Exhibit E-1 - 2025 Partially Recirculated Draft Environmental Impact Report with Appendices — Fresno City Council, May 21, 2026 (part 1 of 2)

Costco Commercial Center Project
Conditional Use Permit Application No. P21-01959
Plan Amendment and Rezone Application No. P21-01960
Conditional Use Permit Application No. P21-03251
Planned Development Permit Application No. P21-03252
7120 North Riverside Drive Fresno, CA 93722
APN: 503-020-12

Exhibit E-1 – 2025 Partially Recirculated Draft
Environmental Impact Report with Appendices
Partially Recirculated Draft
Environmental Impact Report
Fresno Costco
Commercial Center
Project
State Clearinghouse No. 2021100443
Prepared for:

Planning and Development Department
November 2025

Partially Recirculated Draft Environmental Impact Report Fresno Costco Commercial Center Project
State Clearinghouse No. 2021100443

Planning and Development Department
2600 Fresno Street, Third Floor, Room 3043
Fresno, California 93721
Contact:

Steven Martinez
Planner
559.621.8047
Prepared with assistance from:

Ascent Environmental
455 Capitol Mall, Suite 300
Sacramento, CA 95814
November 2025
20210052.01

City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR i

TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS ................................ ................................ ................................ ................................ ................................ ........... II 1 INTRODUCTION ................................ ................................ ................................ ................................ ................................ ........ 1-1

1.1 Purpose of this Document and Background ......................................................................................................... 1-1

1.2 Document Format ......................................................................................................................................................... 1-2

1.3 Additional Revisions to the 2024 EIR ...................................................................................................................... 1-3

1.4 Public Review Process .................................................................................................................................................. 1-4

1.5 Use of this Document .................................................................................................................................................. 1-5

3.7 Greenhouse Gas Emissions and Climate Change ................................ ................................ ................................ ......... 3.7-1 Appendices
Appendix A Greenhouse Gas Emissions Technical Report
Tables
Table 3.7-1 Statewide GHG Emissions by Economic Sector ............................................................................................ 3.7-26 Table 3.7-2 City of Fresno 2010 Baseline and GHG Emission Projections (in MTCO2e) ........................................... 3.7-27 Table 3.7-3 City of Fresno 2016 Baseline GHG Emissions (in MTCO2e) ........................................................................ 3.7-27 Table 3.7-4 Summary of Project GHG Emissions ................................................................................................................. 3.7-31 Table 3.7-5 2022 Scoping Plan Priority GHG Reduction Strategy Consistency Evaluation Summary ................. 3.7-32 Table 3.7-6 RTP/SCS Policy Consistency Evaluation ........................................................................................................... 3.7-35 Table 3.7-7 PCAP Consistency Evaluation .............................................................................................................................. 3.7-37 Table 3.7-8 2014 General Plan
Policy Consistency Evaluation.......................................................................................... 3.7-41

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ii Costco Commercial Center Project Partially Recirculated Draft EIR

LIST OF ABBREVIATIONS
ACC Advanced Clean Cars
ACF Advanced Clean Fleet
ACT Advanced Clean Trucks
ATCM Airborne Toxic Control Measure
ATP Active Transportation Plan
BAU Business As-Usual
BPS Best Performance Standards
CAA Clean Air Act
CalEPA California Environmental Protection Agency
CAP criteria air pollutant
CARB California Air Resources Board
CAT Climate Action Team
CCAP Comprehensive Climate Action Plan
CEC California Energy Commission
CH4 methane
CNRA California Natural Resources Agency
CO2 carbon dioxide
CPUC California Public Utilities Commission
DOE US Department of Energy
EO Executive Order
F Fahrenheit
Fresno COG Fresno Council of Governments
GAMAQ Guidance for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
GHGRP greenhouse gas reduction plan
HFC hydrofluorocarbon
IPCC Intergovernmental Panel on Climate Change
LCFS Low Carbon Fuel Standard
LEV Low-Emission Vehicle
MMTCO2e million metric tons of carbon dioxide equivalent MT metric tons
MWELO Model Water Efficient Landscape Ordinance
N2O nitrous oxide
NHTSA National Highway Traffic Safety Administration
PCAP Priority Climate Action Plan
PFC perfluorocarbon
RPS Renewables Portfolio Standard
RTP Regional Transportation Plan
SAFE Safer Affordable Fuel-Efficient
SB Senate Bill
SCS Sustainable Communities Strategy
SF6 sulfur hexafluoride
SJVAPCD San Joaquin Valley Air Pollution Control District TRU transportation refrigeration unit
USDOT U.S. Department of Transportation
USEPA U.S. Environmental Protection Agency
VMT vehicle miles traveled
ZEV zero emission vehicles

City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 1-1 1 INTRODUCTION

1.1 PURPOSE OF THIS DOCUMENT AND BACKGROUND
In accordance with the California Environmental Quality Act (CEQA), the City of Fresno (City), as Lead Agency, has prepared a Partial Recirculated Draft Environmental Impact Report (PR-DEIR) for the Costco Commercial Center proposed to be located at West Herndon Avenue and North Riverside Drive. The PR-DEIR is intended to comply with the Fresno County Superior Court’s (Court) ruling issued in July 2025 in Fresno County Superior Court Case No. 24CECG02208, Herndon-Riverside Coalition for Responsible Planning and Development v. City of Fresno et al. (Lawsuit) and the requirements of CEQA.

Prior to commencement of the Lawsuit, the City prepared a DEIR for the project and circulated it for public comment through August 28, 2023. The City provided responses to all comments received and published the Final EIR on February 9, 2024. The City’s City Council certified the EIR and approved the project on April 18, 2024. These documents are referred to herein as the 2024 EIR.

Based on the Court’s ruling in the Lawsuit, this Section 3.7, “Greenhouse Gas Emissions and Climate Change,” has been revised and is being recirculated. This section of the 2024 EIR evaluates potential impacts associated with greenhouse gas (GHG) emissions and climate change policy and is the only substantive section of the 2024 EIR included in this PR-DEIR. The 2024 EIR was upheld in the Lawsuit as to the other challenged issue, the alternatives analysis. No sections of the 2024 EIR other than the analyses of GHG emissions and climate change and alternatives were challenged in the Lawsuit.

Because the recirculation is limited to a single revised topical section, pursuant to CEQA Guidelines Section 15088.5, subdivision (c), the rest of the 2024 EIR is not being recirculated for public review and comment. Subdivision (c) provides that “[i]f the revision is limited to a few chapters or portions of the EIR, the lead agency need only recirculate the chapters or portions that have been modified.” State CEQA Guidelines Section 15088.5 subdivision (a) provides that a limited portion of the Draft EIR must be recirculated for public review and comment prior to certification when significant new information is added to an EIR. Recirculation provides the public with an opportunity to comment on the new or revised sections of the Draft EIR, and only on such sections. Comments from reviewers must be limited to the contents of the PR-DEIR only and may not address matters not included in the PR-DEIR. Pursuant to CEQA Guidelines Section 15088.5, subdivision (f)(2)(ii), written responses will be prepared only to comments received regarding the PR-DEIRs sections. Responses to comments received during the review period regarding the environmental analysis in this PR-DEIR will be provided in a separate response to comments document. The Final EIR that the City will consider certifying and will thereafter apply will consist of the following elements:

1. The 2024 EIR certified by the City Council on April 18, 2024 without Section 3.7, “Greenhouse Gas Emissions and Climate Change”;

2. This PR-DEIR, which includes a new, substitute Section 3.7, “Greenhouse Gas Emissions and Climate Change,” and which alters the Greenhouse Gas Emissions and Climate Change entry in Table ES-1 of the Executive Summary and the cumulative impact discussion; and

3. The comments submitted on this PR-DEIR during the public comment period and the responses to those comments.

1.1.1 Reason for Partial Recirculation
The PR-DEIR has been prepared pursuant to an Order After Hearing issued by the Court on July 17, 2025 (“Order”), granting the Petition for Writ of Mandate (“Petition”) in the Lawsuit. The Court granted the Petition in part to the extent as set forth in the Court’s Order with regard to the First Cause of Action (non-CEQA challenge alleging Introduction Ascent
City of Fresno
1-2 Costco Commercial Center Project Partially Recirculated Draft EIR violations of the Fresno Municipal Code) and Second Cause of Action (alleging violation of CEQA pertaining to GHG emissions analysis in the EIR) and denied the Petition in part with regard to the Third Cause of Action (alleging violation of CEQA pertaining to the Alternatives analysis in the EIR).

With respect to GHG emissions and climate change analysis included in the EIR, the Order in pertinent part stated as follows:

The modeling presented within the EIR is substantial evidence of the anticipated emissions of the Project.

The EIR’s conclusion that the Project will have a less than significant impact on climate change is based upon a comparison of the Project’s anticipated emissions with the application of the mitigation measures and implementation of clean vehicle regulations and the 2021 [City of Fresno Greenhouse Gas Reduction Plan (“GHGRP”)]. Following the certification of the EIR, the [2021] GHGRP was set aside and the 2014 GHGRP was adopted. As a result, the EIR conclusion that the Project will have a less than significant impact on climate [is] now without foundation.

For context, the Court’s reference to the 2021 GHGRP being set aside pertains to the Fifth District Circuit Court of Appeal’s unpublished August 6, 2024 decision in the South Fresno Community Alliance v. City of Fresno matter (case no. F086180), where the Court of Appeal directed that the City be compelled to set aside its Program Environmental Impact Report (PEIR) for the continued implementation of the City’s 2014 General Plan (including the 2021 GHGRP) that the City had certified in 2021.

In accordance with the Court of Appeal’s ruling, the City adopted Resolution No. 2025-69, rescinding its certification of the PEIR and vacating its approval of the 2021 GHGRP. Resolution No. 2025-69 provided as follows:

The Master Environmental Impact Report, which was certified in connection with the City’s adoption of its 2014 General Plan in 2014, is the environmental review document for the City’s 2014 General Plan, subject to the requirements of CEQA (Public Resource Code §§21000, et seq.) and the CEQA Guidelines (California Code of Regulations, Title 14, §15000 et seq.). The 2014 Greenhouse Gas Reduction Plan, adopted concurrently with the Master Environmental Impact Report, is the Greenhouse Gas Reduction Plan for the City, subject to the requirements of CEQA and the CEQA Guidelines.

In effect, under Resolution 2025-69, the City reverted to the pre-2021 status quo making the City’s 2014 GHGRP its most current and only operable GHGRP. Consistent with the Court’s ruling, Section 3.7, “Greenhouse Gas Emissions and Climate Change,” has been revised to eliminate reference to the City’s 2021 GHGRP.

1.2 DOCUMENT FORMAT
Consistent with the requirements of PRC Section 21168.9(b), this PR-DEIR contains only the information required to comply with the Court’s decision. All such information is considered significant new information based on Section 15088.5(a) of the State CEQA Guidelines. No other chapters or portions of the 2024 EIR are addressed in this PR-DEIR because no new information or new circumstances exist that would warrant revision of these other chapters or sections.

This PR-DEIR is organized into the following sections. All chapter and section numbering is consistent with the chapter and section numbering outline in the 2024 EIR.
 Chapter 1, “Introduction,” supplements the introduction chapter in the 2024 EIR and describes the purpose and legal requirements of this PR-DEIR, as well as its intended uses. This chapter also revises the 2024 EIR’s Executive Summary and cumulative impact discussion to reflect the revised Greenhouse Gas Emissions and Climate Change section.
 Section 3.7, “Greenhouse Gas Emissions and Climate Change,” responds to the Court ruling that required revaluation of GHG emissions because the 2021 GHGRP has been set aside and is no longer applicable to the project. The section replaces the 2024 EIR’s GHG emissions analysis in its entirety.

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Costco Commercial Center Project Partially Recirculated Draft EIR 1-3

1.3 ADDITIONAL REVISIONS TO THE 2024 EIR

1.3.1 Executive Summary
Table ES-1 of the Executive Summary for the 2024 EIR provides a matrix of all impact statements in the Draft EIR, a brief description of the analysis, the impact significance before mitigation, any applicable mitigation measures, and the impact significance after mitigation. As described above, the threshold of significance for the analysis of GHG emissions is modified in this PR-DEIR. To more accurately reflect the analysis presented in this PR-DEIR the portion of Table ES-1 that appears on page ES-15 of the Draft EIR summarizing the GHG emissions and climate change analysis is revised as follows:

Impacts Significance
before Mitigation Mitigation Measures Significance
after Mitigation
NI = No impact LTS = Less than significant PS = Potentially significant S = Significant SU = Significant and unavoidable Greenhouse Gas Emissions and Climate Change
Impact 3.7-1: Generate GHG Emissions That Would Have a Significant Impact on the Environment
While the project would result in an increase in GHG emissions when compared to the existing conditions (i.e., vacant site with no development), the project would be consistent with applicable state and local plans and would not conflict with or impede the state’s ability to meet its GHG reduction goals. Therefore, there is no cumulatively considerable contribution to GHG emissions
LTS No mitigation is required for this impact. LTS
Impact 3.7-2: Conflict with an Applicable Plan, Policy, or Regulation Adopted for the Purpose of Reducing the Emissions of GHGs
The project would comply with all laws and regulations governing GHG reduction, and would not conflict with an applicable plan, policy or regulation adopted to reduce GHG emissions. Therefore, this impact would be less than significant.

LTS No mitigation is required for this impact. LTS
Impact 4-7: Cumulative Greenhouse Gas Emissions and Climate Change Impacts There is an existing substantial adverse impact related to greenhouse gas (GHG) emissions and global climate change. However, the project’s contribution to this cumulatively significant impact would not be cumulatively considerable. Cumulative impacts would be less than significant.

LTS No mitigation is required for this impact. LTS

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1.3.2 Section 4.3 Analysis of Cumulative Impacts
Chapter 4, “Cumulative Impacts,” of the 2024 EIR includes a discussion of the project’s contribution to GHG emissions and global climate change. To promote consistency with the Court’s decision, the analysis of cumulative GHG emissions on page 4-11 of the 2024 EIR is revised as follows to remove reference to the now vacated 2021 GHGRP.

Impact 4-7: Cumulative Greenhouse Gas Emissions and Climate Change Impacts There is an existing substantial adverse impact related to greenhouse gas (GHG) emissions and global climate change. However, the project’s contribution to this cumulatively significant impact would not be cumulatively considerable. Cumulative impacts would be less than significant.

The geographic scope of the cumulative impact analysis for GHG emissions and climate change is global. Climate change is an inherently cumulative issue and relates to development in the region, California, and, most of all, the world. Whereas most pollutants with localized air quality effects have relatively short atmospheric lifetimes (approximately 1 day), GHGs have long atmospheric lifetimes (1 year to several thousand years). GHGs persist in the atmosphere long enough to be dispersed around the globe. Although the lifetime of any GHG molecule depends on multiple variables and cannot be determined with any certainty, it is understood that more carbon dioxide (CO 2) is
emitted into the atmosphere than is sequestered by ocean uptake, vegetation, and other forms of sequestration. The combination of GHG emissions from past, present, and future projects contribute substantially to the phenomenon of global climate change and its associated environmental impacts.

Therefore, the impacts discussed in Section 3.7, “Greenhouse Gas Emissions and Climate Change,” are also the cumulative effects of the project. As described therein, the project would not conflict with or impede the state’s ability to meet its GHG reduction goals. Therefore, the project would not make a considerable contribution to the cumulative condition. Cumulative impacts would be less than significant.

1.4 PUBLIC REVIEW PROCESS
The City of Fresno is soliciting comments from responsible agencies, trustee agencies, public agencies, organizations, and members of the public regarding the PR-DEIR. In accordance with the time limits established by CEQA, the PR- DEIR will begin November 21, 2025, and end on January 5, 2026. The PR-DEIR will be circulated to state agencies for review through the State Clearinghouse, a division of the Governor’s Office of Land Use and Climate Innovation and via email.

1.4.1 Document Availability
The PR-DEIR can be reviewed at the following websites: https://ceqanet.opr.ca.gov. A hard copy of the PR-DEIR can also be reviewed at the following locations during business hours (Monday through Friday 8:00 a.m.–5:00 p.m.):
i) City of Fresno Planning and Development Department
2600 Fresno Street Third Floor, Room 3043, Fresno, CA 93721 ii) Fresno County Public Library
2420 Mariposa Street Fresno, CA 93721
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Costco Commercial Center Project Partially Recirculated Draft EIR 1-5

1.4.2 Written Comments on the Partial Recirculated Draft EIR Please provide your written/typed comments (including name, affiliation, telephone number, and contact information) via US mail or email to the address shown below by 5:00 p.m. on January 5, 2026:

ATTN: Steven Martinez, City of Fresno – Planning and Development Department 2600 Fresno Street, Room 3043, Fresno, CA 93721
Email: [email protected]

1.4.3 Limitation on Public Review Comments
The City requests that commenters not make new comments on matters not included in the PR-DEIR and limit their written comments to the new material presented in the PR-DEIR, which consists of Section 3.7, “Greenhouse Gas Emissions and Climate Change,” (and corresponding changes to the cumulative discussion and Executive Summary) only.

This request is made pursuant to State CEQA Guidelines Section 15088.5(f)(2), which states that:

When the EIR is revised only in part and the lead agency is recirculating only the revised chapters or portions of the EIR, the lead agency may request that reviewers limit their comments to the revised chapters or portions of the recirculated EIR. The lead agency need only respond to (i) comments received during the initial circulation period that relate to chapters or portions of the document that were not revised and recirculated, and (ii) comments received during the recirculation period that relate to the chapters or portions of the earlier EIR that were revised and recirculated. The lead agency’s request that reviewers limit the scope of their comments shall be included either within the text of the revised EIR or by an attachment to the revised EIR.

1.5 USE OF THIS DOCUMENT
This PR-DEIR will be combined with the 2024 EIR, which will be considered by the City’s City Council at a future City Council meeting. The Final EIR will include the comments received on this PR-DEIR, along with the written responses to those comments.

The City Council will consider certifying the Final EIR prior to completing its deliberations on the project. If it approves the project, then the City Council will adopt the findings, statement of overriding considerations, and mitigation monitoring and reporting program that are required by CEQA.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-1

3.7 GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE
This section was prepared by Ramboll Americas Engineering Solutions, Inc., experts in the fields of air quality and greenhouse gas (GHG) emissions science and policy. This section presents a summary of regulations applicable to GHG emissions; a summary of climate change science and GHG sources in California; and a quantification of project- generated GHGs and discussion about their contribution to global climate change. Prior to initiation of the 2024 EIR, the City released a notice of preparation on October 22, 2021. No comments were received in response to the notice of preparation that specifically address GHG emissions or climate change. Effects related to pollution and air quality concerns are addressed in Section 3.3, “Air Quality,” of the 2024 EIR.

3.7.1 Regulatory Setting

FEDERAL
Clean Air Act
In April 2007, in Massachusetts v. EPA, the U.S. Supreme Court directed the Administrator of the US Environmental Protection Agency (EPA) to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In making these decisions, the EPA Administrator was directed to follow the language of Section 202(a) of the Clean Air Act (CAA). In December 2009, the Administrator signed a final rule with two distinct findings regarding GHGs under Section 202(a) of the CAA:
 Elevated concentrations of GHGs— carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the “endangerment finding.”  The combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is referred to as the “cause or contribute finding.”
These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the CAA.

Endangerment Finding and Cause or Contribute Finding
On December 7, 2009, the EPA Administrator signed two distinct findings regarding GHGs under CAA Section 202(a) (42 United States Code Section 7521).
 Endangerment Finding: The Administrator found that the current and projected concentrations of the six key well-mixed GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) in the atmosphere threaten the public health and welfare of current and future generations. On July 29, 2025, EPA announced a proposal to rescind the Endangerment Finding and repeal all GHG emission standards for light-duty, medium-duty, and heavy-duty vehicles and engines pursuant to CAA section 202(a). As of the writing this PR-DEIR, EPA has not adopted this proposal.1 The proposed rule would remove GHG-related provisions from 40 CFR part 600 without affecting provisions related to Corporate Average Fuel Economy (CAFE) standards and fuel economy labeling. In general, the proposed rule would remove model year (MY) 2012 and later GHG emission standards for passenger cars and light trucks, and MY 2014 and later GHG emission standards for medium-duty vehicles.2 As of the writing of this PR-DEIR, EPA has

1 EPA. 2025. Proposed Rule: Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards. Available:
https://www.epa.gov/regulations-emissions-vehicles-and-engines/proposed-rule-reconsideration-2009-endangerment-finding. Accessed October 2025.
2 Ibid.

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3.7-2 Costco Commercial Center Project Partially Recirculated Draft EIR not adopted this proposal, and CARB has provided no guidance on how to address this issue in emissions modeling.3
 Cause or Contribute Finding: The Administrator found that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution that threatens public health and welfare.

Federal Plan to Reduce GHG Emissions by 2025
In 2015, President Obama signed Executive Order (EO) 13693, which was intended to reduce the federal government’s GHG emissions by 40 percent by 2025 by requiring the following:
 Ensuring that 25 percent of total energy consumption is from clean energy sources.  Reducing energy use in federal buildings by 2.5 percent per year between 2015 and 2025.  Reducing per-mile GHG emissions from federal fleets by 30 percent (from 2014 levels) by 2025 and increasing the percentage of zero-emissions and plug-in hybrid vehicles in federal fleets.  Reducing water intensity in federal buildings by 2 percent per year through 2025.

This executive order was revoked by President Trump’s EO 13834 in May 2018. President Biden’s EO 13990 revoked EO 13834 except for sections 6 (Duties of the Federal Chief Sustainability Officer), 7 (Duties of Heads of Agencies), and 11 (General Provisions).
4 On January 20, 2025, President Trump announced the recission of EO 13990.5 Executive Order 14008
On January 27, 2021, President Biden issued the Executive Order on Tackling the Climate Crisis at Home and Abroad (EO 14008).6 Part I of the order highlighted putting the climate crisis at the center of United States foreign policy and national security. As stated in EO 14008, addressing the climate crisis will require significant short-term global reductions in GHG emissions and net-zero global emissions by mid-century or sooner. The executive order also stated the United States will pursue green recovery efforts and initiatives to advance the clean energy transition.

Part II of the order relayed the government-wide approach to the climate crisis, which involves reducing climate pollution in every sector of the economy, especially through innovation, commercialization, and deployment of clean energy technologies and infrastructure. A National Climate Task Force was established to focus on addressing the climate crisis through key federal actions to reduce climate change impacts. A 100 percent carbon pollution-free electricity sector was targeted by no later than 2035 and a net-zero emissions economy was to be achieved by no later than 2050. Offshore wind was aimed to be doubled by 2030. Opportunities for federal funding of clean energy technology and infrastructure were to be identified. Federal permitting decisions were required to consider the effects of GHG emissions and climate change.

On January 20, 2025, President Trump announced the recission of EO 14008. 7 3 Ibid.
4 White House Briefing Room. 2021. Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis. January 20. Available at: https://bidenwhitehouse.archives.gov/briefing-room/presidential-actions/2021/01/20/executive-order-protecting- public-health-and-environment-and-restoring-science-to-tackle-climate-crisis/. Accessed: August 2025. 5 The White House. 2025. Initial Rescissions of Harmful Executive Orders and Actions. January 20. Available at:
https://www.whitehouse.gov/presidential-actions/2025/01/initial-rescissions-of-harmful-executive-orders-and-actions/. Accessed: August 2025. 6 White House Briefing Room. 2021. Executive Order on Tackling the Climate Crisis at Home and Abroad. January 27. Available at:
https://bidenwhitehouse.archives.gov/briefing-room/presidential-actions/2021/01/27/executive-order-on-tackling-the-climate-crisis-at-home- and-abroad/. Accessed: August 2025.
7 The White House. 2025. Initial Rescissions of Harmful Executive Orders and Actions. January 20. Available at:
https://www.whitehouse.gov/presidential-actions/2025/01/initial-rescissions-of-harmful-executive-orders-and-actions/. Accessed: August 2025.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-3 Paris Climate Agreement
On June 1, 2017, President Trump withdrew the United States from the Paris Agreement.8 The Paris Agreement was negotiated within the United Nations Framework Convention on Climate Change in 2015 to reduce GHG emissions internationally. The goal of the Paris Agreement was to keep the global temperature rise this century to below 2 degrees Celsius above pre-industrial standards, with efforts to limit temperature increase even further to 1.5 degrees Celsius. The Paris Agreement became effective on November 4, 2016. As of October 5, 2016, 155 of 197 parties had ratified the Paris Agreement.9 On January 20, 2021, President Biden signed an executive order formally rejoining the United States to the Paris Agreement.10 On January 20, 2025, upon his return to office, President Trump once again began the process to withdraw the United States from the Paris Climate Agreement.11 The withdrawal will take effect for the United States on January 27, 2026.12
Federal Vehicle Standards
In response to the Massachusetts v. EPA decision discussed above, in 2007, President Bush directed the EPA, the Department of Transportation (USDOT), and the Department of Energy (DOE) to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the National Highway Traffic Safety Administration (NHTSA) issued a final rule regulating fuel efficiency for and GHG emissions from cars and light-duty trucks for model year 2011; and in 2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016.

In 2010, President Obama issued a memorandum directing the same federal agencies to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model year 2017-2025 light-duty vehicles. The proposed standards are projected to achieve 163 grams/mile of CO 2 in
model year 2025, on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017–2021.

In August 2017, the EPA asked for additional information and data relevant to assessing whether the GHG emissions standards for model years 2022-2025 remain appropriate. In early 2018, the EPA Administrator announced that the midterm evaluation for the GHG emissions standards for cars and light -duty trucks for model years 2022-2025 was completed and stated his determination that the current standards should be revised in light of recent data.

Subsequently, in 2018, the EPA and NHTSA proposed to amend certain existing CAFE standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establish new standards, covering model years 2021-2026. Compared to maintaining the post -2020 standards, the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks proposal was anticipated to increase U.S. fuel consumption.
13 California and other states announced their intent to challenge federal actions that would delay or eliminate GHG reductions. In April 2020, NHTSA and EPA amended the CAFE and GHG emissions standards for passenger cars and light trucks and established new less stringent standards, covering model years 2021 through 2026.

8 EPA. 2017. Administrator Scott Pruitt Speech on Paris Accord, As Prepared. June 1. Available at:
https://archive.epa.gov/epa/speeches/administrator-scott-pruitt-speech-paris-accord-prepared.html. Accessed August 2025. 9 United Nations Framework Convention on Climate Change. 2017. The Paris Agreement. July 27. Available at:
http://unfccc.int/paris_agreement/items/9485.php. Accessed: January 2022. 10 White House Briefing Room. 2021. Paris Climate Agreement. January 20. Available at: https://bidenwhitehouse.archives.gov/briefing- room/statements-releases/2021/01/20/paris-climate-agreement/. Accessed: August 2025. 11 The White House. 2025. Putting America First in International Environmental Agreements. January 20. Available at:
https://www.whitehouse.gov/presidential-actions/2025/01/putting-america-first-in-international-environmental-agreements/. Accessed: August 2025.
12 Congress.gov. 2025. U.S. Withdrawal from the Paris Agreement: Process and Potential Effects. April 14. Available at:
https://www.congress.gov/crs-product/R48504. Accessed: October 2025. 13 Federal Register. 2018. The Safer Affordable Fuel-Efficient (SAFE) Vehicles Final Rule for Model Years 2021-2026 Passenger Cars and Light Trucks.

Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/safer-affordable-fuel-efficient-safe-vehicles-final-rule. Accessed:

August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-4 Costco Commercial Center Project Partially Recirculated Draft EIR On September 27, 2019, the EPA and NHTSA published the SAFE Rule (Part One).14 The SAFE Rule (Part One) went into effect in November 2019, and revoked California’s authority to set its own GHGs standards and set zero emission vehicle mandates in California. The SAFE Rule (Part One) froze new zero emission vehicle (ZEV) sales at model year 2020 levels for year 2021 and beyond, and was expected to likely result in a lower number of future ZEVs and a corresponding greater number of future gasoline internal combustion engine vehicles. In response to the EPA’s adoption of the SAFE Rule (Part One), the California Air Resources Board (CARB) issued guidance regarding the adjustment of vehicle emissions factors to account for the rule’s implications on criteria air pollutant and greenhouse gas emissions.15,16 The SAFE Rule was subject litigation and on February 8, 2021, the D.C. Circuit Court of Appeals granted the Biden Administration’s motion to stay litigation over Part 1 of the SAFE Rule. On April 22 and April 28, 2021, respectively, NHTSA and EPA formally announced their intent to reconsider the Safe Rule (Part One).17,18 The NHTSA finalized the Corporate Average Fuel Economy Pre-emption rulemaking to withdraw its portions of the SAFE I Rule on December 21, 2021.19 On March 9, 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate and entirely rescinded the SAFE Rule (Part One).

