Sacramento City Council
November 18, 2025

Airport South Industrial
Project
SCH# 2022030181
Final Environmental Impact Report
Prepared for
Sacramento Local Agency Formation Commission
March 2025
Prepared by
1501 Sports Drive, Suite A, Sacramento, CA 95834
Airport South Industrial Project
Final Environmental Impact Report
SCH# 2022030181
Lead Agency
Sacramento Local Agency Formation Commission
1112 I Street, Suite 100
Sacramento, CA 95814
José C. Henríquez
Executive Officer
(916) 874-2937
Prepared By
Raney Planning and Management, Inc.
1501 Sports Drive, Suite A
Sacramento, CA 95834
(916) 372-6100
Contact:

Rod Stinson
Vice President/Air Quality Specialist
Table of Contents
Final EIR
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March 2025
Table of Contents
Page i

CHAPTER PAGE

1.0 Introduction and List of Commenters.................................... 1-1

1.1 Introduction .................................................................................................1-1

1.2 Background.................................................................................................1-1

1.3 Purpose of the Final EIR .............................................................................1-2

1.4 List of Commenters .....................................................................................1-2

1.5 Organization of the Final EIR ............................................................................1-5

2.0 Responses to Comments ....................................................... 2-1

2.0.1 Introduction .................................................................................................2-1

2.0.2 Master Response........................................................................................2-1

2.0.3 Responses to Comments ............................................................................2-3

3.0 Revisions to the Draft EIR Text ............................................. 3-1

3.1 Introduction .................................................................................................3-1

3.2 Description of Changes...............................................................................3-1

4.0 Mitigation Monitoring and Reporting Program......................... 4-1

4.1 Introduction .................................................................................................4-1

4.2 Compliance Checklist..................................................................................4-1

4.3 Mitigation Monitoring and Reporting Program .............................................4-2 Appendix
Appendix A: AQMP Verification Letter from SMAQMD
Appendix B: City of Sacramento Public Works Department Memo Appendix C: Health Risk Assessment Output Files

TABLE OF CONTENTS

1. Introduction and List of
Commenters
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Chapter 1 – Introduction and List of Commenters

1.1 INTRODUCTION
This Final Environmental Impact Report (EIR) contains agency and public comments received during the public review period of the Airport South Industrial Park Project (proposed project) Draft EIR. This document has been prepared by the City of Sacramento and Sacramento Local Agency Formation Commission (LAFCo), as Co-Lead Agencies, in accordance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines, Section 15132. The Introduction and List of Commenters chapter of the Final EIR discusses the background of the Draft EIR and purpose of the Final EIR, identifies the comment letters received on the Draft EIR, and provides an overview of the Final EIR’s organization.

1.2 BACKGROUND
The Draft EIR identifies the proposed project’s potential environmental impacts and the mitigation measures that would be required to be implemented. The following environmental analysis chapters are contained in the Draft EIR:
• Aesthetics;
• Agricultural Resources;
• Air Quality, Greenhouse Gas Emissions, and Energy;
• Biological Resources;
• Cultural Resources;
• Geology and Soils;
• Hazards and Hazardous Materials;
• Hydrology and Water Quality;
• Land Use and Planning/Population and Housing;
• Noise;
• Public Services, Utilities, and Service Systems;
• Transportation;
• Tribal Cultural Resources;
• Effects Not Found to be Significant;
• Statutorily Required Sections; and
• Alternatives Analysis.

In accordance with CEQA, the Draft EIR was sent to the State Clearinghouse (SCH#:
2022030181) for distribution to State agencies on May 31, 2024, for a 45-day public review period.

In addition, the Draft EIR and a Notice of Availability (NOA) for the Draft EIR were published on the LAFCo and the City of Sacramento Community Development Department websites. Printed copies of the Draft EIR were made available for review at the City of Sacramento Community Development Department (300 Richards Boulevard, 3rd Floor). A public meeting was held before LAFCo on June 12, 2024, to solicit public comments regarding the Draft EIR.

1. INTRODUCTION AND

LIST OF COMMENTERS
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1.3 PURPOSE OF THE FINAL EIR
Under CEQA Guidelines Section 15132, the Final EIR shall consist of:

1. The Draft EIR or a revision of the Draft.

2. Comments and recommendations received on the Draft EIR.

3. A list of persons, organizations, and public agencies commenting on the Draft EIR.

4. The responses to significant environmental points raised in the review process.

5. Any other information added by the Lead Agency.

As required by CEQA Guidelines, Section 15090(a)(1)-(3), a Lead Agency must make the following three determinations in certifying a Final EIR:

1. The Final EIR has been completed in compliance with CEQA.

2. The Final EIR was presented to the decision-making body of the Lead Agency, and the decision-making body reviewed and considered the information in the Final EIR prior to approving the project.

3. The Final EIR reflects the Lead Agency’s independent judgment and analysis.

Under CEQA Guidelines Section 15091, a public agency shall not approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings (Findings of Fact) for each of those significant effects. Findings of Fact must be accompanied by a brief explanation of the rationale for each finding supported by substantial evidence in the record. The Findings of Fact are included in a separate document that will be considered for adoption by the City’s and LAFCo’s decision-makers.

Pursuant to CEQA Guidelines, Section 15093(b), when a Lead Agency approves a project that would result in significant and unavoidable impacts, the agency must state in writing the reasons supporting the action (Statement of Overriding Considerations). The Statement of Overriding Considerations shall be supported by substantial evidence and is subject to adoption by the City’s and LAFCo’s decision-makers along with the Findings of Fact. The proposed project would result in significant and unavoidable impacts related to substantially degrading the existing visual character or the quality of public views (Impact 4.1-3); cause long-term changes in the visual character associated with cumulative development of the proposed project in combination with future buildout of the City of Sacramento 2040 General Plan and Sacramento County General Plan (Impact 4.1-5); convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural-use (Impact 4.2-1); cause impacts related to compliance with the Cortese-Knox-Hertzberg act (Impact 4.2-4); cause cumulative loss of agricultural land (Impact

4.2-5); conflict with or obstruct implementation of the applicable air quality plan (Impact 4.3-2); and result in a cumulatively considerable net increase in criteria pollutants for which the region is in non-attainment (Impact 4.3-6). Thus, a Statement of Overriding Considerations must be adopted if the project is approved.

1.4 LIST OF COMMENTERS
The City of Sacramento and LAFCo received 80 comment letters during the public comment period on the Draft EIR for the proposed project. The comment letters were authored by the following agencies and individuals:

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Agencies
Letter 1 ..................................................................................California Department of Conservation Letter 2............................................................................. California Department of Fish and Wildlife Letter 3.................................................................................California Department of Transportation Letter 4............................................................ Central Valley Regional Water Quality Control Board Letter 5.............................................................................................Natomas Unified School District Letter 6............................................................................................ Sacramento Area Sewer District Letter 7............................................................................................................... Sacramento County Letter 8.................................................................................................Sacramento Regional Transit Letter 9.................................................... Sacramento Metropolitan Air Quality Management District Letter 10.................................................................................... Sacramento Municipal Utility District Groups
Letter 11...................................................................................................................350 Sacramento Letter 12......................................... Environmental Council of Sacramento (Letter 1 of 2, 6/10/2024) Letter 13......................................... Environmental Council of Sacramento (Letter 2 of 2, 7/17/2024) Letter 14.................................................. Friends of the Swainson’s Hawk (Letter 1 of 2, 6/10/2024) Letter 15.................................................. Friends of the Swainson’s Hawk (Letter 2 of 2, 7/17/2024) Letter 16................................Golden State Environmental Justice Alliance (Blum Collins & Ho LLP) Letter 17....................................................................... Metro Air Park Property Owners Association Letter 18................................................................................... North Natomas Community Coalition Letter 19.................................................................Sacramento Citizens for Equitable Development Letter 20........................................................................................Sacramento County Farm Bureau Letter 21.......................................................................................................Sierra Club Sacramento Letter 22.............................................................Sierra Club, Environmental Council of Sacramento, and Friends of the Swainson’s Hawk (Soluri Meserve)
Letter 23.........................................................Sacramento Residents for Responsible Development (Adams, Broadwell, Joseph & Cardozo)
Letter 24............................................................................................... Westlake Master Association Individuals
Letter 25..................................................................................................................... Matthew Alden Letter 26.......................................................................................................................Bhupinder Bal Letter 27...............................................................Chrys Barranti and Joy Pike (Letter 1 of 3, 6/6/24) Letter 28...............................................................Chrys Barranti and Joy Pike (Letter 2 of 3, 6/6/24) Letter 29...............................................................Chrys Barranti and Joy Pike (Letter 3 of 3, 6/6/24) Letter 30.................................................................................................................... Robert Burness Letter 31..............................................................................................................................Leo Chan Letter 32...................................................................................Pamela Davis (Letter 1 of 2, 6/10/24) Letter 33.....................................................................................Pamela Davis (Letter 2 of 2, 7/7/24) Letter 34............................................................................................................... Jacqelyn Donahue Letter 35......................................................................................Lynn Duarte (Letter 1 of 2, 6/10/24) Letter 36......................................................................................Lynn Duarte (Letter 2 of 2, 6/11/24) Letter 37........................................................................................................................ Megan Elsea Letter 38................................................................................................................... Corinne Gartner Letter 39.................................................................................................................. David Grandstaff Letter 40.....................................................................................................................Pamela Harder Letter 41..........................................................................................................................Jared Harris Letter 42..............................................................................................................................Linn Hom Final EIR
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Letter 43...............................................................................Karen Jacques (Letter 1 of 2, 6/8/2024) Letter 44.............................................................................Karen Jacques (Letter 2 of 2, 7/17/2024) Letter 45.............................................................................................................................Alan Jang Letter 46............................................................................................................................. Alex Jang Letter 47.................................................................................................................... Nancy Kapellas Letter 48............................................................................................................................Lynn Lenzi Letter 49....................................................................................................................Archana Maniar Letter 50............................................................................ Margaret McCarthy (Letter 1 of 2, 6/9/24) Letter 51............................................................................ Margaret McCarthy (Letter 2 of 2, 6/9/24) Letter 52....................................................................................................................... Sanjay Mengi Letter 53.........................................................................................................................Nona Mounir Letter 54...........................................................................................................................Pam O’Dell Letter 55...................................................................................................................... Karen O’Haire Letter 56........................................................................................ Chris Paros (Letter 1 of 2, 6/9/24) Letter 57...................................................................................... Chris Paros (Letter 2 of 2, 7/16/24) Letter 58........................................................................................................................... Jeff Phillips Letter 59.............................................................................................. Patricia and Lawrence Rouen Letter 60.....................................................................................................................Myrna Rudman Letter 61.......................................................................................................................Lolly Sangster Letter 62.......................................................................................... Jan Schori and Case Butterman Letter 63.............................................................................Dana J. Schwartz (Letter 1 of 2, 6/12/24) Letter 64.............................................................................Dana J. Schwartz (Letter 2 of 2, 6/12/24) Letter 65........................................................................... Steve Schweigerdt (Letter 1 of 2, 6/10/24) Letter 66........................................................................... Steve Schweigerdt (Letter 2 of 2, 7/14/24) Letter 67..............................................................................................Carmen and Roberto Segovia Letter 68.....................................................................................................................Margit Spencer Letter 69................................................................................DoLee Spurgeon (Letter 1 of 2, 6/9/24) Letter 70..............................................................................DoLee Spurgeon (Letter 2 of 2, 6/10/24) Letter 71................................................................................ Marcella Steele (Letter 1 of 2, 6/11/24) Letter 72................................................................................ Marcella Steele (Letter 2 of 2, 6/11/24) Letter 73......................................................................................................................Harriet Steiner Letter 74........................................................................................................................Muriel Strand Letter 75.......................................................................................................................Edith Thacher Letter 76..................................................................................................................... Brian Thornton Letter 77...................................................................................................................... Carol Turgeon Letter 78.....................................................................................................................Barbara Walter Letter 79......................................................................................................................Dawn Whitney Letter 80..........................................................................................................................Acme Wong In addition, 12 commenters provided verbal comments during the public meeting held before LAFCo on June 12, 2024, to solicit public comments regarding the Draft EIR. A summary of the verbal comments is included as Letter 81.

