Initial Study (Mitigated Negative Declaration) — City Council/Public Finance and Economic Development Authority/Parking Authority, October 6, 2025 (part 1 of 5)

DRAFT INITIAL STUDY AND

MITIGATED NEGATIVE DECLARATION

MERCED GATEWAY PROJECT
(GPA #24-03, R-PD EST. #83, VTSM
#1333, ZC #435, ERC #24-30)
Consultant:

Project #240161
5080 California Avenue, Suite 220
Bakersfield, CA 93309
Contact: Jaymie Brauer, Principal Planner
Phone: (661) 616-2600
May 2025
Attachment 11

NOTICE OF PUBLIC HEARING AND INTENT TO ADOPT A MITIGATED NEGATIVE

DECLARATION
This is to advise that the City of Merced Planning Division has prepared a Mitigated Negative Declaration (MND) for the project identified below that is scheduled to be heard at the City of Merced Planning Commission Meeting on Wednesday, July 9, 2025.

PLEASE BE ADVISED that the City of Merced will consider the MitigatedNegative Declaration at the Planning Commission meeting to be held on July 9, 2025. Presentations will be made at approximately 6:00 PM. Action on items on the Planning Commission agenda will occur after the presentations. The meeting will be held in the Merced Civic Center located at 678 W. 18th Street, Merced, CA 95340. The City of Merced City Council will take final action to approve or deny a General Plan Amendment upon recommendation by the Planning Commission. A public hearing for the City Council shall be held at a later date.

Project Name
Merced Gateway Project (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30) Project Location
The proposed project is located in the City of Merced (City; Assessor’s Parcel Number [APN] 061-710-009, a portion of 061-710-023, and 061-680-001). The proposed project site is approximately 73.7 acres and is generally bounded by East Gerard Avenue to the north, East Mission Avenue to the south, South Coffee Street to the west, and Campus Parkway to the east. The project site will be bifurcated by Campus Parkway, with portions of both commercial and residential on either side of the roadway.

Regional access to the project site is provided by State Route 99 (SR), and SR 140. The site is located within Section 32, Township 7S, Range 14E Mount Diablo Base and Meridian (MDB&M), of the Merced U.S. Geological Survey (USGS) Quad Map.

General Plan/Zoning
The project site is currently designated Business Park and Manufacturing/Industrial and zoned B-P (Business Park) and I-H (Heavy Industrial) by the City of Merced General Plan.

Project Description
The proposed project, Merced Gateway (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30), includes the entitlement and development of almost 570 single-family residential lots, the future development of a 9-acre commercial area, and 3.0 acres of open space/park within the city limits of the City of Merced.

Residential Component:

Phase 1: the northerly portion of the site includes 328 residential lots and 2.4 acres of park space on the eastern boundary of the site. The designated commercial area will be approximately 4.35 acres on the north side of Campus Parkway.

Phase 2: the southerly portion of the site includes 242 residential lots and a 0.6 ac park along the easterly boundary of the site. The designated commercial area will be approximately 4.65 acres in size.

A total of 570 lots are proposed on an approximately 61.7 acres portion of the 73.7-acre site, resulting in a residential density of 8.02 dwelling units per acre. Lot sizes for the residential area will vary and include lot sizes ranging between 2,375 square feet to over 6,559 square feet.

Commercial Component:

There is no proposed commercial tenant at this time, and this component is expected to be developed at a later date.

The commercial areas can be developed with a mixture of business park, general retail and office space. In order to adequately analyze the project, it will be assumed that the northerly commercial area will be developed with approximately 27,225 square feet of general retail and 27,225 square feet of office space. The southerly commercial area is assumed to be developed with approximately 22,325 square feet of general retail space and 22,325 square feet of office space.

Based on these assumptions, the Floor Area Ratio (FAR) is 0.25 (99,100 square feet of commercial and office space / 392,040 square feet of total commercial area).

Entitlements:

The project proponent is requesting approval of the following land use entitlements:
• Amendment of the Land Use Designation of the Merced General Plan to change the land use map code designation of the proposed residential areas from Business Park and Manufacturing/Industrial to Low-Medium Density Residential and High-Medium Density Residential (General Plan Amendment #24-03, Figure 1-5.) • Zone Change from B-P and I-H (Heavy Industrial) of the proposed residential areas to RP-D (Zoning Change #435 and Residential Planned Development #83) • Approval of Vested Tentative Subdivision Map (VSTM) #1333 The document and studies referenced in the Initial Study/Mitigated Negative Declaration are available for review at City of Merced Planning Department located at 678 West 18th Street, Merced, CA 95340.

As mandated by the California Environmental Quality Act (CEQA), the public review period for this document was 30 days (CEQA Section 15073[b]). The public review period began on May 29, 2025, and ended on June 28, 2025. For further information, please contact Jonnie Lan, AICP, Interim Planning Manager, City of Merced at [email protected].

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Table of Contents
List of Acronyms and Abbreviations ....................................................................................................... iv Mitigated Negative Declaration ........................................................... Error! Bookmark not defined.

SECTION 1 - Introduction ............................................................................................................................ 1

1.1 - Overview ........................................................................................................................................................1

1.2 - California Environmental Quality Act.................................................................................................1

1.3 - Impact Terminology...................................................................................................................................1

1.4 - Document Organization and Contents................................................................................................2

1.5 - Incorporated by Reference......................................................................................................................2 SECTION 2 - Project Description ........................................................................................................... 2-1

2.1 - Introduction ..............................................................................................................................................2-1

2.2 - Project Location.......................................................................................................................................2-1

2.3 - Project Environment..............................................................................................................................2-1

2.4 - Proposed Project.....................................................................................................................................2-1 SECTION 3 - Initial Study ......................................................................................................................... 3-1

3.1 - Environmental Checklist......................................................................................................................3-1

3.2 - Environmental Factors Potentially Affected ................................................................................3-4

3.3 - Determination ..........................................................................................................................................3-4

3.4 - Evaluation of Environmental Impacts ............................................................................................3-6

3.4.1 - Aesthetics .................................................................................................................................3-8

3.4.2 - Agriculture and Forestry Resources...........................................................................3-12

3.4.3 - Air Quality .............................................................................................................................3-16

3.4.4 - Biological Resources .........................................................................................................3-27

3.4.5 - Cultural resources..............................................................................................................3-50

3.4.6 - Energy.....................................................................................................................................3-54

3.4.7 - Geology and Soils................................................................................................................3-58

3.4.8 - Greenhouse Gas Emissions.............................................................................................3-65

3.4.9 - Hazards and Hazardous Materials...............................................................................3-70

3.4.10 - Hydrology and Water Quality.....................................................................................3-77

3.4.11 - Land Use and Planning ..................................................................................................3-86

3.4.12 - Mineral Resources...........................................................................................................3-89

3.4.13 - Noise.....................................................................................................................................3-91

3.4.14 - Population and Housing................................................................................................3-99

3.4.15 - Public Services............................................................................................................... 3-102

3.4.16 - Recreation ....................................................................................................................... 3-107

3.4.17 - Transportation .............................................................................................................. 3-109

3.4.18 - Tribal Cultural Resources.......................................................................................... 3-116 Merced Gateway Project May 2025
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3.4.19 - Utilities and Service Systems ................................................................................... 3-118

3.4.20 - Wildfire............................................................................................................................. 3-124

3.4.21 - Mandatory Findings of Significance ...................................................................... 3-127 SECTION 4 - List of Preparers ................................................................................................................ 4-1 SECTION 5 - Bibliography ....................................................................................................................... 5-1 SECTION 6 - Mitigation Monitoring and Reporting Program ....................................................... 6-1 Appendices
Appendix A – Air Quality and Greenhouse Gas Impact Assessment Appendix B – Biological Evaluation
Appendix C – Cultural Resources Study and Evaluation
Appendix D – Phase I Environmental Site Assessment
Appendix E – Water Supply Assessment
Appendix F – Acoustical Analysis
Appendix G – Transportation Impact Study
List of Figures
Figure 1-1 Regional Location ...........................................................................................................................3 Figure 1-2 Project Site.........................................................................................................................................4 Figure 1-3 Tentative Tract Layout .............................................................................................................2-1 Figure 1-4 Existing General Plan Designations .....................................................................................2-1 Figure 1-5 Proposed General Plan Designation ....................................................................................2-1 Figure 1-6 Existing Zoning ............................................................................................................................2-2 Figure 1-7 Proposed Zoning .........................................................................................................................2-3 Figure 3. 4. 4-1 NHD-NWI...........................................................................................................................3-45 List of Tables
Table 3.4.3-1 ....................................................................................................................................................3-20 Table 3.4.3-2 ....................................................................................................................................................3-21 Table 3.4.3-3 ....................................................................................................................................................3-22 Table 3.4.3-4 Health Risk from Project Construction ......................................................................3-24 Table 3.4.3-5 Health Risk from Project Construction with Mitigation......................................3-25 Table 3.4.4-1 Lists of Special Status Species That Could Occur in the Project Vicinity.......3-28 Table 3.4.6-1 Estimated Energy Use.......................................................................................................3-55 Table 3.4.8-1 Project GHG Emissions .....................................................................................................3-65 Table 3.4.10-1..................................................................................................................................................3-80 Table 3.4.10-2..................................................................................................................................................3-80 Table 3.4.10-3..................................................................................................................................................3-80 Merced Gateway Project May 2025
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Table 3.4.13-1 Comparison of Measured and Predicted Noise Levels, Merced Gateway Residential Development............................................................................................................................3-93 Table 3.4.13-2 Modeled Traffic Noise Exposure Levels, dB, Ldn ................................................3-94 Table 3.4-3 Typical Vibration Levels for Construction Equipment............................................3-96 Table 3.4.17-1 Project Trip Generation.............................................................................................. 3-111 Table 3.4.17-1 Intersection Operations ............................................................................................. 3-112

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LIST OF ACRONYMS AND ABBREVIATIONS
AADT Annual Average Daily Traffic
AB Assembly Bill
AF acre feet
ALUCP Airport Land Use Compatibility Plan
APN Assessor Parcel Number
AQAP Air Quality Attainment Plan
AQP Air Quality Plans
BACT Best Available Control Technology
BAU Business as Usual
BE Biological Evaluation
BMP Best Management Practices
BPS Best Performance Standard
CalGEM California Geologic Energy Management Division
CALGreen California Green Building Standards Code
CARB California Air Resources Board
CBC California Building Code
CCAA California Clean Air Act
CCaIC Central California Information Center
CCR California Code of Regulations
CEQA California Environmental Quality Act
CHRIS California Historical Resources Information System CNEL Community Noise Equivalent Level
CO Carbon Monoxide
CUPA Certified Unified Program Agency
CWA Clean Water Act
dB Decibels
DWR Department of Water Resources
EIR Environmental Impact Report
ESA Environmental Site Assessment
FAR Floor Area Ratio
FCAA Federal Clean Air Act
FHWA Federal Highway Administration
FMMP Farmland Mapping and Monitoring Program
FTA Federal Transit Administration
GAMAQI Guidance for Assessing and Mitigating Air Quality Impacts GHG Greenhouse Gas
GHw millions of kilowatts per hour
HC Hydrocarbon
HMBP Hazardous Materials Business Plan
IS Initial Study
IS/MND Initial Study/Mitigated Negative Declaration
ITE Institute of Transportation Engineers
Ldn Day-Night Average Level
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Leq equivalent energy sound level
LOS Level of Service
LRA Local Responsibility Area
MCAG Merced County Association of Governments
MCDEH County of Merced Division of Environmental Health MDB&M Mount Diablo Base and Meridian
MIUGSA Merced Irrigation Urban Groundwater Sustainability Agency MJHMP Multi-Jurisdictional Hazard Mitigation Plan
MMBTU millions of therms
MND Mitigated Negative Declaration
MPO Metropolitan Planning Organization
MRZ Mineral Resource Zone
MTCO2eq./year Metric Tons of Carbon Dioxide Equivalent per year NAHC Native American Heritage Commission
NLR noise level reduction
NOx Nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NRCS National Resources Conservation Service
O3 Ozone
PG&E Pacific Gas and Electric Company
PM10 particulate matter of 10 micrometers or less
PM2.5 particulate matter of 2.5 micrometers or less
PPV peak particle velocity
RHNA Regional Housing Needs Allocation
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy SCAQMD South Coast Air Quality Management District
SJVAB San Joaquin Valley Air Basin
SJVAPCD San Joaquin Valley Air Pollution Control District SOI Sphere of Influence
SR State Route
SWPPP Stormwater Pollution Prevention Plan

Mitigated Negative Declaration
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MITIGATED NEGATIVE DECLARATION
As Lead Agency under CEQA, the City of Merced Planning Department has reviewed the project described below to determine whether it could have a significant effect on the environment because of its development. In accordance with CEQA Guidelines Section 15382, “[s]ignificant effect on the environment” means a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance.

Project Name
Merced Gateway Project (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30) Project Location
The proposed project is located in the City of Merced (City; Assessor’s Parcel Number [APN] 061-710-009, 061-710-023, and 061-680-001; Figure 1-1 and 1-2). The proposed project site is approximately 73.7 acres and is generally bounded by East Gerard Avenue to the north, East Mission Avenue to the south, South Coffee Street to the west, and Campus Parkway to the east. The project site will be bifurcated by Campus Parkway, with portions of both commercial and residential on either side of the roadway.

Project Description
The proposed project, Merced Gateway (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30), includes development of 570 single-family residential lots, the future development of a 9-acre commercial area, and 3.0 acres of open space/park within the city limits of the City of Merced (Figure 1-3).

Residential Component:

Phase 2: the southerly portion of the site includes 242 residential lots and a 0.4 ac park along the easterly boundary of the site. The designated commercial area will be approximately 4.65 acres in size.

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area will vary and include lot sizes ranging between 2,375 square feet to over 6,559 square feet.

Commercial Component:

There is no proposed commercial tenant at this time, and this component is expected to be developed at a later date.

The commercial areas can be developed with a mixture of general retail and office space. In order to adequately analyze the project, it will be assumed that the northerly commercial area will be developed with approximately 27,225 square feet of general retail and 27,225 square feet of office space. The southerly commercial area is assumed to be developed with approximately 22,325 square feet of general retail space and 22,325 square feet of office space.

Based on these assumptions, the Floor Area Ratio (FAR) is 0.25 (99,100 square feet of commercial and office space / 392,040 square feet of total commercial area).

Entitlements:

The project proponent is requesting approval of the following land use entitlements:
• Amendment of the Land Use Designation of the Merced General Plan to change the land use map code designation of the proposed residential areas from Business Park and Manufacturing/Industrial to Low-Medium Density Residential and High-Medium Density Residential (General Plan Amendment #24-03, Figure 1-4 and 1-5) • Zone Change from B-P and I-H (Heavy Industrial) of the proposed residential areas to RP-D (Zoning Change #435 and Residential Planned Development #83, Figure 1-6 and 1-7).
• Approval of Vested Tentative Subdivision Map (VSTM) #1333 The document and documents referenced in the Initial Study/Mitigated Negative Declaration (IS/MND) are available for review at City of Merced Planning Department located at 678 West 18th Street, Merced, CA 95340.

Mailing Address and Email of Contact Person
City of Merced, Planning Department
678 W. 18th Street
Mitigated Negative Declaration

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Merced, CA 95340
Contact Person: Jonnie Lan, AICP
Email: [email protected]
Findings
As Lead Agency, the City of Merced Planning Department finds that the project will not have a significant effect on the environment. The Environmental Checklist (CEQA Guidelines Appendix G) or Initial Study (IS) (see Section 3 - Environmental Checklist) identified one or more potentially significant effects on the environment, but revisions to the project have been made before the release of this Mitigated Negative Declaration (MND) or mitigation measures would be implemented that reduce all potentially significant impacts less-thansignificant levels. The Lead Agency further finds that there is no substantial evidence that this project would have a significant effect on the environment.

Mitigation Measures Included in the Project to Avoid Potentially Significant Effects
MM AQ-1: The project contractor or project representatives shall ensure that all off‐road diesel‐powered construction equipment meets the CARB Tier 4 emissions standards or equivalent.

BIO-1: a) A pre-construction clearance survey of the project site shall be conducted for special-status wildlife species and nesting migratory birds and raptors. The survey shall occur no less than 14-30 days prior to the start of construction activities. If construction is delayed beyond 30 days from the time of the survey, then another survey shall be conducted.

The survey shall be conducted by a qualified biologist with adequate training and prior experience conducting surveys for special-status wildlife species. If no special-status species or migratory birds/raptors or their sign are observed, no further action is warranted. A report outlining the results of the clearance survey shall be provided to the Lead Agency as evidence of compliance.
b) If dens/burrows/nests that could support any of these special-status species are discovered during the preconstruction survey, the avoidance buffers outlined below shall be established, and den or burrow monitoring shall be conducted in accordance with the California Department of Fish and Wildlife (CDFW) Staff Report on Burrowing Owl Mitigation (CDFG 2012) and U.S. Fish and Wildlife Service (USFWS) Standardized Recommendations for Protection of the Endangered San Joaquin Kit Fox Prior to or During Ground Disturbance (U.S. Fish and Wildlife Service, 2011).

Den(s) or burrow(s) shall be monitored using trail cameras or tracking mediums such as diatomaceous earth. If no species are detected for a minimum of four consecutive days/nights, the den or burrow may be burrow-scoped and plugged with a filled sandbag under the direct supervision of a qualified biologist. All tunnels must be examined for animal presence before plugging with a sandbag to ensure no burrowing owls, kit foxes, or other animals are hiding inside.

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No work shall occur within these buffers unless the biologist approves and monitors the activity. A copy of the preconstruction survey report shall be submitted to the Lead Agency as evidence of compliance.

Burrowing Owl (active burrows)
Location Time of Year Level of Disturbance
Low Med High
Nesting Sites April 1-Aug 15 200 m 500 m 500 m
Nesting Sites Aug 16-Oct 15 200 m 200 m 500 m
Nesting Sites Oct 16-Mar 31 50 m 100 m 500 m

American badger/SJKF
Potential or Atypical den – 50 feet
Known den – 100 feet
Natal Den –Contact CDFW for consultation
BIO-2: If construction is planned during the nesting season for migratory birds and raptors (February 15 to August 31) and nesting birds are identified during the preconstruction survey, active Swainson’s hawk nests shall be avoided by 0.5 miles, other raptor nests shall be avoided by 500 feet and all other migratory bird nests shall be avoided by 250 feet.

Avoidance buffers may be reduced if a qualified biological monitor determines that encroachment into the buffer area is not affecting nest building, the rearing of young, or otherwise affecting the breeding behaviors of the resident birds.

BIO-3: If an active Swainson’s hawk nest is discovered at any time within 0.5 miles of active construction, a qualified biologist shall complete an assessment of the potential for current construction activities to impact the nest. The assessment would consider the type of construction activities, the location of construction relative to the nest, the visibility of construction activities from the nest location, and other existing disturbances in the area that are not related to the construction activities of this project. Based on this assessment, the biologist will determine if construction activities can proceed, and the level of nest monitoring required. Construction activities shall not occur within 500 feet of an active nest, but depending on conditions at the site, this distance may be reduced. Full-time monitoring to evaluate the effects of construction activities on nesting Swainson’s hawks may be required. The qualified biologist shall have the authority to stop work if it is determined that project construction is disturbing the nest. These buffers may need to increase depending on the sensitivity of the nesting Swainson’s hawk to disturbances and at the discretion of the qualified biologist.

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potential to occur on the project, their legal status, the course of action shall these species be encountered on-site, and avoidance and minimization measures to protect these species.

BIO-5: The following measures shall be implemented during all phases of the project to reduce the potential for impact from the project.
a. All food-related trash items such as wrappers, cans, bottles, and food scraps shall be disposed of in securely closed containers and removed at least once a week from the construction or project site.
b. Construction-related vehicle traffic shall be restricted to established roads and predetermined ingress and egress corridors, staging, and parking areas. Vehicle speeds shall not exceed 20 miles per hour within the project site. A 10-mile-per-hour speed limit shall be implemented during night-time construction activities. c. To prevent inadvertent entrapment of kit fox or other animals during construction, the contractor shall cover all excavated, steep-walled holes or trenches more than two feet deep at the close of each workday with plywood or similar materials. If holes or trenches cannot be covered, one or more escape ramps constructed of earthen fill or wooden planks shall be installed in the trench. Before such holes or trenches are filled, the contractor shall thoroughly inspect them for entrapped animals. All construction-related pipes, culverts, or similar structures with a diameter of four inches or greater that are stored on the project site shall be thoroughly inspected for wildlife before the pipe is subsequently buried, capped, or otherwise used or moved in any way. If at any time an entrapped or injured kit fox is discovered, work in the immediate area shall be temporarily halted, and USFWS and CDFW shall be consulted for guidance.
d. Kit foxes are attracted to den-like structures such as pipes and may enter stored pipes and become trapped or injured. All construction pipes, culverts, or similar structures with a diameter of four inches or greater that are stored at a construction site for one or more overnight periods shall be thoroughly inspected for kit foxes before the pipe is subsequently buried, capped, or otherwise used or moved in any way. If a kit fox is discovered inside a pipe, that section of pipe shall not be moved until the USFWS and CDFW have been consulted. If necessary, and under the direct supervision of the biologist, the pipe may be moved only once to remove it from the path of construction activity until the fox has escaped.
e. No pets, such as dogs or cats, shall be permitted on the project sites to prevent harassment, mortality of kit foxes, or destruction of dens. f. No fueling of construction equipment will occur within 100 feet of a drainage, water crossing, or wetlands. If a spill or pipe break occurs within 100 feet of any water feature, adherence to the CREH Spill Prevention, Control, and Countermeasure (SPCC) Plan will be followed.

Mitigated Negative Declaration

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g. Use of anticoagulant rodenticides and herbicides in project sites shall be restricted.

This is necessary to prevent primary or secondary poisoning of kit foxes and the depletion of prey populations on which they depend. All uses of such compounds shall observe labels and other restrictions mandated by the EPA, California Department of Food and Agriculture, and other State and federal legislation, as well as additional project-related restrictions deemed necessary by the USFWS and CDFW. If rodent control must be conducted, zinc phosphide shall be used because of the proven lower risk to kit foxes.
h. A representative shall be appointed by the project proponent, who will be the contact source for any employee or contractor who might inadvertently kill or injure a kit fox or who finds a dead, injured, or entrapped kit fox. The representative shall be identified during the employee education program, and their name and telephone number shall be provided to the USFWS.
i. The Sacramento Fish and Wildlife Office of USFWS and CDFW shall be notified in writing within three working days of the accidental death or injury to an SJKF during project-related activities. Notification must include the date, time, and location of the incident or of the finding of a dead or injured animal and any other pertinent information. The USFWS contact is the Chief of the Division of Endangered Species at the addresses and telephone numbers below. The CDFW contact can be reached at (559) 243-4014 and [email protected]. The BLM will also be informed about those wells on the Split Estate property.
j. All sightings of the SJKF shall be reported to the CNDDB. A copy of the reporting form and a topographic map clearly marked with the location of where the kit fox was observed shall also be provided to the USFWS at the address below. k. Any project-related information required by the USFWS or questions concerning the above conditions, or their implementation may be directed in writing to the U.S. Fish and Wildlife Service at Endangered Species Division, 2800 Cottage Way, Suite W 2605, Sacramento, California 95825-1846, phone: (916) 414-6620 or (916) 414- 6600.
l. A copy of the pre-construction survey report shall be submitted to the Lead Agency as evidence of compliance.

BIO-6: Prior to the issuance of any grading or building permit, the Project proponent/developer shall submit a formal notification to the US Army Corps of Engineers (ACOE), Water Resources Control Board (SWRCB) and California Department of Fish and Wildlife (CDFW). If no comments or requests for additional permitting are received by the agencies, no further action is necessary. A copy of all correspondence shall be submitted to the lead agency.

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be made available to the Lead Agency. The report shall include information as shown below as a plan if necessary and shall outline compliance with the following:

1. Delineation of all jurisdictional features at the project site. Potential jurisdictional features within the project boundary identified in the jurisdictional delineation report may be shown in plan form.

2. If the Project has a potential to directly or indirectly impact jurisdictional aquatic resources, a formal aquatic resource delineation of these areas shall be performed by a qualified professional to determine the extent of agency jurisdiction and permits/authorizations from the appropriate regulating agencies (Central Valley Regional Water Quality Control Board (RWQCB), CDFW and US Army Corps of Engineers (USACE) shall be obtained prior to disturbance to jurisdictional features.

If it is determined that drainage is jurisdictional and cannot be avoided, the Project proponent shall obtain a Section 401 Waters Quality Certification from the RWQCB, a Section 404 permit from USACE and a Lake and Streambed Alteration Agreement under Section 1602 from the CDFW, if required prior to impacting any waters.

As part of these authorizations, compensatory mitigation may be required by the regulating agencies to offset the loss of aquatic resources. If so, and as part of the permit application process, a qualified professional shall draft a Mitigation and Monitoring Plan to address implementation and monitoring requirements under the permit to ensure that the Project would result in no net loss of habitat functions and values. The Plan shall contain, at a minimum, mitigation goals and objectives, mitigation location, a discussion of actions to be implemented to mitigate the impact, monitoring methods and performance criteria, extent of monitoring to be conducted, actions to be taken in the event that the mitigation is not successful, and reporting requirements. The Plan shall be approved by the appropriate regulating agencies and compensatory mitigation shall take place either on site or at an appropriate off-site location.

3. Any material/spoils generated from project activities containing hazardous materials shall be located away from jurisdictional areas or special-status habitat and protected from storm water run-off using temporary perimeter sediment barriers such as berms, silt fences, fiber rolls, covers, sand/gravel bags, and straw bale barriers, as appropriate. Protection measures should follow project-specific criteria as developed in a Stormwater Pollution Prevention and Protection Plan (SWPPP).

4. Equipment containing hazardous liquid materials shall be stored on impervious surfaces or plastic ground covers to prevent any spills or leakage from contaminating the ground and at least 50 feet outside the delineated boundary of jurisdictional water features.

5. Any spillage of material shall be stopped if it can be done safely. The contaminated area shall be cleaned, and any contaminated materials properly disposed. For all Mitigated Negative Declaration

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spills, the project foreman or designated environmental representative shall be notified.

MM CUL-1: If prehistoric or historic-era cultural materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a qualified archaeologist can evaluate the find and make recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock, as well as historic resources such as glass, metal, wood, brick, or structural remnants. If the qualified archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation.

These additional studies may include avoidance, testing, and evaluation or data recovery excavation. Implementation of the mitigation measure below would ensure that the proposed project would not cause a substantial adverse change in the significance of a historical resource.

CUL-2: In the event that buried prehistoric archaeological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified archaeologist shall be consulted to determine whether the resource requires further study. The qualified archaeologist shall make recommendations to the developer and City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines.

If the resources are determined to be unique prehistoric archaeological resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor and required to the developer and City. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur around the discovery until the lead agency approves the measures to protect these resources.

Any prehistoric archaeological artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study
MM CUL-3: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code. The specific protocol, guidelines, and channels of communication outlined by the Native American Heritage Commission, in accordance with Section 7050.5 of the Health and Safety Code, Section 5097.98 of the Public Resources Code (Chapter 1492, Statutes of 1982, Senate Bill 297), and Senate Bill 447 (Chapter 44, Statutes of 1987), shall be followed. Section 7050.5(c) shall guide the potential Native American involvement, in the event of a discovery of human remains, at the direction of the county coroner.

Mitigated Negative Declaration

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MM GEO-1: If the proposed development will disturb an area of one or more acres, prior to issuing of grading or building permits, the project applicant shall submit to the City; (1) the approved Stormwater Pollution Prevention Plan (SWPPP) and (2) the Notice of Intent (NOI) to comply with the General National Pollutant Discharge Elimination System (NPDES) from the Central Valley Regional Water Quality Control Board. The requirements of the SWPPP and NPDES shall be incorporated into design specifications and construction contracts.

Recommended Best Management Practices for the construction phase may include the following:
• Stockpiling and disposing of demolition debris, concrete, and soil properly. • Protecting existing storm drain inlets and stabilizing disturbed areas. • Implementing erosion controls.
• Properly managing construction materials.
• Managing waste, aggressively controlling litter, and implementing sediment control.

MM GEO-2: If any paleontological resources are encountered during ground-disturbance activities, all work within 25 feet of the find shall halt until a qualified paleontologist, as defined by the Society of Vertebrate Paleontology Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (2010), can evaluate the find and make recommendations regarding treatment. Paleontological resource materials may include resources such as fossils, plant impressions, or animal tracks preserved in rock. The qualified paleontologist shall contact the Natural History Museum of Los Angeles County or another appropriate facility regarding any discoveries of paleontological resources.

If the qualified paleontologist determines that the discovery represents a potentially significant paleontological resource, additional investigations and fossil recovery may be required to mitigate adverse impacts from project implementation. If avoidance is not feasible, the paleontological resources shall be evaluated for their significance. If the resources are not significant, avoidance is not necessary. If the resources are significant, they shall be avoided to ensure no adverse effects, or such effects must be mitigated. Construction in that area shall not resume until the resource-appropriate measures are recommended, or the materials are determined to be less than significant. If the resource is significant and fossil recovery is the identified form of treatment, then the fossil shall be deposited in an accredited and permanent scientific institution. Copies of all correspondence and reports shall be submitted to the Lead Agency.

MM NSE-1: A sound wall shall be constructed to a minimum height of 7 feet above ground level along the residential portions of the project site that are directly adjacent to Campus Parkway. Suitable construction materials include concrete blocks, masonry, or stucco on both sides of a wood or steel stud wall.

Mitigated Negative Declaration

Merced Gateway Project May 2025
City of Merced Page 10
MM NSE-2: Two-story home construction of lots that will be directly adjacent with Campus Parkway shall be constructed without second-floor balconies. A note prohibiting such second-floor balconies shall be placed as a Note on the VSTM #1333, and all plans and specs.

MM NSE-3: Air conditioning or mechanical ventilation shall be installed in the units so that it will be possible for windows and doors to remain closed for sound insulation purposes.

MM NSE-4: Unless further restricted in the City of Merced Municipal Code, grading and construction shall not take place beyond the hours of 7:00 A.M. and 7:00 P.M. MondaySunday.

MM TRA-1: The project proponent shall pay its equitable share costs percentages for intersection improvements pertaining to the storage pocket length at the northbound right approach at the Mission Avenue and SR 99 NB Off-Ramp intersection.

Payment amount of the equitable share costs shall be determined by the City of Merced and Caltrans and paid prior to issuance of building permits or at a time determined by the Lead Agency. The equitable share cost percentage shall be 7.7% for AM Peak Hour and 13% for PM Peak Hour.

Introduction

Merced Gateway Project May 2025
City of Merced Page 1-1
SECTION 1 - INTRODUCTION

1.1 - Overview
Lennar Homes of California (Applicant) proposes the Merced Gateway Subdivision (project), on an approximately 73.7-acre project site in the City of Merced, Merced County, CA. The project proposes to amend the City of Merced General Plan to designate an approximately

61.7-acre portion of the project site from Business Park and Manufacturing/Industrial to Low-Medium Density Residential and High-Medium Density Residential, and a zone change from B-P (Business Park) to RP-D (Residential Planned Development) to allow construction of a 570-lot single-family subdivision and approximately 2.8 acres of park/open space.

The remaining approximately 9-acre commercial area will remain designated as Business Park under the General Plan and zoned B-P. Figure 1-1 shows the regional location, Figure 1-2 shows the project location and Figure 1-3 illustrates the layout of the Tentative Map.

1.2 - California Environmental Quality Act
The City of Merced is the Lead Agency for this project pursuant to the CEQA Guidelines (Public Resources Code Section 15000 et seq.). The Environmental Checklist (CEQA Guidelines Appendix G) or IS (see Section 3 – Initial Study) provides analysis that examines the potential environmental effects of the construction and operation of the project. Section 15063 of the CEQA Guidelines requires the Lead Agency to prepare an IS to determine whether a discretionary project will have a significant effect on the environment. A MND is appropriate when an IS has been prepared, and a determination can be made that no significant environmental effects will occur because revisions to the project have been made or mitigation measures will be implemented that reduce all potentially significant impacts to less-than-significant levels. The content of an MND is the same as a Negative Declaration, with the addition of identified mitigation measures and a Mitigation Monitoring and Reporting Program (MMRP) (see Section 6 – Mitigation Monitoring and Reporting Program).

Based on the IS, the Lead Agency has determined that the environmental review for the proposed application can be completed with an MND.

1.3 - Impact Terminology
The following terminology is used to describe the level of significance of impacts. • A finding of “no impact” is appropriate if the analysis concludes that the project would not affect a topic area in any way.
• An impact is considered “less than significant” if the analysis concludes that it would cause no substantial adverse change to the environment and requires no mitigation. • An impact is considered “less than significant with mitigation incorporated” if the analysis concludes that it would cause no substantial adverse change to the environment with the inclusion of environmental commitments that have been agreed to by the applicant.

Introduction
Merced Gateway Project May 2025
City of Merced Page 1-2
• An impact is considered “potentially significant” if the analysis concludes that it could have a substantial adverse effect on the environment.

1.4 - Document Organization and Contents
The content and format of this Initial Study/Mitigated Negative Declaration (IS/MND) is designed to meet the requirements of CEQA. The report contains the following sections:
• Section 1 – Introduction: This section provides an overview of CEQA requirements, intended uses of the IS/MND, document organization, and a list of regulations that have been incorporated by reference.
• Section 2– Project Description: This section describes the project and provides data on the site’s location.
• Section 3 – Initial Study: This section contains the evaluation of 21 different environmental resource factors contained in Appendix G of the CEQA Guidelines. Each environmental resource factor is analyzed to determine whether the proposed project would have an impact. One of four findings is made which include: no impact, less-than-significant impact, less than significant with mitigation, or significant and unavoidable. If the evaluation results in a finding of significant and unavoidable for any of the 21 environmental resource factors, then an Environmental Impact Report will be required.
• Section 4 – List of Preparers: This section identifies the individuals who prepared the IS/MND.
• Section 5 – Bibliography: This section contains a full list of references that were used in the preparation of this IS/MND.
• Section 6 – Mitigation Monitoring and Reporting Program: This section contains the Mitigation Monitoring and Reporting Program.

1.5 - Incorporated by Reference
The following documents and/or regulations are incorporated into this IS/MND by reference:
• City of Merced Vision 2030 General Plan
• City of Merced Draft General Plan Environmental Impact Report (EIR) • Merced Municipal Code - Title –0 Zoning Ordinance
• Merced County Airport Land Use Compatibility Plan
• City of Merced 2020 Urban Water Management Plan
• Merced Groundwater Subbasin Groundwater Sustainability Plan Introduction

Merced Gateway Project May 2025
City of Merced Page 1-3

Figure 1-1
Regional Location
Project Location
0 Miles 100 0 Ensenado
Introduction

Merced Gateway Project May 2025
City of Merced Page 1-4

Figure 1-2
Project Site
Introduction

Merced Gateway Project May 2025
City of Merced Page 2-1
Introduction

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City of Merced Page 2-1
Figure 1-3
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Introduction

Merced Gateway Project May 2025
City of Merced Page 2-1

Figure 1-4
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Introduction

Merced Gateway Project May 2025
City of Merced Page 2-1

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Introduction

Merced Gateway Project May 2025
City of Merced Page 2-2

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Introduction

Merced Gateway Project May 2025
City of Merced Page 2-3

Figure 1-7
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Project Description
Merced Gateway Project May 2025
City of Merced Page 2-1
SECTION 2 - PROJECT DESCRIPTION

2.1 - Introduction
Lennar Homes of California (Applicant) proposes the Merced Gateway Subdivision Project on an approximately 73.7-acre project site in the City of Merced, Merced County, CA. Figure 1 1 shows the regional location, Figure 1 2 shows the project location and Figure 1-3 depicts the proposed tentative tract.

2.2 - Project Location
The proposed project is located in the City of Merced (City; Assessor’s Parcel Number [APN] 061-710-009, 061-710-023, and 061-680-001). The proposed project site is approximately

73.7 acres and is generally bounded by East Gerard Avenue to the north, East Mission Avenue to the south, South Coffee Street to the west, and Campus Parkway to the east. The project site will be bifurcated by Campus Parkway, with portions of both commercial and residential on either side of the roadway.

2.3 - Project Environment
The project site is currently undeveloped land. The property is bounded by East Gerard Avenue and residential to the north, agricultural land to the east, residential and agricultural land to the south and commercially developed and vacant land to the west.

2.4 - Proposed Project
The proposed project, Merced Gateway (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30), includes development of 570 single-family residential lots, the future development of 9-acres of commercial area, and 3.0 acres of open space/park within the city limits of the City of Merced.

Residential Component:

Project Description

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City of Merced Page 2-2
A total of 570 lots are proposed on an approximately 61.7-acre portion of the 73.7-acre site, resulting in a residential density of 8.02 dwelling units per acre. Lot sizes for the residential area will vary and include lot sizes ranging between 2,375 square feet to over 6,559 square feet.

Commercial Component:

There is no proposed commercial tenant at this time, and this component is expected to be developed at a later date.

Based on these assumptions, the Floor Area Ratio (FAR) is 0.25 (99,100 square feet of commercial and office space / 392,040 square feet of total commercial area).

Entitlements:

Approval of Tentative Tract Map VSTM #1333
Construction:

Full buildout of the residential area will take approximately six to seven years after approval and necessary permits are issued. As noted above, development of the commercial area would occur separately from the residential development.

Construction of the residential development would occur over a maximum of seven years. It is anticipated that the following pieces of equipment would be used during construction activities:
• Roller
• Loaded trucks
Project Description

Merced Gateway Project May 2025
City of Merced Page 2-3
• Excavator
• Generator
• Service truck
• Air compressor
Initial Study
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SECTION 3 - INITIAL STUDY

3.1 - Environmental Checklist

1. Project Title:

Merced Gateway Project (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30)

2. Lead Agency Name and Address:

City of Merced Planning Department
6787 W. 18th Street
Merced, CA 95340

3. Contact Person and Phone Number:

Jonnie Lan, AICP, Interim Planning Manager
STAFF PHONE 209.385.4768

4. Project Location:

The proposed project (APN 061-710-009, a portion of 061-710-023, and 061-680-001) is approximately 73.7 acres and is generally bounded by East Gerard Avenue to the north, East Mission Avenue to the south, South Coffee Street to the west, and Campus Parkway to the east. The project site will be bifurcated by Campus Parkway, with portions of both commercial and residential on either side of the roadway.

5. General Plan Designation:

Existing: Business Park and Manufacturing/Industrial
Proposed: Low-Medium Density Residential and High-Medium Density Residential

6. Zoning:

Existing: B-P (Business Park) and I-H (Heavy Industrial) Proposed: RP-D (Residential Planned Development)

7. Description of Project:

The proposed project, Merced Gateway (GPA #24-03, R-PD EST. #83, VTSM #1333, ZC #435, ERC #24-30), includes development of 570 single-family residential lots, the future Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-2
development of a 9-acre commercial area, and 3.0 acres of open space/park within the city limits of the City of Merced.

Residential Component:

Phase 1: the northerly portion of the site includes 328 residential lots and a 2.4 acres of park space on the eastern boundary of the site. The designated commercial area will be approximately 4.35 acres on the north side of Campus Parkway.

A total of 570 lots are proposed on an approximately 61.7-acre portion of the 73.7-acre site, resulting in a residential density of 8.02 dwelling units per acre. Lot sizes for the residential area will vary and include lot sizes ranging between 2,375 square feet to over 6,559 square feet.

Commercial Component:

There is no proposed commercial tenant at this time, and this component is expected to be developed at a later date.

Based on these assumptions, the Floor Area Ratio (FAR) is 0.25 (99,100 square feet of commercial and office space / 392,040 square feet of total commercial area).

Entitlements:

Approval of Tentative Tract Map VSTM #1333
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-3

8. Surrounding Land Uses and Setting:

The project site is currently undeveloped land. The property is bounded by East Gerard Avenue and residential to the north, agricultural land to the east, residential and agricultural land to the south and commercially developed and vacant land to the west.

9. Other Public Agencies Whose Approval May be Required:
• California Department of Fish and Wildlife
• California State Water Resources Control Board
• San Joaquin Valley Air Pollution Control District
• US Army Corps of Engineers
Initial Study

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3.2 - 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 & 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

3.3 - Determination
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.

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 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 (a) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (b) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENT IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed Project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed □
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Initial Study
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 pro o o • ect, nothing further is required. s/hb~
Date 1 I
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Merced Gateway Project
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Initial Study

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3.4 - Evaluation of Environmental Impacts

1. 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 Projectspecific screening analysis).

2. 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.

3. 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.

4. "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-Than-Significant Impact." The Lead Agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less-thansignificant level (mitigation measures from "Earlier Analyses," as described in (5) below, may be cross-referenced).

5. 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 measures based on the earlier analysis.
c. Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address sitespecific conditions for the Project.

Initial Study

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6. 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 reference to the page or pages where the statement is substantiated.

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

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a Project's environmental effects in whatever format is selected.

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.

Initial Study

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Discussion
Impact #3.4.1a – Would the Project have a substantial adverse effect on a scenic vista? Scenic vistas are defined as expansive views of highly valued landscapes from publicly accessible viewpoints. Scenic vistas include views of natural features such as topography, water courses, rock outcrops, and natural vegetation as well as manmade scenic structures.

It is noted the General Plan, that the majority of scenic vistas in vicinity of the City are local, with views of the Sierra Nevada to the east and the Coast Ranges to the west. Additional scenic resources include the corridors of the Merced River, San Joaquin River, Los Banos Creek, and Bear Creek. The project site does not contain high quality views of the Sierra Nevada’s or Coast Ranges, and is not located in proximity to the Merced River, San Joaquin River, Los Banos Creek, or Bear Creek.

The General Plan Policy OS-1.3.b identifies several scenic corridors within the city limits along with establishing guidelines for project review of development within a designated scenic corridor under Policy OS-1.3.c. The listed scenic corridors are identified as such due to their part in establishing the City’s identity. The following corridors are designated as Scenic Corridors under General Plan Policy OS-1.3.b:

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact
No
Impact

3.4.1 - AESTHETICS
Except as provided in Public Resources Code
Section 21099, would the Project:
a. Have a substantial adverse effect on a scenic
vista?
b. Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
c. In non-urbanized area, substantially degrade
the existing visual character or quality of
public views of the site and its surroundings?
If the Project is in an urbanized area, would
the Project conflict with applicable zoning
and other regulations governing scenic
quality?
d. Create a new source of substantial light or
glare that would adversely affect day or
nighttime views in the area?
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Initial Study

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a. North and South Bear Creek Drive within the city limits b. N Steet from 16th Street to the Merced County Courthouse c. 21st Street from Merced County Courthouse to Glen Avenue d. M Street from Black Rascal Creek to Bellevue Road
e. West 28th Street from M Street to G Street
f. Lake Road from Yosemite Avenue to Lake Yosemite
g. R Street (extended) from Black Rascal Creek to Bellevue Road h. Olive Avenue East of McKee Road
i. M Street from 18th Street to Bear Creek
j. Campus Parkway
k. Bellevue Road from Lake Road to “G” Street
As Campus Parkway bifurcates the project site, compliance with design guidelines established under General Plan Policy OS-1.3.c would be applicable to both the proposed residential development and future commercial development. Further design policies established under the General Plan Urban Design Element, Urban Expansion Element, and Land Use Element contain standards that would reduce any impacts to the scenic corridor.

These design standards include the use of low FAR (Policy UD-2.2.b) and maximum residential building heights (Title 20, Chapter 20.08). As previously noted, the project FAR is 0.25 (99,100 square feet of commercial and office space / 396,396 square feet of total commercial area). The residential units will be developed with a variety of floor plans and square footages dependent on their lot location. Square footages for the residential units will range from 1,341 square feet up to 1,855 square feet and be one to two-stories in height.

