Responses to Comments Ascent
City of Roseville
2-44 Roseville Environmental Utilities Operations Center Project Final EIR
27.2 miles. The District is concerned that this trip length is experientially underestimated as the origin of the biomass fuel could be at a location much further away from the project.
In addition, Appendix C also assumes 208 separate one-way trips per year to deliver 30,000 tons of biomass fuel.
Based on this assumption, each truck trip will deliver approximately 144 tons of biomass fuel. This substantially exceeds the possible loading capacity for a heavy-heavy duty truck. The District recommends the DEIR to reverify these modeling assumptions and may need to recalculate the related on-road criteria pollutants and GHG emissions from fuel trucks for the proposed biomass facility in Phase 2.
Response A5-11
The comment questions the assumptions used to model biomass fuel deliveries for the potential future biomass gasification facility, including the assumed truck trip length and number of annual truck trips, and recommends verifying whether the transportation assumptions and resulting air quality and greenhouse gas emissions estimates are appropriate.
The biomass fuel source evaluated for the potential future biomass gasification facility consists primarily of locally generated green waste (yard waste) collected from City residents and commercial customers. As such, the fuel source is not anticipated to be transported from distant agricultural or forestry operations. The one-way haul distance of approximately 27.2 miles used in Appendix C of the Draft EIR reflects the local collection and transfer characteristics associated with the City’s service area and is considered a reasonable and representative assumption for this conceptual analysis. Because the biomass feedstock originates from local residential and commercial green waste streams, substantially longer transportation distances are not anticipated. The Final EIR has been revised to describe the anticipated origin of the biomass fuel. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
With respect to annual fuel quantities, the Draft EIR assumes an annual biomass fuel throughput of approximately 30,000 tons per year. The emissions analysis did not assume truck payloads of 144 tons per trip. Rather, Appendix C and associated emissions modeling is based on truck trip estimates assuming a 9-ton capacity truck, which is within the range of typical loading conditions for green waste collection and transfer vehicles. Biomass would enter the facility using the same City fleet required to bring in all solid waste. The project would not result in additional truck trips dedicated to hauling in biomass fuel.
PCAPCD’s calculation appears to be based on the assumption that the 208 annual truck trips identified in Appendix C represent all truck trips associated with biomass fuel delivery. However, the table referenced in Appendix C (PDF page 33 of 180) presents multiple categories of truck activity, including material trucks, fuel trucks (note that these trucks are delivering petroleum [diesel, gasoline, etc.] to energize the on-site equipment and not “wood fuel”), and employee-related vehicle trips. The operational emissions modeling account for the full range of vehicle activity assumptions identified in the appendix and do not rely on a 144-ton payload assumption for fuel deliveries Therefore, the Draft EIR’s transportation and emissions analysis for the conceptual biomass gasification facility was based on locally sourced biomass feedstock, reasonable haul distances representative of the City’s service area, and truck loading assumptions that are consistent with the characteristics of green waste transport. Consequently, the comment does not identify an error in the emissions analysis, and no revisions to the air quality or GHG calculations are required.
Comment A5-12
12. Appendix C “Onsite Material Process Emissions” estimates the on-site equipment used for proposed material transfer station and compost facility. However, it does not include the emission estimation from possible on-site activities for the potential biomass facility. Although there is an uncertainty whether the facility could be built, the DEIR analysis does include the emission estimations of potential criteria pollutants and GHG emissions from the facility. The District recommends that the “Onsite Material Process Emissions” include possible emission estimations from offroad equipment used for the proposed biomass facility.
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-45 Response A5-12
The comment states that the emissions analysis does not include estimates of emissions from off-road equipment that could be associated with the potential future biomass gasification facility and recommends that such emissions be included in the on-site equipment emissions analysis.
The comment correctly observes that Appendix C of the Draft EIR identifies off-road equipment associated with the Material Transfer Station and Compost Facility and does not separately identify equipment assigned exclusively to the Potential Future Biomass Facility. However, the operational emissions analysis did account for off-road equipment used to manage organic materials processed at the Potential Future Organics Facility, including the potential future biomass processing component. For purposes of the air quality and GHG analysis, equipment associated with handling organic materials was included under the Compost Facility assumptions rather than being modeled as a separate equipment fleet for the Biomass Facility. Specifically, the analysis included the following off-road equipment (see Appendix C [PDF page 54 of 180] of the Draft EIR):
▶ Material Transfer Station: 8 front-end loaders and 5 forklifts. ▶ Organics Processing Area (Future Potential Compost Facility and/or Biomass Facility): 10 front-end loaders and 2 water trucks.
▶ Collector/Transfer Trucks: Annual trips apportioned to on-site travel activity.
The 10 front-end loaders and 2 water trucks modeled for organics processing were intended to support management of organic materials at the overall Potential Future Organics Processing Facility, including both composting operations and the biomass processing operations. Therefore, emissions associated with the off-road equipment necessary to handle biomass feedstock were already incorporated into the operational emissions analysis and were not omitted from the modeling. Because the analysis conservatively accounted for off-road equipment associated with processing organic materials, including biomass feedstock, the Draft EIR does not underestimate operational emissions associated with the Potential Future Biomass Facility. No revisions to the criteria pollutant or GHG emissions analysis are required.
Comment A5-13
13. According to the DEIR analysis, the proposed organic process facility and biomass facility would result in substantial ROG and NOx emissions, respectively. The total annual ROG emissions from the organic process facility and total annual NOx emissions from the biomass facility would exceed 25 tons per year and become federal major stationary sources subject to the requirement for the federal operating permit (Title V permit), which is additional to the PCAPCD’s operation permit. Please note that there are only four Title V facilities in Placer County. The District recommends Impact 3.3-1 “Conflict with or Obstruct Implementation of the Applicable Air Quality Plan” should include the discussion if these two potential Title V facilities proposed by the project would result in the difficulties for the Sacramento federal ozone nonattainment area to achieve attainment of federal 2015 ozone standard.
Response A5-13
The comment states that emissions from the proposed organics processing facility and potential biomass facility could exceed federal Title V major source thresholds and recommends evaluating whether these facilities could affect attainment of the federal 2015 ozone standard in the Sacramento ozone nonattainment area. The Draft EIR has been revised to include additional discussion of federal Title V operating permit requirements in Impact 3.3-1. The revised text clarifies that, depending on final facility design and emissions, the Potential Future Organics Processing Facility and/or Potential Future Biomass Gasification Facility could be subject to federal Title V permitting requirements. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
As revised, Impact 3.3-1 explains that the potential applicability of a Title V permit does not, by itself, indicate that the project would conflict with or obstruct implementation of the Sacramento 2015 Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan. The revisions do not alter the impact analysis or significance determination.
The impact remains less than significant.
Responses to Comments Ascent
City of Roseville
2-46 Roseville Environmental Utilities Operations Center Project Final EIR Comment A5-14
14. The DEIR Section 3.4.3 refers to applying the District’s recommended GHG significance thresholds for stationary source projects to determine the project’s GHG emission impact. Please note that the District’s recommended bright-line threshold of 10,000 MTCO2e/year is to consider the complete project’s related GHG emissions from non-biogenic and biogenic sources. Accordingly, the significance determination is not based on whether the project would result in a net increase from fossil-based GHG emissions.
The District does not oppose if the DEIR would apply the net-increase concept to discuss the project’s related GHG emission impacts. If so, the District recommends that the DEIR include further discussion to define the baseline condition to the proposed compost operation and biomass facility to analyze if the related operation would result in a net increase in GHG emissions. For example, the baseline discussion for the biomass facility can be if the feedstock would be biomass waste that can be removed from the forested lands to avoid on-site open pile burning or how much fossil-based electricity can be substituted by the electricity generated from the proposed biomass facility.
Response A5-14
The comment states that PCAPCD's recommended 10,000 MTCO₂e/year significance threshold applies to total project GHG emissions, including both biogenic and non-biogenic sources. The comment further recommends that, if the Draft EIR uses a net-increase approach to evaluate greenhouse gas impacts, it should provide additional discussion of the applicable baseline conditions and the extent to which the potential future composting and/or biomass facilities could reduce emissions through activities such as organic waste diversion, avoided biomass burning, or displacement of fossil fuel-based energy generation.
The City acknowledges PCAPCD’s recommendation. However, the Draft EIR's evaluation of GHG emissions is based on the CEQA principle that significance is determined by comparing project emissions to existing environmental conditions. CEQA Guidelines Section 15125(a) requires that an EIR evaluate a project's impacts compared to the existing physical environmental conditions that constitute the baseline for environmental analysis. Likewise, the California Supreme Court has held that the normal CEQA baseline consists of existing physical conditions rather than hypothetical future scenarios (Communities for a Better Environment v. South Coast Air Quality Management District (2010) 48 Cal.4th 310).
The use of a no-net-increase approach for evaluating GHG emissions is also consistent with applicable CEQA guidance and case law. For example, the California Supreme Court's decision in Center for Biological Diversity v.
California Department of Fish and Wildlife (2015) 62 Cal.4th 204 (Newhall Ranch) recognized that lead agencies have discretion to use a no-net-increase threshold, where appropriate, for evaluating GHG impacts. Similarly, the California Air Resources Board's 2022 Climate Change Scoping Plan identifies a no-net-increase approach as one acceptable framework for evaluating GHG emissions. Under this approach, biogenic carbon emissions are not considered to contribute to a project's significant GHG impact because they are part of the natural carbon cycle and do not represent a net increase in atmospheric GHG. Thus, this approach considers only the GHG emissions solely attributable to the project itself that result in a new increase in non-biogenic emissions that may lead to adverse environmental effects relating to climate change. For the proposed project, carbon contained within woody biomass was previously sequestered during vegetation growth and would ultimately be released to the atmosphere through natural decomposition or other disposal methods, such as open burning or landfilling, with or without the proposed project. Accordingly, the GHG analysis focuses on emissions that represent an additional anthropogenic contribution to atmospheric GHG concentrations relative to existing conditions.
PCAPCD’s suggested comparison of project emissions to other potential future biomass management scenarios, such as avoided forest pile burning or displacement of fossil fuel-based electricity generation, could provide additional context regarding the potential environmental benefits of the proposed composting or biomass facilities. However, such a comparison is not required for determining significance under CEQA. Pursuant to CEQA Guidelines Section 15125(a), project impacts are evaluated against the existing environmental baseline rather than speculative future conditions or alternative waste management scenarios. In addition, sufficient information is not currently available to reliably determine how biomass feedstocks would otherwise be managed or the extent to which future electricity
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-47 generation from a biomass facility would offset fossil fuel-based generation. Therefore, while PCAPCD’s recommended discussion may be informative, it is not necessary to support the Draft EIR's significance determination. The significance conclusion appropriately relies on a comparison of project emissions to existing baseline conditions, consistent with CEQA.
Comment A5-15
15. Appendix C “Biomass Gasifier Emissions” presents the calculation for criteria pollutants and GHG emissions from the biomass gasification facility. The calculation cited emission factors from a recent environmental document prepared for the Tuolumne Biomass Utilization Project. The GHG results were lower than we would expect and significantly lower from previous environmental documents prepared by Ascent for the Placer Cabin Creek biomass energy facility, which proposed a similar gasification system to generate electricity from biomass waste.
Since no additional information is cited in the Tuolumne Biomass Project’s environmental document, the District would like to request the information regarding the emission factors as the reference for future possible permit application evaluation.
Response A5-15
The comment questions the GHG emission factors used for the potential biomass gasification facility, noting that the resulting emissions estimates appear lower than those reported for similar biomass gasification projects. The comment requests additional information regarding the emission factors used in the analysis to support future permit review and evaluation.
As shown on PDF pages 45 through 50 of Appendix C of the Draft EIR, GHG emissions associated with the future potential gasification facility were based on anticipated annual biomass tonnage (i.e., 30,000 tons per year) and calculated emissions associated with operation of a biomass gasification unit using syngas, as well as potential maintenance activities using coal-power to run the gasification unit. Emissions factors were obtained from another surrogate biomass facility project in Tuolumne County, as cited in Appendix C of the Draft EIR. The surrogate facility assumes that syngas would power the gasification unit and that coal could be used to power the facility for regular maintenance testing. In addition, it assumed the inclusion of a dryer to dry the biomass and a combined heat and power engine. At the time the Draft EIR was prepared, no specific technology for the future potential biomass facility had been determined, due to the programmatic nature of this project component. Further, it is likely that by the time the future biomass facility is proposed for development, available technology may vary from what is existing or available today. Accordingly, the analysis provides a reasonable estimate of emissions for a potential future biomass facility using known existing technologies, that may be representative of what could be developed.
All notes and citations are included on page 50 of Appendix C of the Draft EIR. Considering the programmatic nature of the future potential gasification facility, there are no other site-specific emissions factors or emissions sources that the Draft EIR could consider. In the future, if the gasification system is proposed for development, a site-specific and design-level HRA and/or emissions analysis would be required, in accordance with Mitigation Measure 3.3-3b and CEQA requirements that trigger subsequent review when relying on programmatic analyses. No further analysis or modeling is necessary for this Draft EIR.
Comment A5-16
16. The District conducted an independent Health Risk Assessment of the Phase II operations (including all stationary sources and associated mobile sources) using the methods and modeling assumptions prepared by the DEIR’s HRA. Our risk modeling results show that the potential risk is slightly higher than 10 in a million. The District recommends that the DEIR revisit the associated modeling setting and assumptions to ensure the results are still reasonable to present the project’s related risk. If needed, additional mitigation measures should be identified.
Response A5-16
The comment states that PCAPCD conducted an independent HRA for Phase 2 operations using the methods and assumptions described in the Draft EIR and obtained a cancer risk estimate slightly above 10 in one million. Based on these results, the comment recommends that the City revisit the HRA modeling assumptions and determine whether additional mitigation measures may be warranted. However, the independent HRA prepared by PCAPCD was not
Responses to Comments Ascent
City of Roseville
2-48 Roseville Environmental Utilities Operations Center Project Final EIR provided to the City and, therefore, the City cannot evaluate the modeling inputs, assumptions, methodologies, or results used in that analysis, nor can it determine the basis for any differences between PCAPCD’s results and those presented in the Draft EIR.
As discussed on a July 21, 2026 conference call with the City and PCAPCD staff, HRAs involve numerous technical assumptions and professional judgments related to emission rates, source characteristics, meteorological data, receptor placement, and dispersion modeling. As a result, it is not uncommon for different qualified practitioners to obtain somewhat different results when evaluating the same project. The HRA presented in the Draft EIR was prepared using accepted methodologies and the best available project information at the time of analysis. All methods, emissions factors, and model inputs are explained in Section 3.3.3, “Environmental Impacts and Mitigation Measures,” under the subheading, “Methodology,” and contained in greater detail in the HRA memo included as Appendix B of the Draft EIR.
Absent the PCAPCD’s independent HRA and supporting documentation, the City is unable to assess whether the differences identified by the comment are attributable to alternative assumptions, modeling parameters, or other methodological considerations. Further, additional comments by PCAPCD pertaining to specific model inputs and parameters used, some of which suggested that inputs were underestimated. See responses to comments A5-11, A5- 12, A5-15, and A5-17 explaining the inputs and assumptions used in response to those comments and how emissions were not underestimated. Accordingly, the comment does not provide substantial evidence demonstrating that the Draft EIR analysis is inaccurate or that additional mitigation is required. Therefore, no changes to the analysis or conclusions of the Draft EIR are warranted.
Comment A5-17
17. The Operational Fleet Maintenance source type, shown in Table 2 of Appendix B 1-HRA, is mistakenly listed as an “Area” source. Fleet Maintenance activities typically involve two primary emission types: 1) indoor shop emissions escaping through building openings and 2) outdoor mobile/idle emissions from heavy equipment or trucks moving around the yard. The District recommends that these sources for modeling analysis be a “Volume” source, per Bay Area Air District 2022 CEQA Guidelines.
Response A5-17
The comment states that the Operational Fleet Maintenance source identified in the HRA is modeled as an “Area” source and recommends that it instead be modeled as a “Volume” source. The comment states that fleet maintenance activities typically involve emissions from indoor shop activities and outdoor vehicle and equipment movements and refers to Bay Area Air District CEQA guidance as support for using a volume source representation.
The HRA modeling approach was developed by qualified air quality professionals using accepted HRA methodologies and modeling assumptions appropriate for the available project information. Selection of source types for dispersion modeling requires professional judgment and may vary depending on the nature of the emission source, the level of detail available, and the objectives of the analysis. The use of an area source is acceptable for various sources modeled (e.g., equipment use, buildings) because the precise footprint or location of equipment use is not known at a level-of-detail to accurately pinpoint the emission source.
The comment does not provide modeling results or technical evidence demonstrating that use of an area source for the Operational Fleet Maintenance emissions materially understates health risks or changes the conclusions of the HRA. It is not uncommon for qualified practitioners to employ different modeling approaches when representing similar emission sources. The City's HRA used a consistent and reasonable methodology to estimate potential health risks associated with project operations. Accordingly, the comment does not provide substantial evidence that the HRA results or conclusions are inaccurate or that additional mitigation is required. Therefore, no changes to the Draft EIR analysis or conclusions are warranted.
Comment A5-18
18. The VOC emission factor for Fueling/Hose Permeation is improperly listed as 0.008 lb/hr, as shown in Appendix B 1-HRA, Table 4. It should be 0.002 lb/hr based on emission factor of 0.03 lb/1000-gal from CARB (2022) Table 7.
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-49 Emission Factor Table for Underground Storage Tanks and assumed throughput of 1,000 gal/day and 17 hr/day.
The District recommends updating the associated calculations for the modeling analysis.
Response A5-18
The comment states that the VOC emission factor used for the Fueling/Hose Permeation source in the City’s HRA appears to be overstated and recommends revising the emission factor from 0.008 lb/hr to 0.002 lb/hr based on CARB guidance and the assumed fuel throughput. The comment recommends updating the associated calculations used in the modeling analysis. Because the recommended correction would reduce the VOC emission rate used in the HRA, incorporation of the revised emission factor would result in lower emissions and would not increase the health risk estimates presented in the Draft EIR. The HRA conclusions are based primarily on diesel particulate matter emissions and other toxic air contaminants associated with project operations, rather than VOC emissions from fueling hose permeation. Therefore, correction of the VOC emission factor would not materially affect the HRA results or the significance conclusions presented in the Draft EIR. Accordingly, no changes to the impact conclusions or mitigation measures are required.
Comment A5-19
19. Impact 3.3-5 (and Mitigation Measure 3.3-5) should discuss the primary Phase I Operations odor producing sources is the receipt, sorting and handling, and storage of municipal wastes at the material recovery facility; and primary Phase II Operations odor producing source is the composting.
For the materials recycling facility, the odor reduction plan should discuss all procedures to minimize odors, including a time limit to process materials from receipt, time limit to send non-recyclable fines offsite, cleanup procedures at end of shifts, capture and treatment of facility ventilation exhaust gases, containers used for storage of segregated recyclables, and good housekeeping practices within the facility (including managing wase materials on floors and in baling areas, and conveyors, keep facility doors closed, and use of streetsweepers).
For composting, Section 2.4.7 under “Sanitary Sewer” on page 2-23 states that contact water from composting operations would be evaporated on site and is not intended to be discharged to the sewer. On page 2-24 under “Stormwater Management” it states that a series (minimum two) of basins for contact water from the compost facility would be retained and reused in the composting process to the maximum extent possible. Accordingly, the District recommends that the odor reduction plan proposed by MM3.3-5 should exclusively address how the odor control would be proposed from these two specific operations as well as a limit on compost pile height, continuous monitoring and adjustment of compost temperature, moisture, Solvita maturity index, and specific oxygen uptake rate, procedures to prevent pile smoldering and smoking, time limit to integrate food wastes into compost piles, identification of good housekeeping procedures to control accumulated byproduct solids and liquids, and adequate aeration or leachate collection ponds.
Response A5-19
The comment recommends that Impact 3.3-5 and Mitigation Measure 3.3-5 more specifically address the primary odor-generating sources associated with Phase 1 and Phase 2 operations. The comment also recommends additional odor control measures and operational requirements for the material recovery facility and composting operations, including waste handling time limits, housekeeping practices, ventilation exhaust treatment, compost process monitoring, pile management, and management of contact water and leachate facilities.
As discussed in the Draft EIR, the primary odor-generating sources associated with the project include the receipt, handling, sorting, storage, and processing of municipal solid waste and organic materials. Mitigation Measure 3.3-5 was specifically developed to address odor emissions from these activities and requires preparation and implementation of a comprehensive Odor Reduction Plan applicable to all odor-generating operations at the facility.
Mitigation Measure 3.3-5 includes numerous elements identified by the comment, including requirements for receiving and processing organics within building enclosures, management of staging times, covered storage of putrescible materials and residuals, maintenance of aerobic conditions within composting operations, monitoring and management of moisture and pile conditions, identification of corrective actions for upset conditions, routine odor monitoring, complaint response procedures, adaptive management measures, and ongoing review and updating of
Responses to Comments Ascent
City of Roseville
2-50 Roseville Environmental Utilities Operations Center Project Final EIR odor control practices. Mitigation Measure 3.3-5 also provides flexibility to incorporate additional engineering and operational controls as warranted based on facility design, operational experience, regulatory requirements, and observed odor conditions.
The City agrees that specific operational practices for waste handling, compost management, housekeeping, leachate/contact water management, and odor control will be important considerations during preparation of the Odor Reduction Plan. In response to this comment, Mitigation Measure 3.3-5 has been revised to more explicitly identify the primary Phase 1 and Phase 2 odor-generating sources, including material recovery facility operations, composting operations, and management of contact water and leachate-related facilities. The mitigation measure has also been revised to clarify that the Odor Reduction Plan shall identify housekeeping procedures for processing and storage areas and procedures to prevent and respond to smoldering, smoking, anaerobic conditions, and other upset conditions that could increase odor emissions. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes. These revisions further clarify the types of odor-generating activities and odor-control measures that shall be addressed in the Odor Reduction Plan while maintaining the performance-based and adaptive framework of Mitigation Measure 3.3-5; however, the analysis and conclusions of the Draft EIR remain unchanged.
Comment A5-20
20. The DEIR Section 2.4.4 states that an Aerated Static Pile (ASP) type of composting system will be used and is applied as the Best Available Control Technology (BACT) in emission calculation shown in Appendix C “Compositing Fugitive Emissions”. The District recommends that the ASP system should be identified as a suitable mitigation measure in MM 3.3-5 to assist mitigation odor issues from the proposed composting facility.
Response A5-20
The comment states that the Draft EIR identifies an Aerated Static Pile (ASP) composting system and assumes use of ASP technology in the emissions analysis. The comment recommends that use of an ASP system be specifically identified in Mitigation Measure 3.3-5 as an odor control measure for the proposed composting facility.
As described on page 2-18 in Chapter 2, “Project Description,” of the Draft EIR, the potential future compost facility would use an ASP system. In addition, Mitigation Measure 3.3-5 specifically identifies covered ASP composting operations as an odor-generating source that must be addressed through the Facility Odor Reduction Plan. The mitigation measure also requires implementation of operational controls applicable to ASP composting, including maintenance of aerobic conditions, monitoring and management of aeration, moisture, and pile conditions, and corrective actions to address upset conditions that could increase odor generation. Because Mitigation Measure 3.3-5 already expressly identifies covered ASP composting operations and requires development and implementation of odor control measures for those operations, the recommendation is already addressed by the Draft EIR. Therefore, no changes to the Draft EIR are required.
Comment A5-21
21. Table 3.3-5 presents that the proposed organic processing facility and biomass facility would emit criteria pollutant emissions more than 25 tons per year. Therefore, it is subject to both the local and federal permitting program requirements. In addition to District’ Rule 502 New Source Review, Mitigation Measure 3.3-3b should also include additional discussion for District Rule 507 Federal Operating Permit Program. Please note that an operational permit can be issued to the proposed facility only when all regulatory requirements from both regulations are met, which includes but is not limited to obtaining and retiring enough emissions reduction credits to offset all stationary source NOx and VOC emissions, and use of Best Available Control Technology for NOx (which would likely require at least the performance of selective catalytic reduction or equivalent).
Thank you for allowing the District this opportunity to review and comment on the Project. Please do not hesitate to contact me at (530) 745.2325 or [email protected] if you have any questions.
Response A5-21
The comment states that the potential future organics processing facility and potential biomass facility could emit criteria pollutants in amounts exceeding 25 tons per year and therefore may be subject to both local and federal
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-51 stationary source permitting requirements. The comment recommends that Mitigation Measure 3.3-3b be revised to address not only PCAPCD Rule 502 (New Source Review), but also Rule 507 (Federal Operating Permit Program), and notes that permit issuance may require compliance with applicable offset, emissions control, and BACT requirements.
The Draft EIR has been revised to include additional discussion of federal Title V operating permit requirements in the air quality impact analysis. As explained in the revised text, operation of the Potential Future Organics Processing Facility and/or Potential Future Biomass Gasification Facility could be subject to federal Title V permitting requirements, depending on final facility design and emissions. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
Mitigation Measure 3.3-3b addresses compliance with applicable air district permitting requirements and was intentionally drafted to encompass all applicable regulatory requirements that may apply at the time permits are sought. The City agrees that, if applicable, project facilities would be required to comply with PCAPCD Rule 507, Rule 502, and all other applicable federal, state, and local permitting requirements, including any requirements related to emissions offsets, emissions controls, BACT, monitoring, recordkeeping, reporting, and permit conditions. Such requirements would be evaluated and applied by PCAPCD during the permitting process based on the final facility design and emissions characteristics. Because compliance with all applicable permitting requirements is already required by law and would occur through PCAPCD’s permitting process, no additional revisions to Mitigation Measure 3.3-3b are necessary.
Letter A6 City of Lincoln
Angela Frost, Environmental Services Manager, City of Lincoln Public Works Department June 18, 2026
Comment A6-1
The City of Lincoln appreciates the opportunity to review and comment on the Draft Environmental Impact Report (DEIR) for the proposed Roseville Environmental Utilities Operations Center (EUOC) Project (State Clearinghouse No. 2024060953).
Lincoln recognizes the need for long-range planning to accommodate future growth, evolving solid waste regulations, and changing waste management practices. We commend the City of Roseville for proactively planning for future operational needs. However, as a neighboring jurisdiction and member agency that relies upon the Western Placer Waste Management Authority (WPWMA) for disposal and recycling services, Lincoln requests additional analysis regarding several potential regional impacts associated with the proposed project.
Response A6-1
The comment states that the City of Lincoln is a neighboring jurisdiction and WPWMA member agency, and requests further analysis of potential regional impacts identified in the Draft EIR for the project. The comment provides a summary of detailed comments provided below. See responses to the detailed comments below.