Letter 81...........................................................Public Comment Hearing Summary (June 12, 2024) After the conclusion of the public comment period, the City of Sacramento and LAFCo received three additional comment letters on September 25, 2024, October 14, 2024, and January 2, 2025.

The comment letters received after the close of the public comment period were authored by the following groups:

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Comments Received After Close of Comment Period
Letter 82 ........................................................Sacramento Residents for Responsible Development (Adams, Broadwell, Joseph & Cardozo)(September 25, 2024) Letter 83..............................................................Advocates for the Environment (October 14, 2024) Letter 84......................... Carpenters Union Local #46 (Mitchell M. Tsai Law Firm)(January 2, 2025)

1.5 ORGANIZATION OF THE FINAL EIR
The Final EIR is organized into the following chapters:

1. Introduction and List of Commenters
Chapter 1 provides an introduction and overview of the document, describing the background and organization of the Final EIR. Chapter 1 also provides a list of commenters who submitted letters in response to the Draft EIR.

2. Responses to Comments
Chapter 2 presents the comment letters received and responses to each comment. Each comment letter received has been numbered at the top and bracketed to indicate how the letter has been divided into individual comments. Each comment is given a number with the letter number appearing first, followed by the comment number. For example, the first comment in Letter 1 would have the following format: 1-1. The response to each comment will reference the comment number.

3. Revisions to the Draft EIR Text
Chapter 3 summarizes minor changes made to the Draft EIR text since its release.

4. Mitigation Monitoring and Reporting Program
CEQA Guidelines, Section 15097, requires lead agencies to adopt a program for monitoring the mitigation measures required to avoid the significant environmental impacts of a project. The intent of the Mitigation Monitoring and Reporting Program (MMRP) is to ensure implementation of the mitigation measures identified within the EIR for the proposed project.

2. Responses to Comments
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Chapter 2.0 – Responses to Comments

2.0.1 INTRODUCTION
The Responses to Comments chapter contains responses to each of the comment letters submitted regarding the Airport South Industrial Park Project (proposed project) Draft EIR during the public review period and a response to the verbal comments received at the Sacramento Local Agency Formation Commission (LAFCo) meeting to receive public comment on the Draft EIR.

The City of Sacramento and LAFCo appreciate the time and effort taken by commenters to express their views and concerns as a part of this process. These views and recommendations are considered by City and LAFCo staff in developing the staff recommendation, and by the City of Sacramento Planning and Design Commission, City Council, and LAFCo Commission in their deliberations and decision-making regarding certification of the EIR and their actions on the proposed project.

Section 15088(a) of the CEQA Guidelines directs that lead agencies must prepare written responses to those comments received during the Draft EIR comment period that raise “significant environmental issues.” The City and LAFCo are not required to respond to comments on nonCEQA issues or to respond to late comments. Nevertheless, the City and LAFCo have chosen to include in this Response to Comments chapter written responses to comments received after the close of the Draft EIR comment period. The City and LAFCo have opted to take this broad approach to facilitate the public process, document the exchange of information, and provide important information about considerations relevant to the proposed project.

Where a comment provides the opinion, preference, or observation of the commenter (e.g., opinions on the merits of the project that are unrelated to its environmental impacts), without substantiation, this is acknowledged for the record, and no further response is provided. All comments, whether substantiated by facts or simply reflecting the position of the commenter, have been considered by the City and LAFCo throughout this process.

2.0.2 MASTER RESPONSE
Many of the commenters on the Draft EIR raised similar concerns. For such concerns, the City and LAFCo have prepared a master response. Through the master response, the City and LAFCo can address the common topics in a comprehensive manner and without duplication in the individual responses. Some of the thematic comments submitted on the Draft EIR pertain to issues that are not considered significant impacts on the environment under CEQA. The master response has been referenced, as needed, in the individual responses to comments that follow.

Master Response
The CEQA Guidelines frame the scope and focus of review and the extent, nature and scope of responses by a lead agency to comments on a Draft EIR. This Final EIR addresses both comments pertaining to impacts analyses and acknowledges comments not related to

2.0 RESPONSES TO COMMENTS
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Chapter 2.0 – Responses to Comments

environmental impact and analysis. However, other comments received contained the commenter’s opinion on approval or denial and/or concerns about the project’s consistency with LAFCo and City policies. This section provides a response to these types of comments, which are either general or unrelated to the project’s impacts on the physical environment.

The CEQA Guidelines provide the following language:
15204. FOCUS OF REVIEW (relevant excerpts)
(a) In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, in light of factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and the geographic scope of the project. CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commentors. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.
(c) Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.

Notwithstanding the above guidelines language, CEQA Guidelines Section 15204(e) states that these limitations should “not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.”
According to CEQA Guidelines Section 15088, “The level of detail contained in the response […] may correspond to the level of detail provided in the comment (i.e., responses to general comments may be general). A general response may be appropriate when a comment does not contain or specifically refer to readily available information, or does not explain the relevance of evidence submitted with the comment.” Thus, when a commenter expresses general concerns like the proposed project would result in “more traffic,” “increased noise,” “effects on water quality,” or “increased light and glare,” a specific response is not offered. Rather, the commenter is referred to those sections of the Draft EIR where the referenced general concern is evaluated in detail.

For example, project-related traffic and its effect on the regional roadway network is evaluated in Chapter 4.12, Transportation, of the Draft EIR. The project-related increase in air quality emissions and their effect on the surrounding environment, including human health, is addressed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy. The potential effects of the project on local hydrology and water quality, including groundwater, are addressed in Chapter

4.8, Hydrology and Water Quality, of the Draft EIR, and potential impacts related to noise and vibration associated with construction and operation of the proposed project are addressed in Final EIR
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Chapter 4.10, Noise, of the Draft EIR. Those comments in support/opposition do not concern environmental impacts; therefore, they are noted and referred to the decision-makers for consideration in their deliberations for approval or denial of the project.

Multiple commenters voiced concerns about the proposed project being in opposition to goals and policies established by LAFCo and the City of Sacramento. The scope of an EIR is limited to a local agency’s evaluation of potentially significant environmental impacts of a project, which by definition are limited to physical conditions. The determination that the proposed project is consistent or inconsistent with LAFCo or 2040 General Plan policies or other applicable plans and policies is ultimately the decision of the LAFCo and Sacramento City Council. However, the Draft EIR evaluated consistency with goals and policies related to mitigating potential environmental impacts. Furthermore, although CEQA analysis may identify some areas of general consistency with LAFCo and City policies, LAFCo and the City have the ability to impose additional requirements or conditions of approval on a project, at the time of its approval, to bring a project into more complete conformance with existing policies.

CEQA Guidelines Section 15126.2(a) requires an EIR to identify and focus on the significant effects of a project on the environment. Thus, from the standpoint of potential impacts on the environment, the Draft EIR adequately evaluates the proposed project’s consistency with LAFCo and the 2040 General Plan goals, objectives, and policies related to avoiding potential environmental impacts through assessing the potential for the proposed project to result in physical impacts related to the environmental issue areas required for analysis under CEQA.

2.0.3 RESPONSES TO COMMENTS
The following 80 letters were received by the City and LAFCo during the public comment period for the Draft EIR. Each bracketed comment letter is followed by numbered responses to each bracketed comment. In addition, comments from 12 verbal commenters were received during the public hearing held by LAFCo on June 12, 2024, to solicit public comments on the Draft EIR and are identified as Letter 81. A numbered response is provided to the verbal comments, following the responses to the letters. Three additional comment letters were received on September 25, 2024, October 14, 2024, and January 2, 2025, after the conclusion of the public comment period, and are identified as Letter 82, Letter 83, and Letter 84, respectively. The responses amplify or clarify information provided in the Draft EIR and/or refer the reader to the appropriate place in the document where the requested information can be found. Comments that are not directly related to environmental issues (e.g., opinions on the merits of the project that are unrelated to its environmental impacts) are either discussed or noted for the record, as appropriate.