In December 2021, the EPA finalized federal GHG emissions standards for passenger cars and light trucks for Model Years 2023-2026. These standards are the strongest vehicle emissions standards ever established for the light-duty vehicle sector and are based on sound science and grounded in a rigorous assessment of current and future technologies.
20 The updated standards will result in avoiding more than 3 billion tons of GHG emissions through 2050.21 In April 2023, the EPA proposed a new more ambitious proposed standards for national GHG emission standards from light-duty and medium-duty vehicles starting with 2027 model year vehicles.22 On March 20, 2024, EPA finalized these standards, which will phase-in over model years 2027-2032. These standards build upon existing rules, and leverage advances in clean car technology to realize benefits to Americans such as the improvement of public health through reduction of criteria air pollutant (CAP) and GHG emissions from vehicles. 23 In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles.

In August 2016, the EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018-2027 for certain trailers, and model years 2021-2027 for semi-trucks, large pickup trucks, vans and all types

14 EPA and NHTSA. 2019. Federal Register, Vol. 84, No. 188, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program. September 27. Available at: https://www.govinfo.gov/content/pkg/FR-2019-09-27/pdf/2019-20672.pdf. Accessed: August 2025. 15 CARB. 2019. EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicle Rule Part One. November 20. Available at:
https://ww3.arb.ca.gov/msei/emfac_off_model_adjustment_factors_final_draft.pdf. Accessed: August 2025. 16 CARB. 2020. EMFAC Off-Model Adjustment Factors for Carbon Dioxide Emissions to Account for the SAFE Vehicles Rule Part One and the Final SAFE Rule. June 26. Available at: https://ww3.arb.ca.gov/msei/emfac_off_model_co2_adjustment_factors_06262020-final.pdf. Accessed: August 2025.
17 NHTSA. 2021. NHTSA Advances Biden-Harris Administration’s Climate & Jobs Goals. April 22. Available at: https://www.nhtsa.gov/press- releases/nhtsa-advances-biden-harris-administrations-climate-jobs-goals. Accessed: January 2022. 18 EPA. 2021. Federal Register, Vol. 86, No. 80, California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment. April 28. Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/notice-reconsideration-previous-withdrawal-waiver. Accessed: January 2022.
19 NHTSA. Available at: https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy. Accessed: May 2022. 20 EPA. 2021. Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026.

Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-emissions. Accessed:

January 2022.
21 Ibid.
22 United States Environmental Protection Agency. 2023. Proposed Rule: Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles. Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/proposed-rule-multi- pollutant-emissions-standards-model. Accessed: August 2025. 23 United States Environmental Protection Agency. 2023. Final Rule: Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light- Duty and Medium-Duty Vehicles. Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-multi-pollutant- emissions-standards-model. Accessed: August 2025.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-5 of sizes of buses and work trucks. The final standards are expected to lower carbon dioxide emissions by approximately 1.1 billion metric tons (MT) and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program.24
On August 5, 2021, EPA announced plans to reduce GHG emissions and other harmful air pollutants from heavy-duty trucks through a series of rulemakings over the next 3 years. The first rulemaking of this Clean Trucks Plan was the Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards, signed on December 20, 2022, which focuses on reducing emissions that form smog and soot and will apply to heavy-duty engines and vehicles beginning in model year 2027. Two additional rulemakings, Phase 3 GHG rule for heavy-duty engines and the multi-pollutant emissions standards for light-duty and medium-duty vehicles were signed in March 2024, and marked the completion of the Clean Trucks Plan.25 On January 20, 2025, newly re-elected President Trump issued EO 14148, entitled the Initial Rescissions of Harmful Executive Orders and Actions, which revokes a Biden era EO 14037 that directed the EPA and the Secretary of Transportation to consider beginning work on rulemakings to establish vehicle emissions standards and fuel economy standards for vehicles with model years 2027 and later. EO 14148 directed NHTSA to commence review and reconsideration of all existing fuel economy standards for vehicle model years 2022 and later. 26 Energy Independence and Security Act
The Energy Independence and Security Act of 2007 facilitated the reduction of national GHG emissions by requiring the following:
 increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard that required fuel producers to use at least 36 billion gallons of biofuel by 2022;  prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances; and  requiring approximately 25 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014 and requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020.

While superseded by the EPA and NHTSA actions described above, the act also established a miles per gallon target for cars and light trucks and directed the NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for trucks.

Additional provisions of the Energy Independence and Security Act addressed energy savings in government and public institutions, promoted research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”
STATE
The State of California considers GHG emissions and the impacts of climate change to be a serious threat to the public health, environment, economic well-being, and natural resources of California, and has taken an aggressive stance to reduce the State’s impact on climate change through the adoption of policies and legislation. CARB is responsible for the coordination and oversight of State and local air pollution control programs in California.

24 EPA and NHTSA, 2016. Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles – Phase 2.

Available at: https://www.gpo.gov/fdsys/pkg/FR-2016-10-25/pdf/2016-21203.pdf. Accessed: August 2025. 25 EPA. Regulations for Emissions from Vehicles and Engines. Available at: https://www.epa.gov/regulations-emissions-vehicles-and- engines/regulations-greenhouse-gas-emissions-commercial-trucks. Accessed: August 2025. 26 US Department of Transportation, 2025. Memorandum to Office of the Administrator of the National Highway Traffic Safety Administration (NHTSA), Office of the Assistant Secretary of Policy (OST-P) AND Office of the General Counsel (OGC), Subject: Fixing the CAFÉ Program.

January 28, 2025. Available at: https://www.transportation.gov/sites/dot.gov/files/2025- 01/Signed%20Secretarial%20Memo%20re%20Fixing%20the%20CAFE%20Program.pdf. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-6 Costco Commercial Center Project Partially Recirculated Draft EIR California has numerous regulations aimed at reducing the State’s GHG emissions. Some of the major initiatives are summarized below.

Executive Order S-3-05
In 2005, Governor Schwarzenegger issued EO S-3-05, which identifies Statewide GHG emission reduction targets to achieve long-term climate stabilization as follows.
 reduce GHG emissions to 1990 levels by 2020; and
 reduce GHG emissions to 80 percent below 1990 levels by 2050.

In response to EO S-3-05, California Environmental Protection Agency (CalEPA) created the Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT Report”).27 The 2006 CAT Report identified a recommended list of strategies that the State could pursue to reduce GHG emissions. These are strategies that could be implemented by various State agencies to ensure that the emission reduction targets in EO S-3-05 are met and can be met with the existing authority of the State agencies. The strategies include, but are not limited to, the reduction of passenger and light-duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill methane capture.

Assembly Bill 32
Assembly Bill (AB) 32 (Nunez 2006), the California Global Warming Solutions Act of 2006, was enacted after considerable study and expert testimony before the Legislature. The heart of AB 32 is the requirement that statewide GHG emissions be reduced to 1990 levels by 2020. In order to achieve this reduction mandate, AB 32 requires CARB to employ an open public process to adopt rules and regulations that achieve the maximum technologically feasible and cost-effective GHG reductions.

In 2007, CARB approved a statewide limit on the GHG emissions level for year 2020 consistent with the determined 1990 baseline. CARB’s adoption of this limit was in accordance with Health & Safety Code Section 38550, as codified through enactment of AB 32.

Per Health & Safety Code Section 38561(b), CARB also is required to prepare, approve and amend a scoping plan that identifies and makes recommendations on “direct emission reduction measures, alternative compliance mechanisms, market-based compliance mechanisms, and potential monetary and nonmonetary incentives for sources and categories of sources that [CARB] finds are necessary or desirable to facilitate the achievement of the maximum feasible and cost-effective reductions of greenhouse gas emissions by 2020.” In 2008, CARB adopted the
Climate Change Scoping Plan: A Framework for Change (2008 Scoping Plan) in accordance with Health & Safety Code Section 38561. During the development of the 2008 Scoping Plan, CARB created a planning framework that is comprised of eight emissions sectors: (1) transportation; (2) electricity; (3) commercial and residential; (4) industry; (5) recycling and waste; (6) high global warming potential (GWP) gases; (7) agriculture; and (8) forest net emissions. The 2008 Scoping Plan established an overall framework for the measures to be adopted to reduce California’s GHG emissions from the eight emissions sectors to 1990 levels by 2020.

In the 2011 Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document (2011 Final Supplement), CARB revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated information about GHG reduction regulations.

In 2014, CARB adopted the
First Update to the Climate Change Scoping Plan: Building on the Framework (2014 First Update).28 The stated purpose of the 2014 First Update was to “highlight […] California’s success to date in reducing its GHG emissions and lay […] the foundation for establishing a broad framework for continued emission reductions

27 California Environmental Protection Agency (CalEPA), March 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. Available at: https://downloads.regulations.gov/FWS-R8-ES-2020-0074-0003/attachment_9.pdf. Accessed: January 2022. 28 Health & Safety Code Section 38561(h) requires CARB to update the Scoping Plan every five years.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-7 beyond 2020, on the path to 80 percent below 1990 levels by 2050.”29 The 2014 First Update found that California was on track to meet the 2020 emissions reduction mandate established by AB 32, and noted that California could reduce emissions further by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80 percent below 1990 levels by 2050 if the State realizes the expected benefits of existing policy goals.30 In November 2017, CARB published California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan), which was subsequently adopted by CARB’s Board in December 2017.31 The 2017 Scoping Plan identified CARB’s strategy for achieving the State’s 2030 GHG target as established in Senate Bill (SB) 32 (discussed below). The strategy included continuation of the Cap-and-Trade Program through 2030, and incorporated a Mobile Source Strategy that included strategies targeted to increase zero emission vehicle fleet penetration and a more stringent target for the Low Carbon Fuel Standard by 2030. The 2017 Scoping Plan also incorporated approaches to cutting short-lived climate pollutants under the ShortLived Climate Pollutant Reduction Strategy (a planning document that was adopted by CARB in March 2017), and acknowledged the need for reducing emissions in agriculture and highlighted the work underway to ensure that California’s natural and working lands increasingly sequester carbon.

CARB adopted the Final 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) on December 16, 2022, which is the current Scoping Plan relevant for statewide planning efforts. 32 The 2022 Scoping Plan assesses progress
towards achieving the SB 32 2030 target and lays out a path to achieve carbon neutrality no later than 2045. It aims to reduce anthropogenic emissions to 85 percent below 1990 levels by 2045 using technically feasible and cost- effective solutions. The 2022 Scoping Plan focuses on electrification of transportation, homes and buildings, and phasing out fossil fuels. In hard-to-electrify sectors, new solutions such as renewable hydrogen and biomethane are forecasted to be leveraged to achieve emissions reductions.

The 2022 Scoping Plan developed a table of priority GHG reduction strategies that can be utilized by local governments. This is Table 1 in Appendix D of the 2022 Scoping Plan Update. 33 The three main priority areas
addressed in this table are “Transportation Electrification,” “VMT Reduction,” and “Building Decarbonization.” These measures represent the core strategies that local jurisdictions in California can implement to reduce GHGs in alignment with State goals. When discussing Table 1 of Appendix D, the 2022 Scoping Plan notes:

To assist local jurisdictions with developing local climate plans, measures, policies, and actions aligned with the State’s climate goals, Table 1 presents a non-exhaustive list of impactful GHG reduction strategies that can be implemented by local governments. The strategies in Table 1 are not applicable to all local jurisdictions, nor are they the only strategies that local governments can adopt, but they represent the core strategies that most jurisdictions in California can implement to reduce GHG emissions regardless of whether they have developed a CEQA-qualified CAP [climate action plan]. Reaching the outcomes of these priority GHG reduction strategies requires a locally appropriate, comprehensive adoption of policies in support of these objectives. When developing local climate plans, measures, policies, and actions, local jurisdictions should incorporate the recommendations described in Table 1 to the extent appropriate to ensure alignment with State climate goals.

As explained by the 2022 Scoping Plan Update, the state does not expect each individual project to result in net zero with no increase in GHG emissions.
34 Rather, GHG reduction planning must understand that the population and land use/economic sectors in California will continue to grow and, therefore, decisions should balance growth that includes GHG increases with effective GHG reduction strategies.

29 CARB, First Update to the Climate Change Scoping Plan: Building on the Framework (May 2014), p. 4. 30 Id. at p. 34.
31 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. Available at:
https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed: August 2025. 32 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. December. Available at: https://ww2.arb.ca.gov/our-work/programs/ab-32- climate-change-scoping-plan/2022-scoping-plan-documents. Accessed: August 2025. 33 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. December. Available at: https://ww2.arb.ca.gov/our-work/programs/ab-32- climate-change-scoping-plan/2022-scoping-plan-documents. Accessed: August 2025. 34 CARB. 2022. 2022 Scoping Plan Appendix D: Local Actions. November. Available at: https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp- appendix-d-local-actions.pdf. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-8 Costco Commercial Center Project Partially Recirculated Draft EIR SB 605 - Short-lived Climate Pollutants
Short-lived climate pollutants (i.e., black carbon, fluorinated gases, and methane) are powerful climate forcers that remain in the atmosphere for a much shorter period of time than longer-lived climate pollutants. Their relative potency, when measured in terms of how they heat the atmosphere, can be tens, hundreds, or even thousands of times greater than that of CO2. The impacts of short-lived climate pollutants are especially strong over the short term.

Reducing these emissions can make an immediate beneficial impact on climate change.35 Governor Brown signed SB 605 on September 21, 2014, directing CARB to develop a Short-Lived Climate Pollutant Strategy by January 1, 2016.

On May 7, 2015, CARB released a concept paper for reducing emissions of these substances. In September 2015, CARB released a draft of its Short-Lived Climate Pollutant Strategy. Several updates to the draft have been made since September 2015, with the most current version dated March 2017. The strategy aims for a 40 percent reduction in methane and HFC emissions below 2013 levels by 2030 and a 50 percent reduction in anthropogenic emissions of black carbon below 2013 levels by 2030.
36 In September 2016, Governor Brown set methane reduction targets for California through SB 1383 in an effort to reduce SLCPs.
37 Landfills are the third largest source of methane in California, and so the targets focused on ways in which the State can fight climate change through recycling organic waste.38 The targets in SB 1383 must:
 reduce organic waste disposal 75 percent by 2025, and  send at least 20 percent of surplus, fresh food to Californians in need by 2025.

Cap-and-Trade Program
California’s Cap-and-Trade Program (Cal. Code Regs., tit. 17, §§ 95800-96022) regulates the emissions of large electric power plants, large industrial plants, and fuel distributors (including transportation fuel and natural gas). These sources are responsible for about 80 percent of the State’s total GHG emissions inventory. 39 As described by CARB:
“The Cap-and-Trade Regulation establishes a declining limit on major sources of GHG emissions throughout California, and it creates a powerful economic incentive for significant investment in cleaner, more efficient technologies… CARB creates allowances equal to the total amount of permissible emissions (i.e., the “cap”).

One allowance equals one metric ton of carbon dioxide equivalent emissions (using the 100-year GWP). Each year, fewer allowances are created and the annual cap declines. An increasing annual auction reserve (or floor) price for allowances and the reduction in annual allowances creates a steady and sustained carbon price signal to prompt action to reduce GHG emissions. All covered entities in the Cap-and-Trade Program are still subject to existing air quality permit limits for criteria and toxic air pollutants.” 40 In the Cap-and-Trade Program, the State regulates the quantity of emissions by determining, in advance, how many allowances to issue—i.e., setting the “cap.” Each allowance is essentially a permit issued by the State authorizing a certain quantity of GHG emissions. There are only a finite number of allowances, ensuring that covered entities may only lawfully emit a certain quantity of GHGs. If a covered entity wishes to emit carbon, it must obtain allowances to authorize those emissions.

Importantly, the Cap-and-Trade Program has been designed to provide a firm cap, ensuring that the 2020 statewide emissions limit identified by CARB in the 2008 Scoping Plan will not be exceeded.41 Thus, for the emission sources
covered by the program, which are nearly all of the sources associated with land use development projects, compliance with AB 32’s 2020 mandate is assured by the Cap-and-Trade Program.

35 CARB. 2016. Reducing Short-Lived Climate Pollutants in California. Available at: https://www.arb.ca.gov/cc/shortlived/shortlived.htm. Accessed:

January 2022.
36 CARB. 2017. Short-Lived Climate Pollutant Reduction Strategy. Available at: https://ww2.arb.ca.gov/sites/default/files/2020- 07/final_SLCP_strategy.pdf. Accessed: January 2022.
37 CalRecycle. California’s Short-Lived Climate Pollutant Reduction Strategy. Available at: https://calrecycle.ca.gov/organics/slcp/. Accessed: August 2025.
38 Ibid.
39 CARB, Cap-and-Trade Program. Available at: http://www.arb.ca.gov/cc/capandtrade/capandtrade.htm. Accessed: August 2025. 40 Ibid.
41 CARB, 2008. Climate Change Scoping Plan: A Framework for Change (December 2008), pp. 30-31.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-9 AB 398 (2017) extended the statutorily defined horizon year of the Cap-and-Trade Program to December 31, 2030, thereby facilitating continued reliance on the Cap-and-Trade Program for purposes of achieving SB 32’s 2030 statewide reduction target.

In June 2023, CARB proposed to amend the Cap-and-Trade regulation and since then has hosted numerous workshops on the potential amendments.42 In April 2024, CARB published a Standardized Regulatory Impact Assessment of the potential amendments, which outline changes to the regulation such as revision of future allowances, updates to industrial allowance allocations, and other changes that are intended to align the Cap-and- Trade Program with updated statewide GHG reduction targets in the 2022 Scoping Plan Update.43 These updated statewide targets include a 48 percent reduction of anthropogenic GHG emissions below 1990 levels by 2030, an 85 percent reduction of GHG emissions below 1990 levels by 2045, and achieving carbon neutrality by 2045.44 The project did not specifically quantify a benefit from the Cap-and-Trade program.

Executive Order B-30-15
In April 2015, Governor Brown signed EO B-30-15, which established the following GHG emission reduction goal for California: by 2030, reduce GHG emissions to 40 percent below 1990 levels. This executive order also directed all State agencies with jurisdiction over GHG-emitting sources to implement measures designed to achieve the interim 2030 goal, as well as the pre-existing, long-term 2050 goal identified in EO S-3-05 (see discussion above). Additionally, the executive order directed CARB to update its Scoping Plan to address the 2030 goal (CARB has done so; see discussion under “Assembly Bill 32,” above).

Senate Bill 32 and Assembly Bill 197
Enacted in 2016, SB 32 (Pavley 2016) codified the 2030 emissions reduction goal of EO B30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030.

SB 32 was coupled with a companion bill: AB 197 (Garcia, 2016). Designed to improve the transparency of CARB’s regulatory and policy-oriented processes, AB 197 created the Joint Legislative Committee on Climate Change Policies, a committee with the responsibility to ascertain facts and make recommendations to the Legislature concerning statewide programs, policies, and investments related to climate change. AB 197 also requires CARB to make certain GHG emissions inventory data publicly available on its web site; consider the social costs of GHG emissions when adopting rules and regulations designed to achieve GHG emission reductions; and include specified information in all Scoping Plan updates for the emission reduction measures contained therein.

Executive Order B-55-18
In September 2018, Governor Brown signed EO B-55-18, which established a new statewide goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” This executive order directed CARB to “work with relevant state agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.” In January 2019, CARB kicked off workshops regarding carbon neutrality in California,45 during which CARB staff explained that the definitional parameters and meaning of the term – carbon neutrality – were still being explored.

CARB held additional workshops throughout 2019 and 2020 to explore specific topics related to the pursuit of carbon neutrality, engage with other experts in the field and stakeholders, and conduct research to ensure that any path to carbon neutrality balances scientific, economic and social justice principles.

42 CARB. Cap-and-Trade Meetings & Workshops. Available here:
https://ww2.arb.ca.gov/our-work/programs/cap-and-trade-program/cap-and-trade-meetings-workshops. Accessed: August 2025. 43 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. December. Available at: https://ww2.arb.ca.gov/our-work/programs/ab-32- climate-change-scoping-plan/2022-scoping-plan-documents. Accessed: August 2025. 44 CARB. 2024. Regulation for the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms 2024 Amendments Standardized Regulatory Impact Assessment (SRIA). April 9. Available here: https://ww2.arb.ca.gov/sites/default/files/2024-04/nc-Cap-and- Trade_SRIA2024.pdf. Accessed: August 2025.
45 CARB. Carbon Neutrality in California Context Webinar. January 2019. Available at:
https://www.arb.ca.gov/cc/scopingplan/meetings/012319/cneutrality_ca_script.pdf. Accessed: January 2022.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-10 Costco Commercial Center Project Partially Recirculated Draft EIR Assembly Bill 1279
In September 2022, the California Legislature passed AB 1279, which established that the State must achieve carbon neutrality as soon as possible, but no later than 2045, and maintain net negative GHG emissions thereafter.

Additionally, AB 1279 required that by 2045 statewide anthropogenic GHG emissions be reduced at least 85 percent below 1990 levels.46
Energy Sources
Renewables Portfolio Standard
As most recently amended by SB 100 (2018), California’s Renewables Portfolio Standard requires retail sellers of electric services and local publicly owned electric utilities to increase procurement from eligible renewable energy resources to 50 percent of total retail sales by 2026, and 60 percent of total retail sales by 2030. SB 100 also established a State policy goal to achieve 100 percent renewables by 2045.

In March 2021, California Energy Commission (CEC), California Public Utilities Commission (CPUC), and CARB released a joint-agency report evaluating the current feasibility of achieving the energy resource and GHG reductions goals of SB 100. The report found that SB 100 is technically feasible when analyzed under scenarios of varying timelines, advancements in energy generation technology, and energy source portfolios. Under the SB 100 Core Scenario, it is anticipated that California will need to triple its current electricity power capacity.47 To further support the State’s goals, SB 1020 establishes interim targets for the State’s 100 percent clean energy goal in 2045.
48 The bill requires 90 percent renewable and zero-carbon electricity by 2035, 95 percent by 2040, and 100 percent by 2045.49
Building Energy Efficiency Standards
Title 24, Part 6 of the California Code of Regulations regulates the design of building shells and building components.

The standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods.

The CEC’s 2022 Building Energy Efficiency Standards (2022 Building Standards), which became effective January 1, 2023, are the currently applicable version of these standards. 50 However, due to the date of the building permit application submission of the Costco (i.e., prior to January 1, 2023), the CEC’s 2019 Building Energy Efficiency Standards (2019 Building Standards), which became effective January 1, 2020, are the applicable version of these standards for the project. In general, single-family homes built to the 2019 standards are anticipated to use about 7 percent less energy due to energy efficiency measures than those built to the 2016 standards, and nonresidential buildings built to the 2019 standards will use an estimated 30 percent less energy than those built to the 2016 standards. 51 In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CalGreen, and establishes voluntary and mandatory standards pertaining to the planning and design of sustainable site development, energy efficiency, water conservation, material conservation, and interior air quality. Like Part 6 of Title 24, the CalGreen standards are periodically updated, with increasing energy savings and efficiencies associated with each code update.

46 California Legislature Information. 2022. Assembly Bill 1279. September 16. Available at:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB1279. Accessed: August 2025. 47 CEC. 2021. 2021 SB 100 Joint Agency Report, Achieving 100 Percent Clean Electricity in California: An Initial Assessment. Available at:
https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-report-achieving-100-percent-clean-electricity. Accessed: January 2022. 48 California Legislature Information. 2022. Senate Bill No. 1020. September 16. Available at:
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220SB1020. Accessed: October 2025. 49 Ibid.
50 CEC. 2022 Building Energy Efficiency Standards. Available at: https://www.energy.ca.gov/programs-and-topics/programs/building-energy- efficiency-standards/2022-building-energy-efficiency. Accessed: August 2025. 51 CEC. 2018. 2019 Building Energy Efficiency Standards – Frequently Asked Questions. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf. Accessed: January 2022.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-11 At the time of this writing, the CEC has adopted the 2025 Energy Code, which improves upon the 2022 standards for construction of residential and non-residential buildings. The standards will be effective on January 1, 2026. However, as noted above, the project will be subject to the 2019 Building Standards based upon the date of the building permit application submission.52
Appliance Standards
The CEC periodically amends and enforces Appliance Efficiency Regulations contained in Title 20 of the California Code of Regulations. The regulations establish water and energy efficiency standards for both federally regulated appliances and non-federally regulated appliances. The regulations cover numerous categories of appliances (e.g., refrigerators; plumbing fixtures; dishwashers; clothes washer and dryers; televisions) and apply to appliances offered for sale in California.53
Mobile Sources
Sustainable Communities Strategy Plans
SB 375 (Steinberg, 2008), the Sustainable Communities and Climate Protection Act, coordinates land use planning, regional transportation plans, and funding priorities to reduce GHG emissions from passenger vehicles through better-integrated regional transportation, land use, and housing planning that provides easier access to jobs, services, public transit, and active transportation options. SB 375 specifically requires the Metropolitan Planning Organization relevant to the project area (here, the Fresno Council of Governments [Fresno COG]) to include a Sustainable Communities Strategy (SCS) in its Regional Transportation Plan (RTP) that, if implemented, will achieve GHG emission reduction targets set by CARB by reducing vehicle miles traveled (VMT) from light-duty vehicles through the development of more compact, complete, and efficient communities.

For the area under Fresno COG’s jurisdiction, including the project site in the city, CARB originally adopted regional targets for reduction of mobile source-related GHG emissions of 5 percent for 2020 and 10 percent for 2035. The targets are expressed as a percentage change in per capita passenger vehicle GHG emissions relative to 2005 emissions levels. These original targets were in place through September 30, 2018. In March 2018, CARB approved updated regional targets of 6 percent for 2020 and 13 percent for 2035 for Fresno COG, which apply to RTP/SCS planning cycles beginning October 1, 2018.
54 Since the 2022 RTP/SCS for Fresno County was approved by the Fresno COG Policy Board on July 28, 2022, the relevant targets utilized in the plan were 6 percent for 2020 and 13 percent for 2035.

Senate Bill 743
Public Resources Code Section 21099(c)(1), as codified through enactment of SB 743 (Steinberg 2013), authorized the Governor’s Office of Planning and Research to establish “alternative metrics to the metrics used for traffic levels of service for transportation impacts outside transit priority areas.” SB 743 reflects a legislative policy to balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of GHG emissions. As finalized in December 2018, amendments to the State CEQA Guidelines adopted in furtherance of SB 743 establish VMT as the new metric for transportation analysis (in lieu of level of service).

Pavley Regulations
AB 1493 (Pavley 2002) required CARB to adopt regulations to reduce GHG emissions from non-commercial passenger vehicles and light-duty trucks for model years 2009–2016. CARB obtained a waiver from the EPA that allows for implementation of these regulations notwithstanding possible federal pre-emption concerns.

52 CEC. 2022 Building Energy Efficiency Standards. Available at: https://www.energy.ca.gov/programs-and-topics/programs/building-energy- efficiency-standards/2022-building-energy-efficiency. Accessed: January 2022. 53 CEC. Title 20 Appliance Efficiency Program. Available at: https://www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-

20. Accessed: January 2022.
54 CARB. Regional Plan Targets. Available at: https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plan-targets.

Accessed: January 2022.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-12 Costco Commercial Center Project Partially Recirculated Draft EIR Low Carbon Fuel Standard
EO S-1-07, as issued by Governor Schwarzenegger, called for a 10 percent or greater reduction in the average fuel carbon intensity for transportation fuels in California regulated by CARB by 2020.55 In response, CARB approved the Low Carbon Fuel Standard (LCFS) regulations in 2009, which became fully effective in April 2010. Thereafter, a lawsuit was filed challenging CARB’s adoption of the regulations; and in 2013, a court order was issued compelling CARB to remedy substantive and procedural defects of the LCFS adoption process under CEQA.56 However, the court allowed implementation of the LCFS to continue pending correction of the identified defects. In September 2015, CARB re-adopted the LCFS regulations. The most recent amendments to the LCFS regulation were adopted on November 8, 2024. These amendments are projected to reduce GHG emissions by reducing the carbon intensity of transportation fuels used in California by at least 30 percent in 2030 and 90 percent in 2045, as compared to the 2010 baseline.57
Advanced Clean Cars Program
In 2012, CARB approved the Advanced Clean Cars (ACC) program, a new emissions-control program for non- commercial passenger vehicles and light-duty trucks for model years 2017-2025. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero emission vehicles. The Low-Emission Vehicle (LEV) III program GHG component was developed in in coordination with the EPA and NHTSA for One National Program to harmonize GHG and fuel economy standard.

