3, Residential Development Capacity Under General Plan Horizon. Website: https://cityoffresno.wpenginepowered.com/darm/wp- content/uploads/sites/10/2022/12/upload_temp_Consolidated-GP-10-13-2022.pdf. Accessed January 20, 2023.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Other CEQA Considerations

FirstCarbon Solutions 4-7
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx Finding No. 1: Less than significant impact with mitigation incorporated.

Based on the analysis provided in Section 3.4, Biological Resources, the proposed project’s impacts related to special-status species and special-status natural communities and habitat would be less than significant with mitigation incorporated. Additionally, the proposed project’s impacts on riparian habitat, a special-status species associated with riparian or wetlands habitats, as well as federally protected wetlands, and wildlife corridors would be less than significant with mitigation incorporated. Therefore, implementation of MM BIO-1a through MM BIO-1d would reduce impacts on special-status species. Implementation of MM BIO-2a through MM BIO-2c would reduce impacts to sensitive natural communities or riparian habitats. Implementation of MM BIO-3a and MM BIO- 3b would reduce impacts to wetlands and jurisdictional features.

With implementation of MM BIO-1a, MM BIO-1b, MM BIO-1c, MM BIO-1d, MM BIO-2a, MM BIO-2b, MM BIO-2c, MM BIO-3a, and MM BIO-3b, the proposed project would not substantially degrade the quality of the environment, reduce fish or wildlife habitat, reduce fish or wildlife populations below self-sustaining levels, eliminate a plant or animal community, or reduce the number or range of a rare or endangered plant or animal.

Based on the analysis provided in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to California history or prehistory would be less than significant with mitigation incorporated. Implementation of MM CUL-1 and MM CUL-2 would reduce impacts to historical cultural resources or Tribal cultural resources encountered during ground-breaking activities. Implementation of MM CUL-3 would reduce impacts to human remains that could be unearthed during excavation or grading activities.

With implementation of MM CUL-1, MM CUL-2, and MM CUL-3, the proposed project would not substantially degrade the quality of the environment or eliminate important examples of the major periods of California history or prehistory.

Based on the discussion provided above, compliance with required guidelines and statutes and implementation of the mitigation measures, the project would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. Therefore, impacts would be less than significant with incorporation of MM BIO-1a, MM BIO-1b, MM BIO-1c, MM BIO-1d, MM BIO-2a, MM BIO-2b, MM BIO-2c, MM BIO-3a, MM BIO-3b, MM CUL-1, MM CUL-2, and MM CUL-3.

Finding No. 2: Significant and unavoidable impact.

The analysis presented in this Recirculated Draft PEIR includes a review of proposed project's potential impacts related to air quality, biological resources, cultural resources, noise, and transportation, among other environmental issue areas. As presented throughout this PEIR, the City of Fresno—Fresno Southeast Development Area Specific Plan Project Other CEQA Considerations Recirculated Draft Program EIR

4-8 FirstCarbon Solutions
Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec04-00 Other CEQA.docx proposed project’s cumulative impacts would either be significant and unavoidable, less than significant with mitigation incorporated, less than significant, or there would be no impacts.

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

There would be less than significant cumulative impacts with regard to biological resources, energy, geology and soils, hazards and hazardous materials, land use and planning, mineral resources, population and housing, public services, and recreation.

Potentially significant cumulative impacts related to cultural and Tribal cultural resources, greenhouse gas (GHG) emissions, hydrology and water quality, transportation, and utilities would be mitigated to less than significant levels with the implementation of MM CUL-1, MM CUL-2, MM CUL- 3, MM HYD-2a, MM HYD-2b, MM HYD-2c, MM HYD-2d, MM HYD-2e, MM HYD-3a, MM HYD-3b, MM HYD-3c, MM HYD-3d, MM HYD-3e, MM HYD-3f, MM HYD-3g, MM TRANS-1a, MM TRANS-1b, MM TRANS-1c, MM TRANS-1d, MM TRANS-1e, MM TRANS-31, MM TRANS-3b, MM TRANS-4, MM UTIL- 1a, MM UTIL-1b, MM UTIL-1c, MM UTIL-1d, MM UTIL-1e, MM UTIL-1f, MM UTIL-2a, MM UTIL-2b, MM UTIL-2c, and MM UTIL-4.

Significant and unavoidable impacts would occur related to aesthetics, agricultural resources, air quality, GHG emissions, and noise. While implementation of MM AES-4a through MM AES-4e, MM AG-1, MM AIR-1a through MM AIR-1d, and MM AIR-4 would reduce these impacts, there is no feasible mitigation available that would fully bring these impacts to less than significant levels.

Overall, with implementation of the applicable mitigation measures, impacts associated with the proposed project would remain significant and unavoidable for aesthetics, agricultural resources, air quality, and noise. The implementation of other projects in the City would be required to demonstrate regulatory compliance and implement similar mitigation measures, as applicable.