Where revisions to the Draft EIR text are required in response to the comments, such revisions are noted in the response to the comment, and are also listed in Chapter 3 of this Final EIR. All new text is shown as double underlined and deleted text is shown as struck through.

Revisions to the Draft EIR text are not required in response to the comments. It should be noted that, as presented in Chapter 3 of this Final EIR, minor corrections, additions, and revisions have been made to the Draft EIR, as initiated by the Lead Agencies (the City and LAFCo). However, the changes represent minor clarifications/amplifications of the analysis contained in the Draft EIR and do not constitute significant new information that, in accordance with CEQA Guidelines, Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR. Thus, recirculation of the Draft EIR is not required.

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Each letter has been considered by the City and LAFCo and addressed, according to CEQA Guidelines Section 15088, prior to certification of this Final EIR.

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Letter 1
1-1
1-2
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1-3
1-2
Cont.
1-4
Letter 1 Cont.
1-5
1-6
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Letter 1 Cont.
1-7
1-6
Cont.
1-8
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Letter 1 Cont.
1-9
1-8
Cont.
1-10
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Letter 1 Cont.
1-11
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LETTER 1: ERWIN SISON, CALIFORNIA DEPARTMENT OF

CONSERVATION
Response to Comment 1-1
The comment is an opening statement and notes that the Geologic Energy Management Division has reviewed the project; however, the comment does not address the adequacy of the Draft EIR.

Please see the Master Response.

Response to Comment 1-2
The comment states the existence of an on-site well but does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 1-3
The comment provides information regarding the Geologic Energy Management Division’s requirements and policies regarding wells. The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 1-4
See Response to Comment 1-3. In addition, the comment notes the general potential for oil wells to leak in the future.

Response to Comment 1-5
The comment requests on-site wells to be tested; however, Comment 1-12 goes on to note that the well identified by the commenter’s record search would not likely be impacted by project activities. It should be noted that the Phase I Environmental Site Assessment prepared for the project site identified oil/gas wells within the project vicinity, including the well identified by the commenter’s record search, but did not conclude that any would result in a potentially hazardous condition. The commenter’s request will be forwarded to the applicant and decision-makers for their consideration.

Response to Comment 1-6
See Response to Comment 1-3 and 1-5.

Response to Comment 1-7
The comment provides recommendations regarding wells within the project site but does not address the adequacy of the Draft EIR. Please see Response to Comment 1-5.

Response to Comment 1-8
The comment does not specifically address the adequacy of the Draft EIR. However, the comment does make recommendations for LAFCo and the City’s consideration. Please see Response to Comment 1-5.

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Response to Comment 1-9
The comment provides information regarding the authority of the Geologic Energy Management Division. The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 1-10
The comment provides information on procedures in the event any wells are encountered onsite but does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 1-11
The comment provides information regarding the record search results for the identified on-site well. As noted in the table provided within the comment, the identified well would “not likely be impacted by project activities.” Please also see Response to Comment 1-5.

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Letter 2
2-1
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Letter 2 Cont.
2-1
Cont.
2-2
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Letter 2 Cont.
2-3
2-4
2-5
2-6
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Letter 2 Cont.
2-6
Cont.
2-8
2-7
2-9
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Letter 2 Cont.
2-10
2-12
2-11
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2-12
Cont.
2-13
2-14
2-15
2-16
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2-16
Cont.
2-17
2-20
2-18
2-19
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2-20
Cont.
2-21
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LETTER 2: MORGAN KILGOUR, CALIFORNIA DEPARTMENT OF FISH

AND WILDLIFE
Response to Comment 2-1
The comment is an introductory statement regarding the role of the California Department of Fish and Wildlife (CDFW) and provides a summary of the project description and setting. The comment does not address the adequacy of the Draft EIR.

Response to Comment 2-2
The comment is an introductory statement regarding the content of the following comments, which are addressed below. The comment does not address the adequacy of the Draft EIR.

Response to Comment 2-3
As discussed throughout Chapter 4.4, Biological Resources, of the Draft EIR, the potentially significant impacts to sensitive biological resources as a result of project implementation would be mitigated through either: Take Avoidance, Minimization, and Mitigation Measures determined to be sufficient mitigation by the Natomas Basin Habitat Conservation Plan (HCP), or additional project-specific mitigation. The Natomas Basin HCP measures would be applicable to all species that are covered by the Natomas Basin HCP across the entire project site. For potential impacts to species that are not covered by the Natomas Basin HCP, additional project-specific mitigation would be implemented across the entire project site. Therefore, those portions of the project site located outside of the Natomas Basin HCP permit area would be subject to additional mitigation measures, in addition to the HCP measures, to ensure that all project impacts are mitigated to a less-than-significant level. For example, Mitigation Measure 4.4-1(a) provides mitigation consistent with the Natomas Basin HCP for potential impacts to special-status plant species that are covered by the Natomas Basin HCP, and Mitigation Measure 4.4-1(b) consists of additional project-specific mitigation for potential impacts to special-status plant species that are not covered by the Natomas Basin HCP. Both the Natomas Basin HCP measures and the additional projectspecific mitigation measures provided throughout Chapter 4.4, Biological Resources, of the Draft EIR would reduce project impacts to a less-than-significant level.

In addition, based on the overall project area of 474.4 acres, the 121.68-acre portion of the site that currently appears on the Natomas Basin HCP “Permit Area” map (see Figure 4.4-2 of the Draft EIR) comprises about 26 percent of the overall project acreage. Regardless, the overall project area will comply with applicable federal and State Endangered Species Act (ESA) requirements.

Response to Comment 2-4
A map of the boundary area of the Natomas Basin HCP, as well as the project site’s overlap into the Natomas Basin HCP jurisdiction, is presented as Figure 4.4-2, Natomas Basin Habitat Conservation Plan 2023 Permit Area, on page 4.4-5 in Chapter 4.4, Biological Resources, of the Draft EIR. Nonetheless, Figure 4.4-1, Study Areas, in Chapter 4.4, Biological Resources, of the Draft EIR has been revised to include additional clarification, as recommended by CDFW. As shown therein, Figure 4.4-1 clearly presents areas of the project site that are within or outside of the Natomas Basin HCP permit area, including corresponding acreages.

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In addition, pages 4.4-74 and 4.4-75 of Chapter 4.4, Biological Resources, of the Draft EIR are hereby revised as follows:

Swainson’s Hawk Foraging Habitat
Based on the analysis in this chapter, the proposed project would reduce the overall upland land cover in the Natomas Basin that is capable of providing foraging habitat for Swainson’s hawk by approximately 436.5 340 acres (which does not include the 37.9 acre Caltrans I5 fee title ROW portion of the project site that does not provide Swainson’s hawk foraging habitat). The majority of the project’s development area is currently zoned for agriculture.

In addition, nearly all of the project site is not within outside of the Swainson’s Hawk Zone established by the Natomas Basin HCP. A relatively small and narrow, less than 175 feet wide strip of the southwest corner of the project site is within the Swainson’s Hawk Zone established by the Natomas Basin HCP. The area of the proposed project within the Swainson’s Hawk Zone would consist of a drainage basin and does not include any urban hardscape development (i.e., a building or parking lot), nor would the proposed project necessitate the removal of any trees. In addition, the Swainson’s Hawk Zone located immediately south of the project site contains Powerline Road, a paved roadway, as well as a farmhouse on the adjacent parcel. The Swainson’s Hawk Zone, where it overlays the project site, would remain in open space use, consistent with City requirements.

The foregoing revisions are for clarification purposes only and do not affect the conclusions of the analysis. Figure 2.0-1, which shows where the Natomas Basin HCP Swainson’s Hawk Zone slightly overlaps onto the project site, is provided below for informational purposes.

Response to Comment 2-5
See Response to Comment 2-3.

As discussed on page 4.4-41 in Chapter 4.4, Biological Resources, of the Draft EIR, the City’s annual reports have consistently shown unallocated acreage within the City’s permitted 8,050 acres of development under the Natomas Basin HCP that are not tied to specific parcels within the currently-mapped “Permit Area.” A portion of that unallocated acreage could potentially be used by the western portion of the project site. If such unallocated Natomas Basin HCP acreage is applied to the western portion of the project site, the entire project would rely on the Natomas Basin HCP minimization and mitigation measures. If such unallocated Natomas Basin HCP acreage is applied to the western portion of the project site, the entire project would rely on the Natomas Basin HCP minimization and mitigation measures. Nonetheless, this Final EIR includes revised mitigation measures related to potential impacts to special status species, and impacts to biological resources remain less than significant with mitigation.

Projects that mitigate impacts to special-status species under the Natomas Basin HCP are subject to a 0.5:1 mitigation ratio for all lands converted to urban land uses, regardless of species-specific impacts.

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Figure 4.4-1
Study Areas
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Figure 2.0-1
Natomas Basin HCP Swainson’s Hawk Zone
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As stated on page IV-6 of the Natomas Basin HCP, under the plan, “the effective habitat reserve ratio is actually higher than the 0.5 to 1 ratio, because not all lands to be developed under the Natomas Basin HCP Permits are of high value to the Covered Species as habitat. As stated on page IV-6 of the Natomas Basin HCP, because portions of the Natomas Basin currently have marginal value as habitat, and because all land to be developed in the Basin will be subject to mitigation fees, in some cases the 0.5 to 1 mitigation ratio will result in a substantial increase in overall habitat value.” The Natomas Basin HCP benefits in that high value habitat lands are provided for mitigation in addition to payment of HCP fees.

When looking at species-specific impacts and mitigation ratios, such mitigation is calculated based on the actual acreage of impacted habitat for the species. Thus, it is possible for higher species-specific mitigation ratios to result in fewer overall acres of mitigation lands compared to a broader multi-species approach (i.e., participation in the Natomas Basin HCP).

The project site contains marginal habitat for giant garter snake. As stated on page 4.4-25 of the Draft EIR, although giant garter snake was not observed during the field surveys conducted as part of the BRA, due to documented occurrences of giant garter snake in the West Drainage Canal, the Draft EIR concluded that the on-site canals could provide potential habitat for transient individuals.