In 2022, CARB approved the Advanced Clean Cars II (ACC II) regulations which “will seek to reduce criteria and greenhouse gas emissions from new light- and medium-duty vehicles beyond the 2025 model year, and increase the number of ZEVs for sale.”58 In October 2023, CARB launched a new effort to consider potential amendments to the ACC II regulations, including updates to the tailpipe GHG emission standard and limited revisions to the Low- emission Vehicle and ZEV regulations. On December 18, 2024, EPA granted a waiver for California’s ACC II regulation.59
In May 2025, the United States Congress voted to disapprove California’s Clean Air Act waiver for ACC II regulation using the Congressional Review Act. In response to this action, CARB stated that they “will pursue every available remedy to challenge these actions”60 and Governor Newson announced that California would join a 11-state coalition to advance clean cars.61
Zero Emission Vehicles
ZEVs include hydrogen fuel cell electric vehicles and plug-in electric vehicles, such as battery electric vehicles and plug-in hybrid electric vehicles.

In 2012, Governor Brown issued EO B-16-2012, which calls for the increased penetration of ZEVs into California’s vehicle fleet in order to help California achieve a reduction of GHG emissions from the transportation sector equaling 80 percent less than 1990 levels by 2050. In furtherance of that statewide target for the transportation sector, the executive order also calls upon CARB, the CEC, and the CPUC to establish benchmarks that will: (1) allow over 1.5 million ZEVs to be on California roadways by 2025, and (2) provide the State’s residents with easy access to ZEV infrastructure. EO B-

55 Carbon intensity is a measure of the GHG emissions associated with the various production, distribution, and use steps in the “lifecycle” of a transportation fuel.
56 POET, LLC v. CARB (2013) 217 Cal.App.4th 1214.
57 CARB. 2024. Low Carbon Fuel Standard Amendments SCH# 2023020330. Available at:
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2024/lcfs2024/nod.pdf. Accessed: August 2025. 58 Advanced Clean Cars II Program. Available at:
https://ww2.arb.ca.gov/advanced-clean-cars-ii-meetings-workshops. Accessed: August 2025. 59 U.S. EPA. 2024. EPA Grants Waiver for California’s Advanced Clean Cars II Regulations. December 18. Available at:
https://www.epa.gov/newsreleases/epa-grants-waiver-californias-advanced-clean-cars-ii-regulations. Accessed: August 2025. 60 CARB. 2025. CARB Chair Liane Randolph responds to illegal and unconstitutional approval of Congressional Review Act resolutions by the U. S.

Senate. May 22. Available at: https://ww2.arb.ca.gov/news/carb-chair-liane-randolph-responds-illegal-and-unconstitutional-approval- congressional-review. Accessed: August 2025.
61 Governor Gavin Newson. 2025. Following illegal Senate vote, California and 10 other states launch Affordable Clean Cars Coalition. May 23.

Available at: https://www.gov.ca.gov/2025/05/23/following-illegal-senate-vote-california-and-10-other-states-launch-affordable-clean-cars- coalition/. Accessed: August 2025.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-13 16-2012 specifically directed California to “encourage the development and success of zero-emission vehicles to protect the environment, stimulate economic growth, and improve the quality of life in the State.”62 In 2018, Governor Brown also issued EO B-48-18, which launched an 8-year initiative to accelerate the sales of ZEVs through a mix of rebate programs and infrastructure improvements. The EO also sets a new target of five million ZEVs in California by 2030 and includes funding for multiple state agencies to increase electric vehicle (EV) charging infrastructure and provide purchase rebates/incentives.

In September 2018, the Governor’s Interagency Working Group on Zero-Emission Vehicles published the 2018 ZEV Action Plan Priorities Update.63 This update was the result of Governor Brown’s directive to update the 2016 Zero- Emission Vehicle Action Plan to help expand private investment in zero-emission vehicle infrastructure, particularly in low income and disadvantaged communities. The 2018 Priorities Update served three fundamental purposes: 1) provide direction to state agencies on the most important actions to be executed in 2018 to enable progress toward the 2025 targets and 2030 Vision; 2) give stakeholders transparency into the actions state agencies plan to take (or are taking) to further the ZEV market; and 3) create a platform for stakeholder engagement, feedback, and collaboration.

In February 2021, the Governor’s Office of Business and Economic Development ZEV Team published the 2021 Strategy Document.64 The 2021 Strategy is centered around four market pillars:
1) Vehicles: Transitioning California’s economy to zero-emission mobility requires a wide range of vehicles. The Vehicles Pillar encompasses light-, medium-, and heavy-duty vehicles and equipment powered by battery electric and hydrogen fuel cell electric technologies. As of March 2025, over 2 million ZEVs have been sold and there were approximately 18,473 medium-heavy duty ZEVs in California. 2) Infrastructure: This pillar focuses on fueling infrastructure to support ZEVs including EV charging and hydrogen fueling stations, catenary systems, and the energy systems that supply them to drive charging and fueling value for end users and the grid. As of March 2025, there have been 178,549 battery electric chargers and 60 hydrogen stations open.
3) End Users: End users of ZEVs include consumers, riders, fleet operators, transportation network companies, car dealers, drivers, transportation planning agencies, program administrators, ports, regional and local governments and communities, trucking companies, fuel providers, and more. As ZEV adoption increases, the state is working with stakeholders to understand barriers, find solutions, and improve the overall end user experience. As of March 2025, 615,355 ZEVs were incentivized through Clean Cars 4 All in priority communities and over 8,000 vouchers were issued for zero-emission trucks, buses and off-road equipment through the Hybrid and Zero- Emission Truck and Bus Voucher Incentive Project and Clean Off-Road Equipment Voucher Incentive Project. 4) Workforce: California is at the forefront of ZEV production in the United States. As the state strives to achieve its renewable energy objectives, it aims to boost the ZEV and battery manufacturing sectors, both part of the Clean Economy designation in the Jobs First Economic Blueprint. This sector is anticipated to expand by approximately

2.9 percent over the next 8 years. The ZEV workforce encompasses various roles, including design, manufacturing, sales, installation, servicing, and maintenance of ZEVs and their infrastructure, like charging stations and distribution systems. As of June 2025, 55 ZEV-related manufacturing companies were based in California and over 26,100 California jobs were in ZEV-related manufacturing.

Advanced Clean Trucks
In June 2020, CARB approved the Advanced Clean Trucks (ACT) regulation, which has requirements for manufacturer ZEV sales and a one-time reporting requirement for large entities and fleets.65 The Advanced Clean Truck Regulation is part of a holistic approach to accelerate a large-scale transition of zero-emission medium-and heavy-duty vehicles

62 Executive Order B-16-2012. Available at: https://www.ca.gov/archive/gov39/2012/03/23/news17472/. Accessed: August 2025. 63 Governor’s Interagency Working Group on Zero-emission Vehicles. 2018. Available at: https://static.business.ca.gov/wp- content/uploads/2019/12/2018-ZEV-Action-Plan-Priorities-Update.pdf. Accessed: August 2025. 64 GO-Biz ZEV Team. 2021. California Zero-Emission Vehicle Market Development Strategy. Available at: https://business.ca.gov/industries/zero- emission-vehicles/zev-strategy-2/. Accessed: August 2025. 65 CARB. 2020. Advanced Clean Trucks. Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-clean-trucks. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-14 Costco Commercial Center Project Partially Recirculated Draft EIR from Class 2b to Class 8. Manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines are required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales need to be 55 percent of Class 2b – 3 truck sales, 75 percent of Class 4 – 8 straight truck sales, and 40 percent of truck tractor sales. Large employers including retailers, manufacturers, brokers, and others are required to report information about shipments and shuttle services. Fleet owners with 50 or more trucks are required to report about their existing fleet operations. This information helps to identify future strategies to ensure that fleets purchase available zero-emission trucks and place them in service where suitable to meet their needs. In May 2025, the United States Congress voted to disapprove California’s Clean Air Act waiver for the Heavy-Duty Omnibus Regulation using the Congressional Review Act. In response to this action, CARB stated that they “will pursue every available remedy to challenge these actions.”66 Executive Order N-79-20
On September 23, 2020, California Governor Gavin Newsom issued Executive Order N7920, which orders the following actions:
 all new passenger vehicles sold in California be zero-emission by 2035,  all medium- and heavy-duty vehicles be zero-emission where feasible by 2045, and  all off-road vehicles and equipment be zero-emission where feasible by 2035.

Governor Newsom ordered extensive inter-agency efforts to support the executive order, including evaluations of technological feasibility and cost effectiveness, expansion of EV charging options and affordable fueling, as well as identification of near-term strategies to increase zero-emission public transportation options.

The executive order was generally aimed at transitioning away from fossil fuel dependence in the state, with emphasis on transportation initiatives. However, Governor Newsom addressed efforts to repurpose oil production facilities and extraction sites while continuing the State’s existing goals to reduce the carbon intensity of fuels. 67 Advanced Clean Fleets
In October 2022, CARB approved the Advanced Clean Fleets (ACF) regulation, which has requirements for fleets to phase-in the use of ZEV from 2024 to 2042 and beyond. The fleets required to comply with the regulation include state and local government agency fleets, high priority and federal fleets, and drayage fleets. The regulation also includes a requirement for manufacturers to only sell zero emission trucks starting in 2036. The ACF regulation is meant to complement the ACT regulation and will contribute to meeting the goals set out in Governor Newsom’s EO N-79-20. On January 13, 2025, California withdrew its request for a waiver and authorization for the ACF regulation. 68 CARB is not enforcing the existing portions of the ACF regulation that require a federal waiver or authorization. This includes the high priority and drayage fleet portions of the ACF regulation. Note, the state and local government fleets portion of the ACF remain unaffected as CARB does not require a federal waiver or authorization. 69 Airborne Toxic Control Measure (ATCM): Transportation Refrigeration Unit This ATCM applies to transportation refrigeration units (TRUs), which are commonly found on various transported containers, including truck vans, semi-truck trailers, shipping containers and railcars. TRUs are temperature control systems powered by small (typically 9 to 36 horsepower) diesel internal combustion engines. Despite their small individual size, TRUs are often active in dense congregations around distribution centers, truck stops, and other facilities, resulting in a significantly greater combined loading. This ATCM focused on the reduction of diesel particulate emissions as a toxic in order to improve air quality around these centers. Additionally, transitioning diesel TRUs to zero

66 United States. 2025. Public Law 119-15: Providing Congressional Disapproval of the EPA Rule Relating to California Motor Vehicle Pollution Standards. Available at: https://www.congress.gov/bill/119th-congress/house-joint-resolution/87. Accessed: October 2025. 67 State of California. 2020. Executive Order N-79-20. Available at: https://www.gov.ca.gov/wp-content/uploads/2020/09/9.23.20-EO-N-79-20- Climate.pdf. Accessed: January 2022.
68 CARB. 2025. Withdrawal of California’s Request for a Waiver, Pursuant to Clean Air Act Section 209(b), and Request for Authorization, Pursuant to Clean Air Act Section 209(e)(2), for the Advanced Clean Fleets (ACF) Regulation, Docket ID EPA-HQ-OAR-2023-0589. January 13. Available at:
https://www.epa.gov/system/files/documents/2025-01/ca-acf-carb-withdrawal-ltr-2025-1-13.pdf. Accessed: August 2025. 69 CARB. 2025. Advanced Clean Fleets. Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-clean-fleets. Accessed: August 2025.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-15 emissions technologies is a priority because of Executive Order N-79-20, which set a goal of 100 percent zero emission off-road vehicles and equipment in California by 2035. On January 3, 2025, EPA partially granted California Clean Air Act authorization of its TRU Regulation. In its action, EPA did not act on the Zero Emission TRU requirements for the turnover of at least 15 percent of [the] diesel-fueled truck TRU fleet to zero emissions by December 31, 2023 (and each year thereafter) within the 2022 TRU Amendments. On January 13, 2025, CARB withdrew its request for the requirements of the TRU Regulation that were not acted on and is evaluating next steps.70 Water
In January 2014, Governor Brown signed EO B-29-15, which directed the State Water Resources Control Board to impose restrictions to reduce residential potable urban water usage; to implement water efficiency measures at commercial, industrial, and institutional properties; and to prohibit irrigation with potable water for certain uses. In addition, this order directed the California Department of Water Resources to lead a statewide initiative to replace lawns and ornamental turfs with drought tolerant landscapes.  Pursuant to EO B-29-15, water-related standards were adopted as amendments to the 2013 CalGreen Code and carried over into subsequent updates.
 Following EO-B-29-15, Governor Brown signed EO-B-37-16 in May 2016 to promote more conscious consumer water use and to improve agricultural water use efficiency and drought planning.  Following EO-37-16, Governor Brown signed EO B-40-17 in April 2017, which directed state agencies to continue to implement measures aimed at conserving water and advances measures that improve water management practices.

Solid Waste Diversion
The California Integrated Waste Management Act of 1989, as modified by AB 341 (Chesbro 2011), requires each jurisdiction’s source reduction and recycling element to include an implementation schedule that shows: (1) diversion of 25 percent of all solid waste by January 1, 1995, through source reduction, recycling, and composting activities; (2) diversion of 50 percent of all solid waste on and after January 1, 2000; and (3) source reduction, recycling and composting of 75 percent of all solid waste on or after 2020, and annually thereafter. CalRecycle is required to develop strategies, including source reduction, recycling, and composting activities, to achieve the 2020 goal.

CalRecycle published a discussion document, entitled
California’s New Goal: 75 Percent Recycling, which identified concepts that would assist the State in reaching the 75 percent goal by 2020. Subsequently, in August 2015, CalRecycle released the AB 341 Report to the Legislature, which identified five priority strategies for achievement of the 75 percent goal: (1) moving organics out of landfills; (2) expanding recycling/ manufacturing infrastructure; (3) exploring new approaches for State and local funding of sustainable waste management programs; (4) promoting State procurement of post-consumer recycled content products; and (5) promoting extended producer responsibility.

In July 2024, CalRecycle published the Baseline Report for the Zero Waste Plan: Report to the California Legislature, which evaluates the effectiveness of existing programs at CalRecycle and identifies changes needed to improve these programs, consistent with the Budget Act of 2023 .71 The report recommends the state do the following to improve current program and reach zero waste: (1) reach and surpass existing waste and emission reduction mandates and goals; (2) identify and address gaps and overlaps to make current waste management systems more sustainable, effective, and cohesive; (3) improve understanding of the full lifecycle of materials management to reduce loss and discourage disposal within a closed loop economy; (4) combat environmental health and justice issues associated with the lifecycle of material production, consumption, and waste generation; (5) maximize environmental, social, and economic benefits of a circular economy; and (6) stimulate growth of the state’s circular economy.

70 CARB. 2025. RE: Withdrawal of Elements of California’s Request for Authorization, Pursuant to Clean Air Act Section 209(e)(2), of the Zero- Emission Truck TRU Requirements of the Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets, and Facilities Where TRUs Operate (TRU ATCM), Docket ID EPA-HQ-OAR2024-0030. January 13. Available at:
https://www.epa.gov/system/files/documents/2025-01/ca-tru-carb-withdrawal-ltr-2025-1-13.pdf. Accessed: June 2025. 71 CalRecycle. 2024. Baseline Report for the Zero Waste Plan: Report to the California Legislature. Jul. Available at:
https://www2.calrecycle.ca.gov/Publications/Details/1741. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-16 Costco Commercial Center Project Partially Recirculated Draft EIR Climate Adaptation Strategy
The 2022 California Climate Adaptation Strategy Implementation Report outlines the State's key climate resilience priorities, includes specific and measurable steps, and serves as a framework for action across sectors and regions in California.
72 The priorities outlined in the Strategy are as follows: 1) Strengthen Protections for Climate Vulnerable Communities, 2) Bolster Public Health and Safety in Light of Increasing Climate Risks, 3) Build a Climate Resilient Economy, 4) Accelerate Nature-Based Climate Solutions and Strengthen Climate Resilience of Natural Systems, 5) Make Decisions based on the Best Available Climate Science, and 6) Partner and Collaborate to Leverage Resources.

The next iteration of the California Climate Adaptation Strategy is already underway, with a draft available for review (the period for public comments closed on July 12, 2024). 73 LOCAL
San Joaquin Valley Air Pollution Control District
The San Joaquin Valley Air Pollution Control District (SJVAPCD) is the primary agency responsible for addressing air quality concerns in Fresno County. Its role is discussed further in Section 3.3, “Air Quality,” of the 2024 EIR. SJVAPCD also recommends methods for analyzing project-generated GHGs in CEQA analyses and offers multiple potential GHG reduction measures for land use development projects. SJVAPCD developed thresholds of significance to provide a uniform scale to measure the significance of GHG emissions from land use and stationary source projects in compliance with CEQA and AB 32.74 SJVAPCD’s goals in developing GHG thresholds include ease of implementation, use of standard analysis tools, and emissions mitigation consistent with AB 32. However, SJVAPCD has not developed new thresholds since the passage of SB 32, which mandates a statewide emissions target of 40 percent below 1990 levels by 2030.

City of Fresno General Plan
The current City of Fresno General Plan, adopted originally in 2014, has a Resource Conservation and Resilience section that addresses both air quality and GHG emissions. The City’s greenhouse gas reduction plan (GHGRP) adopted in 2014 lists out General Plan policies that align with the strategies of the GHGRP. These General Plan policies are listed below, and a discussion on whether the project conflicts with any of these policies is described in detail in the “Environmental Impacts and Mitigation Measures” section.  Policy RC‐2‐a: Link Land Use to Transportation. Promote mixed‐use, higher density infill development in multi‐ modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher‐intensity development. Discourage investment in infrastructure that would not meet these criteria.
 Policy UF‐1‐c: Legible City Structure. Focus integrated and ongoing planning efforts to achieve an identifiable city structure, comprised of a concentration of buildings, people, and pedestrian‐oriented activity in Downtown; along a small number of prominent east west and north‐south transit‐oriented, mixed‐use corridors with distinctive and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi‐purpose trails and tree lined bike lanes and streets.  Policy UF‐12‐b: Activity Centers. Mixed‐use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include Chapter 3: Urban Form, Land Use, and Design commercial areas; employment centers; schools; compact residential development; religious

72 California Natural Resources Agency. 2022. California Climate Adaptation Strategy: 2022 Implementation Report. Available at:
https://climateresilience.ca.gov/overview/docs/20240405-Climate_Adpatation_Strategy_Report_2023.pdf. Accessed: June 2025. 73 California Natural Resources Agency. 2024. Draft California Climate Adaptation Strategy. May. Available at:
https://climateresilience.ca.gov/overview/docs/20240514-Draft_CA_Climate_Adaptation_Strategy_2024.pdf. Accessed: June 2025. 74 San Joaquin Valley Air Pollution Control District. 2009. Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA. December. Available at: https://www.valleyair.org/media/dnsnicdv/3-ccap-final-lu-guidance-dec-17-2009.pdf. Accessed:

June 2025.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-17 institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place.
 Policy LU‐2‐a: Infill Development and Redevelopment. Promote development of vacant, underdeveloped, and redevelopable land uses within the City Limits where urban services are available by establishing and implementing supportive regulations and programs.
 Policy LU‐2‐b: Infill Development for Affordable Housing. Consider a priority infill incentive program for residential infill development of existing vacant lots and underutilized sites within the City as a strategy to help to meet the affordable housing needs of the community.
 Policy LU‐3‐b: Mixed‐Use Urban Corridors that Connect the Downtown Planning Area. Support the development of mixed‐use urban corridors that connect the Downtown Planning Area with the greater Fresno‐Clovis Metropolitan Area with functional, enduring, and desirable urban qualities along the Blackstone Avenue, Shaw Avenue, California Avenue, and Ventura Avenue/Kings Canyon corridors, as shown on Figure LU‐1: General Plan Land Use Diagram.
 Policy LU‐3‐c: Zoning for High Density on Major Transit Corridors. Encourage adoption of supportive zoning regulations for compact development along BRT corridors leading to the Downtown Core that will not diminish long‐term growth and development potential for Downtown.  Policy LU‐5‐f: High Density Residential Uses. Promote high‐density residential uses to support Activity Centers and BRT corridors, affordable housing and walkable access to transit stops.  Policy RC‐2‐b: Provide Infrastructure for Mixed‐Use and Infill. Promote investment in the public infrastructure needed to allow mixed‐use and denser infill development to occur in targeted locations, such as expanded water and wastewater conveyance systems, complete streetscapes, parks and open space amenities, and trails.

Discourage investment in infrastructure that would not meet these criteria.  Policy UF‐12‐d: Appropriate Mixed‐Use. Facilitate the development of vertical and horizontal mixed‐uses to blend residential, commercial, and public land uses on one or adjacent sites. Ensure land use compatibility between mixed‐use districts in Activity Centers and the surrounding residential neighborhoods.  Policy UF‐12‐f: Mixed‐Use in Activity Centers. Update the Development Code to include use regulations and standards to allow for mixed uses and shared parking facilities, including multi‐story and underground parking facilities, within Activity Centers.
 Policy UF‐12‐e: Access to Activity Centers. Promote adoption and implement standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers.  Policy UF‐14‐a: Design Guidelines for Walkability. Use design guidelines and standards for a walkable and pedestrian‐scaled environment with a network of streets and connections for pedestrians and bicyclists, as well as transit and autos.
 Policy UF‐14‐b: Local Street Connectivity. Design local roadways to connect throughout neighborhoods and large private developments with adjacent major streets and pathways of existing adjacent development. Create access for pedestrians and bicycles where a local street must dead end or be designed as a cul‐de‐sac to adjoining uses that provide services, shopping, and connecting pathways for access to the greater community area.  Policy UF‐14‐c: Block Length. Create development standards that provide desired and maximum block lengths in residential, retail, and mixed‐use districts order to enhanced walkability.  Policy D‐3‐c: Local Streets as Urban Parkways. Develop local streets as “urban parkways,” where appropriate, with landscaping and pedestrian spaces.
 Policy D‐4‐b: Incentives for Pedestrian‐Oriented Anchor Retail. Consider adopting and implementing incentives for new pedestrian‐friendly anchor retail at intersections within Activity Centers and along corridors to attract retail clientele and maximize foot traffic.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-18 Costco Commercial Center Project Partially Recirculated Draft EIR  Policy MT‐1‐h: Update Standards for Complete Streets. Update the City’s Engineering and Street Design Standards to ensure that roadway and streetscape design specifications reflect the Complete Streets concept, while also addressing the needs of through traffic, transit stops, bus turnouts, passenger loading needs, bike lanes, and short and long‐term parking.
 Policy UF‐12‐a: BRT Corridors. Design land uses and integrate development site plans along BRT corridors, with transit‐oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops.
 Policy MT‐8‐a: Street Design Coordinated with Transit. Coordinate the planning, design, and construction of the major street network with transit operators to facilitate efficient direct transit routing throughout the Planning Area.
 Policy MT‐8‐b: Transit Serving Residential and Employment Nodes. Identify the location of current and future residential and employment concentrations and Activity Centers throughout the transit service area in order to facilitate planning and implementation of optimal transit services for these uses. Work with California State University, Fresno to determine locations within the campus core for bus stops.  Policy MT‐8‐g: High Speed Train. If the State moves forward with HST, ensure it is constructed through Fresno in a manner that minimizes impacts to surrounding property owners and creates the most opportunity for redevelopment around the HST station.
 Policy MT‐4‐a: Bicycle, Pedestrian and Trails Master Plan. To the extent consistent with this General Plan, continue to implement and periodically update the Bicycle, Pedestrian, and Trails Master Plan to meet State standards and requirements for recommended improvements and funding proposals as determined appropriate and feasible.  Policy MT‐4‐b: Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right‐of-way and that necessary improvements are constructed to implement the planned bikeway system shown on Figure MT‐2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right‐of‐way is available.
 Policy MT‐4‐c: Bikeway Linkages. Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible.  Policy MT‐5‐a: Sidewalk Development. Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in existing neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes.  Policy MT‐6‐a: Link Residences to Destinations. Design a pedestrian and bicycle path network that links residential areas with Activity Centers, such as parks and recreational facilities, educational institutions, employment centers, cultural sites, and other focal points of the city environment.  Policy MT‐6‐g: Path and Trail Development in Subdivisions. Require all subdivision maps to incorporate planned multi‐purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case‐by‐case determinations as a condition of tentative map approval.  Policy POSS‐7‐h: Interlink City and San Joaquin River Parkway Trail Networks. Strive to connect the parkway trail network to other trails in the vicinity, in order to create a community and regional trail system that offers a variety of different route combinations and enhances public access to the parkway.  Policy MT‐10‐c: Transportation Demand Management Guidelines. Establish transportation demand management guidelines to allow for reduced off‐street parking requirements.  Policy MT‐10‐a: Updating Parking Standards. Update off‐street parking standards to reflect the context and location within activity areas of multiple uses and reductions appropriate for mixed residential and non‐ residential uses and proximity to existing or planned transit service.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-19  Policy MT‐10‐b: Shared Parking. Establish a strategy to promote the sharing of excess parking between uses within Activity Centers and BRT corridors, including specific provisions for this in the Development Code.  Policy MT‐10‐d: Parking Maximums. Explore maximum off‐street parking limits within Activity Centers proximate to BRT corridors, if such an Activity Center is determined compatible with promotion of a healthy and vigorous business environment.
 Policy MT‐10‐f: Parking Benefit Districts. Establish parking benefit districts to fund consolidated public parking where supported by local businesses.
 Policy RC‐8‐j: Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.
 Policy RC‐8‐a: Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations.  Policy RC‐8‐b: Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and nonresidential electricity use to 2,700 kWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost‐effective savings.  Policy RC‐8‐c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by fifteen percent.  Policy RC‐8‐d: Incentives. Establish an incentive program for residential developers who commit to building all of their homes to ENERGY STAR performance guidelines.
 Policy RC‐8‐e: Energy Use Disclosure. Promote compliance with State law mandating disclosure of a building’s energy data and rating of the previous year to prospective buyers and lessees of the entire building or lenders financing the entire building.
 Policy RC-7-i: PACE Financing. Develop a residential Property Assessed Clean Energy (PACE) program, if it is determined to be a feasible option, to help finance water efficiency and energy efficiency upgrades for property owners.
 Policy RC‐8‐h: Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over‐the‐counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved.  Policy RC‐6‐d: Recycled Water. Prepare, adopt, and implement a City of Fresno Recycled Water Master Plan.  Policy RC‐7‐a: Water Conservation Program and 2035 Target. Maintain a comprehensive conservation program that reduces per capita water usage in the city’s water service area to 243 gallons per capita per day (gpcd) by 2020 and 190 gpcd by 2035, by adopting conservation standards and implementing a program of incentives, design and operation standards, and user fees.
 Support programs that result in decreased water demand, such as landscaping standards that require drought
-t
olerant plants, rebates for water conserving devices and systems, turf replacement, xeriscape landscape for new homes, irrigation controllers, commercial/industrial/institutional water conserving programs, prioritized leak detection program, complete water system audit, landscape water audit and budget program, and retrofit upon resale ordinance.
 I
mplement the U.S. Bureau of Reclamation Best Management Practices for water conservation as necessary to maintain the City’s surface water entitlements.
 Adopt and implement policies in the event an artificial lake is proposed for development.  Work cooperatively toward effective uniform water conservation measures that would apply throughout the Planning Area.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-20 Costco Commercial Center Project Partially Recirculated Draft EIR  Expand efforts to educate the public about water supply issues and water conservation techniques.  Policy RC‐7‐d: Update Standards for New Development. Continue to refine water saving and conservation standards for new development.
 Policy RC‐7‐f: Implementation and Update Conservation Program. Continue to implement the City of Fresno Water Conservation Program, as may be updated, and periodically update restrictions on water uses, such as lawn and landscape watering and the filling of fountains and swimming pools, and penalties for violations.