Comment A6-2
1. Regional Waste Flow and WPWMA Impacts
The DEIR references existing agreements between the City of Roseville and the WPWMA and indicates that certain waste streams will continue to be delivered to WPWMA facilities through at least 2043. The City of Lincoln requests clarification regarding:
▶ The specific waste streams that will continue to be delivered to WPWMA facilities; ▶ The estimated annual tonnage of each material type;
▶ The projected reduction in material currently delivered to WPWMA resulting from implementation of the proposed EUOC and Resource Recovery and Transfer Operations (RRTO) facility; and ▶ The assumptions used to evaluate future waste flow allocations.
Responses to Comments Ascent
City of Roseville
2-52 Roseville Environmental Utilities Operations Center Project Final EIR Lincoln is concerned that diversion of significant waste volumes from WPWMA may affect facility utilization, revenue generation, and long-term financial planning for the regional system.
Response A6-2
The comment requests additional detail regarding how the project would affect regional waste flows to WPWMA.
Specifically, the comment requests clarification on the types and quantities of waste that will continue to be delivered, projected reductions in tonnage, and the assumptions used for future waste allocation.
The Draft EIR describes the anticipated materials handling in Section 2.2.4, “Projected Increases in Demand for Materials Hauling.” The level of detail requested, including specific future tonnages by material type, operational assumptions, and allocation strategies, constitutes speculative, operational, and/or proprietary planning information that is not required for evaluation in an EIR. Under CEQA, an EIR is required to analyze the physical environmental effects of a project. The requested information relates primarily to economic considerations, including facility utilization rates, revenue generation, and financial planning for WPWMA. An evaluation of socioeconomic impacts is not required by CEQA because it is not an impact to the natural or physical environment. As stated in Section 15131 of the CEQA Guidelines, the economic and social effects of a project shall not be treated as significant effects on the environment. An EIR can trace a path between a social or economic effect to determine if there is a cause and effect between a social or economic effect and a change in the environment (such as blight). The Draft EIR does not identify, and the comment does not provide, information indicating that the potential socioeconomic effects identified in the comment would result in a significant impact on the physical environment.
The Draft EIR adequately evaluates the environmental effects of the project, including solid waste handling, transportation, air quality, greenhouse gas emissions, and other relevant resource areas based on reasonable assumptions and available information. Future detailed decisions regarding waste stream allocations, contractual arrangements, and operational logistics would be addressed through separate planning and interagency coordination processes, as appropriate, and are outside the scope of CEQA review. Therefore, no additional analysis is required in the EIR.
Comment A6-3
2. Regional Cost-Sharing and Financial Sustainability
WPWMA serves as a critical regional asset utilized by the Cities of Lincoln, Roseville, Rocklin, and Placer County.
Recent investments in processing infrastructure and facility improvements were based upon projected waste flows and long-term regional growth assumptions.
The DEIR should evaluate whether diversion of material currently delivered to WPWMA could:
▶ Reduce facility utilization rates;
▶ Increase fixed costs borne by remaining member agencies; ▶ Increase tipping fees or disposal costs;
▶ Affect future capital planning and infrastructure investments; or ▶ Impact the long-term financial sustainability of the regional waste management system.
Lincoln respectfully requests that the DEIR analyze the potential impacts of the proposed project on regional solid waste infrastructure and regional cost-sharing arrangements resulting from diversion of waste streams currently processed through WPWMA facilities.
Response A6-3
The comment requests that the Draft EIR evaluate how diversion of waste from WPWMA facilities could affect regional cost-sharing and financial sustainability. Specifically, the comment expresses concern about potential reductions in facility utilization, increased costs to remaining member agencies, higher tipping fees, impacts on capital planning, and broader effects on the long-term financial sustainability of the regional waste management system.
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-53 As described in response to comment A6-2, CEQA does not require analysis of economic or social impacts because they are not physical environmental effects; no evidence has been provided in the comment demonstrating that such impacts would lead to a significant physical environmental change. The issues raised in the comment, such as facility utilization rates, tipping fees, and financial planning, are economic and administrative in nature. The comment does not identify a physical environmental impact that would result from these potential fiscal changes beyond those already evaluated in the Draft EIR. As such, these topics are outside the scope of CEQA review.
The Draft EIR appropriately evaluates the project’s potential impacts related to solid waste handling, transportation, air quality, greenhouse gas emissions, and other relevant resource areas based on reasonable assumptions and available information. Potential adjustments to regional cost-sharing arrangements, funding mechanisms, or infrastructure investment strategies are matters for separate decision-making processes, not environmental analysis under CEQA.
Therefore, no additional analysis of economic impacts to WPWMA or its member agencies is required in the EIR.
Comment A6-4
3. Resource Recovery and Transfer Operations (RRTO) Analysis The proposed RRTO facility appears to be a central component of the project. The City of Lincoln requests additional information regarding:
▶ Projected annual tonnage of municipal solid waste, recyclables, and organics processed through the facility; ▶ Daily and peak-period truck trip generation;
▶ Long-term expansion assumptions and buildout capacity; ▶ Whether future operations could expand beyond those currently analyzed in the DEIR; and ▶ Whether the environmental analysis is based on realistic maximum operational capacity.
Lincoln requests confirmation that the DEIR evaluates the reasonably foreseeable maximum operational scenario for the facility rather than only near-term operational conditions.
Response A6-4
The comment requests additional details regarding the proposed RRTO facility, including projected waste tonnage, truck trip generation, long-term capacity and expansion assumptions, and whether the Draft EIR evaluates a realistic maximum operational scenario rather than near-term conditions only.
The Draft EIR includes an analysis of the proposed RRTO facility based on a conservative, reasonably foreseeable maximum operational scenario, consistent with CEQA requirements. As described in Section 2.2.4, “Projected Increases in Demand for Materials Handling,” (pages 2-5 through 2-6), the City developed both near-term and longterm demand scenarios based on projected population growth, regional growth, and the potential to serve waste haulers outside the City. Chapter 2, “Project Description,” identifies an estimated annual material throughput demand of approximately 270,000 tons per year under near-term conditions and approximately 660,000 tons per year under long-term conditions through 2058 (see Table 2-1 on page 2-6). Chapter 2, “Project Description,” further states on page 2-6 that the 660,000-ton-per-year estimate was developed using a 2.5 percent annual growth rate through 2058 and was intended to represent a conservative upper-bound estimate of future demand. Accordingly, the Draft EIR evaluates the project’s potential impacts based on projected long-term operational conditions and ultimate facility buildout, rather than solely near-term operations.
As further described in Section 2.2.4, “Projected Increases in Demand for Materials Handling,” the long-term demand scenario represents the maximum total solid waste stream anticipated to be managed by the facility, including municipal solid waste, recyclable materials, and organic waste generated within Roseville and potentially delivered from sources outside the City. The Draft EIR (page 2-6) identifies this scenario as a conservative estimate intended to evaluate the reasonably foreseeable upper bound of facility demand through 2058.
Chapter 2, “Project Description,” also provides information regarding existing waste streams currently generated within Roseville, including approximately 84,000 tons per year of municipal solid waste, 33,000 tons per year of
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City of Roseville
2-54 Roseville Environmental Utilities Operations Center Project Final EIR recyclables, and 33,000 tons per year of organic waste (Section 2.2.1, pages 2-4 through 2-5). While the Draft EIR identifies existing waste stream quantities by material type, long-term throughput projections are presented on a combined facility-capacity basis because the RRTO Facility is intended to accommodate varying quantities of municipal solid waste, recyclables, and organic materials over time based on service demand, regulatory requirements, and market conditions.
Long-term expansion assumptions are described in Section 2.4, “Description of the Proposed Project” (page 2-7). The project is proposed in two phases, with Phase 2 including expansion of the RRTO Facility and providing capacity through 2058. Table 2-2 identifies the RRTO Facility expansion from approximately 200,000 square feet in Phase 1 to an additional 122,000 square feet at buildout for a total of 322,000 square feet. The Draft EIR also explains that the facility is intended to accommodate materials generated both within and outside the City and includes objectives related to serving regional waste streams (see page 2-6).
Information regarding daily and peak-period truck trip generation is provided in Section 3.16, “Transportation and Circulation,” which evaluates vehicle and truck traffic associated with operation of the RRTO Facility and other project components under the project’s long-term operational assumptions (see in particular Table 3.16-2 on page 3.16-20).
The Draft EIR transportation analysis was conducted using the project characteristics and buildout assumptions described in Chapter 2 and, therefore, reflects anticipated truck activity associated with the reasonably foreseeable operational scenario evaluated in the Draft EIR.
The Draft EIR appropriately evaluates the project’s environmental impacts related to solid waste handling, transportation, air quality, GHG emissions, and other relevant resource areas based on the project description, including the long-term throughput projections, buildout assumptions, and facility capacity planned through 2058.
Any future modifications or expansions beyond the scope of what is analyzed in the Draft EIR would be subject to separate environmental review, as required by CEQA. Therefore, the analysis presented in the Draft EIR is sufficient, and no additional information or analysis is required.
Comment A6-5
4. Compatibility with Regional Waste Infrastructure
The City of Lincoln requests additional analysis regarding the project’s compatibility with existing regional waste management infrastructure, including:
▶ Potential effects on existing regional facilities;
▶ Future material recovery operations that may be contemplated but not fully defined; ▶ Changes to regional waste flow patterns; and
▶ Cumulative impacts to regional solid waste management capacity.
The City believes that a comprehensive evaluation of these issues is important to ensure regional coordination and long-term planning consistency among affected agencies.
Response A6-5
The comment requests additional analysis of the project’s compatibility with regional waste management infrastructure, including potential effects on existing facilities, future material recovery operations, changes in regional waste flow patterns, and cumulative impacts to regional solid waste capacity.
The Draft EIR adequately evaluates the project’s impacts on solid waste capacity and cumulative conditions in accordance with CEQA requirements. The analysis considers whether sufficient landfill and waste processing capacity exists to accommodate the project and concludes that impacts would be less than significant (see Impact 3.15-3 on pages 3.15-16 through 3.15-18). The Draft EIR also addresses cumulative impacts related to solid waste by evaluating the project in the context of other past, present, and reasonably foreseeable future projects (see Section 4.3.15, “Public Utilities,” particularly the discussion of solid waste on page 4-22). The analysis explains that the cumulative setting includes the WPWMA service area and recognizes future regional growth in waste generation, while also
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City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-55 identifying the approved expansion of the Western Regional Sanitary Landfill and concluding that sufficient regional capacity exists through the planning horizon.
In addition, the Draft EIR evaluates transportation and GHG impacts associated with project-related waste collection, transfer, and processing activities, which inherently consider changes in transportation of waste throughout the region.
Impact 3.16-2 evaluates project-generated truck and employee trips associated with waste transfer and recovery operations and analyzes associated changes in regional travel patterns. Likewise, Section 3.4, “Greenhouse Gas Emissions,” quantifies operational emissions from mobile truck trips, material transfer activities, material recovery operations, and potential future organics processing activities (see Tables 3.4-4 and 3.4-6). These analyses account for the physical environmental effects associated with changes in the movement of solid waste and recovered materials.
Speculation regarding future, undefined material recovery operations or shifts in regional waste management strategies is not required where such details are not reasonably foreseeable or would not alter the environmental impact conclusions. Accordingly, the Draft EIR evaluates a reasonably foreseeable future organics processing facility as part of Phase 2 and assesses its potential transportation, air quality, GHG, utility, and cumulative environmental effects.
The additional topics raised in the comment, such as redistribution of waste flows among regional facilities, potential effects on the use or operation of existing infrastructure, and coordination of future material recovery efforts, primarily concern regional planning, operational, and economic considerations, rather than physical environmental impacts. As discussed in responses to comments A6-2 through A6-4, CEQA does not require evaluation of economic or administrative effects (State CEQA Guidelines Section 15131) unless they would result in a reasonably foreseeable physical environmental change, which has not been demonstrated. To the extent that changes in waste flow patterns could result in physical environmental effects, those effects are addressed through the Draft EIR’s transportation, GHG emissions, utilities, and cumulative impact analyses.
Issues of regional coordination, infrastructure utilization, and long-term planning consistency are appropriately addressed through interagency agreements, policy planning, and ongoing coordination among WPWMA member agencies, rather than through CEQA environmental analysis. Therefore, the Draft EIR provides sufficient evaluation of the project’s potential impacts related to regional solid waste infrastructure, and no additional analysis is required.
Comment A6-6
Conclusion
The City of Lincoln appreciates the opportunity to comment on the Draft EIR and respectfully requests that the City of Roseville provide additional analysis and clarification regarding the issues identified above. In particular, Lincoln seeks a better understanding of how the proposed EUOC and RRTO facility may affect regional waste flows, WPWMA operations, cost allocation among member agencies, and the long-term sustainability of the regional waste management system.
The City of Lincoln respectfully requests that these comments be incorporated into the Final EIR and that responses be provided pursuant to CEQA requirements.
We look forward to continued coordination throughout the environmental review process.
Response A6-6
The comment provides a summary of detailed comments provided above. See responses to the detailed comments above.
Letter A7 Western Placer Waste Management Authority
Scott Scholz, General Manager
June 22, 2026
Comment A7-1
The Western Placer Waste Management Authority (WPWMA) appreciates the opportunity to review and provide comments on the Draft Environmental Impact Report (DEIR) for the Roseville Environmental Utilities Operations Center Project (Project).
Responses to Comments Ascent
City of Roseville
2-56 Roseville Environmental Utilities Operations Center Project Final EIR The WPWMA is a regional agency established in 1978 by the County of Placer and the cities of Roseville, Rocklin and Lincoln (Member Agencies) governed by a Board of Directors comprised of elected officials from each of the Member Agencies. The WPWMA provides recycling and waste disposal services to those communities as well as the cities of Auburn and Colfax and the Town of Loomis. The WPWMA also provides these services to individuals, business entities and other governmental agencies in and around Placer County. In total, the WPWMA provides waste management and recycling services to a population of approximately 400,000 and currently receives and manages approximately 484,000 tons per year of residentially and commercially generated solid waste and recyclables.
The WPWMA's nearly 1,000-acre campus, located at the intersection of Athens Avenue and Fiddyment Road immediately north of the City of Roseville and approximately 5.5 miles northeast of the Project location provides a conveniently located, comprehensive solid waste management system that includes a materials recovery facility (MRF), construction and demolition debris recovery facility, organics composting facility, residential and commercial recycling drop-off and buy-back center, permanent household hazardous waste collection facility, and the only remaining active sanitary landfill in Placer County. The WPWMA's systems were designed and are operated to ensure that Placer County's municipalities, businesses and residents are able to comply with state and federal solid waste management laws and regulations, including the organic waste diversion mandates of SB 1383 and required covered products of SB 54, in a cost effective and sustainable manner.
In an effort to proactively plan for continued regional growth, changes in solid waste and climate-related regulations, and ever-increasing volatility in foreign and domestic recyclable commodity markets, the WPWMA prepared and its Board of Directors unanimously certified the Renewable Placer Waste Action Plan Environmental Impact Report (EIR) in December 2022. The EIR represented the culmination of 6 years of extensive planning and research by the WPWMA and its Member Agencies, including the City of Roseville, to identify the most sustainable, cost-effective approach focused on developing a local circular economy and ensuring long-term, locally controlled solid waste management capacity and continued regulatory compliance to support the Member Agencies' solid waste and recycling needs for at least the next 100 years.
The initial phase of Waste Action Plan included the $120 million renovation of the WPWMA's MRF and composting facilities to comply with SB 1383 organic materials diversion requirements and manage waste streams regardless of collection method; the upgraded MRF is also capable of processing both mixed (black bin) and sourceseparated (blue bin) materials for recovery of recyclable materials. After completing construction of its enhanced composting facility, the WPWMA achieved an organics recovery rate of over 82% as part of its Q1 2026 SB 1383 organics measurement requirements.
The WPWMA has also reserved space on its campus to foster development of a local circular economy by facilitating compatible technologies and manufacturing to utilize materials recovered at the WPWMA's MRF. This pivotal action is intended to create and support a vibrant and sustainable local recyclables market, reduce the environmental impacts associated with long-distance transport of materials to foreign and domestic markets, and create local jobs, helping to enhance the region's economy.
Response A7-1
The comment is an introductory statement and does not address the content, analysis, or conclusions in the Draft EIR.
Therefore, a response is not provided here. Responses to specific comments concerning environmental issues are provided below.
Comment A7-2
Based on information provided in the City's June 21, 2024 Notice of Preparation for the Project, the WPWMA requested that the City conduct a comprehensive evaluation of all potentially consequential environmental and economic impacts of the proposed Project on the existing regional solid waste management system analyzing at least the following resource areas associated with additional vehicle traffic necessary to transport materials to the Project site, recovered materials bound for various end markets, and residual wastes requiring disposal at a sanitary landfill: 1) Greenhouse Gas Emissions, 2) Transportation/Traffic, 3) Hazards & Hazardous Materials, and 4) Air Quality.
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-57 Based on its review of the DEIR, the WPWMA was unable to discern if the requested analysis was performed. Given that the Project contains many of the same elements as the WPWMA's existing operation which have been designed and are operated to achieve compliance with SB 1383 and other solid waste regulations, and that the City is planning for waste flows that are approximately 40% greater than the current annual tonnages received and processed at the WPWMA's facility, the WPWMA believes a clear and transparent summary of the requested analysis is critical for the Decision makers and the public to understand the potential long-term impacts of the Project.
The WPWMA looks forward to continuing to engage with the City of Roseville as it evaluates its proposed Project to ensure the long-term viability of the WPWMA's facilities and operations in order to continue providing valuable public services to the WPWMA's customers, including the City of Roseville.
Response A7-2
The comment states that WPWMA previously requested, in an NOP comment letter, a comprehensive analysis of potential environmental and economic impacts of the project on the regional solid waste system, including greenhouse gas emissions, transportation/traffic, hazards, and air quality, but could not determine from the Draft EIR whether this analysis was conducted. The comment also emphasizes the importance of a clear and transparent summary of these impacts, particularly given similarities to WPWMA operations and anticipated increased waste flows.
The Draft EIR evaluates the project’s potential impacts in accordance with CEQA, including analysis of GHG emissions, transportation, hazards and hazardous materials, and air quality; however, CEQA does not require evaluation of economic or fiscal impacts. While the analysis is presented within the applicable resource sections (see Sections 3.4, “Greenhouse Gas Emissions,” 3.16, “Transportation and Circulation,” 3.10, “Hazards and Hazardous Materials,” and 3.3, “Air Quality”) rather than as a single consolidated summary focused on regional solid waste system effects, the Draft EIR provides sufficient information and analysis, by category of impact, for decision makers and the public to understand the project’s potential impacts.
Letter A8 Placer Conservation Authority
Greg McKenzie, Executive Director
June 20, 2026
Comment A8-1
I. Introduction and Interest of the Placer Conservation Authority The Placer Conservation Authority (the "Authority" or "PCA") submits these comments on the City of Roseville's Draft Environmental Impact Report ("Draft EIR" or "DEIR") for the proposed Roseville Environmental Utilities Operations Center Project (the "Project"). The Authority is a California joint exercise of powers authority - formed by the County of Placer, the City of Lincoln, the Placer County Water Agency, and the South Placer Regional Transportation Authority - tasked with implementing the Placer County Conservation Program ("PCCP"), including the Western Placer County Habitat Conservation Plan and Natural Community Conservation Plan (the "HCP/NCCP") and the assembly, management, and perpetual stewardship of a regional reserve system for sensitive native plants, wildlife, and natural communities.
The Authority has a direct and substantial interest in this Project because of where it would be built. The Project site lies immediately east of the Clemetson Property - which therefore adjoins the Project's western boundary - and immediately south of the Mourier West Property, which adjoins the Project's northern boundary across Pleasant Grove Creek. (See attached map.) Both are PCCP reserve-system properties; they are not ordinary parcels of farmland. Together with the Reason Farms Environmental Preserve, the Al Johnson Wildlife Area, the Authority's 241- acre Mourier East preserve, the Toad Hill Ranch Mitigation Bank, and other conservation areas, they form a landscape-scale block of conservation lands totaling approximately 4,116 acres, assembled to link the Pleasant Grove Creek corridor with existing and planned conservation lands and to preserve nesting and foraging habitat for Swainson's hawk, tricolored blackbird, burrowing owl, and other listed species. Protected vernal pool species, including vernal pool fairy shrimp, occur in multiple aquatic features on the Mourier West Property directly north of the Project site and Clemetson Property directly west of the Project site.
Responses to Comments Ascent
City of Roseville
2-58 Roseville Environmental Utilities Operations Center Project Final EIR Response A8-1
The comment explains PCA’s role in implementing the PCCP and managing regional conservation lands. The comment notes that the project site is immediately adjacent to PCCP reserve properties, including the Clemetson and Mourier West reserves, and emphasizes the ecological importance of these lands for special-status species and protected habitats, including Swainson’s hawk, tricolored blackbird, burrowing owl, and vernal pool species. The comment is an introductory statement and does not address the content, analysis, or conclusions in the Draft EIR.
Therefore, a response is not provided here. Responses to specific comments concerning environmental issues are provided below.
Comment A8-2
Placing a large-scale, industrial-character municipal operations center immediately adjacent to these reserve lands will, absent appropriate design features and minimization measures, cause both direct and indirect impacts to their habitat values and will complicate the Authority's management of them. The Authority raised these concerns in its July 19, 2024 letter responding to the City's June 21, 2024 Notice of Preparation, in which it asked the EIR to (1) assess the direct and indirect effects of converting natural and semi-natural lands to urban use on the Project site and on the surrounding conservation lands, including the overall viability of the associated conservation plans and the listed and unlisted species they protect; (2) analyze indirect effects including groundwater and surface-water quality, lighting, noise, trash, impacts to nesting birds, and foraging habitat for listed bird species; and (3) analyze whether the Project is consistent with the HCP/NCCP and the County Aquatic Resources Program. Regrettably, the Draft EIR does not meaningfully respond to these requests.
CEQA requires an EIR to serve as a good-faith, full-disclosure informational document that identifies and clearly describes both the direct and the reasonably foreseeable indirect significant environmental effects of a project, including "alterations to ecological systems" and effects the project "might cause or risk exacerbating by bringing development and people into the area affected." (Pub. Resources Code, §§ 21002.1, 21100, subd. (b); CEQA Guidelines, §§ 15121, 15126.2, subd. (a}, 15358, subd. (a)(2), 15064, subd. (d).) Indirect effects on biological resources - changes to hydrology, noise, light, human intrusion, and the introduction or spread of invasive species - are exactly the kind of reasonably foreseeable secondary effects CEQA requires the EIR to analyze. As to the adjacent reserve lands, the Draft EIR has not done so, and the analysis should be revised.
Response A8-2
The comment states that the project’s location adjacent to PCCP reserve lands could result in direct and indirect impacts to conservation resources, including effects related to hydrology, water quality, lighting, noise, trash, human activity, invasive species, nesting birds, and foraging habitat. The comment further states that the Draft EIR does not adequately analyze these potential effects or evaluate consistency with the HCP/NCCP and recommends that the analysis be revised.
As discussed in responses to similar comments above regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the project site is not located within the PCCP plan area and is not subject to PCCP’s permit requirements, conservation strategy, or mitigation framework.
Nevertheless, the Draft EIR evaluates the project’s potential direct and indirect impacts on biological resources, including special-status species, nesting birds, habitat resources, wildlife movement (see Section 3.5 in the Draft EIR); hydrology and water quality (see Section 3.11 in the Draft EIR); noise (see Section 3.12 in the Draft EIR); and other environmental topics that could affect adjacent lands.
The Draft EIR analysis considers the existing environmental setting, including adjacent open space, waterways, habitat areas, and conservation lands. The Draft EIR evaluates the project’s potential impacts based on CEQA’s significance criteria and includes applicable avoidance, minimization, and mitigation measures to reduce impacts where necessary.
As described in responses to comment A3-5, the City identified the project site as early as 2003 for City use. As described in Chapter 2, “Project Description,” of the Draft EIR, the City purchased the project site (and the larger Reason Farms area) in 2003. Since the purchase, the project site has been intended for future City use. The existing General Plan land use designation for the project site is P/QP, which primarily allows for municipal and governmental
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City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-59 facilities. The zoning for the project site is PD. As a public facility, the project would be consistent with the P/QP land use designation and PD zoning district.
The City acknowledges that portions of the lands adjacent to the project site are now included within the PCCP reserve system and provide habitat values that contribute to the PCCP conservation network (see Figure 2-1 in this Final EIR, above).
Field observations conducted during the April 2024 biological survey of the project site indicated that portions of the western adjacent property were being actively grazed and exhibited characteristics consistent with grazed grassland conditions at the time of the survey. Regardless of the land use designation or conservation status of adjacent properties, the Draft EIR biological resources analysis evaluated the potential for project-related direct and indirect effects on adjacent habitats, special-status species (including PCCP Covered Species), sensitive natural communities, and wildlife movement corridors. Accordingly, the impact analysis was not dependent upon whether adjacent lands were characterized as agricultural land, open space, or PCCP reserve lands.
The Draft EIR provides an analysis of potential impacts to biological resources that may occur on or adjacent to the project site. The Draft EIR does not identify substantial evidence that the project would impede implementation of the PCCP, interfere with reserve management objectives, or preclude achievement of the PCCP’s biological goals and objectives. Therefore, the Draft EIR’s biological resources analysis and conclusions remain unchanged.
Comment A8-3
II. The Draft EIR Does Not Adequately Address Impacts to the Adjacent Reserve Properties, Including Clemetson and Mourier West
The Draft EIR's biological resources analysis acknowledges that Project operation may cause indirect effects including "reduction in water quality caused by storm water runoff, erosion, and siltation; increased litter; noise and light pollution; alteration of the hydrologic regime…; intrusion of humans; and introduction or spread of invasive species that could result in habitat degradation." (DEIR, § 3.5, p. 3.5-23.) These are the very urbanization effects the Authority identified. The deficiency is not that the Draft EIR fails to name these effects - it is that the Draft EIR evaluates them almost entirely with respect to Pleasant Grove Creek and the riparian corridor to the north, and does not evaluate them with respect to the reserve lands the Project actually abuts. Specifically:
▶ Clemetson is not mentioned at all. The Draft EIR does not identify, describe, or analyze the Clemetson Property - the reserve parcel immediately west of the Project - anywhere in its biological, land use, aesthetics, or noise analyses. An EIR cannot disclose impacts to a resource it never acknowledges. (CEQA Guidelines,§ 15125, subds. (a), (c).)
▶ Mourier West is acknowledged only in passing. The Draft EIR refers to Mourier West once, as "[t]he nearest PCCP Reserve Acquisition Area ... approximately 930 feet north of the proposed development area," and then uses that reference to dismiss further analysis. (DEIR, § 3.5., p. 3.5-22.) A separation of roughly 930 feet is well within the distance at which urban-edge effects on habitat occur; it is a reason to analyze impacts, not to forgo the analysis.
The Draft EIR does not assess the Project's indirect effects on the vernal pool features and special-status species documented on Mourier West, or on its value as Swainson's hawk and other listed-bird foraging and nesting habitat.