Therefore, the proposed project would have some impacts that are individually limited but cumulatively considerable.

Finding No. 3: Less than significant impact.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

FirstCarbon Solutions 5-1
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx CHAPTER 5: ALTERNATIVES TO THE PROPOSED PROJECT

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

5.1.1 - Significant Unavoidable Impacts
The proposed project would result in the following significant unavoidable impacts:
• Impact AES-3 (Project-level Visual Character): The proposed project would, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). Buildout of the Southeast Development Area (SEDA) Specific Plan would alter the existing visual character by increasing the intensity of development in many areas that are primarily agriculture. No feasible mitigation measures are available to mitigate the impact to a less than significant level.
• Impact AES-4 (Project-level Light and Glare): The proposed project would create a new source of substantial light or glare which could adversely affect day or nighttime views in the area.

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

Implementation of Mitigation Measure (MM) AES-4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project by requiring shields, low-intensity fixtures, requirements for signs, and non-reflective materials. However, impacts would remain significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

5-2 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx • Cumulative Aesthetics, Lights, and Glare Impacts: Implementation of the proposed project would increase intensify development of structures, which would create new sources of light and glare within the Plan Area and adjacent to the Plan Area. These new sources of glare could result from materials used on building façades, parking lots, signs, roadway surfaces, and motor vehicles. This increase in glare could result in cumulatively considerable significant glare impacts and illumination of the nighttime sky. Additionally, implementation of MM AES- 4a through MM AES-4e would reduce potential glare impacts resulting from the proposed project. However, impacts would remain significant and unavoidable. • Impact AG-1 (Project-level Conversion of Farmland to Nonagricultural Uses): There are approximately 2,475 acres of land designated as Prime Farmland, approximately 1,352 acres of Farmland of Statewide Importance, approximately 1,189 acres of land designated as Farmland of Local Importance, and approximately 1,725 acres of land designated as Unique Farmland scattered throughout the Plan Area. Through its open space framework and land use objectives and policies, the Specific Plan would allow flexibility in the location, form, and function of diverse agricultural types within communities and would establish a buffer between the urban area of the City of Fresno and the surrounding agricultural land. The proposed project would implement MM AG-1, which requires future developments within the Plan Area to evaluate and mitigate the potential loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland by utilizing the Land Evaluation and Site Assessment (LESA) Model and 1:1 conservation easements, or other recorded instruments to mitigate the loss of farmland. If the City adopts a Farmland Preservation Program pursuant to Fresno General Plan Policy RC-9-c, MM AG-1 states that project proponents may compensate for the loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland by complying with the adopted Farmland Preservation Program. However, while implementation of MM AG-1 would reduce the degree of potential impacts associated with future development under the Specific Plan, the conversion of Farmland to nonagricultural uses would still occur. Therefore, this impact would be significant and unavoidable even with implementation of available mitigation.
• Impact AG-2 (Project-level Conflict with Existing Zoning or Williamson Act Contract):

According to the General Plan, the City and its Sphere of Influence (SOI) includes lands under Williamson Act Contract for prime and non-prime agricultural land. According to the Williamson Act property map, the majority of Williamson Act properties within the City and its SOI are located within the Plan Area. Therefore, the continued implementation of the approved General Plan and the proposed Specific Plan could conflict with existing Williamson Act Contracts because non-agricultural uses are allowed on the land under a Williamson Act Contract. As a result, the continued implementation of the General Plan and proposed Specific Plan could result in a significant impact on existing Williamson Act Contract land. While the policies included in the Specific Plan would directly limit farmland conversion and thereby help to preserve agriculture in the Plan Area and implementation of MM AG-1 would reduce impacts related to the conversion of Farmland to nonagricultural use, the conversion of Farmland to nonagricultural uses would still occur. Therefore, this impact would be significant and unavoidable, and no feasible mitigation measures are available to reduce it to less than significant.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

FirstCarbon Solutions 5-3
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx • Cumulative Agricultural Resources and Forestry Resources Impacts: Although the proposed project would promote small farms, community gardens, and farmer’s markets, future development in areas outside of the Plan Area, in combination of the loss of Prime Farmland within the Plan Area, would result in the conversion of farmland to non-agriculture uses, despite the implementation of MM AG-1. Therefore, the implementation of the proposed project would result in a significant and unavoidable impact on agricultural zoning and Williamson Act Contracts. The proposed project includes land use changes that would result in the conversion of farmland to non-agriculture uses, and no feasible mitigation measures are available. Therefore, this impact would be significant and unavoidable. • Impact AIR-1 (Project-level Consistency with Air Quality Management Plan): The proposed project has the potential to exceed the San Joaquin Valley Air Pollution Control District (Valley Air District) significance thresholds during construction and operation. Implementation of the proposed project would result in the generation of substantial long-term criteria air pollutant emissions that would exceed the Valley Air District regional significance thresholds and would therefore not be considered consistent with the existing Air Quality Plans (AQPs). Mitigation measures AIR-1a through AIR-1d will serve to reduce emissions and exposures, however not to levels below the significance thresholds. While the various goals and policies of the proposed project would contribute to reducing long-term criteria air pollutant emissions to the extent feasible, no further feasible measures are available beyond the applicable Valley Air District rules and regulations and the proposed project’s policies and design guidelines.

