26-41 Initial Study Mitigated Negative Declaration — Fresno City Council, September 3, 2026 (part 1 of 3)

1 APPENDIX G/INITIAL STUDY FOR A MITIGATED NEGATIVE DECLARATION Environmental Checklist Form for:

Affordable Cottage Home Village Development at Belmont and Dewitt Project

1. Project Title:

Affordable Cottage Home Village Development at Belmont and Dewitt Project

2. Lead Agency Name and Address:

City of Fresno
Planning and Development Department
2600 Fresno Street
Fresno, CA 93721

3. Contact Person and Phone Number:

Keng Lee, Project Manager
City of Fresno
Housing Production Division, Planning & Development
(559) 621-8050

4. Project Location:

The Project site consists of an approximately 9.7- acre vacant, City -owned parcel located on the north side of East Belmont Avenue and North Dewitt Avenue (Assessor’s Parcel Number [APN] 456-030-60T) (Figure 1).

5. Project Sponsor’s Name and Address:

City of Fresno
2600 Fresno Street
Fresno, CA 93721

6. General and Community Plan Land Use Designation:

Residential Multi-Family, Medium High Density (RM-1) and Corridor/Center Mixed-Use (CMX)

7. Zoning:

Residential Multi-Family, Medium High Density (RM-1) and Corridor/Center Mixed-Use (CMX)
2 8. Description of Project:

The City of Fresno (City) is proposing the Affordable Cottage Home Village Development at Belmont and Dewitt Project (Project), a mixed-use affordable housing development that would include a combination of residential and local -serving retail space of less than 50,000 square feet and associated on-site improvements designed to support the surrounding community. The Project site consists of an approximately

9.7-acre vacant, City-owned parcel located on the north side of East Belmont Avenue and North Dewitt Avenue (Assessor’s Parcel Number [APN] 456- 030-60T) (Figure 1).

The underlying parcels of the Project site were previously merged, and the Project site is now considered to have split zoning. The western Project parcel is 4.17 acres and zoned Residential Multi-Family, Medium High Density (RM -1), which allows up to 16 dwelling units per acre and building heights up to 40 feet. The eastern Project parcel is

5.53 acres and zoned Corridor/Center Mixed- Use (CMX), which allows vertical or horizontal mixed-use development with building heights up to 60 feet and no specified density limit, including ground-floor commercial uses with residential, office, and other supportive uses above.

The proposed Project includes the construction of up to 120 new residential units , up to 15,000 square feet of retail/commercial space, and associated on- site improvements. The proposed Project involves the construction of a mixed-use affordable housing development on the eastern Project parcel, including a mix of American National Standards Institute (ANSI) 119.5- certified mobile tiny homes on wheels, California Residential Code ( CRC)-certified prefabricated factory -built tiny homes, and retail/commercial space designed to accommodate small businesses. The proposed Project also includes the construction of multi-family residential development on the western Project parcel. The proposed Project is estimated to result in up to approximately 240 new residents and up to a maximum of 800 new vehicle trips.

Buildings would be all-electric, and the proposed Project would include the construction of 231 new parking stalls for residential and commercial uses, including 1 0 electric vehicle (EV)-capable, 26 EV-ready spaces, and five EV supply vehicle (EVSE) spaces for residential uses and 25 EV -capable and six EVSE spaces for commercial uses, in accordance with 2022 California Green Building Standards Code ( CALGreen) requirements. The Project also includes the construction of a private on-site park facility that would primarily serve on- site residents and would be available to other members of the public through a paid membership- based system. The proposed Project would require minor off -site improvements for the extension of existing utility infrastructure and right-of-way (ROW) improvements.

Construction
Construction activities would occur over a period of 24 months, beginning in November 2025 and ending in November 2027. Construction activities would result in approximately 9.7 acres of ground disturbance, including approximately 15,649 cubic yards (CY) of cut and fill. Utility trenching would require excavation to a maximum depth of approximately 6 feet. The proposed Project would not require any tree removal or
trimming. Construction activities would occur during daytime hours (9:00 a.m. –4:00 3 p.m.). The construction staging area would be located within the Project site. Project construction is expected to require minimal workers and associated vehicle trips because all residential units would be constructed off -site. Construction workers are expected to be sourced from the local workforce. Construction equipment would include up to two bulldozers, backhoe loaders, excavators, cranes, concrete mixers, and dumpsters.

9. Surrounding land uses and setting:

Planned Land Use Existing Zoning Existing Land Use
North City: Open Space (OS),
Light Industrial (IL)
City: OS, IL City: OS, IL
East City: CMX City: CMX City: CMX
South
City: Residential Single-
Family, Medium Low
Density (RS-4)
County of Fresno
(County): Single Family
Residential (R1BNB)
City: RS-4
County: R1B NB
City: RS-4
County: R1B NB
West City: RM-1 City: RM-1 City: RM-1

10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):

San Joaquin Valley Air Pollution Control District (SJVAPCD) (e.g., Dust Control Plan Approval letter and compliance with Rule 9510 – Indirect Source Review)

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Pub lic Resources Code
(PRC) Section 21080.3.1? If so, has consultation begun? The State requires lead agencies to consider the potential effects of proposed projects and consult with California Native American Tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Resources through the California Environmental Quality Act (CEQA) Guidelines. Pursuant to California Public Resources Code (PRC) Section 21080.3.1, before public distribution of the document, the lead agency shall begin consultation with the California Native American Tribe that is traditionally and culturally affiliated with the geographical area of the proposed project. Such significant cultural resources are either sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a Tribe which is either on or eligible for inclusion in the California Historic Register or local historic register, or, the lead agency, at its discretion, and support by substantial evidence, choose to treat the resources as a Tribal Cultural Resources (PRC Section 21074(a)(1-2)). According to the most recent census data, California is home to 109 currently recognized Indian 4 Tribes. Tribes in California currently have nearly 100 separate reservations or Rancherias. Fresno County has a number of Rancherias such as Table Mountain Rancheria, Millerton Rancheria, Big Sandy Rancheria, Cold Springs Rancheria, and Squaw Valley Rancheria. These Rancherias are not located within the city limits.

Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process ( see PRC Section 21083.3.2.). Information may also be available from the California Native American Heritage Commission (NAHC) Sacred Lands File (SLF) per PRC Section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that PRC Section 21082.3(c) contains provisions specific to confidentiality.

Pursuant to Assembly Bill (AB) 52, Native American T ribes traditionally and culturally affiliated with the Project area were invited to consult regarding the proposed Project based on a list of contacts provided by the NAHC. The City mailed notices of the proposed Project to each of these Tribes on July 1, 2025, which included the required 30-day time period for Tribes to request consultation, which ended on August 1, 2025.

All Tribes that were contacted declined consultation.

5 Figure 1. Project Location Map.

6 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Agriculture and Forestry Resources
☐ Air Quality ☐ Biological Resources
☐ Cultural Resources ☐ Energy
☐ Geology/Soils ☐ Greenhouse Gas Emissions
☐ Hazards and Hazardous Materials ☐ Hydrology/Water Quality ☐ Land Use/Planning ☐ Mineral Resources
☐ Noise ☐ Population/Housing
☐ Public Services ☐ Recreation
☐ Transportation ☐ Tribal Cultural Resources
☐ Utilities/Service Systems ☐ Wildfire
☐ Mandatory Findings of Significance
DETERMINATION: (To be completed by the Lead Agency)
On the basis of this initial evaluation:
___ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. _X_ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
___ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT (EIR) is required. ___ I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An EIR is required, but it must analyze only the effects that remain to be addressed. 7 ___ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Keng Lee, Project Manager Date
EVALUATION OF ENVIRONMENTAL IMPACTS:

1. For purposes of this Initial Study, the following answers have the corresponding meanings:
a. “No Impact” means the specific impact category does not apply to the project, or that the record sufficiently demonstrates that project specific factors or general standards applicable to the project would result in no impact for the threshold under consideration.
b. “Less Than Significant Impact” means there is an impact related to the threshold under consideration, but that the potential impact would be less than significant.
c. “Less Than Significant with Mitigation Incorporat ed” means there is a potentially significant impact related to the threshold under consideration, however, with the mitigation incorporated into the project, the impact would be less than significant.
d. “Potentially Significant Impact” means there is substantial evidence that an effect resulting from the proposed project may be significant related to the threshold under consideration.

2. A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project -specific screening analysis).

3. All answers must take account of the whole action involved, including off -site as well as on-site, cumulative as well as project -level, indirect as well as direct, and construction as well as operational impacts.
8/12/2026
8 4. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required.

5. "Negative Declaration: Less Than Significant With Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less t han Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from, "Earlier Analyses," as described in (6) below, may be cross-referenced).

6. Earlier analyses may be used where, pursuant to the tiering, Program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measur es based on the earlier analysis.
c. Mitigation Measures. For effects that are "Less than Significant with Mitigation Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

7. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances).

Reference to a previously prepared or outside document should, where appropriate, include a ref erence to the page or pages where the statement is substantiated.

8. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

9. The explanation of each issue should identify:
a. The significance criteria or threshold, if any, used to evaluate each question; and
b. The mitigation measure identified, if any, to reduce the impact to less than significance.

9 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
I. AESTHETICS – Except as provided in PRC Section 21099, would the project:
a) Have a substantial adverse
effect on a scenic vista? X
b) Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within a state scenic
highway?
X
c) In non- urbanized areas,
substantially degrade the existing
visual character or quality public
views of the site and its
surroundings? (Public views are
those that are experienced from
publicly accessible vantage point).

If the project is in an urbanized
area, would the project conflict
with applicable zoning and other
regulations governing scenic
quality?
X
d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
X

DISCUSSION
a) Have a substantial adverse effect on a scenic vista? No Impact. A scenic vista is a viewpoint that provides expansive views of a highly valued landscape for the public’s benefit. The approved 2014 Fresno General Plan1 identifies six locations along the San Joaquin River bluffs as designated vista points from which views should be maintained. Scenic vistas within the City could provide distant views of features such as the San Joaquin River to the north and the foothills of the Sierra Nevada Mountains to the east. The Project site is not located within the viewshed of any of the scenic vista points identified in the General Plan and would not

1 City of Fresno. 2014a. Fresno General Plan. Adopted December 18. Available online at:
https://www.fresno.gov/wp-content/uploads/2023/03/upload_temp_Consolidated-GP-10-13- 2022_compressed.pdf. Accessed June 2025.
10 result in adverse effects on a scenic vista . Further, the Project site is located approximately 0.12 mile northeast of Minnewawa Avenue, which is designated as a scenic collector in the General Plan . However, the Project site would not be visible from Minnewawa Avenue due to distance and intervening development and would have no adverse scenic effect. Therefore, no impact would occur, and mitigation is not required.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. According to the California Department of Transportation (Caltrans) State Scenic Highway Mapping System2, there are no eligible or officially designated State Scenic Highways within the City of Fresno. Fresno County has two eligible State Scenic Highways—a portion of State Route (SR-) 180, located approximately 7 miles east of the City, and a portion of SR -168, located approximately 5 miles east of City.

The nearest officially designated State Scenic Highway is located more than 30 miles northeast of the City within Madera County. Since there are no eligible or officially designated State Scenic Highways within or in close proximity to the P roject site , implementation of the proposed Project would not damage scenic resources within a designated State Scenic Highway. Therefore, no impact would occur, and mitigation is not required.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less than Significant Impact. The Project site is located on an approximately

9.7-acre vacant parcel within the RM -1 and CMX zone districts and land use designations in an urbanized area of the City of Fresno. Surrounding land uses include industrial uses to the north, existing residences to the south and west, and undeveloped land within the CMX zone district and land use designation to the east.

The Project includes the construction of up to 120 new residential units, up to 15,000 square feet of retail/commercial space, and associated site improvements . The Project includes the construction of mixed- use development on the eastern Project parcel, including a mix of American National Standards Institute (ANSI) 119.5-certified mobile tiny homes on wheels, CRC -certified prefabricated factory -built tiny homes, and retail/commercial space designed to accommodate small businesses. The Project also includes the construction of multi -family residential development of the western Project parcel. The proposed Project would require minor off -site improvements for the extension of existing utility infrastructure and ROW improvements. The Project also includes the construction of a private on-site park facility that would primarily

2 California Department of Transportation. Scenic Highways. Available online at:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic- highways. Accessed June 2025.
11 serve on-site residents and would be available to other members of the public through a paid membership-based system.

The proposed Project would be consistent with the RM -1 zone district, which allows for 16 dwelling units per acre and structures up to 40 feet in height as well as park facilities and the CMX zone district, which allows for vertical or horizontal mixed- use development with building heights up to 60 feet as well as park facilities . The design of the proposed residential and commercial development would be consistent and visually compatible with the uses and scale of existing development in the Project vicinity and, therefore, would not result in a substantial change to the visual character of the P roject site and surrounding area. As discussed below in Impact Discussion I.d), the proposed Project would not create a new source of substantial light or glare.

Additionally, the proposed Project would not degrade the visual character or quality of the Project site and its surroundings . T herefore, impacts would be less than significant, and mitigation is not required.
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than Significant Impact. The Project site is located in an urbanized area subject to preexisting exterior lighting from surrounding developments, existing street lighting, and intermittent vehicle headlights. The proposed Project includes the construction of a mixed- use development, including up to 120 affordable residential units, up to 15,000 square feet of retail/ commercial space, and associated site improvements, resulting in new sources of outdoor lighting. New sources of light and glare associated with the proposed Project would be standard and used for illumination purposes only and would not be substantial in the context of existing lighting sources in the Project vicinity. New outdoor lighting associated with the proposed Project would be required to comply with Fresno Municipal Code Section 15-2015 (Outdoor Lighting and Illumination), as well as applicable standards under the California Building Code (CBC; California Code of Regulations [CCR] Title 24) to minimize potential light and glare impacts on daytime and nighttime views. All lighting would be used for illumination purposes only and directed downward to minimize light spillover onto surrounding properties. The hours of operation of the private on-site park facility and associated lighting would be limited to the hours of 7:00 a.m. and 10:00 p.m. Proposed construction activities would be limited to daytime hours ( 9:00 a.m.–4:00 p.m.) and would not require the installation of temporary nighttime lighting.

Based on compliance with the Municipal Code and CBC standards, the proposed Project would not create a new source of light and glare. Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.
12 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an op tional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Departm ent of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted b y the California Air Resources Board. Would the project:
a) Convert Prime Farmland,
Unique Farmland, or Farmland of
Statewide Importance (Farm -
land), as shown on the maps
prepared pursuant to the
Farmland Mapping and Monito-
ring Program of the California
Resources Agency, to non-
agricultural use?
X
b) Conflict with existing zoning for
agricultural use, or a Williamson
Act contract?
X
c) Conflict with existing zoning for,
or cause rezoning of, forest land
(as defined in Public Resources
Code section 12220(g)),
timberland (as defined by Public
Resources Code section 4526), or
timberland zoned Timberland
Production (as defined by
Government Code section
51104(g))?
X
d) Result in the loss of forest land
or conversion of forest land to
non-forest use?
X
13 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Involve other changes in the
existing environment which, due
to their location or nature, could
result in conversion of Farmland,
to non- agricultural use or
conversion of forest land to non-
forest use?
X

DISCUSSION
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
No Impact. The Project site is underlain by land designated by the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP) 3 as
Grazing Land. Therefore, the proposed P roject would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a non- agricultural use. Further, the Project site is located within an urbanized area of the City of Fresno and is surrounded by industrial uses to the north, existing residences to the south and west, and undeveloped land within the CMX zone district and land use designation to the east. The Project site was used for agricultural production between 1937 and the late 1970s and had been primarily fallow since the 1980s , with the exception of a small 1.5-acre plot by an independent farmer between 2002 and 2009. 4 The Project site has been vacant since 2009 and is no longer used or zoned for agricultural uses . There are no agricultural uses located within or adjacent to the Project site , and the Project site is no longer suitable for significant agricultural production or grazing because of its size and location. The proposed Project would not result in the conversion of agricultural land to non- agricultural use. Therefore, no impact would occur, and mitigation is not required.
b) Conflict with existing zoning for agricultural use or a Williamson Act contract? No Impact. The Project site is located in an RM-1 and CMX zone districts and is not within the Agriculture zone district in the General Plan. The Project site is not subject to a Williamson Act contract. Development of the proposed Project would not conflict

3 California Department of Conservation. 2022. California Important Farmland Finder. Available online at:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed June 2025. 4 Krazan and Associates, Inc. (Krazan). 2025. Phase I Environmental Site Assessment, Cottage Home Development, North of Belmont Avenue & Dewitt Avenue, APN 456-030-60T, Fresno, California, 93727. June 17.
14 with existing zoning for agricultural use or a Williamson Act contract . Therefore, no impact would occur, and mitigation is not required.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. The Project site is located within an existing urban area and the City’s RM-1 and CMX zone districts and land use designations. The Project site is not within forest land, timberland, or timberland production land use or zoning designations. The proposed Project would not conflict with the existing zoning for, or cause rezoning of, forest land or conversion of forest land to non-forest uses. Therefore, no impact would occur, and mitigation is not required.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. Please refer to Impact Discussion II.c) . The proposed P roject would not result in the loss of forest land or conversion of forest land to non- forest uses.

Therefore, no impact would occur, and mitigation is not required. e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non- agricultural use or conversion of forest land to non-forest use?
No Impact. Please refer to Impact D iscussions II.a) and II.c). The P roject site is located within an existing urban environment and would not result in the conversion of farmland to non- agricultural uses or forest land to non- forest uses. Therefore, no impact would occur, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.
15 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
III. A IR QUALITY – Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct
implementation of the applicable
air quality plan ( e.g., by having
potential emissions of regulated
criterion pollutants which exceed
the San Joaquin Valley Air
Pollution Control Districts
(SJVAPCD) adopted thresholds
for these pollutants)?
X
b) Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is non -attainment
under an applicable federal or
state ambient air quality standard
(including releasing emissions
which exceed quantitative
thresholds for ozone precursors)?
X
c) Expose sensitive receptors to
substantial pollutant
concentrations?
X
d) Result in other emissions (such
as those leading to odors)
adversely affecting a substantial
number of people?
X

DISCUSSION
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact . CEQA requires that certain proposed projects be analyzed for consistency with the applicable air quality plan. An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a non-attainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. The City of Fresno is located within the San Joaquin Valley Air Basin (SJVAB) and is under the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). The SJVAB is designated as Nonattainment -Extreme for the 16 8-hour ozone standard, Maintenance- Serious for the particulate matter less than 10 microns in diameter (PM 10) standard, and Nonattainment -Moderate for the particulate matter less than 2.5 microns in diameter (PM 2.5) standard under the National Ambient Air Quality Standards (NAAQS) and as Nonattainment for the 1-hour and 8-hour ozone standards and the PM 10 and PM2.5 standards under the California Ambient Air Quality Standards (CAAQS).

To bring the SJVAB into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8-Hour Ozone Standard (2022 Ozone Plan)5 in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8- hour ozone standard. To assure the SJVAB’s continued attainment of the U.S.

Environmental Protection Agency (USEPA) respirable particulate mat ter (PM 10) standard, the SJVAPCD adopted the 2023 Maintenance Plan and Redesignation Request for the Revoked 1 Hour Ozone Standard (2023 Maintenance Plan) 6.

SJVAPCD Regulation VIII (Fugitive PM 10 Prohibitions) is designed to reduce PM 10 emissions generated by human activity. The SJVAPCD adopted the 2024 Plan for the 2012 PM2.5 Standard (2024 PM2.5 Plan)7 to address the USEPA federal annual PM2.5 standard of 12 micrograms per cubic meter (µg/m3), established in 2012.

The SJVAPCD has established project construction and operational emissions thresholds for criteria pollutants, as shown in Table 1. 8 For a project to be consistent
with SJVAPCD attainment plans, the pollutants emitted from project operation should not exceed the SJVAPCD daily thresholds, cause a significant impact on air quality, or the project must already have been included in the attainment plans projection.

Table 1: SJVAPCD Project Construction and Operational
Emission Thresholds
CO NOX ROG SOX PM10 PM2.5
Annual Construction Emissions* 100.0 10.0 10.0 27.0 15.0 15.0 Annual Operational Emissions* 100.0 10.0 10.0 27.0 15.0 15.0 Source: SJVAPCD (2015a)
* Emission units = tons per year
Notes: CO = carbon monoxide; NOX = nitrogen oxides; ROG = reactive organic gas; SOX = sulfur oxides

5 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2022. 2022 Plan for the 2015 8-Hour Ozone Standard. Available online at: https://ww2.valleyair.org/media/q55posm0/0000- 2022-plan-for- the-2015-8-hour-ozone-standard.pdf. Accessed June 2025. 6 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2024. 2024 Plan for the 2012 PM2.5 Standards. June 20. Available online at: https://ww2.valleyair.org/media/gw5bacvj/2024- pm25-plan.pdf.

Accessed June 2025.
7 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2024. 2024 Plan for the 2012 PM2.5 Standards. June 20. Available online at: https://ww2.valleyair.org/media/gw5bacvj/2024-pm25-plan.pdf.

Accessed June 2025.
8 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015a. Air Quality Thresholds of Significance – Criteria Pollutants. Available online at: http://www.valleyair.org/transportation/0714- GAMAQI-Criteria-Pollutant-Thresholds-of-Significance.pdf. Accessed June 2025. 17 The Project would also be required to comply with applicable SJVAPCD rules and regulations, including Rules 2010 and 2201 for stationary -source permitting and new or modified stationary source review; Rule 9510 for Indirect Source Review; Rule 4002 for asbestos -related demolition or renovation activities; Rule 4601 for architectural coatings; Regulation VIII, including Rule 8021, for fugitive dust control and construction notification or Dust Control Plan requirements; Rule 4901 for wood- burning fireplaces and heaters; Rule 4102 for nuisance; and Rule 4641 for cutback, slow cure, and emulsified asphalt paving and maintenance operations, as applicable.

As discussed in Impact Discussion III.b) , emissions associated with the construction or operation of the proposed Project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. As discussed in Section XVII, Transportation, the proposed Project would not result in substantial or unplanned population growth or associated vehicle trips in a manner that could conflict with the 2022 Ozone Plan and the 2024 PM

2.5 Plan. The proposed Project would not
conflict with or obstruct implementation of SJVAPCD air quality plans. Therefore, impacts would be less than significant, and mitigation is not required. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less than Significant Impact. The SJVAPCD is in nonattainment with the federal standards set for 8-hour ozone and PM

2.5 and with the State standards set for 8-hour
ozone, PM10, and PM2.5.9 CEQA defines a cumulative impact as two or more individual effects, which, when considered together, are considerable or which compound or increase other environmental impacts. Therefore, if annual emissions of construction- or operational -related criteri a air pollutants exceed any applicable threshold established by the SJVAPCD, the proposed Project would result in a cumulatively significant impact.