Response A8-3
The comment states that the Draft EIR does not adequately analyze potential indirect impacts on adjacent PCCP reserve properties, particularly the Clemetson and Mourier West reserves. The comment states that while the Draft EIR identifies potential urban-edge effects such as noise, lighting, litter, invasive species, human intrusion, and hydrologic changes, it does not specifically evaluate these effects on the adjacent reserve lands and associated special-status species and habitats.
As discussed in the responses to previous comments regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project’s potential direct and indirect impacts on biological resources, including special-status species, nesting birds, habitat resources,
Responses to Comments Ascent
City of Roseville
2-60 Roseville Environmental Utilities Operations Center Project Final EIR wildlife movement, water quality, hydrology, noise, lighting, and other environmental factors that could affect adjacent lands and habitat areas. The purpose of the biological resources analysis is to evaluate the project’s potential physical impacts on environmental resources, rather than to separately analyze individual neighboring properties. The analyses and significance determinations are based on the presence of biological resources and habitats in the project vicinity, including those associated with Pleasant Grove Creek and adjacent open space and conservation lands. Mitigation measures are incorporated to avoid, minimize, or reduce impacts (see Mitigation Measures 3.5-1, 3.5-2a through 3.5-2k, 3.5-3, 3.5-4a and 3.5-4b, 3.5-5, and 3.5-6). In response to comments received on the Draft EIR, the analysis of Impact 3.5-4 and Mitigation Measure 3.5-4b have been revised to further evaluate and address the potential for indirect impacts on off-site wetlands resulting from project implementation. In addition, Mitigation Measure 3.5-5 has been expanded to also apply to the nearby reserve properties to minimize lighting impacts. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
The City recognizes that the Clemetson and Mourier West properties are adjacent to the project site, are included within the PCCP reserve system, and provide habitat values that contribute to the PCCP conservation network.
As described in response to comment A8-2, field observations conducted during the April 2024 biological survey of the project site indicated that portions of the western adjacent property were being actively grazed and exhibited characteristics consistent with grazed grassland conditions at the time of the survey. During the April 2024 survey, off-site areas were viewed through binoculars by a qualified biologist. Although the biologist observed low areas north of the project site, the areas were dry and lacked vegetation, and no potential regulated wetlands were observed. However, information subsequently provided by PCA in July 2026 indicates that wetlands do likely occur on adjacent lands that are now designated as PCCP reserve properties (Figure 2-2 in this Final EIR shows the potential wetlands on the Clemetson property, to the west of the project site, as provided by PCA). Regardless of the land use designation or conservation status of adjacent properties, the Draft EIR biological resources analysis evaluated the potential for project-related direct and indirect effects on adjacent habitats, special-status species (including PCCP Covered Species), sensitive natural communities, and wildlife movement corridors. Accordingly, the impact analysis was not dependent upon whether adjacent lands were characterized as agricultural land, open space, or existing or future PCCP reserve lands.
The City also notes that the Clemetson and Mourier West properties were acquired by PCA in 2025, after circulation of the NOP for the project and after preparation of the EIR analyses was already underway, although the Draft EIR was not published until May 2026. Consistent with CEQA, the Draft EIR evaluates the environmental setting and potential impacts based on conditions existing during the environmental review process and focuses on the biological resources present in and adjacent to the project area rather than the ownership status of particular properties. The subsequent acquisition of these properties by PCA does not alter the underlying biological resources evaluated in the Draft EIR, does not change the project’s regulatory obligations, and does not affect the significance determinations presented in the environmental analysis. Accordingly, the Draft EIR adequately evaluates the project’s potential impacts to adjacent biological resources consistent with CEQA. As discussed above, revisions have been made to the analysis of Impact 3.5- 4 and Mitigation Measure 3.5-4b to further address potential indirect effects on off-site wetlands, and Mitigation Measure 3.5-5 to further address potential edge effects on adjacent reserve properties; however, these revisions do not alter the significance determinations or conclusions presented in the Draft EIR.
Comment A8-4
▶ Adjacent reserve land is mischaracterized as ordinary "agricultural land." The environmental setting describes the Project as "surrounded by agricultural land uses to the west, south, and east." (DEIR, § 3.5.2, p. 3.5-6.) Treating the western neighbor (Clemetson) as undifferentiated farmland obscures that it is protected reserve land managed for conservation values, and it causes the Draft EIR to bypass any assessment of effects on those values.
Response A8-4
The comment states that the Draft EIR incorrectly characterizes land adjacent to the project site as agricultural land, noting that the Clemetson property to the west is now protected conservation land managed by PCA and should be evaluated accordingly.
Ascent Responses to Comments
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-61 As discussed in responses to previous comments regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project’s potential direct and indirect impacts on biological resources based on the environmental resources present in and adjacent to the project area, and those analyses are not dependent on the ownership, management, or conservation status of adjacent properties.
The City also notes that the Clemetson property was acquired by PCA in 2025, after circulation of the NOP for the project and after preparation of the EIR analyses was underway. While the Draft EIR refers to surrounding agricultural land uses in describing the environmental setting, the subsequent acquisition of the property by PCA does not change the biological resources present on the site or alter the impact analysis and conclusions presented in the Draft EIR. For the reasons discussed in the responses above, the Draft EIR adequately evaluates potential impacts to adjacent biological resources and conservation values. Accordingly, no changes to the Draft EIR are required.
Comment A8-5
▶ The edge-effect, lighting, noise, and wildlife-movement analyses are oriented to the creek, not to the reserve interfaces. The Draft EIR's indirect-effects discussion, its fencing and setback measures, and Mitigation Measure
3.5-5 are framed around "trespassing into Pleasant Grove Creek," light "spillover onto sensitive riparian habitat," and a "structural barrier ... directed perpendicular to Pleasant Grove Creek." (DEIR, § 3.5, p. 3.5-42.) None of these measures is designed to protect the reserve lands to the north (Mourier West) and west (Clemetson), and the Draft EIR offers no substantial evidence that creek-oriented measures would also protect those lands.
Response A8-5
The comment states that the Draft EIR's analysis of edge effects, lighting, noise, fencing, and wildlife movement focuses on Pleasant Grove Creek and riparian habitat rather than the adjacent Clemetson and Mourier West reserve properties.
As discussed in the responses to the preceding comments regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project’s potential direct and indirect impacts on biological resources, including lighting, noise, human disturbance, habitat effects, and wildlife movement. The analysis and mitigation measures are intended to address these impact mechanisms regardless of property ownership and are based on the biological resources present in the project vicinity.
Mitigation Measure 3.5-5 references Mitigation Measures 3.12-1 and 3.12-3, which would reduce noise impacts on nearby sensitive human receptors. In addition, Mitigation Measures 3.12-1 and 3.12-3 would also reduce the potential for construction- and operation-related noise to affect nearby reserve properties that may support sensitive habitats and special-status wildlife species. Temporary noise barriers, acoustically treated building components, equipment shielding, quieter equipment, operational restrictions, and other noise attenuation measures would reduce the intensity and duration of noise reaching nearby reserve properties. By reducing noise levels at the project boundary and limiting nighttime noise-generating activities, these measures would help minimize disturbance, disruption of wildlife behavior, and potential avoidance of habitats by sensitive species in nearby reserve properties.
In response to this comment and other PCA comments, Mitigation Measure 3.5-5 has been expanded to also apply to the nearby Placer Conservation Authority reserve properties. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes. Mitigation Measure 3.5-5, as revised, would reduce potential impacts on nearby Placer Conservation Authority reserve properties that may support sensitive habitats and special-status wildlife species. Birdfriendly building design features, wildlife-conscious lighting design, and screening of construction lighting and vehicle headlights would reduce artificial light intrusion, minimize the potential for bird collisions, and lessen disruption of wildlife movement and behavior. By limiting light spillover into Pleasant Grove Creek and adjacent reserve properties through shielding, directional lighting, and other lighting controls, Mitigation Measure 3.5-5 would help maintain more natural nighttime conditions and reduce disturbance to sensitive species within the reserve properties.
See also responses to comments A3-7 and A8-12 through A8-16 regarding the City’s commitment to incorporate applicable PCCP Development Interface Design Requirements and continue coordination with PCA regarding development interface measures intended to minimize potential impacts on adjacent reserve properties.
Responses to Comments Ascent
City of Roseville
2-62 Roseville Environmental Utilities Operations Center Project Final EIR Comment A8-6
▶ On-site species analysis is not a substitute for reserve-directed indirect-effects analysis. The Authority recognizes that the Draft EIR analyzes special-status species on the Project site and the off-site utility easement - including a measure to mitigate the direct loss of on-site Swainson's hawk foraging habitat (Mitigation Measure 3.5-2h) and on-site vernal pool branchiopod habitat. But the Draft EIR does not analyze the Project's reasonably foreseeable indirect effects on the habitat values of the adjacent reserve lands, which is the omission at issue here.
Response A8-6
The comment states that, while the Draft EIR analyzes direct impacts to special-status species and habitats on the project site, it does not adequately evaluate the project's reasonably foreseeable indirect effects on the habitat values of adjacent PCCP reserve lands.
As discussed in the responses to the preceding comments regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates both direct and indirect impacts on biological resources, and is not limited to resources located on the project site.
The comment does not provide justification to develop a separate reserve-specific indirect effects analysis. The Draft EIR evaluates the relevant indirect impact mechanisms and their potential effects on biological resources in the project vicinity, including resources located on adjacent lands (see Figure 2-1 in this Final EIR, which identifies the locations of the reserve properties in relation to the project site, and Figure 2-2 in this Final EIR, which shows the potential wetlands on the Clemetson property, to the west of the project site, as provided by PCA). The comment does not provide substantial evidence demonstrating that the project would result in significant indirect impacts to adjacent reserve lands beyond those evaluated in the Draft EIR or that additional analysis would alter the significance determinations. Accordingly, for the reasons discussed in the responses above, no changes to the Draft EIR are required.
Comment A8-7
Response to the "not discussed further" determination. Under the heading "Issues Not Discussed Further," the Draft EIR states that, because "[t]he City of Roseville is not a participant in this PCCP and the project site is not within the PCCP plan area," the issue of conflict with an adopted HCP/NCCP is "not discussed further." (DEIR, § 3.5.3, p. 3.5-22.) This directly declines the Authority's NOP request that the EIR analyze the Project's consistency with the HCP/NCCP and CARP, and the Authority respectfully disagrees that it disposes of the matter. Whether or not the Project is subject to the HCP/NCCP, and whether or not the City is a permittee, CEQA independently requires the EIR to analyze the Project's reasonably foreseeable physical effects on the sensitive biological resources of the adjacent reserve. (CEQA Guidelines, §§ 15126.2, subd. (a), 15358, subd. (a)(2); Appendix G, § IV [substantial adverse effect on special-status species "directly or through habitat modifications" and on sensitive natural communities; interference with wildlife movement and nursery sites].) A determination that a possible significant effect need not be analyzed must rest on a brief statement of reasons supported by substantial evidence. (Pub. Resources Code,§ 21100, subd. (c); CEQA Guidelines,§§ 15128, 15384.) The stated reason - that the City is not a plan participant - addresses the City's permitting obligations, not the Project's physical effects on the reserve, and therefore does not satisfy CEQA.
Response A8-7
The comment disagrees with the Draft EIR’s conclusion that consistency with the PCCP, HCP/NCCP, and County Aquatic Resources Program need not be discussed further because the project site is not within the PCCP plan area and the City is not a PCCP participant. The comment states that CEQA independently requires analysis of the project’s reasonably foreseeable physical effects on adjacent reserve lands and their biological resources.
The statement on page 3.5-22 of the Draft EIR that consistency with the PCCP and HCP/NCCP is not discussed further reflects that the project is not located within the PCCP plan area, the City is not a PCCP permittee, and the project is not subject to PCCP permitting requirements or consistency determinations. As discussed in the responses to comments regarding the PCCP and adjacent reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), however, the Draft EIR does not rely on that fact to avoid analyzing biological impacts. Rather, the Draft EIR evaluates the project's potential direct and indirect impacts on biological resources
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Roseville Environmental Utilities Operations Center Project Final EIR 2-63 pursuant to CEQA, including special-status species, sensitive habitats, wildlife movement, lighting, noise, human disturbance, hydrology, and other relevant impact mechanisms. The analysis considers biological resources in the project vicinity, including those associated with adjacent lands, regardless of ownership or conservation status. The City therefore does not concur with the comment that the Draft EIR fails to evaluate reasonably foreseeable indirect effects on adjacent biological resources. For the reasons discussed in the responses to the preceding PCCP-related comments, the Draft EIR contains an adequate analysis of the project's potential physical impacts on biological resources consistent with CEQA. Accordingly, no changes to the Draft EIR are required.
Comment A8-8
Ill. Adjacency to Plan Area A Does Not Establish Compatibility with the HCP/NCCP - the Project Abuts Reserve Acquisition Area, Not Growth Area
The Draft EIR observes that the Project site "is immediately adjacent to Plan Area A" of the HCP/NCCP. (DEIR,§ 3.5.1, p. 3.5-6.) The Authority agrees that the Project site is adjacent to, but not within, Plan Area A. The point we wish to make is that adjacency to Plan Area A says nothing, by itself, about whether the Project is compatible with the conservation lands it abuts.
Plan Area A is the portion of the HCP/NCCP where future growth and most covered activities are anticipated, but it is not uniformly a development area. Plan Area A contains two fundamentally different kinds of land designation under the HCP/NCCP: Potential Future Growth ("PFG"), where the HCP/NCCP anticipates that development will occur; and Reserve Acquisition Areas ("RAA"), where the HCP/NCCP instead anticipates that land will be conserved and incorporated into the reserve system. The Plan's conservation strategy uses fees generated by development in the PFG areas to acquire and protect land in the RAA. Whether a project is compatible with the Plan therefore depends not on its general proximity to Plan Area A, but on whether it abuts PFG land or RAA land.
Here, the land adjacent to the Project is Reserve Acquisition Area, not Potential Future Growth area. The Draft ElR's own analysis confirms this: it identifies Mourier West as "the nearest PCCP Reserve Acquisition Area," roughly 930 feet to the north. (DEIR, § 3.5.3, p. 3.5-22.) The Mourier West and Clemetson properties are reserve-acquisition lands the Authority has secured for conservation - the Plan does not contemplate their development; it contemplates their permanent protection and restoration. That the adjacent Plan land is reserve-acquisition land slated for conservation heightens, rather than relieves, the City's obligation to analyze and minimize the Project's urban-edge effects on it.
Response A8-8
The comment states that the project's adjacency to PCCP Plan Area A does not demonstrate compatibility with the HCP/NCCP because the lands adjacent to the Project are Reserve Acquisition Areas intended for conservation rather than Potential Future Growth areas intended for development. The comment also states that the project's proximity to conservation lands increases the need to analyze and minimize potential urban-edge effects on those lands.
As discussed in the responses to the preceding comments regarding the PCCP, adjacent reserve lands, and HCP/NCCP consistency (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR recognizes the project’s proximity to PCCP lands but also correctly notes that the project site is not located within the PCCP plan area and is not subject to PCCP’s permit requirements, conservation strategy, or mitigation framework. Accordingly, the project would not conflict with the provisions of an applicable adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan because it is not subject to those plans. However, the Draft EIR evaluates the project’s potential physical effects on biological resources. Consistent with CEQA, the Draft EIR’s evaluation of biological resources is based on the project's potential physical effects on environmental resources, including direct and indirect impacts to special-status species, sensitive habitats, wildlife movement, lighting, noise, human disturbance, hydrology, and other relevant impact mechanisms.
As described in response to comment A3-7, although the project is not required to comply with the PCCP’s Development Interface Design Requirements, the City has decided to incorporate applicable Development Interface Design Requirements identified in PCCP Section 6.3.1.2.1 into the final project design as a voluntary measure to further minimize potential indirect effects on adjacent reserve lands (this portion of the PCCP is appended to this
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2-64 Roseville Environmental Utilities Operations Center Project Final EIR Final EIR as Appendix A). These measures will supplement the mitigation measures already identified in the Draft EIR and will help reduce the potential for edge effects such as wildlife disturbance, lighting impacts, unauthorized access, invasive species introduction, and other indirect effects on adjacent biological resources. With incorporation of these design measures and implementation of the mitigation measures identified in the Draft EIR (as revised in the Final EIR), the project’s potential indirect impacts on adjacent biological resources would be avoided or minimized.
The character of adjacent lands is relevant to understanding the environmental setting. However, for the reasons discussed in the responses above, the Draft EIR evaluates the potential effects of the project on adjacent biological resources regardless of whether neighboring lands are designated for conservation, agriculture, or other uses. The comment does not provide substantial evidence demonstrating that adjacency to PCCP Reserve Acquisition Areas would result in significant impacts beyond those evaluated in the Draft EIR or require additional mitigation measures.
Accordingly, the Draft EIR adequately addresses the project's potential effects on adjacent biological resources consistent with CEQA, and no changes to the Draft EIR are required.
Comment A8-9
IV. Clemetson and Mourier West Are Protected Wildlife Habitat in a Regional Reserve System It bears emphasis, because the Draft EIR overlooks it, that the Clemetson and Mourier West properties are part of a permitted, regional habitat reserve assembled under the HCP/NCCP and managed in perpetuity for the conservation of covered species and natural communities. They are not only farmland. They anchor an approximately 4,116-acre block of conservation lands designed to link the Pleasant Grove Creek corridor with surrounding reserves and to sustain nesting and foraging habitat for Swainson's hawk, tricolored blackbird, burrowing owl, and other listed species, and Mourier West and Clemetson support protected vernal pool species, including vernal pool fairy shrimp.
Their conservation value depends on protection from the very edge effects adjacent urbanization introduces - altered hydrology and drainage, artificial night lighting, elevated noise, human and pet intrusion, trash and predator subsidies, and colonization by invasive plants and animals.
The Draft EIR's omission is especially consequential because the Pleasant Grove Creek corridor between the Project and Mourier West is not merely an existing resource to be protected; under the goals and objectives of the PCCP, that stream corridor and its floodplain are planned to be restored and enhanced with shaded riverine and riparian habitat to improve water quality, temperature, turbidity, and other benefits to covered species. In addition, both Clemetson and Mourier West are likely locations for the creation or restoration of vernal pool grasslands, another key goal of the PCCP. Project edge effects could undermine not only existing habitat values but also this planned restoration. The Final EIR should describe these properties accurately as protected reserve lands and analyze the Project's effects on their habitat values and planned enhancement, rather than folding them into a generic category of surrounding "agricultural land."
Response A8-9
The comment states that the Clemetson and Mourier West properties are protected conservation lands within the PCCP reserve system that provide habitat for covered species and support broader conservation and restoration objectives. The comment also states that the Draft EIR does not adequately recognize the conservation status of these properties or evaluate the project's potential indirect effects on their existing and planned habitat values.
As discussed in the responses to the preceding comments regarding the PCCP, adjacent reserve lands, and indirect effects (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project's potential direct and indirect impacts on biological resources that could occur in the project vicinity, including impacts related to habitat disturbance, hydrology, lighting, noise, wildlife movement, invasive species, and human activity. The significance determinations are based on the potential effects of the project on environmental resources rather than on the ownership, management, or conservation status of adjacent properties.
The City recognizes the conservation value of the Clemetson and Mourier West properties. However, the comment does not provide substantial evidence demonstrating that the project would result in significant impacts to those properties or their conservation objectives beyond the impacts already analyzed in the Draft EIR. For the reasons
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Roseville Environmental Utilities Operations Center Project Final EIR 2-65 discussed in the responses above, the Draft EIR adequately evaluates the project's potential effects on adjacent biological resources and habitat values consistent with CEQA. Accordingly, no changes to the Draft EIR are required.
Comment A8-10
V. The Fencing Proposed in the Draft EIR Has Not Been Shown to Be Adequate to Protect Reserve Habitat The Draft EIR describes perimeter fencing as "a six-foot-tall chain-link fence, or equivalent," with optional screening, installed principally "[t]o minimize trespassing into Pleasant Grove Creek" and to "help maintain potential debris within the project site." (DEIR, §§ 2.4.5, p. 2-19, 3.5, p. 3.5-26.) This fencing is described as a security and littercontainment feature oriented toward the creek; the Draft EIR does not analyze whether it would minimize habitat impacts to the Clemetson (west) or Mourier West (north) reserve lands. Standard chain-link security fencing is not designed to address light spillover, noise, drainage, or the movement of invasive species or nuisance predators into adjacent habitat, and it may itself impede the movement of small reserve-dependent wildlife if not appropriately designed.
On the present record, the Authority cannot conclude that the proposed fencing would adequately protect habitat on Clemetson and Mourier West, because the Draft EIR does not assess it for that purpose. The Authority therefore requests that the Final EIR (i) expressly evaluate the adequacy of any proposed fencing as a measure to minimize impacts to the adjacent reserve lands, and (ii) commit to fencing along the northern and western reserve interfaces that is designed for habitat protection - for example, wildlife-appropriate fencing that deters human and domesticanimal intrusion and contains debris while still permitting necessary movement of small native wildlife - with the specific design developed in coordination with the Authority.
Response A8-10
The comment questions whether the perimeter fencing described in the Draft EIR would adequately protect adjacent PCCP reserve lands and recommends evaluating the fencing's effectiveness at minimizing impacts to the Clemetson and Mourier West properties. The comment further recommends habitat-oriented fencing along the northern and western project boundaries and coordination with PCA regarding fencing design.
As discussed in the responses to the preceding comments regarding adjacent PCCP reserve lands and indirect effects (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project's potential direct and indirect impacts on biological resources and identifies measures to reduce impacts associated with habitat disturbance, trespass, debris, lighting, noise, and other potential edge effects.
purpose of these features includes site security, access control, and reduction of unauthorized access to adjacent areas. This kind of access control fencing is required by solid waste regulations for the solid waste facility elements, but is not intended to be applied blanketly around the outermost perimeter of the entire project site if more suitable fencing is warranted.
The comment recommends that fencing along the northern and western project boundaries be evaluated from the perspective of habitat protection and compatibility with adjacent conservation lands. The Draft EIR already includes measures intended to reduce indirect effects on adjacent biological resources, including, but not limited to, implementation of wildlife-friendly building design (Mitigation Measure 3.5-5); limitations on outdoor lighting and light spillover (Mitigation Measures 3.1-2 and 3.5-5); avoidance and minimization measures for special-status species and nesting birds (Mitigation Measures 3.5-1 and 3.5-2a through 3.5-2j); and other mitigation measures designed to protect adjacent environmental resources (Mitigation Measures 3.5-3, 3.5-4a, 3.5-4b, and 3.5-6). Perimeter fencing is one component of this broader impact avoidance and minimization strategy because it would help separate project operations from adjacent reserve properties. By limiting access from the project site to adjacent reserve properties, fencing would reduce the potential for project employees, visitors, vehicles, and equipment to enter and disturb sensitive habitats and wildlife on nearby reserve properties. Fencing would also limit the movement of some wildlife from adjacent reserve properties onto the project site, thereby reducing the potential for wildlife exposure to projectrelated hazards, including vehicle traffic, equipment operations, and other human activities. Perimeter fencing would
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City of Roseville
2-66 Roseville Environmental Utilities Operations Center Project Final EIR provide an additional layer of protection beyond the mitigation measures identified in the Draft EIR by helping to reduce indirect effects on adjacent biological resources.
For the reasons discussed in the responses cited above, the Draft EIR adequately evaluates the project's potential impacts on adjacent biological resources. Accordingly, no additional changes to the Draft EIR are required, except as may be incorporated through project refinements.
See also responses to comments A3-7 and A8-12 through A8-16 regarding the City’s commitment to incorporate applicable PCCP Development Interface Design Requirements and continue coordination with PCA regarding development interface measures intended to minimize potential impacts on adjacent reserve properties.
Comment A8-11
VI. The Lighting Standards Proposed in the Draft EIR Have Not Been Shown to Be Adequate to Protect Reserve Habitat
The Draft EIR's lighting measures - Mitigation Measure 3.1-2 (full-cutoff, U0-lens fixtures, height limits, non-reflective surfaces) and Mitigation Measure 3.5-5 (wildlife-friendly building design; screening of light "directed perpendicular to Pleasant Grove Creek"; minimizing "light spillage from the project during operation into Pleasant Grove Creek") - are directed at human nighttime views, skyglow, and the riparian corridor to the north. (DEIR, §§ 3.1, 3.5.) The Draft EIR does not analyze whether these standards would minimize light-related impacts to the reserve habitat on Clemetson (west) or Mourier West (north). General Plan Policy LU7.9 (avoiding spill-over lighting onto "adjacent properties") is invoked, but the Draft EIR does not apply it to the reserve lands or evaluate its sufficiency for protecting habitat values. Notably, the City has already concluded that the Project's cumulative light-and-glare impact is significant and unavoidable - which only underscores the need to analyze, and minimize, lighting effects at the reserve interfaces.
Artificial lighting is a well-recognized edge effect that alters the behavior of nocturnal and crepuscular wildlife, disrupts movement and foraging, and degrades habitat quality at distances comparable to the roughly 930 feet between the development area and Mourier West. Because the Draft EIR does not assess its lighting standards against the habitat values of the adjacent reserve, the Authority cannot conclude that those standards are adequate.
The Authority requests that the Final EIR evaluate the adequacy of the proposed lighting standards and guidelines as measures to minimize impacts to Clemetson and Mourier West, and that the Project's lighting be designed, placed, and operated to minimize spillover toward those reserve lands - including full shielding and downward direction of fixtures along the northern and western boundaries, the lowest feasible mounting heights and lumen levels at those edges, warmer color temperatures (e.g., 2700K or lower), and controls (timers, motion sensors, and curfews) that limit nighttime illumination to what safety and operations actually require.
Response A8-11
The comment states that the Draft EIR's lighting measures are focused on reducing impacts to Pleasant Grove Creek and human nighttime views, and that the Draft EIR does not adequately evaluate whether the proposed lighting standards would minimize light-related effects on the adjacent Clemetson and Mourier West reserve lands. The comment recommends evaluating lighting impacts at the reserve interfaces and incorporating additional measures to minimize light spillover onto adjacent habitat areas.
Specifically, Mitigation Measure 3.5-5 in the Draft EIR requires implementation of wildlife-friendly building design principles, screening of construction lighting and vehicle headlights along the northern portion of the site, and operational lighting controls that require outdoor lighting to be shielded, directed only where illumination is needed, and limited to the minimum wattage necessary. In addition, Mitigation Measure 3.1-2 requires use of full-cutoff fixtures with U0 lenses, placement of lighting to avoid light spillover and glare on adjacent properties, limitations on pole heights, and use of nonreflective building materials. Collectively, these measures are intended to minimize offsite light trespass and reduce the potential for indirect effects on adjacent sensitive habitats and wildlife resources, including habitats located north and west of the project site.
The identified lighting standards would apply to project lighting generally and are intended to minimize light spillover, glare, and skyglow throughout the project area. Full-cutoff fixtures with U0 lenses emit no light above the horizontal plane, while shielding requirements, limitations on fixture heights, and minimum necessary wattage
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Roseville Environmental Utilities Operations Center Project Final EIR 2-67 requirements further reduce the potential for light trespass onto adjacent properties and habitat areas. These measures are consistent with the types of lighting controls identified by the comment, including shielding, directional lighting, minimizing light intensity, and limiting unnecessary nighttime illumination.