Therefore, due to the magnitude and intensity of development accommodated by the proposed project, it would have a significant and unavoidable impact. • Impact AIR-2 (Project-level Cumulative Criteria Pollutant Emissions): Compliance with existing regulatory programs, General Plan policies, and MM AIR-1a through MM AIR-1d would serve to reduce the impacts of the proposed project to the extent feasible. While adherence to Rule 9510 would contribute to reducing exhaust nitrogen oxide (NOx) emissions, it would not be applicable to reducing volatile organic compound (VOC) emissions generated by operation of equipment and from off-gassing from asphalt and paints. Additionally, there is potential for multiple projects to be constructed at one time in the Plan Area, resulting in the generation of cumulatively significant amounts of NOx emissions. Regional emissions generated by the proposed project would exceed applicable thresholds for cumulative criteria pollutant emissions after compliance with all rules, regulations, and mitigation measures during operation. While compliance with the Valley Air District rules and the policies of the proposed Specific Plan may contribute to reducing operation-related regional air quality impacts of individual projects envisioned under the proposed Specific Plan to less than significant levels, the projected cumulative emissions associated with future development projects would be in exceedance of the Valley Air District thresholds. Therefore, implementation of the proposed project would result in a significant impact because it would significantly contribute to the nonattainment designations of the San Joaquin Valley Air Basin (SJVAB). This impact would be significant and unavoidable. • Impact AIR-3 (Project-level Sensitive Receptors Exposure to Pollutant Concentrations):

Compliance with existing regulatory programs, General Plan policies, and MM AIR-1a through MM AIR-1d would serve to reduce the impacts of the proposed project to the extent feasible.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx However, the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Furthermore, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds. Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants, and thus a significant and unavoidable impact may result. • Cumulative Air Quality Impacts: While implementation of MM AIR-1a through MM AIR-1d would serve to reduce criteria air pollutant and toxic air contaminants (TAC) emissions generated by the proposed project, there is currently not enough information to quantify emissions of specific project development that may occur under the proposed project.

Without quantification to guarantee a less than significant finding, future development projects may still exceed the Valley Air District regional significance thresholds. Additionally, due to the size of the proposed project, there is not sufficient 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. Therefore, cumulative impacts to air quality would remain significant and unavoidable. • Impact NOI-1 (Project-level Construction Noise): Short-term construction noise impacts associated with the project are an increase in traffic flow on local streets associated with the transport of workers, equipment, and materials to and from the project site and noise generated during site-preparation, grading, and construction activities. With implementation of MM NOI-1a and MM NOI-1b, construction noise impacts due to construction activities would be reduced to the extent feasible. However, given that details of individual development projects in the vicinity of the Plan Area are currently unknown, it is not possible to quantify the construction noise impacts at specific off-site or on-site sensitive receptors.

Because these construction activities may occur near noise-sensitive receptors and because noise disturbances may occur for prolonged periods of time, construction noise impacts would remain significant and unavoidable.
• Cumulative Construction Noise: Given that details of individual development projects adjacent to the Plan Area are currently unknown, it is not possible to quantify future cumulative construction noise impacts that could occur if multiple developments were to be constructed simultaneously, which could constitute a cumulative noise impact. Because construction activities associated with implementation of the Specific Plan could then also occur simultaneously and because noise disturbances could occur for prolonged periods of time, there is the possibility for cumulative construction noise impacts that would remain significant and unavoidable.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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

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

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

Alternative 2–Consolidated Business Park Alternative
Under the Consolidated Business Park Alternative, the Specific Plan would be developed as described in this Recirculated Draft PEIR, except that this alternative would maintain the existing Research and Development land designations from the General Plan for the area south of Jensen Avenue. It would accommodate approximately 42,900 homes and approximately 36,000 jobs within the 9,000-acre planning area. The area identified in the Specific Plan as Flexible Research and Development to the east of Temperance Avenue and north of Jensen Avenue would be developed as Neighborhood Residential and Mixed Residential with two community centers and five neighborhood centers. Additionally, this alternative would change the land use designations for the planned Mixed Residential and Neighborhood Residential, along with the Community and Neighborhood Centers south of Jensen Avenue. Under the Consolidated Business Park Alternative, that area would be designated as Flexible Research and Development and Offices. Please refer to Exhibit 5-1 for a visual representation of this alternative.