The sites are not within or in the vicinity of a city, county, or State identified scenic vista. As discussed above, the project site is along Campus Parkway which is an identified scenic corridor and will be required to comply with General Plan Policy OS-1.3.c for corridor design guidelines Furthermore, the development of the project would not block or preclude views of any area containing importance or what would be considered visually appealing landforms. Therefore, with compliance with General Plan policies, a less than significant impact is anticipated on scenic resources.

MITIGATION MEASURE(S)
No mitigation is required.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-10

LEVEL OF SIGNIFICANCE
There would be less than significant impact.

Impact #3.4.1b – Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? See Impact #3.4.1a above.

The project does not lie near or within a State Designated or Eligible State Scenic Highway (California Department of Transportation 2024). The nearest Eligible Scenic Highway is SR 49, approximately 29 miles northeast of the project site. The project is devoid of trees; the majority of the property has been under cultivation and does not include the removal of trees determined to be scenic or of scenic value, the destruction of rock outcroppings or degradation of any historic building(s). Therefore, the project would have no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.1c – In non-urbanized area, substantially degrade the existing visual character or quality of public views of the site and its surroundings? If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?
The project site is located in the southeastern boundary of the City. The property is bound by East Mission Avenue to the south, undeveloped commercial land to the west, vacant land to the east, and East Gerard Avenue with residential land to the north. The City zoning map classifies the surrounding parcels to the east as I-H (Heavy Industrial), parcels to the west as P-D (Planned Development), to the north as R-1-5 (Low Density Residential), and land to the south is on zoned A-1 (General Agricultural) under County of Merced jurisdiction.

The proposed project will be subject to the City Zoning Ordinance, which contains development and landscaping standards for commercial and residentially zoned areas.

Specifically, project development would comply with Chapter 20.36 of the Zoning Ordinance for landscaping standards, Chapter 20.46 for residential design standards, and Chapter 20.10 for commercial development standards. The proposed project would be developed in similar visual quality to existing residential developments to the north and further to the west and would not substantially degrade the existing visual character of the area.. The project would comply with City of Merced development and landscape standards and would not conflict with applicable zoning and other regulations governing scenic quality.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-11

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.1d – Would the Project create a new source of substantial light or glare that would adversely affect day or nighttime views in the area? Construction of the proposed project would generally occur during daytime hours, typically from 7:00 A.M. to 7:00 P.M.. Policy N-1.3.a limits operating hours for noisy construction used in the City of Merced and Policy N.1.5.f defined daytime as 7:00 A.M. to 10:00 P.M., however, since this policy allows the City to be able to impose noise level standards that are more restrictive, and since there continues to be concerns with construction noise related to nearby occupied residential units, construction of the project will be held to the 7:00 A.M. to 7:00 P.M. timeframe. Increased truck traffic and the transport of construction materials to the project site would also be minimal and temporary in nature. Construction activity would focus on specific areas on the sites, and any sources of glare would not be stationary for a prolonged period of time. Therefore, construction of the proposed project would not create a new source of substantial glare that would affect daytime views in the area.

Once constructed, the project will include exterior lighting for the proposed residences and commercial development. With the compliance of the Merced Zoning Ordinance (Chapter

20.46 for residential design standards and Chapter 20.10.030 for commercial development standards and guidelines), and other applicable local development standards for exterior lighting, the proposed project would not create new sources of substantial light or glare that would adversely affect day or nighttime views in the area. Therefore, project impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-12

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.2 - 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 Department of
Conservation as an optional 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 Department 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 by the
California Air Resources Board. Would the Project:
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?
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract?
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g)),
timberland (as defined by Public Resources
Code Section 4526), or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?
d. Result in the loss of forest land or conversion
of forest land to non-forest use?
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
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Discussion
Impact #3.4.2a – Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use? The Farmland Mapping and Monitoring Program (FMMP) designation of the project site is listed as Farmland of Local Importance (California Department of Conservation 2024). The project site is bounded by Prime Farmland and Farmland of Statewide Importance to the east, Farmland of Local Importance to the west, and Urban and Built-up Land to the north and south.

The project site is currently zoned BP and I-H and is not zoned for agricultural use, and the General Plan already accounted for the conversion of this property to a non-agricultural use.

Farmland of Local Importance is not considered important farmland under CEQA, and therefore, conversion of the land, the project would not result in the conversion of Farmland and will result in no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.2b – Would the Project conflict with existing zoning for agricultural use or a Williamson Act contract?
The project site is not subject to a Williamson Act land use contract, according to data available from the California Department of Conservation. Additionally, as noted above, the project site is currently zoned BP and I-H and is not zoned for agricultural use. Therefore, the project proposal would not result in a conflict with existing zoning for agricultural use or a Williamson Act contract, and there would be no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be no impact.

Impact #3.4.2c – Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined Initial Study

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by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
The Public Resources Code (PRC) Section 12220(g) and Section 4526 defines “Forest land” as land that can support 10 percent native tree cover of any species, including hardwoods, under natural conditions and that allows for the management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits. Timberland, pursuant to PRC 4526, is land other than land owned by the federal government and land designated as experimental forest land, which is available for and capable of growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees.

There are no forest lands or timberlands identified on the project sites or within its vicinity.

The project would not result in the loss or conversion of forest land to a non-forest use.

Therefore, there would be no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.2d – Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
See discussion of Impact #3.4.2c above.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.2e – Would the Project 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?
See discussion of Impacts #3.4.2a, #3.4.2b, and #3.4.2c above.

MITIGATION MEASURE(S)
No mitigation is required.

Initial Study

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City of Merced Page 3-15

LEVEL OF SIGNIFICANCE
There would be no impact.

Initial Study

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City of Merced Page 3-16
Discussion
The analyses in this section are based on an Air Quality and Greenhouse Gas Impact Assessment (VRPA Technologies, Inc. 2025a), attached as Appendix A. The Air Quality and Greenhouse Gas Impact Assessment considered build out of a larger number of residential lots than is currently proposed. Therefore, it can be assumed that the air quality emissions estimates resulting from the project would be less than those discussed in this IS/MND.

Impact #3.4.3a – Would the Project conflict with or obstruct implementation of the applicable air quality plan?
The City is located in the San Joaquin Valley Air Basin (SJVAB). The surrounding topography includes foothills and mountains to the east and west that direct air circulation and dispersion patterns. Temperature inversions can trap air within the Valley, thereby preventing the vertical dispersal of air pollutants. In addition to topographic conditions, the local climate can also contribute to air quality problems. Climate in Merced is classified as Mediterranean, with moist cool winters and dry warm summers.

The San Joaquin Valley Air Pollution Control District (SJVAPCD) is the agency responsible for monitoring and regulating air pollutant emissions from stationery, area, and indirect sources within Merced County and throughout the SJVAB. The district also has responsibility for monitoring air quality and setting and enforcing limits for source emissions. California Air

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact
No
Impact

3.4.3 - AIR 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?
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?
c. Expose sensitive receptors to substantial
pollutant concentrations?
d. Result in other emissions (such as those
leading to odor) adversely affecting a
substantial number of people?
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□
□
□
□
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Resources Board (CARB) is the agency with the legal responsibility for regulating mobile source emissions. The district is precluded from such activities under State law. The district was formed in mid‐1991 and prepared and adopted the San Joaquin Valley Air Quality Attainment Plan (AQAP), dated January 30, 1992, in response to the requirements of the California Clean Air Act (CCAA). The CCAA requires each non‐attainment district to reduce pertinent air contaminants by at least five percent (5%) per year until new, more stringent, 1988 State air quality standards are met. Activities of the SJVAPCD include the preparation of plans for the attainment of ambient air quality standards, adoption and enforcement of rules and regulations concerning sources of air pollution, issuance of permits for stationary sources of air pollution, inspection of stationary sources of air pollution and response to citizen complaints, monitoring of ambient air quality and meteorological conditions, and implementation of programs and regulations required by the Federal Clean Air Act (FCAA) and CCAA.

The SJVAPCD has prepared the following State Implementation Plans to address ozone, particulate matter of 10 micrometers or less (PM10) and particulate matter of 2.5 micrometers or less (PM2.5) that currently apply to non‐attainment areas:
• The 2016 Ozone Plan (2008 standard) was adopted by SJVAPCD on June 16, 2016, and subsequently adopted by CARB on July 21, 2016.
• The 2013 1‐Hour Ozone Plan (revoked 1997 standard) was adopted by the SJVAPCD on September 19, 2013. EPA withdrew its approval of the plan due to litigation. The district plans to submit a “redesignation substitute” to EPA to maintain its attainment status for this revoked ozone standard.
• The 2007 PM10 Maintenance Plan (as revised in 2015) was approved by EPA on July 8, 2016 (effective September 30, 2016).
• The 2012 PM2.5 Plan (as revised in 2015) was approved by EPA on August 16, 2016 (effective September 30, 2016).

The SJVAPCD Plans identified above represent SJVAPCD’s plan to achieve both State and federal air quality standards. The regulations and incentives contained in these documents must be legally enforceable and permanent. These plans break emissions reductions and compliance into different emissions source categories.

The SJVAPCD also prepared the Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI), dated March 19, 2015. The GAMAQI is an advisory document that provides Lead Agencies, consultants, and project applicants with analysis guidance and uniform procedures for addressing air quality impacts in environmental documents. Local jurisdictions are not required to utilize the methodology outlined therein. This document describes the criteria that SJVAPCD uses when reviewing and commenting on the adequacy of environmental documents. It recommends thresholds for determining whether or not projects would have significant adverse environmental impacts, identifies methodologies for Initial Study

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predicting project emissions and impacts, and identifies measures that can be used to avoid or reduce air quality impacts.

In order to demonstrate that a proposed project would not cause further air quality degradation in either the SJVAPCD’s plan to improve air quality within the air basin or the federal requirements to meet certain air quality compliance goals, each project should also demonstrate consistency with the SJVAPCD’s adopted Air Quality Attainment Plans (AQAP) for Ozone (O3) and PM10. The SJVAPCD is required to submit a “Rate of Progress” document to CARB that demonstrates past and planned progress toward reaching attainment for all criteria pollutants. The CCAA requires air pollution control districts with severe or extreme air quality problems to provide for a 5% reduction in non-attainment emissions per year.

The AQAP prepared for the San Joaquin Valley by the SJVAPCD complies with this requirement. CARB reviews, approves, or amends the document and forwards the plan to EPA for final review and approval within the SIP.

Air pollution sources associated with stationary sources are regulated through the permitting authority of the SJVAPCD under the New and Modified Stationary Source Review Rule (SJVAPCD Rule 2201). Owners of any new or modified equipment that emits, reduces or controls air contaminants, except those specifically exempted by the SJVAPCD, are required to apply for an Authority to Construct and Permit to Operate (SJVAPCD Rule 2010).

Additionally, best available control technology (BACT) is required on specific types of stationary equipment and are required to offset both stationary source emission increases along with increases in cargo carrier emissions if the specified threshold levels are exceeded (SJVAPCD Rule 2201, 4.7.1). Through this mechanism, the SJVAPCD would ensure that all stationary sources within the project area would be subject to the standards of the SJVAPCD to ensure that new developments do not result in net increases in stationary sources of criteria air pollutants.

State CEQA Guidelines and the FCAA (Sections 176 and 316) contain specific references on the need to evaluate consistency between the proposed project and the applicable AQAP for the project site. To accomplish this, CARB has developed a three-step approach to determine project conformity with the applicable AQAP:

1. Determination that an AQAP is being implemented in the area where the project is being proposed. The SJVAPCD has implemented the current, modified AQAP as approved by CARB.

2. The proposed project must be consistent with the growth assumptions of the applicable AQAP. The proposed project land use type was not anticipated in the current growth assumptions. Therefore, growth assumptions in the City of Shafter General Plan will be modified with the approval of the proposed project.

3. The project must contain in its design all reasonably available and feasible air quality control measures. The proposed project incorporates various policy and rulerequired implementation measures that will reduce related emissions.

Initial Study

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City of Merced Page 3-19
The CCAA and AQAP identify transportation control measures as methods to further reduce emissions from mobile sources. Strategies identified to reduce vehicular emissions such as reductions in vehicle trips, vehicle use, vehicle miles traveled, vehicle idling, and traffic congestion, in order to reduce vehicular emissions, can be implemented as control measures under the CCAA as well. Additional measures may also be implemented through the building process such as providing electrical outlets on exterior walls of structures to encourage use of electrical landscape maintenance equipment or measures such as electrical outlets for electrical systems on diesel trucks to reduce or eliminate idling time.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth, and that designate locations for land uses to regulate growth. Merced County Association of Governments (MCAG) uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then vehicle miles traveled (VMT), which are then provided to SJVAPCD to estimate future emissions in the air quality plans (AQP). Existing and future pollutant emissions computed in the AQP are based on land uses from area general plans. AQPs detail the control measures and emission reductions required for reaching attainment of the air standards.

The project is consistent with the currently adopted General Plan and is therefore consistent with the population growth and VMT applied in the plan. Therefore, the project is consistent with the growth assumptions used in the applicable AQPs. As a result, the project will not conflict with or obstruct the implementation of any air quality plans.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.3b – Would the Project 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)?
The Merced County area is nonattainment for federal and State air quality standards for ozone, in attainment of federal standards and nonattainment for State standards for PM10, and nonattainment for federal and State standards for PM2.5. The SJVAPCD has prepared the 2016 and 2013 Ozone Plans, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan to achieve federal and State standards for improved air quality in the SJVAB regarding ozone and PM.

Inconsistency with any of the plans would be considered a cumulatively adverse air quality impact. The project is consistent with the currently adopted General Plan for the City of Merced and is therefore consistent with the population growth and VMT applied in the plan.

Initial Study

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City of Merced Page 3-20
Therefore, the project is consistent with the growth assumptions used in the 2016 and 2013 Ozone Plan, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan.

Project specific emissions that exceed the thresholds of significance for criteria pollutants would be expected to result in a cumulatively considerable net increase of any criteria pollutant for which the County is in non‐attainment under applicable federal or state ambient air quality standards. It should be noted that a project is not characterized as cumulatively insignificant when project emissions fall below thresholds of significance. The SJVAPCD adopted thresholds of significance for criteria pollutants is given in Table 3.4.3-1 below.

Table 3.4.3-1
SJVAPCD Air Quality Thresholds of Significance – Criteria Pollutants Criteria Pollutant
Construction Emissions
(tons per yr.)
Operational Emissions
(tons per yr.)
CO 100 100
NOx 10 10
ROG 10 10
SOx 27 27
PM10 15 15
PM2.5 15 15
Source: (San Joaquin Air Pollution Control District 2015) The proposed project would be required to comply with all recommended measures for construction activities listed in the GAMAQI, applicable measures set for in Title 24 of the Uniform Building Code, and applicable SJVAPCD rules.

Short-Term Construction Emissions
Short‐term impacts are mainly related to the construction phase of a project and are recognized to be short in duration. Construction air quality impacts are generally attributable to dust and exhaust pollutants generated by equipment and vehicles. Fugitive dust is emitted both during construction activity and as a result of wind erosion over exposed earth surfaces. Clearing and earth moving activities do comprise major sources of construction dust emissions, but traffic and general disturbances of soil surfaces also generate significant dust emissions. Further, dust generation is dependent on soil type and soil moisture. Exhaust pollutants are the non‐useable gaseous waste products produced during the combustion process. Engine exhaust contains Carbon Monoxide (CO), Hydrocarbons (HC), and Nitrogen Oxides (NOx) pollutants which are harmful to the environment. Adverse effects of construction activities cause increased dust‐fall and locally elevated levels of total suspended particulate. Dust‐fall can be a nuisance to neighboring properties or previously completed developments surrounding or within the project area and may require frequent washing during the construction period.

Initial Study

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PM10 emissions can result from project related construction activities. The SJVAPCD has determined that compliance with Regulation VIII and other control measures will constitute sufficient mitigation to reduce PM10 impacts to a level considered less‐than significant for most development projects. Even with implementation of District Regulation VIII and District Rule 9510, large development projects may not be able to reduce project specific construction impacts below District thresholds of significance.

SJVAPCD’s required measures for all projects were also applied:
• Water exposed areas three times per day; and
• Reduce vehicle speed to less than 15 miles per hour.

Table 3.4.3-2 below summarizes the anticipated pollutant emissions resulting from construction of the proposed project. Development of the proposed project is anticipated to generate criteria pollutant emissions below SJVAPCD significance threshold levels.

Table 3.4.3-2
Construction Emissions
Emissions
Sources
Pollutant
ROG NOx CO S02 PM10 PM2.5
(tons/year)
Project
Construction
Emissions

3.58 2.76 2.83 0.01 1.13 0.54

SJVAPCD
Significance
Threshold
10 10 100 27 15 15
Is the

SJVAPCD
Threshold
Exceeded
After
Mitigation?
No No No No No No
Source: (VRPA Technologies, Inc. 2025a)
As calculated with CalEEMod, the estimated short-term construction-related emissions for criteria pollutants would not exceed significance threshold levels during any given year.

Long-Term Operational Emissions
Long-term emissions are caused by operational mobile, area, and energy sources. The Merced County area is nonattainment for Federal and State air quality standards for ozone, attainment of Federal standards for PM10 and nonattainment for State standards, and Initial Study

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nonattainment for Federal and State standards for PM2.5. Nitrogen oxides and reactive organic gases are regulated as ozone precursors.

Operation of the proposed project is anticipated to generate criteria pollutant emissions below SJVAPCD significance threshold levels, as shown in the table below.

Table 3.4.3-3
Operational Emissions
Emissions
Sources
Pollutant
ROG NOx CO SOx PM10 PM2.5
(tons/year)
Energy 8.61 5.51 30.70 0.07 7.83 2.20

SJVAPCD
Threshold
10 10 100 27 15 15
Is SJVAPCD
Threshold
Exceeded?
No No No No No No
Source: (VRPA Technologies, Inc. 2025a)
Fugitive Dust Emissions
Operation of the project site at full build-out is not expected to present a substantial source of fugitive dust (PM10) emissions. The main source of PM10 emissions would be from vehicular traffic associated with the project site.

PM10, on its own as well as in combination with other pollutants, creates a health hazard. The SJVAPCD’s Regulation VIII establishes required controls to reduce and minimize fugitive dust emissions. The following SJVAPCD Rules and Regulations apply to the proposed project (and all projects):
• Rule 4102 – Nuisance – prohibits a facility from posing as a nuisance to surrounding receptors and can impose penalties for nuisance issues such as dust, smoke, excess emissions, etc. Compliance with this rule ensures that the area around the project site will not be adversely impacted by such issues.
• Regulation VIII – Fugitive PM10 Prohibitions – a series of regulations to reduce and/or eliminate generation of particulate matter (PM) that can adversely impact visibility as well as the health and safety of people on-site or in the vicinity of the project. • Rule 8011 - General Requirements – this rule is to reduce ambient concentrations of fine particulate matter (PM10) by requiring actions to Initial Study

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prevent, reduce or mitigate anthropogenic (human-caused) fugitive dust emissions.
• Rule 8021 - Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities – restricts generation of airborne dust and visibility impacts from these activities. Places limits on opacity and equipment operation under certain adverse weather conditions.
• Rule 8041 - Carryout and Trackout – requires that equipment and vehicles leaving the construction site control the amount of dirt, soil or mud that is tracked offsite and onto public roadways. This helps eliminate or minimize dust generation and opacity degradation.
• Rule 8051 - Open Areas – limits fugitive dust from open areas, i.e., areas on a construction site that are not actively being constructed upon but may generate wind-blown dust.

The project would comply with applicable SJVAPCD Rules and Regulations, the local zoning codes, and additional emissions reduction measures recommended in the Air Quality Impact Analysis.

The project does not conflict with or obstruct implementation of an applicable air quality plan or exceed the SJVAPCD’s established emissions thresholds and significance thresholds for all CEQA air quality determinations. Therefore, this project would not pose a significant impact to the SJVAB. The proposed project would not 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 and would have a less-thansignificant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.3c – Would the Project expose sensitive receptors to substantial pollutant concentrations?
The first step in evaluating the potential for impacts to sensitive receptors for toxic air contaminants (TAC) from the project is to perform a screening level analysis. For Type B projects, one type of screening tool is found in the CARB Handbook: Air Quality and Land Use Handbook: A Community Perspective. This handbook includes a table with recommended buffer distances associated with various types of common sources. The CARB Handbook indicates that new sensitive land uses shouldn’t be sited within 500 feet of a freeway/urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. SR 99, located Initial Study

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approximately 1,700 feet from the project site, carries approximately 52,000 Annual Average Daily Trips (AADT). The project, particularly its residential uses, are located more than 500 feet from SR 99.

There is an existing gas station (ARCO) located at the southeast corner of Campus Parkway and Coffee Street that offers eight (8) fueling pumps or 16 fueling positions. While the yearly gasoline throughput of the existing gas station is not known, the project site is located more than 1,200 feet to the east.

An evaluation of nearby land uses considering CARB’s Pollution Mapping Tool shows that the project will not place sensitive receptors in the vicinity of existing toxic sources. The project is located more than five (5) miles from the Hilmar Cheese Company, a known toxic emitting source. This facility is the nearest toxic emitting source to the project site based upon CARB’s Pollution Mapping Tool. The screening level analysis for the project shows that TACs are not a concern based upon the recommendations provided in CARB’s Handbook and Pollution Mapping Tool.

Health risks from diesel‐exhaust emissions mainly arise from long‐term exposure and the risk of cancer. Diesel‐powered construction equipment will be used intermittently across the site. State regulations limit idling to 5 minutes, reducing temporary DPM emissions exposure for sensitive receptors. Even during peak construction, diesel PM emissions will come from various locations due to different construction activities not happening in the same place simultaneously. TAC emissions associated with the construction of the project were used to assess impacts to adjacent sensitive receptors. Table 3.4.3-4 shows the analysis results for maximally exposed individuals at nearby sensitive receptors. A threshold of 10 in one million was used instead of the SJVAPCD’s 20 in one million due to the uncertainties in assessing cancer risk from short‐term construction exposures. Results of the analysis show that TAC emissions at residences adjacent to the project site would exceed the 10 in one million threshold from construction activities. Implementation of Mitigation Measure (MM) AQ‐1 would reduce substantial pollutant concentrations during project construction as shown in Table 3.4.3-5. MM AQ-1 requires that all off-road diesel-powered construction equipment meets CARB Tier 4 emissions standards or equivalent, thereby reducing health risk at the closest residences to a less than significant level.

Table 3.4.3-4
Health Risk from Project Construction
Receptor Type Cancer Risk Chronic HI Acute Simple HI
1 Residence 4.08E‐05 8.88E‐02 0.00E+00
2 Residence 4.28E‐05 9.33E‐02 0.00E+00
3 Residence 4.32E‐05 9.42E‐02 0.00E+00
4 Residence 4.02E‐05 8.76E‐02 0.00E+00
5 Residence 3.47E‐05 7.57E‐02 0.00E+00
6 Residence 2.91E‐05 6.34E‐02 0.00E+00
7 Residence 1.57E‐05 3.42E‐02 0.00E+00
Source: (VRPA Technologies, Inc. 2025a)
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Table 3.4.3-5
Health Risk from Project Construction with Mitigation
Receptor Type Cancer Risk Chronic HI Acute Simple HI
1 Residence 9.71E‐06 2.12E‐02 0.00E+00
2 Residence 9.88E‐06 2.15E‐02 0.00E+00
3 Residence 9.58E‐06 2.09E‐02 0.00E+00
4 Residence 8.54E‐06 1.86E‐02 0.00E+00
5 Residence 7.34E‐06 1.60E‐02 0.00E+00
6 Residence 6.37E‐06 1.39E‐02 0.00E+00
7 Residence 4.26E‐06 9.28E‐03 0.00E+00
Source: (VRPA Technologies, Inc. 2025a)
Long‐Term emissions from the project are generated primarily by mobile source (vehicle) emissions from the project site and area sources such as lawn maintenance equipment.

Emissions from long‐term operations generally represent a project’s most substantial air quality impact. The project’s operational impacts by pollutant as summarized in Table 3.4.3- 3 indicate that operational emissions from the project will not exceed the SJVAPCD emissions threshold for any emissions.

Therefore, the potential risk to the population attributable to emissions of TACs during construction would be less than significant with implementation of MM AQ-1.

MITIGATION MEASURE(S)
MM AQ-1: The project contractor or project representatives shall ensure that all off‐road diesel‐powered construction equipment meets the CARB Tier 4 emissions standards or equivalent.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.3d – Would the Project result in emissions (such as those leading to odors) adversely affecting a substantial number of people?
The SJVAPCD’s GAMAQI states “An analysis of potential odor impacts should be conducted for both of the following two situations:

1. Generators – projects that would potentially generate odorous emissions proposed to locate near existing sensitive receptors or other land uses where people may congregate, and

2. Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people locating near existing odor sources.” Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-26
The GAMAQI also states, “The District has identified some common types of facilities that have been known to produce odors in the San Joaquin Valley Air Basin. These are presented in Table 6 (Screening Levels for Potential Odor Sources), along with a reasonable distance from the source within which the degree of odors could possibly be significant. [Table 6] can be used as a screening tool to qualitatively assess a project’s potential to adversely affect area receptors” (VRPA Technologies, Inc. 2025a)Because the project is a residential development and the anticipated activities for the project site are not listed in Table 6 of the GAMAQI as a source that would create objectionable odors, the project is not expected to be a source of objectionable odors.

Based on the provisions of the SJVAPCD’s GAMAQI, the proposed project would not exceed any screening trigger levels to be considered a source of objectionable odors or odorous compounds (VRPA Technologies, Inc. 2025a) Furthermore, there does not appear to be any significant source of objectionable odors in close proximity that may adversely impact the project site when it is in operation. Additionally, the project emissions estimates indicate that it would not be expected to adversely impact surrounding receptors. As such, the proposed project would not be a source of any odorous compounds nor would it likely be impacted by any odorous source. Therefore, impacts of the project related to emissions and odors are less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-27

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact
No
Impact

3.4.4 - 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 Wildlife or
U.S. Fish and Wildlife Service?
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 Wildlife or U.S. Fish
and Wildlife Service?
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?
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?
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
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?

Discussion
The analyses in this section are based on a Biological Evaluation (Live Oak Associates, Inc. 2024)attached as Appendix B.
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Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-28
Impact Analysis
Impact #3.4.4a – Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or specialstatus species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? The Biological Evaluation (BE) describes the biological resources of the project site and evaluated the potential impacts to biological resources associated with project implementation. A reconnaissance-level field survey of the project site was conducted on August 19, 2024. The survey consisted of walking and driving through the project site while identifying its principal land uses, biotic habitats, flora, and fauna, and assessing its potential to support special status species and other sensitive resources. Table 3.4.4-1 below provides a list of special status species that could occur in the project vicinity.

Table 3.4.4-1
Lists of Special Status Species That Could Occur in the Project Vicinity Species Status Habitat/Range Occurrence on the
Project site
Plants
Succulent Owl’s‐Clover
(Castilleja campestris ssp.
succulenta)
FT, CE
CRPR 1B.2
Occurs in vernal pools of
the Central Valley that are
often acidic; blooms April‐
May; elevation 160‐2460 ft.

Absent. Suitable habitat in
the form of vernal pools is
absent from the project
site.

Delta Button Celery
(Eryngium racemosum)
CE, CRPR 1B.1 Found in seasonally flooded
clay depressions in
floodplains at elevations
between 10‐ 100 feet.

Blooms June – October.

Absent. Decades of
agricultural disturbance
have eliminated any habitat
that may have once been
present on site or in the
immediate vicinity. In
addition, the project site is
outside of the species
elevational range.

Boggs Lake Hedge‐Hyssop
(Gratiola heterosepala)
CE
CRPR 1B.2
Inhabits the Central Valley,
inner north coast range,
and Sierra Nevada foothills.

The largest concentration is
located within the Modoc
Plateau. Restricted to clay
soils in or near shallow
water such as lake edges
and vernal pools. Elevation
below 5250 feet. Blooms
April‐ August.

Absent. Suitable habitat in
the form of vernal pools
and/or lake edges is absent
from the project site.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-29
Colusa Grass (Neostapfia
colusana)
FT, CE, CRPR 1B.1 Typically found in alkaline
basins of Sacramento and
San Joaquin Valleys and in
acidic soils along the
eastern San Joaquin Valley
and the Sierra Nevada
foothills.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

San Joaquin Valley Orcutt
Grass (Orcuttia inaequalis)
FT, CE
CRPR 1B.1
Occurs in vernal pools of
the Central Valley; requires
deep pools with prolonged
periods of inundation;
blooms April-September;
elevation 100-2,480 ft.

Absent. Vernal pool habitat
is absent from the project
site.

Hairy Orcutt Grass
(Orcuttia pilosa)
FE, CE Vernal pools of California’s
Central Valley. Requires
deep pools with prolonged
periods of inundation;
blooms May to September.

Absent. Vernal pool habitat
is absent from the project
site.

Hartweg’s Golden
Sunburst (Pseudobahia
bahiifolia)
FE, CE
CRPR 1B.1
Found in heavy clay soils in
open woodlands and nonnative grasslands. The
current known distribution
of this species occurs along
the eastern side of the San
Joaquin Valley and lower
central Sierra Nevada
foothills. Elevation between
330- 650 feet. Blooms
March- April.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity. In
addition, the project site is
outside of the species
elevational range.

Merced Phacelia (Phacelia
ciliate var. opaca)
CRPR 3.2 Restricted to heavy clay
soils on the San Joaquin
Valley floor and adjacent
hills at elevations below
330 feet.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

Keck’s Checkerbloom
(Sidalcea keckii)
FE, CRPR 1B.1 Occurs in cismontane
woodland and valley and
foothill grassland habitat
with serpentine and/or clay
soils between 525 and
2,230 ft. in elevation.

Blooms April-May.

Absent. Suitable habitat is
absent from the project site
and the site is outside the
species elevational range.

Greene’s Tuctoria (Tuctoria
greenei)
FE, CR, CRPR 1B.1 Occurs in vernal pools of
California’s Central Valley
from Shasta Co. on the
north to Tulare Co. on the
south; blooms May to
September.

Absent. Suitable habitat in
the form of vernal pools is
absent from the project
site.

Henderson’s Bent Grass
(Agrostis hendersonii)
CRPR 3.2 Found in vernal pools at
elevations under 984 feet in
north and central San
Absent. Suitable habitat in
the form of vernal pools is
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-30
Joaquin Valley. Blooms
April- June.
absent from the project
site.

Heartscale (Atriplex
cordulata var. cordulata)
CRPR 1B.2 Occurs on saline or alkaline
soils in chenopod scrub,
meadows, seeps, and
grasslands; blooms AprilOctober; elevations below
1,230 ft.

Absent. Suitable soils and
habitat are absent from the
project site.

Lesser Saltscale (Atriplex
minuscula)
CRPR 1B.1 Occurs in cismontane
woodland and valley and
foothill grasslands of the
San Joaquin Valley;
alkaline/sandy soils;
blooms May-October;
elevation 50-660 ft.

Absent. Suitable soils and
habitat are absent from the
project site.

Vernal Pool Smallscale
(Atriplex persistens)
CRPR 1B.2 Occurs in alkaline vernal
pools; blooms July-Oct.;
elevations below 400 ft.

Absent. Suitable habitat in
the form of vernal pools is
absent from the project
site.

Subtle Orache (Atriplex
subtilis)
CRPR 1B.2 Occurs in valley and foothill
grasslands of the San
Joaquin Valley; blooms
August-October; elevation
130-330 ft.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

Watershield (Brasenia
schreberi)
CRPR 2B.3 An aquatic, perennial herb
with floating leaves that
grows in ponds, lakes, and
slow-moving streams.

Absent. The project site’s
irrigation ditches do not
have a sufficient inundation
regime for this species.

Hoover’s Calycadenia
(Calycadenia hooveri)
CRPR 1B.3 Found in rocky soils,
frequently of the Hornitos
series, in Calaveras,
Madera, Mariposa, and
Stanislaus Counties.

Absent. Suitable soils and
habitat are absent from the
project site.

Beaked Clarkia (Clarkia
rostrata)
CRPR 1B.3 This species occurs in the
woodlands of the Sierra
Nevada Forest near the
Merced River. Elevations up
to 1,640 feet. Blooms AprilMay.

Absent. Suitable habitat is
absent from the project
site.

Recurved Larkspur
(Delphinium recurvatum)
CRPR 1B.2 Chenopod scrub,
cismontane woodlands, and
alkaline soils of valley and
foothill grasslands. Blooms
March-May.

Absent. Suitable soils and
Dwarf Downingia
(Downingia pusilla)
CRPR 2B.2 Grows in vernal pools and
other seasonal wetlands.

Blooms March – May.

Unlikely. Suitable habitat in
the form of vernal pools
and other seasonal
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-31
wetlands is absent from the
project site.

Spiny‐Sepaled Button
Celery (Eryngium
spinosepalum)
CRPR 1B.2 Found in vernal pools,
swales and valley and
foothill grasslands at the
eastern edge of the San
Joaquin Valley and in the
Tulare Basin; elevation
between 330 and 840 ft.

Blooms April to May
Absent. Suitable habitat in
the form of vernal pools
and swales is absent from
the project site.

Furthermore, the project
site is outside of this
species’ elevational range.

Forked Hare‐Leaf
(Lagophylla dichotoma)
CRPR 1B.1 Occurs in openings in
woodlands or grasslands at
elevations between 164
feet to 1312 feet. Flowers
April and May.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

Alkali‐Sink Goldfields
(Lasthenia chrysantha)
CRPR 1B.1 Occurs in valley grassland,
alkali sink, wetland riparian
areas less than 328 ft. in
elevation in the southern
Sacramento Valley and San
Joaquin Valley. Blooms
February – June.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

Pincushion Navarretia
(Navarretia myersii spp.
myersii)
CRPR 1B.1 Occurs in vernal pools in
the Central Valley,
particularly on the eastern
edge. Elevations 66 to 295
feet. Blooms in May.

Absent. Suitable habitat in
the form of vernal pools is
absent from the project
site.

Shining Navarretia
(Navarretia nigelliformis
ssp. radians)
CRPR1B.2 Occurs in Valley grassland,
foothill woodland,
freshwater-wetlands, and
wetland-riparian between
525 and 1770 ft. in
elevation. Blooms AprilJuly.

Absent. Suitable habitat is
absent, and the project site
is outside of this species’
elevational range.

California Alkali‐Grass
(Puccinellia simplex)
CRPR 1B.2 Occurs in saline flats and
mineral springs less than
900 m. in elevation in the
Central Valley, San
Francisco Bay area and
western Mojave Desert.

Absent. Decades of
agricultural disturbance
has eliminated any habitat
that may have once been
present on site or in the
immediate vicinity.

Sanford’s Arrowhead
(Sagittaria sanfordii)
CRPR 1B.2 Occurs in freshwater
emergent marsh habitats in
drainage ditches and canals
of California’s Central
Valley. Blooms May to
October.

Unlikely. The project site’s
irrigation ditches do not
appear to have a sufficient
inundation regime for this
species.

Wildlife
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-32
Crotch’s Bumblebee
(Bombus crotchii)
CCE Once common in the
Central Valley, this species
is now absent from most of
it, particularly in the central
portion of its historic range.

Where present, it is
associated with open
grassland and scrub
habitats, where it relies on
food plants of the Asclepias,
Chaenactis, Lupinus,
Medicago, Phacelia, and
Salvia genera (Williams et
al. 2014).

Unlikely. While the project
site contains some
potential foraging
resources for the Crotch
bumblebee, it is situated in
a matrix of intensive
agricultural, residential,
and commercial uses
incompatible with this
species’ ecology. Moreover,
the Crotch’s bumble bee is
thought to be nearly
extirpated from the valley
floor. For these reasons, it
is unlikely to occur on site.

Conservancy Fairy Shrimp
(Branchinecta
conservatio)
FE Occurs in large, turbid
vernal pools in grasslands
of the northern two-thirds
of the Central Valley.

Absent. Suitable habitat in
the form of vernal pools is
absent from the site and
immediately surrounding
lands.

Vernal Pool Fairy Shrimp
(Branchinecta lynchi)
FT Primarily found in vernal
pools of California’s Central
Valley.

Absent. Suitable habitat in
the form of vernal pools is
absent from the site and
immediately surrounding
lands.

Vernal Pool Tadpole
Shrimp (Lepidurus
packardi)
FE Primarily found in vernal
pools but may use other
seasonal wetlands in mesic
valley and foothill
grasslands.

Absent. Suitable habitat in
the form of vernal pools is
absent from the site and
immediately surrounding
lands.

Steelhead ‐ Central Valley
DPS (Oncorhynchus
mykiss irideus pop. 11)
FT, CSC This slender-bodied fish is
endemic to the San
Francisco Bay and
Sacramento-San Joaquin
Delta upstream through
Contra Costa, Sacramento,
San Joaquin, Solano, and
Yolo Counties.

Absent. Suitable habitat in
the form of streams is
absent from the project
site.

California Tiger
Salamander (Ambystoma
californiense pop. 1)
FT, CT Found primarily in annual
grasslands; requires vernal
pools for breeding and
rodent burrows for
aestivation. Although most
CTS aestivate within 0.4
mile of their breeding pond,
outliers may aestivate up to

1.3 miles away (Orloff
2011).

Absent. The project site and
surrounding areas have
experienced decades of
agricultural disturbance
and urban development,
eliminating any potential
habitat that may have once
existed on and within the
vicinity of the project site.

The closest CNDDB
occurrence is from 1999
and lies approximately 4.5
miles southwest of the
project site across
California State Route 99
(CDFW 2024).

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-33
Western Spadefoot (Spea
hammondii)
FPT, CSC Occurs in grasslands of San
Joaquin Valley, where it
breeds in vernal pools or
other seasonal wetlands
and aestivates in
underground refugia such
as rodent burrows.

Baumberger et al. (2019)
recorded a mean maximum
distance of around 230 feet
between breeding and
aestivation sites, with an
overall maximum of 890
feet.

Absent. Suitable breeding
habitat is absent from the
site and surrounding lands
and there are no CNDDB
occurrences within the
vicinity of the project site
(CDFW 2024).

Northwestern Pond Turtle
(Actinemys marmorata)
FPT, CSC Found in ponds, marshes,
rivers, streams, and
irrigation ditches with
aquatic vegetation.

Requires partially
submerged rocks or logs or
sandy banks for basking
sites. Nesting takes place in
open areas, on a variety of
soil types, and up to ¼ mile
away from water.

Unlikely. The project site’s
irrigation ditches do not
have a sufficient inundation
regime for this species. An
irrigation canal lies
approximately 85 ft south
of the southern border of
the project site. Although
historical imagery shows
the irrigation canal
primarily inundated with
water throughout the year,
northwestern pond turtles
are unlikely to be found
here due to the steep edges
of the canal, lack of basking
habitat, and proximity to a
busy street and residential
development. The closest
known CNDDB occurrence
is an undated occurrence 5
miles south of the project
across California State
Route 99 (CDFW 2024).

Blunt‐Nosed Leopard
Lizard (Gambelia sila)
FE, CE, CFP Occurs in semiarid
grasslands, alkali flats, and
washes. Avoids densely
vegetated areas. Inhabits
the San Joaquin Valley and
adjacent valleys and
foothills north to southern
Merced County.

Absent. Historical
agricultural disturbance
and urban development in
and around the site has
created unsuitable habitat
for this species and there
are no CNDDB occurrences
within the vicinity of the
project site (CDFW 2024).

Giant Garter Snake
(Thamnophis gigas)
FT, CT, CFP Occurs in marshes, sloughs,
drainage canals, irrigation
ditches, rice fields, and
adjacent uplands. Prefers
locations with emergent
vegetation for cover and
open areas for basking.

Inhabit small mammal
burrows and other upland
Absent. The giant garter
snake was historically
known from the area; there
is a CNDDB occurrence
from 1908 that was
mapped to the general
vicinity of the City of
Merced (CDFW 2024).

Since that time, the species
has undergone a dramatic
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-34
soil crevices during the
winter during hibernation.
reduction in its range. The
closest known extant
population is in the North
and South Grasslands
region, some 20 miles west
of the project site (USFWS
2012).

Tricolored Blackbird
(Agelaius tricolor)
CT Nests colonially near fresh
water in dense cattails or
tules, in thickets of willows
or shrubs, and increasingly
in grain fields. Forages in
grassland and cropland
areas.

Possible. Tricolored
blackbirds are occasionally
sighted in the general
project vicinity, and may
occasionally pass through
or forage on site, though
this species is not expected
to nest on site or in the
near vicinity. Analysis of
aerial imagery indicates the
site’s agricultural field is
typically planted to row
vegetables, and not to crops
suitable for tricolored
blackbird nesting such as
wheat, soy, or triticale.

Swainson’s Hawk (Buteo
swainsoni)
CT This breeding migrant to
California nests in mature
trees in riparian areas and
oak savannah, and
occasionally in lone trees at
the margins of agricultural
fields. Requires adjacent
suitable foraging areas such
as grasslands or alfalfa
fields supporting rodent
populations.

Likely. There are over 50
sightings of Swainson’s
hawks within the vicinity of
the project site and 30
CNDDB documented
nesting occurrences within
10 miles of the project site
(CDFW 2024, eBird 2024).

The project site offers
suitable foraging habitat for
this species in the form of
an agricultural field. The
project site does not offer
any nesting habitat, though
mature trees within the
vicinity of the project site
represent potential nesting
habitat. The high number of
sightings and nesting
occurrences within the area
make it likely for this
species to occur on site.

Bald Eagle (Haliaeetus
leucocephalus)
CE, CFP Nests and winters on ocean
shores, lake margins and
rivers. Uses old-growth
snags. Mostly forages over
water and along shores.

Unlikely. There are several
eBird sightings of bald
eagles within 10 miles of
the project site and one
unknown dated CNDDB
nesting occurrence
approximately 6 miles
north of the project site at
Lake Yosemite (CDFW
2024, eBird 2024). Bald
eagles are not expected to
forage or nest on or near
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-35
the site due to lack of
suitable habitat. They may
occasionally fly over the
site.

San Joaquin Kit Fox (SJKF)
(Vulpes macrotis mutica)
FE, CT Frequents desert alkali
scrub and annual
grasslands. Utilizes
enlarged ground squirrel
burrows as denning
habitat. May become
adapted to urban
environments, as has
occurred in the cities of
Bakersfield, Taft, and
Coalinga.

Unlikely. The project site is
situated in the outskirts of
Merced, in an area
characterized by
residential, commercial,
and intensive agricultural
uses generally not
compatible with kit fox
ecology. No recent records
of this species are known
from the project vicinity;
the four CNDDB
occurrences within 10
miles of the site are all from
2001 or earlier, and there
are no iNaturalist records
within 20 miles. Finally, the
site is located over 40 miles
away from the nearest SJKF
core population in the
Ciervo-Panoche region. For
these reasons, the SJKF is
considered unlikely to
occur on site.

Hardhead (Mylopharadon
conocephalus)
CSC Occurs in clear deep
streams with a slow but
present flow, in a low to
mid-elevation environment.

May also inhabit lakes or
reservoirs. Spawns in pools,
runs, or rifles with a gravel
and rocky substrate.

Absent. Suitable habitat in
the form of streams is
absent from the project site
Western burrowing owl
(Athene cunicularia)
CCE Frequents open, dry annual
or perennial grasslands,
deserts, and scrublands
characterized by low
growing vegetation.

Dependent upon burrowing
mammals, most notably the
California ground squirrel,
for nest burrows.