In addition, although a site-specific lighting plan has not been prepared yet, the Draft EIR evaluates the project’s reasonably foreseeable lighting impacts and identifies mitigation measures that would guide future lighting design.
The incorporation of wildlife-friendly building design principles and applicable PCCP Development Interface Design Requirements would further minimize the potential for lighting-related effects on adjacent reserve lands. Existing mature riparian vegetation along Pleasant Grove Creek would also provide substantial visual screening between the project and adjacent habitat areas.
For the reasons discussed in the responses above, the Draft EIR adequately evaluates the project’s potential lightingrelated impacts on biological resources. Accordingly, no additional changes to the Draft EIR are required, except as may be incorporated by the City through project refinements.
See also responses to comments A3-7 and A8-12 through A8-16 regarding the City’s commitment to incorporate applicable PCCP Development Interface Design Requirements and continue coordination with PCA regarding development interface measures intended to minimize potential impacts on adjacent reserve properties.
Comment A8-12
VII. Recommended Measures to Avoid and Minimize Impacts to the Reserve System CEQA requires that significant effects be avoided or substantially lessened through feasible, enforceable mitigation. (Pub. Resources Code,§ 21002; CEQA Guidelines, §§ 15126.4, subd. (a), 15370.) The Authority respectfully urges the City to incorporate the following measures into the Project description and the Final EIR's mitigation program:
1. On-site setbacks. Establish meaningful, enforceable setbacks along the northern (Mourier West) and western (Clemetson) Project boundaries that distance buildings, lighting, paving, traffic, staging, and operations from the reserve lands, and that provide a vegetated buffer to attenuate noise, light, and human intrusion. The Draft EIR's existing setbacks are oriented to Phillip Road and Pleasant Grove Creek and do not buffer the western reserve interface.
Response A8-12
The comment recommends incorporating additional measures to avoid and minimize potential impacts on adjacent PCCP reserve lands, including establishment of meaningful setbacks and vegetated buffers along the northern and western project boundaries to separate project facilities and activities from nearby conservation lands and reduce potential edge effects.
In July 2026, City and PCA staff met to discuss PCA’s concerns regarding potential edge effects on the adjacent reserve properties. The City committed to continuing coordination with PCA as project design progresses to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Such measures may include setbacks, fencing and other barriers, buffers, lighting design, drainage features, landscaping, site layout, and other measures intended to reduce potential edge effects and protect biological resources.
Comment A8-13
2. Habitat-protective fencing. Provide fencing along the reserve interfaces specifically designed to deter human and domestic-animal entry into the reserve, contain trash and debris, and avoid impeding the movement of small native wildlife, with design and placement coordinated with the Authority.
Response A8-13
The comment recommends installation of habitat-protective fencing along the boundaries adjacent to PCCP reserve lands to discourage human and domestic-animal intrusion, contain trash and debris, facilitate movement of small native wildlife, and be designed in coordination with PCA.
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City of Roseville
2-68 Roseville Environmental Utilities Operations Center Project Final EIR As described in response to comment A8-12, the City committed to continuing coordination with PCA as project design progresses to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Such measures may include setbacks, fencing and other barriers, buffers, lighting design, drainage features, landscaping, site layout, and other measures intended to reduce potential edge effects and protect biological resources.
Comment A8-14
3. Lighting design, placement, and use. Design, locate, and operate Project lighting to minimize spillover and skyglow toward the reserve - fully shielded, downward-directed, full-cutoff fixtures; minimized mounting heights and lumen output along the northern and western edges; warm color temperatures; and timers, motion sensors, and operational curfews to limit unnecessary nighttime illumination.
Response A8-14
The comment recommends that project lighting be designed, located, and operated to minimize light spillover and skyglow onto adjacent PCCP reserve lands, including use of fully shielded, downward-directed fixtures, lower mounting heights and light levels near reserve boundaries, warmer color temperatures, and lighting controls such as timers, motion sensors, and curfews.
As described in response to comment A8-12, the City committed to continuing coordination with PCA as project design progresses to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Such measures may include setbacks, fencing and other barriers, buffers, lighting design, drainage features, landscaping, site layout, and other measures intended to reduce potential edge effects and protect biological resources.
Also, in response to other comments, Mitigation Measure 3.5-5 has been expanded to also apply to the nearby reserve properties to minimize lighting impacts. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
Comment A8-15
4. Drainage, invasive species, and nuisance-wildlife controls. Ensure that altered surface and storm drainage does not discharge toward or alter the hydrology of the reserve lands or the Pleasant Grove Creek corridor planned for restoration; require locally appropriate, non-invasive landscaping and an invasive-species management commitment along the interface; and extend nuisance-wildlife and refuse-management practices to protect the reserve, not only the creek.
Response A8-15
The comment recommends measures to protect adjacent PCCP reserve lands by ensuring project drainage does not adversely affect reserve lands or the Pleasant Grove Creek corridor, implementing non-invasive landscaping and invasive species management practices along the project boundary, and extending refuse management and nuisance wildlife control measures to minimize impacts on adjacent conservation areas.
As described in response to comment A8-12, the City committed to continuing coordination with PCA as project design progresses to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Such measures may include setbacks, fencing and other barriers, buffers, lighting design, drainage features, landscaping, site layout, and other measures intended to reduce potential edge effects and protect biological resources.
Also, in response to other comments, Mitigation Measure 3.5-4b has been revised to include a requirement for the City to prepare a hydrologic study to characterize existing site hydrology and ensure that project implementation and operation would not result in a substantial change to off-site hydrologic conditions. See Chapter 3, “Revisions to the Draft EIR,” of this Final EIR for the text changes.
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Roseville Environmental Utilities Operations Center Project Final EIR 2-69 Comment A8-16
VIII. Request That the City Consult HCP/NCCP Section 6.3.1.2 for Guidance Although the Project is not subject to the requirements of the HCP/NCCP, Section 6.3.1.2 of the Plan - the Development Interface Design Requirements - was developed precisely to address the situation presented here:
development located next to HCP/NCCP reserve-system land. That section sets out measures intended to minimize the effects of adjacent development on reserve lands, including the kinds of interface controls discussed above - setbacks and buffers, drainage and water-quality management, lighting design to limit spillover, fencing, noise attenuation, invasive-species and landscaping controls, and limits on human access. The Authority respectfully requests that the City review Section 6.3.1.2 and use it as a template and a source of substantial evidence for designing and evaluating measures to protect Clemetson and Mourier West, even though compliance is not mandatory for this Project. Doing so will strengthen both the Project design and the adequacy of the Final El R's analysis.
Response A8-16
The comment recommends that the City review and consider the HCP/NCCP Development Interface Design Requirements (Section 6.3.1.2) as guidance for addressing potential interface effects between the project and adjacent PCCP reserve lands, even though the project is not subject to the HCP/NCCP.
The City recognizes that Section 6.3.1.2 of the HCP/NCCP contains guidance intended to address potential edge effects associated with development adjacent to conservation lands. As discussed in response to comment A3-7, although the project is not required to comply with the PCCP’s Development Interface Design Requirements, the City has decided to incorporate applicable Development Interface Design Requirements identified in PCCP Section
6.3.1.2.1 into the final project design as a voluntary measure to further minimize potential indirect effects on adjacent reserve lands.
As discussed throughout the responses to comments regarding adjacent PCCP reserve lands (see responses to comments A3-5 through A3-7 and responses in this comment letter), the Draft EIR evaluates the project’s potential direct and indirect impacts on biological resources and includes measures to reduce impacts associated with lighting, habitat disturbance, human intrusion, stormwater management, wildlife movement, and other environmental considerations. The comment does not identify a deficiency in the CEQA analysis or demonstrate that incorporation of the HCP/NCCP interface standards is required to support the Draft EIR's conclusions. Accordingly, no changes to the Draft EIR are required.
Comment A8-17
IX. Offer to Collaborate
The Authority raises these concerns in a spirit of cooperation. We share the City's interest in a welldesigned Project, and we are confident that the impacts identified above can be avoided or substantially minimized through the measures described. The Authority's staff would welcome the opportunity to meet with the City and the Project team - promptly, and before the Final EIR is prepared - to discuss appropriate setbacks, fencing, lighting, drainage, and interface measures; to share reserve-management information and the goals of the Mourier West and Clemetson acquisitions and the planned Pleasant Grove Creek corridor enhancement; and to assist the City in applying the guidance in Section 6.3.1.2. We stand ready to provide whatever information would be helpful.
Response A8-17
The comment recommends coordination with PCA regarding project design features adjacent to PCCP reserve lands, including setbacks, fencing, lighting, drainage, and other interface measures. The comment also offers to share information regarding reserve management and conservation objectives for the Clemetson and Mourier West properties.
The City appreciates PCA’s continued participation in the environmental review process and its offer to provide information regarding adjacent conservation lands and management objectives. As described in response to comment A8-12, the City has committed to continuing coordination with PCA as project design progresses to
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2-70 Roseville Environmental Utilities Operations Center Project Final EIR evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. The comment does not identify a deficiency in the environmental analysis or require revisions to the Draft EIR. Therefore, no changes to the Draft EIR are required.
Comment A8-18
X. Conclusion
For the reasons stated, the Authority respectfully requests that the City revise the environmental analysis to (1) accurately describe Clemetson and Mourier West as protected reserve lands within a regional conservation block; (2) analyze, on substantial evidence, the Project's direct and indirect effects on the habitat values of those lands - including effects from hydrology, lighting, noise, human intrusion, and invasive species, and effects on the planned Pleasant Grove Creek corridor enhancement and vernal pool restoration on Clemetson and Mourier West; (3) assess the adequacy of the proposed fencing and lighting standards as measures to protect those lands, or commit to doing so in the Final EIR; and (4) adopt feasible, enforceable measures - setbacks, habitat-protective fencing, and lighting design, placement, and use - to avoid and minimize those effects. Because these issues go to the adequacy of the EIR as an informational document, the City must provide a written response to each of these comments, and should recirculate the EIR if revisions add significant new information. (CEQA Guidelines, §§ 15088, subd. (c), 15151, 15088.5.) Thank you for your consideration of these comments. Please include the Authority in the distribution list for all future notices and documents concerning this Project, and please direct any questions to the undersigned.
Response A8-18
The comment requests that the City revise the analysis of adjacent PCCP reserve lands, evaluate potential direct and indirect effects on those lands, assess the adequacy of proposed fencing and lighting measures, adopt additional avoidance and minimization measures, provide written responses to comments, and recirculate the EIR if significant new information is added.
As discussed in responses to comments A3-5 through A3-7 and A8-2 through A8-17, the Draft EIR analyzes the project’s potential physical effects on adjacent biological resources, including resources located on nearby PCCP reserve properties, regardless of whether the project is subject to PCCP’s permit requirements, conservation strategy, or mitigation framework.
As discussed in the responses to comments A8-1 through A8-17, the City has carefully considered PCA’s concerns regarding the project's proximity to the Clemetson and Mourier West properties and the potential for indirect effects on adjacent biological resources. The City has evaluated the comments and recommendations regarding the environmental analysis, fencing, lighting, setbacks, drainage, and other interface measures.
As described in response to comment A8-12, the City committed to continuing coordination with PCA as project design progresses to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Such measures may include setbacks, fencing and other barriers, buffers, lighting design, drainage features, landscaping, site layout, and other measures intended to reduce potential edge effects and protect biological resources.
The Draft EIR adequately evaluates the project's potential impacts on biological resources, including potential indirect effects, consistent with CEQA. As described above, the City has committed to continuing coordination with PCA during project design to evaluate development interface measures and incorporate feasible design features that would minimize potential impacts on adjacent reserve properties. Any such project refinements would be considered during future project design. To the extent additional environmental review is required following certification of the EIR, the City would evaluate such refinements in accordance with CEQA Guidelines Sections 15162, 15163, and 15164.
These refinements would be intended to further reduce or avoid potential impacts and would not, in themselves, result in new or more severe environmental impacts than those analyzed in the Draft EIR. The City will provide written responses to comments as required by CEQA and will continue to provide notices and environmental documents in accordance with applicable CEQA requirements.
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City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 2-71 Accordingly, except for any project refinements that may be identified by the City, no additional revisions to the environmental analysis are required.
2.2.3 Companies
Letter C1 Pacific Gas & Electric
Plan Review Team, Land Management
May 12, 2026
Comment C1-1
Thank you for submitting the Roseville Environmental Utilities Operations Center project plans for our review. PG&E will review the submitted plans in relationship to any existing Gas and Electric facilities within the project area. If the proposed project is adjacent/or within PG&E owned property and/or easements, we will be working with you to ensure compatible uses and activities near our facilities.
Attached you will find information and requirements as it relates to Gas facilities (Attachment 1) and Electric facilities (Attachment 2). Please review these in detail, as it is critical to ensure your safety and to protect PG&E’s facilities and its existing rights.
Below is additional information for your review:
1. This plan review process does not replace the application process for PG&E gas or electric service your project may require. For these requests, please continue to work with PG&E Service Planning:
https://www.pge.com/en/account/service-requests/building-and-renovation.html.
2. If the project being submitted is part of a larger project, please include the entire scope of your project, and not just a portion of it. PG&E’s facilities are to be incorporated within any CEQA document. PG&E needs to verify that the CEQA document will identify any required future PG&E services.
3. An engineering deposit may be required to review plans for a project depending on the size, scope, and location of the project and as it relates to any rearrangement or new installation of PG&E facilities.
Any proposed uses within the PG&E fee strip and/or easement, may include a California Public Utility Commission (CPUC) Section 851 filing. This requires the CPUC to render approval for a conveyance of rights for specific uses on PG&E’s fee strip or easement. PG&E will advise if the necessity to incorporate a CPUC Section 851filing is required.
This letter does not constitute PG&E’s consent to use any portion of its easement for any purpose not previously conveyed. PG&E will provide a project specific response as required.
Response C1-1
The comment states that PG&E reviewed the submitted project plans for potential conflicts with existing gas and electric facilities and will coordinate with the City to ensure compatible uses near its infrastructure and within any easements. The comment further states that the City should review the attached gas and electric facility requirements, continue separate service application processes, and include the full project scope and PG&E infrastructure in CEQA documentation. Because no specific issues related to the content, analysis, or conclusions in the Draft EIR are raised in this comment, no further response is provided here.
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2-72 Roseville Environmental Utilities Operations Center Project Final EIR This page is intentionally left blank.
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-1 3 REVISIONS TO THE DRAFT EIR
This chapter presents specific text changes made to the Draft EIR since its publication and public review. The changes are presented in the order in which they appear in the original Draft EIR and are identified by the Draft EIR page number.
The information contained within this chapter clarifies and expands on information in the Draft EIR and does not constitute “significant new information” requiring recirculation. (See Public Resources Code Section 21092.1; CEQA Guidelines Section 15088.5.)
3.1 REVISIONS TO THE EXECUTIVE SUMMARY
In response to comments A3-3 and A3-4, and to provide an update to reflect the potential for occurrence of western burrowing owl, a new mitigation measure is added to Table ES-2 on page ES-10 of the Draft EIR as follows:
Original:
Table ES-2 Summary of Impacts and Mitigation Measures
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Biological Resources
Impact 3.5-2: Result in Disturbance to or Loss
of Special-Status Wildlife Species and Habitat
Phase 1: PS
Phase 2: PS
Mitigation Measure 3.5-2a: Conduct Preconstruction
Surveys for Northwestern Pond Turtle, Implement
Avoidance Measures, and Relocate Individuals
Mitigation Measure 3.5-2b: Provide Stream Setbacks,
Best Management Practices
Mitigation Measure 3.5-2c: Develop and Integrate a
Nuisance Wildlife Management Plan into the City’s
Environmental Utilities Facility Management Plan
Mitigation Measure 3.5-2d: Conduct Preconstruction
Surveys for Western Spadefoot, Implement Avoidance
Measures, and Relocate Individuals (Phase 1 only)
Mitigation Measure 3.5-2e: Conduct Pre-construction
Vernal Pool Avoidance Surveys, Protocol-Level
Branchiopod Surveys, and Compensate for Loss of Vernal
Pool Branchiopods (Phase 1 only)
Mitigation Measure 3.5-2f: Conduct Take Avoidance
Surveys for Crotch’s Bumble Bee and Implement
Avoidance Measures
Mitigation Measure 3.5-2g: Conduct Take Avoidance
Survey for Monarch Eggs, Larvae and Pupae, and
Implement Avoidance Measures
Mitigation Measure 3.5-2h: Conduct Focused Surveys for
Special-Status Birds, Nesting Raptors, and Other Native Nesting Birds and Implement Protective Buffers; and
Mitigate for the Loss of Swainson’s Hawk Foraging
Habitat
Mitigation Measure 3.5-2i: Conduct Focused Surveys for
Northern California Ringtail Dens and Implement
Avoidance Measures
Mitigation Measure 3.5-2j: Conduct Focused Bat Surveys
and Implement Avoidance Measures
Phase 1: LTS
Phase 2: LTS
Revisions to the Draft EIR Ascent
City of Roseville
3-2 Roseville Environmental Utilities Operations Center Project Final EIR Revised:
Table ES-2 Summary of Impacts and Mitigation Measures
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Biological Resources
Impact 3.5-2: Result in Disturbance to or Loss
of Special-Status Wildlife Species and Habitat
Phase 1: PS
Phase 2: PS
Mitigation Measure 3.5-2a: Conduct Preconstruction
Surveys for Northwestern Pond Turtle, Implement
Avoidance Measures, and Relocate Individuals
Mitigation Measure 3.5-2b: Provide Stream Setbacks,
Best Management Practices
Mitigation Measure 3.5-2c: Develop and Integrate a
Nuisance Wildlife Management Plan into the City’s
Environmental Utilities Facility Management Plan
Mitigation Measure 3.5-2d: Conduct Preconstruction
Surveys for Western Spadefoot, Implement Avoidance
Measures, and Relocate Individuals (Phase 1 only)
Mitigation Measure 3.5-2e: Conduct Pre-construction
Vernal Pool Avoidance Surveys, Protocol-Level
Branchiopod Surveys, and Compensate for Loss of Vernal
Pool Branchiopods (Phase 1 only)
Mitigation Measure 3.5-2f: Conduct Take Avoidance
Surveys for Crotch’s Bumble Bee and Implement
Avoidance Measures
Mitigation Measure 3.5-2g: Conduct Take Avoidance
Survey for Monarch Eggs, Larvae and Pupae, and
Implement Avoidance Measures
Mitigation Measure 3.5-2h: Conduct Focused Surveys for
Special-Status Birds, Nesting Raptors, and Other Native Nesting Birds and Implement Protective Buffers; and
Mitigate for the Loss of Swainson’s Hawk Foraging
Habitat
Mitigation Measure 3.5-2i: Conduct Focused Surveys for
Northern California Ringtail Dens and Implement
Avoidance Measures
Mitigation Measure 3.5-2j: Conduct Focused Bat Surveys
and Implement Avoidance Measures
Mitigation Measure 3.5-2k: Conduct Preconstruction
Surveys for Western Burrowing Owl and Implement
Avoidance Measures
Phase 1: LTS
Phase 2: LTS
3.2 REVISIONS TO CHAPTER 2, “PROJECT DESCRIPTION”
In response to comment A5-11 and to describe the anticipated origin of the biomass, the description of the potential future biomass facility on page 2-18 of the Draft EIR is revised as follows:
Original:
POTENTIAL FUTURE BIOMASS FACILITY
Another potential future strategy for managing organic wastes is the development of a Biomass Facility. The Biomass Facility would be evaluated by the City on its financial, environmental, and regulatory merits and, if determined to be in the best interest of the City, would be developed at a later time. Its purpose would be to convert biomass (woody material) into energy using thermal means. The specific type of device has yet to be
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-3 selected but for the purposes of this analysis, it is assumed that the biomass facility would handle organic (i.e., food and agricultural) as well as yard-trimming waste. In the event that a biomass facility is proposed at a later date, additional subsequent environmental analysis may be necessary. The potential future Biomass Facility would be co-located in the same area as the potential future Compost Facility.
Revised:
POTENTIAL FUTURE BIOMASS FACILITY
Another potential future strategy for managing organic wastes is the development of a Biomass Facility. The Biomass Facility would be evaluated by the City on its financial, environmental, and regulatory merits and, if determined to be in the best interest of the City, would be developed at a later time. Its purpose would be to convert biomass (woody material) into energy using thermal means. The specific type of device has yet to be selected but for the purposes of this analysis, it is assumed that the biomass facility would handle organic (i.e., food and agricultural) as well as yard-trimming waste. For purposes of this Draft EIR, the biomass feedstock is assumed to consist primarily of locally generated green waste (yard waste) collected from City residents and commercial customers within the City’s service area. Accordingly, biomass feedstock is not expected to originate from distant agricultural or forestry operations.
In the event that a biomass facility is proposed at a later date, additional subsequent environmental analysis may be necessary. The potential future Biomass Facility would be co-located in the same area as the potential future Compost Facility.
In response to comment A4-7 and to acknowledge the potential need for County-issued permits and approvals for activities occurring within County jurisdiction or with the potential to directly or indirectly affect County assets or customers, the list of potential permits and approvals required for the project on page 2-26 of the Draft EIR is revised as follows:
Original:
▶ Placer County: Integrated Waste Management Plan
▪ To comply with the Non-Disposal Facility Element, the facility must be added to the County’s Integrated Waste Management Plan to confirm it is not a disposal facility.
Revised:
▶ Placer County: To the extent project improvements, utility work, construction access, or other activities occur within Placer County jurisdiction or with the potential to directly or indirectly affect County assets or customers, the City would be required to obtain all applicable permits and approvals from Placer County, which may include encroachment permits, improvement plan review and approval, or other permits as determined appropriate by the County; and revisions to the County’s Integrated Waste Management Plan
▪ To comply with the Non-Disposal Facility Element, the facility must be added to the County’s Integrated Waste Management Plan to confirm it is not a disposal facility.
3.3 REVISIONS TO SECTION 3.3, “AIR QUALITY”
In response to comment A5-9, the bulleted list on pages 3.3-7 through 3.3-8 is revised as follows to add the following new bullets:
Revised:
▶ PCAPCD Rule 214 Transfer of Gasoline into Stationary Storage Containers: The provisions of this rule shall apply to the transfer of gasoline from any stationary storage tank into any motor vehicle fuel tank.
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3-4 Roseville Environmental Utilities Operations Center Project Final EIR ▶ PCAPCD Rule 501, General Permit Requirements: To provide an orderly procedure for the review of new stationary sources of air pollution and modification and operation of existing sources through the issuance of permits. Stationary sources which would emit more than 2 pounds in any 24 hour period of any pollutants would be subject to the District’s permit requirement. ▶ PCAPCD Rule 502, New Source Review: The purpose of this rule is to provide for the review of new and modified stationary sources of air pollution and to provide mechanisms, including emission offsets, to ensure that construction and operation of such sources do not interfere with the attainment or maintenance of air quality standards. The rule applies to all new stationary sources and emissions units and all modifications to existing stationary sources and emissions units that, after construction, emit or may emit any New Source Review regulated pollutant within the PCAPCD. The rule establishes requirements for preconstruction permitting, emission controls, and, where applicable, emissions offsets for qualifying sources.
▶ PCAPCD Rule 503, Emission Statement: The purpose of this rule is to establish the requirements for the submittal of emission statements from specified stationary sources pursuant to the requirements of the 1990 amendments to the Federal Clean Air Act [Section 182 (a)(3)(B)]. The requirements of this rule are applicable to every stationary source which has actual emissions or potential in excess of the 10 tons per year of volatile organic compounds (VOC) or oxides of nitrogen (NOx) within the PCAPCD. Those with emissions above specified thresholds are required to submit annual emission statements and operational information to the District for emissions inventory and air quality planning purposes. ▶ PCAPCD Rule 507, Federal Operating Permit Program: The purpose of this rule is to establish procedures and requirements for an operating permit system consistent with the requirements of Title V of the Federal Clean Air Act (CAA), as amended in 1990, and pursuant to 40 CFR Part 70. Rule 507 establishes procedures and requirements for obtaining and maintaining Title V operating permits for major stationary sources and other sources subject to federal operating permit requirements, ensuring compliance with applicable federal, state, and local air quality regulations.
In response to comment A5-10, the paragraph that breaks across pages 3.3-8 and 3.3-9 of the Draft EIR is revised as follows:
Original:
PCAPCD is located within the federally designated Sacramento Federal Ozone Nonattainment Area (SFNA) for air quality planning purposes. This is primarily because emissions generated within Placer County may affect the nearby Sacramento-Metropolitan Area. As a part of the SFNA, PCAPCD works with Sacramento Metropolitan Air Quality Management District (SMAQMD) and the other local air districts within the Sacramento area to develop a regional air quality management plan under CAA requirements. This management plan is called a SIP which describes and demonstrates how Placer County, as well as the Sacramento nonattainment area, would attain the required federal 8-hour ozone standard by the required attainment deadline. At a public meeting held on October 26, 2023, CARB voted to approve the Sacramento Regional 70 parts per billion (ppb) 8-Hour Ozone Attainment and Reasonable Further Progress Plan. The Sacramento Regional 70 ppb 8-Hour Ozone Attainment and Reasonable Further Progress Plan was prepared by the five local air districts of the SFNA, including PCAPCD, with the support of CARB. This plan is an Air Quality Attainment Plan (AQAP) that is applicable to development in the project area. One of the proposed mitigation strategies in the SIP is to recommend and implement mitigation measures through the review of land use projects at the local level (PCAPCD 2017). PCAPCD also adopted the 2014 Reasonably Available Control Technology (RACT) State Implementation Plan Analysis and Federal Negative Declarations for 16 Control Technique Source Categories. CARB submitted the 2014 RACT SIP to the EPA as a revision to the California SIP.
Revised:
PCAPCD is located within the federally designated Sacramento Federal Ozone Nonattainment Area (SFNA) for air quality planning purposes. This is primarily because emissions generated within Placer County may
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-5 affect the nearby Sacramento-Metropolitan Area. As a part of the SFNA, PCAPCD works with Sacramento Metropolitan Air Quality Management District (SMAQMD) and the other local air districts within the Sacramento area to develop a regional air quality management plan under CAA requirements. This management plan is called a SIP which describes and demonstrates how Placer County, as well as the Sacramento nonattainment area, would attain the required federal 8-hour ozone standard by the required attainment deadline. At a public meeting held on October 26, 2023, CARB voted to approve the Sacramento Regional 70 parts per billion (ppb) 8-Hour Ozone Attainment and Reasonable Further Progress Plan. The Sacramento Regional 70 ppb 8-Hour Ozone Attainment and Reasonable Further Progress Plan was prepared by the five local air districts of the SFNA, including PCAPCD, with the support of CARB. This plan is an Air Quality Attainment Plan (AQAP) that is applicable to development in the project area. One of the proposed mitigation strategies in the SIP is to recommend and implement mitigation measures through the review of land use projects at the local level (PCAPCD 2017). PCAPCD also adopted the 2020 Demonstration of Reasonably Available Control Technology for the 2015 Ozone NAAQS (RACT SIP). CARB submitted the 2020 RACT SIP to the EPA as a revision to the California SIP. The 2020 RACT SIP reexamines the RACT determinations made in the previous RACT SIP for the 2008 ozone standard in light of any new additional information and to satisfy planning requirements associated with the 2015 federal 8-hour ozone standard.