Alternative 3–Farmland Conservation Alternative
Under the Farmland Conservation Alternative, buildout of the Specific Plan would occur as proposed in this Recirculated Draft PEIR; however, under this alternative, specific parcels of farmland located within the Plan Area would be desingated for conservation. No future development would be permitted on farmland designated for conservation. Under the proposed project, buildout of the Specific Plan would include a farmland buffer along the east side of the Plan Area. Under the proposed project this area is designated as Rural Cluster Residential which allows specific residential development to be developed on the important farmlands. However, under this alternative, farmland located within the portions of the Plan Area designated as Rural Cluster Residential would be conserved, disallowing development on identified Prime, Unique, and Statewide Importance Farmland within this portion of Plan Area. It would be compatible with the uses of the surrounding land since the farmland preserved will also be rural in nature. Please refer to Exhibit 5-2 for a visual representation of this alternative.

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31680033 • 12/2024 | 5-1_consolidated_business_park_alt.cdr CITY OF FRESNO

FRESNO SOUTHEAST DEVELOPMENT AREA SPECIFIC PLAN

RECIRCULATED PROGRAM ENVIRONMENTAL IMPACT REPORT
Exhibit 5-1
Consolidated Business Park Alternative
Source: City of Fresno
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CONSOLIDATED BUSINESS PARK ALTERNATIVE
= Freeway C Southeast Development Area
• Expressway ~ 4 Fresno Sphere of Influence
■■ Scenic Expressway - Major & Local Roads
• Super Arterial
-• Arterial
...,. Scenic Arterial
.... Scenic Drive
-Collector
•••• Scenic Collector
-+ Railroads
Regional Town Center
Community Town Center
Neighborhood Town Center
Flexible Reseach & Development
Mixed Residential
Neighborhood Residential
Rural Residential
Rural Cluster Residential
Park/Open Space/Flood Control

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Source: City of Fresno, SEDA Illustrative Plan
derived from community and stakeholder meetings.
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Jensen Ave
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Fresno Southeast Development Area 8,769.57 acres
Agricultural Conservation Area 832.39 acres
Land Cover Categories Fresno SEDA Conservation Area Prime Farmland 2,475.31 acres 302.09 acres
Farmland of Statewide Importance 1,352.12 acres 233.58 acres Farmland of Local Importance 1,189.08 acres 62.47 acres Unique Farmland 1,724.99 acres 112.94 acres
Urban and Built-Up Land 337.04 acres 1.08 acres Rural Residential Land 1,535.73 acres 117.50 acres Semi-Agricultural and Rural Commercial Land 60.54 acres 2.73 acres Vacant or Disturbed Land 94.25 acres 0.00 acre Nonagricultural or Natural Vegetation 0.51 acre 0.00 acre ICJJ
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FIRSTCARBON

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

FirstCarbon Solutions 5-11
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx The three alternatives to the proposed project are analyzed below. These analyses compare the proposed project and each individual project alternative. In several cases, the description of the impact may be the same under each alternative when compared with the CEQA Thresholds of Significance (i.e., both the project and the alternative would result in a less than significant impact).

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

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

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

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

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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

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

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

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

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

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

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

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

5.3 - Alternative 1—No Project Alternative
CEQA Guidelines Section 15126.6(e) requires an EIR to evaluate a ‘No Project Alternative,’ which is defined as what would be reasonably expected to occur in the foreseeable future, if the project were City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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

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

5.3.1 - Impact Analysis
Aesthetics, Light, and Glare
As noted in Section 3.1, Aesthetics, Light and Glare, the proposed project’s impacts to aesthetics, light, and glare would be significant and unavoidable even with implementation of mitigation because the proposed project would add sources of light and glare and would increase urbanization, changing the rural character of the community. Under Alternative 1, the proposed project would not be approved and buildout of the Plan Area would be consistent with the General Plan. Buildout under the General Plan includes approximately 17,900 homes and approximately 29,600 jobs in the Plan Area. Comparatively, the proposed Specific Plan would include approximately 45,000 homes and approximately 37,000 jobs. Because the Specific Plan proposes a greater intensity of development, it would have greater impacts than Alternative 1. Under Alternative 1, there would be a significant and unavoidable impact related to visual character as well as light and glare because development would lead to increased development, impacting the existing rural character of the area and increasing sources of light and glare. However, because more existing open space would be retained under the General Plan, Alternative 1 would have similar, but reduced, impacts as compared to the proposed project.