Possible. Burrowing owls
are unlikely to nest or roost
on site due to intensive
agricultural practices in the
oat field and tall, dense
vegetative cover in the
ruderal field. Burrowing
owls may occasionally pass
through or forage on site, if
present in the vicinity. The
closest CNDDB occurrences
of this species are
approximately 4.25 miles
west of the project site at
the Merced Municipal
Airport (CDFW 2024).

Mountain Plover
(Charadrius montanus)
CSC This species is a winter
resident of California’s
Central and Imperial
Valleys, where it forages in
Possible. The site’s
agricultural field could
provide foraging habitat for
wintering mountain
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Merced Gateway Project May 2025
City of Merced Page 3-36
short grasslands and
freshly plowed fields.

Breeds in the western Great
Plains and Rocky Mountain
states.
plovers. This species does
not breed in the region.

Northern Harrier (Circus
cyaneus)
CSC Nests on the ground and
forages in meadows,
grasslands, open
rangelands, freshwater
emergent wetlands;
uncommon in wooded
habitats.

Possible. This species has
been spotted in the general
vicinity of the project site
but is not a common visitor
and there are no CNDDB
nesting records within 10
miles of the project site
(CDFW 2024, eBird 2024).

Nevertheless, the project
site and surrounding lands
provide some suitable
foraging and nesting
habitat for this species.

Northern harriers will
occasionally nest in dry,
open fields if preferable
habitat is unavailable, and
the site’s agricultural field
and ruderal field could
conceivably be used for this
purpose.

Pallid Bat
(Antrozous pallidus)
CSC Roosts in rocky outcrops,
cliffs, and crevices with
access to open habitats for
foraging. May also roost in
caves, mines, hollow trees
and buildings.

Possible. Pallid bats could
forage over the site, but
roosting habitat is absent.

Western Mastiff Bat
(Eumops perotis ssp.
californicus)
CSC Frequents open, semi-arid
to arid habitats, including
conifer, and deciduous
woodlands, coastal scrub,
grasslands, palm oasis,
chaparral and urban.

Roosts in cliff faces, high
buildings, and tunnels.

Possible. The western
mastiff bat could forage
over the site, but roosting
habitat is absent.

Western Red Bat
(Lasiurus blossevillii)
CSC This mostly solitary bat
roosts primarily in trees, 2-
40 feet above ground, from
sea level up through mixed
conifer forests. Prefers
habitat edges and mosaics
with trees that are
protected from above and
open below with open
areas for foraging.

Possible. The western red
bat could forage over the
site, but roosting habitat is
absent.

American Badger
(Taxidea taxus)
CSC Found in drier open stages
of most shrub, forest, and
herbaceous habitats with
friable soils. Utilize
subterranean burrows,
Unlikely. The project site is
located in the outskirts of
Merced, in an area
characterized by
residential, commercial,
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usually self-dug, for rest
and reproduction.
and intensive agricultural
uses generally not
compatible with badger
ecology. The site itself is
highly disturbed and
unlikely to be occupied or
utilized by American
badgers.

Status Codes
FE Federally Endangered
FC Federal Candidate
FT Federally Threatened
CT California Threatened
CE California Endangered
CCE California Candidate
Endangered
CFP California Fully
Protected
CSC California Species of
Special Concern
CR California Rare
CRPR Codes
1A Plants Presumed
Extinct in California
2 Plants Rare, Threatened,
or Endangered in
1B Plants Rare,
Threatened, or Endangered
in California, but more
common elsewhere
California and elsewhere
Source: (Live Oak Associates, Inc. 2024)
Special-Status Species

SPECIAL-STATUS PLANT SPECIES
Two biotic habitats / land uses were identified within the project site: agricultural and ruderal field. the majority of the project site consisted of a harvested oat field bisected into north and south sections by Campus Parkway, with an irrigation ditch running along the eastern margin of the oat field south of Campus Parkway.

Both the oat field and irrigation ditch supported a variety of weedy and native forbs. The margins of the field hosted the greatest diversity of plant life, though the fields center also contained an assortment of plant species as well. Oat (Avena sativa), milk thistle (Silybum marianum), Russian thistle (Salsola tragus), and jimsonweed (Datura wrightii) were most common along the field margins and irrigation ditch, while oat, narrowleaf milkweed (Asclepias fascicularis), panicle willowherb (Epilobium brachycarpum), and prickly lettuce (Latuca serriola) were most common throughout the center of the field.

The northern and northeastern edges of the project site can be categorized as ruderal field.

At the time of the survey, the northernmost portion of ruderal field was densely covered in vegetation including milk thistle, oat, prickly lettuce, Russian thistle, and flax-leaved horseweed (Erigeron bonariensis). A young, shrubby California black walnut tree (Juglans hindsii) was found in this portion of the ruderal field as well. This portion of the ruderal field was separated from the oat field by an irrigation ditch on the north side of the oat field, which was dry at the time of the survey and does not appear to be inundated in any recent aerial images. Vegetative cover in the ditch was indistinguishable from the surrounding ruderal field and at the time of the survey was dominated by oat and Russian thistle. The northeast portion of the ruderal field was less densely vegetated but contained many similar species to the northernmost section including oat, prickly lettuce, Russian thistle, and flax-leaved horseweed.

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Twenty-seven special status plant species have been documented in the general vicinity of the project site (see Table 3.4.4-1). All 27 species are considered absent from the project site due to an absence of suitable habitat. The project is not expected to adversely affect these species, either directly or indirectly, and impacts are considered less than significant under CEQA.

SENSITIVE WILDLIFE SPECIES
At the time of the field survey, the majority of the project site consisted of a harvested oat field bisected into north and south sections by Campus Parkway, with an irrigation ditch running along the eastern margin of the oat field south of Campus Parkway. The project site’s agricultural land provides some habitat for common wildlife species. Common amphibians such as the western toad (Bufo boreas) and Sierran treefrog (Pseudacris sierra) may breed in nearby ditches or basins and subsequently disperse across the oat field. Aerial imagery indicates that the on-site ditches are infrequently inundated and may not, themselves, support amphibian breeding. Reptiles such as side-blotched lizards (Uta stansburiana), Pacific gopher snakes (Pituophis catenifer catenifer), and California king snakes (Lampropeltis californiae) could occur on or pass through the site’s oat field from time to time. Common avian species are expected to utilize the oat field for foraging including American crow (Corvus brachyrhynchos), western meadowlark (Sturnella neglecta), western kingbird (Tyrannus verticalis), and northern mockingbird (Mimus polyglottos).

Raptors such as red-tailed hawks (Buteo jamaicensis) and American kestrels (Falco sparverius) are likely to forage over the oat field as well. Ground nesting birds such as mourning doves (Zenaida macroura) could nest in the field. Small mammal use of the site’s agricultural land may include deer mice (Peromyscus maniculatus), California voles (Microtus californicus), Botta’s pocket gophers (Thomomys bottae), and California ground squirrels (Otospermophilus beecheyi). Several Botta’s pocket gopher and numerous California ground squirrel burrows were observed in the oat field, specifically within the portion south of Campus Parkway.

Mid-tier predatory mammal species that may forage or pass through the site’s agricultural land include raccoon (Procyon lotor), western striped skunk (Mephitis mephitis), Virginia opossum (Didelphis virginiana), red fox (Vulpes vulpes) and coyote (Canis latrans). Various bat species may forage over the site’s agricultural land for insects. Due to the proximity of residences, domestic dogs (Canis familiaris) and cats (Felis catus) may also occur here from time to time.

The northern and northeastern edges of the project site can be categorized as ruderal field.

Wildlife use of the site’s ruderal field would be similar to that described for the agricultural land.

Twenty-two special status wildlife species have been documented in the general vicinity of the project site or are known to occur regionally (Table 3.4.4-1). Of these, 14 are considered absent from or unlikely to occur on the site due to the absence of suitable habitat, the site’s developed setting and other landscape factors, and/or the site’s being situated outside of the species’ known distribution. These comprise of Crotch’s bumblebee (Bombus crotchii), Initial Study

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conservancy fairy shrimp (Branchinecta conservatio), vernal pool fairy shrimp (Branchinecta lynchi), vernal pool tadpole shrimp (Lepidurus packardi), steelhead - Central Valley DPS (Oncorhynchus mykiss irideus pop. 11), California tiger salamander (Ambystoma californiense pop. 1), western spadefoot (Spea hammondii), northwestern pond turtle (Actinemys marmorata), blunt-nosed leopard lizard (Gambelia sila), giant garter snake (Thamnophis gigas), San Joaquin kit fox (Vulpes macrotis muitca), hardhead (Mylopharadon conocephalus), bald eagle (Haliaeetus leucocephalus), and American badger (Taxidea taxus). Because these species have no appreciable potential to occur on site, they are not expected to be affected by the project, directly or indirectly.

Six special status wildlife species potentially occur on site, but the three bat species are not expected to use the site for sensitive activities such as breeding, nesting, or communal roosting due to lack of suitable roosting or nesting habitat. It is also likely that to breed, nest, or communally roost close enough to the site that they would be vulnerable to constructionrelated disturbance during these activities.

Individuals of these species are unlikely to be injured or killed by construction activities because they are highly mobile while foraging or passing through and would be expected to simply avoid active work areas. The project would not adversely affect any of these species through loss of foraging habitat. The site does not offer unique or high-quality habitat for any of these species, nor is it likely to represent an important part of any individual foraging range, given its disturbed nature and developed setting. Similar and higher quality habitats are abundant in the project vicinity and elsewhere in the region. For these reasons, impacts to the mountain plover, pallid bad, western mastiff bat, and western red bat are considered less than significant.

The project site has the potential to be used for nesting and foraging by several avian species including tricolored blackbird, northern harrier and western burrowing owl. Other birds and raptors, among them the state-threatened Swainson’s hawk, may nest on adjacent lands and forage on site. Nearly all native birds are protected by the Migratory Bird Treaty Act (MBTA) and related state laws. Foraging birds and raptors are generally not susceptible to construction-related injury and mortality because they are highly mobile during this activity and can simply avoid active work areas. However, during the breeding season, adult birds have reduced mobility as they attempt to guard their nests, incubate eggs, and care for young, and nestlings may have no mobility at all. Nests may be destroyed by construction equipment, and the birds inside injured or killed. Noise and other forms of disturbance from nearby construction activities may cause birds to abandon their nests. Construction-related mortality of nesting birds and construction-related disturbance leading to nest abandonment are potentially significant impacts of the project. Moreover, such incidents would violate the MBTA and California Fish and Game Code.

The project site is not expected to significantly impact the northern harrier or Swainson’s hawk through loss of habitat as many more acres of similar or higher quality habitat exist in the vicinity of the project site. Loss of habitat for these species is not considered a significant impact of the project.

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CONCLUSION
It is very unlikely that any special-status plant species occur in the project area due to historic disturbance and absence of suitable habitat.

Several special status wildlife species may potentially occur as transient foragers on site, or they may travel through. These species are the tricolored blackbird, western burrowing owl, mountain plover, harrier, San Joaquin kit fox, American badger and Swainson’s hawk.

Impacts to these and other listed species that may occur on site will be reduced to less than significant levels with the implementation of MM BIO-1 through MM BIO-5, as outlined below, would protect, avoid, and minimize impacts to these special-status wildlife species.

When implemented, these mitigation measures would reduce impacts on these species to levels that are less than significant.

MITIGATION MEASURE(S)
BIO-1: a) A pre-construction clearance survey of the project site shall be conducted for special-status wildlife species and nesting migratory birds and raptors. The survey shall occur no less than 14-30 days prior to the start of construction activities. If construction is delayed beyond 30 days from the time of the survey, then another survey shall be conducted.

No work shall occur within these buffers unless the biologist approves and monitors the activity. A copy of the preconstruction survey report shall be submitted to the Lead Agency as evidence of compliance.

Burrowing Owl (active burrows)
Initial Study

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City of Merced Page 3-41
Location Time of Year Level of Disturbance
Low Med High
Nesting Sites April 1-Aug 15 200 m 500 m 500 m
Nesting Sites Aug 16-Oct 15 200 m 200 m 500 m
Nesting Sites Oct 16-Mar 31 50 m 100 m 500 m

American badger/SJKF
Potential or Atypical den – 50 feet
Known den – 100 feet
Natal Den –Contact CDFW for consultation
BIO-2: If construction is planned during the nesting season for migratory birds and raptors (February 15 to August 31) and nesting birds are identified during the preconstruction survey, active Swainson’s hawk nest shall be avoided by 0.5 miles, other raptor nests shall be avoided by 500 feet and all other migratory bird nests shall be avoided by 250 feet.

BIO-4: Prior to the initiation of construction activities, all personnel shall attend a Worker Environmental Awareness Training program developed by a qualified biologist. The program shall include information on the life histories of special-status species with the potential to occur on the project, their legal status, the course of action shall these species be encountered on-site, and avoidance and minimization measures to protect these species.

BIO-5: The following measures shall be implemented during all phases of the project to reduce the potential for impact from the project.

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a. All food-related trash items such as wrappers, cans, bottles, and food scraps shall be disposed of in securely closed containers and removed at least once a week from the construction or project site.
b. Construction-related vehicle traffic shall be restricted to established roads and predetermined ingress and egress corridors, staging, and parking areas. Vehicle speeds shall not exceed 20 miles per hour within the project site. A 10-mile-per-hour speed limit shall be implemented during night-time construction activities. c. To prevent inadvertent entrapment of kit fox or other animals during construction, the contractor shall cover all excavated, steep-walled holes or trenches more than two feet deep at the close of each workday with plywood or similar materials. If holes or trenches cannot be covered, one or more escape ramps constructed of earthen fill or wooden planks shall be installed in the trench. Before such holes or trenches are filled, the contractor shall thoroughly inspect them for entrapped animals. All construction-related pipes, culverts, or similar structures with a diameter of four inches or greater that are stored on the project site shall be thoroughly inspected for wildlife before the pipe is subsequently buried, capped, or otherwise used or moved in any way. If at any time an entrapped or injured kit fox is discovered, work in the immediate area shall be temporarily halted, and USFWS and CDFW shall be consulted for guidance.
d. Kit foxes are attracted to den-like structures such as pipes and may enter stored pipes and become trapped or injured. All construction pipes, culverts, or similar structures with a diameter of four inches or greater that are stored at a construction site for one or more overnight periods shall be thoroughly inspected for kit foxes before the pipe is subsequently buried, capped, or otherwise used or moved in any way. If a kit fox is discovered inside a pipe, that section of pipe shall not be moved until the USFWS and CDFW have been consulted. If necessary, and under the direct supervision of the biologist, the pipe may be moved only once to remove it from the path of construction activity until the fox has escaped.
e. No pets, such as dogs or cats, shall be permitted on the project sites to prevent harassment, mortality of kit foxes, or destruction of dens. f. No fueling of construction equipment will occur within 100 feet of a drainage, water crossing, or wetlands. If a spill or pipe break occurs within 100 feet of any water feature, adherence to the CREH Spill Prevention, Control, and Countermeasure (SPCC) Plan will be followed.
g. Use of anticoagulant rodenticides and herbicides in project sites shall be restricted.

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City of Merced Page 3-43
control must be conducted, zinc phosphide shall be used because of the proven lower risk to kit foxes.
h. A representative shall be appointed by the project proponent, who will be the contact source for any employee or contractor who might inadvertently kill or injure a kit fox or who finds a dead, injured, or entrapped kit fox. The representative shall be identified during the employee education program, and their name and telephone number shall be provided to the USFWS.
i. The Sacramento Fish and Wildlife Office of USFWS and CDFW shall be notified in writing within three working days of the accidental death or injury to an SJKF during project-related activities. Notification must include the date, time, and location of the incident or of the finding of a dead or injured animal and any other pertinent information. The USFWS contact is the Chief of the Division of Endangered Species at the addresses and telephone numbers below. The CDFW contact can be reached at (559) 243-4014 and [email protected]. The BLM will also be informed about those wells on the Split Estate property.
j. All sightings of the SJKF shall be reported to the CNDDB. A copy of the reporting form and a topographic map clearly marked with the location of where the kit fox was observed shall also be provided to the USFWS at the address below. k. Any project-related information required by the USFWS or questions concerning the above conditions, or their implementation may be directed in writing to the U.S. Fish and Wildlife Service at Endangered Species Division, 2800 Cottage Way, Suite W 2605, Sacramento, California 95825-1846, phone: (916) 414-6620 or (916) 414- 6600.
l. A copy of the pre-construction survey report shall be submitted to the Lead Agency as evidence of compliance.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.4b – Would the Project 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 Wildlife or U.S. Fish and Wildlife Service?
As previously discussed, the project site is characterized as agricultural and ruderal fields and does not contain a sensitive natural community. The site is predominantly vacant and does not provide riparian habitat. The project is not located within a river or an area that encompasses a river or potential floodplain and does not contain nor is near any riparian habitat. There are no anticipated impacts to sensitive natural communities as a result of the Initial Study

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proposed project. The proposed project would not have any impacts to a riparian habitat or sensitive natural communities.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.4c – Would the Project 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? The United States Army Corps of Engineers (USACE) has regulatory authority over the Clean Water Act (CWA), as provided for by the EPA. The USACE has established specific criteria for the determination of wetlands based on the presence of wetland hydrology, hydric soils, and hydrophilic vegetation.

Wetlands, streams, reservoirs, sloughs, and ponds typically meet the criteria for federal jurisdiction by US Army Corps of Engineers (USACE) under Section 404 of the CWA, theState Water Resources Control Board (SWRCB) as regulatory authority under Section 401 PorterCologne Water Quality Control Act and/or under the jurisdiction of the California Department of Fish and Wildlife (CDFW) regulatory authority under Section 1602 of the California Fish and Game Code. There are two irrigation ditches that are depicted as blueline water features on USGS topographical maps (Figure 3.4.4-1). With the development of Campus Parkway and other land use changes in the vicinity, both ditches appear to have been modified from their historic blue-line course.

The irrigation ditch running north south (originally part of the Farmdale lateral) along the eastern area of the project site appears to connect to Miles Creek approximately ½ mile south of project boundaries. As a tributary to a known Water of the U.S., it may itself be considered a Water of the U.S. by the USACE if it carries “relatively permanent” flows. The lack of wetland vegetation observed during the field survey, combined with limited evidence of inundation, suggests that it might not meet this standard (Live Oak Associates, Inc. 2024).

The ditch running east to west in the northerly portion of the appears to either terminate and cut off by Campus Parkway and East Gerard Avenue or be undergrounded approximately 700 feet west of project boundaries and is no longer in use. Its vegetative community was indistinguishable from that of the ruderal field at the time of the survey, and there are no available aerial images in which it is obviously inundated. As such, it may be a remnant feature.

Initial Study

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City of Merced Page 3-45

Figure 3. 4. 4-1

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Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-46
Although no jurisdictional water features were identified on or near the project that would meet the criteria for either federal or State jurisdiction MM BIO-6 requires a formal notification of the project be submitted to the pertinent regulatory agencies prior to the issuance of grading permits. In the event drainage is jurisdictional, additional permitting with the appropriate regulatory agencies is also required prior to construction activities.

With the implementation of MM BIO-6, the impact of the project related to water features would be less than significant.

MITIGATION MEASURE(S)
BIO-6: Prior to the issuance of any grading or building permit, the Project proponent/developer shall submit a formal notification to the US Army Corps of Engineers (ACOE), Water Resources Control Board (SWRCB) and California Department of Fish and Wildlife (CDFW). If no comments or requests for additional permitting are received by the agencies, no further action is necessary. A copy of all correspondence shall be submitted to the lead agency.

If a regulatory agency comments or requests additional permitting, the following actions may be taken. A copy of all correspondence and subsequent permitting and/or reports shall be made available to the Lead Agency. The report shall include information as shown below as a plan if necessary and shall outline compliance with the following:

Merced Gateway Project May 2025
City of Merced Page 3-47
monitoring methods and performance criteria, extent of monitoring to be conducted, actions to be taken in the event that the mitigation is not successful, and reporting requirements. The Plan shall be approved by the appropriate regulating agencies and compensatory mitigation shall take place either on site or at an appropriate off-site location.

5. Any spillage of material shall be stopped if it can be done safely. The contaminated area shall be cleaned, and any contaminated materials properly disposed. For all spills, the project foreman or designated environmental representative shall be notified.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.4d – Would the Project 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? Wildlife migratory corridors are described as a narrow stretch of land that connects two open pieces of habitat that would otherwise be unconnected. These routes provide shelter and sufficient food supplies to support wildlife species during migration. Movement corridors generally consist of riparian, woodlands, or forested habitats that span contiguous acres of undisturbed habitat and are important elements of resident species’ home ranges.

The proposed project and surrounding area do not occur within a known terrestrial migration route, significant wildlife corridor, or linkage area as identified by the Essential Habitat Connectivity project (Live Oak Associates, Inc. 2024) The survey conducted for the project did not provide evidence of a wildlife nursery or important migratory habitat being present on the project site. Migratory birds and raptors could use habitat on and near the project for foraging and/or as stopover sites during migrations or movement between local areas.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-48
The project will not restrict, eliminate, or significantly alter a wildlife movement corridor, wildlife core area, or Essential Habitat Connectivity area, either during construction or after the project has been constructed. project construction will not substantially interfere with wildlife movements or reduce breeding opportunities.

The proposed project would not interfere 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. Therefore, there would be no impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.4e – Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? The project is subject to the policies and requirements of the General Plan, which includes a conservation and open space chapter and Municipal Codes that provide guidance on the protection of listed plant and wildlife species, wetlands, and other sensitive biological resources. The project will implement measures such as those listed above (MM BIO-1 through BIO-6) to remain compliant with the General Plan. Therefore, implementation of the proposed project would have no conflict related to any adopted local policies or ordinances protecting biological resources.

MITIGATION MEASURE(S)
Implementation of MM BIO-1 thorough MM BIO-6.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.4f – Would the Project conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan?
The project is not located within any Natural Community Conservation Plan or any other local, regional, or State Conservation Plan. With mitigation, the proposed project would not conflict with the provisions of any adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State Habitat Conservation Plan.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-49

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Initial Study

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City of Merced Page 3-50

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.5 - CULTURAL RESOURCES
Would the Project:
a. Cause a substantial adverse change in the
significance of a historical resource pursuant
to CEQA Guidelines Section 15064.5?
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to CEQA Guidelines Section 15064.5?
c. Disturb any human remains, including those
interred outside of formal cemeteries?

Discussion
The discussion below is based on the Cultural Resources Study and Evaluation completed for the project, attached as Appendix C (Applied EarthWorks, Inc. 2024).

Impact #3.4.5a – Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5? The Cultural Resources Study and Evaluation consisted of a records search at the Central California Information Center (IC) of the California Historical Resources Information System (CHRIS); desktop research to better understand the history of land use in the project area; a search of the Native American Heritage Commission’s (NAHC) Sacred Lands File, and nongovernmental outreach to local tribes and individuals; an intensive pedestrian survey of the entire 71.18-acre project area to identify archaeological and historical built environment cultural resources; and an evaluation of two historical built environment resources for listing in the CRHR.

The records search reported 7 cultural resource studies previously conducted within the project area and 14 previous studies within the 0.5-mile radius. The IC records search returned three previously recorded historic-era cultural resources within the project area— the Merced Irrigation District (P-24-001909), the Doane Lateral (P-24-001886), which is owned by the Merced Irrigation District, and a residential and agricultural property (P-24- 001930)—and nine previously recorded cultural resources within a 0.5-mile radius. A search of the NAHC’s Sacred Land File did not identify Native American cultural resources within or near the project area, and no specific information was gleaned from outreach with local tribal representatives.
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An archaeological pedestrian survey of the project area was conducted on August 28 and November 8, 2024, and a built environment pedestrian survey on August 31, 2024. The archaeologists did not discover any precontact or historic-era archaeological resources within the project area. One possibly historic-era straight razor was observed but not recorded due to lack of provenience. The architectural historians found that the previously recorded residential and agricultural property (P-24-001930) is no longer extant and identified two historic-era built environment resources within and adjacent to the project area—the Doane Lateral (P-24-001886) and an unnamed earthen ditch. Although, the Doane Lateral (P-24-001886) is adjacent to the eastern boundary of the project area, this resource was recorded and evaluated to facilitate potential future development. Two water conveyances resources were evaluated for CRHR eligibility and found both resources ineligible for listing because they do not possess significance under any CRHR evaluation criteria. Therefore, they do not qualify as historical resources, and no further action is recommended for the management of these cultural resources.

Although no historical resource was observed on the site, unknown historical resources may be discovered during ground-disturbing activities. In order to account for unanticipated discoveries and the potential to impact previously undocumented or unknown resources, the following mitigation measures are recommended. With the implementation of MM CUL1 through MM CUL-2, impacts under this criterion would be less than significant with mitigation. With the implementation of the mitigation measures, impacts would be less than significant.

MITIGATION MEASURE(S)
MM CUL-1: If historic-era cultural materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a qualified archaeologist can evaluate the find and make recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock, as well as historic resources such as glass, metal, wood, brick, or structural remnants. If the qualified archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation. These additional studies may include avoidance, testing, and evaluation or data recovery excavation. Implementation of the mitigation measure below would ensure that the proposed project would not cause a substantial adverse change in the significance of a historical resource.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.5b – Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5? See discussion of Impact #3.4.5a above.

Initial Study

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The construction of the project will include trenching to place new piping underground, and some minor grading may be necessary to construct the project. Although unlikely, there is a chance that trenching and grading activities could unearth previously unknown archaeological resources. Implementation of MM CUL-1 through MM CUL-2 would ensure that potential impacts associated with archaeology during the project-related activities phase would be less than significant. With the implementation of these mitigation measures, impacts would be less than significant.

MITIGATION MEASURE(S)
Implementation of MM CUL-1.

If the resources are determined to be unique prehistoric archaeological resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor and required to the developer and City. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the lead agency approves the measures to protect these resources.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.5c – Would the Project disturb any human remains, including those interred outside of formal cemeteries?
There are no known cemeteries or burials on or near the project. Although unlikely, subsurface construction activities, such as trenching and grading, associated with the proposed project could potentially disturb previously undiscovered human burial sites.

Accordingly, this is a potentially significant impact. Although considered unlikely, subsurface construction activities could cause a potentially significant impact to previously undiscovered human burial sites. The cultural resources and Sacred Lands File records searches did not indicate the presence of human remains, burials, or cemeteries within or in the vicinity of the project site. No human remains have been discovered at the project site, Initial Study

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and no burials or cemeteries are known to occur within the area of the site. However, construction would involve earth-disturbing activities, and it is still possible that human remains may be discovered, possibly in association with archaeological sites.

Implementation of mitigation measure MM CUL-2 would ensure that the proposed project would not directly or indirectly destroy previously unknown human remains. It is unlikely that the proposed project would disturb any known human remains, including those interred outside of formal cemeteries. With the implementation of the mitigation measures, impacts would be less than significant.

MITIGATION MEASURE(S)
Implementation of MM CUL-1 and MM CUL-2.

MM CUL-3: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code. The specific protocol, guidelines, and channels of communication outlined by the Native American Heritage Commission, in accordance with Section 7050.5 of the Health and Safety Code, Section 5097.98 of the Public Resources Code (Chapter 1492, Statutes of 1982, Senate Bill 297), and Senate Bill 447 (Chapter 44, Statutes of 1987), shall be followed. Section 7050.5(c) shall guide the potential Native American involvement, in the event of a discovery of human remains, at the direction of the county

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

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Discussion
The analysis in this section is based on an Air Quality and Greenhouse Gas Impact Assessment (VRPA Technologies, Inc. 2025a) attached as Appendix A. The Air Quality and Greenhouse Gas Impact Assessment considered build out of a larger number of residential lots than is currently proposed. Therefore, it can be assumed that the energy consumption estimates resulting from the project would be less than those estimated and discussed in this IS/MND.

Impact #3.4.6a – Would the Project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation?
Construction
Energy demand during the construction phase would result from the transportation of materials, construction equipment, and construction worker vehicle trips. Construction equipment can include tractors, loaded trucks, forklifts, generators, cranes, rollers, compactors, and an air compressor. The project would comply with the SJVAPCD requirements regarding the use of fuel-efficient vehicles and equipment to the extent feasible. The project will not use natural gas during the construction phase. Compliance with standard regional and local regulations would minimize fuel consumption during project construction. Specifically, project construction would comply with City of Merced General Plan Policy SD-3.2 and associated implementing actions 3.2.a through 3.2.e to encourage the use of energy conservation features, low-emission equipment, and alternative energy sources for all new residential and commercial development.

There are no unusual project characteristics that would cause construction equipment to be less energy efficient compared with other similar construction sites in other parts of the

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.6 - ENERGY
Would the Project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during Project construction
or operation?
b. Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?
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State. Thus, construction-related fuel consumption at the project would not result in inefficient, wasteful, or unnecessary energy use.

Operations
Electricity and gas services for the proposed project would be provided by Pacific Gas and Electric Company (PG&E). Electricity in Merced County in 2022 was 3,185 million kilowatts per hour (GHw) and natural gas consumption attributable to Merced County in 2022 was 131.2 million therms (MMBTU) (California Energy Commission 2022a, California Energy Commission 2022b).

Energy estimates provided in the Air Quality and Greenhouse Gas Impact Assessment are summarized in Table 3.4.6-1 below:

Table 3.4.6-1
Estimated Energy Use
Electricity (kWh/yr) Natural Gas (kBTU/yr)
Single-family Housing 46,807,100 14,110,000
General Office Building 438,022 640,186
Strip Mall 392,436 525,726
Project Total 47,637,558 15,275,912
Merced County Total 3,185,000,000 131,200,000
As shown in Table 3.4.6-1 above, the estimated natural gas use would be approximately 11 percent of the total natural gas use of Merced County. With regard to electricity use, the proposed project would result in approximately 1.5 percent of the Merced County total electricity use. The proposed project will be subject to energy conservation requirements in the California Energy Code (24 California Code of Regulations [CCR] Part 6, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (CALGreen) (24 CCR Part 11). Adherence to Title 24 requirements would ensure that the project would not result in wasteful or inefficient use of nonrenewable resources due to operation. The project would also be required to be compliant with City of Merced General Plan Policy SD-3.2 and associated implementing actions 3.2.a through 3.2.e to encourage the use of energy conservation features, lowemission equipment, and alternative energy sources for all new residential and commercial development.

The project will comply with current applicable building code requirements, development standards, and energy efficiency requirements. Equipment used at the facility will be designed to be energy efficient and will not result in unnecessary energy use. The project would result in incremental increases in energy consumption due to new development introduced in an otherwise underutilized area; however, these incremental increases would be subject to energy code and building code standards notes above in addition to complying Initial Study

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with General Plan policies for energy conservation and efficiency. The project would result in a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.6b – Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Energy-saving strategies will be implemented where feasible to reduce the project’s energy consumption during the construction and post-construction phases. Strategies being implemented include those recommended by the CARB that may reduce both the project’s construction energy consumption, including diesel anti-idling measures, light-duty vehicle technology, usage of alternative fuels such as biodiesel blends and ethanol, and heavy-duty vehicle design measures to reduce energy consumption. Additionally, as outlined in the SJVAPCD’s GAMAQI, the project includes recommendations to reduce energy consumption by shutting down equipment when not in use for extended periods, limiting the usage of construction equipment to eight cumulative hours per day, usage of electric equipment for construction whenever possible in lieu of diesel or gasoline powered equipment, and encouragement of employees to carpool to retail establishments or to remain on-site during lunch breaks.

The proposed operation of the project will be subject to energy conservation requirements in the California Energy Code (24 CCR Part 6, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the CALGreen (24 CCR Part 11). Adherence to Title 24 requirements would ensure that the project would not result in wasteful or inefficient use of nonrenewable resources due to operation. The project would also be required to be compliant with City of Merced General Plan Policy SD-3.2 and associated implementing actions 3.2.a through 3.2.e to encourage the use of energy conservation features, low-emission equipment, and alternative energy sources for all new residential and commercial development.

Based on this analysis, the project would be consistent and not conflict with or obstruct a State or local plan related to renewable energy or energy consumption. Impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

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LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact
No
Impact

3.4.7 - GEOLOGY AND SOILS
Would the Project:
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.
i. ii. Strong seismic ground shaking?
ii. iii. Seismic-related ground failure, including
iii. liquefaction?
iv. iv. Landslides?
b. Result in substantial soil erosion or the loss of
topsoil?
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?
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?
e. Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems in areas where
sewers are not available for the disposal of
wastewater?
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
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□
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The analysis in this section is based in part on a Phase 1 Environmental Site Assessment prepared for the project (Krazan and Associates, Inc. 2024).

Discussion
Impact #3.4.7a(i) – Would the Project Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving – 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?
Merced is vulnerable to shaking from a number of faults that run through the mountains to the east and west (City of Merced 2012). There are no known active earthquake faults or Alquist-Priolo fault zones that traverse the City or project site. The nearest known fault is the Ortigalita Fault located approximately 40 miles west of the project site.

The development of the project is expected to comply with California Building Code (CBC) requirements that would ensure acceptable and safe building practices are implemented to reduce potential adverse effects from fault-related ground shaking. Therefore, with consideration of potentially active faults and mandatory compliance with CBC requirements, the project would result in a less than significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.7a(ii) – Would the Project Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving – strong seismic ground shaking?
See discussion of Impact #3.4.7a(i) above.

The City will ensure that all new construction complies with applicable local and State regulations to reduce any potentially significant impacts to structures resulting from strong seismic ground shaking at the project site. Therefore, project impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

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LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.7a(iii) – Would the Project Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving – seismic-related ground failure, including liquefaction?
See discussion of Impact #3.4.7a(i) and (ii) above.

Liquefaction is defined as a phenomenon where earthquake-induced ground vibrations increase the pore pressure in saturated, granular soils until it is equal to the confining, overburdened pressure. When this occurs, the soil can completely lose its shear strength and enter a liquefied state. The possibility of liquefaction is dependent upon grain size, relative density, confining pressure, saturation of the soils, and intensity and duration of ground shaking. In order for liquefaction to occur, three criteria must be met: “low density,” coarsegrained (sandy) soils, a groundwater depth of less than about 50 feet, and a potential for seismic shaking from nearby large magnitude earthquakes.

Areas of the City with high water tables and loose soils are likely to experience damage because of the shockwave carrying ability of the ground (City of Merced 2012). It is further noted that although no liquefaction hazard areas are identified in the City sphere of influence (SOI), the future potential of liquefaction is recognized because unconsolidated sediments and a high-water table do coincide in many areas. In response to the potential of liquefaction hazards, the City General Plan acknowledges that engineering treatment of the ground, structure or both, can stabilize hazards such as liquefaction. The General Plan provides Policy S-2.1 and its associated implementing actions 2.1.a through 2.1.f to reduce the potential danger from earthquake and seismic-related activity. The actions include the requirement of new development meeting seismic design requirements in the adopted Building Code.

However, groundwater levels at the site were reported at a depth of 165 feet below ground surface (Krazan and Associates, Inc. 2024). Based on this, project impacts related to exposing people or structures to potential substantial adverse effects involving seismic-related ground failure, including liquefaction, are less than significant. Adherence to all applicable local and State regulations would reduce or avoid any potential impacts to structures resulting from liquefaction at the project site, and impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Impact #3.4.7a(iv) – Would the Project Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving – landslides? The project site is relatively flat with no significant topological features. As such, there is no potential for rock falls or landslides to impact the project in the event of a major earthquake, as the area has no dramatic elevation changes. The project will not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. Therefore, impacts of the project are less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.7b – Would the Project result in substantial soil erosion or the loss of topsoil? The project sites and surroundings are mostly flat. Construction activities for the project may disturb minimal amounts of soils during construction and would expose these disturbed areas to erosion by wind and water. However, since the project is anticipated to disturb more than one acre of land at, the project is subject to National Pollutant Discharge Elimination System (NPDES) Program requirements. As such, it will have to develop a Stormwater Pollution Prevention Plan (SWPPP). A SWPPP must identify potential sources of erosion or sedimentation as well as identify and implement various types of Best Management Practices (BMPs) to prevent erosion and sedimentation from occurring during construction. Typical BMPs intended to control erosion include sandbags, retention basins, silt fencing, street sweeping, etc.

Mitigation Measure MM GEO-1 requires the approval of a SWPPP to comply with the NPDES General Construction Permit. The project will comply with all grading requirements as outlined in Title 24 and Appendix J of the CBC. The project is not expected to result in substantial erosion or the loss of topsoil with the incorporation of MM GEO-1.

Once constructed, the project will have both impermeable surfaces as well as permeable surfaces. Impermeable surface would include roadways, driveways, and building sites.

Permeable surfaces would include any landscaped areas. Stormwater will be directed to the stormwater drainage systems that will be developed and connected to City of Merced stormwater infrastructure. The stormwater drainage system would be constructed in accordance with the City’s applicable development standards. Therefore, the development of the project would not result in substantial surface soils exposure to wind or water, and with implementation of MM GEO-1, would result in a less than significant impact.

Initial Study

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MITIGATION MEASURE(S)
MM GEO-1: If the proposed development will disturb an area of one or more acres, prior to issuing of grading or building permits, the project applicant shall submit to the City; (1) the approved Stormwater Pollution Prevention Plan (SWPPP) and (2) the Notice of Intent (NOI) to comply with the General National Pollutant Discharge Elimination System (NPDES) from the Central Valley Regional Water Quality Control Board. The requirements of the SWPPP and NPDES shall be incorporated into design specifications and construction contracts.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.7c – Would the Project 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? See discussion in Impact #3.4.7a(iii) and 3.4.7a(iv) above.

There are no slopes on or near the site, and the project would not expose the people or structures to significant risks from landslides.

The proposed project will comply with all City and State regulations pertaining to construction, including CBC and the Merced Municipal Code. In addition, the project site is not in an area that is at high risk for landslides due to the low levels of elevation change.

Compliance with the existing regulatory framework would be adequate to reduce any potential impacts to less-than-significant levels. Moreover, the project will be designed by an engineer to resist potential side effects of spreading, subsidence, liquefaction, or collapse.

Therefore, the impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Impact #3.4.7d – Would the Project 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? Clay soils are typically more susceptible to expansion and subsequent hazards due to the disparity between their wet and dry compositions. Per the National Resources Conservation Service, (NRCS), Web Soil Survey, the project site consists of Wyman clay loam and Landlow silty clay loam (Natural Resources Conservation Service 2023). Wyman Clay loam is characterized as formed in alluvium originating from andesitic and basaltic rocks with a well-drained drainage class, slow to medium runoff, and moderately slow permeability.

Landlow silty clay loam is characterized as moderately fine textured alluvium with somewhat poorly drained drainage class, slow runoff and slow permeability.

Implementation of General Plan Policies, and enforcement of the CBC Standards would reduce the effect of this hazard on new buildings and infrastructure associated with the proposed development. Additionally, the project will comply with applicable CBC regulations for development within specific soils types and would result in less than significant impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.7e – Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems in areas where sewers are not available for the disposal of wastewater?
The proposed project does not include private septic systems. The project will connect to the existing City sewer system for the disposal of generated wastewater during operations.

The project will comply with applicable City of Merced development standards for connection to existing City sewer infrastructure. Therefore, the project would have no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.7f – Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
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The City’s General Plan states that there are no known sectors within the planning area known to contain sites of paleontological significance. However, the project site has likely been disturbed from past agricultural activities. Further ground-disturbing activities during construction could potentially impact previously undiscovered paleontological resources or unique geologic features. To establish proper procedure in the event of inadvertent discovery, MM GEO-2 will require a qualified paleontologist to assess the find and provide necessary steps to take to address the resource.

Therefore, implementation of MM GEO-2 would reduce impacts to less than significant levels related to paleontological resources.

MITIGATION MEASURE(S)
MM GEO-2: If any paleontological resources are encountered during ground-disturbance activities, all work within 25 feet of the find shall halt until a qualified paleontologist, as defined by the Society of Vertebrate Paleontology Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (2010), can evaluate the find and make recommendations regarding treatment. Paleontological resource materials may include resources such as fossils, plant impressions, or animal tracks preserved in rock. The qualified paleontologist shall contact the Natural History Museum of Los Angeles County or another appropriate facility regarding any discoveries of paleontological resources.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact
No
Impact

3.4.8 - GREENHOUSE GAS EMISSIONS
Would the Project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
b. Conflict with any applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse gases?
Discussion
The analyses in this section are based on an Air Quality and Greenhouse Gas Impact Assessment (VRPA Technologies, Inc. 2025a) attached as Appendix A. The Air Quality and Greenhouse Gas Impact Assessment considered build out of a higher residential lot that what is currently proposed. Therefore, it can be assumed that the greenhouse gas estimates resulting from the project would be less that those estimates in Appendix A and discussed in this IS/MND.

Impact #3.4.8a – Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Although construction of the proposed project would result in temporary emissions of greenhouse gases (GHG), the project as a whole is not expected to generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. The estimated GHG emissions from construction and operational activities associated with the proposed project as estimated in CalEEMod are shown below.

Table 3.4.8-1
Project GHG Emissions
CO2e (MT/yr)
Project Operational Emissions per year
(plus amortized construction emissions)
8,120.52
Source: (VRPA Technologies, Inc. 2025a)
CARB, in consultation with Metropolitan Planning Organizations (MPO), has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the Merced County Association of □ □ □
□ □ □
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Governments region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. MCAG’s 2018 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

In 2009, the SJVAPCD adopted the following guidance documents applicable to projects within the San Joaquin Valley:
• Guidance for Valley Land‐use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009), and
• District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009).

This guidance and policy are the reference documents referenced in the SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts adopted in March 2015 (SJVAPCD 2015).

Consistent with the District Guidance and District Policy above, SJVAPCD (2015) acknowledges the current absence of numerical thresholds, and recommends a tiered approach to establish the significance of the GHG impacts on the environment:
i. If a project complies with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, then the project would be determined to have a less than significant individual and cumulative impact for GHG emissions;
ii. If a project does not comply with an approved GHG emission reduction plan or mitigation program, then it would be required to implement Best Performance Standards (BPS); and
iii. If a project is not implementing BPS, then it should demonstrate that its GHG emissions would be reduced or mitigated by at least 29 percent compared to Business as Usual (BAU).

Under these scenarios the project would generate 12,292.20 Metric Tons of Carbon Dioxide Equivalent per year (MTCO2eq./year) using an operational year of 2005, which includes area, energy, mobile, waste, and water sources. “Business as usual” (BAU) is referenced in CARB’s AB 32 Scoping Plan as emissions projected to occur in 2020 if the average baseline emissions during the 2002‐2004 period grew to 2020 levels, without control or Best Performance Standards (BPS) offsets. As a result, an estimate of the project’s operational emissions in 2005 were compared to operational emissions in 2020 in order to determine if the project meets the 29% emission reduction. The SJVAPCD has reviewed relevant scientific information related to GHG emissions and has determined that they are not able to determine a specific quantitative level of GHG emissions increase, above which a project would have a significant impact on the environment, and below which would have an Initial Study

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insignificant impact. As a result, the SJVAPCD has determined that projects achieving at least a 29% GHG emission reduction compared to BAU would be determined to have a less than significant individual and cumulative impact for GHG. Results of the analysis show that the project’s GHG emissions in the year 2020 are 10,230.91 MTCO2eq./year. This represents an achievement of 17% GHG emission reduction based on BAU, which does not meet the 29% GHG emission reduction target.

Therefore, because this threshold has been established by the SCAQMD in an effort to control GHG emissions in the largest metropolitan area in the State of California, this threshold is considered a conservative approach for evaluating the significance of GHG emissions in a more rural area, such as Merced County. Though the project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the project.