Evaluate the feasibility of a 2035 conservation target of 190 gpcd in the next comprehensive update of the City’s Water Conservation Program.
 Policy RC‐7‐h: Landscape Water Conservation Standards. Refine landscape water conservation standards that will apply to new development installed landscapes, building on the State Model Water Efficient Landscape Ordinance and other State regulations.
 Evaluate and apply, as appropriate, augmented xeriscape, “water‐wise,” and “green gardening” practices to be implemented in public and private landscaping design and maintenance.  Facilitate implementation of the State’s Water Efficient Landscape Ordinance by developing alternative compliance measures that are easy to understand and observe.  Policy PU‐9‐a: New Techniques. Continue to collaborate affected stakeholders and partners to identify and support programs and new techniques of solid waste disposal, such as recycling, composting, waste to energy technology, and waste separation, to reduce the volume and toxicity of solid wastes that must be sent to landfill facilities.  Policy PU‐9‐b: Compliance with State Law. Continue to pursue programs to maintain conformance with the Solid Waste Management Act of 1989 or as otherwise required by law and mandated diversion goals.  Policy RC‐11‐a: Waste Reduction Strategies. Maintain current targets for recycling and re‐use of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
 Continue to require recyclable material collection and storage areas in all residential development.  Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated.  Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste.
 Provide recycling canisters and collection in public areas where trash cans are also provided.  Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations.
 Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMax (California Materials Exchange) program.  Evaluate the feasibility of a residential, restaurant and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material.
 Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs.  Expand yard waste collection to divert compostable waste from landfills.  Study the feasibility and cost‐benefit analysis of a municipal composting program to collect and compost food and yard waste, using the resulting compost matter for City park and median maintenance.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-21  Policy RC‐4‐i: Methane Capture. Continue to pursue opportunities to reduce air pollution by using methane gas from the old City landfill and the City’s wastewater treatment process.  Policy RC‐11‐b: Zero Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal.
 Policy PU‐7‐a: Reduce Wastewater. Identify and consider implementing water conservation standards and other programs and policies, as determined appropriate, to reduce wastewater flows.  Policy PU‐7‐d: Wastewater Recycling. Pursue the development of a recycled water system and the expansion of beneficial wastewater recycling opportunities, including a timely technical, practicable, and institutional evaluation of treatment, facility siting, and water exchange elements.  Policy RC‐7‐g: Educate on State Requirements. Educate the residents and businesses of Fresno on the requirements of the California Water Conservation Act of 2009.  Policy RC‐8‐k: Energy Efficiency Education. Provide long‐term and ongoing education of homeowners and businesses as to the value of energy efficiency and the need to upgrade existing structures on the regular basis as technology improves and structures age.
 Policy RC‐7‐c: Best Practices for Conservation. Require all City facilities and all new private development to follow U.S. Bureau of Reclamation Best Management Practices for water conservation, as warranted and appropriate.  Policy RC‐7‐e: Retrofit City Facilities, and Consider Incentives Programs for to Encourage Retrofitting of Other Existing Public and Private Residential and Non‐Residential Facilities and Sites. Reduce water use in municipal buildings and City operations by developing a schedule and budget for the retrofit of existing municipal buildings with water conservation features, such as auto shut‐off faucets and water saving irrigation systems.

Prepare a comprehensive incentive program for other existing public and private residential and non‐residential buildings and irrigation systems.
 Policy RC‐8‐f: City Heating and Cooling. Reduce energy use at City facilities by updating heating and cooling equipment and installing “smart lighting” where feasible and economically viable.  Policy RC‐8‐g: Revolving Energy Fund. Create a City Energy Fund which uses first year savings and rebates from completed City‐owned energy efficiency projects to provide resources for additional energy projects. Dedicate this revolving fund to the sole use of energy efficiency projects that will pay back into the fund.  Policy POSS‐1‐g: Regional Urban Forest. Maintain and implement incrementally, through new development projects, additions to Fresno’s regional urban forest to delineate corridors and the boundaries of urban areas, and to provide tree canopy for bike lanes, sidewalks, parking lots, and trails.

City of Fresno Climate Action Plan
The City adopted its first GHGRP in 2014 in connection with the certification of the Master Environmental Impact Report for the City’s 2014 General Plan.75 The City updated its GHGRP in 2021 concurrently with its certification of the Program Environmental Impact Report (PEIR) for the City’s 2014 General Plan.

As explained in Chapter 1, “Introduction,” of this PR-DEIR, in 2024 the Fifth District Court of Appeal directed that the City be compelled to set aside its approval of the PEIR, including the 2021 GHGRP. The City complied with this direction and adopted Resolution No. 2025-69 on March 13, 2025, which vacated its approval of the 2021 GHGRP and explained that the 2014 GHGRP is now the GHGRP for the City.

The 2014 GHGRP outlines comprehensive development strategies from the General Plan to reduce GHG from all sources within the City’s ability to control or influence. The 2014 GHGRP outlines criteria for individual development projects to qualify for CEQA streamlining and to demonstrate that a project will not result in significant GHG impacts.

The 2014 GHGRP also collates and lists all pertinent General Plan policies related to GHG emissions and strategies.

75 City of Fresno. 2014. General Plan and Development Code Update – Greenhouse Gas Reduction Plan. July. Available here:
https://www.fresno.gov/wp-content/uploads/2023/03/F-2-Greenhouse-Gas-Reduction-Plan.pdf. Accessed: August 2025.

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3.7-22 Costco Commercial Center Project Partially Recirculated Draft EIR Fresno Council of Governments Regional Plans and Strategies Regional Transportation Plan/Sustainable Communities Strategy As described above, SB 375 requires Fresno COG to incorporate an SCS into its RTP that achieves the GHG emission reduction targets set by CARB. Fresno COG’s SCS was first included in the 2014 RTP/SCS, which was adopted by Fresno COG in June 2014. The original plan has since been superseded by the RTP/SCSs adopted by Fresno COG in July 2018, and more recently in July 2022.

In general, the goals and policies of the SCS are to improve mobility, accessibility, reliability, efficiency, livability, sustainability, and equity. The RTP/SCS adopted by Fresno COG is expected to reduce per capita passenger vehicle greenhouse gas emissions by 6 percent by 2020 and by 13 percent by 2035, relative to 2005 baseline levels.

In July 2018, CARB accepted Fresno COG’s determination that the 2018 RT/SCS would meet the region’s GHG reduction targets per Government Code Section 65080(b)(2)(J)(ii), as memorialized in CARB’s Resolution 2018-26.76 As of August 2025, CARB has not yet performed this review of the 2022 Fresno COG RTP/SCS.77 Regional Climate Action Plan: Priority Climate Action Plan and Comprehensive Climate Action Plan The EPA’s Climate Pollution Reduction Grants program provides grants to states, local governments, tribes, and territories to develop and implement ambitious plans for reducing GHG emissions and other harmful air pollution.78 The program provides both noncompetitive planning grants and competitive implementation grants.79 To obtain the competitive implementation grant, the Fresno COG must conduct a comprehensive climate action planning process and prepare a Regional Climate Action Plan for the Fresno County region.80 The Regional Climate Action Plan will cover the 15 incorporated cities in Fresno County and the unincorporated Fresno County areas. The Priority Climate Action Plan (PCAP) is the first component of the Regional Climate Action Plan and it includes a GHG inventory, identification and quantification of priority GHG emissions reduction measures, a benefit analysis for low- income and disadvantaged communities, and identification of implementation authorities. The Final PCAP81 was approved by the Fresno COG Policy Board on February 29, 2024 and was successfully submitted to the EPA.82 The Comprehensive Climate Action Plan (CCAP) will be the second component of the Regional Climate Action Plan. The CCAP will aim to expand on the foundational work established in the PCAP by creating a roadmap outlining the actions to reduce GHG emissions and achieve climate goals, encompassing sectors such as energy, transportation, waste, and water, and reflecting local contexts. Extensive public outreach efforts will be conducted to support the development of the CCAP to ensure that the CCAP reflects the priorities of the local community. As of October 2025, the draft CCAP has been published for public review and has not been adopted. 83 76 CARB. Executive Order G-19-092. Fresno Council of Governments (FCOG) 2018 Sustainable Communities Strategy CARB Acceptance of GHG Quantification Determination. Available at: https://ww2.arb.ca.gov/sites/default/files/2020- 06/FCOG_2018_SCS_ARB_Acceptance_of_GHG_Quantification_Determination_Executive_Order.pdf. Accessed: August 2025. 77 California Air Resources Board. Fresno Council of Governments (FCOG) - Sustainable Communities and Climate Protection Program: Regional Plans & Evaluations. Available here: https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plans- evaluations/fresno-council. Accessed: August 2025.
78 EPA. 2025. Climate Pollution Reduction Grants. February 13. Available at: https://www.epa.gov/inflation-reduction-act/climate-pollution- reduction-grants. Accessed: October 2025.
79 Ibid.
80 Fresno COG. Climate Action Planning. Available at: https://www.fresnocog.org/climate-action-planning-2/. Accessed: August 2025. 81 Fresno COG. 2024. Priority Climate Action Plan. March/ Available at: https://www.fresnocog.org/wp-content/uploads/2024/07/Fresno-COG- PCAP_030124_-FINAL-reduced-size-file.pdf. Accessed: August 2025. 82 Fresno COG. Climate Pollution Reduction Grants - CCAP. Available at: https://publicinput.com/fresnocprg. Accessed: August 2025. 83 Fresno COG. 2025. Comprehensive Climate Action Plan: Public Review Draft. October. Available at:
https://www.dropbox.com/scl/fo/huqscjmidukx2e9v1gtn0/AHuk7FJ74CHAZCqmJe9lK- Q?e=3&preview=Fresno+County+CCAP+101025.docx.pdf&rlkey=ndqti0k2n7wf1lng4d1kmcf45&st=5vxf3zi1&dl=0. Accessed: October 2025.

Ascent Greenhouse Gas Emissions and Climate Change
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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-23

3.7.2 Environmental Setting
Certain gases in the earth’s atmosphere, classified as GHGs, play a critical role in determining the earth’s surface temperature. Solar radiation enters the atmosphere from space. A portion of the radiation is absorbed by the earth’s surface, and a smaller portion of this radiation is reflected toward space. The absorbed radiation is then emitted from the earth as low-frequency infrared radiation. Most solar radiation passes through GHGs; however, infrared radiation is absorbed by these gases. As a result, radiation that otherwise would have escaped back into space is instead “trapped,” resulting in a warming of the atmosphere. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate on earth.

Prominent GHGs contributing to the greenhouse effect are CO 2, CH4, N2O, HFCs, and PFCs, and SF6. Human-caused
emissions of these GHGs in excess of natural ambient concentrations are found to be responsible for intensifying the greenhouse effect and leading to a trend of unnatural warming of the earth’s climate, known as global climate change or global warming. The Intergovernmental Panel on Climate Change (IPCC) prepares comprehensive Assessment Reports on the causes, potential impacts, and response options regarding climate change.84 The Sixth Assessment Report contains the IPCC’s strongest warnings to date on the causes and impacts of climate change.

Importantly, the report notes that, in terms of solutions, “We need transformational change operating on processes and behaviors at all levels: individual, communities, business, institutions, and governments. We must redefine our way of life and consumption.”
Climate change is a global problem. GHGs are global pollutants, unlike criteria air pollutants and toxic air contaminants, which are pollutants of regional and local concern. Whereas most pollutants with localized air quality effects have relatively short atmospheric lifetimes (approximately 1 day), GHGs have long atmospheric lifetimes (1 year to several thousand years). GHGs persist in the atmosphere long enough to be dispersed around the globe. Although the lifetime of any GHG molecule depends on multiple variables and cannot be determined with any certainty, it is understood that more CO
2 is emitted into the atmosphere than is sequestered by ocean uptake, vegetation, and other forms of sequestration. Of the total annual human-caused CO2 emissions, approximately 55 percent are estimated to be sequestered through ocean and land uptake every year, averaged over the last 50 years, whereas the remaining 45 percent of human-caused CO2 emissions remain stored in the atmosphere.85 The quantity of GHGs in the atmosphere responsible for climate change is not precisely known, but it is considered to be enormous. No single project alone would measurably contribute to an incremental change in the global average temperature or to global or local climates or microclimates. SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI) observes that: “It is widely recognized that no single project could generate sufficient GHG emissions to noticeably change global climate temperature. However, the combination of GHG emissions from past, present, and future projects could contribute substantially to global climate change. Thus, project specific GHG emissions should be evaluated in terms of whether or not they would result in a cumulatively significant impact on global climate change.” From the standpoint of CEQA, GHG impacts relative to global climate change are inherently cumulative as no one project is responsible for the global impact of climate change; rather, the emissions of all past, present, and future projects determine the degree of climate change severity.

EFFECTS OF CLIMATE CHANGE ON THE ENVIRONMENT
The global average temperature is expected to increase by 3 to 7 degrees Fahrenheit (°F) by the end of the century, depending on future GHG emission scenarios.86 According to California’s Fourth Climate Change Assessment,

84 Intergovernmental Panel on Climate Change. Reports. Available at: https://www.ipcc.ch/reports/. Accessed: October 2025. 85 Intergovernmental Panel on Climate Change. 2013. Chapter 6, Carbon and Other Biogeochemical Cycles. Pages 465–570 in Climate Change 2013: The Physical Science Basis. Working Group I Contribution to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Available at: http://www.climatechange2013.org/images/report/WG1AR5_ALL_FINAL.pdf. Accessed: August 2025. 86 Intergovernmental Panel on Climate Change. 2007. AR4 Climate Change 2007: The Physical Science Basis. Available at:
https://www.ipcc.ch/report/ar4/wg1/. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
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3.7-24 Costco Commercial Center Project Partially Recirculated Draft EIR depending on future GHG emissions scenarios, average annual maximum daily temperatures in California are projected to increase between 3.6 and 5.8°F by 2050 and by 5.6 to 8.8°F by 2100.87 Other environmental resources could be indirectly affected by the accumulation of GHG emissions and resulting rise in global average temperature. In recent years, California has been marked by extreme weather and its effects. Climate model projections for California demonstrate that impacts will vary throughout the state and show a tendency for the northern part of the state to become wetter and the southern portion of California to become drier.88 According to California Natural Resources Agency’s (CNRA’s) report, Safeguarding California Plan: 2018 Update,89 California experienced the driest 4-year statewide precipitation on record in California from 2012 through 2015; the warmest years on average in 2014, 2015, and 2016; and the smallest and second smallest Sierra snowpack on record in 2015 and 2014. Climate model projections included in California’s Fourth Climate Change Assessment demonstrate that seasonal summer dryness in California may be prolonged due to earlier spring soil drying and would last longer into the fall and winter rainy season. Increases in temperature are also predicted to result in changes to California’s snowpack. Based on climate model projections, the mean snow water equivalent, a common measurement which indicates the amount of water contained within snowpack, in California is anticipated to decline to two-thirds of its historic average by 2050 and between less than half and less than one-third of historic average by 2100, depending on future emissions scenarios. 90,91,92
Climate model projections demonstrate that California will experience variation in precipitation patterns as well. The Northern Sierra Nevada range experienced its wettest year on record in 2016.93 As temperatures increase, the increase in precipitation falling as rain rather than snow also could lead to increased potential for floods because water that would normally be held in the snowpack of the Sierra Nevada and Cascade mountains until spring will flow into the Central Valley concurrently with winter rainstorm events. This scenario will place more pressure on California’s levee/flood control system.94 As the climate continues to warm, extreme precipitation events in California will increase and could, subsequently, increase the probability of “mega-flood” events.95 Climate change is also projected to result in tertiary impacts on energy infrastructure throughout California. Changes in temperature, precipitation patterns, extreme weather events, and sea-level rise have the potential to affect and decrease the efficiency of thermal power plants and substations, decrease the capacity of transmission lines, disrupt electrical demand, and threaten energy infrastructure with the increased risk of flooding. 96 According to California’s Fourth Climate Change Assessment, climate change will create impacts on the State’s transportation network that will have ”ripple effects” including direct and indirect impacts on inter-dependent infrastructure networks as well as negative impacts on the economy. Without appropriate adaptation strategies for roadway materials (i.e., asphalt and pavement), researchers estimate that the median total cost to California for 2040-

87 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment. August. Available at: https://www.climateassessment.ca.gov/. Accessed: August 2025. 88 Pierce, D. W., J. F. Kalansky, and D. R. Cayan. 2018. Climate, Drought, and Sea Level Rise Scenarios for California’s Fourth Climate Change Assessment. California Energy Commission. Available at: https://www.energy.ca.gov/sites/default/files/2019-11/Projections_CCCA4-CEC-2018- 006_ADA.pdf. Accessed: August 2025.
89 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf. Accessed: August 2025. 90 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment. August. Available at: https://www.climateassessment.ca.gov/. Accessed: August 2025. 91 California Energy Commission. 2018. 2019 Building Energy Efficiency Standards: Frequently Asked Questions. March. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf. Accessed: August 2025. 92 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf. Accessed: August 2025. 93 Ibid.
94 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf. Accessed: August 2025. 95 Polade, S. D., A. Gershunov, D. R. Cayan, M. D. Dettinger, and D. W. Pierce. 2017. Precipitation in a Warming World: Assessing Projected Hydro- Climate Changes in California and Other Mediterranean Climate Regions. Scientific Reports 7, article number 10783. Available at:
https://www.nature.com/articles/s41598-017-11285-y. Accessed: August 2025. 96 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf . Accessed: August 2025.

Ascent Greenhouse Gas Emissions and Climate Change
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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-25 2070 will be between $1 billion and $1.25 billion.97,98,99 The California Department of Transportation (Caltrans) owns and operates more than 51,000 miles along 265 highways, as well as three of the busiest passenger rail lines in the nation.

Sea level rise, storm surge, and coastal erosion are imminent threats to highways, roads, bridge supports, airports, transit systems and rail lines near sea level and seaports. Shifting precipitation patterns, increased temperatures, wildfires, and increased frequency in extreme weather events also threaten transportation systems across the state.

Temperature extremes and increased precipitation can increase the risk of road and railroad track failure, decrease transportation safety, and increase maintenance costs.
100 Modeling for flood events in California demonstrates that approximately 370 miles of highways are susceptible to flooding in a 100-year storm event by the year 2100.101,102,103 Water availability and changing temperatures affect the prevalence of pests, disease, and species, which will directly impact crop development, forest health, and livestock production. Other environmental concerns include decline in water quality, groundwater security, and soil health.104 Vulnerabilities of water resources also include risks to degradation of watersheds, alteration of ecosystems and loss of habitat.105,106,107 California’s Fourth Climate Change Assessment also identifies the impacts climate change will have on public health and social systems. Average temperature increases in California are estimated to have impacts on human mortality, with 6,700 to 11,300 additional annual deaths in 2050, depending on higher or lower emissions scenarios.108 Studies have also shown that impacts from climate change can also have indirect impacts on public health, such as increased vector-borne diseases, and stress and mental trauma due to extreme events, economic disruptions, and residential displacement.109,110.111
The CNRA released an updated 2021 Strategy, which builds upon the successful elements of the previous strategies.112 The updates:

1. organize the State’s climate adaptation efforts around six outcome-based resilience priorities, and increases the ability to measure progress;

2. break down siloes and unifies collective climate adaptation efforts across all sectors and regions; and

3. make it easier for Californians to understand and contribute to California’s climate resilience agenda.

97 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment. August. Available at: https://www.climateassessment.ca.gov/ . Accessed: August 2025. 98 California Energy Commission. 2018. 2019 Building Energy Efficiency Standards: Frequently Asked Questions. March. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf. Accessed: August 2025. 99 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf . Accessed: August 2025. 100 Ibid.
101 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment. August. Available at: https://www.climateassessment.ca.gov/ . Accessed: August 2025. 102 California Energy Commission. 2018. 2019 Building Energy Efficiency Standards: Frequently Asked Questions. March. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf. Accessed: August 2025. 103 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf. Accessed: August 2025. 104 Ibid.
105 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment. August. Available at: https://www.climateassessment.ca.gov/. Accessed: August 2025. 106 California Energy Commission. 2018. 2019 Building Energy Efficiency Standards: Frequently Asked Questions. March. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf. Accessed: August 2025. 107 California Natural Resources Agency. 2018. Safeguarding California Plan: 2018 Update. January. Available at:
http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan-2018-update.pdf. Accessed: August 2025. 108 Ostro, Bart, Stephen Rauch, and Shelley Green. 2011. Quantifying the Health Impacts of Future Changes in Temperature in California. Available at: https://www.sciencedirect.com/science/article/abs/pii/S001393511100212X. Accessed: August 2025. 109 Gould, S., and K. Dervin. 2012. Climate Action for Health: Integrating Public Health into Climate Action Planning. California Department of Public Health. Accessed: August 2025.
110 McMichael, A. J., and E. Lindgren. 2011. Climate Change: Present and Future Risks to Health, and Necessary Responses. Journal of Internal Medicine 270(5):401–413. Accessed: August 2025.
111 US Global Change Research Program. 2016. The Impacts of Climate Change on Human Health in the United States: A Scientific Ass essment.

Accessed: August 2025.
112 California Natural Resources Agency. 2021. Available at: https://climateresilience.ca.gov/. Accessed: August 2025.

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3.7-26 Costco Commercial Center Project Partially Recirculated Draft EIR The latest implementation report was released in 2023, which highlighted the ongoing occurrences of climate change, which included higher temperatures and intensified drought, more intense precipitation events, marine heatwaves and harmful algal blooms, sea level rise, and unprecedented wildfire events.113

3.7.3 Statewide and City of Fresno GHG Emissions
As discussed previously, GHG emissions are attributable in large part to human activities. The total GHG inventory for California in 2022 was 371.1 million metric tons of carbon dioxide equivalent (MMTCO2e).114 Table 3.7 -1 summarizes the statewide GHG inventory for California by percentage. As shown in Table 3.7-1, transportation, industry, and in-state electricity generation are the largest GHG emission sectors.

Emissions of CO2 are byproducts of fossil fuel combustion. Methane, a highly potent GHG, primarily results from off- gassing (the release of chemicals from nonmetallic substances under ambient or greater pressure conditions) and is largely associated with agricultural practices, landfills, and forest fires. Nitrous oxide is also largely attributable to agricultural practices and soil management. CO2 sinks, or reservoirs, include vegetation and the ocean, which absorb CO2 through sequestration and dissolution (CO2 dissolving into the water) and are two of the most common processes for removing CO2 from the atmosphere.

Table 3.7-1 Statewide GHG Emissions by Economic Sector
Sector MMTCO2e Percent
Transportation 145 39%
Industrial 85 23%
Electricity (in state) 41 11%
Residential 30 8%
Agriculture 30 8%
Commercial 22 6%
Electricity (Imports) 19 5%
Total 371.11 100%
Note: MMTCO2e = million metric tons of carbon dioxide equivalent. 1 Numbers do not sum to total because of rounding of whole numbers.

Source: CARB 2022 GHG Emissions by Main Economic Sector. Available here: https://ww2.arb.ca.gov/ghg-inventory-graphs. Accessed: August 2025.

A GHG inventory and emissions forecast for the geographic area within the City of Fresno is provided in the City’s 2014 GHGRP and summarized in Table 3.7-2.115 These emissions inventories demonstrate the emissions calculated at the time the GHGRP was prepared, including forecasts if no other statewide or local measures and strategies were adopted and implemented after the GHGRP was adopted in 2014. Similar to statewide emissions trends, the transportation sector was estimated to comprise the greatest GHG emission sector in the city.

In September 2018, ICLEI Local Governments for Sustainability developed an inventory update for the baseline year of 2016 for the City through the Statewide Energy Efficiency Collaborative.116 This inventory is more recent and captures the GHG reductions from statewide and local measures since 2010 and, therefore, better reflects the current GHG emission levels in the city. The 2016 inventory update also includes agriculture and industrial energy sectors, which are additional to the 2010 baseline inventory. The GHG inventory and emissions forecast for the City of Fresno is

113 California Natural Resources Agency. 2023. Implementation Report. Available at: https://climateresilience.ca.gov/overview/docs/20250801- 2023_Climate_Adpatation_Strategy_Implementation_Report.pdf. Accessed: August 2025. 114 CARB. 2022 GHG Emissions by Main Economic Sector. Available here: https://ww2.arb.ca.gov/ghg-inventory-graphs. Accessed: August 2025. 115 The City of Fresno prepared an updated inventory for the 2021 GHGRP. 116UCLEI Local Governments for Sustainability, USA. 2018 (September). City of Fresno Inventory Update: Inventory analysis by ICLEI Local Governments for Sustainability USA through the Statewide Energy Efficiency Collaborative.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-27 summarized in Table 3.7-3. The updated emissions inventory shows a decreasing trend in the City’s emissions compared to that reported in 2014 for the 2010 baseline year.

Table 3.7-2 City of Fresno 2010 Baseline and GHG Emission Projections (in MTCO2e) Sector 2010 2020 2035 2050 2056
Motor vehicles 1,899,799 2,383,023 3,107,859 3,832,694 4,122,629 Electricity – residential 327,813 390,488 469,524 548,921 583,447 Electricity – commercial 361,836 415,012 509,781 626,137 679,888 Natural gas – residential 362,832 476,679 573,160 670,082 712,228 Natural gas – commercial 394,417 514,647 632,169 776,459 843,115 Waste 123,945 147,628 177,508 207,525 220,578
Offroad equipment 1,051 1,138 1,314 1,314 1,314
Ozone depleting substance (ODS) substitutes 273,422 576,784 694,734 812,214 863,300 Total 3,745,116 4,905,399 6,166,049 7,475,346 8,026,499 Notes: Totals may not equal the sum of the numbers because of independent rounding. MTCO2e = metric tons of carbon dioxide equivalent.

Source: City of Fresno Greenhouse Gas Reduction Plan (2014). Available here: https://www.fresno.gov/wp-content/uploads/2023/03/F-2- Greenhouse-Gas-Reduction-Plan.pdf. Accessed: August 2025.

Table 3.7-3 City of Fresno 2016 Baseline GHG Emissions (in MTCO2e) Sector 2016
Transportation (passenger, commercial, and bus gas/diesel) 1,518,997 Commercial Energy (electricity and natural gas) 524,839 Residential Energy (electricity and natural gas) 479,371 Ozone Depleting Substances 251,543
Solid Waste 120,016
Fugitive Emissions (natural gas) 18,588
Industrial Energy 10,055
Off Road Equipment 1,051
Agriculture Energy 20
Total 2,924,484
Notes: Totals may not equal the sum of the numbers because of independent rounding. MTCO2e = metric tons of carbon dioxide equivalent.

Source: ICLEI Local Governments for Sustainability, USA. 2018 (September). City of Fresno Inventory Update: Inventory analysis by ICLE I Local Governments for Sustainability USA through the Statewide Energy Efficiency Collaborative

3.7.4 Environmental Impacts and Mitigation Measures

METHODOLOGY
The following resources were used for this analysis:
 the California Emissions Estimator Model (CalEEMod) 2020.4.0 Computer Program,117

117 California Air Pollution Control Officers Association. 2021. CalEEMod Users Guides. Available at: https://www.aqmd.gov/docs/default- source/caleemod/user-guide-2021/01_user-39-s-guide2020-4-0.pdf. Accessed: August 2025.

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3.7-28 Costco Commercial Center Project Partially Recirculated Draft EIR  SJVAPCD’s Guide to Assessing and Mitigating Air Quality Impacts,118 and  the 2025 Greenhouse Gas Technical Report (Ramboll 2025) (included as Appendix F to this EIR).

Regional and local GHG emissions and associated impacts were estimated in accordance with SJVAPCD- recommended methodologies.

CalEEMod modeling was based on project-specific information (e.g., land use type, construction and operational equipment to be used, trip projections) where available, reasonable assumptions based on typical construction activities, and default values in CalEEMod that are based on the project’s location and land use type. Construction emissions were estimated using an equipment inventory and usage assumptions and on-road vehicle activity provided by the applicant119 and default values in CalEEMod that are based on the project’s location. Construction activities associated with the project would likely require the use of equipment such as excavators, loaders, backhoes, generators, welders, dump trucks, pavers, and cranes. For the purpose of this quantification, it was assumed that construction of the project would begin in May 2023 and end in November 2023. The construction emissions therefore provide a conservative estimate of emissions, as it is expected that the emissions from the off-road and on-road fleet would reduce over time due to the phase-in of newer, more efficient vehicles and equipment and project construction would take place in 2026 at the earliest.