In response to comment A5-13, the discussion of Impact 3.3-1 on page 3.3-22 of the Draft EIR is revised as follows:
Original:
As discussed above in Section 3.3.1, “Regulatory Setting,” the SACOG MTP/SCS establishes a long-range development pattern that identifies the general location of different types of land uses, residential densities, and employment densities. The MTP/SCS addresses air quality by aligning transportation and land use planning with regional and State air quality goals. The SACOG 2025 MTP/SCS forecasts residential and employment growth throughout the City of Roseville and specifically identifies the area in which the project site is located as an established community projected for employment growth (SACOG 2026). The project does not include land use development that would result in population growth beyond what has already been anticipated and planned for, and, therefore, would not generate long-term emissions that would conflict with the applicable AQAP. Rather, the project would continue to serve the City’s existing population and waste generation (Phase 1) and would be designed to accommodate increased growth anticipated in the City of Roseville, which is planned for in the 2035 Roseville General Plan. Because the project would not result in employment growth beyond that projected in the regional plan, the project would not conflict with or obstruct the implementation of the air quality plan. In addition, as discussed above for Phase 1, the existing land use designation for the project site is P/AQP and the zoning is PD. Phase 2 and full operation (2058) of the project would be consistent with the land use designations and zoning established in the City General Plan. Because the City General Plan was developed to guide growth in a manner that minimizes air pollution and protects public health and is the basis for the regional emissions forecasts and reduction targets in the AQAP, consistency with land uses and growth in the General Plan would also be consistency with the AQAP; thus, a project that is consistent with the General Plan would not impede attainment of air quality standards.
Revised:
Operation of the Potential Future Organics Processing Facility and Potential Future Biomass Gasification Facility could require permits from PCAPCD, including potentially a federal Title V operating permit if facility emissions exceed applicable federal major source thresholds. A Title V permit does not authorize emissions beyond those evaluated in this EIR; rather, it establishes federally enforceable operating conditions, monitoring, recordkeeping, reporting, and compliance requirements to ensure that a source complies with all applicable air quality regulations. Any facility subject to Title V permitting would also remain subject to applicable PCAPCD permitting requirements, emissions limits, and air quality regulations. Accordingly, the potential need for Title V permits would not, by itself, indicate that the project would conflict with or obstruct implementation of the Sacramento 2015 Regional 8-Hour Ozone Attainment and Reasonable Further
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City of Roseville
3-6 Roseville Environmental Utilities Operations Center Project Final EIR Progress Plan. Instead, any such facility would be required to demonstrate compliance with applicable federal, state, and local air quality requirements through the permitting process.
As discussed above in Section 3.3.1, “Regulatory Setting,” the SACOG MTP/SCS establishes a long-range development pattern that identifies the general location of different types of land uses, residential densities, and employment densities. The MTP/SCS addresses air quality by aligning transportation and land use planning with regional and State air quality goals. The SACOG 2025 MTP/SCS forecasts residential and employment growth throughout the City of Roseville and specifically identifies the area in which the project site is located as an established community projected for employment growth (SACOG 2026). The project does not include land use development that would result in population growth beyond what has already been anticipated and planned for, and, therefore, would not generate long-term emissions that would conflict with the applicable AQAP. Rather, the project would continue to serve the City’s existing population and waste generation (Phase 1) and would be designed to accommodate increased growth anticipated in the City of Roseville, which is planned for in the 2035 Roseville General Plan. Because the project would not result in employment growth beyond that projected in the regional plan, the project would not conflict with or obstruct the implementation of the air quality plan. In addition, as discussed above for Phase 1, the existing land use designation for the project site is P/AQP and the zoning is PD. Phase 2 and full operation (2058) of the project would be consistent with the land use designations and zoning established in the City General Plan. Because the City General Plan was developed to guide growth in a manner that minimizes air pollution and protects public health and is the basis for the regional emissions forecasts and reduction targets in the AQAP, consistency with land uses and growth in the General Plan would also be consistency with the AQAP; thus, a project that is consistent with the General Plan would not impede attainment of air quality standards. Further, any stationary sources requiring PCAPCD permits or federal Title V permits would be subject to applicable emissions control, monitoring, and compliance requirements intended to support attainment and maintenance of applicable air quality standards.
In response to comment A5-4 and to correct a typographical error, the second paragraph on page 3.3-32 of the Draft EIR is revised as follows:
Original:
Operational activity was modeled in the HRA to determine the maximum future risk exposure associated with full operation of the project. Full operation would include the maximum anticipated waste throughput of 660,00 tpy of waste, including 210,000 tpy of organics. Based on the anticipated 2.5 MW potential future biomass facility and estimated capacity of 12,000 tons of biomass per 1 MW, 30,000 tpy of organic waste was assumed to be processed through the potential future biomass facility. In addition, to handle the waste, onsite diesel equipment would be required at the potential future composting site, on-site diesel material trucks would be used to deliver and transfer material, gasoline and diesel dispensing would occur at the on-site fueling station, maintenance of equipment could result in VOC off-gassing emissions, and various TAC emissions would be associated with the potential future composting and biomass gasification facility.
Revised:
Operational activity was modeled in the HRA to determine the maximum future risk exposure associated with full operation of the project. Full operation would include the maximum anticipated waste throughput of 660,000 tpy of waste, including 210,000 tpy of organics. Based on the anticipated 2.5 MW potential future biomass facility and estimated capacity of 12,000 tons of biomass per 1 MW, 30,000 tpy of organic waste was assumed to be processed through the potential future biomass facility. In addition, to handle the waste, onsite diesel equipment would be required at the potential future composting site, on-site diesel material trucks would be used to deliver and transfer material, gasoline and diesel dispensing would occur at the on-site fueling station, maintenance of equipment could result in VOC off-gassing emissions, and various TAC emissions would be associated with the potential future composting and biomass gasification facility.
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-7 In response to comment A5-5 and to correct a typographical error, the last paragraph on page 3.3-32 of the Draft EIR is revised as follows:
Original:
As shown in Figure 3.3-3, cancer risk results are concentrated closer to the onsite equipment (orange and yellow contours) with some cancer risk estimates also associated with primary access roads (dark green). The modeling assumes that 90 percent of traffic would move west from the site, while 10 percent heads east.
Refer to Appendix B for more details regarding modeling inputs.
Revised:
As shown in Figure 3.3-3, cancer risk results are concentrated closer to the onsite equipment (orange and yellow contours) with some cancer risk estimates also associated with primary access roads (dark green). The modeling assumes that 90 percent of traffic would move east from the site, while 10 percent heads west.
Refer to Appendix B for more details regarding modeling inputs.
In response to comment A5-19 and to add the Placer County Air Pollution Control District’s recommendations as examples of measures that may be incorporated into the Odor Reduction Plan, Mitigation Measure 3.3-5 beginning on page 3.3-39 of the Draft EIR is revised as follows:
Original:
Mitigation Measure 3.3-5: Implement Facility Odor Reduction Plan Prior to commencement of operations involving municipal green waste and food organics, the City shall prepare, implement, and maintain a comprehensive Odor Reduction Plan to minimize the potential for objectionable odors affecting existing and reasonably foreseeable future sensitive receptors. The Odor Reduction Plan shall apply to all odor-generating activities at the facility and shall be implemented for the life of the project. At a minimum, the Odor Reduction Plan shall include the following elements:
▶ Odor source identification and controls
The Odor Reduction Plan shall identify all odor-generating sources, and for each source, the Odor Reduction Plan shall specify operational and engineering controls designed to minimize odor generation and release. Odor sources include, but are not limited to:
▪ receiving, unloading, and sorting of organics within the organics building enclosure; and ▪ pre-processing and mixing of feedstocks.
Odor sources associated with Phase 2 of the project include, but are not limited to:
▪ covered aerated static pile (ASP) composting operations; ▪ curing, screening, and product handling; and
▪ management of leachate or contact water.
▶ Receiving and material recovery building requirements To address the highest odor potential activities, the Odor Reduction Plan shall require that:
▪ reception and sorting of organic waste occur within the building enclosure, with doors closed except during active vehicle ingress and egress;
▪ the organics building enclosure be operated to minimize odor emissions, including use of enclosures, ventilation, and odor control measures as applicable (e.g., negative pressure and treatment through a biofilter, scrubber, or equivalent system, if deemed necessary); ▪ onsite staging time for unprocessed food organics be limited to a defined maximum duration of time not beyond the time necessary to move to the next stage, with covered or contained storage; and
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3-8 Roseville Environmental Utilities Operations Center Project Final EIR ▪ putrescible residuals and screened contaminants be stored in covered containers and removed from the site on a regular schedule sufficient to prevent odor buildup. ▶ Covered aerated static pile operational controls
The Odor Reduction Plan shall include procedures to maintain aerobic conditions within covered ASP bays, including monitoring and management of aeration, moisture, and pile conditions. Corrective actions shall be identified for upset conditions (e.g., power outages, aeration system failures, excessive moisture, or indications of anaerobic conditions) to promptly reduce odor potential. ▶ Odor monitoring, complaints, and adaptive management
The Odor Reduction Plan shall include an odor monitoring and response program consisting of:
▪ installation of odor sensors throughout the site, surrounding the compost, collection, sorting, transfer, storage, areas, and any ancillary process location or odor source (e.g., stationary combustion sources, waste water retention or treatment) ▪ routine odor patrols during operations and under meteorological conditions conducive to odor transport;
▪ a public odor complaint reporting system and complaint log; ▪ defined response times for investigating and addressing complaints; and ▪ adaptive management triggers (e.g., repeated verified offsite odor events or complaint patterns) that require implementation of additional corrective actions or operational changes. Corrective actions will vary depending upon the trigger but could include, and are not limited to, improved containment, increased treatment capacity, modified operations, and increased monitoring and response.
If monitoring indicates that applicable controls are not met, the City shall implement corrective actions within 7 days and increase monitoring and patrol frequency. The City shall also publish an annual report that summarizes complaints, response times, and measures implemented to address complaints. This report shall be kept on file at the facility and made available to the public/PCAPCD upon request.
Documentation and updates
The Odor Reduction Plan shall be kept on file at the facility, made available to the public/PCAPCD upon request, and updated as necessary to reflect changes in operations, waste streams, control technologies, or regulatory requirements.
Revised:
Mitigation Measure 3.3-5: Implement Facility Odor Reduction Plan Prior to commencement of operations involving municipal green waste and food organics, the City shall prepare, implement, and maintain a comprehensive Odor Reduction Plan to minimize the potential for objectionable odors affecting existing and reasonably foreseeable future sensitive receptors. The Odor Reduction Plan shall apply to all odor-generating activities at the facility and shall be implemented for the life of the project. At a minimum, the Odor Reduction Plan shall include the following elements:
▶ Odor source identification and controls
The Odor Reduction Plan shall identify all odor-generating sources, and for each source, the Odor Reduction Plan shall specify operational and engineering controls designed to minimize odor generation and release. Odor sources include, but are not limited to:
▪ receiving, unloading, sorting, handling, and temporary storage of municipal solid waste and organics within the material recovery facility and organics building enclosures; ▪ pre-processing and mixing of feedstocks; and
▪ management of residual materials and recyclables prior to off-site transport.
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City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-9 Odor sources associated with Phase 2 of the project include, but are not limited to:
▪ covered aerated static pile (ASP) composting operations; ▪ curing, screening, and product handling; and
▪ management of leachate or contact water, including associated contact water retention, reuse, and management facilities.
▶ Receiving and material recovery building requirements To address the highest odor potential activities, the Odor Reduction Plan shall require that:
▪ reception and sorting of organic waste occur within the building enclosure, with doors closed except during active vehicle ingress and egress;
▪ the organics building enclosure be operated to minimize odor emissions, including use of enclosures, ventilation, and odor control measures as applicable (e.g., negative pressure and treatment through a biofilter, scrubber, or equivalent system, if deemed necessary); ▪ onsite staging time for unprocessed food organics be limited to a defined maximum duration of time not beyond the time necessary to move to the next stage, with covered or contained storage; and
▪ putrescible residuals and screened contaminants be stored in covered containers and removed from the site on a regular schedule sufficient to prevent odor buildup. ▪ housekeeping procedures be identified to minimize odor accumulation within processing and storage areas, including routine cleaning of floors, equipment, conveyors, tipping areas, loading areas, and management of spilled or accumulated waste materials, as appropriate. ▶ Covered aerated static pile operational controls
The Odor Reduction Plan shall include procedures to maintain aerobic conditions within covered ASP bays, including monitoring and management of aeration, moisture, pile conditions, and other compost operating parameters relevant to odor generation and control. Corrective actions shall be identified for upset conditions (e.g., power outages, aeration system failures, excessive moisture, or indications of anaerobic conditions) to promptly reduce odor potential. The Odor Reduction Plan shall also identify procedures to prevent and respond to anaerobic conditions, pile smoldering, smoking, prolonged anaerobic conditions, and other operational conditions that could increase odor emissions. ▶ Odor monitoring, complaints, and adaptive management
The Odor Reduction Plan shall include an odor monitoring and response program consisting of:
▪ installation of odor sensors throughout the site, surrounding the compost, collection, sorting, transfer, storage, areas, and any ancillary process location or odor source (e.g., stationary combustion sources, waste water retention or treatment) ▪ routine odor patrols during operations and under meteorological conditions conducive to odor transport;
▪ a public odor complaint reporting system and complaint log; ▪ defined response times for investigating and addressing complaints; and ▪ adaptive management triggers (e.g., repeated verified offsite odor events or complaint patterns) that require implementation of additional corrective actions or operational changes. Corrective actions will vary depending upon the trigger but could include, and are not limited to, improved containment, increased treatment capacity, modified operations, increased monitoring and response, enhanced housekeeping practices, reduced material staging times, additional odor-control measures for composting operations, modifications to compost management practices, or additional engineering controls for odor capture and treatment.
Revisions to the Draft EIR Ascent
City of Roseville
3-10 Roseville Environmental Utilities Operations Center Project Final EIR If monitoring indicates that applicable controls are not met, the City shall implement corrective actions as soon as practical and within 7 days and increase monitoring and patrol frequency. The City shall also publish an annual report that summarizes complaints, response times, and measures implemented to address complaints. This report shall be kept on file at the facility and made available to the public/PCAPCD upon request.
Documentation and updates
The Odor Reduction Plan shall be kept on file at the facility, made available to the public/PCAPCD upon request, and updated as necessary to reflect changes in operations, waste streams, control technologies, or regulatory requirements.
3.4 REVISIONS TO SECTION 3.5, “BIOLOGICAL RESOURCES”
In response to comments A3-3 and A3-4, and to provide an update to reflect the current CESA candidate status and potential for occurrence of western burrowing owl, Table 3.5-2 on page 3.5-12 of the Draft EIR is revised as follows:
Original:
Table 3.5-2 Special-Status Wildlife Species Known to Occur in the Vicinity of the Project Site and Potential for Occurrence on the Project Site
Species
Listing
Status1
Federal
Listing
Status1
State
Habitat Potential for Occurrence
Birds
Burrowing owl
Athene cunicularia
– SSC Open, dry annual or perennial grasslands,
deserts and scrublands characterized by lowgrowing vegetation. Subterranean nester, dependent upon burrowing mammals, most
notably, the California ground squirrel.
Not expected to occur. Although the project
site contains earthen berms that may provide
burrow habitat suitable for this species, the
grass covering the berms is high and dense
likely precluding use by this species.
Revised:
Table 3.5-2 Special-Status Wildlife Species Known to Occur in the Vicinity of the Project Site and Potential for Occurrence on the Project Site
Species
Listing
Status1
Federal
Listing
Status1
State
Habitat Potential for Occurrence
Birds
Burrowing owl
Athene cunicularia
– SSC,
SC
Open, dry annual or perennial grasslands,
deserts and scrublands characterized by
low-growing vegetation. Subterranean
nester, dependent upon burrowing
mammals, most notably, the California
ground squirrel.
Not expected to occur. The project site
contains earthen berms that may provide
burrow habitat suitable for this species, the
grass covering the berms is high and dense
likely precluding use by this species.
Although new occurrences have been
reported in the vicinity of the project site,
these observations are outside of the project
site in disturbed habitats (i.e., active
construction sites).
In response to comments A3-3 and A3-4, and to provide an update to the potential for occurrence of western burrowing owl, a discussion of burrowing owl, following the special-status birds, common raptors, and other
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-11 common native birds discussion beginning on page 3.5-31 of the Draft EIR, is added as follows with a new mitigation measure:
Original:
Significance after Mitigation
Implementation of Mitigation Measure 3.5-2h would reduce potential impacts on special-status birds, raptors, and other common native nesting birds to a less-than-significant level by requiring focused surveys for nesting birds, implementation of measures to avoid disturbance, injury, or mortality of the species if nests are detected and compensatory mitigation to offset the loss of Swainson’s hawk foraging habitat.
Revised:
Significance after Mitigation
Implementation of Mitigation Measure 3.5-2h would reduce potential impacts on special-status birds, raptors, and other common native nesting birds to a less-than-significant level by requiring focused surveys for nesting birds, implementation of measures to avoid disturbance, injury, or mortality of the species if nests are detected and compensatory mitigation to offset the loss of Swainson’s hawk foraging habitat.
Burrowing Owl
Although no habitat suitable for burrowing owl was identified on the project site during 2024 surveys conducted for the project, recent construction projects in the vicinity of the project site have converted rice fields to disturbed upland habitat, suitable for burrowing owl. In 2025, burrowing owls were observed approximately 340 feet south of Phillip Road, south of the project site. Burrowing owl surveys in that off-site area have been ongoing since the 2025 observation, and no burrowing owls have been observed in this area since the first observation (CNDDB 2026). The nearest 2026 burrowing owl observations were approximately 4,200 feet south of Phillip Road, which is outside of CDFW’s 500-meter (1,640-foot) recommended survey buffer for western burrowing owls. Western burrowing owls this far from the project site would not be adversely affected by project activities. For these reasons, the project’s impacts on burrowing owls would be less than significant. Nonetheless, in deference to a request from the California Department of Fish and Wildlife (July 3, 2026 email from Patrick Moeszinger to Jessica Lynch), the City shall implement the following burrowing owl mitigation measures prior to and during project construction. The implementation of these measures would ensure this impact remains less than significant.
Mitigation Measures
Mitigation Measure 3.5-2k: Conduct Preconstruction Surveys for Western Burrowing Owl and Implement Avoidance Measures.
▶ A qualified biologist shall conduct surveys for burrowing owls in areas of habitat suitable for the species on and within 1,640 feet (500 meters) of the project site. Inaccessible areas (e.g., adjacent private property) will not be surveyed directly if access is not granted, but the biologist may use binoculars or a spotting scope to survey these areas from the project site or other publicly accessible areas. A minimum of four surveys shall be conducted to determine whether burrowing owls occupy habitats on or within 1,640 feet of the project site. Surveys shall be conducted according to Appendix D of the 2012 Staff Report on Burrowing Owl Mitigation prepared by the California Department of Fish and Game (now CDFW) (CDFG 2012), or any subsequent updated guidance. If feasible, at least one survey should be conducted between February 15 and April 15 and the remaining surveys should be conducted between April 15 and July 15, at least three weeks apart. Because burrowing owls may recolonize a site after only a few days, one of the surveys, or an additional survey, shall be conducted no less than 14 days before initiating ground disturbance activities to verify that take of burrowing owl would not occur. During the non-breeding season (September 1 to January 31), surveys will document whether burrowing owls are using habitat in or directly adjacent to any area to be disturbed by project activities. Survey results will be valid only for the season (breeding or non-breeding) during which the survey was conducted.
Revisions to the Draft EIR Ascent
City of Roseville
3-12 Roseville Environmental Utilities Operations Center Project Final EIR ▶ If no burrowing owls are found, the qualified biologist shall submit a report documenting the survey methods and results to the City, and no further mitigation shall be required. ▶ If a burrow occupied by a burrowing owl is found during the surveys, the City shall establish and maintain a buffer around the occupied burrow and any identified satellite burrows (i.e., burrows used to escape predators or move young into after hatching) to prevent take of the burrowing owls. ▪ During the non-breeding season (September 1 through January 31), the minimum buffer distance shall be 164 feet (50 m). During the breeding season (February 1 through August 31), the minimum buffer distance shall follow CDFW’s recommended buffers depending on the level of disturbance. ▪ The buffer may be adjusted if, in consultation with CDFW, a qualified biologist determines that an alternative buffer would not result in take of burrowing owl adults, young, or eggs because of particular site features (e.g., topography, natural line-of-sight barriers), level of project disturbance, or other considerations. If the buffer is reduced, a qualified biologist shall monitor the behavior of the burrowing owls during all project activities within 1,640 feet of the burrow. If the owls are disturbed or agitated (e.g., vocalizations, bill snaps, fluffing feathers to increase body size appearance, drooping wings and rotating them forward, crouching and weaving back and forth) by the project activities, the biologist shall have the authority to halt the activities and re-establish a buffer consistent with the first bullet until the agitated behavior ceases and normal behavior resumes.
▪ The buffer shall remain in place around the occupied burrow and associated satellite burrows until a qualified biologist has determined through noninvasive methods that the burrows are no longer occupied by burrowing owl. A previously occupied burrow will be considered unoccupied if surveys demonstrate that no owls have used the burrow for seven consecutive days. ▪ Locations of burrowing owls detected during surveys shall be reported to the CNDDB. ▶ If implementation of a buffer to prevent take of burrowing owl is not feasible, the City shall consult with CDFW and obtain an Incidental Take Permit (ITP) prior to commencing project related ground-disturbing activities. The impacts of taking burrowing owl shall be minimized and fully mitigated. ▶ If take occurs, the City shall compensate for the loss of burrowing owl by establishing permanent protection and perpetual management on land that provides burrowing owl habitat. Habitat management lands for burrowing owl may be established by conservation easement or fee title, or credits may be purchased from a CDFW-approved conservation or mitigation bank. The compensatory mitigation shall satisfy permit conditions and all other permit conditions shall be implemented. ▶ The City shall decommission the rice fields and other active agricultural areas on the project site only after these areas have been surveyed for burrowing owls as indicated above. Decommissioning of rice fields and other agricultural areas shall include the removal of all irrigation and drainage components, including pipe culvert, rice trunks/sluice boxes, and any other debris from the area. ▶ All demolition debris shall be removed from the site to prevent wildlife from using the debris as shelter.
Demolition debris may be stored in covered containers immediately prior to off-site transport. ▶ Laydown materials areas shall be maintained and monitored so that materials and equipment do not attract or provide shelter habitat for wildlife. Pipes or other construction materials that could provide burrow surrogate habitat shall be kept covered or sealed.
Significance after Mitigation
Implementation of Mitigation Measure 3.5-2k would ensure potential impacts on burrowing owls remain less-than-significant by requiring that active burrows on or near the project site be identified and avoided or monitored so that project construction would not result in nest abandonment and loss of eggs or young.
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-13 In response to comments A3-3 and A3-4, and to provide an update to the potential for occurrence of western burrowing owl, the discussion of mitigation measures for Phase 2 on page 3.5-36 of the Draft EIR, is revised as follows to identify the new Mitigation Measure 3.5-2k:
Original:
Mitigation Measures
Implement Mitigation Measures 3.5-2a, 3.5-2b, 3.5-2c, 3.5-2f, 3.5-2g, 3.5-2h, 3.5-2i, and 3.5-2j, described above.
Significance after Mitigation
Implementation of Mitigation Measures 3.5-2a, 3.5-2b, and 3.5-2c would reduce potential impacts on northwestern pond turtle to a less-than-significant level by requiring focused surveys for the species, implementation of measures to avoid injury or mortality of northwestern pond turtles if detected, and relocation of individual turtles by a qualified biologist with an appropriate CDFW Scientific Collecting Permit, implementing construction BMPs and providing stream setback by fencing or flagging the limits of disturbance, developing a nuisance wildlife management plan and incorporating it into the City’s Environmental Utilities Facility Management Plan.
Implementation of Mitigation Measures 3.5-2f would reduce the potential impact on Crotch’s bumble bee to a less-than-significant level by requiring focused surveys for bumble bees and implementation of measures to avoid mortality of the Crotch’s bumble bees if nests or overwintering queens are detected.
Implementation of Mitigation Measure 3.5-2g would reduce potential impacts on monarch to a less-thansignificant level by requiring focused surveys for milkweed plant, monarch eggs, larvae, and pupae and implementation of measures to avoid mortality of monarch eggs, larvae, and pupae if they are detected.
Implementation of Mitigation Measure 3.5-2h would reduce potential impacts on special-status birds, raptors, and other common native nesting birds to a less-than-significant level by requiring focused surveys for nesting birds, implementation of measures to avoid disturbance, injury, or mortality of the species if nests are detected and compensate for the loss of Swainson’s hawk foraging habitat.
Implementation of Mitigation Measure 3.5-2i would reduce potential impacts on Northern California ringtail to a less-than-significant level by requiring focused surveys for ringtail dens prior to removing trees or demolishing or repurposing unoccupied buildings at the site and implementing no-disturbance buffers around active dens in consultation with CDFW.
Implementation of Mitigation Measure 3.5-2j would reduce potential impacts on pallid bat and western red bat to a less-than-significant level by requiring focused surveys for bat roosts, implementation of nodisturbance buffers around active special-status bat roosts, and consultation with CDFW if special-status bat roosts would be removed.
For the above reasons, implementation of Mitigation Measures 3.5-2a, 3.5-2b, 3.5-2c, 3.5-2f, 3.5-2g, 3.5-2h,
3.5-2i, and 3.5-2j would reduce impacts to special-status wildlife species to a less-than-significant level.
Revised:
Mitigation Measures
Implement Mitigation Measures 3.5-2a, 3.5-2b, 3.5-2c, 3.5-2f, 3.5-2g, 3.5-2h, 3.5-2i, 3.5-2j, and 3.5-2k, described above.
Significance after Mitigation
Implementation of Mitigation Measures 3.5-2a, 3.5-2b, and 3.5-2c would reduce potential impacts on northwestern pond turtle to a less-than-significant level by requiring focused surveys for the species, implementation of measures to avoid injury or mortality of northwestern pond turtles if detected, and relocation of individual turtles by a qualified biologist with an appropriate CDFW Scientific Collecting Permit,
Revisions to the Draft EIR Ascent
City of Roseville
3-14 Roseville Environmental Utilities Operations Center Project Final EIR implementing construction BMPs and providing stream setback by fencing or flagging the limits of disturbance, developing a nuisance wildlife management plan and incorporating it into the City’s Environmental Utilities Facility Management Plan.