CARB’s California GHG Emissions Inventory provides estimates of anthropogenic GHG emissions within California, as well as emissions associated with imported electricity; natural sources are not included in the inventory. California’s GHG emissions for 2020 totaled approximately 358.76 million MTCO2eq. The proposed project’s GHG emissions represent less than 0.001% of the total GHG emissions for the state of California when compared to year 2018 emissions data. Based on the assessment above, the project will not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Therefore, any impact would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.8b – Would the Project conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? California passed the California Global Warming Solutions Act of 2006. Assembly Bill (AB) 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. Under AB 32, CARB must adopt regulations by January 1, 2011, to achieve reductions in GHGs to meet the Initial Study

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1990 emission cap by 2020. On December 11, 2008, CARB adopted its initial Scoping Plan, which functions as a roadmap of CARB’s plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations. CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan.

SB 375 requires MPOs to adopt an SCS or APS that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. MCAG’s 2022 RTP/SCS, which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

Executive Order B‐30‐15 establishes a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. Executive Order B‐30‐ 15 requires MPO’s to implement measures that will achieve reductions of greenhouse gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth, and that designate locations for land uses to regulate growth. MCAG uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in the AQPs. The applicable General Plan for the project is County of Merced 2030 General Plan Update, which was adopted in 2012.

The project is consistent with the currently adopted General Plan for Merced and the adopted MCAG 2022 RTP/SCS and is therefore consistent with the population growth and VMT applied in those plan documents. Therefore, the project is consistent with the growth assumptions used in the applicable AQP. It should also be noted that yearly GHG emissions generated by the project are approximately 19% less than the threshold identified by the SCAQMD (see the discussion for Impact 3.4.8a above).

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit. Below is a list of applicable strategies in the Scoping Plan and the project’s consistency with those strategies. • California Light‐Duty Vehicle GHG Standards – Implement adopted standards and planned second phase of the program. Align zero‐emission vehicles, alternative and renewable fuel and vehicle technology programs for long‐term climate change goals. o The project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable Initial Study

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to light‐duty vehicles that would access the project. The project would not conflict or obstruct this reduction measure.
• Energy Efficiency – Pursuit of comparable investment in energy efficiency from all retail providers of electricity in California. Maximize energy efficiency building and appliance standards.
o The project is consistent with this reduction measure. Though this measure applies to the State to increase its energy standards, the project would comply with this measure through existing regulation. The project would not conflict or obstruct this reduction measure.
• Low Carbon Fuel – Development and adoption of the low carbon fuel standard. o The project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable to the fuel used by vehicles that would access the project. The project would not conflict or obstruct this reduction measure.

Based on the assessment above, the project will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Therefore, any impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.9 - 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?
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?
c. Emit hazardous emissions or involve
handling hazardous or acutely hazardous
materials, substances, or waste within onequarter mile of an existing or proposed school?
d. Be located on a site that 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?
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 or excessive noise for
people residing or working in the Project
area?
f. Impair implementation of, or physically
interfere with, an adopted emergency
response plan or emergency evacuation plan?
g. Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury, or death involving wildland fires?

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Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-71
Discussion
The discussion below is based on the Phase I Environmental Site Assessment (ESA) completed for the project, attached as Appendix D (Krazan and Associates, Inc. 2024).

Impact #3.4.9a – Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Construction of the project would involve the temporary transport and use of minor quantities of hazardous materials such as fuels, oils, lubricants, hydraulic fluids, paints, and solvents. The types and quantities of hazardous materials to be used and stored on-site would not be of a significant amount to create a reasonably foreseeable upset or accident condition. The handling and transport of all hazardous materials on-site would be performed in accordance with all applicable federal, State, and local laws and regulations. Designated truck routes in the City of Merced include SR-99 and SR-140 (Federal Motor Carrier Safety Administration 2024). The Merced City Fire Department would respond to any hazardous materials incident and additional fire department units would respond as necessary.

A review of the EnviroStor database and the Geotracker database did not identify any active hazardous material site or hazardous material cleanup site in proximity of the project site (California Department of Toxic Substances Control 2024, State Water Resources Control Board 2024).

Construction
Minor amounts of hazardous and non-hazardous materials and construction waste would likely be transported to and from the project site during the construction phase of the proposed project. Any hazardous waste or debris that is generated during the construction of the proposed project would be collected and transported away from the site and disposed of at an approved offsite landfill or other such facilities. In addition, sanitary waste generated during construction would be managed through portable toilets, which would be located at reasonably accessible onsite locations. Hazardous materials such as paint, bleach, water treatment chemicals, gasoline, oil, etc., may be used during construction. These materials are stored in appropriate storage locations and containers in the manner specified by the manufacturer and disposed of in accordance with local, federal, and State regulations.

Residential and commercial construction generally utilize fewer hazardous chemicals or chemicals in relatively small quantities and concentrations compared to industrial uses. No significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous waste during the construction or operation of the new residential development would occur.

Operations
Once constructed, the use of such materials as paint, bleach, etc., is considered common for residential developments. It would be unlikely for such materials to be stored or used in such quantities that would be considered a significant hazard.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-72
For future commercial uses, operations may include the use of materials that require reporting to the local Certified Unified Program Agency (CUPA) and approval of a hazardous materials business plan (HMBP). The County of Merced Division of Environmental Health (MCDEH) serves as the local CUPA. Should the commercial operation handle a hazardous material or mixture containing a hazardous material equal or greater to 55 gallons for liquids, 500 pounds for solids, or 200 cubic feet for compressed gas, a HMBP is required to be submitted and approved by the local CUPA. The purpose of the HMBP is to provide an inventory of hazardous materials at a facility, provide emergency response plans and procedures to follow in the event of a reportable release or threatened release of hazardous materials, and storage and safety procedures for the hazardous material. Therefore, under regulatory requirements, should the commercial operation handle or store hazardous materials exceeding State and local reporting thresholds, a HMBP will be required to be prepared.

Operational activities will comply with the CBC, local building codes, and applicable safety measures, in addition to preparation and approval of a HMBP as necessary to ensure that no significant hazard is generated.

Based on the analysis above, project construction and operation are not anticipated to result in significant impacts due to the transportation, use, or disposal of hazardous materials.

Therefore, project impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9b – Would the Project 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?
See the discussion on Impact #3.4.9a above.

The Phase I ESA conducted a historical review of the property including aerial photographs, pertinent building permit records, interviews with previous and current ownership, review of regulatory agency records, and a site reconnaissance. The results of the Phase I ESA found no evidence of recognized environmental conditions (REC), controlled RECs (CREC), or historical RECs (HREC) in connection with the subject site. A review of historical aerial photographs indicate that the northern portion of the subject site was occupied by a rural residential area. This area included varying numbers of dwellings, barns, and other outbuildings with at least three barn-type structures present in 1950 and five to six barntype structures present in 1984 likely in support on an on-site farming operation. There are no historical records or indication that an underground storage tank is located on the project Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-73
site. However, the Phase I ESA that although there is no evidence of the presence of an underground storage tank, a very low possibility of an unregistered underground storage tank (UST) can exist due to the historical nature of the site. Removal of an unregistered UST would be subject to permit by the Merced County Environmental Health Division and would appropriately address handling and procedure for removal activities.

Historical review also indicate that the subject site was utilized for agricultural purposes.

While there is a potential that environmentally persistent pesticides/herbicides may have been applied to the crops grown on the subject site prior to the 1970s, no chemical spray rig filling/mixing areas or chemical storage areas were observed during the site reconnaissance, no material evidence of the use of environmentally persistent pesticides/herbicides was obtained during the course of this assessment, and the subject site does not appear to have been occupied by a vineyard or an orchard which are typically more directly correlated with the historical use of environmentally persistent pesticides/herbicides (Krazan and Associates, Inc. 2024). The Phase I ESA concludes that the potential for elevated concentrations of environmentally persistent pesticides/herbicides to currently existing in the near-surface soils of the subject site appear to be low.

Additional site development includes the proper abandonment of any existing water wells and septic systems associated with the historical use of the site. Should a previously unidentified water well or septic system be identified during project implementation, proper abandonment in accordance with State and local guidelines would be followed.

Per the California Department of Toxic Substances Control (DTSC) Envirostor database, the project site is not located on a listed hazardous materials/waste facility (California Department of Toxic Substances Control 2024). Additionally, there are no records of leaking underground storage tanks on the project site (State Water Resources Control Board 2024).

There are no active Geologic Energy Management Division (CalGEM) identified oil or gas fields within the project site (CalGEM 2024).

Consequently, the project is not anticipated to create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions. As discussed above, there is no evidence of a significant environmental condition on the project site that could potentially result in a significant impact. Therefore, as discussed above, should a previously unidentified condition be identified, that could result in upset or accidental hazardous material spill, regulatory procedures including proper abandonment/removal of the condition would be followed and the project impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-74
Impact #3.4.9c – Would the Project emit hazardous emissions or involve handling hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
See Impacts #3.4.9a and b above.

The project site is located approximately 0.25 miles east of Pioneer Elementary School.

Construction activities of the proposed project will result in the temporary use of hazardous materials and or substances, such as lubricant and diesel fuel, during construction. As noted in Impact #3.4.3b, exhaust from construction and related activities is expected to be minimal and would not create a significant impact.

Once constructed, the residential portion of the project is unlikely to have materials that are considered hazardous. As noted in above, commercial businesses that store or use hazardous materials that exceed thresholds will prepare a HMBP that would be submitted and approved by the local CUPA. The purpose of the HMBP is to provide an inventory of hazardous materials at a facility, provide emergency response plans and procedures to follow in the event of a reportable release or threatened release of hazardous materials, and storage and safety procedures for the hazardous material. Commercial activities will comply with the CBC, local building codes, and applicable safety measures, in addition to preparation and approval of a HMBP as necessary to ensure that no significant hazard is generated Therefore, the impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9d – Would the Project be located on a site that 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? See Impact 3.4.9b
An online search was conducted to identify hazardous waste locations on or near the project site. The search indicated that there are no reported hazardous or toxic sites within the project site (California Department of Toxic Substances Control 2024).

There is no data identifying any facilities in the vicinity that might reasonably be anticipated to emit hazardous air emissions or handle hazardous materials, substances, or wastes that might affect the proposed residential development. Therefore, impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-75

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9e – 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 or excessive noise for people residing or working in the Project area?
The project site is located approximately 4 miles east of the Merced Regional Airport. The project site is located outside of the airport influence area, as identified in the Merced County Airport Land Use Compatibility Plan (ALUCP) (Merced County Airport Land Use Commission 2012). Therefore, the project is not within two miles of an airport and would not create a safety hazard or generate excessive noise for people working in the project area. As such, there would be no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.9f – Would the Project impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan? The 2021-2026 Merced County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) identifies hazards present within the County, provides a risk assessment for the respective hazard, and adopts mitigation strategies to reduce risk. In addition to the Merced County MJHMP, the project will be required to comply with City safety requirements adopted in Fire Code and other code requirements for emergency response. These requirements will include the meeting minimum emergency access requirements and fire suppression requirements.

The proposed project would not inhibit the ability of local roadways to accommodate emergency response and evacuation activities. Therefore, the impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-76

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9g – Would the Project Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? According to available data from Cal Fire, the project site, is within a Local Responsibility Area (LRA) Unzoned Fire Hazard Severity Zone (Cal Fire 2007). The General Plan includes policies that would protect the project and the community from fire dangers that would be followed during the construction and operation of the project. These policies include maintaining reasonable levels of accessibility and infrastructure support for fire suppression, disaster, and other emergency services, maintaining standards defined in the Fire Code, and enforce nuisance abatement programs regarding weeds during the dry season.

Construction activities and the project operation are not expected to increase the risk of wildfires on and adjacent to the project site. The project will comply with all applicable State and local standards as required by local fire codes. Therefore, the project would have lessthan-significant impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-77
Discussion
The discussion below is based on the Water Supply Assessment (WSA) completed for the project, attached as Appendix E (QK 2025) The Water Supply Assessment considered build

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact
No
Impact

3.4.10 - HYDROLOGY AND WATER QUALITY
Would the Project:
a. Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface water quality?
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the Project
may impede sustainable groundwater
management of the basin?
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 onor off-site? ii. Substantially increase the rate of amount of
surface runoff in a manner which would
result flooding on- or off-site?
iii. Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
iv. Impede or redirect flood flows?
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to Project
inundation?
e. Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
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Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-78
out of a larger number of residential lots than is currently proposed. Therefore, it can be assumed that the water usage estimates resulting from the project would be less than those estimated and discussed in this IS/MND.

Impact #3.4.10a – Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water quality? The proposed project construction and groundbreaking activities have the potential to cause erosion, sedimentation, and discharge of construction debris from the project site. Clearing of vegetation and grading activities, for example, could lead to exposed or stockpiled soils susceptible to peak stormwater runoff flows. Also, the compaction of soils by heavy equipment may minimally reduce the infiltration capacity of soils (exposed during construction) and increase runoff and erosion potential. The presence of significant amounts of raw materials for construction, including concrete and asphalt, may lead to stormwater runoff contamination. If uncontrolled, these materials could lead to water quality problems, including sediment-laden runoff, prohibited non-stormwater discharges, and ultimately the degradation of downstream receiving water bodies. As discussed previously, the project would disturb more than one-acre and would be required to prepare a SWPPP and would ensure implementation of BMPs that address potential issues related to soil erosion and contaminated runoff. Implementing BMPs for construction activities, such as the use of straw waddle sandbags, silt fencing, swales, street sweeping, etc., will be implemented and would reduce stormwater runoff to a less-than-significant impact during construction activities.

The project’s surface or groundwater water quality impacts are expected to be less than significant with incorporation of MM GEO-1 as the preparation and approval of a SWPPP would ensure BMPs for construction activities would be implemented and reduce potential impacts on water quality.

MITIGATION MEASURE(S)
Implementation of MM GEO-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.10b – Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
The California Department of Water Resources, (DWR) has divided the State into 10 Hydrologic Regions. The project site is located within the San Joaquin River Hydrologic Region in a Basin ranked as “high priority” in a Statewide ranking of groundwater importance. The Region encompasses approximately 5,246 square miles. the City of Merced is located in the Merced Subbasin (DWR Subbasin 5-22.04) which is in the greater San Joaquin River hydrologic region (DWR Basin 5.22), and also within the larger San Joaquin Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-79
Valley Groundwater Basin (QK 2025). The Merced Subbasin covers approximately 767 square miles. The Merced subbasin includes lands south of the Merced River between the San Joaquin River on the west and the crystalline basement rock of the Sierra Nevada foothills on the east. The subbasin boundary on the south stretches westerly along the Madera-Merced County line (Chowchilla River) and then between the boundary of the Le Grand-Athlone Water District and the Chowchilla Water District. The boundary continues west along the northern boundaries of Chowchilla Water District and El Nido Irrigation District. The southern boundary then follows the western boundary of El Nido I.D. south to the northern boundary of the Sierra Water District, which is followed westerly to the San Joaquin River.

Groundwater in the Basin is used for all water supply for the City. The city participates in and is a member of the Merced Irrigation-Urban Groundwater Sustainability Agency (MIUGSA). MIUGSA is part of the Merced Groundwater Subbasin Groundwater Sustainability Plan (MGSGSP). The City has an estimated service population of approximately 99,100 people. In 2020, approximately 20,076 acre-feet (6,542 million gallons) of water was delivered to an estimated 22,969 water service connections of which approximately 67% of the water use is for residential services. The remainder are for educational, commercial and industrial uses. The City currently utilizes local groundwater as its source of water supply.

Groundwater is extracted from 20 wells located within the city’s sphere of influence.

Water needed for construction will be obtained from the City, who has confirmed sufficient water to supply the project. The current water distribution system is adjacent to the project site. The construction process is estimated to take place in stages during an approximately seven-year period. During this seven-year period, it is assumed that each acre of land will require a total of one year to construct. Construction water demands are estimated to be approximately 225 gpd/acre for the duration of construction or 17.34 acre-feet, which is equivalent to approximately 5,650,200 gallons (225 gpd/acre x 68.8 total acres to be developed x 365 days per acre). Bottled drinking water will be provided for crews during construction activities. Initial construction water usage will be in support of site preparation and grading activities. During earthwork for grading of access road foundations, building foundations and project components, the principal use of water would be for compaction and dust control. Smaller quantities of water would be required for the preparation of the concrete of foundations and other infrastructure. After the earthwork activities, water usage will be used for dust suppression and normal construction water requirements that are associated with construction of the buildings, internal access roads, and revegetation.

The long-term average day operational water demand will be for the residential and commercial users and is anticipated to be approximately 137.89 million gallons per year or 492.42 acre-feet (AF) per year for the total build out of the project (QK 2025). This is based on each residential unit having an average day water demand of 633.5 gallons per day (based on the 181-gallon per capita/day average in the 2020 City of Merced Urban Water Management Plan (UWMP) and 3.5 people per lot) across the entire buildout of 587 lots.

However, as noted, the proposed number of residential lots was reduced, and therefore, the long-term average day operational water demand will be for the residential and commercial Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-80
users and is anticipated to be approximately 131.8 gallons per year or 404.48 acre-feet per year for the total build out of the project with a buildout of 570 lots.

The water demand for the 9.1-acre commercial development is estimated to be 2.16 million gallons per year or 7.71 acre-feet per year (based on a commercial water use of 650 gpd/acre).

Tables 3.4.10-1 through 3 show the normal year supply and demand comparison, the single dry year supply and demand comparison, and the multiple dry year supply and demand comparison.

Table 3.4.10-1
Normal Year Supply and Demand Comparison
2025 2030 2035 2040 2045 (Opt)
Supply
Totals (AF)
24,418 26,751 28,995 31,825 -
Demand
Totals (AF)
24,418 26,751 28,995 31,825 -
Difference 0 0 0 0 -
Source: (QK 2025)

Table 3.4.10-2
Single Dry Year Supply and Demand Comparison
2025 2030 2035 2040 2045 (Opt)
Supply
Totals (AF)
29,301 32,101 34,794 38,190 -
Demand
Totals (AF)
29,301 32,101 34,794 38,190 -
Difference 0 0 0 0 -
Source: (QK 2025)
Table 3.4.10-3
Multiple Dry Year Supply and Demand Comparison
2025
(AF)
2030
(AF)
2035
(AF)
2040
(AF)
2045(Opt)
(AF)
First year Supply
Totals
26,860 29,426 31,895 35,008 -
Demand
Totals
26,860 29,426 31,895 35,008 -
Difference 0 0 0 0 -
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-81
Second
year
Supply
Totals
39,301 32,101 34,794 38,190 -
Demand
Totals
39,301 32,101 34,794 38,190 -
Difference 0 0 0 0 -
Third year Supply
Totals
26,860 29,426 31,895 35,008 -
Demand
Totals
26,860 29,426 31,895 35,008 -
Difference 0 0 0 0 -
Fourth
year
Supply
Totals
19,534 21,401 23,196 25,460 -
Demand
Totals
19,534 21,401 23,196 25,460 -
Difference 0 0 0 0 -
Fifth year Supply
Totals
19,534 21,401 23,196 25,460 -
Demand
Totals
19,534 21,401 23,196 25,460 -
Difference 0 0 0 0 -
Source: (QK 2025)
The long-term average day operational water demand will be for the residential and commercial users and is anticipated to be approximately 137.89 million gallons per year or 423.2 acre-feet per year for the total build out of the project. This is based on each residential unit having an average day water demand of 633.5 gallons per day (based on the 181-gallon per capita/day average in the 2020 City of Merced Urban Water Management Plan and 3.5 people per lot) across the entire buildout of 587 lots. The water demand for the 9.1-acre commercial development is estimated to be 2.16 million gallons per year or 6.63 acre-feet per year (based on a commercial water use of 650 gpd/acre).

With consideration of the smaller lot count of 570 proposed for the project, the water demand would be less than what was considered in the WSA. The proposed project at 570 lots would result in an operational demand (3.5 people per lot and 181-gallon per capita/day) of 1,31.8 gallons per year or 404.48 acre-feet per year.

The project water demand is included in the projected increase in water demand if a fifth dry year of 19,534 AF from 2025 to 25,460 AF 2040 (Table 3.4.10-3). The project long-term operational water demand is 1.58% (404.48 AF/25,460 AF) of the available water supply in the city and therefore impacts are anticipated to be less than significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-82

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(i) –Would the Project 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 result in substantial erosion or siltation on- or off-site?
As discussed in Impact #3.4.10a above, potential impacts on water quality arising from erosion and sedimentation are expected to be localized and temporary during construction.

Construction-related erosion and sedimentation impacts as a result of soil disturbance would be less than significant after implementation of a SWPPP (MM GEO-1) and BMPs required by the NPDES.

The existing drainage pattern of the site and area would be affected by project development due to grading, the installation of streets, structures and the increase in impervious surfaces.

The construction of the project includes the development of stormwater drainage infrastructure and would be developed to meet City standards. The project will comply with local regulations in order to minimize impacts during construction and post-construction of the project. The project will not alter a stream or river. With the implementation of MM GEO1, BMPs for erosion or siltation on- or off-site would be implemented and result in a less than significant.

MITIGATION MEASURE(S)
Implementation of MM GEO-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.10c(ii) – Would the Project 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 substantially increase the rate of amount of surface runoff in a manner which would result flooding on- or off-site? See also Impact #3.4.10c(i) above.

The project sites do not contain any water features, streams, or rivers. Existing drainage pattern of the site would be affected by project development because of the increase in impervious surfaces at the site. The addition of impervious surfaces can increase the potential for stormwater runoff and soil erosion. All project components will comply with the City of Merced Municipal Code for urban storm water quality management.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-83
The project would not cause substantial surface runoff that would result in flooding on- or off-site. Therefore, with implementation of MM GEO-1, impacts would be less than significant.

MITIGATION MEASURE(S)
Implementation of MM GEO-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.10c(iii) – Would the Project 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 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? Please see Impacts #3.4.10a through c(ii) above.

The project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site, contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems, nor provide additional sources of polluted runoff. Therefore, the project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(iv) – Would the Project 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 impede or redirect flood flows?
Please see Impacts #3.4.10a through c(ii) above.

As discussed in Impact # 3.4.4c, there were no wetlands on the site. However, there is a water feature- an irrigation ditch runs north/south (originally part of the Farmdale lateral) along the eastern area of the project site. The ditch running east to west in the northerly portion of the appears to either terminate and cut off by Campus Parkway and East Gerard Avenue or be undergrounded approximately 700 feet west of project boundaries and is no longer in use. These water features appear to have limited to no indication of inundation or water flow and therefore, can be considered remnant features.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-84
The project is anticipated to be developed on relatively flat land and would not significantly impede flood flows. Therefore, the project will have a less than significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10d – Would the Project, in flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundation?
The project site is within a 100-year floodplain as indicated by the FEMA map for the area.

Because of this, the project could impede or redirect any flood flows. Flooding on the project site could reach a depth of one foot. Merced Municipal Code Chapter 17.48 addresses flood damage prevention and construction within Special Flood Hazard Areas. Section 17.48.135 requires a development permit before the start of construction within a Special Flood Hazard Area. The application for a development permit shall include plans that, among other requirements, show base flood elevation information and proposed elevation, in relation to mean sea level, of the lowest floor. Section 17.48.140 sets forth construction standards for structures within the Special Flood Hazard Area, including the use of materials resistant to flood damage, the use of construction methods and practices that minimize flood damage, and (for AH and AO zones) adequate drainage paths around structures on slopes to guide floodwaters around and away from proposed structures. In addition, new construction and substantial improvement in Zone AO shall have the lowest floor, including basement, elevated above the highest adjacent grade at least as high as the depth number specified in feet on the FIRM, or at least two feet if no depth number is specified. For this project, the elevation would be one foot.

Compliance with the requirements of Merced Municipal Code Chapter 17.48 would reduce potential flooding impacts related to the project, including impeding or redirecting flood flows and would be less than significant.

The project site is not located near the ocean or a steep topographic feature (i.e., mountain, hill, bluff, etc.). Tsunamis are waves generated in oceans from seismic activity. Due to the inland location of the site, tsunamis are not considered a hazard for the site. Therefore, there is no potential for the site to be inundated by tsunami or mudflow.

A seiche is a wave generated by the periodic oscillation of a body of water whose period is a function of the resonant characteristics of the containing basin as controlled by its physical dimensions. There is no body of water within the vicinity of the project site. There is no potential for the inundation of the project site by seiche.

The General Plan identifies dam failure inundation areas resulting from Bear Reservoir and Yosemite Lake. The project site is located outside of the dam failure inundation areas. As the Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-85
project site is not likely to be impacted due to dam failure impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10e – Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
See Impacts #3.4.10a and Impact #3.4.10b.

The project’s long-term operational water demand is 1.58% (404.48 AF/25,460 AF) of the available water supply in the City and therefore a less than significant impact is foreseen.

Utilizing data from the UWMP, it was found that the anticipated water supply for the City would be sufficient to accommodate the project (QK 2025).

The project will comply with all applicable local and State standards during construction and operation including preparation and approval of a SWPPP as per MM GEO-1. This project is not anticipated to use or substantially deplete groundwater supplies or conflict with any adopted groundwater management plan. Therefore, this project will have a less-thansignificant impact.

MITIGATION MEASURE(S)
Implementation of MM GEO-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant mitigation incorporated.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-86

Discussion
Impact #3.4.11a – Would the Project physically divide an established community? The project site is approximately 73.7-acres located in the southeast portion of the City. The property is bound by East Mission Avenue with predominantly cultivated fields to the south, undeveloped commercial land to the west, vacant land to the east, and East Gerard Avenue with residential land to the north. The proposed project site would not create a division between any established communities. The proposed project would not physically divide an established community. Therefore, the project will have no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.11b – Would the Project 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?
The project includes a General Plan Amendment to change 61.7 acres from the Business Park and Manufacturing/Industrial land use designation to the Low-Medium Density Residential and High-Medium Density Residential land use designations.

The following General Plan Goals, Policies, and Implementing Actions have been identified that pertain to proposed land use designations associated with the project.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.11 - LAND USE AND PLANNING
Would the Project:
a. Physically divide an established
community?
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?
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Policy L-1.1: Promote balanced development which provides jobs, services and housing.

Policy L-1.2: Encourage a diversity of building types, ownerships, prices, designs, and site plans for residential areas throughout the City.

Policy L-1.3: Encourage a diversity of lot sizes in residential subdivisions.

Policy L-1.6: Continue to pursue quality single-family and higher density residential development.

Implementing Action 1.3.a: Continue the use of Residential Planned Developments to provide for smaller lot sizes in single-family developments.

Implementing Action 1.6.a: Continue to review proposed subdivision designs to ensure the provision of adequate circulation, public improvements, common open space, landscaping, maintenance, etc. through the Development Review process.

Policy OS-3.1: Provide high-quality park and open space facilities to serve the needs of a growing population.

Implementing Action 3.1.a: Continue efforts to acquire new park sites within future growth areas in advance of development to meet the recreation open space needs of an expanding population.

The project may potentially conflict with General Plan Policy 3.1, which seeks to avoid or minimize the risk of flooding to new development. As described in Impact #3.10d, the project is within a Special Flood Hazard Area. However, the project would comply with the provisions of Merced Municipal Code Chapter 17.48, which addresses flood damage prevention and construction within Special Flood Hazard Areas. This would be consistent with General Plan Implementing Action 3.2.b, which requires new development and substantial improvements or upgrades in identified FEMA flood hazard zones (i.e., 100- and 500-year floodplains) to be constructed in accordance with applicable city, State, and federal regulations, including compliance with the minimum standards of the Federal Emergency Management Agency and the National Flood Improvement Program to avoid or minimize the risk of flood damage.

The project would be consistent with the identified Goals, Policies and Implementing Actions of the City General Plan. In addition to the General Plan Goals, Policies and Implementing Actions, the proposed project would assist the City in meeting its Regional Housing Needs Allocation (RHNA) of 10,517 units for the 2023-2032 planning period (Merced County Association of Governments 2022). RHNA is based on countywide housing projections developed by the California Department of Housing and Community Development (HCD).

HCD works with the regional Council of Governments to determine the amount of housing needed within the region. As such, the proposed project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project.

Therefore, impacts of the project would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-88

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-89

Discussion
Impact #3.4.12a – Would the Project 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? The California Department of Conservation, Geological Survey classifies lands into Aggregate and Mineral Resource Zones (MRZs) based on guidelines adopted by the California State Mining and Geology Board, as mandated by the Surface Mining and Reclamation Act of 1974.

These MRZs identify whether known or inferred significant mineral resources are present in areas. Lead agencies are required to incorporate identified MRZs resource areas delineated by the State into their General Plans. The State has not identified any mineral resource zones within the Merced planning area or area designated for future expansion of the City (City of Merced 2012).

The project sites are not located in an identified CalGEM oilfield, and there are no known wells located on the site (CalGEM 2024). The proposed project would not result in the loss of availability of mineral resources as the project does not propose the extraction of mineral resources.

The proposed project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State. Therefore, the project would have no impacts.

MITIGATION MEASURE(S)
No mitigation is required.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.12 - 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?
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?
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LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.12b – Would the Project 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?
The proposed project is not designated as a mineral recovery area and the project would not alter any existing plans that protect mineral resources. As a result, the proposed project would not interfere with known mining operations and would not result in the loss of land designated for mineral and petroleum.

The proposed project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. Therefore, the project would have no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-91
Discussion
The analyses in this section are based on an Acoustical Analysis (WJV Acoustics 2024) attached as Appendix F.

Impact #3.4.13a – Would the Project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in a local general plan or noise ordinance or applicable standards of other agencies?
The Noise Element of the Merced Vision 2030 General Plan sets noise compatibility standard for transportation noise sources in terms of the Day-Night Average Level (Ldn) or Community Noise Equivalent Level (CNEL) to describe noise exposure for noise compatibility planning purposes. Both the Ldn and CNEL represent the time‐weighted energy average noise level for a 24‐hour day, with a 10 dB penalty added to noise levels occurring during the nighttime hours (10:00 p.m.‐7:00 a.m.). The CNEL includes an additional penalty of 5 dB that is added to noise levels occurring during the evening hours between 7:00 p.m. and 10:00 p.m. Both the Ldn and CNEL represent cumulative exposure to noise over an extended period of time and are therefore calculated based upon annual average conditions.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.13 - 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 a local general plan
or noise ordinance or applicable standards
of other agencies?
b. Generation of excessive ground-borne
vibration or ground-borne noise levels?
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 Project area to
excessive noise levels?
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Policy N‐1.4 states “A maximum of 65 dB Ldn/CNEL for exterior noise level for residential projects proximate to major roadway and railroad corridors. For other arterial, collector and local streets a maximum of 60 dB Ldn/CNEL exterior noise with a maximum of 65 dB Ldn/CNEL when all the best available noise‐reduction techniques have been exhausted without achieving 60 dB, and the strict application of such a maximum becomes a hindrance to development needed or typical for an area.”
Policy N-1.4 of the Noise Element establishes land use compatibility criteria for exterior and interior residential spaces. The City of Merced noise compatibility matrix, for transportation noise sources, is provided as Table I of the Noise Element. Table II of the Noise Element provides the City of Merced noise level standards for non‐transportation (stationary) noise sources. These nose standards typically apply to outdoor activity areas. Outdoor activity areas generally include backyards of single‐family residences, individual patios or decks of multi‐family developments and common outdoor recreation areas of multi‐family developments. The intent of the exterior noise level requirement is to provide an acceptable noise environment for outdoor activities and recreation. Additionally, Policy N‐1.4 of the Noise Element requires that interior noise levels attributable to exterior transportation noise sources not exceed 45 dB Ldn. The intent of the interior noise level standard is to provide an acceptable noise environment for indoor communication and sleep.

Construction-related noise levels and activities will be temporary and intermittent. The proposed project will generate noise from construction equipment including, but not limited to the following equipment: tractor, loaded truck, forklifts, generator, crane, paver, roller, compactor, and an air compressor. Additionally, traffic and the various other noises generally associated with construction activities will be temporary and only take place during permitted hours. In addition, the construction-related noise will be intermittent and cease once the proposed project is completed. MM NSE-04 will address concerns of those residing in existing residential units and the temporary construction activities by limiting the time for those activities from 7:00 A.M. to 7:00 P.M. unless otherwise regulated by City ordinance. This time restriction is consistent with other noise mitigation implemented for other residential developments.

The project site is generally located east of South Coffee Street (and east of the future alignment of Pluim Drive), south of Gerard Avenue and north of Mission Avenue. The project site is bisected by Campus Parkway. Exposure of the project to noise levels associated with vehicle traffic on these roadways is expected.

The distances from the center of the individual residential lot backyards to the centerline of the roadways of concern are approximately as follows:
• East Gerard Avenue: 70 feet
• Campus Parkway: 100 feet
• East Mission Avenue: 75 feet
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Noise exposure from traffic on East Gerard Avenue (west of Campus Parkway), Campus Parkway (east of Coffee Street) and Mission Avenue (east of Coffee Street) was calculated for existing and future (2046) conditions using the Federal Highway Administration (FHWA) Traffic Noise Model and traffic data obtained from MCAG. A description of the FHWA traffic noise model and methodology used is provided in the prepared Acoustical Analysis.

Noise level measurements and concurrent traffic counts were taken as part of the acoustical analysis of the project (WJV Acoustics 2024). The purpose of the measurements was to evaluate the accuracy of the FHWA Model in describing traffic noise exposure within the project site. Two traffic noise measurement sites were located along Campus Parkway (one on the north side of the roadway and one on the south side of the roadway) and one traffic noise measurement site was located within the project site, along the south side of Gerard Avenue. Traffic volumes along Mission Avenue were too low at the time of the project site visit to accurately perform a model calibration noise measurement. Noise measurements were conducted in terms of the equivalent energy sound level (Leq). Measured Leq values were compared to Leq values calculated (predicted) by the FHWA Model using as inputs the traffic volumes, truck mix and vehicle speed observed during the noise measurements. The results of the comparison are shown in Table 3.4.13-1.

Table 3.4.13-1
Comparison of Measured and Predicted Noise Levels, Merced Gateway Residential Development
Campus Pkwy
(north side)
Campus Pkwy
(south side)
Gerard Ave
Measurement Time 2:30 PM 2:55 PM 3:20 PM
Observed # of
Autos/hr
372 492 216
Observed # of
Medium Trucks/hr
24 72 0
Observed # of
Heavy Trucks/hr
12 12 12
Observed Speed
(MPH)
55 55 35
Distance, ft. (from
center of roadway)
180 165 50
Leq, dBA
(Measured)

52.3 55.4 59.9
Leq, dBA
(Predicted)

58.5 61.0 60.8
Difference between
Predicted and
Measured Leq, dBA

6.2 5.6 0.9
Source: (WJV Acoustics 2024)
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From the results of the measurements and FHWA predictions, it may be determined that the traffic noise levels predicted by the FHWA Model were approximately 6 dB higher than those measured for the conditions observed at the time of the noise measurements for Campus Parkway. This overprediction of the model is due to topographic shielding of traffic noise as a result of the elevated roadway over the project site area. However, for the purpose of this analysis and the offset was not applied to modeled traffic noise exposure levels, and noise exposure levels described along Campus Parkway should therefore be considered a worst‐ case assessment. Traffic noise levels predicted by the FHWA model were 0.9 decibels (dB) higher than those measured for the conditions observed at the time of the noise measurement along Gerard Avenue. This is considered to be reasonable agreement between the noise model and the noise measurements, and therefore no adjustments to the model are necessary along Gerard Avenue.

Exterior Noise Level Compliance
Annual average traffic noise exposure was calculated for the closest proposed residential lots from Gerard Avenue, Campus Parkway and Mission Avenue. Table 3.4.13-2 provides the noise exposure levels at these roadways for future 2046 traffic conditions, at the closest proposed residential setbacks from each roadway.

Table 3.4.13-2
Modeled Traffic Noise Exposure Levels, dB, Ldn
Roadway Existing Conditions 2046 Conditions
Gerard Avenue 53 54
Campus Parkway 60 62
Mission Avenue 52 52
Source: (WJV Acoustics 2024)
Table 3.4.13-2 indicates that the traffic noise exposure at the closest residential setbacks to Campus Parkway would be approximately 60 dB Ldn for existing conditions and approximately 62 dB Ldn for future (2046) traffic conditions on Campus Parkway (based upon the traffic volumes provided by MCAG). Such noise exposure levels exceed the City of Merced exterior noise level standard of 60 dB Ldn, and mitigation measures must be included in project design along Campus Parkway. Traffic noise levels at the closest proposed residential lots to both Gerard Avenue and Mission Avenue would not be expected to exceed 60 dB Ldn (based upon the traffic volumes provided by MCAG) and mitigation measures are therefore not required for noise compliance along these roadways. However, exterior noise levels at the closest proposed residential lots along Campus Parkway would be expected to exceed the City of Merced exterior noise level standard of 60 dB Ldn for residential land uses, and a sound wall will be required along the project site adjacent to Campus Parkway.

A sound wall insertion loss program based on the FHWA model was used to calculate the insertion loss (noise reduction) provided by the proposed sound walls. The model calculates the insertion loss of a wall of given height based on the effective height of the noise source, height of the receiver, distance from the receiver to the wall, and distance from the noise Initial Study

Merced Gateway Project May 2025
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source to the wall. The standard assumptions used in the sound wall calculations are effective source heights of 8, 2 and 0 feet above the roadway for heavy trucks, medium trucks, and automobiles, respectively. The standard height of a residential receiver is five (5) feet above the ground elevation. Additionally, Campus Parkway is elevated approximately 3‐4 feet above project site grade, adjacent to the project site areas. Based upon the above‐ described assumptions and method of analysis, the noise level insertion loss values for the proposed sound walls were calculated. The calculations indicated that the proposed 7‐foot sound wall along Campus Parkway would reduce exterior noise exposure at the residential lots adjacent to Campus Parkway by approximately 5 dB, with the resulting noise exposure of 57 dB Ldn. Such levels would not exceed the City of Merced exterior noise standard of 60 dB Ldn (WJV Acoustics 2024).

The installation of a masonry block wall with a minimum height of 7 feet will be included as Mitigation Measure MM NSE-1 to ensure that the noise levels from Campus Parkway traffic do not exceed City of Merced Noise Element thresholds. The sound walls would be effective at first‐floor receiver locations only. As such, if second‐floor balconies are included in the units that back onto Campus Parkway, exterior noise levels at any second‐floor balconies would exceed the 60 dB Ldn exterior noise level thresholds. Mitigation measure MM NSE-2 prohibits the use of outdoor balconies on the second floor of those lots adjacent to Campus Parkway. The design restrictions so that there are no second-floor balconies of residences abutting Campus Parkway will be recommended as MM NSE-02.

Interior Noise Level Compliance
The interior noise level standard for the City of Merced is 45 dB Ldn. Worst‐case exterior project site noise exposure was determined to be approximately 62 dB Ldn for 2046 traffic conditions along Campus Parkway. This means that the proposed residential construction must be capable of providing a minimum outdoor‐to‐indoor noise level reduction (NLR) of approximately 17 dB (62‐45=17).

A specific analysis of interior noise levels was not performed. However, it may be assumed that residential construction methods complying with current CBC and City requirements will reduce exterior noise levels by approximately 25 dB if windows and doors are closed.

This will be sufficient for compliance with City 45 dB Ldn interior standard at all proposed residential units. Mitigation Measure MM NSE-3 requires that air conditioning or mechanical ventilation be installed in each residential unit so windows and doors to remain closed for sound insulation. With implementation of MM NSE-3, interior noise levels are not expected to exceed Merced noise thresholds.

The implementation of Mitigation Measures MM NSE-1 through MM NSE-3 as recommended in the prepared Acoustical Analysis will ensure that proposed residential development along Campus Parkway will not exceed City Noise Element interior and exterior noise level standards, and impacts would be less than significant.

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MITIGATION MEASURE(S)
MM NSE-1: A sound wall shall be constructed to a minimum height of 7 feet above ground level along the residential portions of the project site that are directly adjacent to Campus Parkway. Suitable construction materials include concrete blocks, masonry, or stucco on both sides of a wood or steel stud wall.

MM NSE-2: Two-story home construction of lots that will be directly adjacent with Campus Parkway shall be constructed without second-floor balconies. A note prohibiting such second-floor balconies shall be placed as a Note on the VSTM #1333, and all plans and specs.

MM NSE-3: Air conditioning or mechanical ventilation shall be installed in the units so that it will be possible for windows and doors to remain closed for sound insulation purposes.

MM NSE-4: Unless further restricted in the City of Merced Municipal Code, grading and construction shall not take place beyond the hours of 7:00 A.M. and 7:00 P.M. MondaySunday.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.13b – Would the Project result in generation of excessive ground-borne vibration or ground-borne noise levels?
Construction
Construction activities, in general, can have the potential to create ground-borne vibrations.

It is unlikely that any blasting or pile-driving would be required in connection with the construction of the project. Construction activities most likely to cause vibrations include heavy construction equipment. Therefore, the potential for ground-borne vibrations to occur as part of the construction of the project is considered minimal.

The Federal Transit Administration (FTA) has published standard vibration velocities for construction equipment operations (Federal Highway Administration (FHWA), U.S.

Department of Transportation 2017). In general, the FTA architectural damage criterion for continuous vibrations (i.e., 0.2 inch/second) appears to be conservative even for sustained pile driving. Building damage can be cosmetic or structural. Ordinary buildings that are not particularly fragile would not experience any cosmetic damage (e.g., plaster cracks) at distances beyond 30 feet. This distance can vary substantially depending on the soil composition and underground geological layer between the vibration source and receiver.

In addition, not all buildings respond similarly to vibration generated by construction equipment. The typical vibration produced by construction equipment is illustrated in Table

3.4.13-2.

Table 3.4-3
Typical Vibration Levels for Construction Equipment
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Equipment
Reference peak particle
velocity at 25 feet
(inches/second)1
Approximate peak particle
velocity at 100 feet
(inches/second)2
Loaded trucks 0.076 0.010
Vibratory
compactor/roller

0.210 0.026
Notes:
1 – Federal Transit Administration, Transit Noise and Vibration Impact Assessment Guidelines, May 2006. Table 12-2. 2 – Calculated using the following formula:

PPV equip = PPVref x (25/D)1.5
where: PPV (equip) = the peak particle velocity in inches/second of the equipment adjusted for the distance PPV (ref) = the reference vibration level in inches/second from Table 12-2 of the FTA Transit Noise and Vibration Impact Assessment Guidelines
D = The distance from the equipment to the receiver
As indicated in Table 3.4.13-2, based on the FTA data, vibration velocities from typical heavy construction equipment that would be used during project construction range from 0.076 to

0.210 inch-per-second peak particle velocity (PPV) at 25 feet from the source of activity. The closest sensitive receptors are two existing single-family residences to the west and are located approximately 20 from the southwestern boundary of the project site. The remaining single-family residences to the east of the project area are located approximately 55 feet from the project boundary. With regard to the proposed project, ground-borne vibration would be generated during site clearing and grading activities on-site facilitated by implementation of the proposed project. It should be noted that 0.2 inch-per-second PPV is a conservative threshold, as that is the construction vibration damage criteria for nonengineered timber and masonry buildings. Buildings within the project area would be better represented by the 0.5 inch-per-second PPV significance threshold (construction vibration damage criteria for reinforced concrete, steel, or timber buildings). Therefore, vibration impacts associated with construction are anticipated to be less than significant.

Operation
Once constructed, the project would not result in any activities that would create groundborne vibrations. Thus, the proposed project would not result in the exposure of sensitive receptors or generate excessive ground-borne vibration or ground-borne noise levels.

Therefore, the project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.13c – 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 Initial Study

Merced Gateway Project May 2025
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or public use airport, would the Project expose people residing or working in the Project area to excessive noise levels?
The Merced Regional Airport is approximately 4.3 miles west of the project site. The project site is located outside of the airport influence area, as identified in the Merced County ALCUP (Merced County Airport Land Use Commission 2012). Therefore, the project would not expose people residing or working in the project area to excessive noise levels and there would be no impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.14 - 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)?
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?