The Draft EIR describes potential impacts to canals and ditches on the project site on pages 4.4- 64 to 4.4-65. As discussed therein, bridge and culvert installation could cause temporary impacts to Canal 2 (Lone Tree Canal), which is within the current Natomas Basin HCP Permit Area, while potential impacts to Ditches 1 and 2 would occur in the western portion of the project site. Ditches 1 and 2 comprise approximately 0.58-acre. The project proposes off-site mitigation for impacts to agricultural and open space resources.

In addition, the two parcels currently identified for off-site reserves are located immediately south of the project site and adjacent to existing reserve lands owned by The Natomas Basin Conservancy (TNBC). This proximity would assist TNBC in assembling a 400-acre habitat block in the area (when combined with the Souza, Natomas Farms, Rosa East, and Rosa Central reserves, the block would total roughly 418 acres), and would provide additional qualitative species benefits due to preserving larger blocks of habitat in perpetuity that are also in close proximity to the protected Fisherman’s Lake. The Natomas Basin HCP requires that at the completion of the HCP that all reserve lands be in a minimum of 400-acre blocks and one 2,500- acre block. Completing the 400-acre block would achieve the Natomas Basin HCP requirement that may not otherwise be completed based on the surrounding ownerships (such as airport lands, school district property and other privately owned properties).

Furthermore, it is noted that Mitigation Measures 4.4-3 and 4.4-5(b) require mitigation for potential impacts to giant garter snake and Swainson’s hawk foraging habitat, respectively, that are located outside the Natomas Basin HCP permit area, consistent with CDFW guidelines. Nonetheless, consistent with the recommendation of the commenter, Mitigation Measure 4.4-3 has been revised as follows:

Industrial Park and Nonparticipating Parcels

4.4-3(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that Final EIR
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the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measures have been implemented:

Natomas Basin HCP Section V.A.5.a:

1. Within the Natomas Basin, all construction activity involving disturbance of habitat, such as site preparation and initial grading, is restricted to the period between May 1 and
September 30. This is the active period for the giant garter snake and direct mortality is lessened, because snakes are expected to actively move and avoid danger.

2. Pre-construction surveys for giant garter snake, as well as other NBHCP Covered Species, must be completed for all
development projects by a qualified biologist approved by USFWS. If any giant garter snake habitat is found within a specific site, the following additional measures shall be implemented to minimize disturbance of habitat and
harassment of giant garter snake, unless such project is specifically exempted by USFWS.

3. Between April 15 and September 30, all irrigation ditches, canals, or other aquatic habitat should be completely
dewatered, with no puddled water remaining, for at least 15 consecutive days prior to the excavation or filling in of the dewatered habitat. Make sure dewatered habitat does not continue to support giant garter snake prey, which could detain or attract snakes into the area. If a site cannot be completely dewatered, netting and salvage of prey items may be necessary. This measure removes aquatic habitat
component and allows giant garter snake to leave on their own.

4. For sites that contain giant garter snake habitat, no more than 24-hours prior to start of construction activities (site preparation and/or grading), the project area shall be
surveyed for the presence of giant garter snake. If
construction activities stop on the project site for a period of two weeks or more, a new giant garter snake survey shall be completed no more than 24-hours prior to the re-start of construction activities.

5. Confine clearing to the minimal area necessary to facilitate construction activities. Flag and designate avoided giant garter snake habitat within or adjacent to the project as Environmentally Sensitive Areas. This area shall be avoided by all construction personnel.

6. Construction personnel completing site preparation and grading operations shall receive USFWS approved
environmental awareness training. This training instructs workers on how to identify giant garter snakes and their habitats, and what to do if a giant garter snake is
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encountered during construction activities. During this training an on-site biological monitor shall be designated.

7. If a live giant garter snake is found during construction activities, immediately notify the USFWS and the project’s biological monitor. The biological monitor, or his/her
assignee, shall do the following:
a. Stop construction in the vicinity of the snake. Monitor the snake and allow the snake to leave on its own.

The monitor shall remain in the area for the
remainder of the work day to make sure the snake is
not harmed or if it leaves the site, does not return.

Escape routes for giant garter snake should be
determined in advance of construction and snakes
should always be allowed to leave on their own. If a
giant garter snake does not leave on its own within
1 working day, further consultation with USFWS is
required.

8. Upon locating dead, injured or sick threatened or
endangered wildlife species, the project applicant must notify within 1 working day the Service’s Division of Law Enforcement (2800 Cottage Way, Sacramento CA 95825) or
the Sacramento Fish and Wildlife Office (2800 Cottage Way, Room W2605, Sacramento, CA 95825, telephone 916 414-
6600). Written notification to both offices must be made within 3 calendar days and must include the date, time, and location of the finding of a specimen and any other pertinent information.

9. Fill or construction debris may be used by giant garter snake as an over-wintering site. Therefore, upon completion of construction activities remove any temporary fill and/or construction debris from the site. If this material is situated near undisturbed giant garter snake habitat and it is to be removed between October 1 and April 30, it shall be
inspected by a qualified biologist to assure that giant garter snake are not using it as hibernaculae.

10. No plastic, monofilament, jute, or similar erosion control matting that could entangle snakes will be placed on a
project site when working within 200 feet of snake aquatic or rice habitat. Possible substitutions include coconut coir matting, tactified hydroseeding compounds, or other
material approved by the Wildlife Agencies.

4.4-3(b) To address potential impacts to giant garter snake on-site, but outside of the Natomas Basin HCP permit area, the project applicant shall retain a qualified biologist to conduct preconstruction surveys for giant garter snake prior to the issuance of any grading permit and commencement of project-related ground- Final EIR
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disturbing activities outside of the Natomas Basin HCP Permit Area.

If giant garter snake habitat is not identified on-site and giant garter snakes are not detected, the project may commence as scheduled.

If giant garter snake habitat is found and/or giant garter snake individuals are detected, in areas outside of the Natomas Basin HCP Permit Area that would be impacted by the project, the project applicant shall either:
(1) provide on- and or off-site preservation of giant garter snake habitat at a ratio determined by USFWS and CDFW, and as subject to regulatory permitting requirements of the CDFW, USACE, and or RWQCB, as prescribed by Mitigation Measures

4.4-10(a) through 4.4-10(c) and 4.4-11(a) through 4.4-11(d), as applicable. Applicant purchase of conservation easements or fee title of lands shall be acceptable if approved by the applicable permit-issuing regulatory agency. Final mitigation requirements shall be determined by the permit-issuing
regulatory agency.

OR
(2) Should a portion of the City’s surplus HCP coverage be made available to the proposed project, the project applicant for development projects less than 50-acres in size shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities;
otherwise, off-site land dedication and payment of NBHCP fees are required for project greater than 50-acres in size.

In addition, Mitigation Measure 4.4-5(b) is hereby revised as follows:

4.4-5(b) To address potential impacts to Swainson’s hawk foraging habitat that occurs on-site, but outside of the Natomas Basin HCP permit area, the project applicant shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and
management and monitoring activities, should a portion of the City’s surplus HCP coverage be made available to the proposed project. preserve Swainson’s hawk foraging habitat off-site at a 1:1 ratio, which shall consist of a minimum 0.5:1 ratio habitat preservation offsite plus 0.5:1 ratio as prescribed by Mitigation Measure 4.2-1. The preserved habitat shall be provided through applicant purchase of conservation easements or fee title of lands with suitable Swainson’s hawk foraging habitat as approved by CDFW
(consistent with CDFW guidelines). Additionally, prior to the issuance of any grading permit and commencement of projectrelated ground-disturbing activities outside of the Natomas Basin HCP permit area the project applicant shall consult with CDFW for a Section 2081 Incidental Take Permit, or demonstrate to the City that none was required by CDFW.

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OR
Pursuant to CDFW guidelines, the applicant shall preserve Swainson’s hawk foraging habitat at a 0.5:1 ratio. The preserved habitat shall be at a location approved by the CDFW. Preservation may occur through purchase of conservation easements or fee title of lands with suitable Swainson’s hawk foraging habitat (consistent with CDFW guidelines). Should a portion of the City’s surplus HCP coverage be made available to the proposed project, the project applicant shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities for development projects less than 50-acres in size; otherwise off-site land dedication and payment of NBHCP fees are required for projects greater than 50-acres in size.

Response to Comment 2-6
See Response to Comment 2-5. The project is expected to seek coverage under the Natomas Basin HCP within the 8,050 acres of authorized development allotted to the City of Sacramento under that HCP. In the event such coverage is not available, Mitigation Measures 4.4-3(b) and

4.4-5(b) would require coordination with CDFW and USFWS regarding separate applicable permits by the wildlife resource agencies. The Draft EIR lists CDFW as an agency that may be involved in granting approvals or coordinating with other agencies with regard to the project on page 3-14 in Chapter 3, Project Description, of the Draft EIR.

Response to Comment 2-7
See Responses to Comments 2-5 and 2-6.

Response to Comment 2-8
See Response to Comment 2-5. In addition, Mitigation Measure 4.2-1 is hereby revised as follows:

4.2-1 The City shall ensure that, prior to impacting agricultural/open space resources within the project site by the issuance of a grading permit, any and all project-related subdivision maps satisfy the OnSite Open Space and Off-Site Open Space requirements as defined herein. Open space dedications made pursuant to the Natomas Basin Habitat Conservation Plan (HCP) shall be made to the City and/or the Natomas Basin Conservancy and shall be located in the Natomas Basin. The remaining non-Natomas Basin HCP mitigation acreage may be located in unincorporated Sacramento County, Yolo County, and/or Sutter County, and may be held and managed by a qualified third-party entity with the approval of the City.