To aid in evaluating potentially significant construction and operational impacts of a project, the SJVAPCD has prepared an advisory document, the Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI), 10 which contains standard
procedures for addressing air quality. To streamline the process of assessing significance of criteria pollutant emissions from commonly encountered projects, the SJVAPCD has developed a screening tool—Small Project Analysis Level (SPAL). The SPAL is used to screen projects for potentially significant impacts related to air emissions. A project that meets the screening criteria at this level requires no further analysis and air quality impacts of the project may be deemed less than significant. If

9 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2025. Ambient Air Quality Standards & Attainment Status. Available online at: https://www.valleyair.org/air-quality-information/ambient-air- quality-standards-valley-attainmnet-status/. Accessed May 2025. 10 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015b. Guidance for Assessing and Mitigating Air Quality Impacts. Adopted March 19, 2015. Available online at:
https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf. Accessed June 2025. 18 a project does not meet all the criteria at this screening level, additional impact analysis is required.

The SPAL thresholds are identified by project type and by number of vehicle trips. For low-rise apartments, the size threshold is 224 dwelling units and the vehicle trip threshold is less than 800 trips per day.
11 The proposed Project would result in the
construction of up to 120 new residential units, which falls below the established size threshold of 224 dwelling units. The proposed Project would generate a total of approximately 800 vehicle trips per day for all operational uses (e.g., affordable housing, commercial, associated improvements); therefore, the number of residential vehicle trips generated by the project would fall below the vehicle trip threshold of 800 vehicle trips per day.

The SPAL thresholds for retail/commercial uses (most closely related to a regional shopping center) is a size threshold of 47,000 square feet and a vehicle trip threshold of less than 1,250 vehicle trips per day. The proposed Project would result in the construction of up to 15,000 square feet of retail/commercial space, which falls below the established size threshold of 47,000 square feet . The proposed Project would generate a total of approximately 800 vehicle trips per day for all operational uses (e.g., affordable housing, commercial, associated improvements) ; therefore, the number of commercial vehicle trips would fall well below the vehicle trip threshold of 1,250 vehicle trips per day. As such, the proposed Project would be consistent with the SPAL screening thresholds for residential and commercial uses and associated vehicle trip generation rates and would not require further air quality analysis as construction-related and operational emissions would fall below the thresholds established by the SJVAPCD. Therefore, impacts would be less than significant, and mitigation is not required.
c) Expose sensitive receptors to substantial pollutant concentrations? Less than Significant with Mitigation Incorporated. Sensitive receptors are people that have an increased sensitivity to air pollution or environmental contaminants, such as the elderly, children, people with asthma or other respiratory illnesses, and others who are at a heightened risk of negative health outcomes due to exposure to air pollution. Some land uses are considered more sensitive to changes in air quality than others due to the population that occupies the uses and activities involved. Sensitive receptor locations include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and residences.

The nearest sensitive receptors include residential dwelling units located approximately 10 to 50 feet north, south, and wes t of the Project site and an urgent care facility located approximately 750 feet east of the Project site . Due to this proximity, proposed construction activities associated with the proposed Project have the potential to expose nearby residents to short-term construction-related emissions.

11 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2020. Small Project Analysis Levels (SPAL). November 13. Available online at: https://ww2.valleyair.org/media/5jppiwed/cms -format- spal.pdf. Accessed June 2025.
19 Construction of the proposed Project would generate emissions, including diesel particulate matter (diesel PM) and fugitive dust. Construction and operational emissions would not exceed SJVAPCD thresholds; however, due to the close proximity to sensitive receptors, compliance with the SJVAPCD Standard Regulation VIII Control Measures and Mitigation Measures AQ-1 through AQ-4 would be required to reduce the potential for a nuisance and exposure to diesel PM and fugitive dust.

Potential impacts related to the exposure of sensitive receptors to other emissions are included in Impact Discussion III.d). The proposed Project includes construction of a mixed-use residential and retail/commercial development, and no operational activities are proposed that could expose sensitive receptors to substantial long-term pollutant concentrations. Therefore, impacts would be less than significant with mitigation.

The Project vicinity also includes schools identified as sensitive receptors, including Easterby Elementary School, Kings Canyon Middle School, and Fancher Creek Elementary School.

Subsequent to circulation of the Draft IS/MND, a construction health risk assessment was prepared for the Project to evaluate potential health risks associated with construction-related diesel particulate matter emissions (AMBIENT 2026). The analysis used CalEEMod emissions modeling, AERMOD dispersion modeling, and HARP2 risk calculations to evaluate the maximally exposed individual receptor, identified as a residential receptor adjacent to the northern boundary of the Project site. The H RA assumed an approximately 18- month construction duration, approximately 9.7 acres of total disturbance, approximately 10,000 cubic yards of imported material, use of Tier 4 off-road construction equipment, and compliance with SJVAPCD Regulation VIII fugi tive dust control requirements. The HRA determined that the maximum predicted cancer risk would be 6.04 in one million, which is below the SJVAPCD significance threshold of 20 in one million. The chronic hazard index would be less than 0.01 and the acute h azard index would be 0, both below the applicable significance threshold of 1. Therefore, construction of the Project would not expose sensitive receptors to substantial pollutant concentrations, and no additional mitigation is required.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact. Construction activities would be intermittent and temporary, generally confined to the construction area except for minor utility work , and therefore would not result in significant impacts. Any construction odors would be temporary and limited to the construction phase of the proposed Project. In addition, the proposed residential and retail /commercial mixed-use development would not produce any offensive odors that would result in frequent odor complaints because the proposed Project does not include substantial odor -generating uses, such as agricultural activities, feedlots, wastewater treatment facilities, landfills, or heavy manufacturing uses. The Project site is not located in an area with known potential for 20 naturally occurring asbestos (NOA), 12 and construction activities would not have the potential to expose workers or surrounding land uses to harmful levels of NOA. The proposed Project does not include any demolition activities that could disturb asbestos-containing material (ACM) or lead- based paint (LBP). Further, required compliance with SJVAPCD Rule 8021 Section 6.3, Dust Control Plan, would address Valley Fever during ground- disturbing activities. The proposed Project would not create objectionable odors affecting a substantial number of people during Project construction or operation. Therefore, impacts would be less than significant , and mitigation is not required.

The Project does not identify a specific restaurant tenant or include a known under - fired commercial charbroiler as part of the currently proposed Project. If a future restaurant tenant proposes charbroiler equipment, the operator shall comply with applicable SJVAPCD requirements and Rule 4692-related requirements in effect at the time of installation and operation, including applicable equipment, permitting, monitoring, reporting, and recordkeeping requirements.

The City or applicant may voluntarily consider additional air quality and sustainability enhancements, including vegetative barriers, urban greening, electric lawn and garden equipment, and on-site solar deployment, as part of project design, conditions, or other non- CEQA mechanisms. These measures are not required as CEQA mitigation because the IS/MND identifies less-than-significant air quality impacts with implementation of applicable mitigation and regulatory requirements.

Mitigation Measures
AQ-1 Permit Requirements. Prior to ground disturbance and construction, the Project contractor shall obtain all required permits for dust control and the use of portable equipment, 50 horsepower or greater, from the San Joaquin Valley Air Pollution Control District. Upon applicatio n for construction permits, all required mitigation measures shall be shown on all applicable grading or construction plans and implemented during all applicable grading and construction activities.

AQ-2 Dust Control Measures. No person shall perform any construction, demolition, excavation, extraction, or other earth- moving activities unless measures are sufficiently implemented to limit visible dust emissions (VDE) to 20% opacity and comply with the conditions for a stabilized surface area when applicable.

In addition to the requirements of this rule, a person shall comply with all other applicable requirements of San Joaquin Valley Air Pollution Control District Regulation VIII. A person shall control the fugitive dust emissi ons to meet the following requirements:

12 California Geological Survey (CGS). 2011. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California. 21 Pre-Activity:
a. Pre-water site sufficient to limit VDE to 20% opacity, and b. Phase work to reduce the amount of disturbed surface area at any one time.

During Active Operations:
a. Apply water or chemical/organic stabilizers/suppressants sufficient to limit VDE to 20% opacity; or
b. Construct and maintain wind barriers sufficient to limit VDE to 20% opacity. If utilizing wind barriers, control measure 2.a shall also be implemented.
c. Apply water or chemical/organic stabilizers/suppressants to unpaved haul/access roads and unpaved vehicle/equipment traffic areas sufficient to limit VDE to 20% opacity and meet the conditions of a stabilized unpaved road surface.

Temporary Stabilization During Periods of Inactivity:
a. Restrict vehicular access to the area; and
b. Apply water or chemical/organic stabilizers/suppressants, sufficient to comply with the conditions of a stabilized surface. If an area having 0.5 acre or more of disturbed surface area remains unused for 7 or more days, the area must comply with the condit ions for a stabilized surface area as defined in Section 3.58 of Rule 8011.

AQ-3 Construction Emissions. During all construction activities, the Project shall utilize clean off -road construction equipment, including Tier 4 off -road construction equipment, where feasible, in accordance with the San Joaquin Valley Air Pollution Control District (SJVAPCD) District Policy APR 1305 Best Available Control Technology (BACT). These requirements shall be shown on applicable grading or construction plans and implemented during all applicable construction activities.

AQ-4 Diesel Idling. At all times, idling of heavy -duty diesel trucks will be minimized and auxiliary power units will be used whenever possible. State law requires that:

Drivers of diesel-fueled commercial vehicles shall not idle the vehicle’s primary diesel engine for greater than 5 minutes at any location.

Drivers of diesel -fueled commercial vehicles shall not idle a diesel - fueled auxiliary power system (APS) for more than 5 minutes to power a heater, air conditioner, or any ancillary equipment on the vehicle.

Trucks with 2007 or newer model year engines mus t meet additional requirements (verified clean APS label required).
22 These requirements shall be shown on grading/building plans and/or on a separate sheet to be required with the map and adhered to throughout all grading and construction periods.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse
effect, either directly or through
habitat modifications, on any
species identified as a candidate,
sensitive, or special status
species in local or regional plans,
policies, or regulations, or by the
California Department of Fish and
Game or U.S. Fish and Wildlife
Service?
X
b) Have a substantial adverse
effect on any riparian habitat or
other sensitive natural community
identified in local or regional
plans, policies, regulations or by
the California Department of Fish
and Game or US Fish and Wildlife
Service?
X
c) Have a substantial adverse
effect on federally protected
wetlands as defined by Section
404 of the Clean Water Act
(including, but not limited to,
marsh, vernal pool, coastal, etc.)
through direct removal, filling,
hydrological interruption, or other
means?
X
d) Interfere substantially with the
movement of any native resident
or migratory fish or wildlife
species or with established native
resident or migratory wildlife
corridors, or impede the use of
native wildlife nursery sites?
X
23 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Conflict with any local policies
or ordinances protecting
biological resources, such as a
tree preservation policy or
ordinance?
X
f) Conflict with the provisions of an
adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan?
X

DISCUSSION
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? Less than Significant with Mitigation Incorporated. The following information is based on a literature review and observations made during a reconnaissance- level survey of the Project site and immediately surrounding area, referred to as the Project area in this section. The literature review included a rev iew of the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) planning tool
13 and a nine-quadrangle query of the California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB)14 and California Native Plant Society (CNPS) Rare Plant Inventory 15 to identify special -status plant and animal species that have been previously documented in the Project area (Appendix A). In addition, an SWCA biologist conducted a biological reconnaissance survey of the Project site on June 27, 2025, to document existing conditions of the Project site.

Existing Conditions
The Project site consists of a ruderal weedy lot dominated by nonnative annual grasses, including wild oat ( Avena fatua) and ripgut brome ( Bromus diandrus). One Mexican fan palm tree (Washingtonia robusta) is located in the western portion of the

13 U.S. Fish and Wildlife Service (USFWS). 2025a. Information for Planning and Consultation. Available online at: https://ipac.ecosphere.fws.gov/. Accessed June 2025. 14 California Department of Fish and Wildlife (CDFW). 2025. California Natural Diversity Database.

Available online at: https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data. Accessed June 2025. 15 California Native Plant Society (CNPS). 2025. Rare Plant Inventory. Available online at:
https://rareplants.cnps.org/. Accessed June 2025.
24 Project site . The P roject site is surrounded by industrial land uses to the north, residential development to the south and west, and undeveloped land within the CMX zone district and land use designation immediately east with commercial development beyond the empty lot . The Project site shows signs of regular disturbance from foot and vehicle traffic and vegetation maintenance (e.g., mowing and disking). At the time of the June 27, 2025, survey, the Project site had been recently disked. Evidence of refuse dumping and human disturbance was observed in multiple locations throughout the Project site . Small mammal burrows and California ground squirrel (Otospermophilus beecheyi) were observed. Avian species were observed in the trees and shrubs along the perimeter of the Project area but were not observed within the Project site.

Special-Status Plants
Based on a review of the USFWS IPaC and a nine- quadrangle query of the CDFW CNDDB and CNPS Rare Plant Inventory, the following 17 special-status plant species have been previously documented in the Project vicinity (see Appendix A):
• Hoover’s calycadenia ( Calycadenia hooveri) is a California Rare Plant Rank (CRPR) 1B.3 species that typically occurs in grassland, oak savanna, and rocky, exposed places at elevations between approximately 330 and 1,300 feet. The nearest recorded occurrence is approximately 14.8 miles north of the Project area (CNDDB Occ. 44). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site.
• bristly sedge (Carex comosa) is a CRPR 2B.1 species that typically occurs in wet places at elevations below approximately 1,300 feet. The nearest recorded occurrence is approximately 10.5 miles southeast of the Project area (CNDDB Occ. 31). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site.
• succulent owl’s -clover ( Castilleja campestris var. succulenta) is a federally threatened, State endangered, and CRPR 1B.2 species that typically occurs in vernal pool and wetland areas at elevations below approximately 2,130 feet.

The nearest recorded occurrence is approximately 8.4 miles northeast of the Project area (CNDDB Occ. 43). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site.
• California jewelflower ( Caulanthus californicus ) is a federally endangered, State endangered, and CRPR 1B.1 species that typically occurs on flats and slopes within chenopod scrub, pinyon and juniper woodlands, and valley and foothill grasslands at elevations between approximately 230 and 3,280 feet.

The nearest recorded occurrence is from the late 1890s and overlaps the Project area (CNDDB Occ. 38). Based on the high levels of site disturbance, lack of suitable habitat, and date of the nearest recorded occurrence, this species is not expected to occur on-site.
25 • Ewan’s larkspur (Delphinium hansenii ssp. ewanianum) is a CRPR 4.2 species that typically occurs in oak woodland and grassland at elevations between approximately 200 and 1,970 feet. The nearest recorded occurrence is approximately 10.2 miles north of the Project area (Catalog #SD00092714). 16 Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • dwarf downingia ( Downingia pusilla ) is a CRPR 2B.2 species that typically occurs within vernal pools and roadside ditches at elevations below approximately 500 feet. The nearest recorded occurrence is approximately

11.8 miles north of the Project area (CNDDB Occ. 120). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site. • spiny-sepaled button-celery (Eryngium spinosepalum) is a CRPR 1B.2 species that typically occurs within vernal pools, swales, and roadside ditches at elevations between approximately 330 and 4,170 feet. The nearest recorded occurrence is approximately 7.9 miles east of the Project area (CNDDB Occ. 9). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site.
• California satintail ( Imperata brevifolia) is a CRPR 2B.1 species that typically occurs within wet springs, meadows, streambanks, and floodplains at elevations less than approximately 1,640 feet. The nearest recorded occurrence is from 1893 and overlaps the Project area (CNDDB Occ. 22).

Based on the high levels of site disturbance, lack of suitable habitat, and date of the nearest recorded occurrence, this species is not expected to occur on-site.
• forked hare-leaf (Lagophylla dichotoma) is a CRPR 1B.1 species that typically occurs in grassland openings in woodlands at elevations between approximately 160 and 1,300 feet. The nearest recorded occurrence is approximately 11.7 miles northeast of the Project area (CNDDB Occ. 12).

Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • Madera leptosiphon ( Leptosiphon serrulatus ) is a CRPR 1B.2 species that typically occurs in openings in woodland and chaparral at elevations between approximately 980 and 4,270 feet. The nearest recorded occurrence is from 1922 and overlaps the Project area (CNDDB Occ. 23). Based on the high levels of site disturbance, lack of suitable habitat, and date of the nearest recorded occurrence, this species is not expected to occur on-site. • pincushion navarretia (Navarretia myersii ssp. myersii) is a CRPR 1B.1 species that typically occurs in vernal pools at elevations between approximately 60

16 Consortium of California Herbaria (CCH). 2025. CCH2: Specimen data from the Consortium of California Herbaria. Available online at: https://www.cch2.org/portal/collections/map/index.php.

Accessed June 2025.
26 and 300 feet. The nearest recorded occurrence is approximately 16.7 miles northwest of the Project area (CNDDB Occ. 17). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site. • San Joaquin Valley Orcutt grass (Orcuttia inaequalis) is a federally threatened State endangered, and CRPR 1B.1 species that typically occurs in vernal pool and wetland habitats at elevations between approximately 35 and 2,475 feet.

The nearest recorded occurrence is approximately 7.9 miles northwest of the Project area (CNDDB Occ. 21). Based on the high levels of site disturbance and lack of suitable habitat, this species is not expected to occur on-site. • hairy Orcutt grass ( Orcuttia pilosa) is a federally endangered, State endangered, and CRPR 1B.1 species that typically occurs in vernal pool and wetland habitats at elevations between approximately 150 and 655 feet. The nearest recorded occurrence is approximately 12.9 miles northwest of the Project area (CNDDB Occ. 28). Based on the distance to the nearest recorded occurrence, high levels of site disturbance, and lack of suitable habitat, this species is not expected to occur on-site.
• Hartweg’s golden sunburst (Pseudobahia bahiifolia) is a federally endangered, State endangered, CRPR 1B.1 species that typically occurs in cismontane woodland and valley and foothill grassland habitats between approximately 50 and 490 feet. The nearest recorded occurrence is approximately 14. 9 miles north of the Project area (CNDDB Occ. 23). Based on the distance to the nearest recorded occurrence and frequent site disturbance, this species is not expected to occur on-site.
• San Joaquin adobe sunburst (Pseudobahia peirsonii) is a federally threatened, State endangered, and CRPR 1B.1 species that typically occurs in bare dark clay within grasslands at elevations between approximately 320 and 2,950 feet.

The nearest recorded occurrence is approximately 6.8 miles northeast of the Project area (CNDDB Occ. 31). Based on the distance to the nearest recorded occurrence and frequent site disturbance, this species is not expected to occur on-site.
• Sanford's arrowhead (Sagittaria sanfordii) is a CRPR 1B.2 species that typically occurs within ponds and ditches at elevations lower than approximately 980 feet. The nearest recorded occurrence is approximately 3.5 miles northwest of the Project area (CNDDB Occ. 38). Based on the high levels of site disturbance and lack of suitable habitat, this species is not expected to occur on-site.
• Greene’s tuctoria ( Tuctoria greenei ) is a CRPR 1B.1 species that typically occurs in vernal pool and wetland habitats at elevations between approximately 100 and 3,510 feet. The nearest recorded occurrence is approximately

7.5 miles northeast of the Project area (CNDDB Occ. 22). Based on the distance to the nearest recorded occurrence and frequent site disturbance, this species is not expected to occur on-site.
27 Short-term construction activities would have the potential to result in direct impacts to special -status plant species if present within the Project area during Project construction. No special -status plant species were observed during the reconnaissance-level field survey of the Project area on June 27 , 2025. Further, no special-status plant species are expected to occur within the Project area due to the lack of suitable habitat and extent of disturbance; therefore, the proposed Project would not result in adverse effects to special -status plant species. Following construction, the Project site would be covered in hardscapes and would continue to experience site disturbance and would not provide suitable habitat for spec ial-status plants. Therefore, impacts would be less than significant , and mitigation is not required.