To assess the climate change impacts that would result from operations of the project, trip rate and trip length information based on analyses conducted by Kittelson were used to calculate an estimation of GHGs that would result from both off-site and on-site operational trips.120 The most recent available emissions inventory for Fresno County was derived from EMFAC2021v1.0.2 and applied to CalEEMod to derive the fleet mix for light-duty vehicles used for member vehicles and employee vehicles.121 These trips include worker commute and customer trips to the project site as estimated in the project’s traffic study.122 Market delivery operation (MDO) delivery trucks, fuel delivery trucks, and warehouse delivery trucks were assumed to be diesel-fueled heavy heavy-duty trucks.

Emissions from energy consumption (electricity and natural gas combustion) were estimated using Pacific Gas and El
ectric Company (PG&E) emissions factors applied to the intensities provided for the land use types proposed for the project scaled to PG&E’s requirements to comply with the Renewables Portfolio Standard (RPS). Area-, wastewater-, and solid waste-source emissions were estimated using CalEEMod default values for the proposed land use types (i.e., car wash, commercial center, gas station, and parking lot). Electrical power would be supplied by PG&E and the project will participate in the PG&E “Solar Choice” program, which is PG&E’s program to provide 100 percent renewable electricity to customers. While the anticipated indirect emissions from electricity are expected to be zero due to the project’s participation in the PG&E “Solar Choice” program, the analysis conservatively models GHG emissions based on PG&E’s default utility emission factor.

See Appendix A of this PR-DEIR for a detailed description of modeling assumptions, CalEEMod outputs, and calculations.

THRESHOLDS OF SIGNIFICANCE
State CEQA Guidelines Section 15064 and relevant portions of Appendix G recommend that a lead agency consider a project’s consistency with relevant, adopted plans and any conflicts with applicable regional plans, including plans to reduce GHG emissions. An impact on climate change would be significant if implementation of the project would:
 generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment (“Threshold 1”); or

118 San Joaquin Valley Air Pollution Control District. 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Available at:
https://archive.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF. Accessed: August 2025. 119 Please see the Costco Commercial Center Greenhouse Gas Emissions Technical Appendix Section 2.2.1 for additional details. 120 Please see the Costco Commercial Center Greenhouse Gas Emissions Technical Appendix Section 2.3.2 for additional details. 121 Ibid.
122 Please see the Costco Commercial Center Greenhouse Gas Emissions Technical Appendix Section 2.3.2.1 for additional details.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-29  conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs (“Threshold 2”).

SJVAPCD has adopted guidance documents for assessing and mitigating GHG impacts on global climate change.123 Rather than establishing specific numeric thresholds of significance (as is the case for criteria pollutant emissions), the SJVAPCD guidance utilizes a tiered approach to assess cumulative impacts on global climate change. Notably, the SJVAPCD establishes that a project can demonstrate compliance with an approved GHG emissions reduction program. Furthermore, SJVAPCD’s December 2009 CEQA GHG policies and its 2015 GAMAQI state that a project whose emissions have been reduced or mitigated consistent with the California Global Warming Solutions Act of 2006 (AB 32) should be considered to have a less-than-significant impact on global climate change. The SJVAPCD guidance includes an approach to assess a project against performance-based standards, referred to as Best Performance Standards (BPS), to reduce GHG emissions, and then also an option to assess against a Business-As-Usual (BAU) GHG emissions target. Since the BPS have not yet fully been established, this approach was not used. Furthermore, in the State Supreme Court’s ruling in Center for Biological Diversity v. California Department of Fish and Wildlife and Newhall Land and Farming (2015), 124 the court indicated that a percentage reduction goal must be substantiated based on local conditions to apply to an individual development project. Since the SJVAPCD has not updated its guidance to address the Supreme Court decision, the BAU approach is not relied upon. SJVAPCD has not otherwise adopted a numerical GHG threshold.

The City of Fresno has not developed a quantitative threshold of significance for GHG emissions. As a result of the Fifth District Circuit Court of Appeal’s unpublished August 6, 2024 decision in the South Fresno Community Alliance v.

City of Fresno matter, the City rescinded its approval of the 2021 GHGRP (and the accompanying PEIR), making the City’s 2014 GHGRP the only GHGRP in effect.

In effect, under Resolution 2025-69, the City reverted to the pre-2021 status quo. This makes the City’s 2014 GHGRP its most current and only GHGRP in effect. However, the City’s 2014 GHGRP relies on reduction targets that are now out of date, and therefore the City has determined that is not prudent to rely solely on the currently effective 2014 GHGRP for CEQA streamlining of GHG emissions analysis for individual development projects. The 2014 GHGRP explains:

The State has not adopted comprehensive targets or a new Scoping Plan to address emissions after 2020.  The GHG Plan includes interim targets for later years (2035 and 2050) pending new legislation that sets later targets similar to AB 32 or adoption of a Scoping Plan Update that addresses these years.  Targets after 2020 show the trajectory required to reduce per capita emissions to 80 percent below 1990 by 2050; however, once the State adopts targets for later years, new community targets that match the new state target years will be needed to ensure consistency
In the City of Fresno’s 2014 GHGRP, the City developed GHG policies, and a list of requirements to assist CEQA projects in evaluating significance.

The State of California adopted a new Scoping Plan in 2022 that addresses emissions after 2020. In the 2022 Scoping Plan, CARB set more aggressive GHG reduction targets than those used in the 2014 GHGRP. Therefore, use of the 2014 GHGRP as the sole gauge of project significance would not be consistent with the most recent state guidance and more aggressive GHG reduction strategies.

Accordingly, this PR-DEIR takes a conservative approach of analyzing the project’s GHG emissions in connection with the State of California’s 2022 Scoping Plan, Fresno COG’s 2022 RTP/SCS, and Fresno COG’s PCAP, as well as the policies of the 2014 GHGRP and the pertinent policies of the Fresno General Plan.

This PR-DEIR, relative to Threshold 1, quantifies the project’s GHG emissions during operation and construction for disclosure. In the absence of a numerical GHG significance threshold, the project will be evaluated by whether it would conflict with or impede the ability of the State to meet its GHG reduction goals, consistent with the State Supreme Court’s ruling in Center for Biological Diversity v. California Department of Fish and Wildlife and Newhall

123 San Joaquin Valley Air Pollution Control District. 2009. Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA. December. Available at: https://www.valleyair.org/media/dnsnicdv/3-ccap-final-lu-guidance-dec-17-2009.pdf. Accessed:

June 2025.
124 Center for Biological Diversity v. California Dept. of Fish & Wildlife, 62 Cal. 4th 204 (2015) Greenhouse Gas Emissions and Climate Change Ascent
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3.7-30 Costco Commercial Center Project Partially Recirculated Draft EIR Land and Farming (2015).125 This PR-DEIR, relative to Threshold 2, evaluates whether the project would conflict with applicable plans related to GHG emissions at the state, regional, and local levels.

These analyses include evaluation of the GHG emissions generated by the project’s VMT. As shown in Tables 3.7-2 and 3.7-3, above, mobile source emissions (i.e., transportation emissions from VMT) are a substantial component of the City’s overall GHG inventory and projections. However, there are many other sources of GHG emissions. The City uses VMT as a threshold of significance to evaluate transportation impacts (see Section 3.13, “Transportation and Circulation,” in the 2024 EIR), consistent with CEQA Guidelines Section 15064.3(b). By contrast, CEQA Guidelines Section 15064.4(b) provides lead agencies with guidance to apply discretion in developing thresholds to evaluate GHG emissions impacts. Further, a significant VMT impact does not equate to a significant GHG impact because VMT alone does not account for vehicle characteristics, fuel type, emission standards, and fleet-level standards, all of which directly influence GHG emissions. For example, all-electric vehicles generate VMT while resulting in no tailpipe GHG emissions. Thus, while the GHG analysis does incorporate information regarding VMT, the assessment of GHG impacts is based on the significance thresholds described above (i.e., if the project is found not to conflict with or impede the ability of the state to meet its GHG reduction goals [Threshold 1] and not to conflict with applicable plans related to GHG emissions at the state, regional, and local levels [Threshold 2]).

TOPICS NOT DISCUSSED FURTHER
All issues pertaining to climate change are evaluated in this analysis.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 3.7-1: Generate GHG Emissions That Would Have a Significant Impact on the Environment
While the project would result in an increase in GHG emissions when compared to the existing conditions (i.e., vacant site with no development), the project would not conflict with or impede the state’s ability to meet its GHG reduction goals. Therefore, there is no cumulatively considerable contribution to GHG emissions. This impact would be less than significant.

The project would generate GHG emissions from project construction and operation. Construction-related activities would generate GHG emissions from the use of heavy-duty off-road equipment, materials transport, and worker commutes. Based on modeling conducted for the project, construction is estimated to generate a total of 1,050 MTCO2e. These emissions are amortized over a typical project lifetime of 30 years, which is an industry standard approach, and included in the total emissions evaluated below.126 Operation of the project would also generate GHG emissions from vehicle trips (member vehicles, employee vehicles, and delivery trucks) accessing the project site, on-site natural gas combustion, and solid waste and wastewater generation. While the anticipated indirect emissions from electricity are expected to be zero due to the project’s participation in the PG&E “Solar Choice” program, the analysis also conservatively models GHG emissions based on PG&E’s default utility emission factor. For the first year of operation, the project’s emissions would total 22,428 MTCO2e/year (Table 3.7-4).127

125 Center for Biological Diversity v. California Dept. of Fish & Wildlife, 62 Cal. 4th 204 (2015) 126 This approach to one-time construction GHG emissions is based on the SCAQMD GHG Threshold Working Group Meeting #13 Minutes from August 26, 2009. Available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance- thresholds/year-2008-2009/ghg-meeting-13/ghg-meeting-13-minutes.pdf. Accessed: October 2025. 127 Please see Table 2-7 of the Costco Commercial Center Greenhouse Gas Emissions Technical Appendix for additional details.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-31 Table 3.7-4 Summary of Project GHG Emissions
Emissions Category1 GHG Emissions2 (MT CO2e/yr)
Area Sources 0.02
Energy Usage 334
Mobile3 21,482
Water 38
Waste Disposed 540
Operational Sub-Total 22,393
Construction Amortized4 35
Total5 22,428
1 One-time emissions (i.e., construction) and operational emissions were calculated using CalEEMod. 2 Emissions are presented as CO2e, which includes CO2, CH4, and N2O emissions, weighted by their respective global warming potentials. 3 Total mobile emissions include emissions from on-road vehicles and TRUs. On-road mobile emissions were estimated using CalEEMod default trip lengths, EMFAC2021 emission factors, and project-specific vehicle trip rates provided by Kittelson & Associates. TRU emissions were estimated using OFFROAD2021 emission factors.
4 One-time emissions from construction were amortized over a 30-year period. 5 Sum of annualized one-time emissions and operational emissions.

This quantified inventory is expected to be conservative. While the project does generate an increase in VMT (see Section 3.13, “Transportation and Circulation,” in the 2024 EIR), the VMT analysis does not take into account the Costco trips “replacing” existing trips currently going to other retailers. Furthermore, the project would allow customers to have multiple needs served in one trip, including but not limited to: eye exams, purchase of household goods and groceries, furniture store, appliance store, liquor store, car washes, and refueling at a gas station. Given these factors, it is possible that Costco members make fewer total retail shopping trips in a month or a year when they have the option of shopping at the proposed expanded Costco than they would make if they did not have a Costco nearby. The VMT modeling does not measure the benefit of one Costco trip potentially replacing multiple trips, which makes the quantified inventory conservative.

In the absence of a numerical GHG threshold, the significance of these emissions is judged by whether the project would conflict with or impede the ability of the state to meet its GHG reduction goals. This is evaluated by considering whether the project would conflict with pertinent laws, regulations, and policies adopted to achieve the state’s GHG reduction goals. The project will comport with all applicable laws and regulations discussed above and otherwise enacted to address GHG reduction. These include requirements related to building design, supply of EV charging facilities for customer vehicles, limitations on truck idling times, and purchasing vehicle fleets that meet applicable standards. In addition to legal requirements, as explained above, GHG reduction plans have been adopted at the state, regional, and local levels. The analysis below evaluates whether the project would conflict with the key plans at each level.

Statewide Emissions Reduction Targets (2022 Scoping Plan) The 2022 Scoping Plan has priority GHG reduction strategies that are the focus for the state to achieve its statewide emission reduction targets. The three main priorities areas are “Transportation Electrification,” “VMT Reduction,” and “Building Decarbonization.” These measures represent the core strategies that local jurisdictions in California can implement to reduce GHGs in alignment with State goals.

The project would not conflict with the state’s GHG reduction goals as discussed in the 2022 Scoping Plan. The project would serve the needs of consumers in California and provide an effective and efficient means to shop at the warehouse, fill up a gasoline vehicle, and get a car wash all in the same location. The project’s emissions sources are regulated (and are foreseeably expected to continue to be regulated in the future) in furtherance of the State’s environmental policy objectives. Costco has a focus on sustainability, with specific measures being implemented to manage energy use across its warehouses. Costco continues to improve the design and construction of its buildings, I I
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3.7-32 Costco Commercial Center Project Partially Recirculated Draft EIR as technological advancements in these areas and building materials improve. Improved engineering and design has resulted in the use of less materials than earlier designs. For example, the proposed buildings would be constructed of metal to use the maximum amount of recycled material.

For the purposes of determining whether the project would conflict with the 2022 Scoping Plan, the project features were evaluated against the measures listed in Table 1 from Appendix D: Local Actions of the 2022 Scoping Plan. 128 While not all of these measures are directly applicable to an individual commercial development, the analysis evaluates whether the project would conflict or cause any impairment of such policies.

As demonstrated in Table 3.7-5, the project would not conflict with applicable 2022 Scoping Plan priority strategies for the reduction of GHG emissions.

Table 3.7-5 2022 Scoping Plan Priority GHG Reduction Strategy Consistency Evaluation Summary Priority Areas1 Priority GHG Reduction Strategies1 Does it Conflict? Transportation
Electrification
Convert local government fleets to ZEVs and provide EV
charging at public sites
Does Not Conflict. Although this goal is not the
responsibility of an individual commercial development
project, the project would include 10 DC Fast chargers
and 1 Level 2 charger, which run on 100% clean energy
provided by PG&E and would also provide Costco
members with convenient EV charging at a lower cost.

The total power usage for the system is 1,800 kW, which is greater than both the mandatory requirement (1,172
kW) and the Tier 1 voluntary requirement (1,758 kW) by
the CalGreen Building Code 2025.

Create a jurisdiction-specific ZEV ecosystem to support deployment of ZEVs statewide (such as building standards that exceed state building codes, permit streamlining,
infrastructure siting, consumer education, preferential parking policies, and ZEV readiness plans)
VMT Reduction
Reduce or eliminate minimum parking standards Does Not Conflict. Although this goal is not the responsibility of an individual commercial development
project, the project would implement neighborhood
design improvements. The project includes
modifications to the transportation network consistent
with the City's Complete Streets Policy. Such
improvements include constructing sidewalk along the
project frontage, construction of bicycle facilities along its western, southern, and northern frontages,
constructing a multi-use path, and installing striping to better delineate the roadway cross section for different users. These facilities would be consistent with the City’s Active Transportation Plan.

The project also includes a redesignation of Herndon
Avenue from Expressway Area to Superarterial, which
allows for multiple modes of travel traffic, including
pedestrian and bikes. This could lead to further
development of these types of non-vehicular facilities, including bike lanes and sidewalks, which are not
currently allowed under the Expressway Area
designation.

The project site is largely surrounded by existing
development. The project would increase the
development density of the area and would be located
near transit facilities, such as the NW Herndon-Hayes
transit stop, and therefore would increase the density of development near transit.

Implement Complete Streets policies and investments,
consistent with general plan circulation element requirements Increase access to public transit by increasing density of development near transit, improving transit service by
increasing service frequency, creating bus priority lanes, reducing or eliminating fares, microtransit, etc.

Increase public access to clean mobility options by planning for and investing in electric shuttles, bike share, car share, and walking
Implement parking pricing or transportation demand
management pricing strategies
Amend zoning or development codes to enable mixed-use,
walkable, transit-oriented, and compact infill development (such as increasing the allowable density of a neighborhood) Preserve natural and working lands by implementing land use policies that guide development toward infill areas and do not convert “greenfield” land to urban uses (e.g., green belts, strategic conservation easements)

128 CARB. 2022. 2022 Scoping Plan Appendix D: Local Actions. November. Available at: https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp- appendix-d-local-actions.pdf. Accessed: August 2025.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-33 Priority Areas1 Priority GHG Reduction Strategies1 Does it Conflict? Through implementation of Mitigation Measure 3.13-2,
the project would encourage employee commute trip
reduction through a variety of strategies. The project
would provide carpool incentives, partner with local
agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work. This would reduce the
employee VMT and provide incentives for employees to
commute to work in alternative ways.

Furthermore, the Project would allow customers to have
multiple needs served in one trip, including eye exams, purchase of household goods and groceries, furniture
store, appliance store, liquor store, car washes, and
refueling at gas station. Costco members may make
fewer total retail shopping trips in a month or a year
than they would make if they did not have a Costco
nearby. This may result in VMT reduction that is not
captured in the VMT modeling.

Building
Decarbonization
Adopt all-electric new construction reach codes for
residential and commercial uses
Does Not Conflict. Although this goal is not the
responsibility of an individual commercial development
project, the Project would use PG&E's Solar Choice
program, which provides 100% solar energy to
customers.

The project would meet the 2019 California
Green Building Standards Code, based on the building
permit application submission (i.e., prior to January 1, 2023), which would include a number of energy saving
requirements. The project would also use all-electric
forklifts, scrubbers, and pallet jacks.

Adopt policies and incentive programs to implement energy efficiency retrofits for existing buildings, such as
weatherization, lighting upgrades, and replacing energy- intensive appliances and equipment with more efficient
systems (such as Energy Star-rated equipment and
equipment controllers)
Adopt policies and incentive programs to electrify all
appliances and equipment in existing buildings such as
appliance rebates, existing building reach codes, or time of sale electrification ordinances
Facilitate deployment of renewable energy production and distribution and energy storage on privately owned land uses (e.g., permit streamlining, information sharing)
Deploy renewable energy production and energy storage
directly in new public projects and on existing public facilities (e.g., solar photovoltaic systems on rooftops of municipal buildings and on canopies in public parking lots, battery storage systems in municipal buildings)
1 Priority areas and GHG reduction strategies obtained from 2022 CARB Scoping Plan Update, Appendix D, Local Actions. Available online at:
https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf. Accessed: August 2025.

Abbreviations:

CalGreen - California Green Building Standards Code
CARB - California Air Resources Board
DC - Direct Current
EV - electric vehicle
GHG - greenhouse gas
PG&E - Pacific Gas & Electric
VMT - vehicle miles traveled
ZEV - zero emission vehicle
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3.7-34 Costco Commercial Center Project Partially Recirculated Draft EIR Fresno COG RTP/SCS
The project will not conflict with the state’s GHG reduction goals and strategies as discussed in the Fresno COG’s 2022 RTP/SCS129 (the current RTP/SCS for the region), which contains four key elements:

1. Policy Element– Sets forth Fresno COG’s transportation goals, objectives, and policies for each transportation mode. The project’s consistency with the policy element is evaluated in Table 3.7-6.

2. Sustainable Communities Strategy – Integrates land use and transportation planning efforts to meet Fresno County’s GHG emission reduction targets, and improve accessibility to major employment and other regional activity centers. The SCS is based on information about reasonably foreseeable growth and approved development obtained from the local jurisdiction. Growth projections are developed that reflect a GHG-efficient buildout pattern. The proposed project is located on an infill lot that has been designated for commercial development by the City. Although the project includes an amendment to alter the existing land use designation of the site from Community Commercial to General Commercial to accommodate the proposed car wash, the size and type of use proposed is otherwise consistent with the existing designation. In addition, the number of employees for the project (a maximum of 300 employees) is a very small percentage (<1%) of the overall jobs assumed in the 2022 RTP/SCS and the relocation of these employees from the existing Costco on West Shaw Avenue to the proposed location would not be inconsistent with the growth modeled in the plan. For these reasons, the project would not conflict with the growth forecast used to develop the SCS.

3. Action Element – Describes the existing transportation system, discusses recent accomplishments, provides a transportation needs assessment, and proposes short-term and long-term actions for both transportation planning and actual transportation project improvements. The project would not affect regional transportation planning and includes several transportation infrastructure improvements that are consistent with the City’s adopted plans.

4. Financial Element – Identifies both existing and anticipated revenue sources as well as the financing techniques available for the region’s planned transportation investments, ongoing operations, and maintenance. The transportation infrastructure improvements included in the project include pedestrian improvements and road connections. Implementation of these improvements as part of the project would not affect the financing of other regional transportation investments.

The RTP/SCS is based on an analysis that considers the entire County and includes all projects involving changes in regional growth and land use in Fresno County, as well as the countywide vehicle traffic projections. Cumulative GHG emissions analyzed in the RTP were compared to regional GHG thresholds and analyzed under statewide plans and regulations. The RTP/SCS concluded that there would be a decrease in GHG emissions from existing conditions to 2046, which would primarily be due to addressing new requirements for reducing GHG emissions, focusing growth in developed areas, moderately increasing residential densities, encouraging infill development, protecting open space and agricultural land, and providing alternatives to single-occupancy vehicle trips.

As shown in Table 3.7-6, the project would not conflict with applicable Fresno COG strategies for the reduction of GHG emissions.

129 Fresno COG. 2022 Regional Transportation Plan and Sustainable Communities Strategy. Available at: https://www.planfresno.com/sustainable- communities-strategies-fall-outreach/. Accessed: October 2025.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-35 Table 3.7-6 RTP/SCS Policy Consistency Evaluation
Goal1 Policy1 Does it Conflict?
1 Improved mobility
and accessibility for
all
Encourage and prioritize full, fair, and
equitable participation by all affected
communities in transportation decision-
making and planning processes.

Does Not Conflict. Although this goal is not the sole responsibility of an individual commercial development project, the project would provide additional retail options accessible by nearby residences and local businesses. In addition, the project would implement neighborhood design improvements such as
pedestrian network improvements and bikeway facilities as part of the project, which would be located in close proximity to transit stops (e.g., NW Herndon-Hayes transit stop).

Actively work to ensure equitable distribution
of the benefits and burdens of transportation
projects.

Promote the improvement and expansion of
accessible transportation options to serve the
needs of all residents, especially those who
have historically faced disproportionate
transportation burdens.
2 Vibrant communities
that are accessible
by sustainable
transportation
options
Encourage alternatives to single-occupancy
vehicles that reduce vehicle miles traveled
(VMT) and greenhouse gas emissions.

Does Not Conflict. Although this goal is not the sole responsibility of an individual commercial development project, the project includes a redesignation of Herndon Avenue from Expressway Area to Superarterial, which allows for multiple modes of travel traffic, including pedestrian and bikes. This could lead to further development of these types of non-vehicular facilities, including bike lanes and sidewalks, which are not currently allowed under the Expressway Area designation.

In addition, the project would implement neighborhood design improvements such as pedestrian network improvements and bikeway facilities as part of the project. The project would be located near transit facilities such as the NW Herndon-Hayes transit stop, allowing for alternatives to single-occupancy vehicle trips to the project site. This would support efforts to improve air quality and minimize pollutants from transportation.

Through implementation of Mitigation Measure 3.13-2, the Project would encourage employee commute trip reduction through a variety of strategies. The project would provide carpool incentives, partner with local agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work. This would reduce the employee VMT and provide incentives for employees to commute to work in alternative ways.

The project would not conflict with efforts to minimize the loss of farmland, environmentally sensitive areas, and natural resources.

Section 3.5, Biological Resources,” of the 2024 EIR indicates that the project site does not contain any sensitive natural communities or protected wetlands. Project activities would include ground disturbance, tree removal, and other vegetation removal, which could result in disturbance, injury, or mortality of several special- status wildlife species (if present), reduced breeding productivity of these species, and loss of species habitat. This impact would be reduced to a less-than-significant level with implementation of Mitigation Measures 3.5-1a and 3.5-1b that require preconstruction surveys for burrowing owl, Swainson’s hawk, white-tailed kite, other common raptors, and other native birds, and
implementation of protective measures for active nests. Further, as explained in Section 3.2, “Agricultural and Forestry Resources,” of the 2024 EIR, no agricultural land use or zoning is present within or adjacent to the site.

Support investment in and promotion of
active transportation and transit to improve
public health and mobility, especially in
historically underinvested areas.

Encourage sustainable development that
focuses growth near activity centers and
mobility options that achieve greater location
efficiency.

Support local jurisdictions’ efforts to minimize
the loss of farmland, environmentally sensitive
areas, and natural resources
Support local jurisdictions’ efforts to facilitate
the development of diverse housing choices
for all income groups.

Facilitate and promote interagency
coordination and consistency across planning
efforts.

Incentivize and support efforts to improve air
quality and minimize pollutants from
transportation.

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3.7-36 Costco Commercial Center Project Partially Recirculated Draft EIR Goal1 Policy1 Does it Conflict?
3 A safe, well-
maintained, efficient,
and climate-resilient
multimodal
transportation
network
Prioritize investment in and promote
multimodal safety measures to reduce traffic
fatalities and incidents in the region.

Does Not Conflict. As described in Section 3.13, “Transportation and Circulation,” of the 2024 EIR the project would be consistent with the applicable plans, policies, and programs and would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

The project would implement strategies to reduce commute VMT through implementation of Mitigation Measure 3.13-2. The project would provide carpool incentives, partner with local agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work.

The project would also implement neighborhood design
improvements such as pedestrian network improvements and bikeway facilities as part of the project. In addition, the project would be located near transit stops and would allow for utilization of existing transit facilities to visit the project site.

Promote enhanced Transportation Systems
Management (TSM) and Transportation
Demand Management (TDM) strategies to
reduce congestion and vehicle miles traveled.

Encourage improvements in travel
connections across all modes to create an
integrated, accessible, and seamless
transportation network.

Maximize the cost-effectiveness of
transportation improvements.

Encourage investments that increase the
system’s resilience to extreme weather events,
natural disasters, and pandemics.

Preserve and maintain existing multimodal
transportation assets in a state of good repair
4 A transportation
network that
supports a
sustainable and
vibrant economy
Support local and regional economic
development by leveraging planning and
transportation funds that foster public and
private investment.

Does Not Conflict. Although this goal is not the sole responsibility of an individual commercial development project, the Project would facilitate goods movement to the Fresno area.

Facilitate efficient, reliable, resilient, and
sustainable goods movement.
5 A region embracing
clean transportation,
technology, and
innovation
Support innovative mobility solutions that are
accessible, affordable, reduce greenhouse gas
emissions, and improve air quality.

Does Not Conflict. Although this goal is not applicable to an individual commercial development project, the project would not conflict with regional efforts to embrace innovative mobility solutions. The project would implement strategies to reduce commute VMT through implementation of Mitigation Measure

3.13-2. In addition, the Project would include 10 DC Fast chargers and 1 Level 2 charger, which run on 100% clean energy provided by PG&E and would also provide Costco members with convenient EV charging at a lower cost. The total power usage for the system is 1,800 kW, which is greater than both the mandatory requirement (1,172 kW) and the Tier 1 voluntary requirement (1,758 kW) by the CalGreen Building Code 2025.

Support efforts to expand broadband access
throughout the region.

Not Applicable. The project does not affect broadband access. 1 Goal and policies obtained from Chapter 4: Implementing the Plan of Fresno Council of Government's 2022 Regional Transportation Plan, available at: http://www.planfresno.com/planfresno/uploads/2022/06/Chapter-4-Implementing-The-Plan-Final-Draft.pdf. Accessed: August 2025.