Implementation of Mitigation Measures 3.5-2f would reduce the potential impact on Crotch’s bumble bee to a less-than-significant level by requiring focused surveys for bumble bees and implementation of measures to avoid mortality of the Crotch’s bumble bees if nests or overwintering queens are detected.
Implementation of Mitigation Measure 3.5-2g would reduce potential impacts on monarch to a less-thansignificant level by requiring focused surveys for milkweed plant, monarch eggs, larvae, and pupae and implementation of measures to avoid mortality of monarch eggs, larvae, and pupae if they are detected.
Implementation of Mitigation Measure 3.5-2h would reduce potential impacts on special-status birds, raptors, and other common native nesting birds to a less-than-significant level by requiring focused surveys for nesting birds, implementation of measures to avoid disturbance, injury, or mortality of the species if nests are detected and compensate for the loss of Swainson’s hawk foraging habitat.
Implementation of Mitigation Measure 3.5-2i would reduce potential impacts on Northern California ringtail to a less-than-significant level by requiring focused surveys for ringtail dens prior to removing trees or demolishing or repurposing unoccupied buildings at the site and implementing no-disturbance buffers around active dens in consultation with CDFW.
Implementation of Mitigation Measure 3.5-2j would reduce potential impacts on pallid bat and western red bat to a less-than-significant level by requiring focused surveys for bat roosts, implementation of nodisturbance buffers around active special-status bat roosts, and consultation with CDFW if special-status bat roosts would be removed.
Implementation of Mitigation Measure 3.5-2k would ensure potential impacts on burrowing owls remain less-than-significant by requiring that active burrows on or near the project site be identified and avoided or monitored so that project construction would not result in nest abandonment and loss of eggs or young.
For the above reasons, implementation of Mitigation Measures 3.5-2a, 3.5-2b, 3.5-2c, 3.5-2f, 3.5-2g, 3.5-2h,
3.5-2i, 3.5-2j, and 3.5-2k would reduce impacts to special-status wildlife species to a less-than-significant level.
In response to comments on the Draft EIR from the California Department of Fish and Wildlife (CDFW) and the Placer Conservation Authority (PCA), and to provide an update to the project’s potential to result in indirect effects on offsite wetlands, the analysis of Impact 3.5-4 on page 3.5-38 of the Draft EIR, is revised as follows:
Original:
Impact 3.5-4: Result in Degradation or Loss of State or Federally Protected Wetlands Phase 1
Implementation of Phase 1 would include ground disturbance, vegetation removal, and direct removal of riparian habitat adjacent to wetlands previously identified in the off-site portion of the PUE, which could result in inadvertent fill of the identified wetlands. Fill of wetlands would remove or degrade these features, which would be a potentially significant impact.
No state or federally protected wetlands or other waters of the United States or waters of the state are located within the proposed development area of the project site and, thus, the project would not result in any direct impacts to wetlands or other waters on the project site. Potential indirect effects from sedimentation or runoff from construction and operation of the project are addressed in Section 3.11, “Hydrology and Water Quality.”
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-15 Wetlands with vegetation assemblages associated with vernal pools have been previously identified in the off-site portion of the PUE. Ground disturbance, vegetation removal, and direct removal of riparian habitat adjacent to wetlands previously identified in the off-site portion of the PUE could result in inadvertent fill of the identified wetlands. Fill of wetlands would remove or degrade these features, which would be a potentially significant impact.
Revised:
Impact 3.5-4: Result in Degradation or Loss of State or Federally Protected Wetlands Phase 1
Implementation of Phase 1 would include ground disturbance, vegetation removal, and direct removal of riparian habitat adjacent to wetlands previously identified in the off-site portion of the PUE, which could result in inadvertent fill of the identified wetlands. Fill of wetlands would remove or degrade these features, which would be a potentially significant impact. In addition, wetlands located on nearby Placer Conservation Authority reserve properties could be indirectly affected if project implementation would result in a substantial change to off-site hydrologic conditions. Such changes could adversely affect wetland functions and values, resulting in a potentially significant impact.
No state or federally protected wetlands or other waters of the United States or waters of the state are located within the proposed development area of the project site and, thus, the project would not result in any direct impacts to wetlands or other waters on the project site. Potential indirect effects from sedimentation or runoff from construction and operation of the project are addressed in Section 3.11, “Hydrology and Water Quality.”
Wetlands with vegetation assemblages associated with vernal pools have been previously identified in the off-site portion of the PUE. Ground disturbance, vegetation removal, and direct removal of riparian habitat adjacent to wetlands previously identified in the off-site portion of the PUE could result in inadvertent fill of the identified wetlands. Fill of wetlands would remove or degrade these features, which would be a potentially significant impact. In addition, wetlands located on nearby Placer Conservation Authority reserve properties could be indirectly affected if project implementation would result in a substantial change to offsite hydrologic conditions. Such changes could adversely affect these wetlands and would be a potentially significant impact.
In response to comments on the Draft EIR from CDFW and PCA, and to provide an update to the project’s potential to result in indirect effects on off-site wetlands, a new bullet is added to the end of Mitigation Measure 3.5-4b on page 3.5-39 of the Draft EIR, as follows:
Revised:
Mitigation Measure 3.5-4b: Identify State or Federally Protected Wetlands, Implement Avoidance Measures, and Obtain Permits for Unavoidable Impacts on Wetlands
▶ The City shall prepare a hydrologic study to characterize existing site hydrology and ensure that project implementation and operation would not result in a substantial change to off-site hydrologic conditions within 250 feet from the project’s disturbance boundary. Based on the study findings, the City shall establish and implement appropriate buffers, as warranted, to avoid substantial adverse effects on offsite seasonal wetlands.
Revisions to the Draft EIR Ascent
City of Roseville
3-16 Roseville Environmental Utilities Operations Center Project Final EIR In response to comments on the Draft EIR from CDFW and PCA, and to expand Mitigation Measure 3.5-5 to also apply to the nearby Placer Conservation Authority reserve properties, Mitigation Measure 3.5-5 on page 3.5-42 of the Draft EIR, is revised as follows:
Original:
Mitigation Measure 3.5-5: Utilize Wildlife-Friendly Building Design In addition to Mitigation Measure 3.1-3, described in Section 3.1, “Aesthetics and Visual Resources,” the City shall implement the following measures:
▶ Buildings and other permanent structures shall be designed to minimize impacts on wildlife, including disruption to wildlife movement.
▪ Building design shall utilize guidelines regarding building height, materials, external lighting, and landscaping provided in the American Bird Conservancy’s “Bird Friendly Building Design” (American Bird Conservancy 2015).
▶ The City shall place structural barriers to screen construction lighting and construction vehicular headlights that are directed perpendicular to Pleasant Grove Creek. This may be accomplished through the placement of a 5-6-foot vegetated hedge or other structural method that would screen the northern portion of the project.
▶ To minimize light spillage from the project during operation into Pleasant Grove Creek, outdoor lighting shall be the minimum wattage required for the particular use, shall be shielded, and shall be directed to the specific location intended for illumination to prevent stray light spillover onto sensitive riparian habitat.
Revised:
Mitigation Measure 3.5-5: Utilize Wildlife-Friendly Building Design In addition to Mitigation Measure 3.1-3, described in Section 3.1, “Aesthetics and Visual Resources,” the City shall implement the following measures:
▶ Buildings and other permanent structures shall be designed to minimize impacts on wildlife, including disruption to wildlife movement.
▪ Building design shall utilize guidelines regarding building height, materials, external lighting, and landscaping provided in the American Bird Conservancy’s “Bird Friendly Building Design” (American Bird Conservancy 2015).
▶ The City shall place structural barriers to screen construction lighting and construction vehicular headlights that are directed perpendicular to Pleasant Grove Creek. This may be accomplished through the placement of a 5-6-foot vegetated hedge or other structural method that would screen the northern portion of the project. The City shall also implement measures to minimize spillover of construction lighting onto nearby Placer Conservation Authority reserve properties, including the use of shielded fixtures, directional lighting, and other lighting controls as necessary. ▶ To minimize light spillage from the project during operation into Pleasant Grove Creek and the nearby Placer Conservation Authority reserve properties, outdoor lighting shall be the minimum wattage required for the particular use, shall be shielded, and shall be directed to the specific location intended for illumination to prevent stray light spillover onto sensitive riparian habitat.
Ascent Revisions to the Draft EIR
City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 3-17 To provide an update that reflects the results of tree surveys conducted in May 2026 for the project, the analysis of Impact 3.5-6 on page 3.5-43 is revised as follows:
Original:
Impact 3.5-6: Conflict with Local Policies and Ordinances Phase 1
Chapter 19.66 of the City of Roseville Municipal Code, “Tree Preservation,” contains requirements for projects that would remove protected trees. Implementation of the project would result in direct removal of or damage to trees that may be protected under the City of Roseville Municipal Code. This impact would be potentially significant.
Implementation of Phase 1 would require the removal of trees present within the proposed development area of the project site that may qualify as protected trees (see the discussion of the City of Roseville Municipal Code in Section 3.5.1, “Regulatory Setting”). As defined by the City of Roseville Municipal Code (Chapter 19.66, Tree Preservation), native oak trees greater than 6 inches diameter at breast height are protected. A Tree Permit would be required for the removal of any protected tree, and for any regulated activity within the protected zone of a protected tree where the encroachment exceeds 20 percent. A survey of the trees on the project site has not been completed; therefore, trees planned for removal as part of project implementation may meet the definition of protected trees pursuant to the City of Roseville Municipal Code. This would be a potentially significant impact.
Revised:
Impact 3.5-6: Conflict with Local Policies and Ordinances Phase 1
Chapter 19.66 of the City of Roseville Municipal Code, “Tree Preservation,” contains requirements for projects that would remove protected trees. Implementation of the project would result in direct removal of or damage to trees that may be protected under the City of Roseville Municipal Code. This impact would be potentially significant.
Implementation of Phase 1 would require the removal of trees present within the proposed development area of the project site that may qualify as protected trees (see the discussion of the City of Roseville Municipal Code in Section 3.5.1, “Regulatory Setting”). As defined by the City of Roseville Municipal Code (Chapter 19.66, Tree Preservation), native oak trees greater than 6 inches diameter at breast height are protected. A Tree Permit would be required for the removal of any protected tree, and for any regulated activity within the protected zone of a protected tree where the encroachment exceeds 20 percent. Tree surveys were conducted in May 2026 to document existing tree resources within and adjacent to the project study area, evaluate tree condition and structural characteristics, identify trees that may qualify for protection under applicable City regulations, and provide planning-level information regarding potential tree constraints and opportunities for preservation (Helix Environmental Planning 2026). Based on the survey results, project implementation could require the removal of trees that qualify as protected trees pursuant to the City of Roseville Municipal Code. As project design advances, the City would seek opportunities to avoid and minimize the removal of existing trees through site planning and design refinements where practicable, with priority given to the preservation of mature native oak trees. Nonetheless, project implementation could result in the removal of or damage to trees protected under the City of Roseville Municipal Code. Therefore, this would be a potentially significant impact.
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City of Roseville
Roseville Environmental Utilities Operations Center Project Final EIR 4-1 4 REFERENCES
Chapter 1, “Introduction”
No references were cited in this chapter.
Chapter 2, “Responses to Comments”
California Natural Diversity Database. 2026. Results of electronic records search for unprocessed data from CNDDB Online Field Survey Form. Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved July 27, 2026.
CNDDB. See California Natural Diversity Database.
HELIX Environmental Planning. 2026 (June 3). Roseville Environmental Utilities Operations Center Project (Phillip Rd) Arborist Report. Prepared for HDR Engineering.
Sacramento Municipal Utility District. 2022 (September). Sacramento Municipal Utility District Country Acres Solar Project Draft Environmental Impact Report. State Clearinghouse No. 2021110307. Prepared by AECOM.
Available: https://ceqanet.lci.ca.gov/2021110307/2. Accessed August 2026.
SMUD. See Sacramento Municipal Utility District.
South Placer Regional Transportation Authority, California Department of Transportation, and Federal Highway Administration. 2009 (November). Final Placer Parkway Corridor Preservation Tier 1 Environmental Impact Statement/ Program Environmental Impact Report Final Tier 1 Section 4(f) Evaluation. Prepared by URS Corporation. Available: https://www.pctpa.net/files/563560e2c/_FinalTier1EISEIR.pdf?get_file=true. Accessed August 3, 2026.
Chapter 3, “Revisions to the Draft EIR”
California Department of Fish and Game. 2012 (March 7). Staff Report on Burrowing Owl Mitigation. Available:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843&inline=true. Accessed August 4, 2026.
California Natural Diversity Database. 2026. Results of electronic records search for unprocessed data from CNDDB Online Field Survey Form. Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved July 27, 2026.
CDFG. See California Department of Fish and Game.
CNDDB. See California Natural Diversity Database.
HELIX Environmental Planning. 2026 (June 3). Roseville Environmental Utilities Operations Center Project (Phillip Rd) Arborist Report. Prepared for HDR Engineering.
References Ascent
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Roseville Environmental Utilities Operations Center Project Final EIR 5-1 5 LIST OF PREPARERS
City of Roseville (Lead Agency)
Devin Whittington .......................................................................................Assistant Environmental Utilities Director of Operations Brian Craighead................................................................................................................... Assistant Director of Environmental Utilities Wes Heathcock.........................................................................................................................................Refuse and Stormwater Manager Brian Jones .....................................................................................................................................................................Refuse Superintendent Keith Schmidt, PE.......................................................................................................................................................................Senior Engineer Jessica Lynch.........................................................................................................................................................Environmental Coordinator HDR (Engineering)
Tim Raibley, PE...............................................................................................................................................................................Vice President Charlie O’Neill ............................................................................................................................................................. Senior Project Manager Cindy Liles, PE ........................................................................................................................................................... Organics and Air Quality Andrea Ramirez, PE....................................................................................................................................................................Waste Facilities Bob Rella, PE................................................................................................................................................................................Senior Engineer Lock Quan, PE.............................................................................................................................................................................Water Engineer Rich Stratton, PE.........................................................................................................................................................................Water Engineer Amit Roy, PMP.........................................................................................................................................................................Corporation Yard Jacobs (Consultant to HDR)
Janet Goodrich......................................................................................................................Waste Solutions Global Technology Leader Douglas Environmental (Consultant to HDR)
Doug Brown...............................................................................................................................................................................................Principal Edgar and Associates (Permitting)
Neil Edgar..................................................................................................................................................................... Senior Project Manager Ascent, Inc. (CEQA Compliance)
Mike Parker, AICP ....................................................................................................................................................................................Principal Sarah Henningsen ...................................................................................................................................................................Project Manager Elena Savignano.............................................................................Air Quality, Greenhouse Gas Emissions, Transportation Analyst Dimitri Antoniou..........................................................................................................Senior Air Quality/GHG/Energy/Noise Specialist Carlos Alvarado ................................................................................................................................................................ Biological Resources Tammie Beyerl ............................................................................................................................................................................Senior Biologist Bryn Kirk .......................................................................................................................................................................... Environmental Planner Brian Perry................................................................................................................................................................................Graphic Specialist Gayiety Lane .......................................................................................................................................................................Publishing Specialist Riley Smith...........................................................................................................................................................................Publishing Specialist Kittelson & Associates (Transportation Impact Study)
Mychal Loomis, PE................................................................................................................................................................ Principal Engineer Anusha Musunuru, PhD .............................................................................................................................. Senior Engineering Associate Mingmin Liu...................................................................................................................................................... Senior Engineering Associate Qiming Sun..................................................................................................................................................................... Engineering Associate Sravya Kamalapuram................................................................................................................................................... Engineering Associate
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Appendix A
Placer County Conservation Program:
Development Interface Design Requirements
PLACER COUNTY
CONSERVATION PROGRAM
WESTERN PLACER COUNTY
HABITAT CONSERVATION PLAN/
NATURAL COMMUNITY CONSERVATION PLAN
February 2020
Placer County
Program Participation and
Conditions on Covered Activities
Placer County Conservation Program
Western Placer County HCP/NCCP 6-24 February 2020
ICF 506.10
condition is to provide additional measures to minimize effects on Covered Species and natural communities in reserves from neighboring urban and rural development.
6.3.1.2.1 Conservation Lands: Development Interface Design Requirements Beyond minimizing direct and indirect effects, the design of new development occurring adjacent to conservation lands will consider indirect and long-term effects, such as runoff from developed areas, which can transport harmful substances (e.g., pesticides, fertilizer, automotive fluids, sediment) into conservation lands; changes to hydrological conditions; the establishment of invasive non-native species, which can disperse from landscaped areas; and potential structural and biological damage (e.g., soil compaction, creation of unauthorized trails, disturbance of sensitive species) that can result from unmanaged human access and use. Application of the following design requirements will help minimize the potential for indirect effects of development on conservation lands.
1. Signage will be posted to notify of any usage restrictions and to educate the public on the sensitivity of the area and usage restrictions.
2. Fencing will be installed at the boundary between developed areas and reserves to prevent illegal access by people and pets, unless the conditions on the reserve make trespass unlikely (i.e., surrounded by canals that are difficult to cross). Fences will be suitable to the conditions in the adjacent reserve. The type of fence required will be at the discretion of the County or City, as permitted by County and City codes. Fences will have limited gates and be designed with consideration to not allowing movement of people and their pets. Access will be limited to maintenance and monitoring activities unless a habitat management plan specifies otherwise.
3. Natural or artificial barriers or other access restrictions may be installed around development to protect sensitive land-cover types and Covered Species in the reserves. If used, barriers will be designed so they are appropriate for site conditions and the resources being protected. Some barriers should keep domestic pets outside the reserve, other barriers should keep Covered Species inside the reserve. Before installation of a barrier, consideration shall be given to freedom of movement by Covered Species. If the barrier would prevent movement, or if the barrier would encourage species to use other, less-favorable crossings, alternative solutions shall be considered.
4. Roads constructed adjacent to reserves will be fenced to restrict unauthorized public access.
Through the conditional approval process, the Permittee will only approve fencing that is appropriate (e.g., chain link, post and cable, barbwire) to allow movement of wildlife between reserves.
5. Development will be designed to minimize the length of the shared boundary between development and the reserves (i.e., minimize the urban edge, perimeter).
6. Incorporation of high-intensity lighting (e.g., floodlights used for recreational facilities and commercial parking lots) into site improvement standards near reserves will be avoided. Lowglare, no-glare, or shielded lighting will be installed in developed areas adjacent to reserves to minimize artificial lighting of reserve lands at night. The height and intensity of lights shall be kept to a minimum. Resources providing technical support include publications of the Illuminating Engineering Society of North America and its Lighting Handbook, Reference & Application, Ninth Edition, and Recommended Practices. The intent of this avoidance and minimization measure is to design a lighting system, where determined necessary, that maintains public safety and security in the project area while curtailing the degradation of the
Placer County
Program Participation and
Conditions on Covered Activities
Placer County Conservation Program
Western Placer County HCP/NCCP 6-25 February 2020
ICF 506.10
nighttime visual environment on the reserve property by limiting nighttime light radiation and/or light spill.
7. Public facilities, such as ballparks and fields that require high-intensity night lighting (i.e., floodlights), will be sited at least 0.5 mile from the reserve boundary to minimize light pollution.
Facilities may be sited closer to the Reserve System if the PCA determines the lighting system will not be intrusive to wildlife within the Reserve System (e.g., hills block the lighting).
8. For any landscaping adjacent to reserve properties, non-invasive plants will be required, and the use of native plants will be highly encouraged, consistent with County landscape design guidelines (Placer County 2013) or similar standards for the City of Lincoln.
Any of the above design requirements, or similar requirements developed over time, that are incorporated into projects will be located within the development footprint. These project features will be maintained by the property owners. Conditions of approval on projects are monitored by County or City staff during the construction and development phase and are enforced over time through the efforts of professional land development staff familiar with the project or a code enforcement division. If projects are found to be out of compliance, standard remedial actions would be applied and may include: code enforcement, use of securities, revocation or modification of entitlement. Violations will be reported to the PCA, Wildlife Agencies, and applicable local jurisdiction for potential enforcement.
The above avoidance and minimization measures are intended to serve as guidelines that establish, at a minimum, how effects at the development interface with the Reserve System and other conservation lands can be avoided and minimized. Site conditions may introduce additional opportunities that will need to be considered on a case-by-case basis (e.g., topographic conditions, location of passive recreational facilities, native landscaping buffers).
Non-participating local jurisdictions are encouraged to consult with the PCA during the development review process for large projects planned at the boundary of existing reserves.
6.3.1.3 General Condition 3, Land Conversion
Covered Activities that would result in permanent conversion of natural land cover must pay fees or otherwise contribute to establishing the Reserve System and are subject to the maximum extent of take proposed under the Plan.
Land conversion refers broadly to an activity or process that results in the permanent conversion of a natural or semi-natural land cover to an urban, suburban, rural residential, or other artificial, builtup, or otherwise non-natural condition. It is not meant to apply when one natural or semi-natural land-cover type is converted to another natural or semi-natural land-cover type. It is also not meant to apply to changes in agricultural crop types, which is not a Covered Activity addressed by the Plan.
Application of this condition is a key provision of the Plan. Land conversion allowable under the permits will be subject to an overall maximum extent of take. The proposed extent of take sets a maximum acreage of cumulative land conversion from all Covered Activities. Proposed maximums are set for several communities and are listed in Table 4-1 for permanent effects. Proposed maximums are also set for geographical Plan subareas, with some provision for flexibility in shifting allowable take between subareas.
The conservation strategy outlined in Chapter 5, Conservation Strategy, serves at a regional scale as conservation in perpetuity for Covered Species and mitigation for the effects of Covered Activities.
Ascent
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Ascent.inc
Mitigation Monitoring and Reporting Program for the
Roseville Environmental Utilities
Operations Center Project
State Clearinghouse No. 2024060953
Prepared for:
September 2026
Mitigation Monitoring and Reporting Program for the
Roseville Environmental Utilities
Operations Center Project
State Clearinghouse No. 2024060953
Prepared for:
City of Roseville
Development Services - Planning
311 Vernon Street
Roseville, CA 95678
Contact:
Jessica Lynch
Environmental Coordinator
Prepared by:
Ascent
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Contact:
Sarah Henningsen
Project Manager
20220140.01 September 2026
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 1
MITIGATION MONITORING AND REPORTING PROGRAM
In accordance with the California Environmental Quality Act (CEQA) (Public Resources Code [PRC] Section 21000 et seq.), the City of Roseville prepared an environmental impact report (EIR) for the Roseville Environmental Utilities (EU) Operations Center Project, which is a proposed new EU Operations Center in northwest Roseville. The project would include new facilities and services that would allow the City to cost effectively meet state-level legislation requirements, while providing space to grow for the Roseville EU Department’s services and staff. The EIR (State Clearinghouse No. 2024060953) identified significant impacts and mitigation measures that would reduce the identified impacts to less-than-significant levels, where feasible. CEQA and the State CEQA Guidelines (PRC Section 21081.6 and State CEQA Guidelines Sections 15091[d] and 15097) require public agencies “to adopt a reporting and monitoring program for changes to the project which it has adopted or made a condition of project approval to mitigate or avoid significant effects on the environment.” This Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the Roseville EU Operations Center Project because the EIR identifies significant adverse impacts related to project implementation, and mitigation measures have been identified to reduce or eliminate most of those impacts. Adoption of this MMRP would occur along with approval of the Roseville EU Operations Center Project.
PURPOSE OF THE MITIGATION MONITORING AND REPORTING PROGRAM This MMRP has been prepared to ensure that all required mitigation measures are implemented and completed in a satisfactory manner before and during project construction and operation, as applicable.
The MMRP table provided below has been prepared to assist the responsible parties in implementing the mitigation measures applicable to the Roseville EU Operations Center Project. The table identifies the mitigation measures (as amended through the Final EIR), implementation responsibility, and mitigation timing. The table also includes a column to confirm implementation of the mitigation measures. The numbering of mitigation measures follows the numbering sequence found in the EIR. Mitigation measures that are referenced more than once in the EIR are not duplicated in the MMRP table.
ROLES AND RESPONSIBILITIES
The City of Roseville Development Services – Planning is responsible for overall administration of the MMRP and for verifying that the builder, construction contractor, or other designated party has completed the necessary actions for each measure. The party responsible for implementing each item will identify the staff members responsible for coordinating with the City on the MMRP.
Inquiries should be directed to:
Contact: Jessica Lynch, Environmental Coordinator
City of Roseville Development Services – Planning
311 Vernon Street, Roseville, CA 95678
Phone: (916) 774-5352
Email: [email protected]
Mitigation Monitoring and Reporting Program
City of Roseville
2 Roseville Environmental Utilities Operations Center Project EIR
MITIGATION MONITORING AND REPORTING PROGRAM TABLE
The categories identified in the MMRP table are described below. ▶ Mitigation Measure – This column presents all the mitigation measures identified in the Roseville EU Operations Center Project EIR, each of which has been adopted and incorporated into the project. ▶ Project Phase – This column identifies the applicable project phase. As explained in the Draft EIR (p. 2-25), the two project phases are described as follows:
▪ Phase 1 includes the RRTO Facility (Phase 1), the Vendor Lease Area, and the Corporation Yard; and ▪ Phase 2 includes the RRTO Facility Expansion (Phase 2) and the Potential Future Organics Processing Facility. ▶ Implementation Responsibility – This column identifies the party responsible for implementing the mitigation measure.
▶ Timing – Implementation of the mitigation measure must occur before or during some part of project approval, project design, or project construction or on an ongoing basis. This column identifies the timing for implementation of each mitigation measure.
▶ Verification – The City of Roseville Development Services – Planning is responsible for ensuring that mitigation measures are successfully implemented. This column is to be used by the City to indicate when implementation of a mitigation measure has been completed. The City, at its discretion, may delegate implementation responsibility or portions thereof to qualified consultants or contractors.
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 3 Mitigation Monitoring and Reporting Program
Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
Aesthetics and Visual Resources
Mitigation Measure 3.1-1: Implement a Litter Mitigation Program (Phase 1 & 2) Once the project is operational, the City Solid Waste Division shall fund a continuous litter mitigation program that includes collecting and disposing roadside litter from along the roadways tributary to the site daily (Monday-Friday) on public roads within 1 mile of the project site and weekly within 2 miles of the project site. The litter mitigation program shall include routine monitoring of where litter occurs, logging of complaints, and the deployment of staff to perform litter removal activities. The City shall report the effectiveness of the litter mitigation program to the Local Enforcement Agency. The Solid Waste Division shall also employ a litter management program that collects litter from the site, its fences, and roadways each operating day.