Discussion
Impact #3.4.14a – Would the Project 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)? The project would provide employment opportunities in Merced during its construction, which may attract people from outside the Merced area. However, these opportunities would be limited in number and would most likely be met from the existing population in the Merced area. The project would also provide for approximately 9 acres of commercial (business park) space that will remain under its original General Plan and zoning designation. As the 9 acres will remain under its original land use designation, project impacts related to the commercial component would not result in unplanned population growth.

According to the 2020 U.S. Census, the population of Merced is 86,333, an increase of approximately 9.8% from its 2010 population of 78,958. The City of Merced has a 2023 estimated 29,138 housing units, an increase from the total housing units in 2020 of 29,083 (U.S. Census Bureau 2023). Of the total housing units in 2023, 19, 367 were single-family detached units (typical houses), approximately 66.5% of the total.

The project would involve the construction of 570 single-family residential units on an approximately 61.7-acre site. Based upon the average of 3.41 persons per household in Merced (U.S. Census Bureau 2023), the project would result in a potential population addition of approximately 1,944 people. The proposed development is currently not □ □ □
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consistent with the Merced General Plan, which designates the project site for business park development. The proposed General Plan Amendment and Zone Change would allow for the development of residential within the project area. The Merced County Regional Housing Element identifies a need for 10,517 additional units for the City of Merced. 2,543 of which should be categorized for very low-income, 1,742 low-income, 1,838 for moderate-income, and 4,394 for above moderate-income. The project would be consistent with the objectives in the Housing Element of the Merced to meet Regional Housing Needs Assessment allocations for additional housing units by providing 570 single-family residential units. As previously discussed in Impact #3.4.11b, the proposed project does not actively conflict with land use policies for residential land use.

As previously noted, the project would result in the development of new single-family residences and would provide additional housing opportunities for the City of Merced population. The proposed project includes a General Plan Amendment and Zone Change that would provide additional housing opportunities for an area previously planned for Business Park and Industrial/Manufacturing. A portion of the project site would remain designated as Business Park and provide for commercial and office opportunities. As the commercial component remains unchanged from its original land use and zoning designation, no unplanned population growth is anticipated. With regard to the residential component, the proposed General Plan Amendment and Zone Change would allow for additional housing opportunities that is compliant with the Merced Multi-Jurisdictional Housing Element.

Although population growth would occur in an area currently designated for commercial development, the objectives of the City’s RHNA requirements will be met as a result of the project through the addition of 570 residential lots that have been allocated for the City planning area.

The analysis provided in this document indicates that City services are sufficient or will be sufficient to accommodate growth resulting from the project in addition to meeting the City’s RHNA requirements. Therefore, although population growth would occur as a result of the project, this growth can be accommodated and would result in a less than significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.14b – Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? The project site is currently undeveloped and does not propose the demolition or removal of existing people or housing. The project sites will not displace existing people or housing, necessitating the construction of replacement housing elsewhere. Therefore, the project would have no impact.

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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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City of Merced Page 3-102

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.15 - 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 to other
performance objectives for any of the public
services:
i. (i) Fire protection?
ii. (ii) Police protection?
iii. (iii) Schools?
iv. (iv) Parks?
v. (v) Other public facilities?

Discussion
Impact #3.4.15a(i) – Would the Project 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 to other performance objectives for any of the public services - Fire Protection? Fire protection for the project is provided by the City Fire Department (MFD). The City maintains five stations strategically located throughout the City limits with the nearest station located approximately two miles west of the project site. Per the General Plan, the MFD has a goal of maintaining a response time of four to six minutes for the first crew to arrive at a fire or medical emergency within an assigned district (City of Merced 2012).

The General Plan has adopted policies and actions that require emergency access design standards, adequate water supply for fire suppression is available for new residential developments and requiring new development to provide or pay for its fair share of public facility and infrastructure improvements. The Fire Code contains provisions designed to □
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improve fire safety in structures, including installation of sprinkler systems, alarm systems, and portable fire extinguishers, along with requirements for hydrants and fire flows. The project also would be subject to the City’s adopted Building and Electrical Codes with their applicable provisions related to fire safety, including the installation of smoke detectors and sprinkler systems. Entryways would be constructed to City standards, which consider emergency vehicle accessibility. Compliance with these requirements would minimize fire risk to residents and buildings of the proposed project development.

Buildings constructed as part of the project would be required to comply with the 2019 California Fire Code, as amended by the City in Merced Municipal Code Chapter 17.32 New development is required under Merced Municipal Code Chapter 17.62 to pay Public Facility Impact Fees to the City for future construction or improvement of Fire Department facilities, among other capital improvements. The Public Facility Impact Fee for single-family development is $13,102 per dwelling unit (City of Merced 2025). These impact fees will fund needed capital facilities and infrastructure generated by new development over the next 20 years. Capital projects included in the fee calculations are arterial streets, traffic signals, bridges, railroad crossings, fire stations, police facilities, community parks, bikeways, smart technology, and other public facilities (City of Merced 2025). Compliance with the applicable codes and City standards, along with payment of fees, would reduce project impacts on fire protection services to a level that would be less than significant. Therefore, the impact would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(ii) – Would the Project 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 to other performance objectives for any of the public services – Police Protection? The City of Merced Police Department provides law enforcement services to City of Merced, including the project site. Merced is divided into three police districts, each with its own police facility and officers. The service standard used for planning future police facilities is approximately 1.32 sworn officers per 1,000 population. The nearest police station is located approximately 3.3 miles west of the project site (City of Merced 2012).

The project will increase the local population by developing a 570-lot single-family residential development with approximately 9 acres of commercial area. The resulting impacts on police services related to acceptable service ratios, response times, or other performance objectives of police protection services are anticipated to be impacted.

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The Police Department anticipates that at least one new police station would be needed to serve the City’s population. While the proposed project would not necessarily require new police facilities, new development is required to pay Public Facility Impact Fees to the City, which would in part pay for a new central station that is planned (City of Merced 2021). With payment of Public Service Impact Fees, project impacts related to police protection services would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(iii) – Would the Project 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 to other performance objectives for any of the public services – Schools? School services within the majority of the Merced Planning Area are provided by the Merced City School District (elementary and middle schools); Merced Union High School District; Weaver Union School District; and McSwain Union Elementary School District. The nearest school is Pioneer Elementary School located approximately 0.25 miles west of the project site. Tenaya Middle School and Merced High School are approximately 3.5 miles northwest of the project site.

The increased population generated by the proposed project would increase the number of students attending local schools and could result in significant impacts to these facilities by requiring new facilities. The developer will be required to pay the appropriate school impact fees in order to receive building permits. According to Government Code Section 65996, the development fees authorized by SB 50 are deemed “full and complete school facilities mitigation.” School districts would utilize the General Plan and codes to establish new school sites and make decisions on school amenities and facility size. The development will be subject to school impact fees to reduce increased impacts on school facilities to less than significant levels.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Impact #3.4.15a(iv) – Would the Project 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 to other performance objectives for any of the public services – Parks? The City has a well-developed network of parks and recreation facilities, with a 2010 inventory of parkland within the City being 328 acres of developed parkland. The City of Merced utilizes five acres per 1,000 population standard.

The proposed project intends to develop a 570-lot single-family residential development which would result in the increased use of existing neighborhood and regional parks as an increase in local population would occur. However, the proposed project would include development of 2.8 acres of open space. The U.S. Census estimates an average household size of 3.41 for the City of Merced (U.S. Census Bureau 2024). Therefore, an estimated 1,938 increase in population size would occur as a result of the project. Pursuant to the City of Merced 2004 Parks and Recreation Master Plan, an additional need of school parks/neighborhood parks, large urban/community parks, special use areas, and linear parks was identified. Neighborhood parks are defined as a combination of playground and park space, designed primarily for non-supervised, non-organized recreation activities generally small (about 3 to 7 acres in size) and serve an area of approximately a one-half mile radius. School parks are park facilities, usually in similar size to neighborhood park facilities that are developed adjacent to or on school grounds. Community parks in general are designed for organized activities and sports, much larger in area and offer more facilities.

The optimum size is between 15 and 20 acres and service an area roughly 1 to 2 miles in radius. Large urban parks are designed to service the entire community and provide a wide variety of specialized facilities such as sports fields, indoor recreation areas, and large picnic areas. These parks often exceed 50 acres in size. Special use areas are miscellaneous public recreation areas or land occupied by a specialized facility including community centers, skate parks, community gardens or sites occupied by buildings. Linear parks are defined as open spaces or developed landscape areas that follow linear corridors such as creek corridors, canals, trail corridors, abandoned railroad rights-of-way, canals, and other elongated features.

As noted, the proposed project includes the development of approximately 3.0 acres of open space that will count towards the established parkland to population ratio identified in the General Plan. The amount of park space proposed does not offset the entirety of the approximate population increase associated with the project. Therefore, the proposed project could 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 or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment. Furthermore, the project would be required to pay all applicable impact fees related to parks and recreation. Therefore, with the proposal for open space and payment of impact fees related to parks and recreation, impacts of the project related to parks and recreational spaces would be less than significant.

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City of Merced Page 3-106

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(v) – Would the Project 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 to other performance objectives for any of the public services – Other Public Facilities?
See Impact #3.4.15a(i) through (iv) above.

The closest library to the project site is located approximately 3.5 miles northwest of the project site. The nearest healthcare center to the project site is located 3.5 miles northwest.

The nearest hospital is located approximately 4.6 miles north of the project site.

As noted in Impact #3.4.14a, the Project does not promote unplanned growth or development. As such, the development of the Project will minimally increase the demand for other public services, such as libraries and health services. However, the increase in demand will not in and of itself require the construction of additional facilities. As such, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.16 - 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?
b. Include recreational facilities or require the
construction or expansion of recreational
facilities that might have an adverse physical
effect on the environment?

Discussion
Impact #3.4.16a – Would the project 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?
As noted above in Impact #3.4.15a(iv), the proposed project intends to develop a 570-lot single-family residential development and the dedication of approximately 4.6 acres of park/open space. Development of the proposed project would require payment of in-lieu fees for parkland dedication to the Recreation and Park District in compliance with Government Code Section 66477 (Quimby Act), which would reduce potential impacts to less than significant levels.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.16b – Would the Project include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
See Impact #3.4.16a above.
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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Discussion
The analyses in this section are based on a Transportation Impact Study (VRPA Technologies, Inc. 2025b) attached as Appendix G. The Study considered build out of a larger number residential lot than what is currently proposed. Therefore, it can be assumed that the trips estimates resulting from the project would be less than those discussed in this IS/MND.

Impact #3.4.17a – Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Transit
The City of Merced is served by a local public bus system, inter-regional private bus companies, and private taxicabs, as well as rail and air passenger services that are both dealt with under separate headings. “The Bus”-Merced County Transit system includes the City Shuttle plus the former Merced County MARTS and the Los Banos system. “The Bus” operates on 16 fixed routes and also provides demand responsive service. Weekday and Saturday service is provided. Through MCAG, the City continues to contribute its representative portion of funds necessary for the operation of the expanded, regional system. These funds help to maintain the existing system as well as provide for new equipment such as communications gear, bus shelters, and replacement vehicles.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.17 - TRANSPORTATION
Would the Project:
a. Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b)?
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible
uses (e.g., farm equipment)?
d. Result in inadequate emergency access?
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Bicycle/Pedestrian Facilities
The City Transportation and Circulation Element identified the following roadways in vicinity of the project site for existing or future bike land facilities:
• Campus Parkway east of Coffee Street (Existing Class I, Pathway) • Gerard Avenue (Proposed Class II, Lane)
• Mission Avenue (Proposed Class II, Lane)
• Coffee Street (Existing Class II, Lane)
According to the bikeway design criteria established by Caltrans, these bikeway classifications are defined as follows:
• Class I Bikeways (Bike Paths): Class I bikeways (bike paths) are facilities with exclusive right of way, with cross flows by vehicles minimized. Motor vehicles are prohibited from bike paths, which can be reinforced by signing. • Class II Bikeways (Bike Lanes): Class III Bikeways (Bike Route) are shared routes and do not require pavement markings. In some instances, a 4-inch white edge stripe separating the traffic lanes from the shoulder can be helpful in providing for safer shared use.
• Class III Bikeways (Bike Lanes): Class III bikeways (bike routes) are intended to provide continuity to the bikeway system. Bike routes are established along through routes not served by Class I, II, or IV bikeways, or to connect discontinuous segments of bikeways (normally bike lanes). Class III facilities are facilities shared with motor vehicles or pedestrians, which are designated by signs or permanent markings.

Roadways
The State of California does not recognize traffic congestion and delay as an environmental impact per CEQA. However, under Goal Area T-1, Policy T-1.8 the City General Plan Circulation Element has designated level of services (LOS) “D” as the minimum acceptable LOS standard. The Transportation Research Board Highway Capacity Manual, 7th Edition, (HCM) defines level of service (LOS) as, “a quantitative stratification of a performance measure or measures representing quality of service. The measures used to determine LOS for transportation system elements are called service measures. The HCM defines six levels of service, ranging from A to F, for each service measure or combination of service measures.

LOS A represents the best operating conditions from the traveler’s perspective and LOS F the worst.”
To assess the impacts that the project may have on the surrounding roadway network, the first step is to determine project trip generation. project trip generation was determined using trip generation rates from the Institute of Transportation Engineers (ITE) Trip Initial Study

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Generation Manual (11th Edition) and the ITE Trip Generation Handbook (3rd Edition). The considerations described above led to the recommended trip generation for weekday AM (7:00-9:00am) and PM (4:00- 6:00pm) peak hours shown in Table 3.4.17-1.

Table 3.4.17-1
Project Trip Generation
Land
Use/ITE
Land Use
Code
Quantity Daily Trip Ends
(ADT)
Weekday AM Peak Hour Weekday PM Peak Hour
Rate Volume Rate In/Out
Split
Volume Rate In/Out
Split
Volume
In Out Total In Out Total
SingleFamily
Residential
(210)
587
Units

8.75 5,141 0.70 25:75 93 28 373 0.94 63:37 330 195 525
Shopping
Plaza
(821)
49,550
sq. ft.

67.52 3,346 1.73 62:38 53 33 86 5.19 49:51 126 131 257
Office
(710)
49,550
sq. ft.

10.84 630 1.52 88:12 81 11 92 1.44 17:83 16 77 93
9,117 227 324 551 472 403 875
Internal Vehicle Trips (10%) 912 23 32 55 47 40 88
Passby Trips/Retail Only 1,004 16 10 26 38 39 77
Total External Trip Generation 7,202 188 282 470 387 323 710 Source: (VRPA Technologies, Inc. 2025b)
The Transportation Impact Study (TIS) in consultation with City of Merced staff identified the following intersections for study.

1. Gerard Avenue and Pluim Drive

2. Gerard Avenue and Campus Parkway

3. Mission Avenue and State Route (SR) 99 SB Off Ramp

4. Mission Avenue and SR 99 NB Off Ramp

5. Campus Parkway and Pluim Drive (With Project Scenario Only)

6. Mission Avenue and Pluim Drive (With Project Scenario Only) The City considers levels of service ‘D’ or better to be acceptable, while levels of service ‘E’ and ‘F’ are considered unacceptable. At unsignalized intersections where a substandard level of service exists, traffic signals would only be recommended if warrants for traffic signals are satisfied. The satisfaction of a traffic signal warrant doesn’t, in and of itself, require the installation of a traffic signal. Safety and/or the overall operation of the intersection should be the basis of the installation of a traffic signal. Other improvements, such as the installation of dedicated left/right turning movements, should also be considered for the purpose of alleviating substandard levels of service at an intersection.

The 2030 Merced County General Plan establishes measures of performance for the county roadway systems. The General Plan identifies LOS ‘D’ during weekday peak hours in urban _J
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area and for rural connectors between urban areas (including freeways) and LOS ‘C’ for other rural roadways.

With the changes brought about by SB 743, Caltrans no longer uses level of service to determine the need for transportation improvements. Instead, the focus is on providing adequate facilities for pedestrians, bicycles, and transit as well as safety considerations for all transportation modes. Guidance is provided in the Transportation Impact Study Guide dated May 20, 2020, and the Interim Land Development and Intergovernmental Review Safety Review Practitioners Guidance dated July 2020. This guidance was used in determining the need for roadway improvements on Caltrans facilities.

The intersection level of service (LOS) analysis for the study intersections depicted in the Table 3.4.17-2 show that all the study intersections currently operate at acceptable levels of service considering the LOS threshold.

Table 3.4.17-2
Intersection Operations
Intersection Control Target
LOS
Peak
Hour
Existing Opening Year
Plus Project
Horizon Year
2046 without
Project
Horizon Year
2046 plus
Project
Gerard Avenue /
Pluim Drive
One-way
Stop Sign
(Two-Way
Stop w/
Project
D AM 11.5 B 13.0 B 12.0 B 13.5 B
PM 9.5 A 10.3 B 10.0 B 11.0 B
Gerard Avenue /
Campus Parkway
Signalized D AM 13.5 B 13.7 B 15.0 B 15.3 B
PM 13.1 B 13.8 B 13.8 B 14.2 B
Mission Avenue /
SR 99 SB OffRamp
Signalized - AM 19.1 B 21.1 B 21.7 C 22.4 C
PM 18.4 B 18.5 B 20.4 C 20.6 C
Mission Avenue /
SR 99 BN OffRamp
Signalized - AM 19.5 B 21.4 C 36.6 D 49.4 D
PM 19.7 B 21.1 B 35.5 D 49.5 D
Campus Parkway
/ Pluim Drive
(with Project
only)
Signalized D AM - - 25.4 C - - 26.5 C
PM - - 26.1 C - - 26.2 C
Mission Avenue /
Pluim Drive (with
Project only)
One-way
Stop Sign
D AM - - 9.1 A - - 9.3 A
PM - - 9.3 A - - 9.5 A
Source: (VRPA Technologies, Inc. 2025b)
The results of the analysis show that all the study intersections currently operate at acceptable levels of service considering the City of Merced LOS criteria.

In addition to the LOS analysis, a queuing analysis was conducted for the TIS. The queuing analysis considered the existing storage pocket lengths and found that study intersections currently support the traffic volumes at existing study intersections. Queuing conditions for left and right-turn lanes at all study intersections are based upon Section 400 of Caltrans’ Highway Design Manual. The results of the queuing analysis as provided in the TIS indicate that traffic at the northbound right approach for the Mission Avenue and SR 99 NB Off-Ramp intersection will exceed the existing 425-foot storage pocket during the AM and PM perk hour for the Horizon Year 2046 scenario. Therefore, it is recommended in the TIS that the Initial Study

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northbound right storage pocket at the Mission Avenue and SR 99 NB Off-Ramp intersection be lengthened from 425 feet to 575 feet. To ensure that the recommended improvement is addressed, Mitigation Measure MM TRA-1 will be implemented, and the project proponent will contribute their fair share payment for fees associated with improvements to the impacted intersection. Payment of these equitable share costs would ensure that the project’s impacts to the identified intersection would be less than significant.

Construction related traffic is anticipated to be short-term and would not significantly impact existing or planned circulation infrastructure. The proposed operation of the project would result in no significant LOS impacts to the studied intersections as identified in the TIS. To address queuing deficiencies as a result on the project at the Horizon Year 2046 scenario, the TIS recommends that the project proponent pay its equitable share costs percentage for intersection improvements pertaining to the storage pocket length at the northbound right approach at the Mission Avenue and SR 99 NB Off-Ramp intersection.

Payment of equitable share costs is provided as Mitigation Measure MM TRA-1. Therefore, the project will not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities with compliance of MM TRA-1 and would have a less-than-significant impact

MITIGATION MEASURE(S)
TRA-1: The project proponent shall pay its equitable share costs percentages for intersection improvements pertaining to the storage pocket length at the northbound right approach at the Mission Avenue and SR 99 NB Off-Ramp intersection.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation implemented.

Impact #3.4.17b – Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
The new CEQA Guidelines Section 15064.3, subdivision (b) was adopted in December 2018 by the California Natural Resources Agency. These revisions to the CEQA Guidelines criteria for determining the significance of transportation impacts are primarily focused on projects within transit priority areas and shift the focus from driver delay to a reduction of greenhouse gas emissions, creation of multimodal networks, and promotion of a mix of land Initial Study

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uses. Vehicle Miles Traveled, or VMT, is a measure of the total number of miles driven to or from a development and is sometimes expressed as an average per trip or per person.

VMT analysis was conducted according to MCAG VMT Thresholds and Implementation Guidelines (VRPA TECHNOLOGIES, INC. 2025A). For mixed-use projects, the guidelines recommend analyzing each land use individually while taking credit for internal trip capture.

The VMT analysis for each of the project’s three land uses (office, shopping plaza, and singlefamily residential) is described below:
• For the office land use, the project site is located in a VMT-efficient area according to the VMT per Employee Screening Map for Merced County. Therefore, the office land use is screened out of further VMT analysis and has a less than significant VMT impact. • The shopping plaza land use is considered to be a retail development that is screened out of further VMT analysis due to land use type. Therefore, the shopping plaza land use has a less than significant VMT impact.
• For the single-family residential land use, the project is located in an area that has less than the average VMT per capita but is above the VMT significance threshold of 85% of average VMT/capita or below. However, the project has an internal trip capture of 912 daily trips as compared to 5,141 daily trips generated by the single-family residential land use. After applying credit for internal trip capture, the trip generation of the single-family residential land use would be reduced by 17.7% (921/5,141).

Therefore, the resulting VMT per capita for the single-family residential land use is

17.7% or more below average and meets the VMT threshold of at least 15% below average
Since all three components of the project have a less than significant VMT impact, the project as a whole has a less than significant VMT impact and no mitigation measures are needed.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.17c – Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Construction
The proposed Project may be required to obtain a traffic control permit and implement a traffic control plan (TCP) for construction occurring on City road right-of-way, such as the construction of new access points from Gerard Avenue and Pluim Drive to the proposed Initial Study

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Project site. If required, the TCP would demonstrate appropriate traffic handling during construction activities that could impact the traveling public (e.g., the transport of equipment and materials to the project area); thus, any increased hazards related to traffic and transportation during construction would be minimized. In accordance with existing requirements, the proposed project would be subject to review by City staff to ensure safety standards are met during construction activities. Therefore, the impact related to transportation hazards during construction would be less than significant.

Operation
The project will not include any geometric design features or incompatible uses that would substantially increase hazards. All road improvements would be constructed according to local road standards. Additionally, the proposed project would be subject to review by City staff, which would ensure the project design would comply with all applicable industry roadway design standards. Therefore, the proposed project would not substantially increase hazards due to a design feature or incompatible uses, and the impact would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.17d – Would the Project result in inadequate emergency access? The proposed project would be required to comply with all emergency access requirements adopted and set forth in the City Municipal Code. Project site development will be required to comply with applicable emergency access standards from local and State authorities.

As described above, increased project-related traffic would not cause a significant increase in congestion and or significantly worsen the existing service levels at intersections on area roads; therefore, project-related traffic would not affect emergency access to the project site or any other surrounding locations. The proposed project would not require closures of public roads, which could inhibit access by emergency vehicles. For these reasons, construction and operation would have a less-than-significant impact on emergency access.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.18 - TRIBAL CULTURAL RESOURCES
Would the Project:
a. 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
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.

Discussion
The discussion below is based on the Cultural Resources Study and Evaluation completed for the project, attached as Appendix C (Applied EarthWorks, Inc. 2024).

Impact #3.4.18a(i) – 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 – 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)?
See the discussion presented in Section 3.4.5 - Cultural Resources, Impacts #3.4.5a through

3.4.5c.
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As part of the Cultural Resources Study and Evaluation, a list of individuals to be contacted for information regarding tribal cultural resources was supplied by the NAHC and letters were sent on July 30, 2024. These letters were submitted to individuals’ part of the Amah Mutsun Tribal Band, the North Fork Rancheria of Mono Indians, the Northern Valley Yokut Ohlone Tribe, the Southern Sierra Miwuk Nation, Tule River Indian Tribe, and the Wuksashi Indian Tribe/Eshom Valley Band. Responses from these individuals indicate that there are no tribal cultural resource concerns within the project area.

On April 28, 2025, pursuant to Public Resources Code §21080.3.1 and Government Code §65300 et seq, letters were sent to each of the Native American tribes within the geographic area as identified by the NAHC. The letters included a project description and location maps.

To date, no responses have been received from the tribes that were contacted.

Upon any ground-breaking activity, there is the possibility of uncovering an object of cultural value. Mitigation Measures MM CUL-1 through MM CUL-3 must be implemented if any artifacts or human remains are discovered. Therefore, the project would have a less-thansignificant impact with mitigation incorporated.

MITIGATION MEASURE(S)
Implementation of Mitigation Measures MM CUL-1 through MM CUL-3.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.18a(ii) – 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 – 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? See discussion for Impacts #3.4.5a through#3.4.5c and Impact #3.4.18a(i) above.

MITIGATION MEASURE(S)
Implementation of Mitigation Measures MM CUL-1 through MM CUL-3.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.19 - UTILITIES AND SERVICE SYSTEMS
Would the Project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment, or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
b. Have sufficient water supplies available to
serve the Project and reasonably foreseeable
future development during normal, dry and
multiple dry years?
c. Result in a determination by the wastewater
treatment provider that 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.
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?
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?

Discussion
Impact #3.4.19a – Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment, or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Wastewater
Wastewater (sanitary sewer) collection and treatment in the Merced urban area is provided by the City of Merced. The wastewater collection system handles wastewater generated by residential, commercial, and industrial uses in the City. The City Wastewater Treatment □ □ □
□ □ □
□ □ □
□ □ □
□ □ □
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-119
Plant (WWTP), located in the southwest part of the City about two miles south of the Airport, has been periodically expanded and upgraded to meet the needs of the City’s growing population and new industry. The City’s wastewater treatment facility has a permitted capacity of 10 million gallons per day (mgd), with an average 2008 flow of 8.5 mgd (City of Merced 2012). The City has initiated an expansion project to increase capacity to 12 mgd and upgrade to tertiary treatment with the addition of filtration and ultra-violet disinfection.

Future improvements would add another 8 mgd in capacity (in increments of 4 mgd), for a total of 20 mgd. This design capacity can support a population of approximately 150,000.

The collection system will also need to be expanded as development occurs. Treated effluent is disposed of in several ways depending on the time of year. Most of the treated effluent (75% average) is discharged to Hartley Slough throughout the year. The remaining treated effluent is delivered to a land application area and the on-site City-owned wetland area south of the WWTP.

City of Merced General Plan Policy P-1.3 and its associated Implementing Actions 1.3.c through 1.3.d would be applicable to the project including new development payment for fair share costs of on-site and off-site public infrastructure and municipal services.

Compliance with existing regulations will ensure the resultant level of impact from implementation of project would be maintained at a less than significant level.

Stormwater
The City General Plan has adopted Goal P-5 to provide an adequate storm drainage collection and disposal system. Policy P-5.1 and its associated Implementing Actions require the provision of effective storm drainage facilities for future development and implementation of the City’s Storm Water Master Plan and Storm Water Management Plan. Therefore, compliance with the City’s Stormwater Master Plan and Storm Water Management Plan will ensure that development of the project would result in less than significant project impacts.

Water
See Impact #3.4.10b.

As discussed, groundwater the City obtains its water from local aquifers through 20 active wells. The City has an estimated service population of approximately 99,100 people. In 2020, approximately 20,076 acre-feet (6,542 million gallons) of water was delivered to an estimated 22,969 water service connections of which approximately 67% of the water use is for residential services. The remainder are for educational, commercial and industrial uses.

The city currently utilizes local groundwater as its source of water supply.

Water needed for construction will be obtained from the City, who has indicated sufficient water to supply the project. The current water distribution system is adjacent to the project site. The construction process is estimated to take place in stages during an approximately seven-year period. During this seven-year period, it is assumed that each acre of land will require a total of one year to construct. Construction water demands are estimated to be approximately 225 gpd/acre for the duration of construction or 17.34 acre-feet, which is Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-120
equivalent to approximately 5,650,200 gallons (225 gpd/acre x 68.8 total acres to be developed x 365 days per acre). Bottled drinking water will be provided for crews during construction activities. Initial construction water usage will be in support of site preparation and grading activities. During earthwork for grading of access road foundations, building foundations and project components, the principal use of water would be for compaction and dust control. Smaller quantities would be required for the preparation of the concrete required for foundations and other infrastructure. After the earthwork activities, water usage will be used for dust suppression and normal construction water requirements that are associated with construction of the buildings, internal access roads, and revegetation.

The long-term average day operational water demand will be for the residential and commercial users and is anticipated to be approximately 131.8 gallons per year or 404.48 acre-feet per year for the total build out of the project. This is based on each residential unit having an average day water demand of 633.5 gallons per day (based on the 181-gallon per capita/day average and 3.5 people per lot as estimated in the City’s UWMP) across the entire buildout of 570 lots. The water demand for the 9-acre commercial development is estimated to be 2.16 million gallons per year or 7.71 acre-feet per year (based on a commercial water use of 650 gpd/acre).

As noted in Impact #3.4.10b, the UWMP considered population growth from 2025 to 2040.

The project water demand is included in the projected increase in water demand if a fifth dry year of 19,534 AF from 2025 to 25,460 AF 2040 (Table 3.4.10-3). The project long-term operational water demand is 1.58% (404.48 AF/25,460 AF) of the available water supply in the City and therefore a less than significant impact is foreseen. Utilizing data from the UWMP, it was found that the anticipated water supply for the City would be sufficient to accommodate the project (QK 2025).

Electricity
The Pacific Gas and Electric Company (PG&E) provides electricity to the City. The Merced Irrigation District also provides electrical service to some customers in the area. Telephone service is provided by various vendors. Cable television is available from Comcast, and satellite television is available from several sources. Similarly, cellular telephone service can be purchased from several vendors. Existing poles with attached electrical and communication lines are situated along Parsons Avenue along the western boundary of the project site. State-regulated franchise utilities are obligated to extend services to new development sites as necessary. The project will connect to existing PG&E infrastructure.

Project impacts are anticipated to be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-121
Impact #3.4.19b – Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years?
See Impact #3.4.10b.

Water needed for construction will be obtained from the City of Merced which obtains groundwater from wells located on land within the City. The current water distribution system is adjacent to the project site. The construction process is estimated to take place in stages during an approximately seven-year period. During this seven-year period, it is assumed that each acre of land will require a total of one year to construct. Construction water demands are estimated to be approximately 225 gpd/acre for the duration of construction or 17.34 acre-feet, which is equivalent to approximately 5,650,200 gallons (225 gpd/acre x 68.8 total acres to be developed x 365 days per acre). Bottled drinking water will be provided for crews during construction activities. Initial construction water usage will be in support of site preparation and grading activities. During earthwork for grading of access road foundations, building foundations and project components, the principal use of water would be for compaction and dust control. Smaller quantities would be required for preparation of the concrete required for foundations and other minor uses. After the earthwork activities, water usage will be used for dust suppression and normal construction water requirements that are associated with construction of the buildings, internal access roads, and revegetation.

The long-term average day operational water demand will be for the residential and commercial users and is anticipated to be approximately 131.8 million gallons per year or 404.48 acre-feet per year for the total build out of the project. This is based on each residential unit having an average day water demand of 633.5 gallons per day (based on the 181-gallon per capita/day average in the 2020 City of Merced Urban Water Management Plan and 3.5 people per lot) across the entire buildout of 570 lots for the project. The water demand for the 9-acre commercial development is estimated to be 2.16 million gallons per year or 7.71 acre-feet per year (based on a commercial water use of 650 gpd/acre).

As found in the prepared WSA, utilizing data from the UWMP, it was found that the anticipated water supply for the City of Merced would be able to accommodate the project.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19c – Would the Project result in a determination by the wastewater treatment provider that 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? Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-122
See Impact #3.4.19a above.

The project would place additional demand on the City’s wastewater collection and treatment system. The City of Merced Wastewater Collection System Master Plan 2022 Update provides an average per capita flow of 65 gallons per day per capita (City of Merced 2023). Based on the estimates, the residential component of the project would result in approximately 118,560 gallons per day (0.12 million gallons per day [mgd]) of wastewater generation. With regard to the commercial component of the project, wastewater generation for Business Park land uses is approximately 1,214 gallons per day per acre. Therefore, the commercial component of the project would result in approximately 10,926 gallons per day (0.01 mgd). The City’s wastewater treatment facility currently has capacity of 7.02 mgd on average, and there are plans address in the Wastewater Collection System Master Plan to expand facility capacity by up to 14.21 mgd to meet future build out of the planning area. In consideration of current capacity, the project would result in a 1.85% increase in wastewater. Thus, the City’s wastewater treatment facility would have adequate capacity to accommodate wastewater generated by the project.

Pursuant to identified General Plan Goals, Policies, and Implementing Actions related to wastewater, the project will be required to pay fair share costs for of on-site and off-site public infrastructure and municipal services. City will collect those fair share costs to ensure that adequate capacity is available for the project, and impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19d – Would the Project 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?
During construction, debris and waste generated, which are not anticipated to contain hazardous materials, would be collected and transported away from the site. Once constructed, the proposed project would produce typical refuse generated by residential, office, and commercial uses. Waste would be placed in covered receptacles or dumpsters and removed on a regular basis for disposal at a Class III landfill by the certified waste-handling contractor that services the area. Landfills are maintained by the Merced County Regional Waste Authority, with the closest landfill to the project site being the Highway 59 Landfill.

The Highway 59 Landfill has 28 million cubic yards of remaining capacity (CalRecycle 2025) and, thus, can accommodate the proposed project’s operational solid waste generation.

Impacts from project construction would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-123

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19e – Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste? See discussion for Impact #3.4.19d.

The proposed project would be required to provide solid waste and recycling services for residents pursuant to the California Solid Waste Reuse and Recycling Access Act of 1991.

This service will be provided by American Refuse. Furthermore, the proposed project would be required to comply with all federal, state, and local statutes and regulations related to the handling and disposal of solid waste. Therefore, implementation of the proposed project would result in less than significant impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-124

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.20 - 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?
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose Project occupants to, pollutant
concentration from a wildfire or the
uncontrolled spread of a wildfire?
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?
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?

Discussion
Impact #3.4.20a – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
See also Impact #3.4.9f regarding emergency response.

Cal Fire’s Fire and Resource Assessment Program identifies fire threat based on a combination of two factors: 1) fire frequency, or the likelihood of a given area burning, and 2) potential fire behavior (hazard). These two factors are combined in determining the following Fire Hazard Severity Zones: Moderate, High, Very High, Extreme. These zones apply to areas designated as State Responsibility Areas – areas in which the State has primary firefighting responsibility. According to CAL FIRE, the project site is located within an LRA Unzoned designated area (Cal Fire 2007). Given this designation, the project site is □ □ □
□ □ □
□ □ □
□ □ □
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-125
outside of areas identified by CAL FIRE as having substantial or very high wildfire risk. As noted previously, the project will adhere to the standards set forth in the City of Merced Municipal Codes. The project would also comply with the appropriate local and State requirements regarding emergency response plans and access. The proposed project would not inhibit the ability of local roadways to continue to accommodate emergency response and evacuation activities.

The proposed project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, the project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20b – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to, pollutant concentration from a wildfire or the uncontrolled spread of a wildfire? The project site is not located in or near a State Responsibility Area and the Project will implement State and local fire code requirements. As such, the project would not exacerbate the risk of exposure of project occupants to wildfire and impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20c – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project 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?
See Impacts #3.4.9a and g, #3.4.20a and b above.

The residential portion of the project would be accessed via future Pluim Drive to the west, East Mission Avenue to the south, and East Gerard Avenue to the north. The commercial Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-126
areas have frontage along future Pluim Drive and Campus Parkway. All road improvements would be completed in accordance with the applicable Public Works standards and specifications. Additionally, the project would extend service laterals for potable water and other utilities from existing lines. Furthermore, the project would be required to be consistent with the California Fire Code and City of Merced Fire Code. Therefore, the project would not exacerbate fire risk or result in temporary or ongoing impacts to the environment, and impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20d – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, postfire slope instability, or drainage changes? See Impacts # 3.4.9a and g, #3.4.20a, b, and c above.

The project is not located near State Responsibility Areas or lands classified as very high fire hazard severity zones. The City and the project site are topographically flat land. There are no slopes on or near the property, and the project would not expose the people or structures to significant risks from downslope or downstream flooding or landslides due to a result of runoff, post-fire instability, or drainage changes.

Therefore, the project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-127

Discussion
Impact #3.4.21a – 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 animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
As evaluated in this IS/MND, the proposed project would not substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or animal community; 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. With implementation of the mitigation measures recommended in this

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.21 - 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
animal community, substantially reduce the
number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of
California history or prehistory?
b. Does the Project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
Project are significant when viewed in
connection with the effects of past Projects,
the effects of other current Projects, and the
effects of probable future Projects.)
c. Does the Project have environmental effects
that would cause substantial adverse effects
on human beings, either directly or
indirectly?
□ □ □
□ □ □
□ □ □
Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-128
document, the proposed project would not have the potential to degrade the quality of the environment, significantly impact biological resources, or eliminate important examples of the major periods of California's history or prehistory. Therefore, with the following mitigation measures, the project would have a less-than-significant impact.

MITIGATION MEASURE(S)
Implementation of Mitigation Measures MM BIO-1 through MM BIO-6, MM CUL-1 through MM CUL-3, and MM GEO-2.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.21b - Does the Project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a Project are significant when viewed in connection with the effects of past Projects, the effects of other current Projects, and the effects of probable future Projects.)? As described in the impact analyses in Sections 3.4.1 through 3.4.20 of this IS/MND, any potentially significant impacts of the proposed project would be reduced to a less-thansignificant level following the incorporation of the mitigation measures listed. The proposed project would not otherwise combine with impacts of related development to add considerably to any cumulative impacts in the region. With mitigation, the proposed project would not have impacts that are individually limited but cumulatively considerable.

Therefore, the project would have a less-than-cumulatively-considerable impact with mitigation incorporated.

MITIGATION MEASURE(S)
Implementation of Mitigation Measures MM AIR-1, MM BIO-1 and MM BIO-6, MM CUL-1 through MM CUL-3, MM GEO-1 through MM GEO-2, MM NSE-1 through MM NSE-3, MM NSE4, and MM TRA-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.21c - Does the Project have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly? All of the project’s impacts, both direct and indirect that are attributable to the project were identified and mitigated. The project mitigation measures will substantially reduce or eliminate the impacts of the project. Therefore, the proposed project would not either directly or indirectly cause substantial adverse effects on human beings because all potentially adverse direct impacts of the proposed project are identified as having no impact, less than significant impact, or less than significant impact with mitigation.

Initial Study

Merced Gateway Project May 2025
City of Merced Page 3-129

MITIGATION MEASURE(S)
Implementation of Mitigation Measures MM AIR-1, MM BIO-1 and MM BIO-6, MM CUL-1 through MM CUL-3, MM GEO-1 through MM GEO-2, MM NSE-1 through MM NSE-3, MM NSE3, and MM TRA-1.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

List of Preparers

Merced Gateway Project May 2025
City of Merced Page 4-1
SECTION 4 - LIST OF PREPARERS
Lead Agency- City of Merced
• Jonnie Lan, AICP, Interim Planning Manager, City of Merced Consultants –
QK
• Jaymie Brauer – Project Manager QA/QC
• Thomas Kobayashi – Lead Author
Bibliography

Merced Gateway Project May 2025
City of Merced Page 5-1
SECTION 5 - BIBLIOGRAPHY
Applied EarthWorks, Inc. 2024. "Cultural Resource Study and Evaluation for Merced Gateway."
Cal Fire. 2007. "Draft Fire Hazard Severity Zones in LRA." Accessed September 2024. https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/- /media/osfm-website/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-map/upload2/fhszl06_1_map24.pdf.

CalGEM. 2024. Well Finder. Accessed July 2024.
https://maps.conservation.ca.gov/doggr/wellfinder/.

California Department of Conservation. 2024. California Important Farmland Finder.

Accessed September 2024. https://maps.conservation.ca.gov/DLRP/CIFF/.

California Department of Toxic Substances Control. 2024. California Department of Toxic Substances Control, Envirorstor. https://www.envirostor.dtsc.ca.gov/public/map/.

California Department of Transportation. 2024. California Scenic Highway Mapping System.

Accessed September 2024.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d80 7c46cc8e8057116f1aacaa.

California Energy Commission. 2022b. California Energy Commission, Electricity Consumption by County. Accessed January 2025.
https://ecdms.energy.ca.gov/elecbycounty.aspx.
—. 2022a. California Energy Commission, Gas Consumption by County. Accessed January 2025. http://www.ecdms.energy.ca.gov/gasbycounty.aspx.

CalRecycle. 2025. Calrecycle SWIS Facility. Accessed January 2025. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2908?siteID=186

3. City of Merced. 2025. "City of Merced Public Facilities Impact Fees." City of Merced Development Applications and Fee Schedules. January. Accessed March 2025. https://www.cityofmerced.org/home/showpublisheddocument/21920/63870217 6355600000.

City of Merced. 2023. "City of Merced, Wastewater Collection System Master Plan 2022 Update."
City of Merced. 2012. "Merced Vision 2030 General Plan." Bibliography

Merced Gateway Project May 2025
City of Merced Page 5-2
Federal Highway Administration (FHWA), U.S. Department of Transportation. 2017. "Highway Traffic Noise Analysis and Abatement Policy and Guidance." https://www.fhwa.dot.gov/environMent/noise/regulations_and_guidance/.

Federal Motor Carrier Safety Administration. 2024. "FMCSA National Hazardous Materails Route Registry." National Hazardous Materials Route Registry - By State, California.

Accessed September 2024. https://www.fmcsa.dot.gov/regulations/hazardousmaterials/national-hazardous-materials-route-registry-state.

Krazan and Associates, Inc. 2024. "Phase I Environmental Site Assessment, Campus Gateway Development."
Live Oak Associates, Inc. 2024. "Biological Evaluation, Merced Gateway." Merced County Airport Land Use Commission. 2012. "Merced County Airport Land Use Compatibility Plan."
Merced County Association of Governments. 2022. "Final Regional Housing Needs Allocation Plan, Merced County Region, Cycle 6."
Natural Resources Conservation Service. 2023. USDA Natural Resources Conservation Service. Accessed January 2025.
https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx.

QK. 2025. "Water Supply Assessment, Merced Gateway."
San Joaquin Air Pollution Control District. 2015. "Air Quality Thresholds of Significance – Criteria Pollutants."
State Water Resources Control Board. 2024. State Water Resources Control Board, GeoTracker. https://geotracker.waterboards.ca.gov/map/.

U.S. Census Bureau. 2024. U.S. Census Bureau. Accessed March 2024. https://data.census.gov/table/ACSST5Y2022.S2301?q=Hanford%20city,%20Califo rnia%20unemployment.
—. 2023. United States Census Bureau, American Community Survey, Merced City, CA.

Accessed March 2025.
https://data.census.gov/table/ACSDP1Y2023.DP04?q=Housing+Units,+Merced,+C A&g=160XX00US0646898.