Abbreviations:

DC - Direct Current
EV - electric vehicle
NW - northwest
TDM - Transportation Demand Management
TSM - Transportation Systems Management
VMT - vehicle miles traveled
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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-37 Fresno COG Priority Climate Action Plan
The project would not conflict with the priority GHG emission reductions measures listed in the Fresno COG PCAP130, which contains four main sectors of priority GHG reduction measures:
1) Transportation Sector
2) Building Energy Sector
3) Solid Waste and Wastewater Sector
4) Agriculture Sector
As described above, the PCAP was adopted in February 2024 and is based on an analysis that considers the entire county, including the 15 incorporated cities in Fresno County and the unincorporated Fresno County areas. Each GHG reduction measure in the PCAP was quantified to evaluate the potential GHG emission reductions from the implementation of the measures for each sector. The second phase of the Regional Climate Action Plan, the CCAP has been released for public review. However, this analysis does not evaluate consistency with it because it is still in draft form.

As shown in Table 3.7-7, the project would not conflict with applicable Fresno COG PCAP measures for the reduction of GHG emissions.

Table 3.7-7 PCAP Consistency Evaluation
Sector Measure Description Does it Conflict?
Transportation Measure 1 - EV
Strategy
Develop a robust public electric vehicle
charging network in Fresno County,
including in the disadvantaged
communities, to increase electric vehicle
adoption in Fresno County.
(Implementing measures could include a
neighborhood electric vehicle (NEV)
network)
Does Not Conflict. The project would include 10 DC Fast chargers and 1 Level 2 charger, which run on 100% clean energy provided by PG&E and will also provide Costco
members with convenient EV charging at a lower cost.

The total power usage for the system is 1,800 kW, which is greater than both the mandatory requirement (1,172
kW) and the Tier 1 voluntary requirement (1,758 kW) by
the CalGreen Building Code 2025.

Measure 2 -
Municipal Fleet
Conversion
Continue to convert the municipal fleet
(including transit) into zero emission
vehicles and provide a sustainable and
reliable support system for such zero-
emission fleet which could include, but
not limited to maintenance, charging
facilities, training of personnel, etc.
(Implementing measures could include
fleet electrification, installation of electric
vehicle charging infrastructure, etc.)
Not Applicable. The project does not include municipal
uses.

Measure 3 - Bike
and Pedestrian
Network
Build a well-connected bike and
pedestrian system that provides
alternative transportation options
including micromobility such as shared e-
bike and e-scooter. (Implementing
measures could include pedestrian
network improvements, bike parking,
expanded bikeway networks, electric
bikeshare program, scooter share
program, dedicate land for bike trails)
Does Not Conflict. The project would implement
neighborhood design improvements such as pedestrian
network improvements and bikeway facilities. The
project also includes a redesignation of Herndon Avenue from Expressway Area to Superarterial, which allows for multiple modes of travel traffic, including pedestrian and bikes. This could lead to further development of these
types of nonvehicular facilities, including bike lanes and

130 Fresno COG. Priority Climate Action Plan. Available at: https://www.epa.gov/system/files/documents/2024-03/fresno-cog-pcap.pdf. Accessed:

August 2025.

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3.7-38 Costco Commercial Center Project Partially Recirculated Draft EIR Sector Measure Description Does it Conflict?
Measure 4 - Public
Transportation
Enhance the public transportation system
by maintaining/expanding the existing
transit system and implementing other
transit strategies such as micro transit.
sidewalks, which are not currently allowed under the
Expressway Area designation.

The project’s off-site improvements include construction of bicycle facilities along its western, southern, and
northern frontages (North Riverside Drive, West
Herndon Avenue, and Spruce Avenue, respectively),
thereby providing connections to existing bicycle
facilities on those roads. These improvements would be
consistent with the City of Fresno Active Transportation Plan (ATP) Program.

Trail improvements provided by the proposed project
would include Class I bicycle facilities along the project’s frontage on West Herndon Avenue and North Riverside
Drive, which is consistent with future facilities identified in the City of Fresno’s ATP adjacent to the proposed
project site. Development of the project would not
physically obstruct access to existing recreational
opportunities, including the trails along the San Joaquin River that connect to Riverbottom Park. Moreover, the
project would facilitate multi-modal access to these
existing facilities because it would include through
construction of 12-foot-wide pedestrian and bicycle
paths along the project’s frontage with West Herndon
Avenue and North Riverside Drive. These paths would be
consistent with the City’s ATP and would support
General Plan Policies POSS-3-c and POSS-7-h regarding
linking city pathways with parks and the San Joaquin
Parkway Trail Networks. The project would not preclude
access to existing or planned recreational facilities.

Measure 5 -
Carpool/Vanpool
and Other Shared
Mobility Options
Provide incentives for carpool and
vanpool, and other shared mobility
options. (Implementation measures could
include commute trip reduction
programs, end-of trip facilities, car-
sharing program, employer-sponsored
vanpool/shuttle, priced workplace
parking, and/or employee parking “cash-
out” programs.)
Does Not Conflict. Through implementation of
Mitigation Measure 3.13-2, the Project would encourage
employee commute trip reduction through a variety of
strategies. The project would provide carpool incentives, partner with local agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work.

Building
Energy
Measure 1 -
Incentive Programs
for the Purchase of
Certified Energy-
Efficient Appliances
Incentive programs for the purchase of
certified energy-efficient appliances,
heating and cooling equipment, lighting,
and building products to replace
inefficient products. (Implementation
could include air distribution system
updates such as right-sizing fan system
equipment and converting to a variable-
air-volume system, heating and cooling
system upgrades, reductions in
supplemental energy load consumption
by installing ENERGY STAR equipment,
window films, and adding insulation or
reflective roof coating and/or installation
of energy-efficient lighting.)
Does Not Conflict. The project would meet the 2019
California Green Building Standards Code, based on the
building permit application submission (i.e., prior to
January 1, 2023), which would include energy saving
requirements. Renewable energy would be obtained
through PG&E's Solar Choice program.

The buildings would include restroom fixtures that are
high efficiency to reduce water use. In addition,
mechanical heat from refrigeration systems would be
captured to preheat hot water tanks. Wash water used
for the car wash would be recycled and the car wash
would comply with all regulations pertaining to water
conservation and run-off.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-39 Sector Measure Description Does it Conflict?
Measure 2 -
Incorporate Water
Efficiency Measures
Incorporate water efficiency measures
that reduce water heating energy
consumption by installing alternative
types of water heaters in place of gas
storage tank heaters in residences.

The irrigation system would be a water efficient low flow, point source system designed to provide adequate
watering to support plant growth and ensure deeply
rooted plant material while avoiding excess water
application. The system would be programmable and
would interface with a weather based sensor that would
adjust the amount of water applied to the plant material based on daily weather conditions. Landscape irrigation would comply with the California Department of Water
Resources Model Water Efficient Landscape Ordinance
(MWELO).

Measure 3 - Bundle
On-Site Renewable
Energy Generation
Bundle on-site renewable energy
generation with energy efficiency
improvements in residences and
commercial buildings. (Implementation
could include establishment of on-site
renewable energy systems such as solar
power with fuel cells and battery storage,
biomass combustion, and/or wind power,
limitations on non-renewable energy
sources.)
Solid Waste
And
Wastewater
Measure 1 -
Programs and
Incentives to
Reduce or Divert
Waste
Programs and incentives to reduce or
divert waste (including food and/or yard
waste) through improved production
practices, improved collection services,
and increased reuse or recycling rates.
(Implementation measures could include
organics diversion program, educational
programs to inform residents about
reuse, recycling, composting, waste to
energy, and zero waste programs. Local
recycling and composting initiatives at
the neighborhood level, expansion of
local business recycling and composting
efforts.)
Does Not Conflict. The project would recycle
construction and demolition waste. Structures would be
constructed of recycled metal. Recycling canisters would be provided in public areas where trashcans are also
provided.

Measure 2 -
Wastewater
Treatment Facility
Efficiency
Installation of renewable energy and
energy efficiency measures at wastewater
treatment facilities.

Not Applicable. The project does not include new or
expanded wastewater treatment facilities.

Agriculture Measure 1 - Manure
Management
Programs and incentives to reduce GHG
emissions associated with manure
management from livestock and poultry
operations.

Not Applicable. The project does not propose
agricultural use and is not located on property currently designated for agricultural uses.

Measure 2 -
Agricultural Burning
Programs and incentives to reduce GHG
emissions associated with agricultural
burning, including orchards and
vineyards, through chipping and use for
soil incorporation, on-site land
application on agricultural land, off-site
beneficial re-use, or other approved
methods. (Implementation measures
could include additional funding or
outreach support for existing programs
available through the San Joaquin Valley
Air Pollution Control District (SJVAPCD)
and USDA-NRCS, educational programs,
or other direct funding opportunities for
projects proposed as part of PCAP
development.)
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3.7-40 Costco Commercial Center Project Partially Recirculated Draft EIR Sector Measure Description Does it Conflict?
Measure 3 -
Agricultural
Equipment
Reductions
Programs and incentives to reduce GHG
emissions associated with the operation
of various agricultural equipment, such as
tractors, harvesting equipment, utility
terrain vehicles, dairy feed mixing
electrification and agricultural pumps
through zero-emission replacement as
well as the installation of charging or re-
fueling stations to support deployment.
(Implementation measures could include
additional funding or outreach support
for existing programs available through
USDA-NRCS and the SJVAPCD,
educational programs, or other direct
funding opportunities for projects
proposed as part of PCAP development.)
1 Relevant measures obtained from the Fresno Council of Governments Priority Climate Action Plan (March 2024).

Abbreviations:

ATP - Active Transportation Plan
e-bike - electric bike
e-scooter - electric scooter
EV - Electric Vehicle
GHG - greenhouse gas
MWELO - Model Water Efficient Landscape Ordinance
NEV - neighborhood electric vehicle
PCAP - Priority Climate Action Plan
PG&E - Pacific Gas and Electric
SJVAPCD - San Joaquin Valley Air Pollution Control District USDA-NRCS - United States Department of Agriculture Natural Resources Conservation Service
VMT - Vehicle Miles Traveled
City of Fresno GHG Reduction Plan (2014)
As previously discussed in Section 3.7.4, “Thresholds of Significance,” the Court of Appeal rescinded its approval of the 2021 GHGRP, making the 2014 GHGRP the applicable GHGRP at the time of this report. Due to the age of the City’s 2014 GHGRP, the City has analyzed consistency with the State’s 2022 Scoping Plan and with the RTP/SCS in considering GHG emissions of proposed projects. Those topics are addressed above. Although compliance with the City’s 2014 GHGRP alone would not demonstrate how the project relates to the State’s ability to meet its climate emissions targets, the City adopted the 2014 GHGRP to include policies that would be protective of the environment.

Therefore, to further ensure a complete and robust analysis, the discussion below considers project consistency with the 2014 GHGRP as part of its analysis of environmental impacts.

The GHGRP sets forth criteria for determining whether a development project within the City of Fresno is consistent with the GHGRP so as to be deemed to have a less than significant GHG impact.131. Projects that are not consistent with the GHGRP must prepare a comprehensive project-specific analysis of GHG emissions, including quantification of existing and projected GHG emissions, and apply appropriate GHG reduction mitigation measures.

The GHGRP first (in Section 6.2.1) lists criteria for determining GHGRP consistency that apply to all projects subject to CEQA review. These are:

1. Review General Plan Policies listed in the GHG Plan to determine applicability to the project.

2. Incorporate design features or mitigation measures into the project as needed to demonstrate consistency. a. Street and pedestrian design complies with complete streets concepts. b. Review project against Development Code for mandatory design features required for the project.

131 While the 2014 GHGRP refers to a checklist for use in evaluating project consistency with the GHGRP, the City retired that checklist program under the 2014 GHGRP because the CalGreen Building Code superseded most of the items addressed in that former program.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-41 c. Consider alternative energy generation (solar) if appropriate for the project and site. (The State is working towards zero net energy development that will require increasing efficiency and self-generation over time).
d. Review water conservation building and landscape design features for compliance with City water conservation standards.

3. Implement project design features suitable for the development type and location. a. Projects within core/center areas and BRT corridors should meet minimum density and design requirements to ensure pedestrian and transit orientation is met. b. Maintain and enhance connections to regional bikeways and trail system.

4. Complete the latest version of the Fresno Green Residential or Non‐Residential Checklist. a. Meet the Fresno Green checklist point requirements.
b. Alternatively, meet the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED) Programs, or qualify for Build It Green’s GreenPoint rating system for residential building.

Item 1 in Section 6.2.1 of the GHGRP requires review of the General Plan policies listed in the GHGRP to determine applicability to the project. As shown in Table 3.7-8, the project would be consistent with applicable City of Fresno GHG General Plan policies listed in the GHGRP (Section 5.1).

Table 3.7-8 2014 General Plan Policy Consistency Evaluation GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Land Use and
Transportation
Land Use
Strategies
Policy RC‐2‐a: Link Land Use to
Transportation. Promote mixed‐use, higher
density infill development in multi‐modal
corridors. Support land use patterns that
make more efficient use of the transportation
system and plan future transportation
investments in areas of higher
‐intensity
development. Discourage investment in
infrastructure that would not meet these
criteria.

Does Not Conflict. The project provides convenient
access to an array of Costco services. The project
would allow customers to have multiple needs
served in one trip, including eye exams, purchase of
household goods and groceries, car washes, and
refueling.

The project would intensify development adjacent
to an established transportation corridor. The
project includes a redesignation of Herndon Avenue
from Expressway Area to Superarterial, which allows
for multiple modes of travel traffic, including
pedestrian and bikes. This could lead to further
development of these types of non-vehicular
facilities, including bike lanes and sidewalks, that are not currently allowed under the Expressway Area
designation. Additionally, the project would be
located near transit facilities, such as the NW
Herndon-Hayes transit stop.

The project implements pedestrian, bicycle, and
transit linkages to surrounding land uses and
neighborhoods consistent with Fresno's General
Plan and Active Transportation Plan. The project is
also approximate to the growing commercial area
near State Route 99, between West Herndon
Avenue and North Veterans Boulevard.

Under the General Plan, the project site has long
been designated for commercial use. The project's
requested zoning change from Community
Compact and
Infill
Development
Policy UF‐1‐c: Legible City Structure. Focus
integrated and ongoing planning efforts to
achieve an identifiable city structure,
comprised of a concentration of buildings,
people, and pedestrian
‐oriented activity in
Downtown; along a small number of
prominent east west and north
‐south transit‐
oriented, mixed‐use corridors with distinctive
and strategically located Activity Centers; and
in existing and new neighborhoods
augmented with parks and connected by
multi
‐purpose trails and tree lined bike lanes
and streets.

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3.7-42 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Commercial to General Commercial is to allow a car
wash.

Policy UF‐12‐b: Activity Centers. Mixed‐use
designated areas along BRT and/or transit
corridors are appropriate for more intensive
concentrations of urban uses. Typical uses
could include Chapter 3: Urban Form, Land
Use, and Design commercial areas;
employment centers; schools; compact
residential development; religious institutions;
parks; and other gathering points where
residents may interact, work, and obtain
goods and services in the same place.

Not Applicable. The project site is not in a mixed-
use designated area.

Policy LU‐2‐a: Infill Development and
Redevelopment. Promote development of
vacant, underdeveloped, and redevelopable
land uses within the City Limits where urban
services are available by establishing and
implementing supportive regulations and
programs.

Does Not Conflict. The project would develop
vacant, underdeveloped land uses within City limits.

Policy LU‐2‐b: Infill Development for
Affordable Housing. Consider a priority infill
incentive program for residential infill
development of existing vacant lots and
underutilized sites within the City as a strategy
to help to meet the affordable housing needs
of the community.

Not Applicable. The project does not include
housing.

Policy LU‐3‐b: Mixed‐Use Urban Corridors that
Connect the Downtown Planning Area.

Support the development of mixed‐use urban
corridors that connect the Downtown
Planning Area with the greater Fresno
‐Clovis
Metropolitan Area with functional, enduring,
and desirable urban qualities along the
Blackstone Avenue, Shaw Avenue, California
Avenue, and Ventura Avenue/Kings Canyon
corridors, as shown on Figure LU
‐1: General
Plan Land Use Diagram.

Not Applicable. The project site is not on any of the
listed roads.

Policy LU‐3‐c: Zoning for High Density on
Major Transit Corridors. Encourage adoption
of supportive zoning regulations for compact
development along BRT corridors leading to
the Downtown Core that will not diminish
long
‐term growth and development potential
for Downtown.

Not Applicable. The project site is not in a BRT
corridor.

Policy LU‐5‐f: High Density Residential Uses.

Promote high‐density residential uses to
support Activity Centers and BRT corridors,
affordable housing and walkable access to
transit stops.

Not Applicable. The policy relates to residential
uses.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-43 GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Mixed-Use
Development
Policy RC‐2‐b: Provide Infrastructure for
Mixed‐Use and Infill. Promote investment in
the public infrastructure needed to allow
mixed‐use and denser infill development to
occur in targeted locations, such as expanded
water and wastewater conveyance systems,
complete streetscapes, parks and open space
amenities, and trails. Discourage investment in
infrastructure that would not meet these
criteria.

Does Not Conflict. Although this policy is not
directly applicable to commercial development
projects, the project would generally invest in the
types of public infrastructure that are needed to
support mixed us and infill development in the area.

For example, the project is required to provide
neighborhood design improvements, such as
pedestrian network improvements and bikeway
facilities. The project also includes a redesignation
of Herndon Avenue from Expressway Area to
Superarterial, which allows for multiple modes of
travel, including pedestrian and bikes. This could
lead to further development of these types of non-
vehicular facilities, including bike lanes and
sidewalks, which are not currently allowed under the
Expressway Area designation.

Policy UF‐12‐d: Appropriate Mixed‐Use.

Facilitate the development of vertical and
horizontal mixed
‐uses to blend residential,
commercial, and public land uses on one or
adjacent sites. Ensure land use compatibility
between mixed
‐use districts in Activity Centers
and the surrounding residential
neighborhoods.

Does Not Conflict. The project site is located within
walking distance to nearby residences and will
provide retail and jobs near a housing-rich area.

A mixed-use alternative was evaluated in the 2024
EIR and found to be infeasible.

Policy UF‐12‐f: Mixed‐Use in Activity Centers.

Update the Development Code to include use
regulations and standards to allow for mixed
uses and shared parking facilities, including
multi
‐story and underground parking facilities,
within Activity Centers.

Not Applicable. This policy relates to the City
enacting zoning and development standards and
does not apply to commercial sites.

Pedestrian
Oriented
Development
Policy UF‐12‐e: Access to Activity Centers.

Promote adoption and implement standards
supporting pedestrian activities and bicycle
linkages from surrounding land uses and
neighborhoods into Activity Centers and to
transit stops. Provide for priority transit routes
and facilities to serve the Activity Centers.

Does Not Conflict. To provide transportation
facilities based upon a Complete Streets concept
that facilitates the balanced use of all viable travel
modes, the project would include construction of 12-
foot-wide pedestrian and bicycle paths along the
project’s frontage with West Herndon Avenue and
North Riverside Drive. These facilities would be
consistent with the City’s Active Transportation Plan
(ATP). Trail improvements provided by the proposed
project would include Class I bicycle facilities along
the project’s frontage on West Herndon Avenue and
North Riverside Drive, which is consistent with future
facilities identified in the City of Fresno’s ATP
adjacent to the project site. The project also involves the construction of West Spruce Avenue along the
northern project site boundary. The City has
identified the construction of Spruce Avenue,
including Class II bicycle facilities, as a condition of approval, which would be consistent with the City of
Fresno’s ATP. The project’s off-site improvements
include construction of bicycle facilities along its
western, southern, and northern frontages (North
Policy UF‐14‐a: Design Guidelines for
Walkability. Use design guidelines and
standards for a walkable and pedestrian‐
scaled environment with a network of streets
and connections for pedestrians and bicyclists,
as well as transit and autos.

Policy UF‐14‐b: Local Street Connectivity.

Design local roadways to connect throughout
neighborhoods and large private
developments with adjacent major streets and
pathways of existing adjacent development.

Create access for pedestrians and bicycles
where a local street must dead end or be
designed as a cul
‐de‐sac to adjoining uses
that provide services, shopping, and
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3.7-44 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? connecting pathways for access to the greater
community area.

Riverside Drive, West Herndon Avenue, and Spruce
Avenue, respectively) and would be consistent with
the City of Fresno's ATP.

The project also includes a redesignation from of
Herndon Avenue from Expressway Area to
Superarterial, which allows for multiple modes of
travel, including pedestrian and bikes. This could
lead to further development of these types of non-
vehicular facilities, including bike lanes and
sidewalks, which are not currently allowed under the
Expressway Area designation.

Policy UF‐14‐c: Block Length. Create
development standards that provide desired
and maximum block lengths in residential,
retail, and mixed
‐use districts order to
enhanced walkability.

Not Applicable. Although this policy is not the
responsibility of an individual commercial
development project, the project includes
pedestrian network improvements to attract nearby
residents and to maximize foot traffic.

Policy D‐3‐c: Local Streets as Urban Parkways.

Develop local streets as “urban parkways,”
where appropriate, with landscaping and
pedestrian spaces.

Does Not Conflict. The project will include
landscaping and pedestrian walkways.

Policy D‐4‐b: Incentives for Pedestrian‐
Oriented Anchor Retail. Consider adopting
and implementing incentives for new
pedestrian
‐friendly anchor retail at
intersections within Activity Centers and along
corridors to attract retail clientele and
maximize foot traffic.

Not Applicable. The policy is related to the City’s
adoption of an incentive program. The project has
not participated in an incentive program but
includes pedestrian network improvements to
attract nearby residents and to maximize foot
traffic.

Policy MT‐1‐h: Update Standards for Complete
Streets. Update the City’s Engineering and
Street Design Standards to ensure that
roadway and streetscape design specifications
reflect the Complete Streets concept, while
also addressing the needs of through traffic,
transit stops, bus turnouts, passenger loading
needs, bike lanes, and short and long
‐term
parking.

Not Applicable. Although this policy is not the
responsibility of an individual commercial
development project, to provide transportation
facilities based upon a Complete Streets concept
that facilitates the balanced use of all viable travel
modes, the project would include construction of
12-foot-wide pedestrian and bicycle paths along the
project’s frontage with West Herndon Avenue and
North Riverside Drive. These facilities would be
consistent with the City’s ATP. Trail improvements
provided by the project would include Class I
bicycle facilities along the project’s frontage on
West Herndon Avenue and North Riverside Drive,
which is consistent with future facilities identified in the City of Fresno’s ATP adjacent to the project site.

The project also includes the construction of West
Spruce Avenue along the northern boundary of the
project site. The City has identified the construction
of Spruce Avenue, including Class II bicycle facilities, as a condition of approval, which would be
consistent with the City of Fresno’s ATP. The asphalt
roadway would include curb, gutter, sidewalk, Class
II bicycle facilities, and streetlights.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-45 GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Transit
Oriented
Development
Policy UF‐12‐a: BRT Corridors. Design land
uses and integrate development site plans
along BRT corridors, with transit
‐oriented
development that supports transit ridership
and convenient pedestrian access to bus stops
and BRT station stops.

Not Applicable. The project would not be located in
a BRT corridor. Although this policy is not
applicable, the project includes neighborhood
design improvements such as pedestrian network
improvements and constructing bikeway facilities,
and would be located near transit facilities such as
the NW Herndon-Hayes transit stop.

Transportation
Facilities
Strategies
Transit
Facilities
Policy MT‐8‐a: Street Design Coordinated with
Transit. Coordinate the planning, design, and
construction of the major street network with
transit operators to facilitate efficient direct
transit routing throughout the Planning Area.

Does Not Conflict. Although these policies are not
the responsibility of an individual commercial
development project, the project will be located
near transit facilities such as the NW Herndon-
Hayes transit stop, allowing for alternatives to
single-occupancy vehicle visits to the project site
that would support efforts to improve air quality
and minimize pollutants from transportation.

Additionally, the project is designed to not interfere
with the future High Speed Rail.

Policy MT‐8‐b: Transit Serving Residential and
Employment Nodes. Identify the location of
current and future residential and
employment concentrations and Activity
Centers throughout the transit service area in
order to facilitate planning and
implementation of optimal transit services for
these uses. Work with California State
University, Fresno to determine locations
within the campus core for bus stops.

Policy MT‐8‐g: High Speed Train. If the State
moves forward with HST, ensure it is
constructed through Fresno in a manner that
minimizes impacts to surrounding property
owners and creates the most opportunity for
redevelopment around the HST station.

Bicycle and
Pedestrian
Infrastructure
Policy MT‐4‐a: Bicycle, Pedestrian and Trails
Master Plan. To the extent consistent with this
General Plan, continue to implement and
periodically update the Bicycle, Pedestrian, and
Trails Master Plan to meet State standards and
requirements for recommended improvements
and funding proposals as determined
appropriate and feasible.

Does Not Conflict. The project includes
neighborhood design improvements such as
pedestrian network improvements and bikeway
facilities. The project also includes a redesignation
of Herndon Avenue from Expressway Area to
Superarterial, which allows for multiple modes of
travel traffic, including pedestrian and bikes. This
could lead to further development of these types of
non-vehicular facilities, including bike lanes and
sidewalks, which are not currently allowed under the
Expressway Area designation.

Trail improvements provided by the project would
include Class I bicycle facilities along the project’s
frontage on West Herndon Avenue and North
Riverside Drive, which is consistent with future
facilities identified in the City of Fresno’s ATP
adjacent to the project site. Development of the
project would not physically obstruct access to
existing recreational opportunities, including the
trails along the San Joaquin River that connect to
Riverbottom Park. Moreover, the project would
facilitate multi-modal access to these existing
facilities through construction of 12-foot-wide
Policy MT‐4‐b: Bikeway Improvements.

Establish and implement property
development standards to assure that projects
adjacent to designated bikeways provide
adequate right
‐of-way and that necessary
improvements are constructed to implement
the planned bikeway system shown on Figure
MT
‐2 to provide for bikeways, to the extent
feasible, when existing roadways are
reconstructed; and alternative bikeway
alignments or routes where inadequate right
‐
of‐way is available.

Policy MT‐4‐c: Bikeway Linkages. Provide
linkages between bikeways, trails and paths,
and other regional networks such as the San
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3.7-46 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Joaquin River Trail and adjacent jurisdiction
bicycle systems wherever possible.
pedestrian and bicycle paths along the project’s
frontage with West Herndon Avenue and North
Riverside Drive. These paths would be consistent
with the City’s ATP.

Policy MT‐5‐a: Sidewalk Development. Pursue
funding and implement standards for
development of sidewalks on public streets,
with priority given to meeting the needs of
persons with physical and vision limitations;
providing safe routes to school; completing
pedestrian improvements in existing
neighborhoods with lower vehicle ownership
rates; or providing pedestrian access to public
transportation routes.

Policy MT‐6‐a: Link Residences to
Destinations. Design a pedestrian and bicycle
path network that links residential areas with
Activity Centers, such as parks and
recreational facilities, educational institutions,
employment centers, cultural sites, and other
focal points of the city environment.

Does Not Conflict. The project includes
neighborhood design improvements such as
pedestrian network improvements and bikeway
facilities that would be constructed as part of the
project would improve connectivity between other
nearby land uses and the project site, providing
more convenient access to Costco services.

Policy MT‐6‐g: Path and Trail Development in
Subdivisions. Require all subdivision maps to
incorporate planned multi‐purpose path and
trail development standards and corridor
linkages consistent with the General Plan,
applicable law and case
‐by‐case
determinations as a condition of tentative
map approval.

Policy POSS‐7‐h: Interlink City and San
Joaquin River Parkway Trail Networks. Strive
to connect the parkway trail network to other
trails in the vicinity, in order to create a
community and regional trail system that
offers a variety of different route
combinations and enhances public access to
the parkway.

Transportation
Demand
Strategies
Transportation
Demand
Management
Policy MT‐10‐c: Transportation Demand
Management Guidelines. Establish
transportation demand management
guidelines to allow for reduced off
‐street
parking requirements.

Not Applicable. These policies relate to the
development of parking guidelines and standards
by the city. The project complies with all adopted
and applicable parking standards.

Parking
Measures
Policy MT‐10‐a: Updating Parking Standards.

Update off‐street parking standards to reflect
the context and location within activity areas of
multiple uses and reductions appropriate for
mixed residential and non
‐residential uses and
proximity to existing or planned transit service.

Policy MT‐10‐b: Shared Parking. Establish a
strategy to promote the sharing of excess
parking between uses within Activity Centers
and BRT corridors, including specific
provisions for this in the Development Code.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-47 GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Policy MT‐10‐d: Parking Maximums. Explore
maximum off‐street parking limits within
Activity Centers proximate to BRT corridors, if
such an Activity Center is determined
compatible with promotion of a healthy and
vigorous business environment.