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

Under Alternative 1, the proposed project would not be approved and buildout of the Plan Area would be consistent with the General Plan. Buildout under the General Plan includes approximately 17,900 homes and approximately 29,600 jobs in the Plan Area. Comparatively, the proposed Specific Plan would include approximately 45,000 homes and approximately 37,000 jobs. Because the Specific Plan proposes a greater intensity of development, it would have greater impacts than Alternative 1. Under Alternative 1, there would be a significant and unavoidable impact related to City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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

Biological Resources
As noted in Section 3.4, Biological Resources, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of mitigation, along with applicable regulations. As described above, buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. There would be less than significant impacts related to biological resources because all future development under the General Plan would be required to implement feasible mitigation measures and comply with applicable regulations regarding biological resources. Potential disturbance to biological resources would be similar to the proposed project but less impactful because of the decreased intensity in Alternative 1. The development under Alternative 1 would require the implementation of feasible mitigation measures that would reduce impacts to biological resources but would not have the benefit of enhancements identified in the proposed project. Impacts would be expected to be less than significant, similar to the proposed project.

Cultural Resources and Tribal Cultural Resources
As noted in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to cultural resources and tribal cultural resources would be less than significant with the implementation of applicable policies and regulations, as well as mitigation. Buildout under Alternative 1 would be less intense than under the proposed project and therefore is likely to have a smaller effect on cultural resources. However, similar to the proposed project, impacts would be less than significant with mitigation incorporated.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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

Geology, Soils, and Seismicity
As noted in Section 3.7, Geology, Soils, and Seismicity, the proposed project’s impacts related to geology, soils, and seismicity would be less than significant with the incorporation of mitigation, along with applicable regulations. Buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. Therefore, less soil would be disturbed. Development under Alternative 1 would require the implementation of feasible mitigation measures as well as compliance with applicable regulations regarding geology, soils, and seismicity. Impacts would be expected to be less than significant, similar to the proposed project.

Greenhouse Gas Emissions
As noted in Section 3.8, Greenhouse Gas Emissions, the proposed project’s impacts related to greenhouse gas (GHG) emissions would be less than significant with the incorporation of mitigation and compliance with all applicable regulations regarding GHG emissions. Alternative 1 would result in less intense development than the proposed project. Under Alternative 1, GHG impacts would be less than significant with mitigation incorporated because future development projects would be required to implement feasible mitigation measures, as well as comply with applicable regulations regarding GHG emissions. Therefore, Alternative 1 would have a similar to, but slightly reduced, impact compared to the proposed project with regard to GHG emissions.

Hazards and Hazardous Materials
As noted in Section 3.9, Hazards and Hazardous Materials, the proposed project’s impacts related to hazards and hazardous materials would be less than significant with all mitigation incorporated, along with the implementation of applicable regulations. Buildout of the existing General Plan under Alternative 1 would be less intense than under the proposed project. Notably, because they are policy level documents and do not approve any specific development activities, neither Alternative 1 nor the proposed project would result in physical changes, resulting in a significant environmental effect. Additionally, construction of future individual development projects consistent with the existing General Plan must comply with the California Code of Regulations and implement a Stormwater Pollution Prevention Plan to prevent hazardous material spills and protect public safety.

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

Hydrology and Water Quality
As noted in Section 3.10, Hydrology and Water Quality, the proposed project’s impacts related to hydrology and water quality would be less than significant with the incorporation of all applicable City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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Land Use and Planning
As noted in Section 3.11, Land Use and Planning, the proposed project’s impacts related to land use and planning would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary. Buildout of the General Plan would have a less than significant impact with respect to land use because the approved General Plan includes objectives and policies to reduce land use conflicts and provide for future orderly development to reduce the potential to divide established communities or conflict with a land use plan, policy, or regulation.

Therefore, impacts resulting from Alternative 1 would be less than significant, similar to the proposed project.

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

There are mineral resources within the City, but only in the San Joaquin River Corridor, which is not part of the Plan Area as described in Section 3.12, Mineral Resources. Therefore, Alternative 1 would have the same impact as the proposed project. A less than significant impact would occur.

Noise
As noted in Section 3.13, Noise, the proposed project’s impacts related to noise would be significant and unavoidable for construction noise and less than significant for all other noise and vibration impacts.

Under Alternative 1, impacts with respect to noise would be significant and unavoidable because future development under the General Plan would generate a substantial increase in ambient noise levels in the vicinity of the Plan Area due to increased development and traffic. Buildout of the General Plan under Alternative 1 would be less intense than under the proposed project. As such, noise effects resulting from Alternative 1 would be less than those resulting from the proposed project but would still be significant and unavoidable.