Preservation shall be ensured in perpetuity via conservation easement, fee, or irrevocable offer of dedication to the satisfaction of the City. All mitigation acreage shall consist of land of comparable agricultural and habitat value as the agricultural/open Final EIR
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space resources impacted by the proposed project, as determined by the City.
a. On-Site Agricultural/Open Space Requirements: The
following on-site open space properties are consistent with the mitigation requirements:
• 86 acres of detention basins.
• 37.9 acres of freeway buffer.
• 2.3 acres of canal buffers.
b. Off-site Agricultural/Open Space Requirements: The
following Off-Site Open Space properties:
• 141.51 acres of currently unidentified agricultural/open spaced mitigation property to be located in the
unincorporated Sacramento County and/or
unincorporated Sutter County.
• 50-acre habitat mitigation property APN 225-0020-014. • 67.59-acre habitat mitigation property APN 225-0020-
015.
c. Phasing: The Airport South Industrial Project will develop in phases, as such, the amount of On-Site and Off-Site Open Space to be provided hereunder shall be in proportion to the amount of acreage proposed to be impacted by such
development by the issuance of a grading permit therefor. d. With respect to each unidentified open space property listed above, and any proposed substitution of an open space
property listed above, the City must determine, in writing, that the proposed agricultural/open space property and/or acreage satisfies the requirements for agricultural/open space to be counted towards the requisite Off-Site Agricultural/Open Space acreage total.
e. Nothing in this Agricultural/Open Space Mitigation is intended to limit or restrict USFWS and CDFW in their consideration of Developer's applications for incidental take and/or other habitat mitigation permits or other entitlements under the federal Endangered Species Act and the California Endangered
Species Act.

Response to Comment 2-9
See Response to Comment 2-8. Reserve lands managed by TNBC include site-specific management plans (SSMPs) that are able to restrict crop types for the benefit of Swainson’s hawk. Details of those SSMPs are subject to review by CDFW and USFWS. In the event that the proposed project cannot utilize a portion of the City’s surplus authorized development acreage, Final EIR
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CDFW would also have the opportunity to review proposed agricultural uses on off-site mitigation lands in connection with an application for any applicable required permitting per the ESA.

Response to Comment 2-10
As explained in Chapter 4.4, Biological Resources, of the Draft EIR, the success of the Natomas Basin HCP does not require a certain amount of agricultural land remaining in the basin. For example, portions of the project area, along with other agricultural acreage, were acknowledged by the Natomas Basin HCP to provide foraging habitat for Swainson’s hawk, but as stated on page 4.4-75 of the Draft EIR, such “existing baseline foraging habitat is not considered mitigation under the NBHCP.” Similarly, at the time the Natomas Basin HCP was approved, CDFW found that the impacts of development authorized by the Natomas Basin HCP were fully mitigated by the implementation of the Natomas Basin HCP avoidance and minimization measures, as well as the “establishment, enhancement, and active management of as much as 8,750 acres of highquality reserve habitat in perpetuity designed and managed specifically for the benefit of the Covered Species” (page 4.4-75 of the Draft EIR, quoting page 11 of the Natomas Basin HCP California Endangered Species Act Findings). Even so, the Draft EIR explains on page 4.4-71 that the project could be approved without exceeding the City’s 8,050-acre Authorized Development acreage limit, and thus without exceeding 17,500 acres of development (including the acreage of Metro Airpark HCP) basin-wide.

Acreages for the projects cited by commenter do not specifically represent agricultural land rendered unavailable by development. For example, the Greenbriar Project, listed by the commenter as 1,041 acres, involved development of only 577 acres and preserved over 500 acres of mitigation lands. The Greenbriar mitigation lands, while not part of the TNBC reserve system, nonetheless still provide habitat for the Natomas Basin HCP covered species and connectivity with TNBC reserves to create larger blocks of habitat preserved in perpetuity.

Similarly, the vast majority of acreage committed to the Sacramento Area Flood Control Agency (SAFCA) levee improvement projects remain in open space and/or agricultural uses to serve as a buffer to the levees. Those lands are not slated for urban development and to some extent remain available for use by Natomas Basin HCP covered species. Likewise, the proposed Upper Westside and Grandpark projects have not yet been approved by Sacramento County, and thus have not yet removed agricultural land from the Basin. Thus, the actual conversion of agricultural land to approved and developed urban uses (primarily Greenbriar) since adoption of the Natomas Basin HCP has been fairly minimal. Future conversion of agricultural land to urban uses that involves impacts to special status species would be subject to CDFW review and approval. The EIR properly concluded that the project’s contribution to potential cumulative impacts to special status species’ habitat would be less than cumulatively considerable with mitigation.

Response to Comment 2-11
As an initial clarification, the City of Sacramento is not a party to the Metro Air Park (MAP) HCP.

Chapter 4.2, Agricultural Resources, of the Draft EIR includes analysis of the project’s impacts on agricultural lands, and Chapter 4.4, Biological Resources, includes an analysis of the proposed project’s potential impacts on habitat for special-status species, including those covered by the Natomas Basin HCP. An extensive discussion of the project’s potential effects upon the Natomas Basin HCP Conservation Strategy is presented beginning on page 4.4-71 of the Draft EIR and, as discussed therein, the Draft EIR concluded that the project would not reduce the effectiveness of the HCP’s operating conservation program or conflict with the provisions of an adopted plan.

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The Natomas Basin HCP included mechanisms for evaluating the long-term effectiveness of the plan. In addition to periodic review of various factors including population trends for Natomas Basin HCP-covered species, the Natomas Basin HCP required TNBC to conduct biological effectiveness monitoring within the context of its annual reports (Natomas Basin HCP, Chapter VI). Such review is conducted annually by TNBC, and a copy of the report is provided to CDFW. (See, e.g., 2023 Annual Implementation Report, TNBC.)
Response to Comment 2-12
As discussed under Impact 4.4-12 in Chapter 4.4, Biological Resources, of the Draft EIR, implementation of Mitigation Measure 4.4-3 (amended to be Mitigation Measures 4.4-3(a) and (b) under Response to Comment 2-5 above) was determined to be sufficient to reduce potential impacts related to interfering with the movement of giant garter snake to a less than significant level. For example, through compliance with Mitigation Measures 4.4-3(a) and (b), the proposed project would be required to implement the provisions of the applicable Take Avoidance, Minimization, and Mitigation Measure set forth by the Natomas Basin HCP, which includes, but is not limited to, completion of preconstruction surveys for giant garter snake, additional site inspections for sites that contain the species, USFWS environmental awareness training, USFWS notification if a live giant garter snake is found, USFWS ESA consultation, and prohibition of erosion control matting during implementation of the project which could entangle snakes. As such, the Draft EIR acknowledges potential impacts to the on-site canals, and provides adequate mitigation for such impacts.

As discussed on page 4.4-64 of the Draft EIR, the project would include construction of a bridge and culvert across Canal 2, to the west of the Lot D detention/retention basin and construction of the proposed commercial lots (Parcels 6A through 6C and 7A through 7C) would result in disturbances to Ditch 1 and Ditch 2. A total of 2.081 acres of aquatic features were identified onsite. Canal 2 would only be temporarily impacted during construction of the bridge and culvert in one small reach of the canal. Mitigation Measure 4.4-3 requires dewatering of aquatic habitat prior to any excavation or filling of such habitat, and the time period for disturbance is expected to be minimal.

Response to Comment 2-13
The exact timing, schedule, and duration of project construction is dependent on multiple factors and cannot be determined at this time. However, project potential impacts to the canals used by giant garter snake would only occur during project grading and paving activities related to the proposed crossing of Canal 2. Such activities would be completed during an early phase of project construction, and would be finished relatively quickly in comparison to the rest of the project.

Project compliance with the CWA, PCWQCA, and CFGC is required; thus, coordination with USACE, RWQCB, and CDFW would occur, and corresponding regulatory permitting would be completed if determined required by USACE, RWQCB, and or CDFW. Securing necessary regulatory permits prior to impacts would be required for the project pursuant to Mitigation Measures 4.4-11(a) through 4.4-11(f), as defined below. Final permit requirements would be determined through consultation with the applicable permit-issuing Regulatory Agency. In addition, as discussed under Response to Comment 2-5, Mitigation Measure 4.4-3 was amended to include CDFW consultation, including project specific recommendations provided by CDFW as result of the consultation.

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Response to Comment 2-14
Table 4.4-2 of the Draft EIR has been revised to show that northwestern pond turtle is now a federal candidate for listing. As stated on page 4.4-20 of Chapter 4.4, Biological Resources, of the Draft EIR, the Natomas Basin HCP does include northwestern pond turtle as a covered species. The Natomas Basin HCP refers to the application of giant garter snake avoidance and minimization measures to reduce potential impacts to western pond turtle. That same approach was taken by the Draft EIR, as stated on page 4.4-50: “potential impacts to northwestern pond turtle would be further minimized through compliance with Mitigation Measure 4.4-3, which includes provisions for mitigation impacts to giant garter snake that would simultaneously address impacts to northwestern pond turtle.” As shown above in Response to Comment 2-5, Mitigation Measure 4.4-4(b) has been revised to explicitly incorporate giant garter snake mitigation measures discussed in the Draft EIR.

Response to Comment 2-15
See Response to Comment 2-14. In addition, as described under Impact 4.4-11 in Chapter 4.4, Biological Resources, of the Draft EIR, Mitigation Measures 4.4-11(a) through (g), which require project permitting from the USACE, RWQCB, and CDFW, apply to impacts to jurisdictional aquatic resources, which would likely also serve as suitable habitat for northwestern pond turtle. Thus, the aforementioned mitigation measures would also provide adequate habitat mitigation for the species. Mitigation 4.4-4(b) has been revised to further affirm such application.

Response to Comment 2-16
As noted on page 4.4-31 in Chapter 4.4, Biological Resources, of the Draft EIR, Section 1602 also applies to ephemeral flows. As discussed beginning on page 4.4-64, the Draft EIR also acknowledges that Section 1602 could apply to construction activities, including installation of the culvert across Canal 2 (Lone Tree Canal). Mitigation Measure 4.4-11(d) requires application of Mitigation Measure 4.4-10(a), which requires that CDFW be notified pursuant to CFGC Section 1600, and that the notification “shall include a description of all of the activities associated with the proposed industrial park, not just those associated with the drainages and/or riparian vegetation.” As such, the proposed bridge crossing over the Lone Tree Canal would already be included in the notification. Impacts to jurisdictional aquatic resources located on-site within the project area shall be mitigated by compliance with the Natomas Basic HCP and providing mitigation deemed acceptable by the wildlife agency. In addition, Mitigation Measure 4.4-10(c) is hereby revised as follows:

4.4-10(c) If a Sensitive Natural Community or potentially jurisdictional aquatic resource is identified in a nonparticipating parcel for which a development application has been submitted, the applicant shall implement Mitigation Measure 4.4-10(a).