Policy MT‐10‐f: Parking Benefit Districts.

Establish parking benefit districts to fund
consolidated public parking where supported
by local businesses.

Transportation
Demand
Strategies
(Continued)
Electric Vehicle
Charging
Stations
Policy RC‐8‐j: Alternative Fuel Network.

Support the development of a network of
integrated charging and alternate fuel station
for both public and private vehicles, and if
feasible, open up municipal stations to the
public as part of network development.

Not Applicable. Although this policy is not the
responsibility of an individual commercial
development project, the project includes 10 DC
Fast chargers and 1 Level 2 charger, that would run
on 100% clean energy provided by PG&E and would
also provide Costco members with convenient EV
charging at a lower cost. This development would
add to the network of chargers available in the city.

Energy
Conservation
Strategies for New
and Existing
Buildings
Energy
Efficiency in
New Buildings
Policy RC‐8‐a: Existing Standards and
Programs. Continue existing beneficial energy
conservation programs, including adhering to
the California Energy Code in new
construction and major renovations.

Not Applicable. Although this policy is not
applicable to an individual commercial
development project, the project would meet the
2019 California Green Building Standards Code,
based on the building permit application
submission (i.e., prior to January 1, 2023), which
includes a number of energy saving requirements.

Power would be obtained through PG&E's Solar
Choice program, which provides 100% solar energy
to customers.

Policy RC‐8‐b: Energy Reduction Targets.

Strive to reduce per capita residential
electricity use to 1,800 kWh per year and
nonresidential electricity use to 2,700 kWh per
year per capita by developing and
implementing incentives, design and
operation standards, promoting alternative
energy sources, and cost‐effective savings.

Policy RC‐8‐c: Energy Conservation in New
Development. Consider providing an incentive
program for new buildings that exceed
California Energy Code requirements by
fifteen percent.

Policy RC‐8‐d: Incentives. Establish an
incentive program for residential developers
who commit to building all of their homes to
ENERGY STAR performance guidelines.

Not Applicable. The policy directs the development
of an incentive program specific to residential
development.

Policy RC‐8‐e: Energy Use Disclosure. Promote
compliance with State law mandating
disclosure of a building’s energy data and
rating of the previous year to prospective
buyers and lessees of the entire building or
lenders financing the entire building.

Not Applicable. The project proposes new
construction. This new structure would be more
energy efficient than the existing Costco on Shaw
Avenue, which is in a structure that is approximately
40 years old.

Energy
Efficiency in
Existing
Buildings
Policy RC‐7‐i: PACE Financing. Develop a
residential Property Assessed Clean Energy
(PACE) program, if it is determined to be a
feasible option, to help finance water
efficiency and energy efficiency upgrades for
property owners.

Not Applicable. The policy directs the development
of an incentive program specific to residential
development.

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3.7-48 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Self
Generation
using Solar
Panels and
Solar Hot
Water Systems
Policy RC‐8‐h: Solar Assistance. Identify and
publicize information about financial
mechanisms for private solar installations and
provide over‐the‐counter permitting for solar
installations meeting specified standards,
which may include maximum size (in kV) of
units that can be so approved.

Not Applicable. The policy directs the development
of a program to support solar installation.

Water
Conservation
Strategies
Policy RC‐6‐d: Recycled Water. Prepare,
adopt, and implement a City of Fresno
Recycled Water Master Plan.

Not Applicable. The policy directs the development
of a recycled water plan for the City.

Policy RC-7-a: Water Conservation Program
and 2035 Target. Maintain a comprehensive
conservation program that reduces per capita
water usage in the city’s water service area to
243 gallons per capita per day (gpcd) by 2020
and 190 gpcd by 2035, by adopting
conservation standards and implementing a
program of incentives, design and operation
standards, and user fees.

Support programs that result in decreased
water demand, such as landscaping standards
that require drought
-to
lerant plants, rebates
for water conserving devices and systems, turf
replacement, xeriscape landscape for new
homes, irrigation controllers,
commercial/industrial/institutional water
conserving programs, prioritized leak
detection program, complete water system
audit, landscape water audit and budget
program, and retrofit upon resale ordinance.

Impl
ement the U.S. Bureau of Reclamation
Best Management Practices for water
conservation as necessary to maintain the
City’s surface water entitlements.

Adopt and implement policies in the event an
artificial lake is proposed for development.

Work cooperatively toward effective uniform
water conservation measures that would apply
throughout the Planning Area.

Expand efforts to educate the public about
water supply issues and water conservation
techniques.

Not Applicable. Although these policies are not
applicable to an individual commercial
development project, the project meets the
mandatory outdoor and indoor water use measures.

The buildings would include restroom fixtures that
are high efficiency to reduce water use. In addition,
mechanical heat from refrigeration systems would
be captured to preheat hot water tanks. The
irrigation system would have water efficient low
flow and would be a point source system designed
to provide adequate watering to support plant
growth and ensure deeply rooted plant material
while avoiding excess water application. The system
would be programmable and would interface with a
weather-based sensor that adjusts the amount of
water applied to the plant material based on daily
weather conditions. Landscape irrigation would
comply with the California Department of Water
Resources Model Water Efficient Landscape
Ordinance (MWELO). Lastly, wash water used for
the car wash would be recycled and the car wash
shall comply with all regulations pertaining to water
conservation and run-off.

Policy RC‐7‐d: Update Standards for New
Development. Continue to refine water saving
and conservation standards for new
development.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-49 GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Policy RC‐7‐f: Implementation and Update
Conservation Program. Continue to
implement the City of Fresno Water
Conservation Program, as may be updated,
and periodically update restrictions on water
uses, such as lawn and landscape watering
and the filling of fountains and swimming
pools, and penalties for violations. Evaluate
the feasibility of a 2035 conservation target of
190 gpcd in the next comprehensive update of
the City’s Water Conservation Program.

Policy RC-7-h: Landscape Water Conservation
Standards. Refine landscape water
conservation standards that will apply to new
development installed landscapes, building on
the State Model Water Efficient Landscape
Ordinance and other State regulations.

Evaluate and apply, as appropriate,
augmented xeriscape, “water
-wis
e,” and
“green gardening” practices to be
implemented in public and private
landscaping design and maintenance.

Fac
ilitate implementation of the State’s Water
Efficient Landscape Ordinance by developing
alternative compliance measures that are easy
to understand and observe.

Not Applicable. Although this policy is not applicable
to an individual commercial development project, to
the extent applicable to the project, the project
would meet the 2019 California Green Building
Standards Code, based on the building permit
application submission (i.e., prior to January 1, 2023), which would include mandatory outdoor water use
measures.The irrigation system would be a water
efficient, low flow point source system designed to
provide adequate watering to support plant growth
and ensure deeply rooted plant material while
avoiding excess water application. The system would
be programmable and would interface with a
weather-based sensor that would adjust the amount
of water applied to the plant material based on daily
weather conditions. Landscape irrigation would
comply with the California Department of Water
Resources MWELO.

Waste Diversion
and Recycling and
Energy Recovery
Waste
Diversion and
Recycling and
Energy
Recovery
Policy PU‐9‐a: New Techniques. Continue to
collaborate affected stakeholders and partners
to identify and support programs and new
techniques of solid waste disposal, such as
recycling, composting, waste to energy
technology, and waste separation, to reduce
the volume and toxicity of solid wastes that
must be sent to landfill facilities.

Does Not Conflict. The project would recycle
construction and demolition waste. Recycled metal
would be used in building construction.

Additionally, the project would provide recycling
canisters in public areas where trashcans are also
provided and would recycle pallets.

Policy PU‐9‐b: Compliance with State Law.

Continue to pursue programs to maintain
conformance with the Solid Waste
Management Act of 1989 or as otherwise
required by law and mandated diversion goals.

Policy RC-11-a: Waste Reduction Strategies.

Maintain current targets for recycling and re-
use of
all types of waste material in the city
and enhance waste and wastewater
management practices to reduce natural
resource consumption, including the following
measures:
 Continue to require recyclable material
collection and storage areas in all
residential development.

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3.7-50 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict?  Establish recycling collection and storage
area standards for commercial and
industrial facilities to size the recycling
areas according to the anticipated types
and amounts of recyclable material
generated.
 Provide educational materials to residents
on how and what to recycle and how to
dispose of hazardous waste.
 Provide recycling canisters and collection
in public areas where trash cans are also
provided.
 Institute a program to evaluate major
waste generators and identify recycling
opportunities for their facilities and
operations.
 Continue to partner with the California
Integrated Waste Management Board on
waste diversion and recycling programs
and the CalMax (California Materials
Exchange) program.
 Evaluate the feasibility of a residential,
restaurant and institutional food waste
segregation and recycling program, to
reduce the amount of organic material
sent to landfill and minimize the emissions
generated by decomposing organic
material.
 Evaluate the feasibility of “carbon
footprinting” for the City’s wastewater
treatment facilities, biomass and
composting operations, solid waste
collection and recycling programs.
 Expand yard waste collection to divert
compostable waste from landfills.
 Study the feasibility and cost-ben efit
analysis of a municipal composting
program to collect and compost food and
yard waste, using the resulting compost
matter for City park and median
maintenance.

Policy RC‐4‐i: Methane Capture. Continue to
pursue opportunities to reduce air pollution by
using methane gas from the old City landfill
and the City’s wastewater treatment process.

Not Applicable. The policy is specific to landfill and
wastewater treatment facilities.

Policy RC‐11‐b: Zero Waste Strategy. Create a
strategic and operations plan for fulfilling the
City Council resolution committing the City to
a Zero Waste goal.

Does Not Conflict. The project would recycle
construction and demolition waste. Recycled metal
would be used in building construction.

Additionally, the project would provide recycling
canisters in public areas where trashcans are also
provided and would recycle pallets.

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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-51 GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Wastewater Policy PU‐7‐a: Reduce Wastewater. Identify
and consider implementing water
conservation standards and other programs
and policies, as determined appropriate, to
reduce wastewater flows.

Not Applicable. Although this policy is not
applicable to an individual commercial
development project, the wash water used for the
car wash would be recycled.

The project would
install water efficient systems, including restroom
fixtures and would also implement water
conservation techniques, such as capturing the
mechanical heat from refrigeration systems to
preheat hot water tanks. Due to this, the project
would conserve water and therefore the wastewater
flows will be reduced.

Policy PU‐7‐d: Wastewater Recycling. Pursue
the development of a recycled water system
and the expansion of beneficial wastewater
recycling opportunities, including a timely
technical, practicable, and institutional
evaluation of treatment, facility siting, and
water exchange elements.

Community
Involvement
and Outreach
Policy RC‐7‐g: Educate on State Requirements.

Educate the residents and businesses of
Fresno on the requirements of the California
Water Conservation Act of 2009.

Not Applicable. These policies relate to the City’s
community outreach.

Policy RC‐8‐k: Energy Efficiency Education.

Provide long‐term and ongoing education of
homeowners and businesses as to the value
of energy efficiency and the need to upgrade
existing structures on the regular basis as
technology improves and structures age.

Municipal
Strategies
Municipal
Strategies
Policy RC‐7‐c: Best Practices for Conservation.

Require all City facilities and all new private
development to follow U.S. Bureau of
Reclamation Best Management Practices for
water conservation, as warranted and
appropriate.

Does Not Conflict. The project would implement
project design features that are consistent with the
U.S. Bureau of Reclamation Best Management
Practices for water conservation. The project would
install water efficient systems, including restroom
fixtures.

The project would also implement water
conservation techniques, such as capturing the
mechanical heat from refrigeration systems to
preheat hot water tanks.

The project would also install efficient landscape
irrigation. The irrigation system will be a water
efficient low flow, point source system designed to
provide adequate watering to support plant growth
and ensure deeply rooted plant material while
avoiding excess water application. The system
would be programmable and would interface with a
weather-based sensor that would adjust the
amount of water applied to the plant material
based on daily weather conditions. Landscape
irrigation would comply with the California
Department of Water Resources MWELO.

The Project would also recycle and reuse water the
wash water used for the car wash.

Last, the project would meet the 2019 California
Green Building Standards Code, based on the
building permit application submission (i.e., prior to
January 1, 2023), which would include mandatory
outdoor water use measures.

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3.7-52 Costco Commercial Center Project Partially Recirculated Draft EIR GHG Plan Strategy
Category Sub-Category Key or Relevant General Plan Policies1 Does it Conflict? Policy RC‐7‐e: Retrofit City Facilities, and
Consider Incentives Programs for to
Encourage Retrofitting of Other Existing
Public and Private Residential and Non‐
Residential Facilities and Sites. Reduce water
use in municipal buildings and City operations
by developing a schedule and budget for the
retrofit of existing municipal buildings with
water conservation features, such as auto
shut
‐off faucets and water saving irrigation
systems. Prepare a comprehensive incentive
program for other existing public and private
residential and non
‐residential buildings and
irrigation systems.

Not Applicable. The project would not include the
retrofit of existing building(s).

Policy RC‐8‐f: City Heating and Cooling.

Reduce energy use at City facilities by
updating heating and cooling equipment and
installing “smart lighting” where feasible and
economically viable.

Policy RC‐8‐g: Revolving Energy Fund. Create
a City Energy Fund which uses first year
savings and rebates from completed City
‐
owned energy efficiency projects to provide
resources for additional energy projects.

Dedicate this revolving fund to the sole use of
energy efficiency projects that will pay back
into the fund.

Not Applicable. The project is not related to City
funding.

Regional
Urban Forestry
Program
Policy POSS‐1‐g: Regional Urban Forest.

Maintain and implement incrementally,
through new development projects, additions
to Fresno’s regional urban forest to delineate
corridors and the boundaries of urban areas,
and to provide tree canopy for bike lanes,
sidewalks, parking lots, and trails.

Does Not Conflict. The project would include
landscaping near pedestrian walkways. The project's
preliminary Landscape Plan proposes 130,535
square feet of landscape area, which is 13% of the
total Costco site area and is greater than the
landscape area required (98,162 square feet or 10%
of the total Costco site area). The plan also includes
354 trees on-site, which is greater than the required
number of trees (121 trees). Additionally, the project
would provide 51.3% parking lot shading at 15
years, which is greater than the required 50%
parking lot shading at 15 years.
1 Key or relevant General Plan policies for the City of Fresno GHG Plan Strategy obtained from City of Fresno's 2014 Greenhouse Gas Reduction Plan.

Abbreviations:

ATP - Active Transportation Plan
BRT - Bus Rapid Transit
CalMax - California Materials Exchange
D - Design Element
EV - Electric Vehicle
GHG - greenhouse gas
gpcd - gallons per capita per day
HST - High Speed Train
kV - kilovolt
kWh - kilowatt-hour
LU - Land Use Element
MT - Transportation Element
MWELO - Model Water Efficient Landscape Ordinance
PACE - Property Assessed Clean Energy
PG&E - Pacific Gas and Electric
POSS - Park and Open Space
PU - Public Utilities
RC - Resource Conservation
U.S. - United States
UF - Urban Form Element
VMT - Vehicle Miles Traveled
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Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-53 Item 2 in Section 6.2.1 directs that a project incorporate design features or mitigation measures into the project as needed to demonstrate consistency. The project’s compliance with these elements is described below in detail.

For Item 2a, the project incorporates street and pedestrian design that complies with complete streets concepts. To provide transportation facilities based upon a complete streets concept that facilitates the balanced use of all viable travel modes, the project would include construction of 12-foot-wide pedestrian and bicycle paths along the project’s frontage with West Herndon Avenue and North Riverside Drive. These facilities would be consistent with the City’s Active Transportation Plan (ATP). Trail improvements provided by the proposed project would include Class I bicycle facilities along the project’s frontage on West Herndon Avenue and North Riverside Drive, which is consistent with future facilities identified in the City of Fresno’s ATP (City of Fresno 2016) adjacent to the project site. The proposed project also involves the construction of West Spruce Avenue along the northern project site boundary. The City has identified the construction of Spruce Avenue, including Class II bicycle facilities, as a condition of approval (City of Fresno 2022), which would be consistent with the City of Fresno’s ATP.

Additionally, project’s off-site improvements include construction of bicycle facilities along its western, southern, and northern frontages (North Riverside Drive, West Herndon Avenue, and Spruce Avenue, respectively) and would be consistent with the City of Fresno ATP.

Lastly, applicant would extend West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue. The connection would be consistent with the City of Fresno ATP. The asphalt roadway would include curb, gutter, sidewalk, Class II bicycle facilities, and streetlights.

For Item 2b, the building design will comply with the design requirements included in the City of Fresno Development Code. These include, but are not limited to, the use of enhanced cornices to achieve building articulation requirements, using consistent materials and massing around the entire building and selecting material terminations at intentional locations along the façade instead of at building corners.

Item 2c focuses on alternative energy generation. The project would incorporate renewable energy from PG&E’s “Solar Choice” program, supplying the project with 100 percent renewable energy.

Item 2d focuses on compliance with City water conservation standards. The project would comply with all mandatory indoor/outdoor water use measures implemented by the City and State. The irrigation system would be a water efficient low flow, point source system designed to provide adequate watering to support plant growth and ensure deeply rooted plant material while avoiding excess water application. The system would be programmable, allowing operation during late night and or early morning hours, with multiple start times and cycles. The system would interface with a weather-based sensor that would adjust the amount of water applied to the plant material based on daily weather conditions. Irrigation materials specified for the site would be selected on the basis of durability and ease of maintenance. Landscape irrigation would comply with the California Department of Water Resources Model Water Efficient Landscape Ordinance. Additionally, the project would implement high-efficiency restroom fixtures that would reduce water use and the car wash comply with all regulations pertaining to water conservation and run-off.

Item 3 in Section 6.2.1 concerns implementing project design features suitable for the development type and location, such as enhancing connections to regional bikeways and trail systems. The project’s off-site improvements include construction of bicycle facilities along its western, southern, and northern frontages (North Riverside Drive, West Herndon Avenue, and Spruce Avenue, respectively), thereby providing connections to existing bicycle facilities on those roads. These improvements would be consistent with the City of Fresno ATP.

Moreover, the project would facilitate multi-modal access to these existing facilities through construction of 12-foot-

132 City of Fresno. 2016. Active Transportation Plan. December. Available at: https://www.fresno.gov/wp- content/uploads/2023/07/170022FresnoATPFinal2017Amended042022_compressed-1.pdf. Accessed: August 2025.

Greenhouse Gas Emissions and Climate Change Ascent
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3.7-54 Costco Commercial Center Project Partially Recirculated Draft EIR wide pedestrian and bicycle paths along the project’s frontage with West Herndon Avenue and North Riverside Drive.

These paths would be consistent with the City’s ATP and would support General Plan Policies POSS-3-c and POSS-7- h regarding linking city pathways with parks and the San Joaquin Parkway Trail Networks. The project would not preclude access to existing or planned recreational facilities.

The applicant would extend West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue. The connection would be consistent with the City of Fresno ATP. The asphalt roadway would include curb, gutter, sidewalk, Class II bicycle facilities, and streetlights.

The project also includes a redesignation of Herndon Avenue from Expressway Area to Superarterial, which allows for multiple modes of travel traffic, including pedestrian and bikes. This could lead to further development of these types of non-vehicular facilities, including bike lanes and sidewalks, which are not currently allowed under the Expressway Area designation.

Item 4 in Section 6.2.1 notes that a project must either fill out the Fresno Green checklist point requirements or meet the U.S. Green Building Council’s LEED Program. While this item refers to the Fresno Green checklist for use in evaluating project consistency with the GHGRP, the City retired this checklist program under the 2014 GHGRP. This is because the CalGreen Building Code superseded most of the items addressed in that former program. The project would meet all applicable elements of the CalGreen Building Code in effect at the time of building permit application.

Therefore, the project would meet this last requirement under Section 6.2.1.

As the project includes a General Plan amendment, the project would also be subject to the requirements of “Section

6.2.2 – New Discretionary Development requiring a General Plan Amendment.” The requirements of Section 6.2.2 are as follows133:

1. Comply with all of the measures listed above [in Section 6.2.1] for ministerial and discretionary projects.

2. Ensure that change in land use designation would not result in a significant increase in GHG emissions compared to the existing designation (would require a GHG technical study to quantify GHG emissions and benefits of project design features).

3. Projects currently designated for residential or commercial development that increase development densities and intensities and comply with all other relevant General Plan policies and City design standards are considered to have less than significant GHG impacts.

4. Emissions from stationary sources for new industrial projects are not considered in the significance determination; however, emissions from motor vehicles trips generated by the project and energy efficiency of the building are considered.

5. Projects that propose decreases in development densities or intensities requiring a General Plan will require analysis to determine the impacts on the General Plan land use strategy and must identify mitigation measures to reduce greenhouse gas emissions beyond those required by regulation if needed.

Item 1 of Section 6.2.2 mandates the project to comply with all measures listed in Section 6.2.1 for ministerial and discretionary projects. Those have been addressed above.

Item 2 of the list in Section 6.2.2. notes that the project must ensure the change in land use designation would not result in a significant increase in GHG emissions compared to the existing designation, and notes this requires a GHG technical study to quantify the GHG emissions and benefits of project design features. A GHG technical study was conducted to quantify the GHG emissions and address the benefits of project design features. This study included the emissions from motor vehicle trips, as required by
Item 4 of Section 6.2.2. Such study is reflected in this section as well as in the details set forth in Appendix F. The project proposes a change in the General Plan land use designation;

133 City of Fresno. 2014. General Plan and Development Code Update – Greenhouse Gas Reduction Plan. July. Available here:
https://www.fresno.gov/wp-content/uploads/2023/03/F-2-Greenhouse-Gas-Reduction-Plan.pdf. Accessed: August 2025.

Ascent Greenhouse Gas Emissions and Climate Change
City of Fresno
Costco Commercial Center Project Partially Recirculated Draft EIR 3.7-55 however, the purpose of such change is merely to allow a car wash on the project site. Such change to accommodate the car wash would not itself significantly increase vehicle trips and related GHG emissions.

Item 3 under Section 6.2.2 notes that projects currently designated for commercial development densities and that increase development densities but comply with all other relevant General Plan policies and City design standards are considered to have less than significant GHG impacts. The project includes an amendment to alter the existing designation from Community Commercial to General Commercial. Based on the allowable floor-to-area ratio anticipated under these two designations, the General Commercial designation has the potential to allow development that would generate greater emissions than the Community Commercial zoning designation. As the proposed project would increase allowable development densities and intensities (though the purpose of the amendment in the context of the project is merely to allow the car wash use), compliance with relevant General Plan policies and City design standards is evaluated to determine whether the project will have less than significant GHG impacts, consistent with
Item 3 under Section 6.2.2. Per the discussion above and Table 3.7-8 evaluating General Plan policies related to GHG reduction, as well as the discussion in the Land Use section of the 2024 EIR (Impact 3.10.1), the project will be consistent with relevant General Plan policies and design standards. Thus, under the standards of the GHGRP, the project would result in less than significant GHG impacts.

Summary
Based on the analysis provided above, the project would not conflict with or impede the state’s ability to meet its GHG reduction goals and, therefore, the project’s GHG emissions will be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 3.7-2: Conflict with an Applicable Plan, Policy, or Regulation Adopted for the Purpose of Reducing the Emissions of GHGs
The project would comply with all laws and regulations governing GHG reduction, and would not conflict with an applicable plan, policy or regulation adopted to reduce GHG emissions. Therefore, this impact would be less than significant.

The project would comply with all laws and regulations governing the reduction of GHG emissions. The project aligns with Federal Vehicle Standards, which regulate fuel efficiency and GHG emissions from motor vehicles. Additionally, the project would comply with Title 24 of the California Code of Regulations, which establishes energy efficiency standards for residential and non-residential buildings, contributing to GHG emission reductions. Finally, the project would comply with the California Renewables Portfolio Standards and the Low Carbon Fuel Standard, and would not conflict with the ability of these policies to reduce the carbon intensity of electricity and fuels used in California.

The project would not conflict with applicable state, regional, or local plans and policies adopted to reduce GHG emissions. Such applicable plans and policies are listed in Impact 3.7-1, and are as follows: 2022 Scoping Plan, Fresno COG RTP/SCS, Fresno COG PCAP, and City of Fresno GHGRP. As discussed in Impact 3.7-1, the project would not conflict with applicable plans adopted for the purpose of reducing GHG emissions. Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Greenhouse Gas Emissions and Climate Change Ascent
City of Fresno

3.7-56 Costco Commercial Center Project Partially Recirculated Draft EIR This page is intentionally left blank.

Appendix A
Greenhouse Gas Emissions
Technical Report
Prepared for
Ascent Environmental, Inc.

Sacramento, California
Project Number
1690023335
Date
November 2025

COSTCO COMMERCIAL CENTER

GREENHOUSE GAS EMISSIONS

TECHNICAL APPENDIX

FRESNO, CALIFORNIA

RAMS LL
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Contents

CONTENTS
Page

1. Introduction 1

2. Project GHG Emissions Inventory 2

2.1 Measurement, Resources and Baseline Condition 2

2.1.1 Units of Measurement: Tonnes of CO2 and CO2e 2

2.1.2 Resources 2

2.1.2.1 CalEEMod® Methodology 2

2.1.2.2 OFFROAD2017 4

2.1.2.3 Other Resources 4

2.1.3 Indirect GHG Emissions from Electricity Use 4

2.2 One-Time Emissions 5

2.2.1 Construction Emissions 5

2.2.1.1 Emissions from On-Road Construction Trips 5

2.2.1.2 Emissions from Construction Equipment 6

2.2.1.3 Total Construction Emissions 7

2.2.2 Vegetation Changes 7

2.3 Annual Operational Emissions 7

2.3.1 Area Sources 7

2.3.2 Mobile Sources 7

2.3.2.1 Estimating Mobile Source Emissions 8

2.3.2.2 Mobile Source Emissions 9

2.3.3 Water Supply, Treatment and Distribution 9

2.3.4 Energy Use 9

2.3.5 Solid Waste 10

2.4 Total Annual Operational Emissions 10
TABLES
Table 2-1: Construction Schedule
Table 2-2: Construction Equipment
Table 2-3: Construction Material Movement
Table 2-4: Construction Demolition Assumptions
Table 2-5: Utility GHG Emission Factor Associated with Renewable Portfolio Standard Table 2-6: TRU Greenhouse Gas Emission Calculations
Table 2-7: Summary of GHG Emissions

ATTACHMENTS
Attachment A CalEEMod® Output
Attachment B Operational Mobile Source Emissions Calculations Costco Commercial Center
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Acronyms and Abbreviations Ramboll

ACRONYMS AND ABBREVIATIONS
Acronym Definition
AB Assembly Bill
ACC Advanced Clean Cars
AP-42
Factors
CalEEMod® California Emission Estimator Model®
CalRecycle California Department of Resources Recycling and Recovery CAMX California and Mexico
CARB California Air Resources Board
CEC California Energy Commission
CFCs Chlorofluorocarbons
CH
4 Methane
CO2 carbon dioxide
CO2e carbon dioxide equivalent
EF emission factor
EIR Environmental Impact Report
EMFAC EMission FACtors model
GHG greenhouse gas
GWP global warming potential
HFCs hydrofluorocarbons
IPCC Intergovernmental Panel on Climate Change
lbs Pounds
MDO Market delivery operation
MSW Municipal solid waste
MT metric tons
N2O nitrogen dioxide
NHTSA National Highway Traffic Safety Administration
OFFROAD Off-road Emissions Inventory Program model
PG&E Pacific Gas and Electric
RPS Renewables Portfolio Standards
SAFE Safer Affordable Fuel-Efficient
SCAQMD South Coast Air Quality Management District
TRU transportation refrigeration unit
USEPA United States Environmental Protection Agency
VMT vehicle miles traveled

United States Environmental Protection Agency's Compilation of Air Pollutant Emission Costco Commercial Center
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1 Introduction Ramboll

1. INTRODUCTION
Ramboll US Consulting, Inc. (Ramboll) was retained to assist in preparing the Greenhouse Gas Emissions and Climate Change section of the Draft Environmental Impact Report (EIR) along with this accompanying Greenhouse Gas (GHG) Emissions Appendix for the proposed Costco warehouse and gasoline dispensing facility in Fresno, California (Project).

This GHG Emissions Technical Appendix discusses and documents the methodology used to evaluate GHG emissions related to both construction and operation of the Project.