Population and Housing
As noted in Section 3.14, Population and Housing, the proposed project’s impacts related to population and housing would be less than significant with the implementation of applicable policies and regulations. Buildout of the General Plan under Alternative 1 would be less dense than under the proposed project. The General Plan provides for only 17,900 homes, whereas the proposed City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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

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

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

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

Under Alternative 1, utilities and service systems impacts would be significant and unavoidable with respect to water, surface water treatment, wastewater treatment, wastewater collection, electric, natural gas, and telecommunications facilities because project-specific design details would be developed as individual development projects are proposed, meaning that mitigation measures cannot be developed at this time. Instead, the availability of utilities and service systems would be evaluated and determined on a project-by-project basis under the General Plan. Development under Alternative 1 would result in development at less intensity than the proposed project. The proposed City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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

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

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

5.4 - Alternative 2—Consolidated Business Park Alternative Under the Consolidated Business Park Alternative (Alternative 2), the SEDA Specific Plan would occur as planned, but this alternative maintains the Flexible Research and Development land designations from the General Plan for the area south of Jensen Avenue. It would accommodate approximately 42,900 homes and 36,000 jobs within the 9,000-acre planning area. This is approximately 2,100 fewer homes and 1,000 fewer jobs, when compared with the proposed project. Alternative 2 would have slightly less density of development than the proposed project. The area identified in the SEDA Specific Plan as Flexible Research and Development to the east of Temperance Avenue and north of Jensen Avenue would be developed as Neighborhood Residential and Mixed Residential with two community centers and five neighborhood centers. Additionally, this alternative would change the land use designations for the planned Mixed Residential and Neighborhood Residential, along with the Community and Neighborhood Centers south of Jensen Avenue. Under Alternative 2, that area would be designated as Flexible Research and Development and Offices. Please refer to Exhibit 5-1 for a visual representation of this alternative.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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

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

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

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

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

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

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

Buildout consistent with Alternative 2 would be similar to the proposed project. Although the Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue, both this alternative and the proposed project have the same footprint of approximately 9,000 acres. Alternative 2 would result in a similar amount of development as the proposed project, although at a slightly lower intensity. Therefore, impacts to air City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx quality would be expected to be significant and unavoidable, similar to, but slightly less than, the proposed project.

Biological Resources
As noted in Section 3.4, Biological Resources, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of mitigation, along with applicable regulations.

Buildout under Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both Alternative 2 and the proposed project have the same footprint of approximately 9,000 square acres, although Alternative 2 would be slightly less dense. Additionally, this alternative would comply with the General Plan policies and implement mitigation measures identified in Section 3.4, Biological Resources.

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

Cultural Resources and Tribal Cultural Resources
As noted in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to cultural resources and Tribal cultural resources would be less than significant with the incorporation of mitigation and compliance with applicable regulations.

Buildout consistent with Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both Alternative 2 and the proposed project have the same footprint of approximately 9,000 acres, although Alternative 2 would be slightly less dense. Additionally, future development within the Plan Area could have significant impacts on known or previously unidentified cultural resources or Tribal cultural resources. Development would be required to comply with federal, State, and local law and policies that protect cultural and Tribal cultural resources, as well as the mitigation measures identified in Section 3.5, Cultural Resources and Tribal Cultural Resources. Therefore, impacts to cultural and Tribal cultural resources would be expected to be less than significant, similar to, but slightly less than the proposed project.

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

Buildout consistent with Alternative 2 would be similar to the proposed project. Under this alternative, the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue. Both this alternative and the proposed project have the same footprint of approximately 9,000 acres, although Alternative 2 would be slightly less dense. Additionally, since all past, present, and future City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx development projects would be required to comply with the Municipal Code, City ordinances, and County policies that address energy conservation and efficiency during construction and operation, impacts would be less than significant, similar to, but slightly less than the proposed project.

Geology, Soils, and Seismicity
As noted in Section 3.7, Geology, Soils, and Seismicity, the proposed project’s impacts related to geology, soils, and seismicity would be less than significant with the incorporation of mitigation, along with applicable regulations.

Buildout under Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project have the same footprint of approximately 9,000 acres. However, Alternative 2 would have slightly less density than the proposed project. Alternative 2 would result in the same amount of development as the proposed project. Therefore, impacts to geology, soils, and seismicity would be expected to be less than significant, similar to, but slightly less than the proposed project.

GHG Emissions
As noted in Section 3.8, Greenhouse Gas Emissions, the proposed project’s impacts related to GHG emissions would be less than significant with the incorporation of mitigation and all applicable regulations.

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

However, Alternative 2 would have slightly less density than the proposed project. Therefore, impacts to GHG emissions would be expected to be less than significant, similar to but slightly less than the proposed project.

Hazards and Hazardous Materials
As noted in Section 3.9, Hazards and Hazardous Materials, the proposed project’s impacts related to hazards and hazardous materials would be less than significant with all mitigation incorporated, along with the implementation of applicable regulations.

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

However, Alternative 2 would have slightly less density than the proposed project. Additionally, all projects under this alternative would be subject to the requirements and regulations set forth by the United States Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), United States Department of Transportation (USDOT), California Department of Toxic Substances Control (DTSC), California Department of Transportation (Caltrans), California City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Highway Patrol (CHP), and the Valley Air District related to transport, use, and disposal of hazardous materials. Therefore, impacts to hazards and hazardous materials would be expected to be less than significant, similar to, but slightly less than the proposed project.