VRPA Technologies, Inc. 2025b. "Merced Gateway Residentia/Commercial Development, Transportation Impact Study."
VRPA Technologies, Inc. 2025a. "Merced Gateway Residential/Commercial Development, Air Quality and Greenhouse Gas Impact Assessment."
Bibliography

Merced Gateway Project May 2025
City of Merced Page 5-3
WJV Acoustics. 2024. "Acoustical Analysis, Merced Gateway Residential Development." Mitigation Monitoring and Reporting Program

Merced Gateway Project May 2025
City of Merced Page 6-1
SECTION 6 - MITIGATION MONITORING AND REPORTING PROGRAM

APPENDIX A

AIR QUALITY AND GREENHOUSE GAS IMPACT ASSESSMENT
Merced Gateway Residential/Commercial Development
Air Quality & Greenhouse Gas Impact Assessment
January 2025
Prepared by:

VRPA Technologies, Inc.
4630 W. Jennifer, Suite 105
Fresno, CA 93722
Project Manager: Georgiena Vivian

PROJECT LAYOUT FOR

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Table of Contents
Section Description Page

1.0 Introduction 1

1.1 Description of the Region/Project 1

1.2 Regulatory 1

1.2.1 Federal Agencies 1

1.2.2 Federal Regulations 5

1.2.3 State Agencies 6

1.2.4 State Regulations 11

1.2.5 Regional Agencies 14

1.2.6 Regional Regulations 15

1.2.7 Local Plans 17

2.0 Environmental Setting 18

2.1 Geographical Locations 18

2.2 Topographic Conditions 18

2.3 Climate Conditions 18

2.4 Anthropogenic (Man‐made) Sources 20

2.4.1 Motor Vehicles 21

2.4.2 Agricultural and Other Miscellaneous 22

2.4.3 Industrial Plants 22

2.5 San Joaquin Valley Air Basin Monitoring 22

2.6 Air Quality Standards 24

2.6.1 Ozone (1‐hour and 8‐hour) 25

2.6.2 Suspended PM (PM10 and PM2.5) 27

2.6.3 Carbon Monoxide (CO) 28

2.6.4 Nitrogen Dioxide (NO2) 29

2.6.5 Sulfur Dioxide (SO2) 31

2.6.6 Lead (Pb) 31

2.6.7 Toxic Air Contaminants (TAC) 32

2.6.8 Odors 34

2.6.9 Naturally Occurring Asbestos (NOA) 35

2.6.10 Greenhouse Gas Emissions 35

3.0 Air Quality Impacts 37

3.1 Methodology 37

3.1.1 CalEEMod 37

3.2 Short‐Term Impacts 38

3.3 Long Term Emissions 39

3.3.1 Localized Operational Emissions
Ozone/Particulate Matter 39

3.3.2 Localized Operational Emissions 39

4.0 Impact Determinations and Recommended
Mitigation 46

4.1 Air Quality 46

4.1.1 Conflict with or obstruct implementation
of the applicable air quality plan 46

4.1.3 Expose sensitive receptors to substantial
pollutant concentrations 47

4.1.4 Result in other emissions such as those leading to odors adversely affecting a substantial number of people 50

4.2 Greenhouse Gas Emissions 51

4.2.1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact
on the environment 51

4.2.2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases 52
Appendices
Appendix A – CalEEMod Worksheets
Appendix B – AERMOD Worksheets (Construction)

List of Tables
1 Ambient Air Quality Standards 9
2 Maximum Pollutant Levels at Merced’s
South Coffee Avenue Monitoring Station 23
3 Merced County Attainment Status 24
4 Recommendations on Siting New Sensitive Land Uses Such As Residences, Schools, Daycare Centers, Playgrounds, or Medical Facilities 33
5 Screening Levels for Potential Odor Sources 35
6 SJVAPCD Air Quality Thresholds of Significance 37
7 Project Construction Emissions (tons/year) 39
8 Project Operational Emissions (tons/year) 39
9 Health Risks from Project Construction 42
10 2005/2020 Operational Green House Gas Emissions 45 11 Project Operational Greenhouse Gas Emissions 45
12 Health Risks from Project Construction With Mitigation 49 List of Figures
1 Regional Location 3
2 Project Location 4
3 San Joaquin Valley Air Basin 8
1 Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment

1.0 Introduction

1.1 Description of the Region/Project
The proposed project is the construction of 587 single family residential units on 64.3 acres of land and

8.9 acres of local commercial in the City of Merced.

This Air Quality & Greenhouse Gas Impact Assessment has been prepared for the purpose of identifying potential project‐specific or site‐specific air quality impacts that may result from the Project. Figures 1 and 2 show the location of the Project along with major roadways and highways.

The City of Merced is located in the San Joaquin Valley Air Basin (SJVAB). The surrounding topography includes foothills and mountains to the east and west. These mountain ranges direct air circulation and dispersion patterns. Temperature inversions can trap air within the Valley, thereby preventing the vertical dispersal of air pollutants. In addition to topographic conditions, the local climate can also contribute to air quality problems. Climate in Merced is classified as Mediterranean, with moist cool winters and dry warm summers.

1.2 Regulatory
Air quality within the Project area is addressed through the efforts of various federal, state, regional, and local government agencies. These agencies work jointly, as well as individually, to improve air quality through legislation, regulations, planning, policymaking, education, and a variety of programs. The agencies primarily responsible for improving the air quality within the City of Merced and Merced County are discussed below along with their individual responsibilities.

1.2.1 Federal Agencies
 U.S. Environmental Protection Agency (EPA)
The Federal Clean Air Bill was first adopted in 1967 and periodically amended since then, established federal ambient air quality standards. A 1987 amendment to the Bill set a deadline for the attainment of these standards. That deadline has passed. The other Clean Air Act (CAA) Bill Amendments, passed in 1990, share responsibility with the State in reducing emissions from mobile sources. The U.S. Environmental Protection Agency (EPA) is responsible for enforcing the 1990 amendments.

The CAA and the national ambient air quality standards identify levels of air quality for six “criteria” pollutants, which are considered the maximum levels of ambient air pollutants considered safe, with an adequate margin of safety, to protect public health and welfare.

Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
2 The six criteria pollutants include ozone, carbon monoxide (CO), nitrogen dioxide, sulfur dioxide, particulate matter, and lead.

CAA Section 176(c) (42 U.S.C. 7506(c)) and EPA transportation conformity regulations (40 CFR 93 Subpart A) require that each new RTP and Transportation Improvement Program (TIP) be demonstrated to conform to the State Implementation Plan (SIP) before the RTP and TIP are approved by the Metropolitan planning organization (MPO) or accepted by the U.S.

Department of Transportation (DOT). The conformity analysis is a federal requirement designed to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS). However, because the State Implementation Plan (SIP) for particulate matter 10 microns or less in diameter (PM10), particulate matter 2.5 microns or less in diameter (PM2.5), and Ozone address attainment of both the State and federal standards, for these pollutants, demonstrating conformity to the federal standards is also an indication of progress toward attainment of the State standards. Compliance with the State air quality standards is provided on the pages following this federal conformity discussion.

The EPA approved San Joaquin Valley reclassification of the ozone (8‐hour) designation to extreme nonattainment in the Federal Register on May 5, 2010, even though the San Joaquin Valley was initially classified as serious nonattainment for the 1997 8‐hour ozone standard.

In accordance with the CAA, EPA uses the design value at the time of standard promulgation to assign nonattainment areas to one of several classes that reflect the severity of the nonattainment problem; classifications range from marginal nonattainment to extreme nonattainment. In the Federal Register on October 26, 2015, the EPA revised the primary and secondary standard to 0.070 parts per million (ppm) to provide increased public health protection against health effects associated with long‐ and short‐term exposures. The previous ozone standard was set in 2010 at 0.075 ppm.

Merced County is located in a nonattainment area for the 8‐hour ozone standard, PM2.5 standard, and has a maintenance plan for PM10 standard.

Merced Gateway Residential Property Development
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3 Merced Gateway Residential/Commercial Development
Regional Location
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Merced Gateway Residential Property Development
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4 Merced Gateway Residential/Commercial Development Figure Project Location 2
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VRPA TECHNOlOG/ES. INC.

Merced Gateway Residential Property Development
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5 1.2.2 Federal Regulations
 National Environmental Policy Act (NEPA)
NEPA provides general information on the effects of federally funded projects. The Act was implemented by regulations included in the Code of Federal Regulations (40CFR6). The code requires careful consideration concerning environmental impacts of federal actions or plans, including projects that receive federal funds. The regulations address impacts on land uses and conflicts with state, regional, or local plans and policies, among others. They also require that projects requiring NEPA review seek to avoid or minimize adverse effects of proposed actions and to restore and enhance environmental quality as much as possible.  State Implementation Plan (SIP)/ Air Quality Management Plans (AQMPs) To ensure compliance with the NAAQS, EPA requires states to adopt SIP aimed at improving air quality in areas of nonattainment or a Maintenance Plan aimed at maintaining air quality in areas that have attained a given standard. New and previously submitted plans, programs, district rules, state regulations, and federal controls are included in the SIPs. Amendments made in 1990 to the federal CAA established deadlines for attainment based on an area’s current air pollution levels. States must enact additional regulatory programs for nonattainment areas in order to adhere with the CAA Section 172. In California, the SIPs must adhere to both the NAAQS and the California Ambient Air Quality Standards (CAAQS).

To ensure that State and federal air quality regulations are being met, Air Quality Management Plans (AQMPs) are required. AQMPs present scientific information and use analytical tools to identify a pathway towards attainment of NAAQS and CAAQS. The San Joaquin Valley Air Pollution Control District (SJVAPCD) develops the AQMPs for the region where the Merced County Association of Governments (MCAG) operates. The regional air districts begin the SIP process by submitting their AQMPs to the California Air Resources Board (CARB). CARB is responsible for revising the SIP and submitting it to EPA for approval.

EPA then acts on the SIP in the Federal Register. The items included in the California SIP are listed in the Code of Federal Regulations Title 40, Chapter 1, Part 52, Subpart 7, Section

52.220.
 Transportation Control Measures
One particular aspect of the SIP development process is the assessment of available transportation control measures (TCMs) as a part of making progress towards clean air goals.

TCMs are defined in Section 108(f)(1) of the CAA and are strategies designed to reduce vehicle miles traveled, vehicle idling, and associated air pollution. These goals are generally achieved by developing attractive and convenient alternatives to single‐occupant vehicle use.

Examples of TCMs include ridesharing programs, transportation infrastructure improvements such as adding bicycle and carpool lanes, and expansion of public transit.

Merced Gateway Residential Property Development
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6  Energy Policy Act of 1992 (EPAct)
The Energy Policy Act of 1992 (EPAct) was passed to reduce the country’s dependence on foreign petroleum and improve air quality. EPAct includes several parts intended to build an inventory of alternative fuel vehicles (AFVs) in large, centrally fueled fleets in metropolitan areas. EPAct requires certain federal, state, and local government and private fleets to purchase a percentage of light duty AFVs capable of running on alternative fuels each year.

In addition, financial incentives are included in EPAct. Federal tax deductions will be allowed for businesses and individuals to cover the incremental cost of alternative fueled vehicles (AFVs). States are also required by the act to consider a variety of incentive programs to help promote AFVs.

1.2.3 State Agencies
 California Air Resources Board (CARB)
CARB is the agency responsible for coordination and oversight of State and local air pollution control programs in California and for implementing its own air quality legislation called the California Clean Air Act (CCAA), adopted in 1988. CARB was created in 1967 from the merging of the California Motor Vehicle Pollution Control Board and the Bureau of Air Sanitation and its Laboratory.

CARB has primary responsibility in California to develop and implement air pollution control plans designed to achieve and maintain the NAAQS established by the EPA. Whereas CARB has primary responsibility and produces a major part of the SIP for pollution sources that are statewide in scope, it relies on the local air districts to provide additional strategies for sources under their jurisdiction. CARB combines its data with all local district data and submits the completed SIP to the EPA. The SIP consists of the emissions standards for vehicular sources and consumer products set by CARB, and attainment plans adopted by the Air Pollution Control Districts (APCDs) and Air Quality Management District’s (AQMDs) and approved by CARB.

States may establish their own standards, provided the State standards are at least as stringent as the NAAQS. California has established California Ambient Air Quality Standards (CAAQS) pursuant to California Health and Safety Code (CH&SC) [§39606(b)] and its predecessor statutes.

The CH&SC [§39608] requires CARB to “identify” and “classify” each air basin in the State on a pollutant‐by‐pollutant basis. Subsequently, CARB designated areas in California as nonattainment based on violations of the CAAQSs. Designations and classifications specific to the SJVAB can be found in the next section of this document. Areas in the State were also classified based on severity of air pollution problems. For each nonattainment class, the CCAA specifies air quality management strategies that must be adopted. For all nonattainment Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
7 categories, attainment plans are required to demonstrate a five percent‐per‐year reduction in nonattainment air pollutants or their precursors, averaged every consecutive three‐year period, unless an approved alternative measure of progress is developed. In addition, air districts in violation of CAAQS are required to prepare an Air Quality Attainment Plan (AQAP) that lays out a program to attain and maintain the CCAA mandates.

CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035.

For the Merced County Association of Governments (MCAG) region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. MCAG’s 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

Other CARB duties include monitoring air quality. CARB has established and maintains, in conjunction with local APCDs and AQMDs, a network of sampling stations (called the State and Local Air Monitoring [SLAMS] network), which monitor the present pollutant levels in the ambient air.

Merced County is in the CARB‐designated, SJVAB. A map of the SJVAB is provided in Figure 3.

In addition to Merced County, the SJVAB includes Fresno, Kings, Kern, Madera, San Joaquin, Stanislaus, and Tulare counties. Federal and State standards for criteria pollutants are provided in Table 1.

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8 Merced Gateway Residential/Commercial Development
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Merced Gateway Residential Property Development
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9 Table 1
Ambient Air Quality Standards
Concentration 3 Method 4 Primary 3,5 Secondary 3,6 Method 7 1 Hour 0.09 ppm (180 µg/m3
) ‐‐
8 Hour 0.070 ppm (137 µg/m3
) 0.070 ppm (137 µg/m3)
24 Hour 50 µg/m3 150 µg/m3
Annual
Arithmetic Mean 20 µg/m3 ‐‐
24 Hour ‐‐ ‐‐ 35 µg/m3 Same as
Primary Standard
Annual
Arithmetic Mean 12 µg/m3 Gravimetric or Beta Attenuation 12.0 µg/m3 15 µg/m3 1 Hour 20 ppm (23 mg/m3
) 35 ppm (40 mg/m3) ‐‐
8 Hour 9.0 ppm (10 mg/m3
) 9 ppm (10 mg/m3) ‐‐
8 Hour
(Lake Tahoe) 6 ppm (7 mg/m3
) ‐‐ ‐‐
1 Hour 0.18 ppm (339 µg/m3
) 100 ppb (188 µg/m3) ‐‐
Annual
Arithmetic Mean 0.030 ppm (57 µg/m3
) 0.053 ppm (100 µg/m3)
Same as
Primary Standard
1 Hour 0.25 ppm (655 µg/m3
) 75 ppb (196 µg/m3) ‐‐
3 Hour ‐‐ ‐‐ 0.5 ppm
(1300 µg/m3
)
24 Hour 0.04 ppm (105 µg/m3
) 0.14 ppm
(for cetain areas) 11 ‐‐
Annual
Arithmetic Mean ‐‐ 0.030 ppm
(for cetain areas) 11 ‐‐
30 Day Average 1.5 µg/m3 ‐‐ ‐‐
Calendar
Quarter ‐‐ 1.5 µg/m3
(for certain areas)
11 Rolling 3‐Month
Average ‐‐ 0.15 µg/m3
Visibility Reducing
Particles 14 8 Hour See footnote 14
Beta Attenuation
and Transmittance
through Filter Tape
Sulfates 24 Hour 25 µg/m3 Ion Chromatography
Hydrogen Sulfide 1 Hour 0.03 ppm (42 µg/m3
)
Ultraviolet
Fluorescence
Vinyl Chloride 12 24 Hour 0.01 ppm (26 µg/m3
)
Gas
Chromatography
Nitrogen Dioxide
(NO2) 10
Sulfur Dioxide
(SO2) 11
Ultraviolet
Fluorescence
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
Gravimetric or
Beta Attenuation
Same as
Primary Standard
Inertial Separation
and Gravimetric
Analysis
Gas Phase
Chemiluminescence
Gas Phase
Chemiluminescence
No
National
Standards
Lead 12,13
High Volume
Sampler and Atomic
Absorption Same as
Primary Standard
Atomic Absorption
Pollutant Averaging
Time
California Standards 1 National Standards 2
Ozone (O3) 8 Ultraviolet
Photometry
Same as
Primary Standard
Ultraviolet
Photometry
Fine Particulate
Matter (PM2.5) 9
Inertial Separation
and Gravimetric
Analysis
Carbon Monoxide
(CO)
Non‐Dispersive
Infrared Photometry
(NDIR)
Non‐Dispersive
Infrared Photometry
(NDIR)
See footnotes on next page …
Respirable
Particulate Matter
(PM10) 9
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10 Footnotes:

1. California standards for ozone, carbon monoxide (except 8‐hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8‐hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24‐hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.

3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4. Any equivalent measurement method which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used.

5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.

6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

7. Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the U.S. EPA.

8. On October 1, 2015, the national 8‐hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.

9. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing national 24‐hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24‐hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.

10. To attain the 1‐hour national standard, the 3‐year average of the annual 98th percentile of the 1‐hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1‐hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1‐hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.

11. On June 2, 2010, a new 1‐hour SO2 standard was established and the existing 24‐hour and annual primary standards were revoked. To attain the 1‐ hour national standard, the 3‐year average of the annual 99th percentile of the 1‐hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24‐hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1‐hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the 1‐hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.

12. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined.

These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

13. The national standard for lead was revised on October 15, 2008 to a rolling 3‐month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

14. In 1989, the ARB converted both the general statewide 10‐mile visibility standard and the Lake Tahoe 30‐mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively.

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11 1.2.4 State Regulations
 CARB Mobile‐Source Regulation
The State of California is responsible for controlling emissions from the operation of motor vehicles in the State. Rather than mandating the use of specific technology or the reliance on a specific fuel, CARB’s motor vehicle standards specify the allowable grams of pollutant per mile driven. In other words, the regulations focus on the reductions needed rather than on the manner in which they are achieved.
 California Clean Air Act
The CCAA was first signed into law in 1988. The CCAA provides a comprehensive framework for air quality planning and regulation, and spells out, in statute, the state’s air quality goals, planning and regulatory strategies, and performance. The CCAA establishes more stringent ambient air quality standards than those included in the Federal CAA. CARB is the agency responsible for administering the CCAA. CARB established ambient air quality standards pursuant to the CH&SC [§39606(b)], which are similar to the federal standards. The SJVAPCD is one of 35 AQMDs that have prepared air quality management plans to accomplish a five percent (5%) annual reduction in emissions documenting progress toward the State ambient air quality standards.
 Tanner Air Toxics Act
California regulates Toxic Air Contaminants (TACs) primarily through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588).

The Tanner Act sets forth a formal procedure for CARB to designate substances as TACs. This includes research, public participation, and scientific peer review before CARB can designate a substance as a TAC. To date, CARB has identified more than 21 TACs and has adopted EPA's list of Hazardous Air Pollutants (HAPs) as TACs. Once a TAC is identified, CARB then adopts an Airborne Toxics Control Measure (ATCM) for sources that emit that particular TAC. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate Best Available Control Technology (BACT) to minimize emissions.

AB 2588 requires that existing facilities that emit toxic substances above a specified level prepare a toxic‐emission inventory, prepare a risk assessment if emissions are significant, notify the public of significant risk levels, and prepare and implement risk reduction measures. CARB has adopted diesel exhaust control measures and more stringent emission standards for various on‐road mobile sources of emissions, including transit buses and off‐ road diesel equipment (e.g., tractors, generators).

These rules and standards provide for:

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12  More stringent emission standards for some new urban bus engines, beginning with 2002 model year engines.
 Zero‐emission bus demonstration and purchase requirements applicable to transit agencies
 Reporting requirements under which transit agencies must demonstrate compliance with the urban transit bus fleet rule.
 AB 1493 (Pavley)
AB 1493 (Pavley) enacted on July 22, 2002, required CARB to develop and adopt regulations that reduce greenhouse gases emitted by passenger vehicles and light duty trucks.

Regulations adopted by CARB would apply to 2009 and later model year vehicles. CARB estimated that the regulation would reduce climate change emissions from light duty passenger vehicles by an estimated 18 percent in 2020 and by 27 percent in 2030 [Association of Environmental Professionals (AEP) 2007]. In 2005, the CARB requested a waiver from U.S.

EPA to enforce the regulation, as required under the CAA. Despite the fact that no waiver had ever been denied over a 40‐year period, the then Administrator of the EPA sent Governor Schwarzenegger a letter in December 2007, indicating he had denied the waiver. On March 6, 2008, the waiver denial was formally issued in the Federal Register. Governor Schwarzenegger and several other states immediately filed suit against the federal government to reverse that decision. On January 21, 2009, CARB requested that EPA reconsider denial of the waiver. EPA scheduled a re‐hearing on March 5, 2009. On June 30, 2009, EPA granted a waiver of CAA preemption to California for its greenhouse gas emission standards for motor vehicles beginning with the 2009 model year.  Assembly Bill 32 (California Global Warming Solutions Act of 2006) California passed the California Global Warming Solutions Act of 2006 (AB 32; California Health and Safety Code Division 25.5, Sections 38500 ‐ 38599). AB 32 establishes regulatory, reporting, and market mechanisms to achieve quantifiable reductions in greenhouse gas (GHG) emissions and establishes a cap on statewide GHG emissions. AB 32 has achieved the goal of reducing statewide GHG emissions to 1990 levels by 2020. Now, the goal under AB 32 is to further reduce GHG emissions to 40% below 1990 levels by 2030. To effectively implement the cap, AB 32 directs CARB to develop and implement regulations to reduce statewide GHG emissions from stationery sources. AB 32 specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions from vehicles. However, AB 32 also includes language stating that if the AB 1493 regulations cannot be implemented, then CARB should develop new regulations to control vehicle GHG emissions under the authorization of AB 32.

AB 32 requires CARB to adopt a quantified cap on GHG emissions representing 1990 emissions levels and disclose how it arrived at the cap; institute a schedule to meet the emissions cap; and develop tracking, reporting, and enforcement mechanisms to ensure that the state reduces GHG emissions enough to meet the cap. AB 32 also includes guidance on Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
13 instituting emissions reductions in an economically efficient manner, along with conditions to ensure that businesses and consumers are not unfairly affected by the reductions. Using these criteria to reduce statewide GHG emissions to 1990 levels by 2030 would represent an approximate 40 percent reduction in current emissions levels. However, CARB has discretionary authority to seek greater reductions in more significant and growing GHG sectors, such as transportation, as compared to other sectors that are not anticipated to significantly increase emissions.

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan adopted in December of 2008. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit.  Senate Bill 375
SB 375, signed in September 2008 (Chapter 728, Statutes of 2008), aligns regional transportation planning efforts, regional GHG reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt a sustainable communities strategy (SCS) or alternative planning strategy (APS) that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the Merced County Association of Governments, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2018.MCAG’s 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

This law also extends the minimum time period for the regional housing needs allocation cycle from five years to eight years for local governments located within an MPO that meets certain requirements. City or county land use policies (including general plans) are not required to be consistent with the regional transportation plan (and associated SCS or APS).

However, new provisions of CEQA incentivize (through streamlining and other provisions) qualified projects that are consistent with an approved SCS or APS, categorized as "transit priority projects."
 Executive Order B‐30‐15
Executive Order B‐30‐15, which was signed by Governor Brown in 2016, establishes a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. Executive Order B‐30‐15 requires MPO’s to implement measures that will achieve reductions of greenhouse gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets.

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14  California Global Warming Solutions Act of 2006: emissions limit, or SB 32 SB 32 is a California Senate bill expanding upon AB 32 to reduce greenhouse gas (GHG) emissions. SB 32 was signed into law on September 8, 2016, by Governor Brown. SB 32 sets into law the mandated reduction target in GHG emissions as written into Executive Order B‐ 30‐15. SB 32 requires that there be a reduction in GHG emissions to 40% below the 1990 levels by 2030. Greenhouse gas emissions include carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons. The California Air Resources Board (CARB) is responsible for ensuring that California meets this goal. The provisions of SB 32 were added to Section 38566 of the Health and Safety Code subsequent to the bill’s approval. The bill went into effect January 1, 2017. SB 32 builds onto Assembly Bill (AB) 32 written by Senator Fran Pavley and Assembly Speaker Fabian Nunez passed into law on September 27, 2006. AB 32 required California to reduce greenhouse gas emissions to 1990 levels by 2020 and SB 32 continues that timeline to reach the targets set in Executive Order B‐30‐15. SB 32 provides another intermediate target between the 2020 and 2050 targets set in Executive Order S‐3‐05.

1.2.5 Regional Agencies
 San Joaquin Valley Air Pollution Control District
The SJVAPCD is the agency responsible for monitoring and regulating air pollutant emissions from stationery, area, and indirect sources within Merced County and throughout the SJVAB.

The district also has responsibility for monitoring air quality and setting and enforcing limits for source emissions. CARB is the agency with the legal responsibility for regulating mobile source emissions. The district is precluded from such activities under State law.

The district was formed in mid‐1991 and prepared and adopted the San Joaquin Valley Air Quality Attainment Plan (AQAP), dated January 30, 1992, in response to the requirements of the State CCAA. The CCAA requires each non‐attainment district to reduce pertinent air contaminants by at least five percent (5%) per year until new, more stringent, 1988 State air quality standards are met.

Activities of the SJVAPCD include the preparation of plans for the attainment of ambient air quality standards, adoption and enforcement of rules and regulations concerning sources of air pollution, issuance of permits for stationary sources of air pollution, inspection of stationary sources of air pollution and response to citizen complaints, monitoring of ambient air quality and meteorological conditions, and implementation of programs and regulations required by the FCAA and CCAA.

The SJVAPCD has prepared the following State Implementation Plans to address ozone, PM‐ 10 and PM2.5 that currently apply to non‐attainment areas:
 The 2016 Ozone Plan (2008 standard) was adopted by SJVAPCD on June 16, 2016, and subsequently adopted by ARB on July 21, 2016.

Merced Gateway Residential Property Development
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15  The 2013 1‐Hour Ozone Plan (revoked 1997 standard) was adopted by the SJVAPCD on September 19, 2013. EPA withdrew its approval of the plan due to litigation. The district plans to submit a “redesignation substitute” to EPA to maintain its attainment status for this revoked ozone standard.
 The 2007 PM‐10 Maintenance Plan (as revised in 2015) was approved by EPA on July 8, 2016 (effective September 30, 2016).
 The 2012 PM2.5 Plan (as revised in 2015) was approved by EPA on August 16, 2016 (effective September 30, 2016).

The SJVAPCD Plans identified above represent SJVAPCD’s plan to achieve both state and federal air quality standards. The regulations and incentives contained in these documents must be legally enforceable and permanent. These plans break emissions reductions and compliance into different emissions source categories.

The SJVAPCD also prepared the Guide for Assessing and Mitigation Air Quality Impacts (GAMAQI), dated March 19, 2015. The GAMAQI is an advisory document that provides Lead Agencies, consultants, and project applicants with analysis guidance and uniform procedures for addressing air quality impacts in environmental documents. Local jurisdictions are not required to utilize the methodology outlined therein. This document describes the criteria that SJVAPCD uses when reviewing and commenting on the adequacy of environmental documents. It recommends thresholds for determining whether or not projects would have significant adverse environmental impacts, identifies methodologies for predicting project emissions and impacts, and identifies measures that can be used to avoid or reduce air quality impacts.

1.2.6 Regional Regulations
The SJVAPCD has adopted numerous rules and regulations to implement its air quality plans.

Following, are significant rules that will apply to the Project.  Regulation VIII – Fugitive PM10 Prohibitions
Regulation VIII is comprised of District Rules 8011 through 8081, which are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and track out, landfill operations, etc. The proposed Project will be required to comply with this regulation. Regulation VIII control measures are provided below:

1. All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, covered with a tarp or other suitable cover or vegetative ground cover.

2. All on‐site unpaved roads and off‐site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

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16 3. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut & fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking.

4. When materials are transported off‐site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least six inches of freeboard space from the top of the container shall be maintained.

5. All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.

6. Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/suppressant.

7. Within urban areas, track out shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday.
 Rule 8021 – Construction, Demolition, Excavation, and Other Earthmoving Activities District Rule 8021 requires owners or operators of construction projects to submit a Dust Control Plan to the District if at any time the project involves non‐residential developments of five or more acres of disturbed surface area or moving, depositing, or relocating of more than 2,500 cubic yards per day of bulk materials on at least three days of the project or residential projects which include 10 or more acres of disturbed surface area. The proposed Project will meet these criteria and will be required to submit a Dust Control Plan to the District in order to comply with this rule.
 Rule 4641 – Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations
If asphalt paving will be used, then paving operations of the proposed Project will be subject to Rule 4641. This rule applies to the manufacture and use of cutback asphalt, slow cure asphalt and emulsified asphalt for paving and maintenance operations.  Rule 9510 – Indirect Source Review (ISR)
The purpose of this rule is to fulfill the district’s emission reduction commitments in the PM10 and Ozone Attainment Plans, achieve emission reductions from construction activities, and to provide a mechanism for reducing emissions from the construction of and use of development projects through off‐site measures. The rule is expected to reduce nitrogen oxides and particulates throughout the San Joaquin Valley by more than 10 tons per day.

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17 1.2.7 Local Plans
 City of Merced General Plan
California State Law requires every city and county to adopt a comprehensive General Plan to guide its future development. The General Plan essentially serves as a “constitution for development”— the document that serves as the foundation for all land use decisions. The City of Merced General Plan includes various elements, including air quality and greenhouse gases, that address local concerns and provides goals and policies to achieve its development goals.
 Merced County General Plan
California State Law requires every city and county to adopt a comprehensive General Plan to guide its future development. The General Plan essentially serves as a “constitution for development”— the document that serves as the foundation for all land use decisions. The 2030 Merced County General Plan includes various elements, including air quality and greenhouse gases, that address local concerns and provides goals and policies to achieve its development goals.

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18 2.0 Environmental Setting
This section describes existing air quality within the San Joaquin Valley Air Basin and in Merced County, including the identification of air pollutant standards, meteorological and topological conditions affecting air quality, and current air quality conditions. Air quality is described in relation to ambient air quality standards for criteria pollutants such as, ozone, carbon monoxide, and particulate matter. Air quality can be directly affected by the type and density of land use change and population growth in urban and rural areas.

2.1 Geographical Location
The SJVAB is comprised of eight counties: Merced, Fresno, Kern, Kings, Madera, San Joaquin, Stanislaus, and Tulare. Encompassing 24,840 square miles, the San Joaquin Valley is the second largest air basin in California. Cumulatively, counties within the Air Basin represent approximately 16 percent of the State's geographic area. The Air Basin is bordered by the Sierra Nevada Mountains on the east (8,000 to 14,492 feet in elevation), the Coastal Range on the west (4,500 feet in elevation), and the Tehachapi Mountains on the south (9,000 feet elevation). The San Joaquin Valley is open to the north extending to the Sacramento Valley Air Basin.

2.2 Topographic Conditions
Merced County is located within the San Joaquin Valley Air Basin [as determined by the California Air Resources Board (CARB)]. Air basins are geographic areas sharing a common "air shed." A description of the Air Basin in the County, as designated by CARB, is provided in the paragraph below. Air pollution is directly related to the region's topographic features, which impact air movement within the Basin.

Wind patterns within the SJVAB result from marine air that generally flows into the Basin from the San Joaquin River Delta. The Coastal Range hinders wind access into the Valley from the west, the Tehachapi’s prevent southerly passage of airflow, and the high Sierra Nevada Mountain Range provides a significant barrier to the east. These topographic features result in weak airflow that becomes restricted vertically by high barometric pressure over the Valley. As a result, the SJVAB is highly susceptible to pollutant accumulation over time. Most of the surrounding mountains are above the normal height of summer inversion layers (1,500‐3,000 feet).

2.3 Climate Conditions
Merced is located in one of the most polluted air basins in the country. Temperature inversions can trap air within the Valley, thereby preventing the vertical dispersal of air pollutants. In addition to topographic conditions, the local climate can also contribute to air quality problems.

Climate in Merced is characterized by warm, dry summers and cool winters with significant Tule fog.

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19 Ozone, classified as a “regional” pollutant, often afflicts areas downwind of the original source of precursor emissions. Ozone can be easily transported by wind from a source area. Peak ozone levels tend to be higher in the southern portion of the Valley, as the prevailing summer winds sweep precursors downwind of northern source areas before concentrations peak. The separate designations reflect the fact that ozone precursor transport depends on daily meteorological conditions.

Other primary pollutants, carbon monoxide (CO), for example, may form high concentrations when wind speed is low. During the winter, Merced experiences cold temperatures and calm conditions that increase the likelihood of a climate conducive to high CO concentrations.

Precipitation and fog tend to reduce or limit some pollutant concentrations. Ozone needs sunlight for its formation, and clouds and fog block the required radiation. CO is slightly water‐ soluble, so precipitation and fog tends to “reduce” CO concentrations in the atmosphere. PM10 is somewhat “washed” from the atmosphere with precipitation. Precipitation in the San Joaquin Valley is strongly influenced by the position of the semi‐permanent subtropical high‐pressure belt located off the Pacific coast. In the winter, this high‐ pressure system moves southward, allowing Pacific storms to move through the San Joaquin Valley. These storms bring in moist, maritime air that produces considerable precipitation on the western, upslope side of the Coast Ranges.

Significant precipitation also occurs on the western side of the Sierra Nevada. On the valley floor, however, there is some down slope flow from the Coast Ranges and the resultant evaporation of moisture from associated warming results in a minimum of precipitation. Nevertheless, the majority of the precipitation falling in the San Joaquin Valley is produced by those storms during the winter. Precipitation during the summer months is in the form of convective rain showers and is rare. It is usually associated with an influx of moisture into the San Joaquin Valley through the San Francisco area during an anomalous flow pattern in the lower layers of the atmosphere.

Although the hourly rates of precipitation from these storms may be high, their rarity keeps monthly totals low.

Precipitation on the San Joaquin Valley floor and in the Sierra Nevada decreases from north to south. Stockton in the north receives about 20 inches of precipitation per year, Merced in the center, receives about 10 inches per year, and Bakersfield at the southern end of the valley receives less than 6 inches per year. This is primarily because the Pacific storm track often passes through the northern part of the state while the southern part of the state remains protected by the Pacific High. Precipitation in the San Joaquin Valley Air Basin (SJVAB) is confined primarily to the winter months with some also occurring in late summer and fall. Average annual rainfall for the entire San Joaquin Valley is approximately 5 to 16 inches. Snowstorms, hailstorms, and ice storms occur infrequently in the San Joaquin Valley and severe occurrences of any of these are very rare.

The winds and unstable air conditions experienced during the passage of storms result in periods of low pollutant concentrations and excellent visibility. Between winter storms, high pressure and light winds allow cold moist air to pool on the San Joaquin Valley floor. This creates strong Merced Gateway Residential Property Development
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20 low‐level temperature inversions and very stable air conditions. This situation leads to the San Joaquin Valley’s famous Tule Fogs. The formation of natural fog is caused by local cooling of the atmosphere until it is saturated (dew point temperature). This type of fog, known as radiation fog, is more likely to occur inland. Cooling may also be accomplished by heat radiation losses or by horizontal movement of a mass of air over a colder surface. This second type of fog, known as advection fog, generally occurs along the coast.

Conditions favorable to fog formation are also conditions favorable to high concentrations of CO and PM10. Ozone levels are low during these periods because of the lack of sunlight to drive the photochemical reaction. Maximum CO concentrations tend to occur on clear, cold nights when a strong surface inversion is present and large numbers of fireplaces are in use. A secondary peak in CO concentrations occurs during morning commute hours when a large number of motorists are on the road and the surface inversion has not yet broken.

The water droplets in fog, however, can act as a sink for CO and nitrogen oxides (NOx), lowering pollutant concentrations. At the same time, fog could help in the formation of secondary particulates such as ammonium sulfate. These secondary particulates are believed to be a significant contributor to winter season violations of the PM10 and PM2.5 standards.

2.4 Anthropogenic (Man‐made) Sources
In addition to climatic conditions (wind, lack of rain, etc.), air pollution can be caused by anthropogenic or man‐made sources. Air pollution in the SJVAB can be directly attributed to human activities, which cause air pollutant emissions. Human causes of air pollution in the Valley consist of population growth, urbanization (gas‐fired appliances, residential wood heaters, etc.), mobile sources (i.e., cars, trucks, airplanes, trains, etc.), oil production, agriculture, and other socioeconomic activities. The most significant factors, which are accelerating the decline of air quality in the SJVAB, are the Valley's rapid population growth and its associated increases in traffic, urbanization, and industrial activity.

Carbon monoxide emissions overwhelmingly come from mobile sources in the San Joaquin Valley; on‐road vehicles contributed 38 percent, while other mobile vehicles, such as trains, planes, and off‐road vehicles, contribute another 20 percent in 2021 according to emission projections from the CARB. Motor vehicles account for significant portions of regional gaseous and particulate emissions. Local large employers such as industrial plants can also generate substantial regional gaseous and particulate emissions. In addition, construction and agricultural activities can generate significant temporary gaseous and particulate emissions (dust, ash, smoke, etc.).

Ozone is the result of a photochemical reaction between Oxides of nitrogen (NOx) and Reactive Organic Gases (ROG). Mobile sources contribute 84 percent of all NOx emitted from anthropogenic sources based on data provided in Appendix B of the Air District’s 2016 Ozone Merced Gateway Residential Property Development
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21 Plan. In addition, mobile sources contribute 26 percent of all the ROG emitted from sources within the San Joaquin Valley.

The principal factors that affect air quality in and around Merced are:

1. The sink effect, climatic subsidence and temperature inversions and low wind speeds

2. Automobile and truck travel

3. Increases in mobile and stationary pollutants generated by local urban growth.

Automobiles, trucks, buses and other vehicles using hydrocarbon (HC) fuels release exhaust products into the air. Each vehicle by itself does not release large quantities; however, when considered as a group, the cumulative effect is significant.

Other sources may not seem to fit into any one of the major categories or they may seem to fit in a number of them. These could include agricultural uses, dirt roads, animal shelters; animal feed lots, chemical plants and industrial waste disposal, which may be a source of dust, odors, or other pollutants. For Merced County, this category includes several agriculturally related activities, such as plowing, harvesting, dusting with herbicides and pesticides and other related activities. Finally, industrial contaminants and their potential to produce various effects depend on the size and type of industry, pollution controls, local topography, and meteorological conditions. Major sources of industrial emissions in Merced County consist of agricultural production and processing operations.

The primary contributors of PM10 emissions in the San Joaquin Valley are farming activities (22%) and road dust, both paved and unpaved (35%) in 2020 according to emission projections from the CARB. Fugitive windblown dust from “open” fields contributed 14 percent of the PM10.

The four major sources of air pollutant emissions in the SJVAB include industrial plants, motor vehicles, construction activities, and agricultural activities. Industrial plants account for significant portions of regional gaseous and particulate emissions. Motor vehicles, including those from large employers, generate substantial regional gaseous and particulate emissions.

Finally, construction and agricultural activities can generate significant temporary gaseous and particulate emissions (dust, ash, smoke, etc.). In addition to these primary sources of air pollution, urban areas upwind from Merced County including areas north and west of the San Joaquin Valley, can cause or generate emissions that are transported into Merced County. All four of the major pollutant sources affect ambient air quality throughout the Air Basin.

2.4.1 Motor Vehicles
Automobiles, trucks, buses and other vehicles using hydrocarbon fuels release exhaust products into the air. Each vehicle by itself does not release large quantities; however, when considered as a group, the cumulative effect is significant.

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22 2.4.2 Agricultural and Other Miscellaneous Activities Other sources may not seem to fit into any one of the major categories or they may seem to fit in a number of them. These could include agricultural uses, dirt roads, animal shelters, animal feed lots, chemical plants and industrial waste disposal, which may be a source of dust, odors, or other pollutants. For Merced, this category includes several agriculturally related activities, such as plowing, harvesting, dusting with herbicides and pesticides and other related activities.

2.4.3 Industrial Plants
Industrial contaminants and their potential to produce various effects depend on the size and type of industry, pollution controls, local topography, and meteorological conditions. Major sources of industrial emissions in Merced County consist of agricultural production and processing operations.

2.5 San Joaquin Valley Air Basin Monitoring
SJVAPCD and the CARB maintain numerous air quality monitoring sites throughout each County in the Air Basin to measure ozone, PM2.5, and PM10. It is important to note that the federal ozone 1‐hour standard was revoked by the EPA and is no longer applicable for federal standards.

The closest monitoring station to the Project is located at Merced – South Coffee Avenue Monitoring Station. The station monitors particulates, ozone, carbon monoxide, and nitrogen dioxide. Monitoring data for the past three years is summarized in Table 2.

Table 3 identifies Merced County’s attainment status. As indicated, the SJVAB is nonattainment for Ozone (1 hour and 8 hour) and PM. In accordance with the FCAA, EPA uses the design value at the time of standard promulgation to assign nonattainment areas to one of several classes that reflect the severity of the nonattainment problem; classifications range from marginal nonattainment to extreme nonattainment. The FCAA contains provisions for changing the classifications using factors such as clean air progress rates and requests from States to move areas to a higher classification.

On April 16, 2004, EPA issued a final rule classifying the SJVAB as extreme nonattainment for Ozone, effective May 17, 2004 (69 FR 20550). The (federal) 1‐hour ozone standard was revoked on June 6, 2005. However, many of the requirements in the 1‐hour attainment plan (SIP) continue to apply to the SJVAB. The current ozone plan is the (federal) 8‐hour ozone plan adopted in 2007. The SJVAB was reclassified from a "serious" nonattainment area for the 8‐hour ozone standard to “extreme” effective June 4, 2010.

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23 Table 2
Maximum Pollutant Levels at Merced
South Coffee Avenue Monitoring Station
I
Time
Pollutant Averaging
Ozone (03) 1 hour 0.099 ppm 0.096ppm
Ozone (03) 8 hour 0.089ppm 0.083 ppm
Nitrogen Dioxide (N02) 1 hour 38.2 ppb 39.1 ppb
Nitrogen Dioxide (N02) Annual Average • 7.0 ppb
Particulates (PM 10) 24 hour • . Particulates (PM10)
Federal Annual
• • Arithmetic Mean
Particulates (PM2_5) 24 hour 77.3 µg/m3 I 39.6µg/m3
Federal Annual I
Particulates (PM2.sl Arithmetic Mean 11.2 µg/m3 9.8 µg/m' Source: California Air Resources Soard (ADAM) Air Pollution Summaries, 2024 • Means there was insufficient data available to determine the value

0.096 ppm . 0.09 ppm

0.079 ppm 0.070 ppm 0.070ppm

37.1 ppb 100 ppb 0.18 ppm

6.0 ppb 8.0ppm 0.030 ppm
• 150 µg/m3 SO µg/m3
• . 20 µg/m3

35.7 µg/m3 35 µg/m3 .

8.4 µg/m3 12 µg/m3 12 µg/m3
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24 Table 3
Merced County Attainment Status

2.6 Air Quality Standards
The FCAA, first adopted in 1963, and periodically amended since then, established National Ambient Air Quality Standards (NAAQS). A set of 1977 amendments determined a deadline for the attainment of these standards. That deadline has passed. Other CAA amendments, passed in 1990, share responsibility with the State in reducing emissions from mobile sources.

Pollutant Federal Standards State Standards
Ozone ‐ 1 Hour Revoked in 2005 Nonattainment
Ozone ‐ 8 Hour Nonattainment/Extreme No State Standard
PM10 Attainment Nonattainment
PM2.5 Nonattainment Nonattainment
Carbon Monoxide Unclassified/Attainment Unclassified
Nitrogen Dioxide Unclassified/Attainment Attainment
Sulfur Dioxide Unclassified/Attainment Attainment
Lead (Particulate) Unclassified/Attainment Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Sulfates No Federal Standard Attainment
Visibility Reducing Particles No Federal Standard Unclassified Source: CARB Website, 2024
Designation/Classification
a. Though the Valley was initially classified as serious nonattainment for the 1997 8‐hour ozone standard, EPA approved Valley reclassification to extreme nonattainment in the Federal Register on May 5, 2010 (effective June 4, 2010).