Phase 1 & 2 City of Roseville During operation ⎯
Mitigation Measure 3.1-2: Minimize Potential Sources of Light and Glare (Phase 1 & 2) The City shall implement the following design standards to minimize potential sources of light and glare, which are based on measures in the City’s Design Guidelines for office and industrial projects:
⯈ Lighting sources shall have full cut off, U0 lenses and shall be located to avoid any light spillage and glare on adjacent properties and in private spaces; ⯈ Pole mounted lighting shall be spaced for maximum energy efficiency and be no taller than 25 feet for office areas and 35 feet for industrial areas; and ⯈ Nonreflective exterior surfaces and nonreflective (mirrored) glass shall be used for all new structures.
Phase 1 & 2 City of Roseville Prior to or during
construction
⎯
Land Use Planning and Agricultural Resources
Mitigation Measure 3.2-2: Compensate for Important Farmland Conversion (Phase 1 & 2) The following mitigation measure would be implemented to mitigate the project’s conversion of approximately 1 acre of Prime Farmland and 105 acres of Unique Farmland (a total of 106 acres of Important Farmland).
Prior to project construction, the City (Environmental Utilities Department) shall place a conservation easement on the Unique and Prime Farmland located within the project site but outside of the project development footprint, which includes 6 acres of Prime Farmland and 84 acres of Unique Farmland. This permanent, on-site easement would mitigate for the loss of 90 acres of Important Farmland. Though there are no specific requirements for additional off-site preservation of farmland, Phase 1 & 2 City of Roseville Prior to construction ⎯
Mitigation Monitoring and Reporting Program
City of Roseville
4 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
Implementation
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the City will seek opportunities to provide for farmland conservation outside of the city within Placer County. This may be accomplished through the purchase of land or an easement, or providing funding for, Important Farmland conservation in Placer County. Should the City’s effort to create the on-site conservation easement prove impossible or impractical, the City may pay in-lieu fees to mitigate the equivalent farm value of farmland as close to the project area as feasible.
Air Quality
Mitigation Measure 3.3-3a: Reduce Fugitive Dust From Composting (Phase 2 only) The following mitigation measure would be required if the City constructs and operates the composting component of the Potential Future Organics Processing Facility. To minimize fugitive PM₁₀ emissions from composting operations, including the use of an Aerated Static Pile (ASP) or a Covered Aerated Static Pile (CASP) system, the City shall implement the following dust control measures during all compost feedstock handling, pile building, screening, and on-site material movement activities:
⯈ Moisture Control: Maintain compost feedstocks and active piles at optimal moisture levels to reduce dust generation during pile construction, loading, and unloading.
⯈ Water or Suppressants: Apply water or environmentally safe dust suppressants to stockpiles and material handling areas as needed to minimize visible dust emissions.
⯈ Wind Barriers or Vegetative Buffers: Install fencing, berms, or vegetative windbreaks around the perimeter of the composting and feedstock handling areas to reduce windblown dust generation.
⯈ Enclosed or Covered Operations: Where feasible, enclose or provide windsheltered structures for high-dust-generating activities such as grinding or screening.
⯈ Monitoring and Response: Implement a visible dust observation program during active operations. If visible dust is observed beyond the property line, operations contributing to dust shall be temporarily suspended until effective dust control measures are applied.
Phase 2 only City of Roseville During construction and
operation
⎯
Mitigation Measure 3.3-3b: Permitting-Level Ambient Air Quality Evaluation for Composting and/or Stationary Biomass Facility (Phase 2 only) The following mitigation measure would be required if the City constructs and operates the Potential Future Organics Processing Facility, which could include a future Phase 2 only City of Roseville Prior to issuance of a
building permit or air
quality permit
⎯
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 5 Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
composting and/or biomass facility. Prior to issuance of a building permit or air quality permit for the installation or operation of the composting and/or any stationary biomass energy generation system, the City of Roseville shall prepare a permitting-level emissions evaluation, in coordination with PCAPCD. The evaluation shall:
⯈ Estimate all criteria air pollutant emissions based on the proposed technology type, combustion or conversion process, equipment specifications, fuel throughput, stack parameters, and emission factors;
⯈ Quantitatively estimate daily and annual emissions in accordance with PCAPCD Rule 502 New Source Review; and
⯈ Identify and evaluate Best Available Control Technology (BACT) and other emission control measures or procure emissions offsets to reduce emissions, in accordance with PCAPCD emissions limits contained in Rule 502.
The ambient air quality evaluation shall be submitted to PCAPCD for review and the City shall incorporate identified BACT controls and/or emissions offsets, if necessary, to ensure that emissions achieve all emissions limits contained in PCAPCD’s Rule 502.
Implementation of control technology and final site design shall be demonstrated prior to issuance of building permits.
Mitigation Measure 3.3-4: Implement Clean Construction Fleet (Phase 1 & 2) During all phases of project construction, all off-road diesel-powered construction equipment greater than 25 horsepower shall meet EPA’s Tier 4 emission standards, as defined in 40 CFR 1039, and comply with the appropriate test procedures and provisions contained in 40 CFR Parts 1065 and 1068. This measure can also be achieved by using battery-electric off-road equipment as it becomes available. The City shall require the primary construction contractor(s) and its subcontractor(s) to submit copies of the valid Certificate of Reported Compliance for their fleets prior to awarding a contract. In addition, all construction equipment shall be subject to inspection for regulatory compliance. Implementation of this measure shall be required in the contract the City establishes with its construction contractors.
Phase 1 & 2 Construction
contractor(s)
During construction ⎯
Mitigation Measure 3.3-5: Implement Facility Odor Reduction Plan (Phase 1 & 2) Prior to commencement of operations involving municipal green waste and food organics, the City shall prepare, implement, and maintain a comprehensive Odor Reduction Plan to minimize the potential for objectionable odors affecting existing and reasonably foreseeable future sensitive receptors. The Odor Reduction Plan shall apply to all odor-generating activities at the facility and shall be implemented for the life of the project. At a minimum, the Odor Reduction Plan shall include the following elements:
Phase 1 & 2 City of Roseville Prior to operation ⎯
Mitigation Monitoring and Reporting Program
City of Roseville
6 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
⯈ Odor source identification and controls
The Odor Reduction Plan shall identify all odor-generating sources, and for each source, the Odor Reduction Plan shall specify operational and engineering controls designed to minimize odor generation and release. Odor sources include, but are not limited to:
◾ receiving, unloading, sorting, handling, and temporary storage of municipal solid waste and organics within the material recovery facility and organics building enclosures;
◾ pre-processing and mixing of feedstocks; and
◾ management of residual materials and recyclables prior to off-site transport.
⯈ Odor sources associated with Phase 2 of the project include, but are not limited to:
◾ covered aerated static pile (ASP) composting operations; ◾ curing, screening, and product handling; and
◾ management of leachate or contact water, including associated contact water retention, reuse, and management facilities.
⯈ Receiving and material recovery building requirements To address the highest odor potential activities, the Odor Reduction Plan shall require that:
◾ reception and sorting of organic waste occur within the building enclosure, with doors closed except during active vehicle ingress and egress; ◾ the organics building enclosure be operated to minimize odor emissions, including use of enclosures, ventilation, and odor control measures as applicable (e.g., negative pressure and treatment through a biofilter, scrubber, or equivalent system, if deemed necessary);
◾ onsite staging time for unprocessed food organics be limited to a defined maximum duration of time not beyond the time necessary to move to the next stage, with covered or contained storage; and
◾ putrescible residuals and screened contaminants be stored in covered containers and removed from the site on a regular schedule sufficient to prevent odor buildup.
◾ housekeeping procedures be identified to minimize odor accumulation within processing and storage areas, including routine cleaning of floors, equipment, conveyors, tipping areas, loading areas, and management of spilled or accumulated waste materials, as appropriate.
Mitigation Monitoring and Reporting Program
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Roseville Environmental Utilities Operations Center Project EIR 7 Mitigation Measures Project Phase
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⯈ Covered aerated static pile operational controls
The Odor Reduction Plan shall include procedures to maintain aerobic conditions within covered ASP bays, including monitoring and management of aeration, moisture, pile conditions, and other compost operating parameters relevant to odor generation and control. Corrective actions shall be identified for upset conditions (e.g., power outages, aeration system failures, excessive moisture, or indications of anaerobic conditions) to promptly reduce odor potential. The Odor Reduction Plan shall also identify procedures to prevent and respond to anaerobic conditions, pile smoldering, smoking, prolonged anaerobic conditions, and other operational conditions that could increase odor emissions.
⯈ Odor monitoring, complaints, and adaptive management
The Odor Reduction Plan shall include an odor monitoring and response program consisting of:
◾ installation of odor sensors throughout the site, surrounding the compost, collection, sorting, transfer, storage, areas, and any ancillary process location or odor source (e.g., stationary combustion sources, waste water retention or treatment)
◾ routine odor patrols during operations and under meteorological conditions conducive to odor transport;
◾ a public odor complaint reporting system and complaint log; ◾ defined response times for investigating and addressing complaints; and ◾ adaptive management triggers (e.g., repeated verified offsite odor events or complaint patterns) that require implementation of additional corrective actions or operational changes. Corrective actions will vary depending upon the trigger but could include, and are not limited to, improved containment, increased treatment capacity, modified operations, increased monitoring and response, enhanced housekeeping practices, reduced material staging times, additional odor-control measures for composting operations, modifications to compost management practices, or additional engineering controls for odor capture and treatment.
If monitoring indicates that applicable controls are not met, the City shall implement corrective actions as soon as practical and within 7 days and increase monitoring and patrol frequency. The City shall also publish an annual report that summarizes complaints, response times, and measures implemented
Mitigation Monitoring and Reporting Program
City of Roseville
8 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
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to address complaints. This report shall be kept on file at the facility and made available to the public/PCAPCD upon request.
⯈ Documentation and updates
◾ The Odor Reduction Plan shall be kept on file at the facility, made available to the public/PCAPCD upon request, and updated as necessary to reflect changes in operations, waste streams, control technologies, or regulatory requirements
Greenhouse Gas Emissions
Mitigation Measure 3.4-1a: Use Low- or Zero-Emission Heavy-Duty Trucks and Equipment (Phase 2 only)
The City shall expedite a transition to zero GHG emission vehicles for all vehicle fleets that the City owns (i.e., no net increase in anthropogenic emissions [renewable diesel counts toward compliance]), with the applicable City fleet fully zero-emission by December 31, 2039 to coincide with Phase 2 becoming operational. The City shall ensure use of a “clean fleet” of vehicles/delivery vans/trucks (Class 2 through 7) as part of Phase 2 operations as follows:
⯈ For any vehicle (Class 2 through 6) domiciled at the project site, the following “clean fleet” requirements apply:
◾ 50 percent of the fleet shall be zero emissions by the year 2035, ◾ 100 percent of the fleet shall be zero emission vehicles by January 1, 2040. ◾ "Domiciled at the project site” shall mean the vehicle is either (1) parked or kept overnight at the project site more than 70 percent of the calendar year or (2) dedicated to the project site (defined as more than 70 percent of the truck routes (during the calendar year) that start at the project site even if parked or kept elsewhere). This applies to City vehicles and fleets that the City has direct control over, but not personal employee vehicles. ⯈ For on-site diesel-powered equipment, the following shall be required:
◾ During Phase 2 operations, all on-site diesel-powered equipment shall use 100 percent renewable diesel fuel. Alternatively, as comparable zeroemission equipment alternatives (e.g., renewable natural gas, electric) to diesel-powered equipment become available and existing equipment are replaced, they shall be replaced with such equipment.
This shall be enforced through bi-annual reports submitted for review by the City, submitted to the Placer APCD if so directed.
Phase 2 only City of Roseville During Phase 2 (biannually)⎯
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 9 Mitigation Measures Project Phase
Implementation
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Mitigation Measure 3.4-1b: Prepare an Emissions Capture and Control Plan (Phase 2 only) The following mitigation measure will be required if the City constructs and operates the Potential Future Organics Processing Facility. Prior to the approval of final design plans and issuance of any building or operating permits for a composting or biomass gasification facility developed under the project, the City shall prepare an Emissions Capture and Control Plan that shall demonstrate incorporation of best available methane capture and control technology that is reasonably expected to be commercially available and technically feasible at the time of facility construction (anticipated prior to 2040). At a minimum, the plan shall:
⯈ Technology Benchmarking: Identify and evaluate technologies anticipated to represent Best Available Control Technology (BACT) or Maximum Achievable Control Technology for methane and other short-lived climate pollutants (e.g., advanced biofilters, composting with negative aeration and gas collection, anaerobic digestion with biogas upgrading, or comparable capture systems). ⯈ Design Requirements: Include design features to achieve at least 95 percent capture efficiency of methane generated within process areas of the biomass gasification facility, or the highest level of capture demonstrated to be achievable at the time of permitting, whichever is greater. For composting operations, methane generation will be mitigated through implementation of BACT to optimize aerobic conditions and/or provide biofiltration appropriate to the technology application selected for the project.
⯈ Control System Integration: Ensure captured methane is directed to beneficial use (e.g., renewable natural gas production, combined heat and power) or, if beneficial use is not feasible, to destruction through flaring or equivalent hightemperature oxidation consistent with BACT for the biomass gasification facility.
Composting technology deployment will provide controls consistent with BACT, as described in the Design Requirements above.
⯈ Performance Verification: Incorporate monitoring, reporting, and verification protocols (continuous monitoring or periodic testing) to demonstrate ongoing compliance with methane capture and control performance standards.
Phase 2 only City of Roseville Prior to approval of
design plans or issuance
of a building permit
⎯
Biological Resources
Mitigation Measure 3.5-1: Conduct Special-Status Plant Surveys and Implement Avoidance Measures and Mitigation (Phase 1 & 2)
⯈ Prior to implementation of project activities within the PUE, and during the blooming period for the special-status plant species with potential to occur within the PUE (i.e., approximately May to October), a qualified botanist shall Phase 1 & 2 City of Roseville and a
qualified botanist
Prior to and during
construction
⎯
Mitigation Monitoring and Reporting Program
City of Roseville
10 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
conduct protocol-level surveys for special-status plants within the PUE following survey methods from CDFW’s Protocols for Surveying and Evaluating Impacts on Special-Status Native Plant Populations and Natural Communities (CDFW 2018 or most recent version). The qualified botanist shall: (1) be knowledgeable about plant taxonomy, (2) be familiar with plants of the Sacramento Valley region, including special-status plants and sensitive natural communities, (3) have experience conducting floristic botanical field surveys as described in CDFW 2018, (4) be familiar with the California Manual of Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/), and (5) be familiar with federal and state statutes and regulations related to plants and plant collecting. ⯈ If special-status plants are not found, the botanist shall document the findings in a report to the City of Roseville, and no further mitigation shall be required. ⯈ If special-status plant species are found during protocol-level surveys, the plant shall be avoided completely, if feasible (i.e., project objectives can still be met).
This may include establishing a no-disturbance buffer around the plants and demarcation of this buffer by a qualified biologist or botanist using flagging or high-visibility construction fencing. The size of the buffer shall be determined by the qualified biologist or botanist and shall be large enough to avoid direct or indirect impacts on the plant.
⯈ If special-status plants are found during special-status plant surveys and cannot be avoided, the City of Roseville shall, in consultation with CDFW as appropriate depending on the particular species, develop and implement a site-specific mitigation strategy to offset the loss of occupied habitat and individual plants.
Mitigation measures shall include, at a minimum, preserving and enhancing existing populations, establishing populations through seed collection or transplantation from the site that is to be affected, and/or restoring or creating habitat in sufficient quantities to achieve no net loss of occupied habitat or individuals. Potential mitigation sites could include suitable locations within or outside of the project site, with a preference for on-site mitigation. Habitat and individual plants lost shall be mitigated at a minimum 1:1 ratio, considering acreage as well as function and value. Success criteria for preserved and compensatory populations shall include:
◾ The extent of occupied area and plant density (number of plants per unit area) in compensatory populations shall be equal to or greater than the affected occupied habitat.
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 11 Mitigation Measures Project Phase
Implementation
Responsibility
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◾ Compensatory and preserved populations shall be self-producing.
Populations shall be considered self-producing when:
⦁ plants reestablish annually for a minimum of five years with no human intervention such as supplemental seeding; and
⦁ reestablished and preserved habitats contain an occupied area and flower density comparable to existing occupied habitat areas in similar habitat types in the project vicinity.
If off-site mitigation includes dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures, the details of these measures shall be included in the mitigation plan, including information on responsible parties for long-term management, conservation easement holders, long-term management requirements, success criteria such as those listed above and other details, as appropriate to target the preservation of long-term viable populations.
Mitigation Measure 3.5-2a: Conduct Preconstruction Surveys for Northwestern Pond Turtle, Implement Avoidance Measures, and Relocate Individuals (Phase 1 & 2) ⯈ Prior to implementation of project activities within the project site, a qualified biologist familiar with the life history of northwestern pond turtles and experienced in performing surveys for northwestern pond turtle shall conduct a focused survey of aquatic habitat and upland habitats suitable for the species within approximately 1,600 feet of aquatic habitat. The qualified biologist shall inspect the project site for northwestern pond turtles as well as burrow habitat suitable for the species.
⯈ If northwestern pond turtles are not detected during the focused survey, the qualified biologist shall submit a report summarizing the results of the survey to the City of Roseville, and further mitigation will not be required. ⯈ If northwestern pond turtles are detected, a no-disturbance buffer of at least 100 feet shall be established around any identified nest sites or overwintering sites. These nest and overwintering sites shall be monitored until the northwestern pond turtles have left the nest on their own accord. ⯈ A qualified biologist with an appropriate CDFW Scientific Collecting Permit that allows handling of reptiles shall be present during initial ground disturbance activities and shall inspect the project site before initiation of project activities. If northwestern pond turtles are detected, the qualified biologist shall move the turtles downstream and out of harm’s way.
Phase 1 & 2 City of Roseville and a
qualified biologist
Prior to project approval,
before and during
construction
⎯
Mitigation Monitoring and Reporting Program
City of Roseville
12 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
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Mitigation Measure 3.5-2b: Provide Stream Setbacks, Best Management Practices (Phase 1 & 2)
Although the project would have a buffer between the edge of construction and Pleasant Grove Creek of between 930 and 1,614 feet, the following protection measure shall be implemented during construction:
⯈ Prior to the start of construction activities on the project site, the limits of disturbance shall be established, flagged or fenced with brightly visible construction flagging and or fencing under the direction of a qualified biologist, and no project activities (e.g., vegetation removal, ground disturbance, staging) shall occur beyond these areas. All workers and contractors shall be made aware that this area is an environmentally sensitive area and it is off-limits. After construction is completed, this temporary fencing shall be removed from the area.
Phase 1 & 2 City of Roseville and a
qualified biologist
During construction ⎯
Mitigation Measure 3.5-2c: Develop and Integrate a Nuisance Wildlife Management Plan into the City’s Environmental Utilities Facility Management Plan (Phase 1 & 2) ⯈ The City shall develop a nuisance wildlife management plan and incorporate it into the City’s Environmental Utilities Facility Management Plan that includes BMPs to minimize attracting nuisance wildlife, ensuring the measures comply with local, state and federal regulations.
Phase 1 & 2 City of Roseville Prior to construction ⎯
Mitigation Measure 3.5-2d: Conduct Preconstruction Surveys for Western Spadefoot, Implement Avoidance Measures, and Relocate Individuals (Phase 1 only) ⯈ Within three days of commencement of ground-disturbing activities, a qualified biologist familiar with the life history of western spadefoot and experienced in performing surveys for western spadefoot shall conduct a focused survey of wetland habitat in the PUE. The qualified biologist shall inspect the project site for western spadefoot, western spadefoot tadpoles and eggs, and suitable terrestrial and overwintering habitat (i.e., burrows).
◾ If an overwintering western spadefoot, western spadefoot tadpoles, or western spadefoot eggs are observed on the project site during the preconstruction survey, the area shall be fenced off and avoided until the eggs hatch, tadpoles develop, and/or the burrow is no longer active, as determined by a qualified biologist. The fenced area shall be open on one side with the opening facing the nearest aquatic or upland dispersal habitat so that young or overwintering western spadefoot can freely travel from the fenced area to the aquatic or dispersal habitat. A qualified biologist shall monitor the nest area to ensure that western spadefoot do not disperse into the construction area. Monitoring shall occur until the Phase 1 only City of Roseville and a
qualified biologist
Prior to and during
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qualified biologist determines the area to no longer be actively occupied by western spadefoot.
◾ A qualified biologist shall be present during all ground-disturbing activities to monitor these activities. If a western spadefoot is encountered, work shall be suspended in a 100-foot radius of the animal until the animal leaves the project site of its own volition. If necessary, a qualified biologist shall notify CDFW to determine the appropriate procedures related to relocation, which shall include, but not be limited to, obtaining a valid and applicable CDFW Scientific Collecting Permit. Any worker who inadvertently injures or kills a western spadefoot or who finds a western spadefoot dead, injured, or entrapped must immediately report the incident to the City, who must immediately notify CDFW. Entrapped western spadefoot shall be relocated by a qualified biologist with a valid and applicable CDFW Scientific Collecting Permit if approved by CDFW. ⦁ Because western spadefoot is proposed for listing under ESA, if the species is listed before completion of project construction activities that could result in injury or mortality of western spadefoots (i.e., ground disturbance, grading, land conversion), then the City may be required to consult with USFWS under Section 7 or Section 10 of ESA.
If it is determined, in consultation with USFWS, that take of this species could occur after implementation of the measures described above, then the City may be required to obtain incidental take authorization through Section 7 consultation or a Section 10 permit pursuant to ESA. In this case, the project shall not proceed until a Biological Opinion is issued by USFWS. Any conservation measures developed in coordination with USFWS during the course of formal or informal consultation under Section 7 or during Section 10 consultation would supersede the measures listed here.
⦁ Such conservation measures could include, but would not be limited to, seasonal work restrictions for initial ground disturbance, preconstruction surveys by a qualified biologist, installation of wildlife exclusion fencing, biological monitoring, and worker environmental awareness training. Additional measures could include preservation, restoration, or enhancement of habitat on-of off-site; purchase of habitat credits from an agency-approved mitigation/conservation bank; work with a local land trust to preserve land; or any other method acceptable to USFWS.
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⦁ If USFWS determines that listing of western spadefoot under ESA is not warranted, or the species is not listed prior to project completion, then the above measures related to consultation with USFWS would not be applicable.
Documentation of compliance with this mitigation measure and the coordination/consultation process with CDFW shall be provided to the City of Roseville before commencement of any project construction activities.
Mitigation Measure 3.5-2e: Conduct Pre-construction Vernal Pool Avoidance Surveys, Protocol-Level Branchiopod Surveys, and Compensate for Loss of Vernal Pool Branchiopods (Phase 1 only)
⯈ Prior to implementation of project activities in the PUE, wetland and vernal pool habitat in the PUE area shall be delineated and a no-disturbance buffer of at least 100 feet will be implemented, as determined by a qualified biologist. No project activities, including staging of equipment, will occur within the nodisturbance buffer, if feasible. ⯈ If the no-disturbance buffer is not feasible, a qualified biologist familiar with vernal pool branchiopods shall conduct a focused survey for vernal pool fairy shrimp and vernal pool tadpole shrimp, following Survey Guidelines for the Listed Large Branchiopods (USFWS 2017), or any subsequently published guidelines. Protocol-level surveys for branchiopods require authorization from the USFWS Sacramento Fish and Wildlife Office and a Section 10(a)(1)(A) permit. ⯈ The City of Roseville shall report all survey results to USFWS. If no vernal pool branchiopods are identified, no further mitigation shall be required. ⯈ If vernal pool branchiopods are identified on the project site, the City shall initiate Section 7 consultation with USFWS. USACE is presumed to be the federal action agency because it has jurisdiction over the aquatic habitat on the project site. If it is determined, in consultation with USFWS, that take of these species will occur as a result of project activities, then the City may be required to obtain incidental take authorization pursuant to Section 7 of ESA. The project shall not proceed until a Biological Opinion is issued by USFWS. ◾ Any conservation measures developed in coordination with USFWS during formal or informal consultation under Section 7 shall be implemented. ◾ Additional measures may include preservation, restoration, or enhancement of habitat on- or off-site; purchase of habitat credits from an agency-approved mitigation/conservation bank; work with a local land Phase 1 only City of Roseville and a
qualified biologist
Prior to construction ⎯
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trust to preserve land; or any other method acceptable to USFWS at a nonet-loss level.
Mitigation Measure 3.5-2f: Conduct Take Avoidance Surveys for Crotch’s Bumble Bee and Implement Avoidance Measures (Phase 1 & 2)
⯈ A qualified biologist familiar with bumble bees of California and experienced using survey methods for bumble bees shall conduct a habitat assessment and focused survey for Crotch’s bumble bees before the start of any grounddisturbing activities. Surveys shall be performed when Crotch’s bumble bee is most likely to be identified, typically from April through August when floral resources and ideal weather conditions are present and shall follow the methods in Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species (CDFW 2023) or any subsequent protocol approved by CDFW. Surveys shall be conducted during the colony active period closest to the start of planned construction activities. At least three (3) on-site surveys shall take place prior to the initiation of ground disturbing activities.
Each survey shall be spaced 2-4 weeks apart during the Colony Active Period. ⯈ The City of Roseville shall submit a survey report to CDFW within 1 month of survey completion and shall notify CDFW within 24 hours if Crotch’s bumble bees are detected.
⯈ If Crotch’s bumble bees are detected during the focused surveys, appropriate avoidance measures shall be implemented. Avoidance measures may include, but not be limited to, the following:
⯈ Protective buffers shall be implemented around active nesting colonies or overwintering queens until these sites are no longer active. A qualified biologist, in consultation with CDFW, shall determine the appropriate buffer size to protect nesting colonies or overwintering queens.
⯈ If impacts on crotch’s bumble bee cannot be avoided, the City shall obtain an incidental take permit (ITP) from CDFW and shall implement all measures included in the ITP to reduce the amount of take and offset the loss of individuals or their habitat from the project site and provide compensatory mitigation for the loss of individuals or habitat.
⯈ Compensatory mitigation for the loss of individual bumblebees or their habitat may include:
1. Preserving existing habitat outside of the project site in perpetuity; this may entail purchasing mitigation credits and/or lands from a CDFW- or USFWSPhase 1 & 2 City of Roseville and a qualified biologist
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approved entity in sufficient quantity to offset the residual significant impacts, generally at a ratio of 1:1 for habitat; and
2. Restoring or enhancing existing habitat within the project site or outside of the project site but within the range of the species in the City limits. ⯈ The City shall prepare a Compensatory Mitigation Plan that identifies the residual significant effects that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects:
a. For preserving existing habitat outside of the project site in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanisms for longterm conservation (e.g., holder of conservation easement or fee title). The City shall submit evidence that the necessary mitigation has been implemented or that the City has entered into a legal agreement to implement it and that compensatory habitat will be preserved in perpetuity. b. For restoring or enhancing habitat within or outside of the project site, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored habitat.