Hydrology and Water Quality
As noted in Section 3.10, Hydrology and Water Quality, the proposed project’s impacts related to hydrology and water quality would be less than significant with the incorporation of all applicable mitigation measures and regulations.

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

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

Land Use and Planning
As noted in Section 3.11, Land Use and Planning, the proposed project’s impacts related to land use and planning would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

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

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

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

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

Buildout under Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project have the same footprint of approximately 9,000 acres. However, Alternative 2 would have slightly less density than the proposed project.

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

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

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

Noise
As noted in Section 3.13, Noise, the proposed project’s impacts related to noise would be significant and unavoidable for construction noise and less than significant for all other noise and vibration impacts.

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

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

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

Buildout under Alternative 2 would be similar to the proposed project. Although the proposed Office Center and Flexible Research and Development land uses would be consolidated to the area south of Jensen Avenue and west of Temperance Avenue under Alternative 2, both this alternative and the proposed project would provide for a similar number of homes and jobs. This alternative would provide for approximately 42,900 homes and 36,000 jobs within the Plan Area, while the proposed project would provide for approximately 45,000 homes and 37,000 jobs within the Plan Area. The City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Alternative 2 would result in a less than significant impact, similar to but slightly less than the proposed project.

Public Services
As noted in Section 3.15, Public Services, the proposed project’s impacts related to public services would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

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

Recreation
As noted in Section 3.16, Recreation, the proposed project’s impacts related to recreation would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

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

Transportation and Traffic
As noted in Section 3.17, Transportation and Traffic, the proposed project’s impacts related to transportation and traffic would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Utilities and Service Systems
As noted in Section 3.18, Utilities and Service Systems, the proposed project’s impacts related to utilities and service systems would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

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

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

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

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx

5.5 - Alternative 3—Farmland Conservation Alternative
Under the Farmland Conservation Alternative (Alternative 3), buildout of the SEDA Specific Plan would occur as proposed in this Recirculated Draft PEIR; however, under this alternative, specific parcels of farmland along the entire eastern boundary of the Plan Area from Shields Avenue to Jensen Avenue would be conserved. No future development or ground-disturbing activities would be permitted on farmland designated for conservation. This would conserve a total of 648.61 acres of farmland that would not be conserved under the proposed project (Exhibit 5-1). The Plan Area currently has 5,552 acres of Prime Farmland, Unique Farmland, and Farmland of Statewide Importance.

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

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

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

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

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would slightly reduce the loss of farmland in the Plan Area, the majority of the Plan Area would be developed as proposed.

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Air Quality
As noted in Section 3.3, Air Quality, the proposed project’s impacts to air quality would be significant and unavoidable even with the implementation of mitigation.

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

Biological Resources
As noted in Section 3.4, Biological Resources, the proposed project’s impacts related to biological resources would be less than significant with the incorporation of mitigation, along with applicable regulations.

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

Cultural Resources and Tribal Cultural Resources
As noted in Section 3.5, Cultural Resources and Tribal Cultural Resources, the proposed project’s impacts related to cultural resources and Tribal cultural resources would be less than significant with the incorporation of mitigation, as well as applicable policies and regulations.

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Geology, Soils, and Seismicity
As noted in Section 3.7, Geology, Soils, and Seismicity, the proposed project’s impacts related to geology, soils, and seismicity would be less than significant with the incorporation of mitigation, along with applicable regulations.

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

Greenhouse Gas Emissions
As noted in Section 3.8, Greenhouse Gas Emissions, the proposed project’s impacts related to GHG emissions would be less than significant with the incorporation of mitigation, as well as applicable policies and regulations.

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

Hazards and Hazardous Materials
As noted in Section 3.9, Hazards and Hazardous Materials, the proposed project’s impacts related to hazards and hazardous materials would be less than significant with all mitigation incorporated, along with the implementation of applicable regulations.

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

Hydrology and Water Quality
As noted in Section 3.10, Hydrology and Water Quality, the proposed project’s impacts related to hydrology and water quality would be less than significant with the incorporation of all applicable mitigation measures and regulations.

Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. While this would result in slightly less development and therefore, slightly less disturbance of current hydrology patterns, the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Land Use and Planning
As noted in Section 3.11, Land Use and Planning, the proposed project’s impacts related to land use and planning would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

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

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

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

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

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce the number of residences and, therefore, population increase in the Plan Area, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant.

Public Services
As noted in Section 3.15, Public Services, the proposed project’s impacts related to public services would be less than significant with the implementation of applicable policies and regulations. No mitigation is necessary.