Notes:

National Designation Categories
Non‐Attainment Area: Any area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the national primary or secondary ambient air quality standard for the pollutant.

Unclassified/Attainment Area: Any area that cannot be classified on the basis of available information as meeting or not meeting the national primary or secondary ambient air quality standard for the pollutant or meets the national primary or secondary ambient air quality standard for the pollutant.

State Designation Categories
Unclassified: A pollutant is designated unclassified if the data are incomplete and do not support a designation of attainment or non‐attainment.

Attainment: A pollutant is designated attainment if the State standard for that pollutant was not violated at any site in the area during a three‐year period.

Non‐attainment: A pollutant is designated non‐attainment if there was at least one violation of a State standard for that pollutant in the area.

Non‐Attainment/Transitional: A subcategory of the non‐attainment designation. An area is designated non‐attainment/transitional to signify that the area is close to attaining the standard for the pollutant.

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25 In 1988, the State of California passed the CCAA (State 1988 Statutes, Chapter 568), which set forth a program for achieving more stringent California Ambient Air Quality Standards. The CARB implements State ambient air quality standards, as required in the CCAA, and cooperates with the federal government in implementing pertinent sections of the FCAA Amendments (FCAAA).

Further, CARB regulates vehicular emissions throughout the State. The SJVAPCD regulates stationary sources, as well as some mobile sources. Attainment of the more stringent State PM10 Air Quality Standards is not currently required.

The EPA uses six "criteria pollutants" as indicators of air quality and has established for each of them a maximum concentration above which adverse effects on human health may occur. These threshold concentrations are called the NAAQS.

The SJVAPCD operates regional air quality monitoring networks that provide information on average concentrations of pollutants for which State or federal agencies have established ambient air quality standards. Descriptions of nine pollutants of importance in Merced County follow.

2.6.1 Ozone (1‐hour and 8‐hour)
The most severe air quality problem in the Air Basin is the high level of ozone. Ozone occurs in two layers of the atmosphere. The layer surrounding the earth’s surface is the troposphere.

Here, ground level, or “bad” ozone, is an air pollutant that damages human health, vegetation, and many common materials. It is a key ingredient of urban smog. The troposphere extends to a level about 10 miles up, where it meets the second layer, the stratosphere. The stratospheric, or “good” ozone layer, extends upward from about 10 to 30 miles and protects life on earth from the sun’s harmful ultraviolet rays.
“Bad” ozone is what is known as a photochemical pollutant. It needs reactive organic gases (ROG), NOx, and sunlight. ROG and NOx are emitted from various sources throughout Merced County. In order to reduce ozone concentrations, it is necessary to control the emissions of these ozone precursors.

Significant ozone formation generally requires an adequate number of precursors in the atmosphere and several hours in a stable atmosphere with strong sunlight. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins.

Ozone is a regional air pollutant. It is generated over a large area and is transported and spread by wind. Ozone, the primary constituent of smog, is the most complex, difficult to control, and pervasive of the criteria pollutants. Unlike other pollutants, ozone is not emitted directly into the air by specific sources. Ozone is created by sunlight acting on other air pollutants (called precursors), specifically NOx and ROG. Sources of precursor gases to the photochemical reaction Merced Gateway Residential Property Development
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26 that form ozone number in the thousands. Common sources include consumer products, gasoline vapors, chemical solvents, and combustion products of various fuels. Originating from gas stations, motor vehicles, large industrial facilities, and small businesses such as bakeries and dry cleaners, the ozone‐forming chemical reactions often take place in another location, catalyzed by sunlight and heat. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins. Approximately 50 million people lived in counties with air quality levels above the EPA’s health‐based national air quality standard in 1994. The highest levels of ozone were recorded in Los Angeles, closely followed by the San Joaquin Valley. High levels also persist in other heavily populated areas, including the Texas Gulf Coast and much of the Northeast.

While the ozone in the upper atmosphere absorbs harmful ultraviolet light, ground‐level ozone is damaging to the tissues of plants, animals, and humans, as well as to a wide variety of inanimate materials such as plastics, metals, fabrics, rubber, and paints. Societal costs from ozone damage include increased medical costs, the loss of human and animal life, accelerated replacement of industrial equipment, and reduced crop yields.  Health Effects
While ozone in the upper atmosphere protects the earth from harmful ultraviolet radiation, high concentrations of ground‐level ozone can adversely affect the human respiratory system. Many respiratory ailments, as well as cardiovascular disease, are aggravated by exposure to high ozone levels. Ozone also damages natural ecosystems, such as: forests and foothill communities; agricultural crops; and some man‐made materials, such as rubber, paint, and plastic. High levels of ozone may negatively affect immune systems, making people more susceptible to respiratory illnesses, including bronchitis and pneumonia. Ozone accelerates aging and exacerbates pre‐existing asthma and bronchitis and, in cases with high concentrations, can lead to the development of asthma in active children. Active people, both children and adults, appear to be more at risk from ozone exposure than those with a low level of activity. Additionally, the elderly and those with respiratory disease are also considered sensitive populations for ozone.

People who work or play outdoors are at a greater risk for harmful health effects from ozone.

Children and adolescents are also at greater risk because they are more likely than adults to spend time engaged in vigorous activities. Research indicates that children under 12 years of age spend nearly twice as much time outdoors daily than adults. Teenagers spend at least twice as much time as adults in active sports and outdoor activities. In addition, children inhale more air per pound of body weight than adults, and they breathe more rapidly than adults. Children are less likely than adults to notice their own symptoms and avoid harmful exposures.

Ozone is a powerful oxidant—it can be compared to household bleach, which can kill living cells (such as germs or human skin cells) upon contact. Ozone can damage the respiratory Merced Gateway Residential Property Development
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27 tract, causing inflammation and irritation, and it can induce symptoms such as coughing, chest tightness, shortness of breath, and worsening of asthmatic symptoms. Ozone in sufficient doses increases the permeability of lung cells, rendering them more susceptible to toxins and microorganisms. Exposure to levels of ozone above the current ambient air quality standard leads to lung inflammation and lung tissue damage and a reduction in the amount of air inhaled into the lungs.

The CARB found ozone standards in Merced County nonattainment of Federal and State standards.

2.6.2 Suspended PM (PM10 and PM2.5)
Particulate matter pollution consists of very small liquid and solid particles that remain suspended in the air for long periods. Some particles are large or concentrated enough to be seen as soot or smoke. Others are so small they can be detected only with an electron microscope. Particulate matter is a mixture of materials that can include smoke, soot, dust, salt, acids, and metals. Particulate matter is emitted from stationary and mobile sources, including diesel trucks and other motor vehicles; power plants; industrial processes; wood‐burning stoves and fireplaces; wildfires; dust from roads, construction, landfills, and agriculture; and fugitive windblown dust. PM10 refers to particles less than or equal to 10 microns in aerodynamic diameter. PM2.5 refers to particles less than or equal to 2.5 microns in aerodynamic diameter and are a subset of PM10. Particulates of concern are those that are 10 microns or less in diameter. These are small enough to be inhaled, pass through the respiratory system and lodge in the lungs, possibly leading to adverse health effects.

In the western United States, there are sources of PM10 in both urban and rural areas. Because particles originate from a variety of sources, their chemical and physical compositions vary widely. The composition of PM10 and PM2.5 can also vary greatly with time, location, the sources of the material and meteorological conditions. Dust, sand, salt spray, metallic and mineral particles, pollen, smoke, mist, and acid fumes are the main components of PM10 and PM2.5. In addition to those listed previously, secondary particles can also be formed as precipitates from chemical and photochemical reactions of gaseous sulfur dioxide (SO2) and NOx in the atmosphere to create sulfates (SO4) and nitrates (NO3). Secondary particles are of greatest concern during the winter months where low inversion layers tend to trap the precursors of secondary particulates.

The district’s 2008 PM2.5 Plan built upon the aggressive emission reduction strategy adopted in the 2007 Ozone Plan and strives to bring the valley into attainment status for the 1997 NAAQS for PM2.5. The district’s 2012 PM2.5 Plan provides multiple control strategies to reduce emissions of PM2.5 and other pollutants that form PM2.5. The plan’s comprehensive control strategy includes regulatory actions, incentive programs, technology advancement, policy and legislative positions, public outreach, participation and communication, and additional strategies.

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28  Health Effects
PM10 and PM2.5 particles are small enough—about one‐seventh the thickness of a human hair, or smaller—to be inhaled and lodged in the deepest parts of the lung where they evade the respiratory system’s natural defenses. Health problems begin as the body reacts to these foreign particles. Acute and chronic health effects associated with high particulate levels include the aggravation of chronic respiratory diseases, heart and lung disease, and coughing, bronchitis, and respiratory illnesses in children. Recent mortality studies have shown a statistically significant direct association between mortality and daily concentrations of particulate matter in the air. Non‐health‐related effects include reduced visibility and soiling of buildings. PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections.

PM10 and PM2.5 can aggravate respiratory disease and cause lung damage, cancer, and premature death.

Although particulate matter can cause health problems for everyone, certain people are especially vulnerable to adverse health effects of PM10. These “sensitive populations” include children, the elderly, exercising adults, and those suffering from chronic lung disease such as asthma or bronchitis. Of greatest concern are recent studies that link PM10 exposure to the premature death of people who already have heart and lung disease, especially the elderly. Acidic PM10 can also damage manmade materials and is a major cause of reduced visibility in many parts of the United States.

The CARB found PM10 standards in Merced County in attainment of Federal standards and nonattainment for State standards. The CARB found PM2.5 standards in Merced County nonattainment of Federal and State standards.

2.6.3 Carbon Monoxide (CO)
Carbon monoxide (CO) is emitted by mobile and stationary sources as a result of incomplete combustion of hydrocarbons or other carbon‐based fuels. CO is an odorless, colorless, poisonous gas that is highly reactive. CO is a byproduct of motor vehicle exhaust, contributes more than two thirds of all CO emissions nationwide. In cities, automobile exhaust can cause as much as 95 percent of all CO emissions. These emissions can result in high concentrations of CO, particularly in local areas with heavy traffic congestion. Other sources of CO emissions include industrial processes and fuel combustion in sources such as boilers and incinerators. Despite an overall downward trend in concentrations and emissions of CO, some metropolitan areas still experience high levels of CO.

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29  Health Effects
CO enters the bloodstream and binds more readily to hemoglobin than oxygen, reducing the oxygen‐carrying capacity of blood and thus reducing oxygen delivery to organs and tissues.

The health threat from CO is most serious for those who suffer from cardiovascular disease.

Healthy individuals are also affected but only at higher levels of exposure. At high concentrations, CO can cause heart difficulties in people with chronic diseases and can impair mental abilities. Exposure to elevated CO levels is associated with visual impairment, reduced work capacity, reduced manual dexterity, poor learning ability, difficulty performing complex tasks, and in prolonged, enclosed exposure, death.

The adverse health effects associated with exposure to ambient and indoor concentrations of CO are related to the concentration of carboxyhemoglobin (COHb) in the blood. Health effects observed may include an early onset of cardiovascular disease; behavioral impairment; decreased exercise performance of young, healthy men; reduced birth weight; sudden infant death syndrome (SIDS); and increased daily mortality rate.

Most of the studies evaluating adverse health effects of CO on the central nervous system examine high‐level poisoning. Such poisoning results in symptoms ranging from common flu and cold symptoms (shortness of breath on mild exertion, mild headaches, and nausea) to unconsciousness and death.

The CARB found CO standards in Merced County as unclassified/attainment of Federal standards and attainment for State standards.

2.6.4 Nitrogen Dioxide (NO2)
Nitrogen oxides (NOx) are a family of highly reactive gases that are primary precursors to the formation of ground‐level ozone and react in the atmosphere to form acid rain. NOx is emitted from combustion processes in which fuel is burned at high temperatures, principally from motor vehicle exhaust and stationary sources such as electric utilities and industrial boilers. A brownish gas, NOx is a strong oxidizing agent that reacts in the air to form corrosive nitric acid, as well as toxic organic nitrates. EPA regulates only nitrogen dioxide (NO2) as a surrogate for this family of compounds because it is the most prevalent form of NOx in the atmosphere that is generated by anthropogenic (human) activities.1
 Health Effects
NOx is an ozone precursor that combines with Reactive Organic Gases (ROG) to form ozone.

See the ozone section above for a discussion of the health effects of ozone.

Direct inhalation of NOx can also cause a wide range of health effects. NOx can irritate the 1 United States Environmental Protection Agency (EPA), Nitrogen Oxides (NOx). Why and How They Are Controlled, 456/F‐99‐ 006R, November 2019
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30 lungs, cause lung damage, and lower resistance to respiratory infections such as influenza.

Short‐term exposures (e.g., less than 3 hours) to low levels of nitrogen dioxide (NO2) may lead to changes in airway responsiveness and lung function in individuals with preexisting respiratory illnesses. These exposures may also increase respiratory illnesses in children.

Long‐term exposures to NO2 may lead to increased susceptibility to respiratory infection and may cause irreversible alterations in lung structure. Other health effects associated with NOx are an increase in the incidence of chronic bronchitis and lung irritation. Chronic exposure to NO2 may lead to eye and mucus membrane aggravation, along with pulmonary dysfunction.

NOx can cause fading of textile dyes and additives, deterioration of cotton and nylon, and corrosion of metals due to production of particulate nitrates. Airborne NOx can also impair visibility. NOx is a major component of acid deposition in California. NOx may affect both terrestrial and aquatic ecosystems. NOx in the air is a potentially significant contributor to a number of environmental effects such as acid rain and eutrophication in coastal waters.

Eutrophication occurs when a body of water suffers an increase in nutrients that reduce the amount of oxygen in the water, producing an environment that is destructive to fish and other animal life.

NO2 is toxic to various animals as well as to humans. Its toxicity relates to its ability to combine with water to form nitric acid in the eye, lung, mucus membranes, and skin. Studies of the health impacts of NO2 include experimental studies on animals, controlled laboratory studies on humans, and observational studies.

In animals, long‐term exposure to NOx increases susceptibility to respiratory infections, lowering their resistance to such diseases as pneumonia and influenza. Laboratory studies show susceptible humans, such as asthmatics, exposed to high concentrations of NO2, can suffer lung irritation and, potentially, lung damage. Epidemiological studies have also shown associations between NO2 concentrations and daily mortality from respiratory and cardiovascular causes as well as hospital admissions for respiratory conditions.

NOx contributes to a wide range of environmental effects both directly and when combined with other precursors in acid rain and ozone. Increased nitrogen inputs to terrestrial and wetland systems can lead to changes in plant species composition and diversity. Similarly, direct nitrogen inputs to aquatic ecosystems such as those found in estuarine and coastal waters can lead to eutrophication as discussed above. Nitrogen, alone or in acid rain, also can acidify soils and surface waters. Acidification of soils causes the loss of essential plant nutrients and increased levels of soluble aluminum, which is toxic to plants. Acidification of surface waters creates conditions of low pH and levels of aluminum that are toxic to fish and other aquatic organisms.

The CARB found NO2 standards in Merced County as unclassified/attainment of Federal standards and attainment for State standards.

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31 2.6.5 Sulfur Dioxide (SO2)
The major source of sulfur dioxide (SO2) is the combustion of high‐sulfur fuels for electricity generation, petroleum refining and shipping. High concentrations of SO2 can result in temporary breathing impairment for asthmatic children and adults who are active outdoors. Short‐term exposures of asthmatic individuals to elevated SO2 levels during moderate activity may result in breathing difficulties that can be accompanied by symptoms such as wheezing, chest tightness, or shortness of breath. Other effects that have been associated with longer‐term exposures to high concentrations of SO2, in conjunction with high levels of PM, include aggravation of existing cardiovascular disease, respiratory illness, and alterations in the lungs’ defenses. SO2 also is a major precursor to PM2.5, which is a significant health concern and a main contributor to poor visibility. In humid atmospheres, sulfur oxides can react with vapor to produce sulfuric acid, a component of acid rain.

The CARB found SO2 standards in Merced County as unclassified for Federal standards and attainment for State standards.

2.6.6 Lead (Pb)
Lead, a naturally occurring metal, can be a constituent of air, water, and the biosphere. Lead is neither created nor destroyed in the environment, so it essentially persists forever. Lead was used until recently to increase the octane rating in automobile fuel. Since the 1980s, lead has been phased out in gasoline, reduced in drinking water, reduced in industrial air pollution, and banned or limited in consumer products. Gasoline‐powered automobile engines were a major source of airborne lead through the use of lead fuels; however, the use of leaded fuel has been mostly phased out. Since this occurred the ambient concentrations of lead have dropped dramatically.

Exposure to lead occurs mainly through inhalation of air and ingestion of lead in food, water, soil, or dust. It accumulates in the blood, bones, and soft tissues and can adversely affect the kidneys, liver, nervous system, and other organs. Excessive exposure to lead may cause neurological impairments such as seizures, mental retardation, and behavioral disorders. Even at low doses, lead exposure is associated with damage to the nervous systems of fetuses and young children.

Effects on the nervous systems of children are one of the primary health risk concerns from lead.

In high concentrations, children can even suffer irreversible brain damage and death. Children 6 years old and under are most at risk, because their bodies are growing quickly.

The CARB found Lead standards in Merced County as unclassified/attainment of Federal standards and attainment for State standards.

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32 2.6.7 Toxic Air Contaminants (TAC)
In addition to the criteria pollutants discussed above, Toxic Air Contaminants (TAC) are another group of pollutants of concern. TAC is injurious in small quantities and are regulated despite the absence of criteria documents. The identification, regulation and monitoring of TAC is relatively recent compared to that for criteria pollutants. Unlike criteria pollutants, TAC is regulated on the basis of risk rather than specification of safe levels of contamination. The ten TAC are acetaldehyde, benzene, 1,3‐butadiene, carbon tetrachloride, hexavalent chromium, para‐ dichlorobenzene, formaldehyde, methylene chloride, perchloroethylene, and diesel particulate matter (diesel PM). Caltrans’ guidance for transportation studies references the Federal Highway Administration (FHWA) memorandum titled “Interim Guidance on Air Toxic Analysis in NEPA Documents” which discusses emissions quantification of six “priority” compounds of 21 Mobile Source Air Toxics (MSAT) identified by the United States Environmental Protection Agency (USEPA). The six “priority” compounds are diesel exhaust (particulate matter and organic gases), benzene, 1,3‐butadiene, acetaldehyde, formaldehyde, and acrolein.

Some studies indicate that diesel PM poses the greatest health risk among the TAC listed above.

A 10‐year research program (California Air Resources Board 1998) demonstrated that diesel PM from diesel‐fueled engines is a human carcinogen and that chronic (long‐term) inhalation exposure to diesel PM poses a chronic health risk. In addition to increasing the risk of lung cancer, exposure to diesel exhaust can have other health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. Diesel exhaust is a major source of fine particulate pollution as well, and studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems.

Diesel PM differs from other TAC in that it is not a single substance but a complex mixture of hundreds of substances. Although diesel PM is emitted by diesel‐fueled, internal combustion engines, the composition of the emissions varies, depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emission control system is present.

Unlike the other TAC, however, no ambient monitoring data is available for diesel PM because no routine measurement method currently exists. The CARB has made preliminary concentration estimates based on a diesel PM exposure method. This method uses the CARB emissions inventory’s PM10 database, ambient PM10 monitoring data, and the results from several studies to estimate concentrations of diesel PM. Table 4 depicts the CARB Handbook’s recommended buffer distances associated with various types of common sources.

Existing air quality concerns within Merced and the entire SJVAB are related to increases of regional criteria air pollutants (e.g., ozone and particulate matter), exposure to toxic air contaminants, odors, and increases in greenhouse gas emissions contributing to climate change.

The primary source of ozone (smog) pollution is motor vehicles. Particulate matter is caused by dust, primarily dust generated from construction and grading activities, and smoke which is emitted from fireplaces, wood‐burning stoves, and agricultural burning.

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33 TABLE 4
Recommendations on Siting New Sensitive Land Uses Such as Residences, Schools, Daycare Centers, Playgrounds, or Medical Facilities*
SOURCE CATEGORY ADVISORY RECOMMENDATIONS
Freeways and High‐Traffic Roads 1 ‐ Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day.

Distribution Centers
‐ Avoid siting new sensitive land uses within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units (TRUs) per day, or where TRU unit operations exceed 300 hours per week).
‐ Take into account the configuration of existing distribution centers and avoid locating residences and other new sensitive land uses near entry and exit points.

Rail Yards
‐ Avoid siting new sensitive land uses within 1,000 feet of a major service and maintenance rail yard. ‐ Within one mile of a rail yard, consider possible siting limitations and mitigation approaches.

Ports ‐ Avoid siting of new sensitive land uses immediately downwind of ports in the most heavily impacted zones. Consult local air districts or the ARB on the status of pending analyses of health risks.

Refineries ‐ Avoid siting new sensitive land uses immediately downwind of petroleum refineries. Consult with local air districts and other local agencies to determine an appropriate separation.

Chrome Platers ‐ Avoid siting new sensitive land uses within 1,000 feet of a chrome plater.

Dry Cleaners Using Perchloroethylene
‐ Avoid siting new sensitive land uses within 300 feet of any dry cleaning operation. For operations with two or more machines, provide 500 feet. For operations with 3 or more machines, consult with the local air district.
‐ Do not site new sensitive land uses in the same building with perchloroethylene dry cleaning operations.

Gasoline Dispensing Facilities
‐ Avoid siting new sensitive land uses within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater). A 50 foot separation is recommended for typical gas dispensing facilities.

Source: SJVAPCD 2024
1: The recommendation to avoid siting new sensitive land uses within 500 feet of a freeway was identified in CARB’s Air Quality and Land Use Handbook published in 2005. CARB recently published a technical advisory to the Air Quality and Land Use Handbook indicating that new research has demonstrated promising strategies to reduce pollution exposure along transportation corridors. *Notes:
• These recommendations are advisory. Land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues. • Recommendations are based primarily on data showing that the air pollution exposures addressed here (i.e., localized) can be reduced as much as 80% with the recommended separation.
• The relative risk for these categories varies greatly (see Table 1‐2). To determine the actual risk near a particular facility, a site‐specific analysis would be required. Risk from diesel PM will decrease over time as cleaner technology phases in. • These recommendations are designed to fill a gap where information about existing facilities may not be readily available and are not designed to substitute for more specific information if it exists. The recommended distances take into account other factors in addition to available health risk data (see individual category descriptions).
• Site‐specific project design improvements may help reduce air pollution exposures and should also be considered when siting new sensitive land uses.
• This table does not imply that mixed residential and commercial development in general is incompatible. Rather it focuses on known problems like dry cleaners using perchloroethylene that can be addressed with reasonable preventative actions. • A summary of the basis for the distance recommendations can be found in the ARB Handbook: Air Quality and Land Use Handbook: A Community Health Perspective.

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34 2.6.8 Odors
Typically, odors are regarded as an annoyance rather than a health hazard. However, manifestations of a person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache).

With respect to odors, the human nose is the sole sensing device. The ability to detect odors varies considerably among the population and overall is quite subjective. Some individuals have the ability to smell minute quantities of specific substances; others may not have the same sensitivity but may have sensitivities to odors of other substances. In addition, people may have different reactions to the same odor; in fact, an odor that is offensive to one person (e.g., from a fast‐food restaurant) may be perfectly acceptable to another. It is also important to note that an unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. This is because of the phenomenon known as odor fatigue, in which a person can become desensitized to almost any odor and recognition only occurs with an alteration in the intensity.

For example, a person may use the word “strong” to describe the intensity of an odor. Odor intensity depends on the odorant concentration in the air.

When an odorous sample is progressively diluted, the odorant concentration decreases. As this occurs, the odor intensity weakens and eventually becomes so low that the detection or recognition of the odor is quite difficult. At some point during dilution, the concentration of the odorant reaches a detection threshold. An odorant concentration below the detection threshold means that the concentration in the air is not detectable by the average human.

The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJVAB. The types of facilities that are known to produce odors are shown in Table 5 along with a reasonable distance from the source within which the degree of odors could possibly be significant. The Project does not propose any uses that would be potential odor sources; however, the information presented in Table 5 will be used as a screening level analysis to determine if the Project would be impacted by existing odor sources in the study area. Such information is presented for informational purposes, but it is noted that the environment’s effect on the Project, including exposure to potential odors, would not be an impact for CEQA purposes.

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35 TABLE 5
Screening Levels for Potential Odor Sources

2.6.9 Naturally Occurring Asbestos (NOA)
Asbestos is a term used for several types of naturally occurring fibrous minerals found in many parts of California. The most common type of asbestos is chrysotile, but other types are also found in California. Asbestos is commonly found in ultramafic rock and near fault zones. The amount of asbestos that is typically present in these rocks’ ranges from less than 1% up to approximately 25% and sometimes more. It is released from ultramafic rock when it is broken or crushed. This can happen when cars drive over unpaved roads or driveways, which are surfaced with these rocks, when land is graded for building purposes, or at quarrying operations.

Asbestos is also released naturally through weathering and erosion. Once released from the rock, asbestos can become airborne and may stay in the air for long periods of time. Asbestos is hazardous and can cause lung disease and cancer dependent upon the level of exposure. The longer a person is exposed to asbestos and the greater the intensity of the exposure, the greater the chances for a health problem.

The proposed Project's construction phase may cause asbestos to become airborne due to the construction activities that will occur on site. The Project would be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021.

2.6.10 Greenhouse Gas Emissions
Gases that trap heat in the atmosphere are often called greenhouse gases. Some greenhouse Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Compositing Facility 1 mile
Petroleum Refinery 2 miles
Asphalt Batch Plant 1 mile
Chemical Manufacturing 1 mile
Fiberglass Manufacturing 1 mile
Painting/Coating Operations (e.g. auto body shops) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Type of Facility Distance
Source: SJVAPCD 2024
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36 gases such as carbon dioxide occur naturally and are emitted to the atmosphere through natural processes and human activities. Other greenhouse gases (e.g., fluorinated gases) are created and emitted solely through human activities. The principal greenhouse gases that enter the atmosphere because of human activities are:
 Carbon Dioxide (CO2): Carbon dioxide enters the atmosphere through the burning of fossil fuels (oil, natural gas, and coal), solid waste, trees and wood products, and also as a result of other chemical reactions (e.g., manufacture of cement, asphalt paving, truck trips). Carbon dioxide is also removed from the atmosphere (or "sequestered") when it is absorbed by plants as part of the biological carbon cycle.
 Methane (CH4): Methane is emitted during the production and transport of coal, natural gas, and oil. Methane emissions also result from livestock and other agricultural practices and by the decay of organic waste in municipal solid waste landfills.  Nitrous Oxide (N2O): Nitrous oxide is emitted during agricultural and industrial activities, as well as during combustion of fossil fuels and solid waste.  Fluorinated Gases: Hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride are synthetic, powerful greenhouse gases that are emitted from a variety of industrial processes.

Fluorinated gases are sometimes used as substitutes for ozone‐depleting substances (i.e., CFCs, HCFCs, and halons). These gases are typically emitted in smaller quantities, but because they are potent greenhouse gases, they are sometimes referred to as High Global Warming Potential gases ("High GWP gases").

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37 3.0 Air‐Quality Impacts

3.1 Methodology
The impact assessment for air quality focuses on potential effects the Project might have on air quality within the Merced region. The SJVAPCD has established thresholds of significance for determining environmental significance. These thresholds separate a project’s short‐term emissions from its long‐term emissions. The short‐term emissions are mainly related to the construction phase of a project, which are recognized to be short in duration. The long‐term emissions are primarily related to the activities that will occur indefinitely as a result of Project operations. Impacts will be evaluated both on the basis of CEQA Appendix G criteria and SJVAPCD significance criteria. The impacts to be evaluated will be those involving construction and operational emissions of criteria pollutants. The SJVAPCD has established thresholds for certain pollutants shown in Table 6.

Table 6
SJVAPCD Air Quality Thresholds of Significance

3.1.1 CalEEMod
CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects. The model quantifies direct emissions from construction and operations (including vehicle use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use.

The model is an accurate and comprehensive tool for quantifying air quality impacts from land use projects throughout California. The model can be used for a variety of situations where an air quality analysis is necessary or desirable such as CEQA and NEPA documents, pre‐project planning, compliance with local air quality rules and regulations, etc.

CO NOX ROG SOX PM10 PM2.5
Construction Emissions 100 10 10 27 15 15
Operational Emissions
(Permitted Equipment and Activities)
100 10 10 27 15 15
Operational Emissions
(Non‐Permitted Equipment and Activities)
100 10 10 27 15 15
Project Type
Ozone Precursor Emissions (tons/year)
Source: SJVAPCD 2024
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38 3.2 Short‐Term Impacts
Short‐term impacts are mainly related to the construction phase of a project and are recognized to be short in duration. Construction air quality impacts are generally attributable to dust and exhaust pollutants generated by equipment and vehicles. Fugitive dust is emitted both during construction activity and as a result of wind erosion over exposed earth surfaces. Clearing and earth moving activities do comprise major sources of construction dust emissions, but traffic and general disturbances of soil surfaces also generate significant dust emissions. Further, dust generation is dependent on soil type and soil moisture. Exhaust pollutants are the non‐useable gaseous waste products produced during the combustion process. Engine exhaust contains CO, HC, and NOx pollutants which are harmful to the environment.

Adverse effects of construction activities cause increased dust‐fall and locally elevated levels of total suspended particulate. Dust‐fall can be a nuisance to neighboring properties or previously completed developments surrounding or within the Project area and may require frequent washing during the construction period.

PM10 emissions can result from construction activities of the Project. The SJVAPCD has determined that compliance with Regulation VIII and other control measures will constitute sufficient mitigation to reduce PM10 impacts to a level considered less‐than significant for most development projects. Even with implementation of District Regulation VIII and District Rule 9510, large development projects may not be able to reduce project specific construction impacts below District thresholds of significance.

Ozone precursor emissions are also an impact of construction activities and can be quantified through calculations. Numerous variables factored into estimating total construction emission include level of activity, length of construction period, number of pieces and types of equipment in use, site characteristics, weather conditions, number of construction personnel, and amount of materials to be transported onsite or offsite. Additional exhaust emissions would be associated with the transport of workers and materials. Because the specific mix of construction equipment is not presently known for this Project, construction emissions were estimated using CalEEMod Model defaults for construction equipment.

Table 7 shows the CalEEMod estimated construction emissions that would be generated from construction of the Project. Results of the analysis show that emissions generated from construction of the Project will not exceed the SJVAPCD emission thresholds.

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39 Table 7
Project Construction Emissions (tons/year)

3.3 Long‐Term Emissions
Long‐Term emissions from the Project would be generated primarily by mobile source (vehicle) emissions from the Project site and area sources such as lawn maintenance equipment.

3.3.1 Localized Operational Emissions – Ozone/Particulate Matter The Merced County area is nonattainment for Federal and State air quality standards for ozone, attainment of Federal standards for PM10 and nonattainment for State standards, and nonattainment for Federal and State standards for PM2.5. Nitrogen oxides and reactive organic gases are regulated as ozone precursors. Significant criteria have been established for criteria pollutant emissions as documented in Section 3.1. Operational emissions have been estimated for the Project using the CalEEMod Model and detailed results are included in Appendix A of this report.

Results of the CalEEMod analysis are shown in Table 8 for operational emissions. Results indicate that the annual operational emissions from the Project will be less than the SJVAPCD emission thresholds for criteria pollutants.

Table 8
Project Operational Emissions (tons/year)

3.3.2 Localized Operational Emissions
 Carbon Monoxide
The SJVAPCD is currently in unclassified/attainment for Federal standards and unclassified Project Construction Emissions 2.832.763.580.011.130.54 682.64 SJVAPCD Level of Significance 100 10 10 27 15 15 None
Does the Project Exceed Standard? NoNoNoNo NoNoNo
Source: CalEEMod
Summary Report CO NOX ROG SOx PM10 PM2.5 CO2e
Project Opeational Emissions 30.70 5.51 8.61 0.07 7.83 2.20 8,097.77 SJVAPCD Level of Significance 100 10 10 27 15 15 None
Does the Project Exceed Standard? NoNoNoNo NoNoNo
Source: CalEEMod
Summary Report CO NOX ROG SOx PM10 PM2.5 CO2e

I I I I I I I

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40 for State standards for CO. An analysis of localized CO concentrations is typically warranted to ensure that standards are maintained. Also, an analysis is required to ensure that localized concentrations don’t reach potentially unhealthful levels that could affect sensitive receptors (residents, school children, hospital patients, the elderly, etc.).

Typically, high CO concentrations are associated with roadways or intersections operating at an unacceptable Level of Service (LOS). CO “Hot Spot” modeling is required if a traffic study reveals that the project will reduce the LOS on one or more streets to E or F or if the project will worsen an existing LOS F.

To analyze the Cumulative Year 2046 Plus Project “worst case” CO concentrations at study roadway segments, the analysis methodology considered the highest annual maximum CO concentration reported in 2013, using 1.0 PPM as an estimate of the background concentration for the 8‐hour standard and 2.2 PPM for the 1‐hour standard (source: CARB annual publications). Other modeling assumptions include a wind speed of .5 m/s, flat topography, 1,000‐meter mixing height, and a 5‐degree wind deviation.  Toxic Air Contaminants (TAC)
The SJVAPCD’s Guidance Document, Guidance for Assessing and Mitigating Air Quality Impacts – 2015, identifies the need for projects to analyze the potential for adverse air quality impacts to sensitive receptors. Sensitive receptors refer to those segments of the population most susceptible to poor air quality (i.e., children, the elderly, and those with pre‐existing serious health problems affected by air quality). Land uses that have the greatest potential to attract these types of sensitive receptors include schools, parks, playgrounds, daycare centers, nursing homes, hospitals, and residential communities. From a health risk perspective, the Project is a Type B Project in that it may potentially place sensitive receptors in the vicinity of existing sources.

The first step in evaluating the potential for impacts to sensitive receptors for TAC’s from the Project is to perform a screening level analysis. For Type B Projects, one type of screening tool is found in the CARB Handbook: Air Quality and Land Use Handbook: A Community Perspective. This handbook includes a table (depicted in Table 4) with recommended buffer distances associated with various types of common sources. Table 4 indicates that new sensitive land uses shouldn’t be sited within 500 feet of a freeway/urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. State Route (SR) 99, located approximately 1,700 feet from the Project site, carries approximately 52,000 Annual Average Daily Trips (AADT). The Project, particularly its residential uses, are located more than 500 feet from SR 99.

There is an existing gas station (ARCO) located at the southeast corner of Campus Parkway and Coffee Street which offers eight (8) fueling pumps or 16 fueling positions. While the yearly gasoline throughput of the existing gas station is not known, the Project site is located Merced Gateway Residential Property Development
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41 more than 1,200 feet to the east.

An evaluation of nearby land uses considering CARB’s Pollution Mapping Tool shows that the Project will not place sensitive receptors in the vicinity of existing toxic sources. The Project is located more than five (5) miles from the Hilmar Cheese Company, a known toxic emitting source. This facility is the nearest toxic emitting source to the Project site based upon CARB’s Pollution Mapping Tool. The screening level analysis for the Project shows that TACs are not a concern based upon the recommendations provided in Table 4 and CARB’s Pollution Mapping Tool.
 Construction
In 1998, the California Environmental Protection Agency (CalEPA) classified diesel exhaust particulate matter (DPM) as a toxic air contaminant (TAC) due to its potential to cause cancer, premature death, and other health issues. The highest potential for TAC emissions during construction is associated with diesel particulate matter emissions from heavy‐duty equipment for construction related activities such as demolition, site preparation, paving, building construction, grading and other miscellaneous activities. Diesel exhaust from construction equipment operating at the site poses a health risk to nearby sensitive receptors. The nearest sensitive receptors include the residences to the north of Gerard Avenue and just south of Mission Avenue, located approximately 125 feet from the northern and southern boundaries of the Project site.

Health risks from diesel‐exhaust emissions mainly arise from long‐term exposure and the risk of cancer. Diesel‐powered construction equipment will be used intermittently across the site.

State regulations limit idling to 5 minutes, reducing temporary DPM emissions exposure for sensitive receptors. Even during peak construction, diesel PM emissions will come from various locations due to different construction activities not happening in the same place simultaneously. Cancer risk was calculated using the most recent version of the Office of Environmental Health Hazard Assessment (OEHHA) guidelines for health risk assessments.

TAC emissions associated with the construction of the Project were used to assess impacts to adjacent sensitive receptors. Table 9 shows the analysis results for maximally exposed individuals at nearby sensitive receptors. A threshold of 10 in one million was used instead of the SJVAPCD’s 20 in one million due to the uncertainties in assessing cancer risk from short‐ term construction exposures. The OEHHA guidelines suggest a lower cancer risk threshold for managing short‐term projects.

Results of the analysis show that TAC emissions at residences adjacent to the Project site would exceed the 10 in one million threshold from construction activities. Implementation of Mitigation Measure AQ‐1, discussed in Section 4.0, would be required to reduce substantial pollutant concentrations during Project construction.

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42 Table 9
Health Risks from Project Construction
 Odors
Typically, odors are regarded as an annoyance rather than a health hazard. However, manifestations of a person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache).

Quality and intensity are two properties present in any odor. The quality of an odor indicates the nature of the smell experience. For instance, if a person describes an odor as flowery or sweet, then the person is describing the quality of the odor. Intensity refers to the strength of the odor. For example, a person may use the word “strong” to describe the intensity of an odor. Odor intensity depends on the odorant concentration in the air.

While offensive odors rarely cause any physical harm, they can be very unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and the SJVAPCD. Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.

The SJVAPCD requires that an analysis of potential odor impacts be conducted for the following two situations:
 Generators – projects that would potentially generate odorous emissions proposed to be located near existing sensitive receptors or other land uses where people may congregate, and
 Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people locating near existing odor sources.

Receptor Type Cancer Risk Chronic HI Acute
Simple HI
1 Residence 4.08E‐05 8.88E‐02 0.00E+00
2 Residence 4.28E‐05 9.33E‐02 0.00E+00
3 Residence 4.32E‐05 9.42E‐02 0.00E+00
4 Residence 4.02E‐05 8.76E‐02 0.00E+00
5 Residence 3.47E‐05 7.57E‐02 0.00E+00
6 Residence 2.91E‐05 6.34E‐02 0.00E+00
7 Residence 1.57E‐05 3.42E‐02 0.00E+00

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43 The Project will not generate odorous emissions given the nature or characteristics of the Project. The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJV Air Basin. The types of facilities that are known to produce odors are shown in Table 5 above along with a reasonable distance from the source within which, the degree of odors could possibly be significant. None of the facilities shown in Table 5 are located within two (2) miles of the Project.
 Naturally Occurring Asbestos (NOA)
Asbestos is a term used for several types of naturally occurring fibrous minerals found in many parts of California. The most common type of asbestos is chrysotile, but other types are also found in California. Construction of the Project may cause asbestos to become airborne due to the construction activities that will occur on site. The Project would be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021. Compliance with Rule 8021 would limit fugitive dust emissions from construction, demolition, excavation, extraction, and other earthmoving activities associated with the Project.

The Dust Control Plan may include the following measures:

1. Water wetting of road surfaces

2. Rinse vehicles and equipment

3. Wet loads of excavated material, and

4. Cover loads of excavated material
 Greenhouse Gas Emissions
CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035.

For the Merced County Association of Governments region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. MCAG’s 2018 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

In 2009, the SJVAPCD adopted the following guidance documents applicable to projects within the San Joaquin Valley:
 Guidance for Valley Land‐use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009), and
 District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009).

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44 This guidance and policy are the reference documents referenced in the SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts adopted in March 2015 (SJVAPCD 2015).

Consistent with the District Guidance and District Policy above, SJVAPCD (2015) acknowledges the current absence of numerical thresholds, and recommends a tiered approach to establish the significance of the GHG impacts on the environment:
i. If a project complies with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, then the project would be determined to have a less than significant individual and cumulative impact for GHG emissions; ii. If a project does not comply with an approved GHG emission reduction plan or mitigation program, then it would be required to implement Best Performance Standards (BPS); and
iii. If a project is not implementing BPS, then it should demonstrate that its GHG emissions would be reduced or mitigated by at least 29 percent compared to Business as Usual (BAU).

As shown in Table 10, the Project would generate 12,292.20 Metric Tons of Carbon Dioxide Equivalent per year (MTCO2eq./year) using an operational year of 2005, which includes area, energy, mobile, waste, and water sources. “Business as usual” (BAU) is referenced in CARB’s AB 32 Scoping Plan as emissions projected to occur in 2020 if the average baseline emissions during the 2002‐2004 period grew to 2020 levels, without control or Best Performance Standards (BPS) offsets. As a result, an estimate of the Project’s operational emissions in 2005 were compared to operational emissions in 2020 in order to determine if the Project meets the 29% emission reduction. The SJVAPCD has reviewed relevant scientific information related to GHG emissions and has determined that they are not able to determine a specific quantitative level of GHG emissions increase, above which a project would have a significant impact on the environment, and below which would have an insignificant impact. As a result, the SJVAPCD has determined that projects achieving at least a 29% GHG emission reduction compared to BAU would be determined to have a less than significant individual and cumulative impact for GHG. Results of the analysis show that the Project’s GHG emissions in the year 2020 are 10,230.91 MTCO2eq./year. This represents an achievement of 17% GHG emission reduction based on BAU, which does not meet the 29% GHG emission reduction target.

In the event that a local air district’s guidance for addressing GHG impacts does not use numerical GHG emissions thresholds, at the lead agency’s discretion, a neighboring air district’s GHG threshold may be used to determine impacts. In December 2008, the South Coast Air Quality Management District (SCAQMD) Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is lead agency. The SCAQMD guidance identifies a threshold of 10,000 MTCO2eq./year for GHG for construction emissions amortized over a 30‐year project lifetime, plus annual operation emissions. This threshold is often used by agencies, such as the California Public Utilities Commission, to evaluate GHG impacts in areas that do not have specific thresholds (CPUC Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
45 2015)2. Therefore, because this threshold has been established by the SCAQMD in an effort to control GHG emissions in the largest metropolitan area in the State of California, this threshold is considered a conservative approach for evaluating the significance of GHG emissions in a more rural area, such as Merced County. Though the Project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the Project. Table 11 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model, which is approximately 19% less than the threshold identified by the SCAQMD. Though the Project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the Project.

Table 11 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model.

Table 10
2005/2020 Operational Greenhouse Gas Emissions
Table 11
Project Operational Greenhouse Gas Emissions
2 California Public Utilities Commission (CPUC). 2015. Section 4.7, “Greenhouse Gases.” Final Environmental Impact Report for the Santa Barbara County Reliability Project. May 2015. Accessed January 18, 2018. http://www.cpuc.ca.gov/environment/info/ene/sbcrp/SBCRP_FEIR.html.