Special-Status Animals
Based on a review of the USFWS IPaC and a nine- quadrangle query of the CDFW CNDDB, the following 2 5 special-status animal species have been previously documented in the Project vicinity (see Appendix A):
• northwestern pond turtle ( Actinemys marmorata) is a federally proposed threatened species and a CDFW Species of Special Concern (SSC) that typically occurs in aquatic and wetland habitats. The nearest recorded occurrence is approximately 7.5 miles north of the Project area (CNDDB Occ. 1,355). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • tricolored blackbird ( Agelaius tricolor ) is a State threatened species and an SSC that typically occurs in freshwater marsh, marsh, swamp, and wetland habitats. The nearest recorded occurrence is approximately 4.1 miles northeast of the Project area (CNDDB Occ. 664). Based on the lack of suitable habitat, this species is not expected to occur on-site.
• California tiger salamander – Central California Distinct Population Segment (DPS) (Ambystoma californiense pop. 1) is a federally and State threatened species that typically occurs in cismontane woodland, meadow and seep, riparian woodland, valley and foothill grassland, vernal pool, and wetland habitats. The nearest recorded occurrence is from 1879 and overlaps the Project area (CNDDB Occ. 478). Based on the date of the nearest recorded occurrence and lack of suitable habitat and connection to natural areas, this species is not expected to occur on-site.
• northern California legless lizard ( Anniella pulchra) is an SSC that typically occurs in sandy or loose loamy soils under coastal scrub or oak trees. The nearest recorded occurrence is from the late 1800s and overlaps the Project area (CNDDB Occ. 116). Based on the date of the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • pallid bat ( Antrozous pallidus ) is an SSC that typically occurs in deserts, grasslands, shrublands, woodlands, and forests. This species is most common in open, dry habitats with rocky areas for roosting and may roost in hollow trees 28 and old buildings. The nearest recorded occurrence is approximately 3.5 miles west of the Project area (CNDDB Occ. 147). Based on the lack of suitable habitat, this species is not expected to occur on-site. • California glossy snake (Arizona elegans occidentalis) is an SSC that typically occurs in open areas with loose soil for easy burrowing in arid scrub, rocky washes, grasslands, chaparral. The nearest recorded occurrence is from 1893 and overlaps the Project site (CNDDB Occ. 1). Based on the date of the nearest recorded occurrence and the lack of connection to natural areas, this species is not expected to occur on-site.
• golden eagle (Aquila chrysaetos) is a State fully protected species that typically occurs in open country in prairies, tundra, open coniferous forest, and barren areas, especially in hilly or mountainous regions. This species n ests in large, prominent trees in wooded areas and on cliff ledges. The nearest recorded occurrence is approximately 23.4 miles northeast of the Project area (CNDDB Occ. 29). Based on the distance to the nearest recorded occurrence and the lack of suitable habitat, this species is not expected to occur on-site. • burrowing owl ( Athene cunicularia) is a S tate candidate endangered species and an SSC that typically occurs in wide- open, sparsely vegetated areas like prairies, deserts, grasslands and agricultural fields. The nearest recorded occurrence is approximately 2.5 miles northwest of the Project area (CNDDB Occ. 1,962). The project site provides suitable habitat for this species in the undeveloped grassland and ground squirrel burrows present on the project site could provide. The on-site grassland vegetation is subject to frequent anthropogenic disturbance and shows evidence of regular mowing for general maintenance that reduces the suitability of on-site habitat. Nevertheless, there is some potential for burrowing owl individuals to nest on-site. • Crotch’s bumble bee ( Bombus crotchii ) is a S tate candidate endangered species that typically occurs in grassland and scrub habitats. The nearest recorded occurrence is approximately 6.73 miles northwest of the Project area (CNDDB Occ. 53). Based on the distance to the nearest recorded occurrence and history of disturbance at the Project site, this species is not expected to occur on-site.
• vernal pool fairy shrimp (Branchinecta lynchi) is a federally threatened species that typically occurs in valley and foothill grassland, vernal pool, and wetland habitats. The nearest recorded occurrence is approximately 5.2 miles northeast of the Project area (CNDDB Occ. 148). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site.
• Swainson’s hawk (Buteo swainsoni) is a State threatened species that typically occurs in grassland, riparian forest, riparian woodland, and valley and foothill grassland habitats. The nearest recorded occurrence is from 1956 and overlaps the Project area (CNDDB Occ. 2,583). There is potential to observe this species soaring overhead; however, based on the date of the nearest 29 recorded occurrence and history of disturbance at the Project site, this species is not expected to nest on-site.
• western yellow-billed cuckoo (Coccyzus americanus occidentalis) is a federally threatened and S tate endangered species that typically occurs in forests to open riparian woodlands with a thick understory. The nearest recorded occurrence is approximately 2.5 miles east of the Project area (CNDDB Occ. 87). Based on the lack of suitable habitat, this species is not expected to occur on-site.
• monarch butterfly ( Danaus plexippus ) is a federally proposed threatened species that is dependent on milkweed (Asclepias spp.) as a host plant for offspring and typically overwinters in wind- protected tree groves. The nearest recorded occurrence is approximately 97 .3 miles east of the Project area (CNDDB Occ. 198). The Project site does not contain any suitable roost habitat, and the Project site is outside of this species’ overwintering range. Therefore, this species is not expected to occur on-site.
• valley elderberry longhorn beetle ( Desmocerus californicus dimorphus ) is a federally threatened species that typically occurs in riparian forests on valley floors and low foothills throughout the Central Valley. This species is dependent on its host plant, elderberry (Sambucus spp.), throughout all stages of life. The nearest recorded occurrence is approximately 9.9 miles northwest of the Project area (CNDDB Occ. 135). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site.
• Fresno kangaroo rat ( Dipodomys nitratoides exilis ) is a federally and State endangered species that typically occurs in alkali sink communities in the central portion of the San Joaquin Valley. This species occupies burrows in relatively light, sandy soils in raised areas. The nearest recorded occurrence is approximately 7.1 miles west of the Project area (CNDDB Occ. 15). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site.
• spotted bat ( Euderma maculatum) is an SSC that typically roosts high in cliff crevices, occasionally in human -made structures, and in a wide variety of habitats from desert shrub to coniferous forests. The nearest recorded occurrence is approximately 16.7 miles north of the Project area (CNDDB Occ. 40). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • western mastiff bat ( Eumops perotis californicus ) is an SSC that typically occurs in broad open areas, chaparral, montane meadows, rocky cliffs, and canyon areas. This species roosts in crevices, tunnels, and buildings. The nearest recorded occurrence is approximately 3.2 miles west of the Project area (CNDDB Occ. 47). Based on the lack of suitable habitat, this species is not expected to occur on-site.
30 • bald eagle (Haliaeetus leucocephalus) is a State endangered and CDFW fully protected species that typically occurs in forests or woodlands adjacent to large waterbodies. This species is tolerant of human activity and commonly spotted around dumps and fish processing plants. The nearest recorded occurrence is approximately 28.8 miles north of the Project area (CNDDB Occ. 260). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site.
• blunt-nosed leopard lizard (Gambelia sila) is a federally and State endangered species that typically occurs in chenopod scrub habitats. The nearest recorded occurrence is approximately 23.8 miles northwest of the project site (CNDDB Occ. 107). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • hardhead (Mylophardon conocephalus) is an SSC that typically p refers pools and runs with deep, clear water ; slow velocities ; and sand- gravel-boulder substrates at low to mid-elevations. This species is usually absent from streams that are heavily altered or occupied by nonnative fish , and it primarily forages as a bottom feeder on invertebrates and aquatic vegetation. The nearest recorded occurrence is approximately 9.7 miles northwest of the Project area (CNDDB Occ. 12). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site. • coast horned lizard ( Phrynosoma blainvillii) is an SSC that occurs in a wide variety of habitats and is most common in lowlands along sandy washes with scattered low bushes. The nearest recorded occurrence is from the late 1800s and overlaps the Project area (CNDDB Occ. 863). Based on the extent of disturbance at the Project site and date of the nearest recorded occurrence, this species is not expected to occur on-site.
• western spadefoot ( Spea hammondii ) is a federally proposed threatened species and an SSC that typically occurs in seasonal/vernal pools in coastal scrub, grassland, chaparral, woodland habitat, and open areas with sandy or gravelly soils. The nearest recorded occurrence is approximately 8.6 miles northeast of the Project area (CNDDB Occ. 790). Based on the distance to the nearest recorded occurrence and lack of suitable habitat, this species is not expected to occur on-site.
• American badger (Taxidea taxus) is an SSC that typically occurs in dry, open fields with friable soil for tunneling and foraging. The nearest recorded occurrence is approximately 2. 5 miles north of the Project area (CNDDB Occ. 80). Based on the lack of suitable habitat and frequent site disturbance, this species is not expected to occur on-site.
• least Bell’s vireo ( Vireo bellii pusillus ) is a federally and State endangered species that typically occurs in riparian forest, riparian scrub, and riparian woodland habitats. The nearest recorded occurrence is approximately

1.7 miles north of the Project area (CNDDB Occ. 505). Based on the lack of suitable habitat, this species is not expected to occur on-site. 31 • San Joaquin kit fox ( Vulpes macrotis mutica ) is a federally endangered and State threatened species that typically occurs in chenopod scrub and annual grasslands with loose sandy soils. The nearest recorded occurrence is approximately 7.9 miles southeast of the Project area (CNDDB Occ. 1,115).

Based on the lack of suitable habitat and connection to natural areas , this species is not expected to occur on-site.

Short-term construction activities would have the potential to result in direct (e.g., take) or indirect (e.g., light pollution, noise pollution, habitat loss, etc.) impacts to special - status animal species if present within the Project area during Project construction.

No special-status animal species or evidence of special -status animal species were observed during the reconnaissance-level field survey of the Project area on June 27, 2025. Further, most special -status animal species known to occur in the region are not expected to occur within the Project area based on the proposed Project’s location in an urbanized area surrounded by existing development, the lack of connectivity to natural areas, and frequent site disturbance. However, there is potential for migratory bird species to temporarily nest in the Mexican fan palm within the Project site, as well as in landscape trees in the Project area. Additionally, there is potential for the low - quality grassland habitat within the Project site to provide temporary nesting and foraging habitat for migratory nesting bird species and burrowing owl s. Proposed construction activities have the potential to result in direct and indirect disturbance to migratory nesting bird species and burrowing owl s if present within the Project area during construction. Mitigation Measure BIO -1 has been included to require preconstruction nesting bird surveys and identifies the proper protocol to be implemented if birds are found nesting within the Project area. In addition, Mitigation Measure BIO-2 requires preconstruction surveys and identifies avoidance measures to be implemented if burrowing owl are identified on- site. Following construction, the Project site would be covered in hardscapes and would continue to experience site disturbance and would not provide suitable habitat for special -status animals.

Implementation of Mitigation Measures BIO-1 and BIO-2 would avoid and/or minimize potential impacts related to nesting migratory birds
and burrowing owl individuals .

Therefore, impacts related to special -status animal species would be less than significant with mitigation.

Based on the lack of suitable habitat and anthropogenic disturbance, special -status plant or animal species are not expected to occur within the Project area; therefore, the proposed Project would not result in adverse effects to special -status plant species. Implementation of Mitigation Measures BIO-1 and BIO-2 would avoid and/or minimize potential impacts related to nesting migratory birds and burrowing owl individuals. Following construction, the Project site would be covered in hardscapes , would continue to experience site disturbance, and would not provide suitable habitat for special -status plants or animals. Therefore, impacts related to special -status species would be less than significant with mitigation. 32 b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
No Impact. Future development that occurs in the vicinity of the San Joaquin River, its tributaries, any lakes or streams, and/or open grasslands with seasonal wetlands may result in a significant impact to riparian habitat or a special ‐status natural community. According to the USFWS National Wetlands Inventory (NWI) Surface Waters and Wetlands Mapper,
17 no riparian habitat or other sensitive natural
communities occur within or in the vicinity of the Project site. The Project site consists of nonnative vegetation, and no riparian habitat or other sensitive natural communities were observed on-site during the reconnaissance survey. The proposed Project would not result in a substantial adverse effect on any riparian habitat or other sensitive natural community. Therefore, no impact would occur, and mitigation is not required. c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. Future development that occurs in the vicinity of the San Joaquin River corridor may result in significant impacts to protected wetlands. According to the USFWS NWI Surface Waters and Wetlands Mapper , no aquatic resources occur within or in the vicinity of the Project site.
18 The Project site consists of nonnative
vegetation, and no aquatic features or indicators of potential aquatic features were observed on-site during the reconnaissance survey. The proposed Project would not result in a substantial adverse effect on a feder ally or State -protected wetland.

Therefore, no impact would occur, and mitigation is not required. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less than Significant Impact. Open space areas, undeveloped land, and agricultural land are mainly located along the boundaries of the City, particularly near the northern boundary along the San Joaquin River corridor, which functions as a wildlife movement corridor for a number of terrestrial and aquatic mammals and birds. The San Joaquin River corridor facilitates movement of wildlife species from the City to the Sierra Nevada to the east and open agricultural land to the west.

The Project site is located in a developed area in the southeastern portion of the City and is not located within a wildlife movement corridor. The Project site consists of an

17 U.S. Fish and Wildlife Service (USFWS). 2025b. National Wetlands Inventory (NWI) Surface Waters and Wetlands Mapper. Available online at: https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands - mapper/. Accessed June 2025.
18 U.S. Fish and Wildlife Service (USFWS). 2025b. National Wetlands Inventory (NWI) Surface Waters and Wetlands Mapper. Available online at: https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands - mapper/. Accessed June 2025.
33 undeveloped and disturbed area that is surrounded by existing developed areas, including SR-180 along the northern boundary of the Project site; residential properties to the north, south, and west ; and undeveloped land within the CMX zone district and land use designation immediately east with commercial development beyond the empty lot. The Project site shows signs of regular disturbance from foot and vehicle traffic and vegetation maintenance (e.g., mowing and disking). At the time of the June 27, 2025, survey, the Project site had been recently disked. Based on the level of existing development , lack of connectivity to natural habitat areas, and frequent anthropogenic disturbance, the Project area is not suitable for terrestrial habitat connectivity. There are no waterways within the Project area that could provide migratory fish or breeding habitat. As previously identified, there is low potential for migratory birds to utilize ornamental trees within the Project area and the grassland habitat within the Project site for nesting habitat. The proposed Project would not result in the removal of any trees from the Project site or surrounding area that could impede the use of the Project site as nesting bird habitat. The proposed Project would not interfere substantially with the movement of migratory species. Therefore, impacts would be less than significant, and mitigation is not required. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No Impact. The proposed Project would not conflict with any local policies or ordinances protecting biological resources. Though the proposed Project is subject to provisions of the Municipal Code regarding trees on public property ( Municipal Code Chapter 13, Article 3 , Street Trees and Parkways ), the proposed Project does not propose the removal of any trees and would not conflict with any of the existing ordinances. Therefore, no impact would occur, and mitigation is not required. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The PG&E San Joaquin Valley Operation & Maintenance Habitat Conservation Plan (PG&E O&M HCP)
19 was approved in 2007 and covers portions of
nine counties, including Fresno County. The PG&E O&M HCP covers Pacific Gas and Electric Company (PG&E) activities that occur as a result of ongoing operations and maintenance that would have an adverse impact on any of the 65 covered species and provides incidental take coverage from the USFWS and CDFW. The PG&E O&M HCP is not applicable to the proposed Project. The Project site is not located within the covered area of any HCP, Natural Community Conservation Plan (NCCP), or other adopted local, regional, or State HCP. The Project site is not located within the

19 Pacific Gas and Electric Company (PG&E). 2007. PG&E San Joaquin Valley Operation & Maintenance Habitat Conservation Plan. December 2006; Updated December 2007. Sacramento, CA: Jones & Stokes. Available online at: https://ecos.fws.gov/docs/plan_documents/thcp/thcp_838.pdf. Accessed June 2025.
34 covered area of any other HCP or NCCP. Therefore, no impact would occur, and mitigation is not required.

Mitigation Measures
BIO-1 Preconstruction Nesting Bird Survey. Prior to initiation of any Project site preparation or construction activities, if work is planned to occur between February 1 and August 31, a qualified biologist shall survey the area for nesting birds within 1 week prior to initial Project activity beginning, including ground disturbance and/or vegetation removal/trimming. If nesting birds are located on or near the Project site, they shall be avoided until they have successfully fledged, or the nest is no longer deemed active, as detailed below:

A 50-foot exclusion zone shall be placed around non- listed, passerine species and a 250- foot exclusion zone will be implemented for raptor species. Each exclusion zone shall encircle the nest and have a radius of 50 feet (non-listed passerine species) or 250 feet (raptor species). All Project activities, including foot and vehicle traffic and storage of supplies and equipment, are prohibited inside exclusion zones.

Exclusion zones shall be maintained until all exterior construction activities have been term inated for the current phase of work (e.g., if initial site improvements are completed, exclusion zones may be removed until initiation of site preparation for residence construction begins), or it has been determined by a qualified biologist that the young have fledged or that Project activities would not cause adverse impacts to the nest, adults, eggs, or young.

If special-status avian species are identified and observed nesting within the work area, no work will begin until an appropriate exclusion zone is determined in consultation with the City of Fresno and any relevant resource agencies.

The results of the survey shall be provided to the City of Fresno prior to initiation of site preparation or construction activities. The results shall detail appropriate fencing or flagging of exclusion zones and include recommendations for additional monitoring requirements. A map of the Project site and nest locations shall be included with the results. The qualified biologist conducting the nesting bird survey shall have the authority to reduce or increase the recommended exclusion zone depending on site conditions and species (if non-listed).

If 2 weeks lapse between different phases of Project activities (e.g., vegetation trimming, the start of grading), during which no or minimal work activity occurs, the nesting bird survey shall be repeated, and a separate survey report shall be prepared and submitted to the City of Fresno.

BIO-2 Preconstruction Survey for Overwintering Burrowing Owl . If work is planned to occur between October 16 and March 31, a qualified biologist shall survey the area for overwintering burrowing owls within 1 week prior to activity 35 beginning on-site. If overwintering burrowing owls are located on or near the proposed Project site, occupied burrows shall be avoided until a qualified biologist determines the burrow is no longer occupied. A site- specific, non - disturbance buffer shall be established and maintained between the project activities and occupied burrows, using t he distances recommended in the CDFW 2012 Staff Report on Burrowing Owl Mitigation. Refer to the table below for these site- specific, no -disturbance buffer zones. The appropriateness of using reduced buffer distances or burrow -specific buffer distances shall be established on a case-by-case basis by a qualified biologist in consultation with the California Department of Fish and Wildlife ( CDFW) and shall depend on existing conditions (e.g., vegetation/topographic screening and current distance regimes). If necessary, buffer distances shall be carefully reassessed and relaxed or modified, based on future development plans (e.g., increased or intensified construction activities) by a qualified biologist who may consult with the CDFW. The buffer zones shall be clearly delineated by using highl y visible methods, such as stakes and rope, which shall be maintained in good condition through construction of the project or until construction activities are no longer occurring in the vicinity of the burrow.

Site-Specific No-Disturbance Buffer Zones
Level of Disturbance (October 16–March 31)
Low (feet) Mid (feet) High (feet)
164 328 1,640

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse
change in the significance of a
historical resource as defined in
Section 15064.5?
X
b) Cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to Section 15064.5?
X
c) Disturb any human remains,
including those interred outside of
formal cemeteries?
X
36 DISCUSSION
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
No Impact. A historical resource defined by CEQA includes one or more of the following criteria: 1) the resource is listed, or found eligible for listing in, the California Register of Historical Resources (CRHR); 2) listed in a local register of historical resources as defined by PRC Section 5020.1(k); 3) identified as significant in a historical resources survey meeting the requirements of PRC Section 5024.1(g); or 4) determined to be a historical resource by the project’s lead agency (PRC Section 21084.1; State CEQA Guidelines Section 15064.(a)). Under CEQA, historical resources include built environment resources and archaeological sites.

The Project site is entirely undeveloped and does not consist of any buildings or structures that could qualify for listing as a historical resource. In addition, the Project site is not located in a historic district. The proposed Project would not cause a substantial adverse change in the significance of a historical resource. Therefore , no impact would occur, and mitigation is not required.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less than Significant with Mitigation Incorporated. According to the State CEQA Guidelines, “When a project will impact an archaeological site, a lead agency shall first determine whether the site is an historical resource” ( State CEQA Guidelines Section 15064.5(c)(1)). Those archaeological sites that do not qualify as historical resources shall be assessed to determine if these qualify as “unique archaeological resources” (PRC Section 21083.2).

Construction activities would result in approximately 9.7 acres of ground disturbance, including approximately 15,649 CY of ground-disturbing activities. The maximum depth of excavation would be approximately 6 feet for utility trenching. Based on a records search conducted at the California Historical Resources Information System (CHRIS) San Joaquin Valley Information Center (SSJVIC), located at California State University, Bakersfield, and the NAHC SLF, there are no previously recorded archaeological resources within the Project area; therefore, proposed ground- disturbing activities would not adversely affect any known cultural resource sites within the Project area. Further, Mitigation Measure CR-1 requires that in the unlikely event that previously unidentified cultural resources are uncovered during proposed ground- disturbing activities, all work shall cease within the vicinity of the find until a qualified archaeologist is retained to evaluate the significance of the find and determine the need for further study. Based on the low potential to uncover archaeological resources within the Project area and implementation of Mitigation Measure CR-1, the proposed Project would not result in adverse impacts to known or unknown cultural resources.

Therefore, impacts would be less than significant with mitigation. 37 c) Disturb any human remains, including those interred outside of formal cemeteries?
Less than Significant Impact. There are no known human remains or cemeteries located within or in the immediate vicinity of the Project site, and the Project area is considered to have low sensitivity for the presence of unidentified human resources.

Although there is no record of isolated human remains or unknown cemeteries on the Project site, there is always a possibility that ground‐ disturbing activities associated with future development may uncover previously unknown buried human remains. The proposed Project would be required to comply with California Health and Safety Code Section 7050.5, which outlines the protocol for unanticipa ted discovery of human remains. Section 7050.5 states that no further disturbance shall occur until the County of Fresno (County) Coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98. The County Coroner must be notified of the find immediately. If the human remains are determined to be prehistoric, the coroner will notify the NAHC, which will determine and notify a Most Likely Descendant (MLD).

The MLD shall complete the inspection of the site within 48 hours of notification and may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials. Based on required compliance with California Health and Safety Code Section 7050.5, the proposed Project would not result in disturbance to human remains. Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
CR-1 If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified cultural resources specialist shall be consulted to determine whether the resource requires further study. The qualified cultural resources specialist shall make recommendations to the City of Fresno on the measures that shall be implemented to protect the discovered resources, including, but not limited to, excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the California Environmental Quality Act (CEQA) Guidelines and the City of Fresno Historic Preservation Ordinance. If the resources are determined to be unique historical resources as defined under State C EQA Guidelines Section 15064.5, measures shall be identified by the cultural resources specialist and recommended to the City of Fresno . Appropriate measures for significant resources could include avoidance or capping; incorporation of the Project site in green space, parks, or open space; or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the City of Fresno approves the measures to protect these resources. Any historical artifacts recovered as a result of mitigation shall be provided to a City of Fresno- approved institution or person who is capable of providing long-term preservation to allow future scientific study. 38 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VI. ENERGY – Would the project:
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
X
b) Conflict with or obstruct a state
or local plan for renewable energy
or energy efficiency?
X

DISCUSSION
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than Significant Impact . During construction activities, fossil fuels, electricity, and natural gas would be used by construction vehicles and equipment. The energy consumed during construction would be temporary in nature and typical of other similar construction activities in the City. Federal and State regulations in place require the use of fuel -efficient equipment and vehicles and that wasteful activities, such as diesel idling, be limited. Further, construction contractors, in an effort to ensure cost efficiency, would be expected to not engage in wasteful or unnecessary energy and fuel practices, such as diesel idling. Energy consumption during construction would not conflict with a State or local plan for renewable energy and would not be wasteful, unnecessary, or inefficient.

Operational energy consumption would include electricity use for building operations and fossil fuel use for vehicle trips to and from the Project site . The expected energy consumption during operation of the proposed Project would be consistent with typical usage rates for medium-high density uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings.

Electricity would be provided by PG&E, which consists of approximately 40% renewable energy sources and 95% greenhouse gas (GHG) -free energy sources. 20 By using electricity from PG&E, the proposed Project would reduce the long-term use of non- renewable energy resources. The proposed Project would also use new modern appliances and equipment, in accordance with the Appliance Efficiency

20 Pacific Gas and Electric Company (PG&E). 2025. Corporate Responsibility & Sustainability. Available online at: https://www.pge.com/en/about/corporate-responsibility-and-sustainability.html. Accessed June 2025.
39 Regulations (20 CCR 1601–1608). The proposed development would also be required to comply with applicable CALGreen ( 24 CCR Part 11) and California Energy Code (24 CCR Part 6) requirements to encourage energy-efficient design.

As discussed in Section XVII, Transportation, the Fresno Vehicle Miles Traveled (VMT) Thresholds states that projects with a high level of affordable housing units should be presumed to cause a less -than-significant transportation impact. The proposed Project includes the construction of a mixed- use building consisting of a majority of affordable housing units and therefore would be presumed to have a less- than-significant impact related to VMT. Therefore, the proposed Project is not anticipated to generate VMT in a manner that could result in substantial consumption of fossil fuels. Based on required compliance with Appliance Efficiency Regulations and CALGreen, California Energy Code, and General Plan p olicies, the proposed Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation. Therefore, impacts would be less than significant, and mitigation is not required.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less than Significant Impact. In 2002 the Legislature passed Senate Bill (SB) 1389, which required the California Energy Commission (CEC) to develop an integrated energy plan every 2 years for electricity, natural gas, and transportation fuels, for the California Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for zero emission (ZE) vehicles and their infrastructure needs, and encouragement of urban designs that reduce VMT and accommodate pedestrian and bicycle access.

In February 2024, the CEC approved the 2023 Integrated Energy Policy Report (2023 Energy Report),
21 which provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs. The 2023 Energy Report identifies methods towards achieving California’s goals for mitigating climate change and protecting the health of all Californians while simultaneously transitioning to renewable generation and electrifying the State’s economy. California needs to accelerate the pace of clean energy resource deployment, including flexible loads like EV chargers and heat pumps connected at the distribution level as well as grid- scale renewables and storage connected at the transmission level.

21 California Energy Commission (CEC). 2024. 2023 Integrated Energy Policy Report Highlights.

February. Available online at: https://www.energy.ca.gov/sites/default/files/2024- 05/2023_Integrated_Energy_Policy_Report_Highlights_ADA.pdf. Accessed June 2025. 40 As evaluated in Impact Discussion VI.a) , the proposed Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operation. Because California’s energy conservation planning actions are conducted at a regional level, and because the proposed Project’s total impact to regional energy supplies would be marginal, the proposed Project would not conflict with California’s energy conservation plans as described in the 2023 Energy Report.