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2. PROJECT GHG EMISSIONS INVENTORY
This section describes the methodology that Ramboll used to develop the GHG emission inventories associated with the Project, which include one-time emissions (construction emissions and emissions due to vegetation changes) and operational emissions.

Sub-categories of GHG operational emissions include: area sources, energy use, water supply and wastewater, solid waste, and mobile sources. The emissions inventory reflects the reasonably foreseeable change based on the discontinued operation of the Costco Warehouse located at 4500 W Shaw Avenue. For purposes of this analysis, 4500 W Shaw Avenue is assumed to be backfilled by another retail use within the existing shopping center.

2.1 Measurement, Resources and Baseline Condition

2.1.1 Units of Measurement: Tonnes of CO2 and CO2e
effect, such as carbon dioxide (CO2), methane (CH4), nitrogen dioxide (N2O), and water, as well as gases that are only man-made and that are emitted through the use of modern industrial products, such as hydrofluorocarbons (HFCs) and chlorofluorocarbons (CFCs).

GHG emissions are typically measured in terms of mass of carbon dioxide equivalent (CO2e).

CO2e are calculated as the product of the mass of a given GHG and its specific global warming potential (GWP). GWPs of 25 and 298 were used for CH4 and N2O, respectively, for this analysis. In many sections of this report, including Section 2.4, emissions are presented in units of CO2e either because the GWPs of CH4 and N2O were accounted for explicitly, or the CH4 and N2O are assumed to contribute a negligible amount of GWP when compared to the CO2 emissions from that particular emissions category.

In this report, a tonne refers to 1,000 kilograms or a metric ton (MT). Additionally, exact totals presented in all tables and report sections may not equal the sum of components due to independent rounding of numbers.

2.1.2 Resources

2.1.2.1 CalEEMod® Methodology
Ramboll primarily utilized the California Emissions Estimator Model (CalEEMod®) version 2020.4.01 methodology to assist in quantifying the GHG emissions in the inventories presented in this report for the Project. CalEEMod® provides methodology to calculate both construction emissions and operational emissions from a land use development project. It calculates total or annual GHG emissions. Specifically, the model methodology aids the user in the following calculations:

One-time short-term construction emissions associated with demolition, site preparation, grading, building, and paving from off-road construction equipment, and on-road mobile equipment associated with workers, vendors, and hauling.

One-time vegetation sequestration changes, such as permanent vegetation land use changes and new tree plantings.

1 SCAQMD. 2021. California Emissions Estimator Model ®. Available at: https://www.aqmd.gov/caleemod/.

Accessed: August 2025.

In this report, the term "GHGs" includes gases that contribute to the natural greenhouse •
•
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Operational emissions associated with the fully built out land use development, such as on-road mobile vehicle traffic generated by the land uses, off-road emissions from landscaping equipment, natural gas usage in the buildings, electricity usage in the buildings, water usage by the land uses, and solid waste disposal by the land uses.

CalEEMod
® is a statewide program designed to calculate both criteria pollutant and GHG emissions from development projects in California. It was developed under the auspices of the South Coast Air Quality Management District (SCAQMD), with input from other California air districts, and is currently supported by numerous lead agencies for use in quantifying the emissions associated with development projects undergoing environmental review.

CalEEMod
® utilizes widely accepted models for emission estimates combined with appropriate default data that can be used if site-specific information is not available. These models and default estimates use sources such as the United States Environmental Protection Agency (USEPA) AP-42 emission factors,2 California Air Resources Board (CARB) on-road and off-road equipment emission models such as the EMission FACtor model (EMFAC) and the Off-road Emissions Inventory Program model (OFFROAD), and studies commissioned by California agencies such as the California Energy Commission (CEC) and California Department of Resources Recycling and Recovery (CalRecycle).

As mentioned above, CalEEMod
® is based upon the CARB-approved OFFROAD and EMFAC
models. OFFROAD3 is an emission factor model used to calculate emission rates from off-road mobile sources (e.g., construction equipment, agricultural equipment). The off-road diesel emission factors used by CalEEMod® are based on the CARB OFFROAD2011 program.

EMFAC is an emission factor model used to calculate emissions rates from on-road vehicles (e.g., passenger vehicles). CalEEMod® 2020.4.0 contains EMFAC2017 emission factors. The latest version of EMFAC at the time of analysis was the CARB EMFAC2021v1.0.2 model.4 In addition, CalEEMod® contains default values and existing regulation methodologies to use in each specific local air district region. Appropriate statewide default values can be utilized if regional default values are not defined. Ramboll used default factors for the Fresno County area (within the San Joaquin Valley Air Pollution Control District jurisdiction) for the emissions inventory, unless otherwise noted in the methodology descriptions below.

Details regarding the specific methodologies used by CalEEMod® can be found in the CalEEMod® 5

2 The USEPA maintains a compilation of Air Pollutant Emission Factors and process information for several air pollution source categories. The data is based on source test data, material balance studies, and engineering estimates. Available at: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air- emissions-factors. Accessed: August 2025.
3 CARB. 2011. Off Road Mobile Source Emission factors. Available at: https://ww2.arb.ca.gov/our- work/programs/msei/road-categories/road-diesel-models-and-documentation. Accessed: August 2025. 4 CARB. 2021. EMFAC2021. Available at: https://arb.ca.gov/emfac/. Accessed: August 2025. 5 SCAQMD. 2021. California Emissions 2020.4.0. Available at:
https://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/01_user-39-s-guide2020-4-0.pdf.

Accessed: August 2025.
•
's
's
User's Guide and associated appendices.

Estimator Model User's Guide. Version
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2.1.2.2 OFFROAD2017
The latest version of OFFROAD at the time of analysis was OFFROAD2017. The exhaust emission factors for each equipment at each horsepower range were back-calculated from total daily emissions reported in the model output files and annual usage in terms of horsepower-hours for each equipment type in the specified region and calendar year. These emission factors are then used in the calculation of Project emissions for each type of equipment utilized within the Project.

2.1.2.3 Other Resources
Ramboll directly or indirectly relied on emissions estimation guidance from government sponsored organizations, government-commissioned studies of energy use patterns, Project-specific studies (e.g.,
Fresno Costco Relocation Transportation Impact
Analysis),6 and emission estimation software as described above. In cases noted below, third-party studies were also relied upon to support analyses and assumptions made outside of the approach described above.

2.1.3 Indirect GHG Emissions from Electricity Use
Project-related electricity use results in indirect emissions, due to electricity generation activities occurring at off-site power plant locations. For the Project, electrical power will be supplied by Pacific Gas and Electric Company (PG&E) and the Project will participate in the

customers. While the anticipated indirect emissions from electricity are expected to be zero

conservatively models GHG emissions based on PG&E default utility emission factor. The indirect GHG emissions created as a result of Project-related electricity use are calculated through application of the following methodology.

For purposes of electricity use, intensity factors are GHG emission rates from a given source relative to the energy generation activities, and are expressed in terms of the amount of GHG released per megawatt of energy produced. The default electricity intensity factors for PG&E in CalEEMod® for CO2, CH4, and N2O are 203.983, 0.033, and 0.004 pounds (lbs) of GHG per megawatt-hour, respectively. The CalEEMod® CO2 default factor is based on the emission factor provided to Sacramento Metro Air Quality Management District by PG&E. The CH
4 and N2O default factors are based on E-Grid values for the Western Electricity Coordinating Council California and Mexico (CAMX) region. PG&E Power/Utility Protocol reports show that renewable energy sources do not result in any new CO2 emissions.

While CalEEMod® 4 and N2O conservatively were used for this Project, CalEEMod®'s CO2 intensity factor was modified based on PG 2019 Corporate for 2030 (i.e., 60 percent RPS). The 2017 and 2018 mix of renewable and non-renewable energy sources in P energy supply were both used to calculate the intensity factors for P non-renewable energy (for disclosure purposes, P 2020 RPS is 30.6 percent).7 The PG&E data provides the basis for the estimate of the intensity factors for the non-renewable energy; and this data is used to project what the intensity factors will be

6 Kittelson & Associates, Inc. 2023. Fresno Costco Relocation Transportation Impact Analysis. May. 7 PG&E. 2021 Corporate Responsibility and Sustainability Report. Available at:
https://www.pgecorp.com/corp_responsibility/reports/2021/pf04_renewable_energy.html.

Accessed: August 2025.

Kittelson's
PG&E "Solar Choice" program, which is PG&E's program to provide 100% solar electricity to due to the Project's participation in the PG&E "Solar Choice" program, the analysis 's
's
's emission factors for CH
&E's
Sustainability Report, to account for the Renewables Portfolio Standard's (RPS) requirement G&E's
G&E's G&E's
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when the Project reaches build-out. The intensity factor for CO2 is calculated by multiplying the percentage of energy delivered by PG&E from non-renewable energy resources with the intensity factor for non-renewable energy as calculated (see Section 2.3.4 below).

2.2 One-Time Emissions
One-time emissions are those emissions that are not reoccurring over the life of the Project.

This includes emissions associated with construction and emissions associated with land use changes.

2.2.1 Construction Emissions
This section describes the estimation of GHG emissions from construction activities at the Project site. While the exact construction schedule and equipment mix may vary from the current analysis, the GHG emissions are not expected to be higher than that calculated given the conservative assumptions included in this analysis.

The major construction phases included in this analysis are:

Demolition: involves removing buildings or structures.

Site Preparation: involves clearing vegetation (grubbing and tree/stump removal) and removing stones and other unwanted material or debris prior to grading.

Grading: involves the cut and fill of land to ensure the proper base and slope for the construction foundation.

Building Construction: involves the construction of structures and buildings.

Paving: involves the laying of concrete or asphalt such as in parking lots or roads.

Architectural Coating: involves the application of coatings to both the interior and exterior of buildings or structures, the painting of parking lot or parking garage striping, associated signage and curbs, and the painting of the walls or other components such as stair railings inside parking structures.

GHG emissions from these construction phases are attributable to fuel use from construction equipment usage onsite and from on-road worker, vendor, and hauling trips.

Ramboll primarily used CalEEMod® to quantify the construction emissions. The modeled construction schedule is shown in Table 2-1. As shown in Table 2-1, it was assumed that construction of the Project would begin in May 2023 and end in November 2023. The construction off-road equipment list is a Project-specific estimate; the off-road equipment specifications are based on CalEEMod® model defaults.

The construction-related equipment mix assumptions are shown in Table 2-2. Table 2-3 presents the material handling volumes which are anticipated to be imported and exported.

Table 2-4 includes the Project-specific demolition assumptions.

2.2.1.1 Emissions from On-Road Construction Trips
Construction generates on-road vehicle GHG emissions from personal vehicles for worker and vendor commuting, and trucks for soil and material hauling. These emissions are based on the number of trips and vehicle miles traveled (VMT), along with emission factors from EMFAC. Default model trip rates were used for construction. The emissions from mobile •
•
•
•
•
•
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sources were calculated in CalEEMod® with the trip rates, trip lengths, and emission factors for running exhaust from EMFAC as follows:8
Emissions pollutant = VMT * EF running, pollutant
Where:

Emissions pollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EF running, pollutant = emission factor for running emissions On-road construction trip emissions are presented in the CalEEMod® output in Attachment A.

2.2.1.2 Emissions from Construction Equipment
The emissions associated with construction equipment are from off-road equipment engine use based on the equipment list and phase length, and on-road vehicle trips and phase length.

Since the majority of the off-road construction equipment used for construction projects are diesel-fueled, CalEEMod® assumes all of the equipment operates on diesel fuel. The calculations include the running exhaust emissions from off-road equipment. Since the equipment is assumed to be diesel, there are no starting emissions associated with the equipment, as these are de minimis for diesel-fueled equipment. The exhaust emissions are calculated sented
below.9
Where:

EF = Emission factor in grams per horsepower-hour (g/bhp-hr) as processed from OFFROAD2011
Pop = Population, or the number of pieces of equipment AvgHp = Maximum rated average horsepower
Load = Load factor
Activity = Hours of operation
i = equipment type
Emissions for off-road construction equipment for each phase of construction are detailed in Attachment A.

8 SCAQMD. 2021. California Emissions Estimator Model ®
https://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/appendix-a2020-4-0.pdf.

Accessed: August 2025.
9 SCAQMD. 2021. California Emissions Estimator Model ®
https://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/appendix-a2020-4-0.pdf.

Accessed: August 2025.
based on CARB's OFFROAD2011 methodology using the equation pre Emissions Diesel L(EFixPopixAvgHPixLoadixActivityi)
i
User's Guide, Appendix A. Available at:

User's Guide, Appendix A. Available at:

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2.2.1.3 Total Construction Emissions
The Project construction emissions were run within CalEEMod® to generate the annual emissions. The total emissions from construction from all phases for off-road and on-road emissions in 2023 are summarized in Attachment A.

2.2.2 Vegetation Changes
Vegetation changes that occur as a result of land use development constitute a one-time change in the carbon sequestration capacity of a project site. In this case, the land the Project will occupy is vacant/unvegetated and the new landscaping is conservatively not included.

2.3 Annual Operational Emissions
This section describes the estimation of GHG emissions from operational activities at the Project site. The operational emissions were calculated with CalEEMod ® and separately for
mobile source emissions. Operational GHG emissions are calculated for landscaping, natural gas and electricity usage, on-road mobile trips, water usage, and solid waste generated.

Operational emissions are evaluated for the first year of Project Operation in 2023.

2.3.1 Area Sources
Area sources are direct sources of GHG emissions, such as emissions from landscaping activities. The area source GHG emissions included in this analysis are landscaping-related fuel combustion sources, such as lawn mowers.

2.3.2 Mobile Sources
The GHG emissions associated with on-road mobile sources are generated from vehicles, members vehicles, and delivery trucks visiting the site. The GHG emissions associated with on-road mobile sources include running and starting exhaust emissions.

Running emissions are dependent on VMT. Starting emissions are associated with the number of starts or time between vehicle uses and the assumptions used in determining these values are described below. Ramboll calculated mobile source emissions using trip rates and trip length information based on analyses conducted by Kittelson.

The analysis includes the benefit of reductions from some adopted regulatory programs, which are accounted within EMFAC2021 as follows:

Assembly Bill (AB)
January 1, 2005, to reduce GHG emissions from non-commercial passenger vehicles and light-duty trucks of model year 2009 and thereafter. EMFAC2021 includes emission reductions for non-commercial passenger vehicles and light-duty trucks of model year 2017
2025.

The Advanced Clean Cars (ACC) program adopted by CARB, introduced in 2012, combines the control of smog, soot causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2015 through 2025. EMFAC2021 includes reductions associated with this regulation that are represented in this analysis. employees'
• 1493 ("the Pavley Standard") required CARB to adopt regulations by •
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The USEPA/National Highway Traffic Safety Administration (NHTSA) advanced fuel economy and GHG standards (Phase 1) were adopted in 2011 for medium and heavy-duty trucks for model years 2014-2018.10 This Heavy-Duty National Program is intended to reduce fuel use and GHG emissions from medium- and heavy-duty vehicles, semi-trucks, pickup trucks and vans, and all types and sizes of work trucks and buses in between. EMFAC2021 includes reductions associated with this regulation that are represented in this analysis.

The USEPA/NHTSA advanced fuel economy and GHG standards (Phase 2) were adopted in 2016 for medium- and heavy-duty trucks for model years 2018 and beyond. 11 The
Phase 2 program includes technology-advancing standards that substantially reduce GHG emissions and fuel consumption resulting in an ambitious, yet achievable, program that will allow manufacturers to meet the applicable standards over time, at reasonable phased in, beginning with model year 2021 and culminating with model year 2027.12 In June 2020, CARB released EMFAC off-model adjustment factors to account for the Final Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule.13 The SAFE Rule has been incorporated into this analysis as it is incorporated in EMFAC2021.

2.3.2.1 Estimating Mobile Source Emissions
Mobile source emissions calculation requires trip rates and trip lengths for each different trip type in the Project (e.g., employee vehicles member vehicles, and delivery trucks).

The following sections describe the methodology to derive the necessary inputs.

Trip Generation Rates
The trip generation rates for the Project were based on Kittelson data. The trips for the northeast corner of W. Herndon Ave. and N. Riverside Dr (Herndon/Riverside) and 4500 W Shaw Ave are shown in Attachment B in Table B-1a and Table B-1b.

Trip Lengths
The Project trip lengths were based on the Kittelson analysis, other than the market delivery operation (MDO) delivery truck trip length, which was based on the average routed round trip length for Fresno MDO deliveries. These trip lengths for Herndon/Riverside and 4500 W Shaw Ave are represented in Attachment B, Table B-1a and Table B-1b, respectively.

10 USEPA, Office of Transportation and Air Quality. 2011. Available at: https://www.gpo.gov/fdsys/pkg/FR-2011- 09-15/pdf/2011-20740.pdf. Accessed: August 2025.
11 USEPA, Office of Transportation and Air Quality. 2016. Available at: https://www.gpo.gov/fdsys/pkg/FR-2016- 10-25/pdf/2016-21203.pdf. Accessed: August 2025.
12 The emission reductions attributable to Phase 2 of the regulations for medium- and heavy-duty trucks were not included in the Project's emissions inventory due to the difficulty in quantifying the reductions. Excluding these reductions results in a more conservative (i.e., higher) estimate of emissions for the Project. 13 CARB. 2020. EMFAC Off-Model Adjustment Factors for Carbon Dioxide (CO2) Emissions to Account for the SAFE Vehicles Rule Part One and the Final SAFE Rule. Available at: https://ww2.arb.ca.gov/sites/default/files/2023- 02/emfac_off_model_co2_adjustment_factors_06262020-final.pdg. Accessed: August 2025. •
•
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Fleet Mix
The fleet mixes derived based on CalEEMod® and EMFAC2021 were used to determine the mix of light-duty vehicles used for member vehicles and employee vehicles. The MDO delivery trucks, fuel delivery trucks, and warehouse delivery trucks were assumed to be diesel-fueled heavy-heavy-duty trucks. The fleet mixes for the operational mobile trips are shown in Table B-2 of Attachment B.

Transport Refrigeration Units
The Project includes Transport Refrigeration Units (TRUs), which are refrigeration systems powered by diesel internal combustion engines designed to refrigerate or heat perishable products that are transported in various containers, including truck vans, semi-truck trailers, shipping containers, and railcars. These TRUs account for approximately 15% of the warehouse delivery trucks. This analysis assumes that TRUs are plugged in at the loading dock. OFFROAD2021 has emission factors for TRUs, which were obtained for Fresno County in 2023. Emissions of CO
2 from TRUs were estimated, as shown in Table 2-6.

2.3.2.2 Mobile Source Emissions
The weighted emission factors from running exhaust for each vehicle type are presented in Attachment B, Table B-3. Starting exhaust emission factors for each vehicle type are displayed in Attachment B, Table B-4. Idling emission factors for passenger vehicles and delivery trucks are presented in Attachment B, Table B-5. The overall mobile source emissions from running, starting, and idling are shown in Attachment B, Table B-6a and B-6b, along with the VMT, trips, and idling durations.

2.3.3 Water Supply, Treatment and Distribution
Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute the Project's water and wastewater. The amount of electricity required to convey, treat, and distribute water depends on the volume of water as well as the sources of the water. Additionally, direct CH4 and N2O emissions result from the treatment of wastewater.

Water demand and wastewater generation values were based on CalEEMod® defaults.

The water usage and associated GHG emissions are shown in Attachment A.

2.3.4 Energy Use
Energy usage within buildings (e.g., electricity and natural gas fueled equipment) contribute . Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions.

To estimate GHG emissions from the natural gas and electricity usage for the Project, Ramboll utilized CalEEMod® default assumptions, which incorporate Title 24 2019 Standards.

Table 2-5 identifies the emission factors for electricity (i.e., pounds of CO2 per megawatt-hour delivered) used in this analysis. As illustrated in Table 2-5, a PG&E-specific emission factor that accounts for interpolation between the 33 percent RPS required by 2020 and 60 percent RPS required by 2030, as discussed in Section 2.1.3, was calculated based on 41.1 percent RPS in 2023. T
customers. Therefore,
the anticipated indirect emissions from electricity are expected to be zero. The reported GHG to the facility's GHG inventory
he Project will participate in the PG&E "Solar Choice"
program, which is PG&E's program to provide 100% solar electricity to Costco Commercial Center
Greenhouse Gas Emissions Technical Report
Fresno, California
10 Project GHG Emissions Inventory Ramboll
emissions from energy are conservative represented based on the default utility emission factor.

The annual natural gas and electricity use and corresponding GHG emissions for the Project are shown in Attachment A.

2.3.5 Solid Waste
Municipal solid waste (MSW) is the amount of material that is disposed of by landfilling, recycling, or composting. CalEEMod
® calculates the indirect GHG emissions associated with waste that is disposed of at a landfill. The program uses annual waste disposal rates from the CalRecycle data for individual land uses. CalEEMod
® uses the overall California Waste
Stream composition to generate the necessary types of different waste disposed into landfills. The program quantifies the GHG emissions associated with the decomposition of the waste, which generates methane based on the total amount of degradable organic carbon.

The program quantifies the CO2 emissions associated with the combustion of methane, if applicable. Default landfill gas concentrations were used as reported in Section 2.4 of AP-42.

The Intergovernmental Panel on Climate Change (IPCC) has a similar method to calculate GHG emissions from MSW in its 2006 Guidelines for National Greenhouse Gas Inventories.

Solid waste generation associated with the Project is based on default values for waste generation in CalEEMod® solid waste generation and GHG emissions associated with solid waste are provided in Attachment A.

2.4 Total Annual Operational Emissions
As shown in Table 2-7, the Project emissions are projected to be 22,428 MT CO2e per year.

The total GHG emissions from Project construction are forecast to be 1,047 MT CO2e and are summarized in Attachment A for construction off-road equipment and mobile trips. When amortized over a period of 30 years, the emission estimates for the Project construction become 35 MT CO2e/yr.14 The total GHG emissions of 22,428 MT CO2e per year includes the amortized construction emissions.

14 This approach to one-time construction and vegetation change GHG emissions is based on the GHG Threshold Working Group Meeting #13 Minutes from August 26, 2009. Available at: http://www.aqmd.gov/docs/default- source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting- 13/ghg-meeting-13-minutes.pdf. Accessed: August 2025.
. The Project's
Costco Commercial Center
Greenhouse Gas Emissions Technical Report
Fresno, California
Ramboll
TABLES
Table -1. Construction Schedule
Costco Commercial Center
Fresno, California
CalEEMod®
Phase Type1 Start Date1 End Date1
Phase
Duration2
(days)
Demolition 5/1/2023 5/8/2023 7
Site Preparation 5/1/2023 5/8/2023 7
Grading 5/9/2023 6/12/2023 30
Grading/BC Overlap 6/13/2023 7/5/2023 20
Building Construction 7/6/2023 11/10/2023 110
Paving 7/29/2023 9/13/2023 40
Architectural Coating 9/14/2023 11/10/2023 50
Notes:
1 Construction phases and duration are based on Project-specific estimates. 2 The construction work week was assumed to be 6 days per week.

Abbreviations:

CalEEMod® - California Emissions Estimator Model

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2 Table -2. Construction Equipment
Costco Commercial Center
Fresno, California
Phase Name
Offroad Equipment Type 1
Number of
Equipment1
Usage Hours2
(hours/day)
Equipment
Horsepower2
(hp)
Equipment Load
Factor2
Concrete/Industrial Saws 1 8 81 0.73
Excavators 3 8 158 0.38
Rubber Tired Dozers 2 8 247 0.4
Site Preparation Tractors/Loaders/Backhoes 4 8 97 0.37
Graders 3 8 187 0.41
Other Construction Equipment 2 8 401 0.42
Paving Equipment 1 8 132 0.36
Rubber Tired Dozers 4 8 247 0.4
Scrapers 2 8 367 0.48
Surfacing Equipment 1 8 263 0.3
Tractors/Loaders/Backhoes 2 8 97 0.37
Excavators 3 8 158 0.38
Rough Terrain Forklifts 2 8 100 0.4
Rubber Tired Dozers 3 8 247 0.4
Tractors/Loaders/Backhoes 3 8 97 0.37
Excavators 3 8 158 0.38
Rough Terrain Forklifts 2 8 100 0.4
Rubber Tired Dozers 3 8 247 0.4
Tractors/Loaders/Backhoes 3 7 97 0.37
Rough Terrain Forklifts 1 8 100 0.4
Rubber Tired Dozers 2 8 247 0.4
Tractors/Loaders/Backhoes 2 8 97 0.37
Architectural Coating Air Compressors 1 6 78 0.48
Notes:

Abbreviations:

CalEEMod® - California Emissions Estimator Model
hp - horsepower
2 Equipment usage hours, horsepower, and load factor are based on CalEEMod ® defaults, with the exception of the horsepower value for "Other Construction Equipment" during the Grading phase. The "Other Construction Equipment" represents soil compactors and is based is based on project-specific data.

Demolition
Grading
Grading/BC Overlap
Building Construction
Paving
1 Number and type of offroad equipment for the Grading, Grading/BC Overlap, Building Construction, and Paving phases based on Project- specific data. Equipment used in the Demolition and Architectural Coating phases are based on CalEEMod ® default values.

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2 Table -3. Construction Material Movement
Costco Commercial Center
Fresno, California
Phase Name
Material Imported1
(yd3)
Material Exported1
(yd3)
Grading 60,000 0
Grading/BC Overlap 0 3,000
Notes:
1 Soil import and export quantities based on project-specific data.

Abbreviations:
yd3 - cubic yard

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2 Table -4. Construction Demolition Assumptions
Costco Commercial Center
Fresno, California
Phase Name Size Metric Unit Amount1
Demolition/Site Prep Tons of Debris 10
Notes:
1 Square-footage quantity based on project-specific data.

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2 Table 2-5. Utility GHG Emission Factor Associated with Renewable Portfolio Standard Costco Commercial Center
Fresno, California
Energy Delivered
[MWh]
2017 2018 Averaae Units
CO2 Intensity Factor per Total Energy 210 206 208 lbs CO2/MWh delivered Delivered 1 % of Total Energy From Renewables2 33.0% 38.9% 36.0%
CO2 Intensity Factor per Total Non- 314 338 325 lbs CO2/MWh delivered Renewable Energy3 Calculated Intensity Factors for Total Energy Delivered 4 2020 RPS (33%) 210.4 226.2 218.0 lbs CO2/MWh delivered
2030 RPS (60%) 125.6 135.1 130.1 lbs CO2/MWh delivered
2023 RPS5 185.0 198.9 191.6 lbs CO2/MWh delivered
Emission Factors
(lb/MWh1
Year CO2 CH4 N20 CO2e
2018 208.4 0.033 0.004 210.4
2023 191.61 0.033 0.004 193.6
Notes:
12017 and 2018 intensity factors per total energy delivered available at: https://www.theclimateregistry.org/our members/cris-public-reports/. Accessed: September 2021. 2Percent of total energy from RPS-eligible renewables are from the PG&E 2018 and 2019 Corporate Responsibility Reports. Available at: http://www.pgecorp.com/corp_responsibility/reports/2018/assets/PGE_CRSR_2018.pdf and http://www.pgecorp.com/corp_responsibility /reports/2019/assets/PGE_CRSR_2019.pdf. Accessed: September 2021. 3 The emissions metric presented here is calculated based on the total CO2 emissions divided by the energy delivered from non-renewable sources.
4 The intensity factors for default RPS assumption are calculated by multiplying the percentage of energy delivered from non-renewable energy by the CO2 emissions per total non-renewable energy metric calculated above. The emission factors presented here are 33% RPS for 2020 and 60% RPS for 2030. The estimate provided here and the PUP reports issued by PG&E assume that renewable energy sources do not result in any CO2 emissions. 5The RPS percentage for the 2023 future year is interpolated from the goals of 33% RPS in 2020 and 60% RPS in 2030.

Emission factors for 2023 are estimated using values from 2017 and 2018, as these were the most recent emission factors available at the time of analysis.

Abbreviations:

CO2 - carbon dioxide
GHG - greenhouse gases
lbs - pounds
MT - metric tonnes
MWh - megawatt-hour
PG&E - Pacific Gas and Electric
PUP - Power/Utility Protocol
RPS - Renewable Portfolio Standards

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Fresno City CouncilMay 21, 2026

Fresno City Council
May 21, 2026