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

Recreation
As noted in Section 3.16, Recreation, the proposed project’s impacts related to recreation would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

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

Transportation and Traffic
As noted in Section 3.17, Transportation and Traffic, the proposed project’s impacts related to transportation and traffic would be less than significant with the implementation of all applicable mitigation measures, policies, and regulations.

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

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

City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

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https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx Alternative 3 would result in less dense development in the area designated as Rural Cluster Residential because all farmland in this area would be preserved. This would slightly reduce population growth and development in the Plan Area, slightly reducing the demand for utilities services, although the majority of the Plan Area would be developed as proposed. As such, impacts under Alternative 3 would still be less than significant with mitigation incorporated.

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

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

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

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

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

5.6 - Environmentally Superior Alternative
CEQA Guidelines Section 15126(e)(2) requires identification of an environmentally superior alternative. If the No Project Alternative is environmentally superior, CEQA requires selection of the “environmentally superior alternative other than the No Project Alternative” among the project and City of Fresno—Fresno Southeast Development Area Specific Plan Project Alternatives to the Proposed Project Recirculated Draft Program EIR

5-32 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx the alternatives evaluated. The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 5-1.

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

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

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

CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other alternatives.

None of the alternatives analyzed would reduce the significant and unavoidable impacts related to Aesthetics, Light, and Glare; Agricultural Resources and Forestry Resources; and Noise, to below a City of Fresno—Fresno Southeast Development Area Specific Plan Project Recirculated Draft Program EIR Alternatives to the Proposed Project

FirstCarbon Solutions 5-33
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec05-00 Alternatives.docx level of significance although they would be incrementally less than the proposed project. Most of the less than significant impacts in other resources areas would be substantially similar; although incrementally less than the proposed project (with the exception of land use impacts under Alternative 3, which would be incrementally greater than the proposed project).

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

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

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

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

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

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City of Fresno—Fresno Southeast Development Area Specific Plan Project Persons and Organizations Consulted/ Recirculated Draft Program EIR List of Preparers

FirstCarbon Solutions 6-1
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec06-00 Preparers-Contributors.docx CHAPTER 6: PERSONS AND ORGANIZATIONS CONSULTED/LIST OF

PREPARERS

6.1 - Lead Agency

6.1.1 - City of Fresno
Planning and Development Department
Director ............................................................................................................................... Jennifer Clark Long Range Planning Manager .................................................................................... Sophia Pagoulatos Supervising Planner .................................................................................... Adrienne Asadoorian-Gilbert

6.2 - List of Preparers

6.2.1 - Lead Agency
City of Fresno
Director ............................................................................................................................... Jennifer Clark Long Range Planning Manager .................................................................................... Sophia Pagoulatos Supervising Planner .................................................................................... Adrienne Asadoorian-Gilbert

6.2.2 - Lead Consultant
FirstCarbon Solutions
Project Director ....................................................................................................................... Mary Bean Project Director ......................................................................................................... Phil Ault, LEED® AP Project Manager .......................................................................................................... Rachel Krusenoski Assistant Project Manager ................................................................................................ Laura Campion Legal Counsel ................................................................................................................... Megan Starr, JD Director of Cultural Resources .......................................................................... Dana DePietro, PhD, RPA Senior Archaeologist ......................................................................................................... Stefanie Griffin Archaeologist and Field Supervisor .................................................................................. Natalie Adame Director of Noise and Air Quality .............................................................................. Phil Ault, LEED® AP Senior Air Quality Scientist ............................................................................................................. Tsui Li Air Quality Associate ........................................................................................................... Jackie Winkle Principal Biologist .................................................................................... Michael Tuma, PhD, CWB, RPA Senior Biologist ................................................................................................................... Robert Carroll Environmental Analyst ................................................................................................ Stephanie Shepard Environmental Analyst ...................................................................................................... Madelyn Dolan Environmental Analyst ............................................................................................................ Kelly Evans Environmental Analyst ................................................................................................. Brandon Bourassa Environmental Analyst ......................................................................................................... Heather Carr Environmental Analyst ........................................................................................................ Zach Landucci Senior Managing Editor ......................................................................................................... Susie Harris Persons and Organizations Consulted/ City of Fresno—Fresno Southeast Development Area Specific Plan Project List of Preparers Recirculated Draft Program EIR

6-2 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN -JN)/3168/31680037/EIR/1 - Recirculated Draft PEIR/31680037 Sec06-00 Preparers-Contributors.docx Publications Coordinator ........................................................................................................ Alec Harris Technical Editor ....................................................................................................................... Sarah Vine Document Specialist ....................................................................................................... Melissa Ramirez GIS/Graphics ................................................................................................................ Karlee McCracken

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

Principal ................................................................................................................................... Amy Lapin Senior Technical Associate ................................................................................................ Allison Shaffer TJKM
Senior Transportation Planner .................................................................................... Praveena Samaleti Transportation Planner ......................................................................................................... Garvit Goyal

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