The Fresno General Plan Resource Conservation and Resilience Element 22 identifies
goals and policies to reduce the consumption of non-renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources. Construction of the proposed Project would require the use of energy for building operations and fossil fuel use for vehicle trips to and from the Project site. The energy consumed during construction would be temporary and would not represent a significant or wasteful demand on available resources. Construction activities would include the use of clean off -road construction equipment, including the latest tier equipment, where feasible, which would be consistent with the General Plan efficiency policies, including, but not limited to, General Plan Policy RC-8-b, 23 which encourages
the use of alternative energy sources , and Policy RC- 8-c, which requires energy conservation in new development.

As discussed in Impact Discussion VI.a) , required compliance with Appliance Efficiency Regulations and CALGreen, California Energy Code, and General Plan policies would ensure that the proposed Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources. Furthermore, as discussed in Section VIII, Greenhouse Gas Emissions, the proposed Project would be consistent with the GHG and energy measures included in the General Plan and the GHG emissions impact thresholds recommended to ensure that the proposed Project would reduce its “fair share” of emissions needed to support State goals for long-term GHG emissions reductions and carbon neutrality.

As such, the proposed Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency, including the Resource Conservation and Resilience Element. Therefore, impacts would be less than significant, and mitigation is not required.

22 City of Fresno. 2018. Fresno General Plan, Chapter 7: Resource Conservation and Resilience Element.

Updated December 13. Available online at: https://www.fresno.gov/wp- content/uploads/2023/03/General-Plan-7-Resources-Conservation-and-Resilience-7-19.pdf. Accessed June 2025.
23 City of Fresno. 2018. Fresno General Plan, Chapter 7: Resource Conservation and Resilience Element.

Updated December 13. Available online at: https://www.fresno.gov/wp- content/uploads/2023/03/General-Plan-7-Resources-Conservation-and-Resilience-7-19.pdf. Accessed June 2025.
41 Mitigation Measures

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or Indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:

X
i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist -Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? Refer
to Division of Mines and Geology
Special Publication 42.

X
ii) Strong seismic ground
shaking? X
iii) Seismic-related ground failure,
including liquefaction? X
iv) Landslides? X
b) Result in substantial soil
erosion or the loss of topsoil? X
c) Be located on a geologic unit or
soil that is unstable, or that would
become unstable as a result of
the project, and potentially result
in on- or off-site landslide, lateral
spreading, subsidence,
liquefaction or collapse?
X
d) Be located on expansive soil,
as defined in Table 18 -1-B of the
Uniform Building Code (1994),
creating substantial risks to life or
property?
X
42 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Have soils incapable of
adequately supporting the use of
septic tanks or alternative waste
water disposal systems where
sewers are not available for the
disposal of waste water?
X
f) Directly or indirectly destroy a
unique paleontological resource
or site or unique geologic feature?
X

DISCUSSION
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

No Impact. Fault ruptures are generally expected to occur along active fault traces that have exhibited signs of recent geological movement (i.e., in the last 11,000 years). Alquist-Priolo Earthquake Fault Zones delineate areas around active faults with potential surface fault rupture hazards that would require specific geological investigations prior to approval of certain kinds of development within the delineated area. The Project site is not located within an Alquist-Priolo Earthquake Fault Zone. In addition, no known active or potentially active faults or fault traces are located in the P roject vicinity. The nearest active fault is the Nunez Fault, located approximately 50 miles southwest of the City .
24 The proposed Project
would not expose people or structures to risk as a result of fault rupture. Therefore, no impact would occur, and mitigation is not required.
ii. Strong seismic ground shaking?
Less than Significant Impact. Fresno is located in an area with a historically low to moderate level of seismicity. However, there is some potential for seismic activity along the nearby Great Valley Fault Zone, the Nunez Fault, or other associated faults, which could affect the Project site through strong seismic ground shaking. Strong seismic ground shaking could potentially cause structural damage

24 California Department of Conservation. 2024. EQ Zapp: California Earthquake Hazards Zone Application. Updated November 21. Available online at:
https://www.conservation.ca.gov/cgs/geohazards/eq-zapp. Accessed June 2025. 43 to the proposed Project. The proposed Project would be required to comply with the CBC (24 CCR) to ensure that the proposed Project would be designed to withstand seismic hazards, which would reduce risk associated with seismic ground shaking. Based on the low potential for seismic ground shaking and required compliance with the CBC, the proposed Project would not result in the risk of loss, injury, or death as a result of seismic ground shaking; t herefore, impacts would be less than significant, and mitigation is not required. iii. Seismic-related ground failure, including liquefaction? Less than Significant Impact . Liquefaction takes place when loosely packed, water-logged sediments at or near the ground surface lose their strength in response to strong ground shaking. The predominant soils within the City consist of varying combinations of loose/very soft to very dense/hard silts, clays, sands, and gravels. Groundwater has been encountered near the ground surface in close proximity to water‐filled features such as canals, ditches, ponds, and lakes. Based on these characteristics, the potential for soil liquefaction within the City ranges from very low to moderate due to the variable density of the subsurface soils and the presence of shallow groundwater. In addition to liquefaction, the City could be susceptible to induced settlement of loose unconsolidated soils or lateral spread during seismic shaking events. Based on the nature of the subsurface materials and the relatively low to moderate seismicity of the region, seismic settlement and/or lateral spread are not anticipated to represent a substantial hazard within the City during seismic events and the potent ial for seismic-related ground failure is low. Based on the low potential for liquefaction and seismic -related ground failure and required compliance with the CBC, the proposed Project would not result in the risk of loss, injury, or death as a result of liquefaction. Therefore, impacts would be less than significant, and mitigation is not required. iv. Landslides?
Less than Significant Impact . Landslides generally occur on relatively steep slopes and/or on slopes underlain by weak materials. The City of Fresno is located within an area that consists of mostly flat topography within the Central Valley.

Accordingly, there is no risk of large landslides in the majority of the City; however, there is potential for landslides and slumping along the steep banks of rivers, creeks, or drainage basins such as the San Joaquin River bluff and the many unlined basins and canals that trend throughout the City. The Project site is located on relatively flat topography, and it is not in the vicinity of the San Joaquin River bluff or any unlined basins or canals.
25 In addition, the proposed Project would be
required to be designed and constructed in accordance with the CBC to reduce the risk associated with landslides. Based on the low potential for landslide and required compliance with CBC requirements, the proposed Project would not result

25 City of Fresno. 2020a. Fresno General Plan, Chapter 9: Noise and Safety Element, pgs. 9-24, 9-34.

Updated May 21. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/9-Noise-and- Safety-02-03-21.pdf. Accessed June 2025.
44 in the risk of loss, injury, or death as a result of landslide. Therefore, impacts would be less than significant, and mitigation is not required. b) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact . Construction activities would result in approximately

9.7 acres of ground disturbance, including approximately 15,649 CY of cut and fill .

Grading and earthmoving during project construction has the potential to result in erosion and loss of topsoil. Exposed soils could be entrained in stormwater runoff and transported off the Project site. The proposed Project would be subject to the Regional Water Quality Control Board (RWQCB) General Construction Permit requirements, which require the preparation of a Stormwater Pollution Prevention Plan (SWPPP) with best management practices (BMPs) to address stormwater runoff during construction. In addition, the proposed Project would be required to comply with Municipal Code Chapter 6, Article 7 ( Urban Storm Water Quality Management and Discharge Control ), which requires the implementation of BMPs to reduce erosive runoff during construction. Following Project construction, the Project site would be covered with hardscapes, which would reduce the potential for long -term erosion to occur. Based on required compliance with RWQCB and City requirements, impacts would be less than significant, and mitigation is not required. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off- site landslide, lateral spreading, subsidence, liquefaction, or collapse? Less than Significant Impact . As described in Impact Discussions VII.a.i) through VII.a.iv), soils on the Project site would not be subject to liquefaction, lateral spreading, or landslides. Further, the Project site is not located in an area with known subsidence.
26 Additionally, the proposed P roject would be required to conform with the CBC, which would reduce risks related to unstable soils. Based on the low potential for ground failure and required compliance with CBC requirements, the proposed Project would not result in the risk associated with ground- failure events.

Therefore, impacts would be less than significant, and mitigation is not required. d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated), creating substantial direct or indirect risks to life or property?
Less than Significant Impact. The surface and near ‐surface soils observed throughout the City consist of varying combinations of clay, silt, sand, gravel, and cobble. Expansive soils are characterized by the potential for shrinking and swelling as the moisture content of the soil decreases and increases, respectively. The clayey soils, which consist of very fine particles, are considered to be slightly to moderately expansive. The Project site is underlain by one soil type, Atwater sandy loam (ArA) ,

26 U.S. Geological Survey (USGS). 2024. Areas of Land Subsidence in California. Available online at:
https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html. Accessed June 2025. 45 which consists of sandy loam and loamy sand.27 Due to the limited amount of clay components, soils at the Project site would have low potential for expansion potential.

In addition, the proposed Project would be required to be constructed in accordance with the CBC to further reduce the risk associated with development on expansive soils. Based on the low potential for soil expansion and required compliance with the CBC, the proposed Project would not result in the risk associated with expansive soils.

Therefore, impacts would be less than significant, and mitigation is not required. e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. The Project site would be served by a wastewater conveyance system maintained by the City’s Wastewater Management Division (WMD). Wastewater from the City’s collection system is treated at the Fresno/Clovis Regional Wastewater Reclamation Facility. Development of the proposed Project would not involve the use of septic tanks or alternative wastewater disposal systems . Therefore, no impact would occur, and mitigation is not required.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than Significant with Mitigation Incorporated. The Project site is underlain by nonmarine deposits of the Pleistocene era (Qc) and Great Valley fan deposits (Qf) , both of which have low paleontological sensitivity due to their relatively young age. 28 The maximum depth of excavation would be up to 6 feet for utility trenching and would not be expected to reach the underlying bedrock. Further, Mitigation Measure GEO-1 has been identified to address inadvertent discovery of paleontological resources if encountered during excavation activities. Based on the low paleontological sensitivity of the underlying geologic unit and implementation of Mitigation Measure GEO-1, the proposed Project would not directly or indirectly disturb a unique paleontological resource. Therefore, impacts would be less than significant with mitigation.

Mitigation Measures
GEO-1 Inadvertent Dis covery of Paleontological Resources. During excavation activities that reach or occur within the bedrock of the underlying geologic unit, if a paleontological resource is encountered, the Project contractor shall cease ground-disturbing activities within 50 feet of the find. A qualified paleontologist shall evaluate the significance of the resource(s) and recommend appropriate treatment measures. At each fossil locality, field data forms shall be used to record pertinent geologic data, stratigraphic sections shall be measured, and appropriate sediment samples shall be collected and submitted for analysis.

27 Natural Resources Conservation Service. Web Soil Survey. Available online at:
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. Accessed June 2025. 28 California Geological Survey (CGS). 1978. Fresno sheet. Map Scale: 1:250,000. Bouguer Gravity Map of California BGA-05. California Geological Survey Publications. Available online at:
https://ngmdb.usgs.gov/Prodesc/proddesc_114520.htm. Accessed June 2025. 46 Any fossils encountered and recovered shall be catalogued and presented for donation to a public, non- profit institution with a research interest in the materials. Accompanying notes, maps, and photographs shall also be filed at the repository.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
X
b) Conflict with an applicable plan,
policy or regulation adopted for
the purpose of reducing the
emissions of greenhouse gases?
X

DISCUSSION
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact. The State CEQA Guidelines indicate that a project would normally have a significant adverse GHG emission impact if that project would:
• Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions.

State CEQA Guidelines Section 15064.4 states that: “A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of GHG emissions resulting from a project.” In performing that analysis, the lead agency has discretion to determine whether to use a model or methodology to quantify GHG emissions, or to rely on a qualitative analysis or performance- based standards. In making a determination as to the significance of potential impacts, the lead agency then considers the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting, whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and the extent to which the project complies with regulations or requirem ents adopted to implement a Statewide, regional, or local plan for the reduction or mitigation of GHG emissions. 47 The City does not have a current GHG reduction plan, and the SJVAPCD also does not have adopted thresholds of significance for GHG emissions. Therefore, in the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed Project for consistency with the Bay Area Air District (BAAD) 29 Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (Justification Report). 30 In April 2022, the BAAD adopted the Justification Report, which identifies applicable GHG significance thresholds. These thresholds establish whether a project would be consistent with California’s efforts to meet long- term climate goals as established in the State’s Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan Update),
31 including achieving carbon neutrality by 2045 or earlier. If a project is designed and built to incorporate design elements related to natural gas, energy, VMT, and EVs, then it would contribute its portion of what is necessary to achieve California’s long-term climate goals —its “fair share” —and an agency reviewing the project under CEQA can conclude that the project would not make a cumulatively considerable contribution to global climate change.

The Justification Report provides substantial evidence supporting the use of their thresholds for projects throughout California because the thresholds are applicable to meeting the State’s established GHG reduction goals. In the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed project for consistency with the identified project design elements as the applicable thresholds of significance to establish if the proposed project is achieving its “fair share” of emission reductions to support long- term State goals for GHG emissions and carbon neutrality.

According to the Justification Report, a project would have a less -than-significant impact related to GHG emissions if it would include the following project design elements:

Buildings
a. The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).

29 As of January 2025, the Bay Area Air Quality Management District was renamed the Bay Area Air District.
30 Bay Area Air Quality Management District (BAAQMD). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans . April. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds- 2022/justification-report-pdf.pdf?la=en. Accessed June 2025. 31 California Air Resources Board (CARB). 2022. 2022 Scoping Plan Documents. Available online at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan- documents. Accessed June 2025.
48 b. The project will not result in any wasteful, inefficient, or unnecessary electrical usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

Transportation
a. Achieve a reduction in project -generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA:
i. Residential projects: 15 percent below the existing VMT per capita ii. Office projects: 15 percent below the existing VMT per employee iii. Retail projects: no net increase in existing VMT
b. Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

These project design elements are utilized in the following analysis as the thresholds of significance to evaluate the proposed Project’s potential GHG emissions impact.

Per the significance thresholds described above, a less -than-significant GHG impact would occur if the proposed P roject were consistent with the identified design standards, as evaluated below.

Construction Greenhouse Gas Emissions
Construction activities associated with the proposed Project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil -based fuels creates GHGs such as carbon dioxide (CO 2),
methane (CH 4), and nitrous oxide (N 2O). Furthermore, CH 4 is emitted during the fueling of heavy equipment. Exhaust emissions from on- site construction activities would vary daily as construction activity levels change. The SJVAPCD does not have an adopted threshold of significance for construction-related GHG emissions.

Operational Greenhouse Gas Emissions
Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle and truck trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile- source GHG emissions would include Project - generated vehicle trips to and from the Project site. Area- source emissions would be associated with acti vities such as landscaping and maintenance on the Project site.

Energy-source emissions would be generated at off-site utility providers as a result of increased electricity demand generated by the proposed Project. Waste- source 49 emissions generated by the proposed Project include energy generated by land filling and other methods of disposal related to transporting and managing Project - generated waste. In addition, water -source emissions associated with the proposed Project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment. The SJVAPCD does not have an adopted threshold of significance for operational GHG emissions.

As previously identified, in the absence of any City or SJVAPCD specific guidelines or thresholds, this analysis evaluates the proposed Project for consistency with the BAAD Justification Report, which identifies project design elements as the applicable thresholds of significance. If a project is designed and built to incorporate design elements related to natural gas, energy, VMT, and EVs, then it would contribute its portion of what is necessary to achieve California’s long- term climate goals—its “fair share”—and an agency reviewing a project under CEQA can conclude that the project would not make a cumulatively considerable contribution to global climate change.

Per the significance thresholds described above, a less -than-significant GHG impact would occur if the proposed P roject were consistent with the identified design standards, as evaluated below.

Natural Gas Usage
A less -than-significant GHG impact would occur if the proposed P roject does not include natural gas appliances or natural gas plumbing. The new 120-unit mixed-use development would consist of all-electric buildings and would not include natural gas.

Therefore, the proposed Project would be consistent with this design element.

Energy Use
Under this design criterion, the proposed P roject must not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and State CEQA Guidelines Section 15126.2(b). As evaluated in Section VI, Energy, the energy consumed during construction would be temporary in nature and typical of other similar construction activities in the City.

Federal and State regulations in place require the use of fuel-efficient equipment and vehicles and that wasteful activities, such as diesel idling, be limited. Operational electricity would be provided by PG&E, which consists of 38% renewable energy sources and 57% GHG -free energy sources.
32 By using electricity from PG&E, the
proposed Project would reduce the long-term use of non-renewable energy resources.

Further, the proposed Project would be required to comply with CALGreen and California Energy Code requirements to encourage energy -efficient design.

Therefore, the proposed Project would not result in any wasteful, inefficient, or unnecessary electrical usage, and the proposed Project would be consistent with this design element.

32 Pacific Gas and Electric Company (PG&E). 2022. Exploring Clean Energy Solutions. Available online at: https://www.pge.com/en_US/about-pge/environment/what-we-are-doing/clean-energy- solutions/clean-energy-solutions.page. Accessed June 2025. 50 Vehicle Miles Traveled
As discussed above, development that meets a locally adopted SB 743 VMT target reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA would be considered to have a less -than-significant GHG emissions impact from transportation sources. As discussed in Section XVII, Transportation, the Fresno VMT Thresholds states that projects with a high level of affordable housing units should be presumed to cause a less -than-significant transportation impact. According to the Fresno Council of Governments (FCOG) VMT Screening Application, 33 the Project
site is in an area that generates low residential VMT, less than 13% of the regional average. The region has an average existing residential VMT per capita of 17.63, and the Project site has an average baseline residential VMT per capita of 10.42. The proposed Project includes the construction of a mixed- use building consisting of a majority of affordable housing units and would be presumed to have a less -than- significant impact related to VMT. Therefore, in addition to the Project site’s location in an area of low residential VMT, the proposed P roject would be screened out from further VMT analysis due to its high level of affordable units. Further, the proposed Project would include the construction of local -serving commercial uses in close proximity to existing and proposed residences, which would reduce regional VMT by reducing the length of vehicle trips that are needed to reach these services elsewhere.

The Project site is also in close proximity to an existing transit stop and the proposed Project includes implementation of off -site pedestrian ROW improvements, which would promote the use of alternative modes of transportation and promote the reduction of project VMT. Therefore, the p roposed P roject would meet a locally adopted SB 743 VMT target reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA; and the proposed Project would be consistent with this design element.

Electric Vehicle Requirements
Under this design criterion, the proposed P roject must demonstrate consistency with the Tier 2 measures for off -street EV parking included in the most recently adopted version of CALGreen. The proposed Project would include the construction of 231 new parking stalls for residential and commercial uses, including 10 EV-capable, 26 EV-ready spaces, and five EVSE spaces for residential uses and 25 EV -capable and six EVSE spaces for commercial uses in accordance with 2022 CALGreen requirements. Therefore, the proposed Project would be consistent with this design element.

Conclusion
The proposed Project would be consistent with the Project design elements related to natural gas, energy, VMT, and EVs, which demonstrate that the proposed Project is

33 Fresno Council of Governments (FCOG). 2025. Fresno County – VMT Screening Application. Available at: https://lsa.maps.arcgis.com/apps/dashboards/8c52b2d1f61b48f89312c904935f5d9b. Accessed November 2025.
51 achieving its “fair share” of GHG emission reductions. The proposed Project would not generate substantial GHG emissions or conflict with plans, policies, or regulations adopted for the purpose of reducing GHG emissions. Therefore, impacts would be less than significant.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than Significant Impact. As described in Impact Discussion VIII.a) , the proposed Project would not conflict with plans, policies, or regulations adopted for the purpose of reducing GHG emissions, including State initiatives, or the BAAQMD Thresholds for Land Use Projects.
34 Therefore, impacts would be less than significant.

Mitigation Measures
Mitigation measures are not required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to
the public or the environment
through the routine transport, use,
or disposal of hazardous
materials?
X
b) Create a significant hazard to
the public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of
hazardous materials into the
environment?
X
c) Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within one-
quarter mile
of an existing or proposed
school?
X

34 Bay Area Air Quality Management District (BAAQMD). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans . April. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds- 2022/justification-report-pdf.pdf?la=en. Accessed June 2025. 52 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Be located on a site which is
included on a list of hazardous
materials sites compiled pursuant
to Government Code Section
65962.5 and, as a result, would it
create a significant hazard to the
public or the environment?
X
e) For a project located within an
airport land use plan or, where
such a plan has not been
adopted, within two miles of a
public airport or public use airport,
would the project result in a safety
hazard for people residing or
working in the project area?
X
f) Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
X
g) Expose people or structures ,
either directly or indirectly, to a
significant risk of loss, injury or
death involving wildland fires?
X

DISCUSSION
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less than Significant Impact. Construction activities associated with the proposed Project would involve the use of limited amounts of potentially hazardous materials, including, but not limited to, solvents, paints, fuels, oils, and transmission fluids.

However, all materials used during construction would be contained, stored, and handled in compliance with applicable standards and regulations established by the U.S. Environmental Protection Agency (USEPA), U.S. Occupational Safety and Health Administration (OSHA) , and California Department of Toxic Substances Control (DTSC), the. All storage, handling, and disposal of hazardous materials during Project construction and operation would comply with applicable safety standards and regulations.

The proposed Project is limited to the construction of a mixed- use residential and commercial development and associated private on- site park facility, 53 and no manufacturing, industrial, or other uses utilizing large amounts of hazardous materials would occur at the Project site. Therefore, impacts related to the routine transport, use, or disposal of hazardous materials would be less than significant, and no mitigation is required.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less than Significant with Mitigation Incorporated. As described in Impact Discussion IX.a), the proposed Project would not result in a significant hazard to the public or environment through the transport of hazardous materials through required compliance with applicable standards and regulations established by the USEPA, OSHA, and DTSC.

A Phase I Environmental Site Assessment (ESA; Appendix B) 35 was prepared for the
proposed P roject to determine if any on- site Recognized Environmental Concerns (RECs), including, but not limited to, soil staining, aboveground storage tanks ; signs of underground storage tanks, odors, hazardous debris, etc. Based on the results of the background review and field vis it, no evidence of RECs, controlled RECs , or historical RECs occur within the Project site. The background review found that a 1.5- acre area on the western portion of the Project site was used as a small -plot agricultural use between 2002 and 2009. It is not uncommon for agricultural land to be subject to the implementation of a pest management strategy that includes the application of pesticides and organochlorine pesticides (OCPs). Although no evidence of the use of environmentally persistent OCPs was obtained, due to the recent agricultural use of the Project site, Mitigation Measure HAZ -1 requires a chemical analysis of shallow soil samples to screen for OCPs in the area of the 1.5- acre agricultural plot and identifies proper disposal methods for contaminated soils.

The Project site is not located in an area with known potential for NOA. Therefore, construction activities would not have the potential to expose workers or surrounding land uses to harmful levels of NOA. The proposed Project does not include any demolition activities that could disturb ACM or LBP. The proposed Project would include operation of residential and commercial uses that would use limited quantities of common household substances and would not result in the use of large quantities of hazardous materials that could create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions.