Response to Comment 2-17
See Response to Comment 2-16.

Response to Comment 2-18
Contrary to the claim in the comment, in Table 4.4-2 in Chapter 4.4, Biological Resources, of the Draft EIR, white-tailed kite is identified as a CDFW Fully Protected species. Potential impacts to the species are addressed under Impact 4.4-9 and are mitigated through implementation of Mitigation Measure 4.4-9(a).

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Response to Comment 2-19
See Response to Comment 2-18. Mitigation Measure 4.4-9(a) requires a pre-construction nesting survey and prohibits construction activities within 0.5-mile of active raptor nests, including whitetailed kite nests, until a qualified biologist determines that the young have fledged or that the nesting attempt has failed, and states that the applicant and a qualified biologist shall jointly determine the nest avoidance buffer and if nest monitoring is necessary. As such, the recommendations provided by the commenter would be implemented, if deemed necessary, and revisions to the mitigation is not required.

Response to Comment 2-20
The comment does not address the adequacy of the Draft EIR. It is noted that the proposed project shall comply with all applicable requirements related to consultation with the CDFW and payment of applicable fees.

Response to Comment 2-21
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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Letter 3
3-1
3-2
3-3
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3-3 cont.

Letter 3 Cont.
3-4
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3-6
3-4 cont.
3-5
Letter 3 Cont.

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3-7
3-8
Letter 3 Cont.
3-9
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LETTER 3: GARY ARNOLD, CALIFORNIA DEPARTMENT OF

TRANSPORTATION
Response to Comment 3-1
The comment is an introductory statement regarding the goals of the California Department of Transportation (Caltrans) and does not address the adequacy of the Draft EIR.

Response to Comment 3-2
The comment consists of a summary of the project description and setting. The comment does not address the adequacy of the Draft EIR.

Response to Comment 3-3
Below are bulleted responses to the comment:
• As stated in Chapter 3, Project Description, of the Draft EIR, Objective #11 of the proposed project is to “Phase project construction to be responsive to market demands.” • Because the phasing of the project is currently unknown, as stated on page 46 of the LTA, the LTA conservatively assumes 100 percent of the proposed development against the baseline condition.
• As defined on page 1 of the LTA, existing conditions are defined as average traffic conditions as of May 2022; project buildout and baseline with project conditions are defined as 2025; and cumulative with project conditions includes all planned developments for the forecasting year of 2040.
• Baseline with project scenario lane configurations are provided in Figure 16 on pages 44 and 45 of the LTA and the cumulative with project scenario lane configurations are provided in Figure 20 on pages 65 through 67 of the LTA. For the purposes of volume forecasting, it was assumed that the project did not influence the planned mainline freeway. The assumption included two general purpose lanes per direction in the Baseline Scenarios and two general purpose and one HOV 2+ lane per direction in the Cumulative Scenarios. Additionally, auxiliary lanes were assumed on southbound I-5 in the vicinity of the project for the Cumulative Scenarios.

Response to Comment 3-4
Below are bulleted responses to the comment:
• Managed lanes were not assumed for the Baseline analysis scenarios and were assumed to be in place with HOV 2+ operations for the Cumulative Scenarios. • With respect to Metro Air Parkway interchange ramps and intersection geometry, as well as current queue length at the ramp, as summarized in Table 5 of the LTA:
o The existing 95th percentile queue length for the I-5 northbound exit ramp right-turn lane is 75 feet and 89 feet, respectively, for the AM and PM peak hours. o The existing 95th percentile queue length for the I-5 northbound exit ramp left/through lane is 47 feet and 38 feet, respectively, for the AM and PM peak hours. o The existing 95th percentile queue length for the I-5 southbound exit ramp is 32 feet and 37 feet, respectively, for the AM and PM peak hours.

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With respect to timing for the planned dual left lanes, the developer and City will work with Caltrans and Sacramento County in the implementation of interchange improvements in a timely manner to maintain safe traffic flow.
• The commenter indicates a typo in the LTA that should be referring to a westbound ramp (WBR) at the intersection because a northbound lane (NBL) would not be available under cumulative conditions. The proposed project would build additional westbound left turn lanes at the intersection and, thus, queues would decrease on the westbound approach due to the operational improvement from the project.
• The project is assumed to build additional turn lanes for the northbound I-5 off ramp given the high amount of additional volume the project would add to the intersection. The improvement was included to minimize queueing and to meet Caltrans operational guidelines for number of turn lanes needed to service a given volume. The project has two additional access points at Power Line Road and Bayou Way. • Under the cumulative scenarios (both no project and with project), volumes greatly exceed capacity for movements at Del Paso and East Commerce and at Del Paso and the Northbound Off-Ramp. Such conditions create significant queueing on the Northbound Off-Ramp which exceeds the available storage and causes delays for both the northbound right and northbound left turning vehicles. When travel demand exceeds capacity, queueing results become unstable. As noted within the LTA, for intersection 9 at the cumulative and cumulative with project scenarios, the off-ramp traffic volumes are substantially similar and the changes in queueing are more reflective of this unstable flow condition than a reflection of project-caused queueing. • The project travel demand model showed some volume redistribution away from El Centro and Del Paso southbound slip ramp due to the improved access to the Metro Air Parkway/I-5 interchange proposed by the project. It should be noted that independent of the project, the cumulative scenarios include the proposed connection over I-5 between El Centro Road and East Commerce Way. This connection allows some traffic which would have exited I-5 at Del Paso Road to access destinations east of I-5 to instead exit at Metro Air Parkway, use the proposed roadway network to access El Centro Road, and then use the connection over I-5 to East Commerce way to bypass the Del Paso Road interchange area. Volume demand south of this connection on El Centro Road went down by a similar amount as an increase in demand on East Commerce Way south of this connection, which supports the foregoing finding.
• As stated on page 4.12-28 in Chapter 4.12, Transportation, of the Draft EIR, “Based on Caltrans guidance related to freeway queuing, the proposed project would not result in a significant impact related to traffic safety, as the queues already spill back onto the mainline under the Cumulative condition, without the addition of project traffic.” As discussed above, the project would add traffic to a movement which already exceeds capacity in the cumulative scenario. When an intersection is already at capacity, microsimulation results will have larger run to run variability because of unstable flow conditions. The metric used is the 95th percentile queue length which is susceptible to this variability. The commentor asks for a fair-share contribution without providing any evidence that a feasible solution exists.
• Due to limitations of the analysis software, the ramp meters were analyzed using fixed time operations. Actual ramp meters in use in the corridor use traffic responsive timing which may operate better or worse depending on mainline freeway congestion levels. The fixed time operations used for analysis were set to use a vehicle release rate similar to the current average variable rate.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 3-5
As stated on page 4.12-21 in Chapter 4.12, Transportation, of the Draft EIR, compliance with the requirements of Mitigation Measure 4.12-3 shall be submitted to the City’s Department of Public Works and Community Development Department. The City would be tasked with ensuring that the VMT Reduction Plan shows the required VMT reduction percentage. As noted in Mitigation Measure 4.12-3, the Draft EIR included as Appendix Q a VMT Mitigation Memorandum prepared by Avdis & Cucci. The VMT Mitigation Memorandum provides evidence of the feasibility of achieving the reductions required by the mitigation measure.

Response to Comment 3-6
The comment notes that the Draft EIR is adequate and has been noted for the record.

Response to Comment 3-7
The comment provides background information regarding requirements of plan-sets prepared for the proposed project. The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Response to Comment 3-8
The comment provides background information regarding required permits. The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Response to Comment 3-9
The comment consists of a conclusion statement and does not address the adequacy of the Draft EIR.
.

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March 2025
Chapter 2.0 – Responses to Comments

Letter 4
4-1
4-2
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Letter 4 Cont.
4-2
Cont.

Final EIR
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Letter 4 Cont.
4-2
Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

Letter 4 Cont.
4-2
Cont.

Final EIR
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4-2
Cont.

Letter 4 Cont.

Final EIR
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Letter 4 Cont.
4-2
Cont.
4-3
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

LETTER 4: CARTER COOK, CENTRAL VALLEY REGIONAL WATER

QUALITY CONTROL BOARD
Response to Comment 4-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.

Response to Comment 4-2
The comment provides background information regarding applicable regulations and required permits. Compliance with such regulations is discussed in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR. The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Response to Comment 4-3
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 5
5-1
5-2
5-3
5-4
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

LETTER 5: LALANYA ROTHENBERGER, NATOMAS UNIFIED SCHOOL

DISTRICT
Response to Comment 5-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.

Response to Comment 5-2
The comment does not address the adequacy of the Draft EIR. The proposed project would not include any improvements that would extend into surrounding pathways accessing the Paso Verde School site from surrounding neighborhoods. The commenter’s policy request has been provided to the decision-makers for their consideration.

Response to Comment 5-3
Potential impacts of the proposed project upon nearby existing uses, including the Paso Verde School, have been identified and addressed throughout the Draft EIR. For example, sound generated by project construction and operation is addressed in Chapter 4.10, Noise, of the Draft EIR. Please see the Master Response.

Response to Comment 5-4
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 6
6-1
6-2
6-3
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Letter 6 Cont.
6-4
6-5
6-6
6-7
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

LETTER 6: ROBB ARMSTRONG, SACRAMENTO AREA SEWER

DISTRICT
Response to Comment 6-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.

Response to Comment 6-2
The comment consists of a summary of the project description and setting. The comment does not address the adequacy of the Draft EIR.

Response to Comment 6-3
The proposed project’s requirement for LAFCo approval of annexation into the SacSewer service area is stated on page 3-5 in Chapter 3, Project Description, of the Draft EIR, and analyzed further in Chapter 4.11, Public Services and Utilities, of the Draft EIR. As stated therein, approval of annexation is a necessary entitlement for project buildout.