Mitigation Measure 3.5-2g: Conduct Take Avoidance Survey for Monarch Eggs, Larvae and Pupae, and Implement Avoidance Measures (Phase 1 & 2) ⯈ No more than 14 days prior to implementing project activities that would result in ground disturbance or vegetation removal during the time when milkweed plants could host monarch eggs or caterpillars (approximately mid-March through late September), a qualified biologist shall conduct focused surveys for milkweed plants and inspect these plants for monarch eggs, larvae (i.e., caterpillars), and pupae. If monarch eggs, caterpillars, or pupae are found, the host plants shall be avoided until metamorphosis is completed and adult butterflies emerge and leave the host plant. If no eggs, caterpillars or pupae are detected, the qualified biologist shall submit a report summarizing the results of the survey to the City of Roseville, and further mitigation shall not be required.
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Mitigation Measure 3.5-2h: Conduct Focused Surveys for Special-Status Birds, Nesting Raptors, and Other Native Nesting Birds and Implement Protective Buffers; and Mitigate for the Loss of Swainson’s Hawk Foraging Habitat (Phase 1 & 2) ⯈ To minimize the potential for loss of special-status bird species, raptors, and other native birds, project construction activities (e.g., tree removal, vegetation clearing, ground disturbance, staging) shall be conducted during the nonbreeding season (approximately September 1-January 31, as determined by a qualified biologist), if feasible. If project construction activities are conducted during the nonbreeding season, and before January 1, no further mitigation shall be required.
⯈ If project construction activities, including tree removal, occur after January 1 but before February 1, a preconstruction survey for nesting great-horned owl shall take place. This survey shall be conducted within 500 feet of the development area where activities or tree removals are to take place. If no nesting great-horned owls are found, the qualified biologist shall prepare and submit a report summarizing the result of the survey to the City of Roseville, and construction or tree removals can move forward. If nesting great-horned owls are found, impacts on nesting great-horned owls shall be avoided by establishing a 500-foot buffer around the active nest site(s) identified during focused surveys to prevent disturbance to the nest. Project construction activity shall not commence within the buffer areas until a qualified biologist has determined that the young have fledged, the nest is no longer active, or reducing the buffer will not likely result in nest abandonment. ⯈ Within 14 days before the onset of project construction activities during the breeding season of other birds besides great-horned owl (approximately February 1 through August 31, as determined by a qualified biologist), a qualified biologist familiar with birds of California and with experience conducting nesting bird surveys shall conduct focused surveys for special-status birds, other nesting raptors, and other native birds. Surveys shall be conducted within 0.25 miles of the project site for Swainson’s hawk; within 500 feet of the project site for other special-status birds and common raptors; and within 50 feet of the project site for non-raptor common native bird nests. ⯈ Because the nests of riparian-nesting birds (i.e., song sparrow [“Modesto” population], tricolored blackbird, and western yellow-billed cuckoo) are small and difficult to find, occupancy of habitat suitable for these species (i.e., riparian woodland) shall be determined by a qualified biologist familiar with the life history of these species and with experience identifying the calls of these species. If special-status riparian-nesting birds are observed calling, exhibiting Phase 1 & 2 City of Roseville and a
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territorial displays, carrying nest materials, carrying prey, or other signs of breeding behavior, the habitat shall be considered occupied. ⯈ If no nests are found, the qualified biologist shall submit a report documenting the survey methods and results to the City of Roseville, and no further mitigation shall be required.
⯈ Impacts on nesting birds shall be avoided by establishing appropriate buffers around active nest sites identified during focused surveys to prevent disturbance to the nest. Project construction activity shall not commence within the buffer areas until a qualified biologist has determined that the young have fledged, the nest is no longer active, or reducing the buffer will not likely result in nest abandonment. An avoidance buffer of a minimum of 0.25 miles shall be implemented for Swainson’s hawk in consultation with CDFW. An avoidance buffer of a minimum of 500 feet shall be implemented for western yellow-billed cuckoo in consultation with USFWS and CDFW and for tricolored blackbird in consultation with CDFW. Buffers typically will be 500 feet for other specialstatus birds and common raptors. For other species, a qualified biologist shall determine the size of the buffer for non-raptor nests after a site- and nestspecific analysis. Factors to be considered for determining buffer size will include presence of natural buffers provided by vegetation or topography, nest height above ground, baseline levels of noise and human activity, species sensitivity, and proposed project construction activities. Generally, buffer size for these species will be at least 20 feet. The size of the buffer may be adjusted if a qualified biologist determines that such an adjustment would not be likely to adversely affect the nest. Any buffer reduction for a special-status species shall require consultation with CDFW. Periodic monitoring of the nest by a qualified biologist during project construction activities shall be required if the activity has potential to adversely affect the nest, the buffer has been reduced, or if birds within active nests are showing behavioral signs of agitation (e.g., standing up from a brooding position, flying off the nest) during project construction activities, as determined by the qualified biologist. ⯈ The City shall mitigate for the loss of 51.63 acres of Swainson’s hawk foraging habitat by purchasing foraging habitat credits at a CDFW-approved mitigation bank in the area at a 1:1 ratio for each acre of foraging habitat removed by the project. This mitigation shall occur before the approval of any grading or improvement plans for the project.
⯈ If egret or night heron rookeries are found within trees on the project site, an avoidance buffer shall be implemented, the size of which will be determined by a qualified biologist. Buffer size for large rookeries will likely be larger than for
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single nests due to the number of birds and nests within the rookery. Rookery trees identified on the project site shall be retained permanently.
Mitigation Measure 3.5-2i: Conduct Focused Surveys for Northern California Ringtail Dens and Implement Avoidance Measures (Phase 1 & 2)
⯈ To minimize the potential loss of ringtail and active ringtail dens, tree removal within the development area on the project site shall be conducted outside of the ringtail breeding season (not well defined, but likely approximately March 1 to July 31), if feasible.
⯈ Within seven days before initiation of tree removal within the development area on the project site or demolishing or repurposing of the associated buildings during the ringtail breeding season, a qualified biologist familiar with ringtail shall conduct a focused survey for potential ringtail dens (e.g., hollow trees, snags) within the trees planned for removal, and buildings within the development area of the project site. The qualified biologist shall identify individual ringtails, as well as potential dens.
⯈ If individuals or occupied dens are not found, the qualified biologist shall submit a report summarizing the results of the survey to the City of Roseville, and further mitigation shall not be required.
⯈ If ringtails are identified or if potential dens are found in the trees planned for removal or within one of the existing unoccupied buildings, an appropriate method, based on current professional standards, shall be used by the qualified wildlife biologist to confirm whether a ringtail is occupying the den. This may include use of remote field cameras, track plates, or hair snares. Other devices, such as a fiber optic scope, may be utilized to determine occupancy. ◾ If no ringtail occupies the potential den, the tree or structure may be removed.
◾ If a den is found to be occupied by a ringtail, the tree or building may not be removed, and a no-disturbance buffer shall be established around the occupied den. The no-disturbance buffer shall include the den tree or building plus a suitable buffer as determined by the biologist in coordination with CDFW. Project activities in the no-disturbance buffer shall be avoided until the den is no longer occupied as determined by the qualified wildlife biologist in coordination with CDFW.
Phase 1 & 2 City of Roseville and a
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Mitigation Measure 3.5-2j: Conduct Focused Bat Surveys and Implement Avoidance Measures (Phase 1 & 2)
⯈ Prior to tree removal activities and demolition or repurposing of existing buildings, a qualified biologist familiar with bats and bat ecology and experienced in conducting bat surveys shall conduct surveys for bat roosts in large trees and existing buildings on the project site. ⯈ If no evidence of bat roosts is found, the qualified biologist shall submit a report summarizing the results of the survey to the City of Roseville, and no further mitigation will be required.
⯈ If evidence of bat roosts is observed, the species and number of bats using the roost shall be determined. Bat detectors shall be used if deemed necessary to supplement survey efforts by the qualified biologist.
⯈ A no-disturbance buffer of 250 feet shall be established around active pallid bat or western red bat roosts, and project construction activities shall not occur within this buffer until the roosts are no longer occupied by bats as determined by a qualified biologist.
⯈ If roosts of pallid bat or western red bat are determined to be present and must be removed, the bats shall be excluded from the roosting site before the tree or structure is removed. A program addressing compensation, exclusion methods, and roost removal procedures shall be developed in consultation with CDFW before implementation. Exclusion efforts may be restricted during periods of sensitive activity (e.g., during hibernation or while females in maternity colonies are nursing young). The loss of each roost (if any) shall be replaced in consultation with CDFW and may require construction and installation of bat boxes suitable to the bat species and colony size excluded from the original roosting site. If determined necessary during consultation with CDFW, replacement roosts shall be implemented before bats are excluded from the original roost sites. Once the replacement roosts are constructed and it is confirmed that bats are not present in the original roost site by a qualified biologist, the roost tree or building may be removed, demolished, or repurposed.
Phase 1 & 2 City of Roseville and a
qualified biologist
Prior to and during
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Mitigation Measure 3.5-2k: Conduct Preconstruction Surveys for Western Burrowing Owl and Implement Avoidance Measures (Phase 1 & 2)
⯈ A qualified biologist shall conduct surveys for burrowing owls in areas of habitat suitable for the species on and within 1,640 feet (500 meters) of the project site. Inaccessible areas (e.g., adjacent private property) will not be surveyed directly if access is not granted, but the biologist may use binoculars Phase 1 & 2 City of Roseville and a
qualified biologist
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or a spotting scope to survey these areas from the project site or other publicly accessible areas. A minimum of four surveys shall be conducted to determine whether burrowing owls occupy habitats on or within 1,640 feet of the project site. Surveys shall be conducted according to Appendix D of the 2012 Staff Report on Burrowing Owl Mitigation prepared by the California Department of Fish and Game (now CDFW) (CDFG 2012), or any subsequent updated guidance. If feasible, at least one survey should be conducted between February 15 and April 15 and the remaining surveys should be conducted between April 15 and July 15, at least three weeks apart. Because burrowing owls may recolonize a site after only a few days, one of the surveys, or an additional survey, shall be conducted no less than 14 days before initiating ground disturbance activities to verify that take of burrowing owl would not occur. During the non-breeding season (September 1 to January 31), surveys will document whether burrowing owls are using habitat in or directly adjacent to any area to be disturbed by project activities. Survey results will be valid only for the season (breeding or non-breeding) during which the survey was conducted.
⯈ If no burrowing owls are found, the qualified biologist shall submit a report documenting the survey methods and results to the City, and no further mitigation shall be required.
⯈ If a burrow occupied by a burrowing owl is found during the surveys, the City shall establish and maintain a buffer around the occupied burrow and any identified satellite burrows (i.e., burrows used to escape predators or move young into after hatching) to prevent take of the burrowing owls. ◾ During the non-breeding season (September 1 through January 31), the minimum buffer distance shall be 164 feet (50 m). During the breeding season (February 1 through August 31), the minimum buffer distance shall follow CDFW’s recommended buffers depending on the level of disturbance.
◾ The buffer may be adjusted if, in consultation with CDFW, a qualified biologist determines that an alternative buffer would not result in take of burrowing owl adults, young, or eggs because of particular site features (e.g., topography, natural line-of-sight barriers), level of project disturbance, or other considerations. If the buffer is reduced, a qualified biologist shall monitor the behavior of the burrowing owls during all project activities within 1,640 feet of the burrow. If the owls are disturbed or agitated (e.g., vocalizations, bill snaps, fluffing feathers to increase body size appearance, drooping wings and rotating them forward, crouching
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and weaving back and forth) by the project activities, the biologist shall have the authority to halt the activities and re-establish a buffer consistent with the first bullet until the agitated behavior ceases and normal behavior resumes.
◾ The buffer shall remain in place around the occupied burrow and associated satellite burrows until a qualified biologist has determined through noninvasive methods that the burrows are no longer occupied by burrowing owl. A previously occupied burrow will be considered unoccupied if surveys demonstrate that no owls have used the burrow for seven consecutive days.
◾ Locations of burrowing owls detected during surveys shall be reported to the CNDDB.
⯈ If implementation of a buffer to prevent take of burrowing owl is not feasible, the City shall consult with CDFW and obtain an Incidental Take Permit (ITP) prior to commencing project related ground-disturbing activities. The impacts of taking burrowing owl shall be minimized and fully mitigated. ⯈ If take occurs, the City shall compensate for the loss of burrowing owl by establishing permanent protection and perpetual management on land that provides burrowing owl habitat. Habitat management lands for burrowing owl may be established by conservation easement or fee title, or credits may be purchased from a CDFW-approved conservation or mitigation bank. The compensatory mitigation shall satisfy permit conditions and all other permit conditions shall be implemented.
⯈ The City shall decommission the rice fields and other active agricultural areas on the project site only after these areas have been surveyed for burrowing owls as indicated above. Decommissioning of rice fields and other agricultural areas shall include the removal of all irrigation and drainage components, including pipe culvert, rice trunks/sluice boxes, and any other debris from the area.
⯈ All demolition debris shall be removed from the site to prevent wildlife from using the debris as shelter. Demolition debris may be stored in covered containers immediately prior to off-site transport.
⯈ Laydown materials areas shall be maintained and monitored so that materials and equipment do not attract or provide shelter habitat for wildlife. Pipes or other construction materials that could provide burrow surrogate habitat shall be kept covered or sealed.
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Mitigation Measure 3.5-3: Provide Stream Setbacks, Best Management Practices, and Compensate for Unavoidable Loss of Riparian Habitat (Phase 1 only) The City shall implement the following protection measures prior to implementation of project activities (e.g., construction, staging) within 50 feet of valley oak riparian woodland habitat on the project site:
⯈ Setbacks shall be established around all valley oak riparian woodland habitat on the project site and shall be flagged or fenced with brightly visible construction flagging and/or fencing under the direction of the qualified biologist and no project activities (e.g., vegetation removal, ground disturbance, staging) shall occur within these areas. Setback distances shall be determined by a qualified biologist in consultation with the appropriate agency (e.g., CDFW), but will generally be a minimum of 50 feet. Foot traffic by personnel shall also be limited in these areas to prevent the introduction of invasive or weedy species or inadvertent crushing of plants and soil compaction. Periodic inspections during construction shall be conducted by a qualified biologist to maintain the integrity of exclusion fencing/flagging throughout the period of construction involving ground disturbance.
⯈ If project implementation cannot avoid and thus may adversely affect the bed, bank, channel, or associated riparian habitat subject to CDFW jurisdiction under California Fish and Game Code Section 1602, the following measures shall apply.
◾ A Streambed Alteration Notification shall be submitted to CDFW, pursuant to Section 1602 of the California Fish and Game Code. If proposed project activities are determined to be subject to CDFW jurisdiction, the City shall abide by the measures to protect fish and wildlife resources required by any executed agreement prior to any vegetation removal or activity that may affect the resource. Measures to protect fish and wildlife resources shall include, at a minimum, a combination of the following mitigation. ◾ The City shall compensate for the loss of riparian habitat and habitat function and value of this habitat by:
⦁ restoring riparian habitat function and value within the project site; ⦁ restoring degraded riparian habitat outside of the project site; ⦁ purchasing riparian habitat credits at a CDFW-approved mitigation bank; or
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⦁ preserving existing riparian habitat of equal or better value to the affected riparian habitat through a conservation easement at a sufficient ratio to offset the loss of riparian habitat function (at least 1:1). ◾ The City shall prepare and implement a Compensatory Mitigation Plan that will include the following:
⦁ For preserving existing riparian habitat outside of the project site in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., holder of conservation easement or fee title). The City will provide evidence in the plan that the necessary mitigation has been implemented or that the City has entered into a legal agreement to implement it and that compensatory habitat will be preserved in perpetuity.
⦁ For restoring or enhancing riparian habitat within the project site or outside of the project site, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored or enhanced habitat.
⦁ Compensatory mitigation may be satisfied through compliance with permit conditions, or other authorizations obtained by the City (e.g., Lake and Streambed Alteration Agreement), if these requirements are equally or more effective than the mitigation identified above.
Mitigation Measure 3.5-4a: Implement Mitigation Measure 3.5-3 (Phase 1 only) The City shall implement Mitigation Measure 3.5-3, described above.
See Mitigation Measure
3.5-3, above
See Mitigation Measure
3.5-3, above
See Mitigation Measure
3.5-3, above
See Mitigation
Measure 3.5-3,
above
Mitigation Measure 3.5-4b: Identify State or Federally Protected Wetlands, Implement Avoidance Measures, and Obtain Permits for Unavoidable Impacts on Wetlands (Phase 1 only)
The following measures shall be implemented prior to initiation of project construction activities:
⯈ The City shall retain a qualified biologist, hydrologist, or wetland ecologist to prepare a formal delineation of the boundaries of state or federally protected Phase 1 only City of Roseville and a
qualified biologist,
hydrologist, or wetland
ecologist
Prior to construction ⎯
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wetlands and other waters within the project site according to methods established in the USACE wetlands delineation manual (Environmental Laboratory 1987) and the Arid West regional supplement (USACE 2008). The qualified biologist shall also delineate the boundaries of wetlands that may not meet the definition of waters of the United States, but would qualify as waters of the state, according to the state wetland procedures (SWRCB 2019). This delineation report shall be submitted to USACE, and a preliminary jurisdictional determination shall be requested.
⯈ Where state or federally protected wetlands can be avoided, the boundary of the delineated ordinary high-water mark shall be demarcated with highvisibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). Project activities (e.g., ground disturbance, vegetation removal, staging) shall be prohibited within the established boundary. A qualified biologist shall periodically inspect the materials demarcating the buffer to confirm that they are intact and visible, and wetland impacts are being avoided.
⯈ Authorization for fill of waters of the United States associated with project activities, including utility installation in the PUE, shall be secured from USACE through the Section 404, Section 10, and Section 408 permitting processes, as well as through CVFPB. Any state or federally protected wetlands that would be affected by the project shall be replaced or restored on a no-net-loss basis in accordance with the applicable USACE mitigation guidelines in place at the time of construction. In association with the Section 404 permit (if applicable) and prior to the issuance of any grading permit, Section 401 Water Quality Certification from the Central Valley RWQCB shall be obtained. For any activity that may result in discharges of dredged or fill material to waters of the state that may not be covered by the 401 Water Quality Certification, Panattoni shall secure a permit from the Central Valley RWQCB and provide compensatory mitigation for permanent loss of any waters of the state in accordance with State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (California Water Boards 2019), such that the project would not result in a net loss of overall abundance, diversity, and condition of aquatic resources within the affected watershed based on a watershed assessment using an assessment method approved by the permitting authority (e.g., Central Valley RWQCB or California Water Resources Control Board). The City shall comply with waste discharge requirements as described in Section 3.12, “Hydrology and Water Quality.”
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⯈ The City shall notify CDFW before commencing activity that may divert the natural flow or otherwise alter the bed, bank, or riparian corridor of any stream protected pursuant to Section 1602 of the Fish and Game Code. If project activities trigger the need for a Streambed Alteration Agreement, the proponent shall obtain an agreement from CDFW before the activity commences. The City shall conduct project construction activities in accordance with the agreement, including implementing reasonable measures in the agreement necessary to protect the fish and wildlife resources, when working within the bed or bank of waterways or in riparian habitats associated with those waterways. These measures may include but not be limited to demarcation of the construction area, biological monitoring, environmental awareness training for construction crews, and compensatory measures (e.g., restoration, long-term habitat management). Compensatory mitigation for impacts on state or federally protected wetlands, described in the prior bullet, may count towards compensation for loss of fish and wildlife resources protected pursuant to CDFW’s jurisdiction pursuant to Section 1602 of the Fish and Game Code.
⯈ The City shall obtain a permit for the installation of utility infrastructure in the PUE, or shall obtain an amendment to existing Army Permit #200200666 which previously permitted work in the PUE. The new permit or amendment shall be obtained through USACE in coordination with USFWS and additional agencies as required. The City shall adhere to all requirements of the new or amended permit, which may include the mitigation of any wetland habitat loss in the PUE through the purchase of equivalent wetland credits at an approved mitigation bank within the project’s service area.
⯈ The City shall prepare a hydrologic study to characterize existing site hydrology and ensure that project implementation and operation would not result in a substantial change to off-site hydrologic conditions within 250 feet from the project’s disturbance boundary. Based on the study findings, the City shall establish and implement appropriate buffers, as warranted, to avoid substantial adverse effects on off-site seasonal wetlands.
Mitigation Measure 3.5-5: Utilize Wildlife-Friendly Building Design (Phase 1 only) In addition to Mitigation Measure 3.1-3, described in Section 3.1, “Aesthetics and Visual Resources,” the City shall implement the following measures:
⯈ Buildings and other permanent structures shall be designed to minimize impacts on wildlife, including disruption to wildlife movement.
Phase 1 only City of Roseville During project design
and construction
⎯
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 27 Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
◾ Building design shall utilize guidelines regarding building height, materials, external lighting, and landscaping provided in the American Bird Conservancy’s “Bird Friendly Building Design” (American Bird Conservancy 2015).
⯈ The City shall place structural barriers to screen construction lighting and construction vehicular headlights that are directed perpendicular to Pleasant Grove Creek. This may be accomplished through the placement of a 5-6-foot vegetated hedge or other structural method that would screen the northern portion of the project. The City shall also implement measures to minimize spillover of construction lighting onto nearby Placer Conservation Authority reserve properties, including the use of shielded fixtures, directional lighting, and other lighting controls as necessary.
⯈ To minimize light spillage from the project during operation into Pleasant Grove Creek and the nearby Placer Conservation Authority reserve properties, outdoor lighting shall be the minimum wattage required for the particular use, shall be shielded, and shall be directed to the specific location intended for illumination to prevent stray light spillover onto sensitive riparian habitat.
Mitigation Measure 3.5-6: Remove and Replace Protected Trees Consistent with Chapter 19.66 of the City of Roseville Municipal Code, “Tree Preservation” (Phase 1 & 2) The City would implement the following measures to avoid or compensate for impacts on protected trees and comply with the City of Roseville Municipal Code (Chapter 19.66).
⯈ The City shall retain an ISA-certified arborist to survey the trees within the project site and prepare an arborist report that meets the requirements under the City of Roseville Municipal Code.
⯈ Prior to the start of construction activities (i.e., ground disturbance, tree removal, staging), the City or its contractor shall apply for a Tree Permit from the City of Roseville. The application shall include the arborist report and a site plan map with information deemed necessary by the City Planning Manager.
The site plan map shall include physical characteristics of the project (e.g., property lines, existing and proposed buildings and structures, existing and proposed grades), tree locations, and the location of the protected zone of each protected tree.
⯈ The number, location, species, health, and sizes of all protected trees to be removed, relocated, or replaced shall be identified. This information shall also be provided on a map or design drawing to be included in the project plans.
Phase 1 & 2 City of Roseville and ISAcertified arboristPrior to construction ⎯
Mitigation Monitoring and Reporting Program
City of Roseville
28 Roseville Environmental Utilities Operations Center Project EIR Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
⯈ Protected trees that would be retained on the project site would be subject to tree preservation measures as outlined in the code, including protective fencing, signing, and modified ground disturbance activities (e.g., trenching with hand tools).
⯈ The City shall compensate for the loss of protected trees using one of the following four methods, as approved by the City Planning Manager:
replacement of trees, relocation of trees, revegetation, or in-lieu mitigation fees. ⯈ The City Planning Manager may allow removal of a protected tree that has been certified by an arborist to be a dead tree without any replacement or mitigation requirements.
Cultural Resources
Mitigation Measure 3.6-1a: Conduct Records Search and Archaeological Resources Surveys for Off-Site Utilities, and Avoid Archaeological Resources (Phase 1 only) Once the final design and route of off-site utilities have been determined, and at least a month prior to the start of construction, a qualified archeologist who meets the US Secretary of the Interior Professional Qualifications Standards for Archaeology shall conduct a records search and perform archeological resources surveys for the off-site utilities that have not yet been surveyed. For the purposes of this mitigation measure, all archaeological resources discovered during surveys shall be assumed to be unique archaeological resources or historical resources as defined by State CEQA Guidelines Section 15064.5 and will be recorded by a qualified archaeologist on a California Department of Parks and Recreation DPR 523 primary form or equivalent documentation. Each such resource will be indicated, such as via a GIS device, through Environmentally Sensitive Area (ESA) mapping, with flagging tape, safety fencing, and/or signage designating it as an ESA to ensure that construction crews and heavy equipment will not intrude on these sites during construction. At the discretion of the City, monitoring may be done in lieu of or in addition to marking. If it is determined that the project cannot avoid impacts on one or more of the sites, then the City shall redesign the project site so that the archaeological sites will be completely avoided.
Phase 1 only Qualified archaeologist
and City of Roseville
Prior to construction ⎯
Mitigation Monitoring and Reporting Program
City of Roseville
Roseville Environmental Utilities Operations Center Project EIR 29 Mitigation Measures Project Phase
Implementation
Responsibility
Timing Verification
Mitigation Measure 3.6-1b: Halt Ground Disturbance Upon Discovery of Subsurface Archaeological Features (Phase 1 & 2)
In the event that any subsurface archaeological features or deposits, including locally darkened soil (“midden”) and concentrations of charcoal, flaked stone, glass, metal, or ceramic, are discovered during construction, all ground-disturbing activity within 100 feet of the find shall be halted and a qualified professional archaeologist shall be retained to assess the significance of the find. If the qualified archaeologist determines the archaeological material to be Native American in nature, the applicant shall contact the appropriate Native American tribe for their input on the preferred treatment of the find (consistent with Mitigation Measure 3.7-1b). If the find is determined to be significant (i.e., because it is determined to constitute a unique archaeological resource), the archaeologist shall develop, and the applicant shall implement, appropriate procedures to protect the integrity of the resource and ensure that no additional resources are affected. Procedures could include but would not necessarily be limited to preservation in place, archival research, subsurface testing, or contiguous block unit excavation and data recovery.
Phase 1 & 2 Qualified archaeologist
and construction
contractors
During construction ⎯
Tribal Cultural Resources
Mitigation Measure 3.7-1a: Prepare and Implement a Worker Awareness Training Program for Tribal Cultural Resources (Phase 1 & 2)
Prior to project-specific ground-disturbing activities, a Tribal cultural resources awareness training program will be provided to all construction personnel active on the project site. A representative or representatives from culturally affiliated Native American Tribe(s) will be invited to participate in the development and delivery of the training program in coordination with a professional archaeologist meeting the United States Secretary of Interior’s qualification standards for archaeology. The program will include relevant information regarding Tribal cultural resources, including applicable laws and regulations, the consequences of violating said laws and regulations, protocols for resource avoidance, and protocols for discoveries, including who to contact in the event of a discovery and what to do upon the discovery of human remains. The program will also underscore the requirement for confidentiality and culturally appropriate treatment of any find of significance to Native Americans and protocols, consistent with Native American Tribal values.
Phase 1 & 2 Qualified Native
American monitor and
construction contractors
Prior to construction ⎯
Mitigation Measure 3.7-1b: Unanticipated Discovery of Tribal Cultural Resources (Phase 1 & 2)
During ground-disturbing construction activities, if any suspected Tribal cultural resources are discovered, all work shall cease within 100 feet of the find, and a Tribal Phase 1 & 2 Qualified Native
American monitor and
construction contractors
During construction ⎯