Based on implementation of Mitigation Measure HAZ-1, and required compliance with existing regulations, the proposed Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset or accident

35 Krazan and Associates, Inc. (Krazan). 2025. Phase I Environmental Site Assessment, Cottage Home Development, North of Belmont Avenue & Dewitt Avenue, APN 456-030-60T, Fresno, California, 93727. June 17.
54 conditions involving the release of hazardous materials into the environment , Therefore, impacts would be less than significant with mitigation. c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one- quarter mile of an existing or proposed school?
No Impact. The closest existing school is Bakman Elementary School , located approximately 1.2 miles east of the Project site. Further, there are no planned schools within a 0.25 -mile radius of the Project site. T he Project site would not be located within 0.25 mile of an existing or planned school . Therefore, no impact would occur, and mitigation is not required.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. According to the DTSC EnviroStor36 and State Water Resources Control Board (State Water Board) GeoTracker37 databases, the Project site is not located on a federal superfund site, State response site, voluntary cleanup site, school cleanup site, evaluation site, school investigation site, military evaluation site, tiered permit site, or corrective action site. Additionally, the Project site does not contain active hazardous waste sites included on the list of hazardous waste sites compiled pursuant to California Government Code Section 65962.5. 38 As a result, no hazards to the public or environment are anticipated. Therefore, no impact would occur, and mitigation is not required.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
No Impact. The nearest airports include the Fresno Yosemite International Airport, located approximately 1.4 miles north west of the Project site; Fresno Chandler Executive Airport, located approximately 6.5 miles southwest of the Project site; and the Sierra Sky Airport, located approximately 11.2 miles to the northwest of the Project site. The nearest medical center helipads include Community Regional Medical Center, located approximately 4.5 miles south-west of the Project site. Each of these airports is considered under the Fresno County Airport Land Use Compatibility Plan

36 California Department of Toxic Substances Control (DTSC). 2025. EnviroStor. Available online at:
https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=fresno. Accessed June 2025. 37 State Water Resources Control Board (State Water Board). 2025. GeoTracker. Available online at:
https://geotracker.waterboards.ca.gov/. Accessed June 2025. 38 California Environmental Protection Agency (CalEPA). 2018. Government Code Section 65962.5(a) Hazardous Waste and Substances Site List. Available online at:
https://calepa.ca.gov/sitecleanup/corteselist/section-65962-5a/. Accessed June 2025. 55 (Fresno County ALUCP),39 which guides local jurisdictions in determining appropriate compatible land uses with detailed findings and policies. The Fresno County ALUCP includes airport safety zone maps that are based on the likelihood of aircraft accidents adjacent to airports. The Project site is located within Saf ety Zone 6 - Traffic Pattern Zone, which is an area of low aircraft accident risk. Due to the distance between the Project site and local airports and helipads, the proposed Project would not result in a safety hazard for people residing or working in the Project area. Therefore, no impact would occur, and mitigation is not required.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact. The City does not have an adopted Emergency Response and Evacuation Plan; however, the Fresno County Multi -Jurisdictional Hazard Mitigation Plan
40 contains several goals and policies regarding emergency evacuation, including Objective 1.3: Improve community transportation corridors to allow for better evacuation routes for the public and better access for emergency responders. The proposed Project includes the construction of up to 120 residential units, up to 15,000 square feet of retail/commercial space , and a private on-site park facility on an existing parcel. The proposed Project would not require any temporary traffic controls . As such, the proposed Project would not result in the alteration of existing roadways that could interfere with emergency evacuation routes within the City or an adopted emergency response plan. The proposed Project would be consistent with the Fresno County Multi -Jurisdictional Hazard Mitigation Plan . 41 Therefore, impacts would be less than significant, and mitigation is not required. g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Less than Significant Impact . The Project site is located in an area mapped as a Local Responsibility Area (LRA) and is not located within a V ery High Fire Hazard Severity Zone (VHFHSZ),
42 indicating that the area is urbanized and not susceptible

39 Fresno Council of Governments (Fresno COG). 2021. Fresno County Airport Land Use Compatibility Plan. December 2018; Amended December 2021. Available online at:
https://www.dropbox.com/scl/fi/clh8iltq4f3eb10qyp93i/Fresno-Updated-ALUCP-Amended-Oct- 2023.pdf?rlkey=e4ao8oy6ifk2btgzci95szb0u&e=1&dl=0. Accessed June 2025. 40 County of Fresno. 2018. Fresno County Multi-Jurisdictional Hazard Mitigation Plan. May. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/FresnoCountyHMPFinal.pdf. Accessed June 2025.
41 County of Fresno. 2018. Fresno County Multi-Jurisdictional Hazard Mitigation Plan. May. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/FresnoCountyHMPFinal.pdf. Accessed June 2025.
42 California Department of Forestry and Fire Protection (CAL FIRE). 2023. Fresno County State Responsibility Area Fire Hazard Severity Zones. June 15. Available online at: https://34c031f8-c9fd- 4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/what-we-do/community- wildfire-preparedness-and-mitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-map- 2022/fire-hazard-severity-zones-maps-2022-files/fhsz_county_sra_11x17_2022_fresno_2.pdf.

Accessed June 2025.
56 to wildland conflagrations. The proposed Project would be constructed in accordance with the California Fire Code (CFC) to reduce risk of loss, injury, or death involving wildland fires. The Project site is located in a highly developed area that is not considered to be a VHFHSZ and is required to comply with the CFC to reduce risk associated with wildfire ignition at the Project site. Based on the proposed Project’s location and required compliance with the CFC , the proposed P roject would not expose people or structures to a significant loss, injury , or death involving wildland fires. Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
HAZ-1 Soil sampling. Prior to site disturbance, the construction contractor shall retain a qualified professional to conduct a chemical analysis of shallow soil samples to screen for persistent pesticides , organochlorine pesticides, and herbicides in the area of the 1.5-acre agricultural plot on the western portion of the Project parcel. If reportable amounts of persistent pesticides, organochlorine pesticides, or herbicides are identified within the Project site, the soils shall be handled and disposed of in accordance with State and local regulations established by applicable agencies , including, but not limited to, U.S.

Environmental Protection Agency, State Water Resources Control Board, California Department of Toxic Substances Control, and Fresno County Department of Public Health – Environmental Health Division , as directed by the City of Fresno.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface or
ground water quality?
X
b) Substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge such that the project
may impede sustainable
groundwater management of the
basin?
X
57 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river, or through the
addition of impervious surfaces, in
a manner which would:

X
i) Result in a substantial erosion or
siltation on- or off-site; X
ii) Substantially increase the rate
or amount of surface runoff in a
manner which would result in
flooding on- or off-site:

X
iii) create or contribute runoff
water which would exceed the
capacity of existing or planned
stormwater drainage systems or
provide substantial additional
sources of polluted runoff; or
X
iv) impede or redirect flood flows? X
d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
X
e) Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
X

DISCUSSION
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less than Significant Impact . The State Water Board and nine RWQCBs regulate the water quality of surface water and groundwater bodies throughout California. The proposed Project is within the jurisdiction of the Central Valley RWQCB.

Pollutants of concern during construction include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. During Project 58 construction, there would be an increased potential to expose soils to wind and water erosion, which could result in temporary minimal increases in sediment load in nearby waterbodies. There is a human-made basin located approximately 0.25 mile northwest of the Project site; however, there are no surface water resources located within or adjacent to the Project site.

Project construction activities would result in approximat ely 9.7 acres of ground disturbance, including approximately 15,649 CY of cut and fill. In compliance with the General Plan, any development project disturbing 1 acre or more of soil must obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit Order 2009‐ 0009‐DWQ).

Construction activities subject to the Construction General Permit include clearing, grading, and other ground‐disturbing activities such as stockpiling or excavation. The Construction General Permit requires development and implementation of a SWPPP.

A SWPPP includes features designed to eliminate contact of rainfall and stormwater runoff with sources of pollution that occur on construction sites, the main source being soil erosion resulting from unstabilized soils coming in contact with water and wind.

These features are known as BMPs. Common BMPs to limit pollution in stormwater runoff from construction sites include maintaining or creating drainages to convey and direct surface runoff away from bare areas and installing physical barriers such as berms, silt fencing, waddles, straw bales, and gabions. The proposed P roject would be required to comply with requirements under the Central Valley RWQCB National Pollutant Discharge Elimination System (NPDES) Construction General Permit, including the SWPPP and BMPs, which would reduce Project construction impacts on water quality. In addition, the proposed Project would be required to comply with Municipal Code Chapter 6, Article 7 ( Urban Storm Water Quality Management and Discharge Control ), which requires the implementation of BMPs to reduce and/or eliminate pollutant discharge during construction.

Long-term operation impacts associated with the proposed Project would be reduced to less-than-significant levels with the implementation of the City’s Storm Drainage and Flood Control Master Plan (SDFCMP), which manages the City’s stormwater drainage systems, and the City’s participation in the Phase 1 NPDES Permit for Stormwater Discharges From Municipal Separate Storm Sewer Systems (Phase 1 MS4),
43 which requires the City to implement water quality and watershed protection measures for all development projects. Therefore, impacts would be less than significant, and mitigation is not required.

43 Regional Water Quality Control Board (RWQCB). 2016. National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements General Permit for Discharges from Municipal Separate Storm Sewer Systems. Order R5-2016-0040; NPDES No. CAS0085324. California Regional Water Quality Control Board Central Valley Region. June 23. Available online at:
https://www.waterboards.ca.gov/rwqcb5/board_decisions/adopted_orders/general_orders/r5- 2016- 0040_ms4.pdf. Accessed June 2025.
59 b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less than Significant Impact . The Project site is located in the Kings Subbasin of the San Joaquin Valley Groundwater Basin.
44 The Kings Subbasin encompasses an
area of approximately 976,000 acr es (1,530 square miles) within Fresno, Kern, and Tulare Counties ; therefore, a marginal increase in impervious surface area at the Project site would not substantially interfere with groundwater recharge in a manner that could impede sustainable groundwater management of the basin.

The City’s Water Division provides potable water to the majority of the City and some users within the City’s Sphere of Influence ( SOI), with the exception of the Bakman Water Company (Bakman), Pinedale County Water District, Park Van Ness Mutual Water Company, and California State University, Fresno. The Project site is within the Bakman service area and water supply for the proposed Project would be supplied by Bakman. Wastewater services for the proposed Project would be provided by the City Department of Public Utilities (DPU) Water and Wastewater Management Divisions.

As discussed in Bakman’s 2020 Urban Water Management Plan (UWMP), 45 Bakman
relies on groundwater from the Kings Subbasin for water supply . Bakman also has access to surface water supplies for recharge purposes. As discussed in Section XIX, Utilities and Service Systems , Bakman’s water supply has historically been very consistent, due in large part to the reliability of the groundwater aquifer, and it is anticipated to remain reliable into the future year of 2040. The demand on water supply is expected to be consistent with the existing and future water supply, and the groundwater supply would not result in any deficiencies for future users in the service area.46 Therefore, the proposed Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the proposed Project may impede sustainable groundwater management of the basin. Therefore, impacts would be less than significant, and mitigation is not required. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? Less than Significant Impact. There are no existing streams or rivers on or adjacent to the Project site, and the proposed Project would not result in direct alteration of any drainage or surface water features. Construction of the proposed Project would result in grading on the Project site that would expose native soils

44 California Department of Water Resources (DWR). 2006. San Joaquin Valley Groundwater Basin Kings Subbasin. California’s Groundwater Bulletin 118. Available at: https://water.ca.gov/-/media/DWR- Website/Web-Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003-Basin- Descriptions/5_022_08_KingsSubbasin.pdf. Accessed June 2025. 45 Bakman Water Company (Bakman). 2021. 2020 Urban Water Management Plan. August. 46 Bakman Water Company (Bakman). 2021. 2020 Urban Water Management Plan. August. 60 that could be subject to the effects associated with wind and water erosion unless adequate measures are taken to limit the transport of soil in surface water from the Project site to downstream locations.

Stormwater collection and disposal and flood control for the City of Fresno, City of Clovis, and unincorporated areas within the City’s SOI are provided by the Fresno Metropolitan Flood Control District (FMFCD). The proposed Pr oject site is a

9.7-acre undeveloped vacant lot that does not contain any storm drainage features on-site. There is one biofiltration swale located adjacent to the northeastern edge of the Project site and one approximately 0.02 mile east of the Project site along North Clovis Avenue.

The proposed Project would disturb approximately 9.7 acres of soil and be required to comply with the RWQCB NPDES General Construction Permit Requir ements.

The proposed Project would also be required to comply with Municipal Code Chapter 6, Article 7 ( Urban Storm Water Quality Management and Discharge Control), requiring the implementation of a SWPPP that includes BMPs to reduce erosive runoff during construction. Following Project construction, the Project site would be covered with hardscapes that would reduce the potential for long- term erosion to occur at the Project site. Additionally, compliance with the City’s grading plan check process, the FMFCD SDFCMP, and stipulations of the RWQCB NPDES Construction General Permit requirements would ensure that potential impacts related to erosion and saltation on- and off -site would be less than significant, and mitigation is not required.
ii. Substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site?
Less than Significant Impact. The proposed Project site is a 9.7- acre undeveloped vacant lot and does not contain any storm drainage features on-site.

The proposed Project includes the construction of a new mixed-use development and would result in an increase in impervious surfaces at the Project site. Ground‐ disturbing activities related to project construction, such as grading, excavation, placing fill, and trenching, could change existing surface drainage patterns and increase the potential for flooding, particularly during storm events. Regulatory mechanisms in place that would reduce the effects of construction activities on drainage patterns that would result in flooding on or off the construction site include compliance with the City’s grading plan check process, the FMFCD SDFCMP, and the RWQCB NPDES Construction General Permit. Compliance with these required regulations would reduce P roject construction impacts on grading patterns and flooding on and off the construction site to less-than-significant levels.

Long-term operation impacts associated with the proposed Project would be reduced to less -than-significant levels with the implementation of the FMFCD SDFCMP, which manages the City’s stormwater drainage systems, and the City’s 61 participation in the Phase 1 MS4, 47 which requires the City to implement water quality and watershed protection measures for all development projects. Based on required compliance with City stormwater requirements, the proposed Project would not increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. Therefore, impacts would be less than significant, and mitigation is not required.
iii. Create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Less than Significant Impact. Please refer to Impact Discussions X.a), X.c.i, and X.c.ii). The proposed P roject would increase impervious surfaces at the Project site; however, with implementation of a SWPPP, which would require execution of BMPs for controlling pollution sources during Project construction, compliance with the FMFCD SDFCMP, implementation of the RWQCB NPDES Permit , and adherence to the stipulations of the Phase 1 MS4, the proposed Project would not exceed capacity of stormwater drainage systems or generate additional sources of polluted runoff. Additionally, the Project Applicant would pay the City a Drainage Fee to address impacts related to the increased amount of surface runoff resulting from the proposed Project. Based on required compliance with existing regulations, the proposed P roject would not create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff . Therefore, impacts would be less than significant, and mitigation is not required. iv. Impede or redirect flood flows?
Less than Significant Impact. Regulations in 40 Code of Federal Regulations (CFR) Part 60 and the City’s F loodplain Ordinance require that placement and flood provision structures within a floodplain not result in a cumulative change in the floodplain water surface that exceeds 1 foot. In addition, the regulations under 40 CFR 60 do not allow placement of structures within a regulatory floodway unless that placement would not result in any increase in the floodplain water surface elevation, meaning that there is no displacement or redirection of the floodway. The City’s Floodplain Ordinance requires that a registered Civil Engineer in the State of California certify that no displacement of floodwater would result from the flood proofing of a structure within a floodplain or a regulatory floodway.

47 Regional Water Quality Control Board. 2016. National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements General Permit for Discharges from Municipal Separate Storm Sewer Systems. Order R5-2016-0040; NPDES No. CAS0085324. California Regional Water Quality Control Board Central Valley Region. June 23. Available online at:
https://www.waterboards.ca.gov/rwqcb5/board_decisions/adopted_orders/general_orders/r5- 2016- 0040_ms4.pdf. Accessed June 2025.
62 According to Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) 06019C1590H (effective date 2/18/2009),48 the proposed Project is located within Shaded Zone X (500- year floodplain), an area of 0.2% annual chance of flood hazard and 1% annual chance of flood with average depth less than 1 foot or with drainage areas of less than 1 square mile. The City’s Floodplain Ordinance applies to Special Flood Hazard Areas (SFHAs), including Zones A, AO, A1-A30, AE, A99, and AH. The Project site is not located within an SFHA and would not be subject to the City’s Floodp lain Ordinance. The Project site is currently an undeveloped vacant lot ; therefore, construction of the proposed Project would increase the amount of impervious surfac e area on the Project site that could increase the rate or amount of surface water runoff. The proposed Project would be s ubject to Municipal Code Chapter 6, Article 7 (Urban Storm Water Quality Management and Discharge Control ), the Phase 1 MS4, and the FMFCD SDFCMP to address long-term pollutant control and drainage conditions at the Project site. Based on required compliance with existing regulations , the proposed Project would not impede or redirect flood flows . Therefore, impacts would be less than significant, and mitigation is not required. d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less than Significant Impact. The Project site is not located in a tsunami or seiche zone, but it is located in a 500-year floodplain, as mapped by FEMA. The Project site is currently an undeveloped vacant lot; therefore, construction of the proposed Project would increase the amount of impervious surface area on the Project site that could increase the rate or amount of surface water runoff . However, the proposed Project would be subject to RWQCB requirements, Municipal Code Chapter 6 , Article 7 (Urban Storm Water Quality Management and Discharge Control), the Phase 1 MS4, and the FMFCD SDFCMP for short - and long- term pollutant control and drainage conditions. Based on compliance with RWQCB and City requirements, the proposed Project would not risk the release of pollutants due to project inundation. Therefore, impacts would be less than significant, and mitigation is not required. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than Significant Impact. The City is located within the Kings Subbasin, which is part of the larger San Joaquin Valley Groundwater Basin. As evaluated in Impact Discussion X.b), the proposed Project would not decre ase groundwater supply or interfere with groundwater recharge in a manner that would impede sustainable management of the groundwater basin. The planning documents regarding groundwater resources for the City include the North Kings Groundwater Sustainability

48 Federal Emergency Management Agency (FEMA). 2020. FEMA Flood Map Service Center: Search By Address. Available online at: https://msc.fema.gov/portal/search?AddressQuery#searchresultsanchor Accessed June 2025.
63 Agency (GSA) Groundwater Sustainability Plan,49 City’s 2020 Urban Water Management Plan,50 and City’s Metropolitan Water Resources Management Plan. 51 As evaluated in Impact Discussion X .b), the proposed Project would not decrease groundwater supply or interfere with groundwater recharge in a manner that would impede sustainable management of the groundwater basin.

The Project site is under the jurisdiction of the Central Valley RWQCB and would be subject to The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region,52 which established water quality objectives for beneficial uses of water resources within the Sacramento and San Joaquin River Basins. The proposed Project would be required to adhere to RWQCB NPDES drainage control requirements during construction and operation, as well as long-term drainage requirements established by the Phase 1 NPDES and FMFCD. In addition, the proposed Project would be required to comply with Municipal Code Chapter 6, Article 7 (Urban Storm Water Quality Management and Discharge Control) during construction and operation, which requires the implementation of BMPs to reduce and/or eliminate pollutant discharge during construction. Based on required compliance with RWQCB and City requirements, the proposed Project would be consistent with sustainable management of the San Joaquin Valley G roundwater Basin and Basin Plan and would not conflict with any applicable water quality control plan or groundwater management plan. Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.

49 North Kings Groundwater Sustainability Agency (GSA). 2025. Groundwater Sustainability Plan.

Available at: https://northkingsgsa.org/groundwater-sustainability-plan/. Accessed August 2025. 50 City of Fresno. 2021a. Final 2020 Urban Water Management Plan. City of Fresno Department of Public Utilities. Available at: https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-2020- UWMP_Final_2021-07-21.pdf. Accessed June 2025.
51 City of Fresno. 2007. Metropolitan Water Resources Management Plan Update. Available at:
https://www.fresno.gov/wp-
content/uploads/2023/03/Phase1BaselineSystemCharacterizationDec2007.pdf . Accesses August 2025. 52 Regional Water Quality Control Board (RWQCB). 2019. The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region. Fifth Edition. California Regional Water Quality Control Board Central Valley Region. Revised February 2019 (with Approved Amendments). Available at:
https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/sacsjr_201902.pdf . Accessed June 2025.
64 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an
established community? X
b) Cause a significant
environmental impact due to a
conflict with any land use plan,
policy, or regulation adopted for
the purpose of avoiding or
mitigating an environmental
effect?
X

DISCUSSION
a) Physically divide an established community?
No Impact. The physical division of an established community typically refers to the construction of a physical feature (such as an interstate highway or railroad tracks) or removal of a means of access (such as a local road or bridge) that would impair mobility within an existing community, or between a community and outlying areas.

For instance, the construction of an interstate highway through an existing community may constrain travel from one side of the community to another; similarly, such construction may also impair travel to areas outside of the community.

The proposed project site is a 9.7-acre City-owned parcel located in an urbanized area and consists of an existing undeveloped and vacant parcel on the north side of East Belmont and North Dewitt Avenues. The proposed Project site was previously merged and is now considered to have split zoning, with the western section zoned RM-1 and the eastern section zoned CMX. The proposed Project would include the construction of a mixed- use and multi -family residential development on an existing parcel, with minor off -site improvements for the extension of utility infrastructure and ROW improvements. These improvements and the proposed Project would not affect connectivity and would not divide an established community. Therefore, no impact would occur, and no mitigation is required.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant with Mitigation Incorporated. The Project site is in the RM-1 and CMX zone districts and land use designations in the General Plan. The RM-1 zone district and land use designation allows for 12 to 16 dwelling units per acre and is intended for neighborhoods with a mix of single-family residences, townhomes, and multi-family units as well as park facilities . The CMX zone district and land use 65 designation allows a minimum of 16 dwelling units per acre with no limit on the maximum number of dwelling units as well as park facilities. This land use is intended to allow for horizontal and vertical mixed- use development consisting of multi -story buildings along key circulation corridors.

The proposed Project is consistent with standards and policies set forth in the General Plan, Fresno Municipal Code, SJVAPCD 2022 Ozone Plan, SJVAPCD 2024 PM2.5 Plan, and any other applicable plans. The P roject Applicant would be required to implement Mitigation Measures AQ-1 through AQ-4 included in Section III, Air Quality; Mitigation Measures BIO-1 and BIO-2, included in Section IV, Biological Resources ; Mitigation Measure CR -1, included in Section V, Cultural Resources ; Mitigation Measure GEO-1, included in Section VII, Geology and Soils; Mitigation Measure HAZ- 1, included in Section IX, Hazards and Hazardous Materials; and Mitigation Measure N-1, included in Section XIII, Noise, to mitigate potential impacts associated with Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Noise, and Tribal Resources, which is consistent with identified plans, policies, and regulations intended to avoid or mitigate adverse environmental effects. With the implementation of the identified mitigation measures, the proposed Project would not conflict with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating environmental effects. Therefore, the impact would be less than significant with mitigation.