Operational Emissions Per Year (2005) 12,292.20 MT/yr
Operational Emissions Per Year (2020) 10,230.91 MT/yr
SJVAPCD Level of Significance 29% Reduction Compared to BAU Does the Project Meet the Standard No
Summary Report CO2e
Source: CalEEMod
Project Operational Emissions Per Year( Plus
amortized construction emissions) 8,120.52 MT/yr
Source: CalEEMod
Summary Report CO2e
Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
46 4.0 Impact Determinations and Recommended
Mitigation
In accordance with CEQA, when a proposed project is consistent with a General Plan for which an EIR has been certified, the effects of that project are evaluated to determine if they will result in project‐specific significant adverse impacts on the environment. The criteria used to determine the significance of an air quality or greenhouse gas impact are based on the following thresholds of significance, which come from Appendix G of the CEQA Guidelines and the General Plan EIR. Accordingly, air quality or greenhouse gas impacts resulting from the Project are considered significant if the Project would:

Air Quality
a) Conflict with or obstruct implementation of the applicable air quality plan? 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?
c) Expose sensitive receptors to substantial pollutant concentrations? d) Result in other emissions such as those leading to odors adversely affecting a substantial number of people?
Greenhouse Gas Emissions
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

4.1 Air Quality

4.1.1 Conflict with or obstruct implementation of the applicable air quality plan The primary way of determining consistency with the air quality plan’s (AQP’s) assumptions is determining consistency with the applicable General Plan to ensure that the Project’s population density and land use are consistent with the growth assumptions used in the AQPs for the air basin.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth, and that designate locations for land uses to regulate growth. MCAG uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
47 the AQPs. Existing and future pollutant emissions computed in the AQP are based on land uses from area general plans. AQPs detail the control measures and emission reductions required for reaching attainment of the air standards.

The applicable General Plan for the project is the County of Merced 2030 General Plan Update, which was adopted in 2011. The Project is consistent with the currently adopted General Plan for the City of Merced and is therefore consistent with the population growth and VMT applied in the plan. Therefore, the Project is consistent with the growth assumptions used in the applicable AQPs. As a result, the Project will not conflict with or obstruct implementation of any air quality plans. Therefore, no mitigation is needed.

4.1.2 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
The Merced County area is nonattainment for Federal and State air quality standards for ozone, in attainment of Federal standards and nonattainment for State standards for PM10, and nonattainment for Federal and State standards for PM2.5. The SJVAPCD has prepared the 2016 and 2013 Ozone Plans, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan to achieve Federal and State standards for improved air quality in the SJVAB regarding ozone and PM. Inconsistency with any of the plans would be considered a cumulatively adverse air quality impact. As discussed in Section 4.1.1, the Project is consistent with the currently adopted General Plan for the City of Merced and is therefore consistent with the population growth and VMT applied in the plan.

Therefore, the Project is consistent with the growth assumptions used in the 2016 and 2013 Ozone Plan, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan.

Project specific emissions that exceed the thresholds of significance for criteria pollutants would be expected to result in a cumulatively considerable net increase of any criteria pollutant for which the County is in non‐attainment under applicable federal or state ambient air quality standards. It should be noted that a project is not characterized as cumulatively insignificant when project emissions fall below thresholds of significance. As discussed in Section 3.1, the SJVAPCD has established thresholds of significance for determining environmental significance which are provided in Table 6.

As discussed above in Section 3.2 and 3.3, results of the analysis show that emissions generated from construction and operation of the Project will be less than the applicable SJVAPCD emission thresholds for criteria pollutants. Therefore, no mitigation is needed.

4.1.3 Expose sensitive receptors to substantial pollutant concentrations The first step in evaluating the potential for impacts to sensitive receptors for TAC’s from the Project is to perform a screening level analysis. For Type B Projects, one type of screening tool is found in the CARB Handbook: Air Quality and Land Use Handbook: A Community Perspective.

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48 This handbook includes a table (depicted in Table 4) with recommended buffer distances associated with various types of common sources. Table 4 indicates that new sensitive land uses shouldn’t be sited within 500 feet of a freeway/urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. State Route (SR) 99, located approximately 1,700 feet from the Project site, carries approximately 52,000 Annual Average Daily Trips (AADT). The Project, particularly its residential uses, are located more than 500 feet from SR 99.

This facility is the nearest toxic emitting source to the Project site based upon CARB’s Pollution Mapping Tool. The screening level analysis for the Project shows that TACs are not a concern based upon the recommendations provided in Table 4 and CARB’s Pollution Mapping Tool.  Construction
Health risks from diesel‐exhaust emissions mainly arise from long‐term exposure and the risk of cancer. Diesel‐powered construction equipment will be used intermittently across the site. State regulations limit idling to 5 minutes, reducing temporary DPM emissions exposure for sensitive receptors. Even during peak construction, diesel PM emissions will come from various locations due to different construction activities not happening in the same place simultaneously. TAC emissions associated with the construction of the Project were used to assess impacts to adjacent sensitive receptors. Table 9 shows the analysis results for maximally exposed individuals at nearby sensitive receptors. A threshold of 10 in one million was used instead of the SJVAPCD’s 20 in one million due to the uncertainties in assessing cancer risk from short‐term construction exposures. Results of the analysis show that TAC emissions at residences adjacent to the Project site would exceed the 10 in one million threshold from construction activities. Implementation of Mitigation Measure AQ‐1 would reduce substantial pollutant concentrations during Project construction as shown in Table 12.
 Mitigation Measure AQ‐1: The Project contractor or Project representatives shall ensure that all off‐road diesel‐powered construction equipment meets the CARB Tier 4 emissions standards or equivalent.

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49 Table 12
Health Risks from Project Construction with Mitigation
Short‐Term Impacts
The annual emissions from the construction phase of the Project will be less than the applicable SJVAPCD emission thresholds for criteria pollutants as shown in Table 8. The construction emissions are therefore considered less than significant with the implementation of the SJVAPCD applicable Regulation VIII control measures, which are provided below.

2. All on‐site unpaved roads and off‐site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

3. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut & fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking.

7. Within urban areas, track out shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday.

Receptor Type Cancer Risk Chronic HI Acute
Simple HI
1 Residence 9.71E‐06 2.12E‐02 0.00E+00
2 Residence 9.88E‐06 2.15E‐02 0.00E+00
3 Residence 9.58E‐06 2.09E‐02 0.00E+00
4 Residence 8.54E‐06 1.86E‐02 0.00E+00
5 Residence 7.34E‐06 1.60E‐02 0.00E+00
6 Residence 6.37E‐06 1.39E‐02 0.00E+00
7 Residence 4.26E‐06 9.28E‐03 0.00E+00

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50 Naturally Occurring Asbestos (NOA)
The proposed Project's construction phase may cause asbestos to become airborne due to the construction activities that will occur on site. In order to control naturally occurring asbestos dust, the Project will be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021.

The Dust Control Plan may include the following measures:

1. Water wetting of road surfaces

2. Rinse vehicles and equipment

3. Wet loads of excavated material, and

4. Cover loads of excavated material
Long‐Term Impacts
Long‐Term emissions from the Project are generated primarily by mobile source (vehicle) emissions from the project site and area sources such as lawn maintenance equipment.

Emissions from long‐term operations generally represent a project’s most substantial air quality impact. Table 8 summarizes the Project’s operational impacts by pollutant. Results indicate that operational emissions from the Project will not exceed the SJVAPCD emissions threshold for any emissions, hence no mitigations are required.

4.1.4 Result in other emissions such as those leading to odors adversely affecting a substantial number of people
The SJVAPCD requires that an analysis of potential odor impacts be conducted for the following two situations:
 Generators – projects that would potentially generate odorous emissions proposed to be located near existing sensitive receptors or other land uses where people may congregate, and
 Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people located near existing odor sources.

The proposed Project will not generate odorous emissions given the nature or characteristics of residential developments. The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJV Air Basin. The types of facilities that are known to produce odors are shown in Table 5 above along with a reasonable distance from the source within which, the degree of odors could possibly be significant. None of the facilities shown in Table 5 are located within two (2) miles of the Project.

Therefore, no mitigation is needed.

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Air Quality & Greenhouse Gas Impact Assessment
51 4.2 Greenhouse Gas Emissions

4.2.1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment
In 2009, the SJVAPCD adopted the following guidance documents applicable to projects within the San Joaquin Valley:
 Guidance for Valley Land‐use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009), and
 District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009).

This guidance and policy are the reference documents referenced in the SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts adopted in March 2015 (SJVAPCD 2015).

Consistent with the District Guidance and District Policy above, SJVAPCD (2015) acknowledges the current absence of numerical thresholds, and recommends a tiered approach to establish the significance of the GHG impacts on the environment:
i. If a project complies with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, then the project would be determined to have a less than significant individual and cumulative impact for GHG emissions; ii. If a project does not comply with an approved GHG emission reduction plan or mitigation program, then it would be required to implement Best Performance Standards (BPS); and
iii. If a project is not implementing BPS, then it should demonstrate that its GHG emissions would be reduced or mitigated by at least 29 percent compared to Business as Usual (BAU).

As shown in Table 10, the Project would generate 12,292.20 Metric Tons of Carbon Dioxide Equivalent per year (MTCO2eq./year) using an operational year of 2005, which includes area, energy, mobile, waste, and water sources. “Business as usual” (BAU) is referenced in CARB’s AB 32 Scoping Plan as emissions projected to occur in 2020 if the average baseline emissions during the 2002‐2004 period grew to 2020 levels, without control or Best Performance Standards (BPS) offsets. As a result, an estimate of the Project’s operational emissions in 2005 were compared to operational emissions in 2020 in order to determine if the Project meets the 29% emission reduction. The SJVAPCD has reviewed relevant scientific information related to GHG emissions and has determined that they are not able to determine a specific quantitative level of GHG emissions increase, above which a project would have a significant impact on the environment, and below which would have an insignificant impact. As a result, the SJVAPCD has determined that projects achieving at least a 29% GHG emission reduction compared to BAU would be determined to have a less than significant individual and cumulative impact for GHG. Results of the analysis show that the Project’s GHG emissions in the year 2020 are 10,230.91 Merced Gateway Residential Property Development
Air Quality & Greenhouse Gas Impact Assessment
52 MTCO2eq./year. This represents an achievement of 17% GHG emission reduction based on BAU, which does not meet the 29% GHG emission reduction target.

In the event that a local air district’s guidance for addressing GHG impacts does not use numerical GHG emissions thresholds, at the lead agency’s discretion, a neighboring air district’s GHG threshold may be used to determine impacts. In December 2008, the South Coast Air Quality Management District (SCAQMD) Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is lead agency. The SCAQMD guidance identifies a threshold of 10,000 MTCO2eq./year for GHG for construction emissions amortized over a 30‐year project lifetime, plus annual operation emissions. This threshold is often used by agencies, such as the California Public Utilities Commission, to evaluate GHG impacts in areas that do not have specific thresholds (CPUC 2015). Therefore, because this threshold has been established by the SCAQMD in an effort to control GHG emissions in the largest metropolitan area in the State of California, this threshold is considered a conservative approach for evaluating the significance of GHG emissions in a more rural area, such as Merced County. Though the Project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the Project. Table 11 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model, which is approximately 19% less than the threshold identified by the SCAQMD. Though the Project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the Project. Table 11 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model.

Based on the assessment above, the Project will not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Therefore, any impacts would be less than significant.

4.2.2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases
California passed the California Global Warming Solutions Act of 2006. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. Under AB 32, CARB must adopt regulations by January 1, 2011, to achieve reductions in GHGs to meet the 1990 emission cap by 2020. On December 11, 2008, CARB adopted its initial Scoping Plan, which functions as a roadmap of CARB’s plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations. CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan.

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53 SB 375 requires MPOs to adopt an SCS or APS that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the FCOF region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. MCAG’s 2022 RTP/SCS, which was adopted in August 2022, projects that the Merced County region would achieve the prescribed emissions targets.

Executive Order B‐30‐15 establishes a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. Executive Order B‐30‐15 requires MPO’s to implement measures that will achieve reductions of greenhouse gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth, and that designate locations for land uses to regulate growth. MCAG uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in the AQPs. The applicable General Plan for the project is County of Merced 2030 General Plan Update, which was adopted in 2011.

The Project is consistent with the currently adopted General Plan for Merced and the adopted MCAG 2022 RTP/SCS and is therefore consistent with the population growth and VMT applied in those plan documents. Therefore, the Project is consistent with the growth assumptions used in the applicable AQP. It should also be noted that yearly GHG emissions generated by the Project (Table 11) are approximately 19% less than the threshold identified by the SCAQMD (see the discussion for Impact 4.2.1 above).

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit. Below is a list of applicable strategies in the Scoping Plan and the Project’s consistency with those strategies.
 California Light‐Duty Vehicle GHG Standards – Implement adopted standards and planned second phase of the program. Align zero‐emission vehicles, alternative and renewable fuel and vehicle technology programs for long‐term climate change goals.  The Project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable to light‐duty vehicles that would access the Project. The Project would not conflict or obstruct this reduction measure.

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Air Quality & Greenhouse Gas Impact Assessment
54  Energy Efficiency – Pursuit of comparable investment in energy efficiency from all retail providers of electricity in California. Maximize energy efficiency building and appliance standards.
 The Project is consistent with this reduction measure. Though this measure applies to the State to increase its energy standards, the Project would comply with this measure through existing regulation. The Project would not conflict or obstruct this reduction measure.
 Low Carbon Fuel – Development and adoption of the low carbon fuel standard.  The Project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable to the fuel used by vehicles that would access the Project. The Project would not conflict or obstruct this reduction measure.

Based on the assessment above, the Project will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Therefore, any impacts would be less than significant.

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55 Appendix A
Merced Gateway
Fresno County, Annual
Project Characteristics -
Land Use - Consistent w/ Project Site Plan
Woodstoves - No Wood Stoves onsite
Construction Phase -
Architectural Coating - 50 g/L of VOC consistent with current CalEEMod Defaults Vehicle Trips - Adjusted to be consistent w/ traffic study Area Mitigation -

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 49.55 1000sqft 4.45 49,550.00 0 Single Family Housing 587.00 Dwelling Unit 64.30 1,056,600.00 1679 Strip Mall 49.55 1000sqft 4.45 49,550.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 45

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2031
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblArchitecturalCoating EF_Nonresidential_Exterior 150.00 50.00 CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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• • • • ················································································ •················································································ -•' -------,--------········································ • • . • . • . ················································································ •················································································ -1···············································································• ----: __ _.__ __ __. ....................................... . ' ' : ' ' : ! ! :

2.0 Emissions Summary
tblArchitecturalCoating EF_Nonresidential_Interior 150.00 50.00 tblArchitecturalCoating EF_Parking 150.00 50.00
tblArchitecturalCoating EF_Residential_Exterior 150.00 50.00 tblArchitecturalCoating EF_Residential_Interior 150.00 50.00 tblConstructionPhase PhaseEndDate 10/4/2030 6/28/2030
tblConstructionPhase PhaseEndDate 3/8/2030 11/30/2029
tblConstructionPhase PhaseEndDate 12/5/2025 8/29/2025
tblConstructionPhase PhaseEndDate 6/21/2030 3/15/2030
tblConstructionPhase PhaseEndDate 7/4/2025 3/28/2025
tblConstructionPhase PhaseStartDate 6/22/2030 3/16/2030 tblConstructionPhase PhaseStartDate 12/6/2025 8/30/2025 tblConstructionPhase PhaseStartDate 7/5/2025 3/29/2025
tblConstructionPhase PhaseStartDate 3/9/2030 12/1/2029
tblConstructionPhase PhaseStartDate 5/10/2025 2/1/2025
tblLandUse LotAcreage 1.14 4.45
tblLandUse LotAcreage 190.58 64.30
tblLandUse LotAcreage 1.14 4.45
tblVehicleTrips WD_TR 9.74 10.84
tblVehicleTrips WD_TR 9.44 8.75
tblVehicleTrips WD_TR 44.32 67.52
tblWoodstoves NumberCatalytic 61.00 0.00
tblWoodstoves NumberNoncatalytic 61.00 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied • • • • • ·····························t············································································t ·:--------------------i • • ······························!·············································································t •• _________________ .J • ' ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···································!·············································································t ··-----------------1 • ' ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···································• •• ·············································································t ·.·------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ·····························!.··············································································'•·.·-------------------l ii ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···································!··············································································t··---------------....J • ' ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ·····························!·············································································?t·----------------.J • ' ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ·····························• •• ··············································································f ·.·------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ····························!.··············································································t··------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ··································!··············································································t •• _______________ _j • ' ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ····························!·············································································?t·----------------.J • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ····························• •• ·············································································f ·.·------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ·································!·············································································t •• _______________ _j • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···························!·············································································t ,. ________________ _J • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···························!.·············································································f ·.·------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···························• •• ·············································································t ··------------------.J ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ································!·············································································t •• _______________ _j • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ···························!·············································································t ,. ________________ _J • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ • • ·························t············································································t ·:------------------.J • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ ·························t············································································t ·:------------------.J • • ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ ·······························!·············································································t _. _______________ _J : 1······································································

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2025 0.3051 2.7614 2.8032 6.8100e0031.0195 0.1086 1.1281 0.4355 0.1004 0.5359 0.0000 604.6079 604.6079 0.1448 0.0116 611.6866 2026 0.2676 2.1206 2.8300 7.4400e0030.3219 0.0728 0.3947 0.0871 0.0685 0.1557 0.0000 670.9316 670.9316 0.0766 0.0329 682.6412 2027 0.2624 2.1134 2.7931 7.3400e0030.3219 0.0727 0.3946 0.0871 0.0684 0.1556 0.0000 661.6065 661.6065 0.0761 0.0320 673.0495 2028 0.2567 2.0996 2.7520 7.2200e0030.3206 0.0724 0.3930 0.0868 0.0681 0.1549 0.0000 650.5039 650.5039 0.0755 0.0311 661.6590 2029 0.2428 2.0233 2.6715 6.8400e0030.2972 0.0711 0.3684 0.0805 0.0669 0.1473 0.0000 614.9990 614.9990 0.0762 0.0281 625.2639 2030 3.5820 0.2266 0.5302 9.9000e0040.0179 9.7500e0030.0277 4.7700e0039.7400e0030.0145 0.0000 86.1409 86.1409 3.6600e0032.7000e00486.3144 Maximum 3.5820 2.7614 2.8300 7.4400e0031.0195 0.1086 1.1281 0.4355 0.1004 0.5359 0.0000 670.9316 670.9316 0.1448 0.0329 682.6412 Unmitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------+·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------+·················· +-----+-----+-----+-----···················

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 2-1-2025 4-30-2025 0.9203 0.9203
2 5-1-2025 7-31-2025 1.0164 1.0164
3 8-1-2025 10-31-2025 0.7351 0.7351
4 11-1-2025 1-31-2026 0.6079 0.6079
5 2-1-2026 4-30-2026 0.5836 0.5836
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ --------·················· ----··················· ······························ --------·················· .................. . ······························ --------·················· .................. . ······························ --------·················· .................. . ······························ --------·················· .................. .

I I I I I I I I I I I I I I I I I I
6 5-1-2026 7-31-2026 0.5988 0.5988
7 8-1-2026 10-31-2026 0.6011 0.6011
8 11-1-2026 1-31-2027 0.6045 0.6045
9 2-1-2027 4-30-2027 0.5805 0.5805
10 5-1-2027 7-31-2027 0.5956 0.5956
11 8-1-2027 10-31-2027 0.5978 0.5978
12 11-1-2027 1-31-2028 0.6014 0.6014
13 2-1-2028 4-30-2028 0.5843 0.5843
14 5-1-2028 7-31-2028 0.5928 0.5928
15 8-1-2028 10-31-2028 0.5951 0.5951
16 11-1-2028 1-31-2029 0.5987 0.5987
17 2-1-2029 4-30-2029 0.5753 0.5753
18 5-1-2029 7-31-2029 0.5902 0.5902
19 8-1-2029 10-31-2029 0.5925 0.5925
20 11-1-2029 1-31-2030 0.3950 0.3950
21 2-1-2030 4-30-2030 1.6989 1.6989
22 5-1-2030 7-31-2030 2.0106 2.0106
Highest 2.0106 2.0106
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.7300 0.2697 4.4414 1.6300e0030.0419 0.0419 0.0419 0.0419 0.0000 261.4141 261.4141 0.0117 4.6600e003263.0949 Energy 0.0824 0.7073 0.3247 4.4900e0030.0569 0.0569 0.0569 0.0569 0.0000 1,325.0975 1,325.0975 0.0981 0.0249 1,334.9839 Mobile 2.7983 4.5351 25.9350 0.0641 7.6870 0.0481 7.7351 2.0557 0.0452 2.1008 0.0000 5,935.6144 5,935.6144 0.2969 0.3298 6,041.3049 Waste 0.0000 0.0000 0.0000 0.0000 142.6113 0.0000 142.6113 8.4281 0.0000 353.3135 Water 0.0000 0.0000 0.0000 0.0000 16.0919 35.6784 51.7703 1.6586 0.0397 105.0726 Total 8.6106 5.5121 30.7011 0.0703 7.6870 0.1470 7.8339 2.0557 0.1440 2.1997 158.7032 7,557.8045 7,716.5077 10.4933 0.3991 8,097.7698 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Site Preparation Site Preparation 2/1/2025 3/28/2025 5 40 2 Grading Grading 3/29/2025 8/29/2025 5 110
3 Building Construction Building Construction 8/30/2025 11/30/2029 5 1110 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ·····························• ------+----f----l------•················• -------..----1••················· ·····························• ------+----f----l------•················· .................. . ·····························• ------+----f----l------•················· .................. . ·····························• ------+----f----l--.+----+----+-----+·················· .................. .

I I I I I I I I I I I I I I I I I I
• • • • • • .................................................................................... --._____,___...... _________ ································································· • • • • ................... r .............................................................. _ .• ----.. ································································· ' ' : : ' ' : : ! ! : :
4 Paving Paving 12/1/2029 3/15/2030 5 75
5 Architectural Coating Architectural Coating 3/16/2030 6/28/2030 5 75 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Residential Indoor: 2,139,615; Residential Outdoor: 713,205; Non-Residential Indoor: 148,650; Non-Residential Outdoor: 49,550; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 60
Acres of Grading (Grading Phase): 330
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied I
• •
I
! 1-------------------1------------1---------------------I••··································· ; • ········································································· •'------------------+------------1------------------+····································· • • ········································································· •'------------------+------------1---------,.---------+····································· • • ! 1-------------------1------------1---------------------I••··································· ; • ········································································· • -·------------------+------------1-------------------+····································· • • ········································································· •'------------------+------------1------------------+····································· • • ········································································· •'------------------+------------1---------,.---------+····································· • • ! 1-------------------1------------1---------------------I••··································· ; • ········································································· • -·------------------+------------1------------------+····································· • • ········································································· •'------------------+------------1---------,.---------+····································· • • ········································································· •'------------------+------------1---------,.---------+····································· • • ! 1-------------------1------------1---------------------I••··································· ; • ········································································· • -·------------------+------------1------------------+····································· • • ········································································· •'------------------+------------1---------,.---------+····································· • • ......................................................................... ~ .• _________________ ..._ __________ ......................................... ;... ________ ...................................... . i : : ' : : ! : :

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 243.00 79.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 49.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ' ' ·······································•· -f •'----------i-------+-------+--------+-------+------+------+----------+-------i••························· ' ' ·······································•• -f •'----------i-------+-------+--------+-------+------+------+----------+-------1··························· ' ' ·······································•• -f ·'----------i-------+-------+--------+-------+--------1-------+---------~-------i••·············· ·········· ' ·······································•• -f ' •• _________ .... _______ ...._ ______ ...._ _____ _. _______ ...._ ______ ..._ ______ .._ ________ _._ ...................................................... . ' : : ' : : ! : :
····························•· tt-----+----+----+----+----+-----+-----+-----+-----+-----·················· +-----+-----+-----+-------t···················

3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.6000e0045.7000e0047.2600e0032.0000e0052.8800e0031.0000e0052.8900e0037.6000e0041.0000e0057.8000e0040.0000 2.1151 2.1151 6.0000e0056.0000e0052.1333 Total 9.6000e0045.7000e0047.2600e0032.0000e0052.8800e0031.0000e0052.8900e0037.6000e0041.0000e0057.8000e0040.0000 2.1151 2.1151 6.0000e0056.0000e0052.1333 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.3931 0.0000 0.3931 0.2021 0.0000 0.2021 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0495 0.5047 0.3582 7.6000e0040.0217 0.0217 0.0200 0.0200 0.0000 66.9339 66.9339 0.0217 0.0000 67.4751 Total 0.0495 0.5047 0.3582 7.6000e0040.3931 0.0217 0.4149 0.2021 0.0200 0.2221 0.0000 66.9339 66.9339 0.0217 0.0000 67.4751 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.5062 0.0000 0.5062 0.2010 0.0000 0.2010 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1596 1.5369 1.4482 3.4100e0030.0622 0.0622 0.0572 0.0572 0.0000 299.7842 299.7842 0.0970 0.0000 302.2081 Total 0.1596 1.5369 1.4482 3.4100e0030.5062 0.0622 0.5684 0.2010 0.0572 0.2582 0.0000 299.7842 299.7842 0.0970 0.0000 302.2081 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.9300e0031.7300e0030.0222 7.0000e0058.7900e0034.0000e0058.8300e0032.3400e0034.0000e0052.3700e0030.0000 6.4629 6.4629 1.7000e0041.7000e0046.5186 Total 2.9300e0031.7300e0030.0222 7.0000e0058.7900e0034.0000e0058.8300e0032.3400e0034.0000e0052.3700e0030.0000 6.4629 6.4629 1.7000e0041.7000e0046.5186 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.5062 0.0000 0.5062 0.2010 0.0000 0.2010 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1596 1.5369 1.4482 3.4100e0030.0622 0.0622 0.0572 0.0572 0.0000 299.7838 299.7838 0.0970 0.0000 302.2077 Total 0.1596 1.5369 1.4482 3.4100e0030.5062 0.0622 0.5684 0.2010 0.0572 0.2582 0.0000 299.7838 299.7838 0.0970 0.0000 302.2077 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0602 0.5487 0.7077 1.1900e0030.0232 0.0232 0.0218 0.0218 0.0000 102.0446 102.0446 0.0240 0.0000 102.6443 Total 0.0602 0.5487 0.7077 1.1900e0030.0232 0.0232 0.0218 0.0218 0.0000 102.0446 102.0446 0.0240 0.0000 102.6443 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 3.5400e0030.1521 0.0438 6.7000e0040.0231 9.9000e0040.0240 6.6600e0039.4000e0047.6000e0030.0000 64.4484 64.4484 3.2000e0049.7000e00367.3469 Worker 0.0284 0.0168 0.2158 6.9000e0040.0855 3.7000e0040.0859 0.0227 3.4000e0040.0231 0.0000 62.8189 62.8189 1.6600e0031.6800e00363.3603 Total 0.0320 0.1689 0.2595 1.3600e0030.1085 1.3600e0030.1099 0.0294 1.2800e0030.0307 0.0000 127.2672 127.2672 1.9800e0030.0114 130.7073 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0602 0.5487 0.7077 1.1900e0030.0232 0.0232 0.0218 0.0218 0.0000 102.0444 102.0444 0.0240 0.0000 102.6441 Total 0.0602 0.5487 0.7077 1.1900e0030.0232 0.0232 0.0218 0.0218 0.0000 102.0444 102.0444 0.0240 0.0000 102.6441 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1785 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6549 302.6549 0.0711 0.0000 304.4335 Total 0.1785 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6549 302.6549 0.0711 0.0000 304.4335 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0103 0.4485 0.1276 1.9500e0030.0684 2.9100e0030.0713 0.0198 2.7800e0030.0225 0.0000 187.3831 187.3831 9.2000e0040.0282 195.8077 Worker 0.0789 0.0449 0.6034 1.9700e0030.2535 1.0600e0030.2546 0.0674 9.7000e0040.0684 0.0000 180.8937 180.8937 4.4900e0034.6800e003182.4000 Total 0.0892 0.4933 0.7310 3.9200e0030.3219 3.9700e0030.3258 0.0871 3.7500e0030.0909 0.0000 368.2767 368.2767 5.4100e0030.0329 378.2077 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1784 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6545 302.6545 0.0711 0.0000 304.4331 Total 0.1784 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6545 302.6545 0.0711 0.0000 304.4331 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2027
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1785 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6549 302.6549 0.0711 0.0000 304.4335 Total 0.1785 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6549 302.6549 0.0711 0.0000 304.4335 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2027
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0101 0.4455 0.1258 1.9100e0030.0684 2.8900e0030.0712 0.0198 2.7600e0030.0225 0.0000 183.4029 183.4029 8.8000e0040.0276 191.6464 Worker 0.0739 0.0407 0.5683 1.9100e0030.2535 1.0000e0030.2545 0.0674 9.2000e0040.0683 0.0000 175.5488 175.5488 4.1000e0034.4200e003176.9696 Total 0.0840 0.4861 0.6941 3.8200e0030.3219 3.8900e0030.3258 0.0871 3.6800e0030.0908 0.0000 358.9516 358.9516 4.9800e0030.0320 368.6160 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1784 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6545 302.6545 0.0711 0.0000 304.4331 Total 0.1784 1.6273 2.0991 3.5200e0030.0689 0.0689 0.0648 0.0648 0.0000 302.6545 302.6545 0.0711 0.0000 304.4331 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1778 1.6211 2.0910 3.5000e0030.0686 0.0686 0.0645 0.0645 0.0000 301.4953 301.4953 0.0709 0.0000 303.2671 Total 0.1778 1.6211 2.0910 3.5000e0030.0686 0.0686 0.0645 0.0645 0.0000 301.4953 301.4953 0.0709 0.0000 303.2671 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 9.8900e0030.4415 0.1239 1.8700e0030.0681 2.8600e0030.0710 0.0197 2.7400e0030.0224 0.0000 178.9169 178.9169 8.4000e0040.0269 186.9558 Worker 0.0691 0.0371 0.5371 1.8500e0030.2526 9.3000e0040.2535 0.0671 8.6000e0040.0680 0.0000 170.0917 170.0917 3.7500e0034.2000e003171.4362 Total 0.0790 0.4785 0.6610 3.7200e0030.3206 3.7900e0030.3244 0.0868 3.6000e0030.0904 0.0000 349.0086 349.0086 4.5900e0030.0311 358.3919 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1778 1.6211 2.0910 3.5000e0030.0686 0.0686 0.0645 0.0645 0.0000 301.4949 301.4949 0.0709 0.0000 303.2667 Total 0.1778 1.6211 2.0910 3.5000e0030.0686 0.0686 0.0645 0.0645 0.0000 301.4949 301.4949 0.0709 0.0000 303.2667 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2029
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1641 1.4964 1.9302 3.2400e0030.0633 0.0633 0.0596 0.0596 0.0000 278.3033 278.3033 0.0654 0.0000 279.9389 Total 0.1641 1.4964 1.9302 3.2400e0030.0633 0.0633 0.0596 0.0596 0.0000 278.3033 278.3033 0.0654 0.0000 279.9389 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.4 Building Construction - 2029
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 9.0000e0030.4052 0.1133 1.6900e0030.0629 2.6200e0030.0655 0.0182 2.5100e0030.0207 0.0000 161.8037 161.8037 7.4000e0040.0243 169.0709 Worker 0.0597 0.0315 0.4725 1.6700e0030.2331 8.1000e0040.2339 0.0620 7.4000e0040.0627 0.0000 153.0451 153.0451 3.1900e0033.7100e003154.2309 Total 0.0687 0.4367 0.5858 3.3600e0030.2960 3.4300e0030.2994 0.0801 3.2500e0030.0834 0.0000 314.8489 314.8489 3.9300e0030.0280 323.3018 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1641 1.4964 1.9302 3.2400e0030.0633 0.0633 0.0596 0.0596 0.0000 278.3030 278.3030 0.0654 0.0000 279.9385 Total 0.1641 1.4964 1.9302 3.2400e0030.0633 0.0633 0.0596 0.0596 0.0000 278.3030 278.3030 0.0654 0.0000 279.9385 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----···················

3.5 Paving - 2029
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.6100e0030.0901 0.1531 2.4000e0044.3900e0034.3900e0034.0400e0034.0400e0030.0000 21.0202 21.0202 6.8000e0030.0000 21.1902 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 9.6100e0030.0901 0.1531 2.4000e0044.3900e0034.3900e0034.0400e0034.0400e0030.0000 21.0202 21.0202 6.8000e0030.0000 21.1902 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.5 Paving - 2029
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.2000e0041.7000e0042.5500e0031.0000e0051.2600e0030.0000 1.2600e0033.3000e0040.0000 3.4000e0040.0000 0.8266 0.8266 2.0000e0052.0000e0050.8330 Total 3.2000e0041.7000e0042.5500e0031.0000e0051.2600e0030.0000 1.2600e0033.3000e0040.0000 3.4000e0040.0000 0.8266 0.8266 2.0000e0052.0000e0050.8330 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.6100e0030.0901 0.1531 2.4000e0044.3900e0034.3900e0034.0400e0034.0400e0030.0000 21.0202 21.0202 6.8000e0030.0000 21.1902 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 9.6100e0030.0901 0.1531 2.4000e0044.3900e0034.3900e0034.0400e0034.0400e0030.0000 21.0202 21.0202 6.8000e0030.0000 21.1902 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.5 Paving - 2030
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0374 0.1923 0.4279 7.6000e0048.9300e0038.9300e0038.9300e0038.9300e0030.0000 65.0687 65.0687 3.0500e0030.0000 65.1450 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0374 0.1923 0.4279 7.6000e0048.9300e0038.9300e0038.9300e0038.9300e0030.0000 65.0687 65.0687 3.0500e0030.0000 65.1450 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.5 Paving - 2030
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.8000e0044.1000e0046.2900e0032.0000e0053.2400e0031.0000e0053.2500e0038.6000e0041.0000e0058.7000e0040.0000 2.0765 2.0765 4.0000e0055.0000e0052.0923 Total 7.8000e0044.1000e0046.2900e0032.0000e0053.2400e0031.0000e0053.2500e0038.6000e0041.0000e0058.7000e0040.0000 2.0765 2.0765 4.0000e0055.0000e0052.0923 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0374 0.1923 0.4279 7.6000e0048.9300e0038.9300e0038.9300e0038.9300e0030.0000 65.0686 65.0686 3.0500e0030.0000 65.1449 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0374 0.1923 0.4279 7.6000e0048.9300e0038.9300e0038.9300e0038.9300e0030.0000 65.0686 65.0686 3.0500e0030.0000 65.1449 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

3.6 Architectural Coating - 2030
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.5300e0031.8400e0030.0285 1.0000e0040.0147 5.0000e0050.0147 3.9000e0034.0000e0053.9500e0030.0000 9.4210 9.4210 1.9000e0042.3000e0049.4928 Total 3.5300e0031.8400e0030.0285 1.0000e0040.0147 5.0000e0050.0147 3.9000e0034.0000e0053.9500e0030.0000 9.4210 9.4210 1.9000e0042.3000e0049.4928 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 3.5354 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 4.9000e0030.0321 0.0674 1.1000e0047.6000e0047.6000e0047.6000e0047.6000e0040.0000 9.5747 9.5747 3.9000e0040.0000 9.5844 Total 3.5403 0.0321 0.0674 1.1000e0047.6000e0047.6000e0047.6000e0047.6000e0040.0000 9.5747 9.5747 3.9000e0040.0000 9.5844 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+-----+----+----+----+-----+------+-----+-----·················· +-----+-----+-----+-----···················

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 29 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ······························ •-----+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 2.7983 4.5351 25.9350 0.0641 7.6870 0.0481 7.7351 2.0557 0.0452 2.1008 0.0000 5,935.6144 5,935.6144 0.2969 0.3298 6,041.3049 Unmitigated 2.7983 4.5351 25.9350 0.0641 7.6870 0.0481 7.7351 2.0557 0.0452 2.1008 0.0000 5,935.6144 5,935.6144 0.2969 0.3298 6,041.3049

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
General Office Building 537.12 109.51 34.69 966,075 966,075 Single Family Housing 5,136.25 5,599.98 5018.85 15,192,462 15,192,462 Strip Mall 3,345.62 2,083.08 1012.31 4,361,257 4,361,257 Total 9,018.99 7,792.57 6,065.84 20,519,794 20,519,794
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or CWH-S or C-C H-O or C-NW Primary Diverted Pass-by General Office Building 9.50 7.30 7.30 33.00 48.00 19.00 77 19 4 Single Family Housing 10.80 7.30 7.50 48.40 15.90 35.70 86 11 3 Strip Mall 9.50 7.30 7.30 16.60 64.40 19.00 45 40 15

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Office Building 0.545460 0.054723 0.176449 0.132329 0.021147 0.005812 0.015202 0.022551 0.000674 0.000277 0.021695 0.001298 0.002384 CalEEMod Version: CalEEMod.2020.4.0 Page 30 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ,:
,:
,:
,:
,:
. . . . . r: , !-----~,··················•, !------,··················· ,·················•· , !------!,••···············••, !------!,••·················· r ················· .... ----,·················•• , !------!,••·················,··················· , : : : : : : : : : : . : : : : , : : : : : : : : : : . : : : : , : : : : : : : : : : . : : : : , : : : : : : : : : : . : : : :
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • "'9"'---------,1--------·····························•• i••······························································ ····································································· · • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ······························· i································································ •···································································· · • • • ! ' ' I I I I I . . . . . . . . ' ' ................................ •-------1------....;• ·-------+--------. ······························ =·························· =························ =············································· I . : . . ' : . : : : : ••••••••••••••••••••••••••••• ■..-------~------. ····························•······················· . • ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• , •••••••••••••••••••••••••••• , ••••••••••••••••••••••••••••••••••••••••••••• : ' : : ' ' ' : : : : : : :

Single Family Housing 0.545460 0.054723 0.176449 0.132329 0.021147 0.005812 0.015202 0.022551 0.000674 0.000277 0.021695 0.001298 0.002384 Strip Mall 0.545460 0.054723 0.176449 0.132329 0.021147 0.005812 0.015202 0.022551 0.000674 0.000277 0.021695 0.001298 0.002384

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 509.9145 509.9145 0.0825 0.0100 514.9566 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 509.9145 509.9145 0.0825 0.0100 514.9566 NaturalGas
Mitigated

0.0824 0.7073 0.3247 4.4900e0030.0569 0.0569 0.0569 0.0569 0.0000 815.1831 815.1831 0.0156 0.0150 820.0273 NaturalGas
Unmitigated

0.0824 0.7073 0.3247 4.4900e0030.0569 0.0569 0.0569 0.0569 0.0000 815.1831 815.1831 0.0156 0.0150 820.0273

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 31 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ,:
" " " ······························ -----+----+----+----+----+----+ " ----+----+----+----- ·················· +-----+-----+-----+--------t··················· ,:
" " " ······························ -----+----+----+----+----+----+ " ----+----+----+----- ·················· +-----+-----+-----+--------t··················· ,:
" " " r, " : : , : : : , : : : , : : : , : : :
1·················•· 1!------!1•·················· 1··················1 • • • • •
: : f : : : : ' : : : : ' : : : : ' : : : : ' : :
1··················•. 1!------!••·················

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
General Office
Building
640186 3.4500e0030.0314 0.0264 1.9000e0042.3900e0032.3900e0032.3900e0032.3900e0030.0000 34.1628 34.1628 6.5000e0046.3000e00434.3658 Single Family
Housing

1.411e
+007

0.0761 0.6502 0.2767 4.1500e0030.0526 0.0526 0.0526 0.0526 0.0000 752.9656 752.9656 0.0144 0.0138 757.4401 Strip Mall 525726 2.8300e0030.0258 0.0217 1.5000e0041.9600e0031.9600e0031.9600e0031.9600e0030.0000 28.0547 28.0547 5.4000e0045.1000e00428.2214 Total 0.0824 0.7073 0.3247 4.4900e0030.0569 0.0569 0.0569 0.0569 0.0000 815.1830 815.1830 0.0156 0.0149 820.0273 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 32 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied • •
I I I
.............................. L----12~----l----+----}-----l-----t----+----J----i----1----1·················· 1-----t----+----+----,·················· .............................. L~---+--+-+--~--t--t---t--r,-7i·················· 1---+---t---+-----i·················· · . ' . ' . • ' •

1.411e
+007

0.0761 0.6502 0.2767 4.1500e0030.0526 0.0526 0.0526 0.0526 0.0000 752.9656 752.9656 0.0144 0.0138 757.4401 Strip Mall 525726 2.8300e0030.0258 0.0217 1.5000e0041.9600e0031.9600e0031.9600e0031.9600e0030.0000 28.0547 28.0547 5.4000e0045.1000e00428.2214 Total 0.0824 0.7073 0.3247 4.4900e0030.0569 0.0569 0.0569 0.0569 0.0000 815.1830 815.1830 0.0156 0.0149 820.0273 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 33 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied • •
I I I
.............................. L----12~----l----+----}-----l-----t----+----J----i----1----1·················· 1-----t----+----+----,·················· .............................. L~---+--+-+--~--t--t---t--r,-7i·················· 1---+---t---+-----i·················· · . ' . ' . • ' •

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Office
Building
438022 40.5275 6.5600e0037.9000e00440.9282
Single Family
Housing

4.68071e
+006
433.0774 0.0701 8.4900e003437.3597
Strip Mall 392436 36.3097 5.8700e0037.1000e00436.6687 Total 509.9145 0.0825 9.9900e003514.9566
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 34 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ +----..... 11-----+-----+------1••················ ······························ +----..... 11-----+-----+------1••················

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Office
Building
438022 40.5275 6.5600e0037.9000e00440.9282
Single Family
Housing

4.68071e
+006
433.0774 0.0701 8.4900e003437.3597
Strip Mall 392436 36.3097 5.8700e0037.1000e00436.6687 Total 509.9145 0.0825 9.9900e003514.9566
Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 35 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ······························ +----..... 11-----+-----+------1••················ ······························ +----..... 11-----+-----+------1••················ ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.7300 0.2697 4.4414 1.6300e0030.0419 0.0419 0.0419 0.0419 0.0000 261.4141 261.4141 0.0117 4.6600e003263.0949 Unmitigated 5.7300 0.2697 4.4414 1.6300e0030.0419 0.0419 0.0419 0.0419 0.0000 261.4141 261.4141 0.0117 4.6600e003263.0949

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

1.0606 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.5136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0257 0.2196 0.0934 1.4000e0030.0178 0.0178 0.0178 0.0178 0.0000 254.2927 254.2927 4.8700e0034.6600e003255.8039 Landscaping 0.1301 0.0501 4.3479 2.3000e0040.0242 0.0242 0.0242 0.0242 0.0000 7.1214 7.1214 6.7900e0030.0000 7.2911 Total 5.7300 0.2697 4.4414 1.6300e0030.0419 0.0419 0.0419 0.0419 0.0000 261.4141 261.4141 0.0117 4.6600e003263.0950 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 36 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 1···················1·················•· 1!------!1•··················1 1···················1··················• 1!------·················· 1···················1··················•1 ,!------!••················· ······························ tt------t------t------t------t------t------t------1------1------1------ ·················· t-----t-----1-----1------1··················· ······························ tt------t------t------t------1------1------1------1------1------1------ ·················· t-----1-----1-----1------1··················· ······························ tt------t------t------t------1------1------1------1------1------1------ ·················· t-----1-----1-----1------1···················

7.1 Mitigation Measures Water

7.0 Water Detail

1.0606 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.5136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0257 0.2196 0.0934 1.4000e0030.0178 0.0178 0.0178 0.0178 0.0000 254.2927 254.2927 4.8700e0034.6600e003255.8039 Landscaping 0.1301 0.0501 4.3479 2.3000e0040.0242 0.0242 0.0242 0.0242 0.0000 7.1214 7.1214 6.7900e0030.0000 7.2911 Total 5.7300 0.2697 4.4414 1.6300e0030.0419 0.0419 0.0419 0.0419 0.0000 261.4141 261.4141 0.0117 4.6600e003263.0950 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 37 of 42 Date: 1/25/2025 2:32 AM Merced Gateway - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· ····························•• Ill------+------+------+------+------+------+------+------+------+------·················· +-----+-----+-----+-----··················· Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 51.7703 1.6586 0.0397 105.0726
Unmitigated 51.7703 1.6586 0.0397 105.0726

City Council/Public Finance and Economic Development Authority/Parking AuthorityOctober 6, 2025

City Council/Public Finance and Economic Development Authority/Parking Authority
October 6, 2025