Response to Comment 6-4
The comment provides background information about the operation and authority of SacSewer and does not address the adequacy of the Draft EIR.

Response to Comment 6-5
As discussed in Chapter 4.11, Public Services and Utilities, of the Draft EIR, a Targeted Municipal Services Review (Targeted MSR) and the Airport South Industrial Level 1 Sewer Study (Sewer Study) were prepared for the proposed project by Wood Rodgers using SacSewer criteria. In addition, an evaluation of the proposed project’s impacts related to SacSewer capacity is included under Impact 4.11-7. Furthermore, as discussed therein, the proposed project would be required to be developed in compliance with all applicable SacSewer requirements.

Response to Comment 6-6
See Response to Comment 6-4.

Response to Comment 6-7
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 7
7-1
7-2
7-3
7-4
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March 2025
Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-5
7-6
7-7
7-8
7-9
7-10
7-11
7-12
7-13
7-14
7-15
7-16
7-17
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March 2025
Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-17
Cont.
7-18
7-19
7-20
7-21
7-22
7-23
7-24
7-25
7-26
7-27
7-28
7-29
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-29
Cont.
7-30
7-31
7-32
7-33
7-34
7-35
7-36
7-37
7-38
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-39
7-40
7-41
7-42
7-43
7-44
7-45
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-45
Cont.
7-46
Final EIR
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Chapter 2.0 – Responses to Comments

7-47
7-48
Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

7-48
Cont.

Letter 7 Cont.

Final EIR
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Chapter 2.0 – Responses to Comments

Letter 7 Cont.
7-48
Cont.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

LETTER 7: TODD SMITH, SACRAMENTO COUNTY
Response to Comment 7-1
The comment consists of a summary of the project description. The comment does not address the adequacy of the Draft EIR.

Response to Comment 7-2
The comment consists of a summary of the required entitlements for the proposed project. The comment does not address the adequacy of the Draft EIR.

Response to Comment 7-3
The comment is an introductory statement regarding the content of the following comments, which are addressed below. The comment does not address the adequacy of the Draft EIR.

Response to Comment 7-4
The comment is an introductory statement regarding the content of the following comments from the Sacramento County Department of Transportation, which are addressed below. The comment does not address the adequacy of the Draft EIR.

Response to Comment 7-5
The comment does not address the adequacy of the Draft EIR because intersection level of service (LOS) is not considered a transportation impact under CEQA. As such, the proposed changes in the geometric assumptions in the LTA analysis would not affect the conclusions of CEQA transportation impacts in the Draft EIR. The developer and City will work with Caltrans and Sacramento County regarding implementation of interchange improvements in a timely manner to ensure safe and efficient operations. The City will work with the County to develop a phased transportation improvement plan and cost sharing mechanism to ensure the timely implementation of roadway improvements.

Response to Comment 7-6
Contrary to the commenter’s assertion, some trips may be permitted as local trips. Therefore, the assumption should not be zero percent truck distribution because approximately two percent of heavy vehicles were anticipated to be routed via Power Line Road to the south, and some of these trips may be permitted as local trips.

With respect to the request for truck restrictions on Del Paso Road west of Hovnanian Drive, less than two percent of heavy vehicles were anticipated to use the roadway segment. Most of the roadway is in County jurisdiction, and the above Power Line Road restriction would effectively block truck through trips to the project site.

Response to Comment 7-7
Figures 15 and 16 of the LTA, on pages 41 and 43 of the LTA, respectively, illustrate the baseline intersection lane configurations. In addition, the level of development used in the baseline analysis was developed in collaboration with County staff in 2022 and is summarized as follows: North Lake was assumed to be built out with 796 households; Metro Air Park was assumed to have 3,818 industrial employees, 2,084 office employees, 204 medical employees, 315 retail employees, 310 food/beverage employees, and 308 service employees.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 7-8
See Response to Comment 7-5.

Response to Comment 7-9
See Response to Comment 7-5.

Response to Comment 7-10
See Response to Comment 7-5.

Response to Comment 7-11
See Response to Comment 7-5.

Response to Comment 7-12
See Response to Comment 7-5.

Response to Comment 7-13
See Response to Comment 7-5.

Response to Comment 7-14
See Response to Comment 7-5.

Response to Comment 7-15
The applicant and City will work with Caltrans and Sacramento County in the implementation of interchange and roadway improvements in a timely manner to ensure safe and efficient operations.

Response to Comment 7-16
See Response to Comment 7-5.

Response to Comment 7-17
See Response to Comment 7-5. According to the LTA, the requested additional intersections did not trigger any queueing deficiencies. As such, improvements or fair share obligations were not identified.

Response to Comment 7-18
See Response to Comment 7-5.

Response to Comment 7-19
See Response to Comment 7-5.

Response to Comment 7-20
See Response to Comment 7-5.

Response to Comment 7-21
See Response to Comment 7-5.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 7-22
See Response to Comment 7-5.

Response to Comment 7-23
See Response to Comment 7-15.

Response to Comment 7-24
See Response to Comment 7-17.

Response to Comment 7-25
See Response to Comment 7-6. In addition, the applicant and City will work with Caltrans and Sacramento County in the implementation of interchange and roadway improvements in a timely manner to ensure safe and efficient operations, including appropriate roadway pavement to accommodate heavy vehicles, as appropriate.

Response to Comment 7-26
See Response to Comment 7-25.

Response to Comment 7-27
The State Route (SR) 99 interchange with West Elkhorn Boulevard was analyzed with geometrics consistent with the geometrics used for the Greenbriar Second Recirculated Draft EIR, which identified improvements to the interchange. As such, the analysis is based on approved future conditions, thus providing a more accurate basis of analysis for the currently proposed project.

Response to Comment 7-28
See Response to Comment 7-15.

Response to Comment 7-29
See Response to Comment 7-15.

Response to Comment 7-30
The comment is an introductory statement regarding the content of the following comments from the Sacramento County Department of Transportation, which are addressed below. The comment does not address the adequacy of the Draft EIR.

Response to Comment 7-31
See Response to Comment 7-15.

Response to Comment 7-32
See Response to Comment 7-15.

Response to Comment 7-33
See Response to Comment 7-17.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 7-34
Because the CEQA thresholds of significance related to transportation impacts, as defined on pages 4.12-11 and 4.12-12 of Chapter 4.12, Transportation, of the Draft EIR, do not include thresholds related to maintenance and operations agreements, the comment is not related to a CEQA issue. The applicant and City will work with Caltrans and Sacramento County in the implementation of interchange and roadway improvements in a timely manner to ensure safe and efficient operations.

Response to Comment 7-35
See Response to Comment 7-34.

Response to Comment 7-36
In response to the comment, page 4.11-7 in Chapter 4.11, Public Services and Utilities, of the Draft EIR, has been revised as follows:

Additionally, the City provides wholesale water service to other agencies from its entitlements, including the Sacramento County Water Agency (SCWA) (which includes the Sacramento International Airport and SCWA Zone 40 41), Sacramento Suburban Water District, and California American Water.

The foregoing revision corrects a clerical error and is for clarification purposes only.

Response to Comment 7-37
In response to the comment, page 4.11-11 in Chapter 4.11, Public Services and Utilities, of the Draft EIR, has been revised as follows:

With respect to groundwater, while the City’s wholesale agreements primarily rely on surface water, SCWA’s Sacramento International Airport and Metro Air Park service areas receive both surface water and groundwater from the City. The groundwater supply is pumped from the North American Subbasin.

The foregoing revision is for clarification purposes only.

Response to Comment 7-38
The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Response to Comment 7-39
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 7-40
As discussed under Impact 4.11-6 in Chapter 4.11, Public Services and Utilities, of the Draft EIR, sufficient water supplies are available to serve the proposed project, and impacts related to such would be less than significant.

Response to Comment 7-41
The comment does not address the adequacy of the Draft EIR. Nonetheless, in response to the comment, the title page of Appendix L to the Draft EIR, Airport South Industrial Preliminary Water Study, is hereby revised as follows:

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

NOTE TO FILE: The transfer of the 4700 linear feet of 30-inch water transmission main to the City from the Sacramento County Water Authority Agency will require reimbursement to the County for the depreciated value of the transmission main. As of January 19, 2024, the depreciated value of the water transmission main is estimated at $1,012,502.78. During plan review, additional discussion between the County, City, Sacramento International Airport and Developer will be required regarding this matter. If an agreement is not reached and the transfer of ownership of the 30-inch water t-main does not occur, a revised design of the water system for the Airport South Industrial will be required.

The foregoing revision is for clarification purposes only and does not affect the analysis of the Draft EIR.

Response to Comment 7-42
The comment does not address the adequacy of the Draft EIR and has been noted for the record.

The applicant has been informed of this requirement. Please see the Master Response.

Response to Comment 7-43
The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Please see the Master Response. Final Improvement Plans will be reviewed by the City to ensure adequate building/infrastructure setbacks prior to Improvement Plan approval.

Response to Comment 7-44
The comment does not address the adequacy of the Draft EIR; however, the requested Condition of Approval is noted for the record.

Response to Comment 7-45
Please see Response to Comment 7-44.

Response to Comment 7-46
Please see Response to Comment 7-44.

Response to Comment 7-47
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

Response to Comment 7-48
The comment reiterates comments provided above and does not address the adequacy of the Draft EIR.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 8
8-1
8-2
8-3
8-4
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Letter 8 Cont.
8-4
Cont.
8-5
8-6
8-7
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March 2025
Chapter 2.0 – Responses to Comments

LETTER 8: KEVIN SCHRODER, SACRAMENTO REGIONAL TRANSIT
Response to Comment 8-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.

Response to Comment 8-2
The comment consists of a summary of the project description and setting. The comment does not address the adequacy of the Draft EIR.

Response to Comment 8-3
The comment does not address the adequacy of the Draft EIR and has been noted for the record.

Response to Comment 8-4
As correctly noted by the commentor, one of the options available for future users of the project to reduce VMT is to improve the availability of transit options for future employees. However, as shown in the CAPCOA Handbook, the transit-related measure T-9 (Maximum 5.5% reduction. [See CAPCOA Handbook, p. 95]), is insufficient on its own for the project to achieve the required performance standard of 22 percent and, thus, a multi-pronged approach is required. The commenter’s suggestion regarding cost sharing to provide SacRT service to the site is forwarded to decision-makers for consideration.