Mitigation Measures
Implement Mitigation Measure AQ -1 through AQ-4 included in Section III , Air Quality; Mitigation Measures BIO-1 and BIO -2, included in Section IV, Biological Resources ; Mitigation Measure CR-1, included in Section V, Cultural Resources; Mitigation Measure GEO-1, included in Section VII, Geology and Soils; Mitigation Measure HAZ-1, included in Section IX, Hazards and Hazardous Materials ; and Mitigation Measure N-1, included in Section XIII, Noise.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability
of a known mineral resource that
would be of value to the region
and the residents of the state?
X
b) Result in the loss of availability
of a locally -important mineral
resource recovery site delineated
on a local general plan, specific
plan or other land use plan?
X
66 DISCUSSION
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
No Impact. The principal area for mineral resources in the City is located along the San Joaquin River Corridor. The California Department of Mines and Geology classifies lands along the San Joaquin River Corridor as Mineral Resource Zone (MRZ-) 1, MRZ-2, and MRZ-3. The Project site is not located in the vicinity of the San Joaquin River, is not an MRZ, and does not contain an MRZ. The Project site is in the RM-1 and CMX zone districts and land use designations , as defined in the General Plan, and is not zoned for mineral extraction. As such, the proposed Project would not result in the loss of availability of a known mineral resource of value to the region or residents of the State. Therefore, no impact would occur, and no mitigation is required. b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. Please refer to Impact Discussion XII.a). The proposed Project would not result in the loss of availability of any known locally important mineral resource recovery sites. Therefore, no impact would occur, and no mitigation is required.

Mitigation Measures
Mitigation measures are not required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial
temporary or permanent increase
in ambient noise levels in the
vicinity of the project in excess of
standards established in the local
general plan or noise ordinance,
or applicable standards of other
agencies?
X
b) Generation of excessive
groundborne vibration or
groundborne noise levels?
X
67 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project expose people residing or
working in the p roject area to
excessive noise levels?
X

DISCUSSION
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or in other applicable local, state, or federal standards?
Less than Significant with Mitigation Incorporated. Noise is usually defined as unwanted sound and consists of any sound that may produce physiological or psychological damage and/or interfere with communication, work, rest, recreation, or sleep. Several noise measurement scales exist that are used to describe noise in a particular location. A decibel (dB) is a unit of measurement that indicates the relative intensity of a sound. Sound levels in dB are calculated on a logarithmic basis. An increase of 10 dB represents a 10- fold increase in acoustic energy, while 20 dB is 100 times more intense and 30 dB is 1,000 times more intense. Each 10 dB increase in sound level is perceived as approximately a doubling of loudness , and similarly, each 10 dB decrease in sound level is perceived as half as loud. Sound intensity is normally measured through the A -weighted sound level (dBA). This scale gives greater weight to the frequencies of sound to which the human ear is most sensi tive.

The A-weighted sound level is the basis for 24-hour sound measurements that better represent human sensitivity to sound at night.

As noise spreads from a source, it loses energy so that the farther away the noise receiver is from the noise source, the lower the perceived noise level would be.

Geometric spreading causes the sound level to attenuate or be reduced, resulting in a 6 dB r eduction in the noise level for each doubling of distance from a single point source of noise to the noise sensitive receptor of concern.

There are many ways to rate noise for various time periods, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound.

Equivalent continuous sound level (Leq) is the total sound energy of time- varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq, the community noise equivalent 68 level (CNEL), and the day-night average level (Ldn) based on dBA. CNEL is the time varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours) and 10 dBA weighting factor applied to noise occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale, but without the adjustment for events occurring during the evening relaxation hours. CNEL and Ldn are within 1 dBA of each other and are normally exchangeable. The noise adjustments are added to the noise events occurring during the more sensitive hours.

A project would have a significant noise effect if it would substantially increase the ambient noise levels for adjoining areas or conflict with adopted environmental plans and goals of applicable regulatory agencies, including, as appropriate, the City.

Existing Ambient Noise Setting
Noise is addressed in the Fresno General Plan Noise and Safety Element 53 and
Municipal Code Chapter 10, Article 1 ( Noise Regulations ). The Noise and Safety Element sets noise standards for stationary noise sources, as shown in Table 2.

Table 2: Stationary Noise Source
Daytime
(7:00 a.m.–10:00 p.m.)
Nighttime
(10:00 p.m.–7:00 a.m.)
Hourly Equivalent Sound
Level (Leq), dBA
50 40
Maximum Sound Level
(Lmax), dBA
70 60
Source: City of Fresno (2020a)
Note: Lmax = maximum sound level
Further, according to Implementing Policy NS-1-J of the Noise and Safety Element, a significant increase in ambient noise levels is assumed if a project would increase noise levels in the immediate vicinity by 3 dB Ldn or CNEL or more above the ambient noise limits established in the General Plan.

Existing ambient noise levels in the Project area consist of vehicle noise along SR - 180, Belmont Avenue, North Clovis Avenue, and other proximate roadways , as well as noise from surrounding multi -family residential and commercial land uses .

According to Figure NS-2 of the Noise and Safety Element, existing noise levels along SR-180 are over 80 dB and the levels along Belmont and North Clovis Avenues are between 60 and 75 dB.

53 City of Fresno. 2020a. Fresno General Plan, Chapter 9: Noise and Safety Element. Updated May 21.

Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/9-Noise-and-Safety-02-03-

21.pdf. Accessed June 2025.
69 Construction-Related Impacts
During Project construction, noise from construction activities may intermittently dominate the noise environment in the immediate Project area. Construction of t he proposed Project would require the use of typical construction equipment (e.g., dozers, excavators, etc.) during proposed construction and excavation activities.

According to the Federal Highway Administration (F HWA), noise from standard construction equipment generally ranges between 80 and 85 dBA Leq at 50 feet from the source. The nearest noise- sensitive land uses are multi -family residences 10 to 50 feet from the Project site to the north , south, and west and an urgent care facility 750 feet to the east of the P roject site. According to Municipal Code Section 10- 109 (Noise Regulations Exceptions), construction-related noise is exempt from the City’s noise standards between 7:00 a.m. and 10:00 p.m. on any day except Sunday.

Construction-related noise associated with the proposed Project would be temporary and conducted in accordance with the Municipal Code. Due to the proximity of nearby noise-sensitive land uses, Mitigation Measure N -1 has been included to reduce construction-related noise through implementation of noise- reducing construction BMPs. With implementation of Mitigation Measure N -1, construction of the proposed Project would not result in a substantial increase in construction -related noise or exceed City noise standards . Therefore, impacts would be less than significant with mitigation.

Operational Impacts
The proposed Project would add 120 residential units with the potential to have approximately 240 new residents. The Project site would also include 15,000 square feet of retail/commercial space and associated site improvements, including a private on-site park facility. All futures uses would be limited to “permitted” uses for the RM-1 and CMX zone districts and land use designations , which includes residential and mixed-use dwellings as well as park facilities . As such, the proposed Project would not result in any major changes to the existing or planned ambient noise setting.

Potential sources of operational noise would include stationary noise from mechanical equipment associated with heating, ventilation, and air conditioning (HVAC) equipment for residential and commercial uses and mobile noise from vehicle trips generated by the proposed Project. Noise generated by HVAC systems or other equipment would not result in a noticeable increase in ambient noise levels based on the density of surrounding development. The private on-site park facility would be located within the central portion of the site and would not be located along any property boundaries. Further, the proposed private on-site park facility would primarily serve on-site residents and would only be available to other members of the public through a paid membership- based system. This would limit the generation of additional population at the proposed Project site and would not result in a noticeable increase in ambient noise levels. Further, the hours of operation of the private on-site park facility would be limited to the hours of 7:00 a.m. and 10:00 p.m ., which is consistent with the City’s noise ordinance. In addition, the proposed Project would be located in an existing urban area, would be consistent with the existing zoning of the Project site, and would not facilitate substantial or unplanned population growth in a 70 manner that could generate a substantial number of new vehicle trips that could substantially increase long-term ambient noise levels in the Project area.

Per Policy NS-1-J of the Noise and Safety Element, a significant increase in ambient noise levels is assumed if a p roject would increase noise levels in the immediate vicinity by 3 dB. Currently, there are between approximately 54,000 and 78,000 vehicle trips on SR -180, 6,000 and 15,000 vehicle trips on Belmont Avenue, and 30,000 and 35,000 vehicle trips on North Clovis Avenue. 54 The proposed Project would result in up to 800 new vehicle trips. Because the exact distribution of vehicle trips along each proximate roadway is currently not known, the conservative estimate of 800 vehicle trips along SR-180, 800 vehicle trips on Belmont Avenue, and 800 vehicle trips along North Clovis Avenue was assumed. Based on the maximum number of existing vehicle trips along proximate roadways and assumed trip distribution, the proposed Project would result in a total of 78,800 daily trips on SR- 180, 15,800 trips on Belmont Avenue, and 35,800 daily trips on North Clovis Avenue.

Project trips would represent a small increase in noise level —up to approximately

0.044 dBA CNEL on SR-180, up to approximately 0. 22 dBA CNEL on Belmont Avenue, and up to approximately 0.098 dBA CNEL on North Clovis Avenue, based on the following equation:

𝐶𝐶ℎ𝑎𝑎𝑎𝑎𝑎𝑎𝑎𝑎 𝑖𝑖𝑎𝑎 (𝑑𝑑𝑑𝑑𝑑𝑑) = 10 ∗ lo g
10 �𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝑎𝑎𝑎𝑎𝐶𝐶 𝑉𝑉𝑉𝑉𝑉𝑉𝐶𝐶𝑉𝑉𝑎𝑎
Future Volume �
Therefore, vehicle noise generated by the proposed Project would not exceed 3 dB, which is consistent with Policy NS-1-J of the Noise and Safety Element.

Conclusion
The proposed Project would be consistent with the level and scale of surrounding residential and commercial uses and would not result in incompatible land uses that could introduce new sources of adverse noise within the Project area. Based on the limited increase in operational noise, the proposed Project would not increase ambient noise levels in a manner that would be noticeable to surrounding land uses or exceed City noise standards. Therefore, impacts would be less than significant, and mitigation is not required.
b) Generation of excessive groundborne vibration or groundborne noise levels? Less than Significant Impact. Vibration refers to groundborne noise and perceptible motion. Groundborne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors. Vibration energy propagates from a source, through intervening soil and rock layers, to the foundations of nearby buildings. The vibration then propagates from the foundation throughout the remainder of the structure. Building vibration may be perceived by the occupants as the motion of building surfaces, rattling of items on shel ves or hanging on walls, or as a low -

54 ArcGIS. 2024. Fresno Traffic Counts. Available online at:
https://www.arcgis.com/home/webmap/viewer.html?layers=40444f5a3d88427499f034acf8355fc0.

Accessed June 2025.
71 frequency rumbling noise. The rumbling noise is caused by the vibrating walls, floors, and ceilings radiating sound waves. Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by 10 dB or less. This is an order of magnitude below the damage threshold for normal buildings.

The proposed Project has the potential to generate limited groundborne vibration during construction and excavation activities that require the use of heavy equipment.

Equipment used during Project construction and excavation activities would be most similar to a large bulldozer, which generates a vibration level of 0.089 inches per second. Therefore, vibration from short -term construction activities would be below the 0.3 inch per second building damage criterion established by Caltrans . 55 Further,
Municipal Code Section 15-2507 (Vibration) exempts temporary construction activities from the City’s vibration standards. The proposed Project would be limited to the operation of 120 residential units, small commercial businesses, and associated site improvements and would not include new activities or features that could generate substantial groundborne noise. Therefore, impacts related to groundborne vibration would be less than significant, and mitigation is not required. c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No Impact. The nearest medical centers with helipads include Community Regional Medical Center, located approximately 4.5 miles southwest of the Project site, and Saint Agnes Medical Center, located approximately 7.55 miles north west of the Project site. The nearest airports include the Fresno Yosemite International Airport, located approximately 1 mile north of the Project site; Fresno Chandler Executive Airport, located approximately 6.4 miles southwest of the Project site; and the Sierra Sky Airport, located approximately 10.8 miles northwest of the Project site.

Each of these airports is considered under the Fresno County ALUCP, 56 which guides
local jurisdictions in determining appropriate compatible land uses with detailed findings and policies. The General Plan, other City land use plans, and all City land use decisions must be compatible with the adopted Fresno County ALUCP, whi ch includes CNEL noise contours based on projected airport and aircraft operations.

Although the Project site is located within 2 miles of the Fresno Yosemite International Airport, the Project site is not located within the 2022 forecasted NEM Contours (65– 75 dB CNEL) identified in the Fresno Yosemite International Airport Noise Exposure

55 Federal Highway Administration (FHWA). 2006. Construction Noise Handbook. August. Available online at: https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/. Accessed June 2025.
56 Fresno Council of Governments (Fresno COG). 2021. Fresno County Airport Land Use Compatibility Plan. December 2018; Amended December 2021. Available online at:
https://www.dropbox.com/scl/fi/clh8iltq4f3eb10qyp93i/Fresno-Updated-ALUCP-Amended-Oct- 2023.pdf?rlkey=e4ao8oy6ifk2btgzci95szb0u&e=1&dl=0. Accessed June 2025. 72 Map.57 The proposed Project would not result in the exposure of sensitive receptors to the excessive noise levels from aircraft noise sources. Therefore, no impact would occur, and mitigation is not required.

Mitigation Measures
N-1 For the entire duration of the construction phase of the Project, the following noise-reduction measures shall be implemented to ensure that noise levels are maintained within levels allowed by the City of Fresno General Plan Noise and Safety Element:

Construction activities should be limited to the hours of 7:00 a.m. to 10:00 p.m., Monday through Saturday. No construction activities shall occur on Sundays or federal holidays.

Stationary construction equipment that generates noise that exceeds 65 A-weighted decibels (dBA) at the Project boundaries shall be shielded with the most modern noise control devices (i.e., mufflers, lagging, and/or motor enclosures).

Impact tools (e.g., jackhammers, pavement breakers, rock drills, etc.) used for Project construction shall be hydraulically or electrically powered wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools.

Where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used.

All construction equipment shall have the manufacturers’ recommended noise abatement methods installed, such as mufflers, engine enclosures, and engine vibration insulators, intact and operational.

All construction equipment shall undergo inspection at periodic intervals to ensure proper maintenance and presence of noise control devices (e.g., mufflers, shrouding, etc.).

The Project contractor shall inform residents at properties within 300 feet of the Project of proposed construction timelines and noise- compliant procedures to minimize potential annoyance related to construction noise.

57 Fresno County GIS. 2022. Figure 15, Forecast Conditions (2022) Noise Exposure Map. https://flyfresno.com/wp-content/uploads/2018/03/2022-NEM_Contour.pdf. Accessed June 2025. 73 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned
population growth in an area,
either directly (for example, by
proposing new homes and
businesses) or indirectly (for
example, through extension of
roads or other infrastructure)?
X
b) Displace substantial numbers
of existing people or housing,
necessitating the construction of
replacement housing elsewhere?
X

DISCUSSION
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less than Significant Impact. The City’s Planning Area is defined as the geographic area for which the General Plan establishes policies related to future urban growth and resource conservation and includes the area within the City Limits, the City’s SOI, and land immediately north and southwest of the SOI. The General Plan identifies a “General Plan Horizon” and “General Plan Buildout” to categorize and predict future growth and buildout conditions. The General Plan Horizon is set to occur in 2035, and General Plan Buildout refers to complete development under the General P lan past the horizon year of 2050.

General Plan Horizon is set to accommodate a population of approximately 226,000 new residents by 2035, resulting in a total population of 771,000. General Plan Buildout anticipates an additional 425,000 new residents over the existing population, resulting in a total population of 970,000. As of 202 4, the population estimate was 550,105 for the City.
58 General Plan Horizon is set to accommodate an estimated 267,000 residential units by 2035, of which 32,000 residential units would be located in the existing city limits. General Plan Buildout anticipates complete buildout of approximately 336,000 residential units, of which 55,610 units would be located in the existing city limits.

58 U.S. Census Bureau. 2023. Quick Facts, Fresno city, California. Available online at:
https://www.census.gov/quickfacts/fact/table/fresnocitycalifornia/PST045223. Accessed February 2025. 74 The proposed Project includes the construction of a mixed-use development, including up to 120 affordable residential units , up to 15,000 square feet of retail/commercial space, and a private on-site park facility. The proposed Project would result in up to 240 new residents. The Project site is in the City’s RM-1 and CMX zone districts and land use designations and is located entirely within the Fresno City Limits and City’s SOI. The proposed Project would be consistent with the allowable uses of the RM -1 and CMX zone districts and land use designations ; therefore, buildout of the P roject site would be consistent with the City’s planned buildout scenario and would not result in unplanned growth. Further, the proposed P roject includes the construction of affordable housing units that would be consistent with the Fresno Council of Governments (Fresno COG) sixth cycle Regional Housing Needs Allocation (RHNA) Determination that calls for the creation of 58,298 new affordable units within the City between June 30, 2023, and December 31, 2031. Therefore, the proposed P roject would be consistent with local and regional housing projections and would not result in substantial or unplanned growth. The proposed P roject also includes the construction of commercial uses that would be consistent with the allowable uses of the RM-1 and CMX zone districts and land use designations; therefore, any new long- term employment opportunities would be consistent with the City’s planned buildout scenario and would not result in unplanned growth. Proposed demolition and construction activities have the potential to generate short -term employment opportunities; however, Project construction is expected to use workers from the local employment force and would not require workers to relocate to the P roject area. The proposed P roject would not result in unplanned or substantial population growth .

Therefore, impacts would be less than significant, and mitigation is not required. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The Project site is entirely undeveloped. The proposed Project would not require the demolition or removal of existing housing or necessitate the displacement or removal of existing housing. Therefore, no impact would occur, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.
75 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XV. PUBLIC SERVICES – Would the project:
a) Result in substantial adverse
physical impacts associated with
the provision of new or physically
altered governmental facilities,
need for new or physically altered
governmental facilities, the
construction of which could cause
significant environmental impacts,
in order to maintain acceptable
service ratios, response times or
other performance objectives for
any of the public services:

X
Fire protection? X
Police protection? X
Schools? X
Parks? X
Other public facilities? X

DISCUSSION
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause si gnificant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
i. Fire protection?
Less than Significant Impact. The City of Fresno Fire Department (FFD) would provide fire protection services to the proposed Project. There are 21 FFD fire stations in Fresno, and the closest fire station, Fire Station 15, is located approximately 1.7 miles south of the Project site. The proposed Project includes the construction of up to 120 affordable residential units —resulting in as many as 240 new residents—and up to 15,000 square feet of retail/commercial space, and associated on- site improvements, including private on-site park facility , which would incrementally increase the demand for fire protection services. The Project site is in the City’s RM-1 and CMX zone districts and land use designations and is located entirely within the Fresno City Limits. The proposed P roject would be 76 consistent with the allowable uses of the RM -1 and CMX zone districts and land use designations; therefore, buildout of the Project site would be consistent with the City’s planned buildout scenario and would not result in unplanned growth. The proposed Project would also be required to pay a Fire Facilities Fee and a Development Impact Fee pursuant to Municipal Code Chapter 12, Article 4.9 (Fire Facilities Fee) to address the incremental increase in demand on fire services.

The FFD would continue providing fire protection services to the P roject site and would not require additional firefighters to serve the proposed P roject; therefore, the construction of a new or expanded fire station would not be required. The proposed Project would not result in a significant impact on the physical environment or adversely affect emergency response times due to the incremental increase in demand for fire protection services . Therefore, impacts would be less than significant, and mitigation is not required.
ii. Police protection?
Less than Significant Impact . The City of Fresno Police Department (FPD) provides police protection to the P roject site. The Police Department Patrol Division is divided into five policing districts; the Project site is located within the Southeast District. The proposed Project would result in as many as 240 new residents, which would incremental ly increase demand for police protection services. The Project site is in the City’s RM -1 and CMX zone districts and land use designations and is located entirely within the Fresno City Limits. The proposed Project would be consistent with the allowable uses of the RM -1 and CMX zone districts and land use designations; therefore, buildout of the P roject site would be consistent with the City’s planned buildout scenario and would not result in unplanned growth. Additionally, the proposed P roject would be required to pay a Police Impact Fee and a Development Impact Fee pursuant to Municipal Code Chapter 12, Article 4.8 (Police Facilities Fee) to account for the incremental increase in demand on police protection services.

The FPD would continue providing services to the Project site and would not require additional personnel to serve the proposed Project or construction of new or expanded police facilities. The proposed Project would not result in a significant impact on the physical environment or adversely affect emergency response times due to the incremental increase in demand for police protection services .

Therefore, impacts would be less than significant, and mitigation is not required. iii. Schools?
Less than Significant Impact . The Project site is located within the Fresno Unified School District (FUSD), which serves more than 68,000 students and operates 64 elementary schools, 15 middle schools, eight high schools, four alternative schools, and three special education schools. The proposed Project would result in up to 240 new residents, and according to the FUSD, the proposed Project has the potential to generate 65 elementary and middle school students.

The FUSD schools that serve the Project site include Bakman Elementary School, 77 Kings Canyon Middle School, and Sunnyside High School. As discussed in Section XIV, Population and Housing, the proposed Project would not result in substantial or unplanned population growth in a manner that would exceed the City’s planned buildout scenario. Additionally, t he Project developer would be required to pay appropriate school fees pursuant to Municipal Code Chapter 12, Article 8 (Development in Overcrowded School Areas ) at the time of building permits to address the incremental increase in demand on public schools. According to the FUSD, if the assigned neighborhood schools cannot accommodate the increased number of students, current school assignments would be evaluated for potential adjustments. As such, the proposed Project would not require the construction of new or physically altered school facilities . Therefore, impacts would be less than significant, and mitigation is not required.
iv. Parks?
Less than Significant Impact. The proposed Project includes the construction of a mixed-use development, including up to 120 affordable residential units , up to 15,000 square feet of retail/ commercial space, and a private on-site park facility.

The proposed Project would result in up to 240 new residents, which would result in a marginal increase in the demand on public parks and nearby facilities. The Project developer would be required to pay applicable park facilities fees, pursuant to Municipal Code Chapter 12, Article 4.7 ( Park Facilities Fee ), to address the incremental increase in demand on park facilities. In addition, the proposed Project includes the construction of a private on-site park facility, which would reduce the demand on other nearby public parks in the area by providing residents with accessible on- site facilities . The proposed P roject would not require the construction of new or physically altered public park facilities . Therefore, impacts to parks would be less than significant, and mitigation is not required. v. Other public facilities?
Less than Significant Impact. The proposed would result in a marginal demand for other public services, including libraries, community centers, and public health care facilities. The proposed Project would be consistent with the allowable uses of the RM-1 and CMX zone districts and land use designations; therefore, buildout of the P roject site would be consistent with the City’s planned buildout scenario and would not result in unplanned growth that would require new or physically altered governmental facilities. Therefore, impacts would be less than significant , and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.
78 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVI. RECREATION – Would the project:
a) Increase the use of existing
neighborhood and regional parks
or other recreational facilities such
that substantial physical
deterioration of the facility would
occur or be accelerated?
X
b) Does the project include
recreational facilities or require
the construction or expansion of
recreational facilities which might
have an adverse physical effect
on the environment?
X

DISCUSSION
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less than Significant Impact. The proposed Project would include the construction of up to 120 new residential units, up to 15,000 square feet of retail/commercial space, and a private on-site park facility. The proposed Project is estimated to result in up to 240 new residents. The nearest parks include Al Radka Park, located approximately

0.70 mile east of the Project site and Trolley Creek Park, located approximately 1.13 miles southwest of the Project site . The proposed Project may increase the demand on recreational facilities in the vicinity of the Project site. As discussed in Section XIV, Population and Housing, the proposed Project would not result in substantial or unplanned population growth in a manner that would exceed the City’s planned buildout scenario; therefore, the proposed Project would not result in a substantial or unplanned population increase that could rapidly increase the physical deterioration of existing recreational facilities. In addition, the p roposed P roject includes the construction of a private on-site park facility, which would reduce the demand on other nearby public parks in the area by providing residents with accessible on-site facilities.

Further, the Project developer would be required to pay park impact fees pursuant to Municipal Code Chapter 12, Article 4.7 (Park Facilities Fee ) at the time building permits are obtained to account for the in cremental increase in demand on recreational facilities. Therefore, impacts would be less than significant, and mitigation is not required.
79 b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
Less than Significant I mpact. The proposed P roject would consist of the construction of 120 new residential units , up to 15,000 square feet of commercial space, and a private on-site park facility . The proposed private on- site park facility would be located entirely within the footprint of the proposed Project site. The impacts of construction activities at the Project site have been analyzed throughout this Initial Study, and no new impacts would occur as a result of construction activities for the on-site park facility. Therefore, impacts would be less than significant.

Mitigation Measures
Mitigation measures are not required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle and
pedestrian facilities?
X
b) Conflict or be inconsistent with
CEQA Guidelines § 15064.3,
subdivision (b)?
X
c) Substantially increase hazards
due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment)?
X
d) Result in inadequate
emergency access? X
80 DISCUSSION
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less than Significant Impact. The Fresno General Plan Mobility and Transportation Element59 identifies goals and implementing policies related to promoting a C ity of healthy communities, improving the quality of life in established neighborhoods, planning for all modes of travel on local and major streets in Fresno, providing a well- maintained transportation system, and protecting and improving public health and safety. Additionally, the Fresno COG 2022 Regional Transportation Plan (RTP) 60 reflects transportation planning for Fresno County through 2046 and is intended to create a region of diverse, safe, resilient, and accessible transportation options that improve the quality of life for all residents by fostering sustainability, equity, a vibrant economy, clean air, and healthy communities. The proposed Project includes construction of up to 120 affordable housing units, retail/commercial space designed to accommodate small businesses , and associated site improvements, including a private on- site park facility . The proposed P roject would be located in an existing urban area, would be consistent with the existing zoning of the Project site, and would not facilitate substantial or unplanned population growth in a manner that could generate a substantial number of new vehicle trips, which is consistent with the objectives of the General Plan. Further, the P roject site is located adjacent to an existing transit stop on Bus Line 35 that would allow for the use of alternative modes of transportation and allow residents to access other areas of the City, which would be consistent with the F resno COG 2022 RTP. The proposed P roject would be consistent with the Mobility and Transportation Element and the F resno COG 2022 RTP. Therefore, impacts would be less than significant, and mitigation is not required. b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less than Significant Impact. Senate Bill (SB) 743 requires that relevant CEQA analysis of transportation impacts be conducted using a metric known as VMT instead of Level of Service (LOS). VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If a project adds excessive car travel onto our roads, the project may cause a significant transportation impact.

The State CEQA Guidelines were amended to implement SB 743, by adding Section 15064.3. Among its provisions, Section 15064.3 confirms that, except with respect to transportation projects, a project’s effect on automobile delay shall not constitute a

59 City of Fresno. 2021b. Fresno General Plan, Chapter 4: Mobility and Transportation Element. Updated September 30. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/upload_temp4- Mobility-and-Transportation-9-30-2021.pdf. Accessed June 2025. 60 Fresno Council of Governments (Fresno COG). 2022. 2022 Regional Transportation Plan/Sustainable Communities Strategy. Available online at: https://www.planfresno.com/sustainable-communities- strategies-fall-outreach/. Accessed June 2025.
81 significant environmental impact. Therefore, LOS measures of impacts on traffic facilities are no longer a relevant CEQA threshold for transportation impacts.

State CEQA Guidelines Section 15064.3(b)(4) states that “[a] lead agency has discretion to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled and may revise those estimates to reflect professional judgment based on substantial evidence.

Any assumptions used to estimate used to estimate vehicle miles traveled and any revision to model outputs should be documented and explained in the environmental document prepared for the proposed P roject. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.” On June 25, 2020, the City adopted the CEQA Guidelines for Vehicle Miles Traveled Thresholds (City of Fresno VMT Thresholds), pursuant to SB 743, to be effective July 1, 2020. The City of Fresno VMT Thresholds document was prepared and adopted consistent with the requirements of State CEQA Guidelines Sections 15064.3 and 15064.7. The December 2018 Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory)
61 published by the California Governor’s Office
of Planning and Research (OPR), 62 was utilized as a reference and guidance document in the preparation of the City of Fresno VMT Thresholds.

The proposed Project includes the construction of up to 120 new residential units, up to 15,000 square feet of retail/commercial space, and associated site improvements, including a private on-site park facility . City of Fresno VMT Thresholds Section 3.0 regarding Project Screening
63 discusses a variety of projects that may be screened out of a VMT analysis, including specific development and transportation projects. For development projects, conditions may exist that would presume that a development project has a less -than-significant impact. These may be size, location, proximity to transit, or trip ‐making potential. For transportation projects, the primary attribute to consider with transportation projects is the potential to increase vehicle travel, sometimes referred to as “induced travel.”
The City of Fresno VMT Thresholds states that projects with a high level of affordable housing units should be presumed to cause a less -than-significant transportation impact. The proposed P roject includes the construction of a mixed- use building consisting of mostly affordable housing units and therefore would be presumed to

61 California Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December. Available online at: https://opr.ca.gov/docs/20180416- 743_Technical_Advisory_4.16.18.pdf. Accessed July 2025. 62 As of July 1, 2024, the California Governor’s Office of Planning and Research was renamed the California Governor’s Office of Land Use and Climate Innovation. 63 City of Fresno. 2020b. CEQA Guidelines for Vehicle Miles Traveled Thresholds. June 25. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/CEQA-Guidelines-for-Vehicle-Miles- Traveled-Final-Adopted-
Version.pdf#:~:text=final%20rulemaking%20surrounding%20SB%20743%20and%20the%20implement ation. Accessed July 2025.
82 have a less -than-significant impact related to VMT . The proposed Project would be consistent with State CEQA Guidelines Section 15064.3(b). Therefore, impacts would be less than significant, and mitigation is not required. c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less than Significant Impact. The proposed Project includes the construction of up to 120 new residential units , up to 15,000 square feet of retail/commercial space designed to accommodate small businesses, and associated site improvements. The proposed Project would include the construction of access and off -site ROW improvements. All vehicle and pedestrian access to the Project site would be constructed in compliance with applicable design standards, including City Department of Public Works Standard Specifications
64 to avoid hazardous roadway
design. The proposed Project would facilitate improved pedestrian and vehicle access to the Project site and would not introduce incompatible design features or equipment that would substantially increase the risk of hazards. The proposed Project would be located in an existing urban area, would be consistent with the existing zoning of the Project site, and would not facilitate substantial or unplanned population growth in a manner that could generate a substantial number of new vehicle trips that could increase congestion and associated hazards. T he proposed P roject would not substantially increase hazards due to design features . Therefore, impacts would be less than significant, and mitigation is not required.
d) Result in inadequate emergency access?
Less than Significant Impact. The proposed Project includes the construction of up to 120 new residential units , up to 15,000 square feet of retail/commercial space designed to accommodate small businesses , and associated site improvements .

Emergency vehicles would have access to the Project site from Belmont Avenue.

Proposed access and off-site ROW improvements would be planned and constructed in accordance with City Department of Public Works Standard Specifications 65 to
avoid hazardous access design features. Construction activities would be limited to an existing parcel and would not require the closure of any public roadways that could impede emergency access to the Project site during temporary construction activities.

Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.

64 City of Fresno. 2021c. Standard Specifications. City of Fresno Department of Public Works. March 5.

Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/City-of-Fresno-Standards-Vol- 2-Std.-Specifications_Mar-2021-Accessible.pdf. Accessed April 2025. 83 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVII. TRIBAL CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse
change in the significance of a
tribal cultural resource, defined in
PRC section 21074 as either a
site, feature, place, cultural
landscape that is geographically
defined in terms of the size and
scope of the landscape, sacred
place, or object with cultural value
to a California Nat
ive American
tribe, and that is:

X
i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
PRC section 5020.1(k), or
X
ii) A resource determined by the
lead agency, in its discretion and
supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of PRC section
5024.1. In applying the criteria set
forth in subdivision (c) of PRC
section 5024.1, the lead agency
shall consider the significance of
the resource to a California Native
American tribe.

X
84 DISCUSSION
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
No Impact. As previously discussed in Section V, Cultural Resources, the Project site does not contain historical resources listed or eligible for listing in the CRHR, or in any local listing for the County or City. Furthermore, the area surrounding the Project site does not contain any listed historical resources. As a result, no impact would occur, and mitigation is not required.
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less than Significant with Mitigation Incorporated. The State requires lead agencies to consider the potential effects of proposed projects and consult with California Native American Tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Resources through the Sta te CEQA Guidelines. Pursuant to PRC Section 21080.3.1, the lead agency shall begin consultation with the Native American Tribe that is traditionally and culturally affiliated with the geographical area of the proposed Project. Such significant cultural resources are either sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a Tribe that is either in or eligible for inclusion in the CRHR or a local historic register, or, the lead agency, at its discretion, and support by substantial evidence, choose to treat the resources as Tribal Cultural Resources (PRC Section 21074(a)(1–2)).

Additional information may also be available from the NAHC SLF per PRC Section 5097.96 and the CHRIS SSJVIC, administered by the California Office of Historic Preservation. Please also note that PRC Section 21082.3(c) contains provisions specific to confidentiality.

AB 52, which became law January 1, 2015, requires that, as part of the CEQA review process, public agencies provide early notice of a project to Native American Tribes to allow for consultation between the Tribe and the public agency.

The purpose of AB 52 is to provide the opportunity for public agencies and Tribes to consult and consider potential impacts to Tribal Cultural Resources, as defined by PRC Section 2107(a). Under AB 52, public agencies shall reach out to Native 85 American Tribes who have requested to be notified of projects in areas within or that may have been affiliated with their Tribal geographic range. Pursuant to AB 52, the Table Mountain Rancheria Tribe, Amah Mutsun Tribal Band, Kitanemuk & Yowlumne Tejon Indians, Northern V alley Yokut/Ohlone Tribe, and Picayune Rancheria of Chukchansi In dians, and the Wuksachi Indian Tribe/Eshom Valley Band were invited to consult on July 1, 2025. The contracted Tribes did not provide a response to invitations to consult within the 30-day AB 52 period, which ended on August 1, 2025.

As previously discussed in Section V, Cultural Resources , based on searches of the SSJVIC records and NAHC SLF, there are no previously recorded archaeological resources within the Project site or surrounding area, and the Project site is considered to have low sensitivity for the presence of unidentified prehistoric or historic archaeological resources. Therefore, proposed ground- disturbing activities are not anticipated to adversely affect any known cultural resource sites within the P roject area. Further, Mitigation Measure CR-1 requires that in the unlikely event that previously unidentified cultural resources are uncovered during proposed ground-disturbing activities, all work shall cease within the vicinity of the find until a qualified archaeologist is retained to evaluate the significance of the find and determine the need for further study. T he proposed Project would also be required to comply with California Health and Safety Code Section 7050.5, which outlines the protocol for unanticipated discovery of human remains. California Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98. The County Coroner must be notified of the find immediately. If the human remains are determined to be prehistoric, the coroner will notify the NAHC, which will determine and notify an MLD. The MLD shall complete the inspection of the Project site within 48 hours of notification and may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials. With implementation of Mitigation Measure CR -1 and required compliance with California Health and Safety Code Section 7050.5, the proposed Project would not cause a substantial adverse change in the significance of a Tribal Cultural Resource. Therefore, impacts would be less than significant with mitigation.

Mitigation Measures
Implement Mitigation Measure CR-1, included in Section V, Cultural Resources. 86 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the
relocation or construction of new
or expanded water, wastewater
treatment or storm water
drainage, electric power, natural
gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effect?
X
b) Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry
and multiple dry years?
X
c) Result in a determination by the
wastewater treatment provider,
which serves or may serve the
project that it has adequate
capacity to serve the project’s
projected demand in addition to
the provider’s existing
commitments?
X
d) Generate solid waste in excess
of state or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?
X
e) Comply with federal, state, and
local management and reduction
statutes and regulations related to
solid waste?
X
87 DISCUSSION
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less than Significant Impact. The proposed Project would result in a marginal increase in the use of water, sewer, electricity, telecommunications, and other utilities and would require the installation of utility extensions to connect to existing City , Bakman, and other utility provider infrastructure to serve the proposed Project. The proposed Project would be required to include the installation of utility infrastructure in accordance with City and Bakman standard specifications, accordingly. The impacts of construction activities at the Project site have been analyzed throughout this Initial Study, and no new impacts would occur as a result of construction activities for utility extensions. The proposed Project would be served by existing energy and telecommunications services, and no new electric or telecommunications facilities would be required to support the proposed Project. The City’s Department of Public Utilities has determined that adequate sewer services would be available to serve the proposed Project. Bakman has not provided comments on this P roject. Further, the proposed Project would be subject to the payment of applicable connection charges and/or fees and extension of services in a manner that is compliant with the City’s Department of Public Utilities and Bakman standards, specifications, and policies.

Based on the evaluation provided above, the proposed Project would not result in adverse environmental effects related to the relocation or installation of utility infrastructure. Therefore, impacts would be less than significant, and mitigation is not required.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less than Significant Impact. The Project site is within the Bakman service area and the water supply for the proposed Project would be supplied by Bakman. Bakman’s current water service connection area includes residential and commercial uses within a 1,996-acre area. The population projection within the Bakman service area is based on past average growth between 2010 and 2020 and is estimated to be 21,304 persons in 2040. Water supply and demand for the Bakman service area during normal, single dry, and multiple dry years is shown in Table 3.

88 Table 3: Water Supply Reliability
2025 2030 2035 2040
Normal Year
Supply totals 1,213 1,172 1,242 1,313
Demand totals 1,213 1,172 1,242 1,313
Difference 0 0 0 0
Single Dry Year
Supply totals 1,213 1,172 1,242 1,313
Demand totals 1,213 1,172 1,242 1,313
Difference 0 0 0 0
Multiple Dry Years1
Supply totals 1,213 1,172 1,242 1,313
Demand totals 1,213 1,172 1,242 1,313
Difference 0 0 0 0
Source: City of Fresno (2014b)
1 The multiple dry year scenario is consistent for first through fifth year conditions. It is anticipated State-wide conservation mandate would be required during a prolonged drought; however, the magnitude of those mandates is unknown, and supplies would be available from the aquifer to meet the demands, even in a reduced amount.

As shown in Table 3 , Bakman’s water supply is expected to remain reliable into the future year of 2040. The demand on water supply is expected to be consistent with the existing and future water supply, and the groundwater supply would not result in any deficiencies for future users in the service area. Further, as discussed in Bakman’s 2020 UWMP,
66 Bakman relies entirely on groundwater from the Kings Subbasin for water supply, which is a non- adjudicated groundwater basin with no current limits on pumping and that has been labeled as being in a critical state of overdraft. Therefore, reliability of t he groundwater supply would depend on the long- term balance between groundwater extraction and recharge for the subbasin as a whole as discussed in previous sections. To minimize its contribution to groundwater depletion, sustainable use of groundwater supply sources is a primary focus of Bakman’s urban water management activities extending into the future. Bakman engages in groundwater recharge activities when surface water supplies are available to replenish the water table and continues to look for ways to expand those recharge activities, including an exchange agreement for their treated wastewater effluent impacts.

66 Bakman Water Company (Bakman). 2021. 2020 Urban Water Management Plan. August. 89 The Project site is located entirely within the Fresno City L imits and City’s SOI, and the proposed Project would be consistent with the allowable uses and density of the RM-1 and CMX zone districts and land use designations , as defined in the General Plan; therefore, the proposed Project would be consistent with the City’s planned buildout scenario. The proposed Project would have sufficient water supplies available to serve the proposed Project and reasonably foreseeable future development during normal, dry, and multiple dry years. Therefore, impacts would be less than significant, and mitigation is not required.
c) Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less than Significant Impact. The proposed Project is not expected to exceed the wastewater treatment requirements of the applicable RWQCB. The City owns and operates two wastewater treatment facilities: the Fresno-Clovis Regional Wastewater Reclamation Facility ( RWRF) and North Fresno Wastewater Reclamation Facility (NFWRF). The Fresno-Clovis RWRF currently has a capacity of 91.5 million gallons per day (mgd) and the NFWRF is presently rates at 1.07 mgd (maximum daily flow).

The proposed Project would result in the construction of up to 120 new residential units, up to 15,000 square f eet of commercial space , and associated on- site improvements which would result in an incremental increase in wastewater generation. The Project site is located entirely within the Fresno City L imits, and the proposed Project would be consistent with the allowable uses and density of the RM- 1 and CMX zone districts and land use designations, as defined in the General Plan.

The proposed Project would be consistent with the City’s planned buildout scenario and would not result in unplanned growth that could result in a substantial increase in wastewater generation. Therefore, impacts would be less than significant , and mitigation is not required.
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less than Significant Impact. Garbage generated in the City is taken to the Cedar Avenue Recycling and Transfer Station. Once trash has been off ‐loaded at the transfer station, it is sorted, and non‐recyclable solid waste is loaded onto large trucks and taken to the American Avenue Landfill located approximately 6 miles southwest of Kerman, which is owned and operated by the County of Fresno (City of Fresno 2025).
67 The American Avenue Landfill (i.e., American Avenue Disposal Site 10‐AA‐0009) has a maximum permitted capacity of 32,700,000 CY and a remaining capacity of

67 City of Fresno. 2025. Solid Waste Facilities. Available at: https://www.fresno.gov/publicutilities/trash- disposal-recycling/solid-waste-facilities/. Accessed October 2025. 90 29,358,535 CY, with an estimated closure date of August 31, 2031. The maximum permitted throughput is 2,200 tons per day68.

Construction of the proposed Project may result in a temporary increase in solid waste, which would be disposed of in accordance with applicable State and local laws and regulations, such as CALGreen Sections 4.408 and 5.408, which require diversion of at least 75% of construction waste. The proposed Project would also be required to comply with the City’s Construction and Demolition Approved Disposal Facilities guide
69 for proper disposal methods. Based on required compliance with CALGreen and City regulations, construction of the proposed Project would not generate solid waste in excess of local infrastructure capacity.

According to the California Department of Resources Recycling and Recovery (CalRecycle) Estimated Solid Waste Generation Rates, operation of up to 120 residential units and up to 1 5,000 square feet of commercial space would generate approximately 1,662.6 pounds of solid waste per day. Proposed solid waste calculations are shown in Table 4.

Table 4: Estimated Solid Waste Generation Rates
Waste
Generation
Source
Generation
Rate Unit of Measure
Proposed
Development Total (lb/day)
Residential 12.23 lb/household/day 120 units 1,467.6
Commercial 13 lb/1000 sq ft /day 15,000 sq ft 195
Total 1,662.6
Note: lb = pound
As shown in Table 4, the proposed Project would result in an incremental increase in solid waste of approximately 1,662.6 pounds per day (0.8 tons per day). CalRecycle does not identify an estimated solid waste generation rate for park uses; however, any increase in solid waste associated with the private on- site park facility would be nominal. This increase in solid waste would represent an increase of less than 1% of the American Avenue Landfill’s daily permitted capacity. Further, t he Project site is located entirely within the Fresno City limits and City’s SOI, and the proposed Project would be consistent with the City’s planned buildout scenario and would not result in unplanned growth that could result in a substantial or unplanned increase in solid waste generation. The proposed Project would result in a marginal increase in solid

68 California Department of Resources Recycling and Recovery (CalRecycle). 2025. SWIS Facility/Site Summary: American Avenue Disposal Site (10-AA-0009). Available online at:
https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/352. Accessed June 2025. 69 City of Fresno. 2020c. Construction & Demolition Approved Disposal Facilities. Available online at:
https://www.fresno.gov/wp-content/uploads/2023/05/DPUSW191004-Construction-Demolition- Approved-Disposal-Facilities-PDF.pdf. Accessed June 2025. 91 waste and would not generate waste in excess of State or local standards or in excess of the capacity of local infrastructure; therefore, impacts would be less than significant, and mitigation is not required.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less than Significant Impact . The proposed Project would result in a marginal increase in solid waste and would not result in a substantial increase in solid waste that could interfere with solid waste reduction statutes and regulations, including, but not limited to, policies identifi ed in the Fresno General Plan Public Utilities and Services Element .
70 The proposed Project would be required to comply with CALGreen and City requirements to ensure proper diversion and disposal of short - and long-term solid waste. The proposed Project would not conflict with federal, State, and local management and reduction statutes and regulations related to solid waste.

Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
X
b) Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks, and thereby expose
project occupants to pollutant
concentrations from a wildfire or
the uncontrolled spread of a
wildfire?
X

70 City of Fresno. 2014b. Fresno General Plan, Chapter 6: Public Utilities and Services Element . Adopted December 18. Available online at: https://www.fresno.gov/wp-content/uploads/2023/03/General-Plan-6- Public-Utilities-and-Services-7-19.pdf. Accessed June 2025. 92 ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water
sources, power lines or other
utilities) that may exacerbate fire
risk or that may result in temporary
or ongoing impacts to the
environment?
X
d) Expose people or structures to
significant risks, including
downslope or downstream
flooding or landslides, as a result
of runoff, post-fire slope instability,
or drainage changes?
X

DISCUSSION
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact. The City does not have an adopted Emergency Response and Evacuation Plan; however, the Fresno County Multi -Jurisdictional Hazard Mitigation Plan71 contains goals and policies regarding emergency evacuation, including Objective 1.3: Improve community transportation corridors to allow for better evacuation routes for the public and better access for emergency responders . The proposed Project includes the construction of up to 120 residential units, up to 15,000 square feet of retail/commercial space, and associated site improvements . The Project site would be limited to the existing parcel and would not result in the alteration of existing roadways that could interfere with emergency evacuation routes within the City or an adopted emergency response plan. The proposed Project is consistent with the Fresno County Multi -Jurisdictional Hazard Mitigation Plan. Therefore, impacts would be less than significant, and mitigation is not required.

71 County of Fresno. 2018. Fresno County Multi-Jurisdictional Hazard Mitigation Plan. May. Available online at: https://www.fresnocountyca.gov/files/sharedassets/county/v/1/public-health/fresno-county- hmp-final.pdf. Accessed June 2025.
93 b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less than Significant Impact. The Project site is in an urban area and is not located within a VHFHSZ.
72 The Project site does not possess physical characteristics that would exacerbate wildfire risks. The proposed Project would include the construction of up to 120 new residential units, up to 15,000 square feet of retail/commercial space, and associated site improvements. The proposed Project would be required to comply with the CFC to reduce risk associated with wildfire ignition at the Project site. Based on required compliance with the CFC, the proposed Project would not expose Project occupants to pollutant concentrations from or the uncontrolled spread of a wildfire.

Therefore, impacts would be less than significant, and mitigation is not required. c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Less than Significant Impact. The Project site is located in a developed area of the City and it would require the expansion of utility infrastructure to serve the proposed project. The proposed Project would be required to comply with the CFC to reduce risk associated with wildfire ignition at the P roject site. Since the proposed Project is not located within a VHFHSZ, and based on required compliance with the CFC, the proposed Project would not exacerbate wildfire risk within the Project site. Therefore, impacts would be less than significant, and mitigation is not required. d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes?
Less than Significant Impact. The Project site is located on a relatively flat area and is not located adjacent to any hills or other sloping areas. In general, the potential for land sliding or slope failure in Fresno is very low and the P roject site would not be susceptible to landslides. The P roject site is not located in a flood hazard zone and would not be susceptible to flooding due to post-fire drainage changes. 73 As discussed
above, the proposed P roject is not located within a VHFHSZ and would be required to comply with applicable CFC requirements to avoid risk associated with post -fire hazards. The proposed Project would also be required to comply with the most recent

72 California Department of Forestry and Fire Protection (CAL FIRE). 2023. Fresno County State Responsibility Area Fire Hazard Severity Zones. June 15. Available online at: https://34c031f8-c9fd- 4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/what-we-do/community- wildfire-preparedness-and-mitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-map- 2022/fire-hazard-severity-zones-maps-2022-files/fhsz_county_sra_11x17_2022_fresno_2.pdf.

Accessed June 2025.
73 Federal Emergency Management Agency (FEMA). 2020. FEMA Flood Map Service Center: Search By Address. Available online at: https://msc.fema.gov/portal/search?AddressQuery#searchresultsanchor.

Accessed June 2025.
94 CBC to reduce risk associated with post-fire hazards. The proposed Project would not expose people or structures to significant risks associated with post -fire hazards .

Therefore, impacts would be less than significant, and mitigation is not required.

Mitigation Measures
Mitigation measures are not required.

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the
potential to degrade the quality of
the environment, substantially
reduce the habitat of a fish or
wildlife species, cause a fish or
wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or ani mal
community, reduce the number or
restrict the range of a rare or
endangered plant or animal or
eliminate important examples of
the major periods of California
history or prehistory?
X
b) Does the project have impacts
that are individually limited, but
cumulatively considerable?
(“Cumulatively considerable”
means that the incremental
effects of a project are
considerable when viewed in
connection with the effects of past
projects, the effects of other
current projects, and the effects of
probable future projects)?
X
c) Does the project have
environmental effects which will
cause substantial adverse effects
on human beings, either directly
or indirectly?
X
95 DISCUSSION
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a p lant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory? Less than Significant with M itigation Incorporated. The proposed Project would include the construction of up to 120 new residential units , up to 15,000 square feet of commercial space, and associated site improvements, including a private on- site park facility within a developed area located in the City’s SOI. The proposed Project does not involve development in a rural area and would not result in a substantial reduction of habitat, plant or animal species, or significant cultural resources from major periods of California history or prehistory. Further, Mitigation Measures BIO-1 and BIO-2, included in Section IV, Biological Resources, has been identified to reduce impacts to migratory birds; Mitigation Measure CR -1 included in Section V, Cultural Resources, has been identified to reduce impacts to cultural resources; and Mitigation Measure GEO -1 included in Section VII, Geology and Soils has been identified to reduce impacts to paleontological resources.

Therefore, the proposed Project would not have the potential to substantially degrade the quality of the environment ; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self -sustaining levels ; threaten to eliminate a plant or animal community; substantially reduce the number or restrict the range of an endangered, rare, or threatened species; or eliminate important examples of the major periods of California history or prehistory, and impacts would be less than significant with mitigation.
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
Less than S ignificant with M itigation Incorporated. When project impacts are considered along or in combination with other impacts, the project -related impacts may be significant. Construction and operation of the proposed Project would contribute to cumulative impacts related to Air Quality, Biological Resources, Cultural and Tribal Cultural Resources, Geology and Soils , and Noise . Mitigation measures have been incorporated into the proposed Project to reduce Project -related impacts to a less-than-significant level. Based on implementation of Mitigation Measures AQ- 1 through AQ -4 included in Section III, Air Quality ; Mitigation Measures BIO-1 and BIO-2, included in Section IV, Biological Resources ; Mitigation Measure CR -1, included in Section V, Cultural Resources ; Mitigation Measure GEO -1, included in Section VII, Geology and Soils ; Mitigation Measure HAZ -1, included in Section IX, Hazards and Hazardous Materials ; and Mitigation Measure N-1, included in Section 96 XIII, Noise, the cumulative effects of the proposed Project would be less than significant.

Implementation of these mitigation measures would ensure that the impacts of the proposed Project would be below established thresholds of significance and that these impacts would not combine with the impacts of other cumulative projects to result in a cumulatively considerable impact on t he environment as a result of Project development. Therefore, this impact would be less than significant with mitigation. c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Less than Significant with M itigation Incorporated. The proposed Project would result in air emissions and short -term noise during construction activities. Mitigation Measures AQ-1 through AQ-4, included in Section III, Air Quality, have been identified that would reduce these Project -specific impacts to a less -than-significant level; therefore, the proposed Project would not result in substantial, adverse environmental effects to human beings, either directly or indirectly, and impacts would be less than significant with mitigation.

97 SOURCES CITED
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ArcGIS. 2024. Fresno Traffic Counts. Available online at:
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Bakman Water Company (Bakman). 2021. 2020 Urban Water Management Plan. August.

Bay Area Air District (BAAD). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans . April.

Available online at: https://www.baaqmd.gov/~/media/files/planning- and- research/ceqa/ceqa-thresholds-2022/justification-report-pdf.pdf?la=en.

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California Department of Fish and Wildlife (CDFW). 2025. California Natural Diversity Database. Available online at: https://wildlife.ca.gov/Data/CNDDB/Maps -and- Data. Accessed June 2025.

California Department of Forestry and Fire Protection (CAL FIRE). 2023. Fresno County State Responsibility Area Fire Hazard Severity Zones. June 15. Available online at: https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/- /media/osfm-website/what-we-do/community-wildfire-preparedness-and- mitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-map-2022/fire- hazard-severity-zones-maps-2022-
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California Department of Resources Recycling and Recovery (CalRecycle). 2025. SWIS Facility/Site Summary: American Avenue Disposal Site (10- AA-0009). Available online at: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/352.

Accessed June 2025.
98 California Department of Toxic Substances Control (DTSC). 2025. EnviroStor. Available online at: https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=fresno.

Accessed June 2025.

California Department of Transportation (Caltrans). Scenic Highways. Available online at:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways. Accessed June 2025.

California Department of Water Resources (DWR). 2006. San Joaquin Valley Groundwater Basin Kings Subbasin. California’s Groundwater Bulletin 118.

Available at: https://water.ca.gov/- /media/DWR-Website/Web- Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003-Basin- Descriptions/5_022_08_KingsSubbasin.pdf. Accessed June 2025.

California Energy Commission (CEC). 2024. 2023 Integrated Energy Policy Report Highlights. February. Available online at:
https://www.energy.ca.gov/sites/default/files/2024-
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California Environmental Protection Agency (CalEPA). 2018. Government Code Section 65962.5(a) Hazardous Waste and Substances Site List. Available online at:
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City of Fresno. 2007. Metropolitan Water Resources Management Plan Update. Available at: https://www.fresno.gov/wp-
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99 City of Fresno. 2014a. Fresno General Plan. Adopted December 18. Available online at:
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content/uploads/2023/03/upload_temp_Consolidated-GP-10-13- 2022_compressed.pdf. Accessed July 2025.

City of Fresno. 2014b . Fresno General Plan, Chapter 6: Public Utilities and Services Element. Adopted December 18. Available online at: https://www.fresno.gov/wp- content/uploads/2023/03/General-Plan-6-Public-Utilities-and-Services-7-19.pdf.

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City of Fresno. 2018. Fresno General Plan , Chapter 7: Resource Conservation and Resilience Element . Updated December 13. Available online at:
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City of Fresno. 2020b. CEQA Guidelines for Vehicle Miles Traveled Thresholds. June 25.

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Version.pdf#:~:text=final%20rulemaking%20surrounding%20SB%20743%20and %20the%20implementation. Accessed July 2025.

City of Fresno. 2020c. Construction & Demolition Approved Disposal Facilities. Available online at: https://www.fresno.gov/wp-content/uploads/2023/05/DPUSW191004- Construction-Demolition-Approved-Disposal-Facilities-PDF.pdf. Accessed June 2025.

City of Fresno. 2021a. Final 2020 Urban Water Management Plan. City of Fresno Department of Public Utilities. Available at: https://www.fresno.gov/wp - content/uploads/2023/03/Fresno-2020-UWMP_Final_2021-07-21.pdf. Accessed June 2025.

City of Fresno. 20 21b. Fresno General Plan, Chapter 4: Mobility and Transportation Element. Updated September 30. Available online at: https://www.fresno.gov/wp- content/uploads/2023/03/upload_temp4-Mobility-and-Transportation-9-30- 2021.pdf. Accessed June 2025.

City of Fresno. 2021c. Standard Specifications . City of Fresno Department of Public Works. March 5. Available online at: https://www.fresno.gov/wp - content/uploads/2023/03/City-of-Fresno-Standards-Vol-2-Std.- Specifications_Mar-2021-Accessible.pdf. Accessed June 2025. 100
City of Fresno. 2025. Solid Waste Facilities. Available at:
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County of Fresno. 2018. Fresno County Multi-Jurisdictional Hazard Mitigation Plan. May.

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content/uploads/2023/03/FresnoCountyHMPFinal.pdf. Accessed June 2025.

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Federal Highway Administration (F HWA). 2006. Construction Noise Handbook. August.

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Fresno Council of Governments (Fresno COG). 2021. Fresno County Airport Land Use Compatibility Plan. December 2018; Amended December 2021. Available online at: https://www.dropbox.com/scl/fi/clh8iltq4f3eb10qyp93i/Fresno-Updated- ALUCP-Amended-Oct-2023.pdf?rlkey=e4ao8oy6ifk2btgzci95szb0u&e=1&dl=0.

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Fresno Council of Governments (F resno COG). 2022. 2022 Regional Transportation Plan/Sustainable Communities Strategy . Available online at:
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Fresno Council of Governments (FCOG). 2025. Fresno County – VMT Screening Application. Available at:
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Natural Resources Conservation Service. Web Soil Survey. Available online at:
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Regional Water Quality Control Board (RWQCB). 2016. National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements General Permit for Discharges from Municipal Separate Storm Sewer Systems . Order R5-2016- 0040; NPDES No. CAS0085324. California Regional Water Quality Control Board Central Valley Region. June 23. Available online at:
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Regional Water Quality Control Board (RWQCB). 2019. The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region . Fifth Edition. California Regional Water Quality Control Board Central Valley Region. Revised February 2019 (with Approved Amendments).

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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015a. Air Quality Thresholds of Significance – Criteria Pollutants . Available online at:
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015b. Guidance for Assessing and Mitigating Air Quality Impacts. Adopted March 19, 2015. Available online at: https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf. A ccessed June 2025.
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2020. Small Project Analysis Levels (SPAL). November 13. Available online at:
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2022. 2022 Plan for the 2015 8- Hour Ozone Standard. Available online at:
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2022. District Policy APR 1305 Best Available Control Technology (BACT). Available at:
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2024. 2024 Plan for the 2012 PM2.5 Standards . June 20. Available online at:
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San Joaquin Valley Air Pollution Control District (SJVAPCD). 2025. Ambient Air Quality Standards & Attainment Status. Available online at: https://www.valleyair.org/air- quality-information/ambient-air-quality-standards-valley-attainmnet-status/.

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State Water Resources Control Board (State Water Board). 2025. GeoTracker. Available online at: https://geotracker.waterboards.ca.gov/. Accessed June 2025.

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U.S. Fish and Wildlife Service (USFWS). 2025a. Information for Planning and Consultation. Available online at: https://ipac.ecosphere.fws.gov/. Accessed June 2025.

U.S. Fish and Wildlife Service (USFWS) . 2025b. National Wetlands Inventory (NWI) Surface Waters and Wetlands Mapper . Available online at:
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed June 2025.

U.S. Geological Survey (USGS). 2024. Areas of Land Subsidence in California. Available online at: https://ca.water.usgs.gov/land_subsidence/california- subsidence- areas.html. Accessed June 2025.

APPENDIX A

USFWS IPaC, CDFW CNDDB, and CNPS Query Results
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/15/9/11/14/6/7/16/3/i255/13/19/i255/13/11/1/9/19/i255/23/6/8/8/9/16/i255/27/9/6/11/24/19/9/3/i255/23/6/20/i255/1/6/18/9/i255/5/1/6/7/28/9/16/i255/3/2/7/5/9/i255/11/1/9/i255/16/6/11/9/i255/13/27/i255/11/1/9/i255/2/23/6/28/9/19/20/i255/13/19/i255/27/2/9/14/16/i255/10/13/19/56/30/i255/0/1/9/19/9/i255/23/6/20/i255/25/9/i255/13/5/5/6/3/2/13/7/6/14/i255/16/2/27/27/9/19/9/7/5/9/3/i255/2/7/i255/8/13/14/20/28/13/7 /25/13/24/7/16/6/19/2/9/3/i255/13/19/i255/5/14/6/3/3/2/27/2/5/6/11/2/13/7/3/i255/25/9/11/10/9/9/7/i255/11/1/9/i255/2/7/27/13/19/23/6/11/2/13/7/i255/16/9/8/2/5/11/9/16/i255/13/7/i255/11/1/9/i255/23/6/8/i255/6/7/16/i255/11/1/9/i255/6/5/11/24/6/14/i255/5/13/7/16/2/11/2/13/7/3/i255/13/7/i255/3/2/11/9/30 /38/39/40/39/i255/58/59/60/42/61/47/43/45/46/47
/62/9/19/11/6/2/7/i255/10/9/11/14/6/7/16/i255/1/6/25/2/11/6/11/3/i255/6/19/9/i255/9/55/5/14/24/16/9/16/i255/27/19/13/23/i255/11/1/9/i255/12/6/11/2/13/7/6/14/i255/23/6/8/8/2/7/28/i255/8/19/13/28/19/6/23/i255/25/9/5/6/24/3/9/i255/13/27/i255/11/1/9/i255/14/2/23/2/11/6/11/2/13/7/3/i255/13/27/i255/6/9/19/2/6/14/i255/2/23/6/28/9/19/20/i255/6/3/i255/11/1/9/i255/8/19/2/23/6/19/20/i255/16/6/11/6/i255/3/13/24/19/5/9/i255/24/3/9/16/i255/11/13 /16/9/11/9/5/11/i255/10/9/11/14/6/7/16/3/30/i255/0/1/9/3/9/i255/1/6/25/2/11/6/11/3/i255/2/7/5/14/24/16/9/i255/3/9/6/28/19/6/3/3/9/3/i255/13/19/i255/3/24/25/23/9/19/28/9/16/i255/6/54/24/6/11/2/5/i255/18/9/28/9/11/6/11/2/13/7/i255/11/1/6/11/i255/6/19/9/i255/27/13/24/7/16/i255/2/7/i255/11/1/9/i255/2/7/11/9/19/11/2/16/6/14/i255/6/7/16/i255/3/24/25/11/2/16/6/14/i255/50/13/7/9/3/i255/13/27/i255/9/3/11/24/6/19/2/9/3/i255/6/7/16 /7/9/6/19/3/1/13/19/9/i255/5/13/6/3/11/6/14/i255/10/6/11/9/19/3/30/i255/48/13/23/9/i255/16/9/9/8/10/6/11/9/19/i255/19/9/9/27/i255/5/13/23/23/24/7/2/11/2/9/3/i255/21/5/13/19/6/14/i255/13/19/i255/11/24/25/9/19/27/2/5/2/16/i255/10/13/19/23/i255/19/9/9/27/3/22/i255/1/6/18/9/i255/6/14/3/13/i255/25/9/9/7/i255/9/55/5/14/24/16/9/16/i255/27/19/13/23/i255/11/1/9/i255/2/7/18/9/7/11/13/19/20/30/i255/0/1/9/3/9/i255/1/6/25/2/11/6/11/3/26 /25/9/5/6/24/3/9/i255/13/27/i255/11/1/9/2/19/i255/16/9/8/11/1/26/i255/28/13/i255/24/7/16/9/11/9/5/11/9/16/i255/25/20/i255/6/9/19/2/6/14/i255/2/23/6/28/9/19/20/30 /38/39/40/39/i255/63/64/58/60/39/61/40/43/45/46/47
/65/9/16/9/19/6/14/26/i255/3/11/6/11/9/26/i255/6/7/16/i255/14/13/5/6/14/i255/19/9/28/24/14/6/11/13/19/20/i255/6/28/9/7/5/2/9/3/i255/10/2/11/1/i255/29/24/19/2/3/16/2/5/11/2/13/7/i255/13/18/9/19/i255/10/9/11/14/6/7/16/3/i255/23/6/20/i255/16/9/27/2/7/9/i255/6/7/16/i255/16/9/3/5/19/2/25/9/i255/10/9/11/14/6/7/16/3/i255/2/7/i255/6/i255/16/2/27/27/9/19/9/7/11/i255/23/6/7/7/9/19/i255/11/1/6/7/i255/11/1/6/11/i255/24/3/9/16/i255/2/7/i255/11/1/2/3 /2/7/18/9/7/11/13/19/20/30/i255/0/1/9/19/9/i255/2/3/i255/7/13/i255/6/11/11/9/23/8/11/26/i255/2/7/i255/9/2/11/1/9/19/i255/11/1/9/i255/16/9/3/2/28/7/i255/13/19/i255/8/19/13/16/24/5/11/3/i255/13/27/i255/11/1/2/3/i255/2/7/18/9/7/11/13/19/20/26/i255/11/13/i255/16/9/27/2/7/9/i255/11/1/9/i255/14/2/23/2/11/3/i255/13/27/i255/8/19/13/8/19/2/9/11/6/19/20/i255/29/24/19/2/3/16/2/5/11/2/13/7/i255/13/27/i255/6/7/20/i255/65/9/16/9/19/6/14/26/i255/3/11/6/11/9/26/i255/13/19/i255/14/13/5/6/14 /28/13/18/9/19/7/23/9/7/11/i255/13/19/i255/11/13/i255/9/3/11/6/25/14/2/3/1/i255/11/1/9/i255/28/9/13/28/19/6/8/1/2/5/6/14/i255/3/5/13/8/9/i255/13/27/i255/11/1/9/i255/19/9/28/24/14/6/11/13/19/20/i255/8/19/13/28/19/6/23/3/i255/13/27/i255/28/13/18/9/19/7/23/9/7/11/i255/6/28/9/7/5/2/9/3/30/i255/66/9/19/3/13/7/3/i255/2/7/11/9/7/16/2/7/28/i255/11/13/i255/9/7/28/6/28/9/i255/2/7/i255/6/5/11/2/18/2/11/2/9/3/i255/2/7/18/13/14/18/2/7/28 /23/13/16/2/27/2/5/6/11/2/13/7/3/i255/10/2/11/1/2/7/i255/13/19/i255/6/16/29/6/5/9/7/11/i255/11/13/i255/10/9/11/14/6/7/16/i255/6/19/9/6/3/i255/3/1/13/24/14/16/i255/3/9/9/56/i255/11/1/9/i255/6/16/18/2/5/9/i255/13/27/i255/6/8/8/19/13/8/19/2/6/11/9/i255/65/9/16/9/19/6/14/26/i255/3/11/6/11/9/26/i255/13/19/i255/14/13/5/6/14/i255/6/28/9/7/5/2/9/3/i255/5/13/7/5/9/19/7/2/7/28/i255/3/8/9/5/2/27/2/9/16/i255/6/28/9/7/5/20 /19/9/28/24/14/6/11/13/19/20/i255/8/19/13/28/19/6/23/3/i255/6/7/16/i255/8/19/13/8/19/2/9/11/6/19/20/i255/29/24/19/2/3/16/2/5/11/2/13/7/3/i255/11/1/6/11/i255/23/6/20/i255/6/27/27/9/5/11/i255/3/24/5/1/i255/6/5/11/2/18/2/11/2/9/3/30

Species
Element Code
Federal Status
State Status
Global Rank
State Rank
Rare Plant
Rank/CDFW
SSC or FP
American badger
Taxidea taxus
AMAJF04010
None
None
G5
S3
SSC
American bumble bee
Bombus pensylvanicus
IIHYM24260
None
None
G3G4
S2
Antioch efferian robberfly
Efferia antiochi
IIDIP07010
None
None
G1G2
S1S2
black-crowned night heron
Nycticorax nycticorax
ABNGA11010
None
None
G5
S4
bristly sedge
Carex comosa
PMCYP032Y0
None
None
G5
S2
2B.1
burrowing owl
Athene cunicularia
ABNSB10010
None
Candidate
Endangered
G4
S2
SSC
California glossy snake
Arizona elegans occidentalis
ARADB01017
None
None
G5T2
S2
SSC
California horned lark
Eremophila alpestris actia
ABPAT02011
None
None
G5T4Q
S4
WL
California jewelflower
Caulanthus californicus
PDBRA31010
Endangered
Endangered
G1
S1
1B.1
California linderiella
Linderiella occidentalis
ICBRA06010
None
None
G2G3
S2S3
California satintail
Imperata brevifolia
PMPOA3D020
None
None
G3
S3
2B.1
California tiger salamander - central California DPS
Ambystoma californiense pop. 1
AAAAA01181
Threatened
Threatened
G3T3
S3
WL
coast horned lizard
Phrynosoma blainvillii
ARACF12100
None
None
G4
S4
SSC
Crotch's bumble bee
Bombus crotchii
IIHYM24480
None
Candidate
Endangered
G2
S2
double-crested cormorant
Nannopterum auritum
ABNFD01020
None
None
G5
S4
WL
dwarf downingia
Downingia pusilla
PDCAM060C0
None
None
GU
S2
2B.2
forked hare-leaf
Lagophylla dichotoma
PDAST5J070
None
None
G1
S1
1B.1
Fresno kangaroo rat
Dipodomys nitratoides exilis
AMAFD03151
Endangered
Endangered
G2TH
SH
great egret
Ardea alba
ABNGA04040
None
None
G5
S4
Query Criteria:

Quad IS (Clovis (3611976) OR Friant (3611986) OR Malaga (3611966) OR Lanes Bridge (3611987) OR Fresno North (3611977) OR Fresno South (3611967) OR Academy (3611985) OR Round Mountain (3611975) OR Sanger (3611965)) Report Printed on Thursday, February 05, 2026

Page 1 of 3 ends

Fresno City CouncilSeptember 3, 2026

Fresno City Council
September 3, 2026