Response to Comment 8-5
See Response to Comment 8-3 and 8-4.

Response to Comment 8-6
General Plan Mobility Policy M-1.40 does not indicate transit-related improvements, but rather a proportion of infrastructure improvements that the project induces. The proposed project will be required to provide their required infrastructure improvements and fair-share contributions induced by the project as identified in the local transportation analysis.

Response to Comment 8-7
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Letter 9
9-1
9-2
9-3
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Letter 9 Cont.
9-3
Cont.
9-4
9-5
9-6
9-7
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Letter 9 Cont.
9-7
Cont.
9-8
9-9
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March 2025
Chapter 2.0 – Responses to Comments

LETTER 9: ROBERTO RAMIREZ, SACRAMENTO METROPOLITAN AIR

QUALITY MANAGEMENT DISTRICT
Response to Comment 9-1
The comment consists of an introductory statement and a summary of the project description and setting. The comment does not address the adequacy of the Draft EIR.

Response to Comment 9-2
The comment summarizes the standards of significance used in the Draft EIR for evaluating air quality impacts to sensitive receptors. The comment does not address the adequacy of the Draft EIR.

Response to Comment 9-3
As discussed on page 4.3-53 of the Draft EIR, given that site-specific development plans or designs have not been proposed for Parcel 8, the location of the loading docks are not currently known. As a result, health risks associated with Parcel 8 would be speculative, and, thus, such risks associated with Parcel 8 were not modeled for the Draft EIR analysis.

Nonetheless, because the potential exists for a future distribution center to be developed on Parcel 8 within 1,000 feet of the existing sensitive receptors, future development of Parcel 8 could expose sensitive receptors to excess concentrations of pollutants, and the proposed project could result in a significant impact related to DPM. As such, the Draft EIR includes Mitigation Measure

4.3-3, which requires that if Parcel 8 is proposed to be developed with a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week) within 1,000 feet of a sensitive receptor, prior to the issuance of any building permit, a Health Risk Assessment (HRA) be conducted to calculate the cancer risk associated with on-site truck diesel particulate matter (DPM) emissions. The HRA is required to be prepared in accordance with SMAQMD guidelines, as well as the guidelines identified in the California Office of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments. If health risks associated with Parcel 8 are determined to exceed the applicable SMAQMD thresholds, a qualified air quality consultant is required to identify measures sufficient to reduce the project’s health risks to below the SMAQMD’s thresholds of significance. Reduction measures may include, but are not limited to, relocation of loading docks to further than 1,000 feet from sensitive receptors, electrification of the heavy-duty truck fleet, and/or other options as they become available.

Response to Comment 9-4
The comment summarizes recommendations related to landscaping and does not address the adequacy of the Draft EIR. Please see Response to Comment 9-3.

Response to Comment 9-5
Please see Response to Comment 9-3. The comment does not specifically address the adequacy of the Draft EIR; however, the requested Condition of Approval is noted for the record and will be forwarded to the decision-makers for their consideration.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 9-6
In response to the comment, Table 4.3-1 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, has been revised as follows:

Table 4.3-1
Ambient Air Quality Standards
Pollutant Averaging Time CAAQS
NAAQS
Primary Secondary
Ozone 1 Hour 0.09 ppm - Same as primary 8 Hour 0.070 ppm 0.070 ppm Carbon
Monoxide
8 Hour 9 ppm 9 ppm - 1 Hour 20 ppm 35 ppm
Nitrogen Dioxide
Annual Mean 0.030 ppm 53 ppb Same as primary
1 Hour 0.18 ppm 100 ppb -
Sulfur Dioxide
24 Hour 0.04 ppm - -
3 Hour - - 0.5 ppm
1 Hour 0.25 ppm 75 ppb -
Respirable
Particulate
Matter (PM10)
Annual Mean 20 ug/m3 - Same as primary
24 Hour 50 ug/m3 150 ug/m3
Fine Particulate
Matter (PM2.5)
Annual Mean 12 ug/m3 12 9 ug/m3 15 ug/m3
24 Hour - 35 ug/m3 Same as primary
Lead 30 Day Average 1.5 ug/m3 - -
Calendar Quarter - 1.5 ug/m3 Same as primary
Sulfates 24 Hour 25 ug/m3 - -
Hydrogen
Sulfide 1 Hour 0.03 ppm - -
Vinyl Chloride 24 Hour 0.010 ppm - -
Visibility
Reducing
Particles
8 Hour (see note) - -
ppm = parts per million
ppb = parts per billion
µg/m3 = micrograms per cubic meter
Note: Statewide Visibility Reducing Particle Standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 0.23 per kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.

Source: California Air Resources Board. Ambient Air Quality Standards. May 4, 2016. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf. Accessed February 2024.

The foregoing revision is for clarification purposes only. It is noted that the standard indicated by the commenter was adopted after the NOP for the Draft EIR was published.

Response to Comment 9-7
In response to the comment, Mitigation Measures 4.3-1(a) and 4.3-1(b) in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, have been revised as follows:

4.3-1(a) The following SMAQMD’s Basic Construction Emissions Control Practices (BMPs) for dust control shall be included through a notation on all project grading plans prior to the issuance of grading permits, to the satisfaction Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

of the City of Sacramento Community Development Department and SMAQMD.
• Water all exposed surfaces two times daily. Exposed surfaces include, but are not limited to soil piles, graded areas, unpaved parking areas, staging areas, and access roads;
• Cover or maintain at least two feet of free board space on haul trucks transporting soil, sand, or other loose material on the site.

Any haul trucks that would be traveling along freeways or major roadways should be covered;
• Use wet power vacuum street sweepers to remove any visible trackout mud or dirt onto adjacent public roads at least once a day.

Use of dry power sweeping is prohibited;
• Limit vehicle speeds on unpaved roads to 15 miles per hour (mph);
• All roadways, driveways, sidewalks, parking lots to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used;
• Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes [CCR Title 13, Sections 2449(d)(3) and 2485]. Provide clear signage that posts this requirement for workers at the entrances to the site; • Provide current certificate(s) of compliance for CARB’s In-Use OffRoad Diesel-Fueled Fleets Regulation [CCR Title 13, Sections 2449 and 2449.1]. For more information contact CARB at 877- 593-6677, [email protected], or
www.arb.ca.gov/doors/compliance_ cert1.html.; and
• Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determine to be running in proper condition before it is operated.

4.3-1(b) Prior to approval of any Improvement Plans, the project applicant shall provide proof of compliance with the following to the satisfaction of the City of Sacramento Community Development Department and SMAQMD:

The project applicant shall show on the plans via notation that the contractor shall ensure that the heavy-duty off-road vehicles (50 horsepower or more) to be used in the construction of all project components (i.e., construction of the industrial park,
nonparticipating parcels, and off-site force main), including owned, leased, and subcontractor vehicles, shall be a
combination of engine Tier 3 or Tier 4 off-road construction equipment, or hybrid, electric, or alternatively fueled equipment (or any combination of the above), sufficient to achieve a fleetwide average reduction in construction-related NOX emissions to below the applicable SMAQMD thresholds of significance (85 lbs/day). For instance, the emissions presented in Table 4.3-8 of the Draft EIR were achieved by requiring all equipment used during construction to be engine Tier 4.

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In addition, all off-road equipment operating at the construction site must be maintained in proper working condition according to manufacturer’s specifications. Idling shall be limited to five minutes or less in accordance with the In-Use Off-Road Diesel Vehicle Regulation as required by CARB. Clear signage regarding idling restrictions shall be placed at the entrances to the construction site.

Portable equipment over 50 horsepower must have either a valid SMAQMD Permit to Operate (PTO) or a valid statewide Portable Equipment Registration Program (PERP) placard and sticker issued by CARB.

Conformance with the foregoing requirements shall be included as notes and be confirmed through review and approval of grading plans by the City of Sacramento Community Development
Department.

Response to Comment 9-8
The comment does not address the adequacy of the Draft EIR and is noted for the record.

Response to Comment 9-9
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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Letter 10
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Letter 10 Cont.
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LETTER 10: ROB FERRERA, SACRAMENTO MUNICPAL UTILITY

DISTRICT
Response to Comment 10-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 10-2
The comment summarizes the goals of the Sacramento Municipal Utility District (SMUD) and introduces the following comments. The comment does not address the adequacy of the Draft EIR.

Response to Comment 10-3
Please see the Master Response. It is noted that potential environmental impacts related to electrical infrastructure are addressed in Chapter 4.11, Public Services and Utilities, of the Draft EIR, and potential impacts related to the energy demand of the proposed project are addressed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR.

Response to Comment 10-4
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

However, the comment is noted for the record and will be forwarded to the decision-makers for their consideration.

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Letter 11
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LETTER 11: LESLEY CUMMINGS AND OSCAR BALAGUER, 350

SACRAMENTO
Response to Comment 11-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 11-2
Please see the Master Response. The Draft EIR addresses cumulative impacts from the proposed project consistent with CEQA requirements. The commenter is referred to page 6-5 of the Draft EIR where the cumulative setting is discussed, as well as the Cumulative Impacts and Mitigation Measures section of each technical chapter of the Draft EIR.

Response to Comment 11-3
The comment does not specifically address the adequacy of the Draft EIR and is noted for the record. Please see the Master Response.

Response to Comment 11-4
The Draft EIR, beginning on page 6-1, includes an evaluation of the potential for the proposed project to result in significant effects associated with an elimination of obstacles to population growth or encourage/facilitate other activities that could affect the environment. As noted therein, the proposed project would not result in any significant impacts except for the change in visual character of the site, loss of agricultural land, and emissions of criteria air pollutants. Please also see the Master Response.

Response to Comment 11-5
The comment does not address the adequacy of the Draft EIR and is noted for the record. Please see the Master Response.

Response to Comment 11-6
The comment does not address the adequacy of the Draft EIR and is noted for the record.

Response to Comment 11-7
The comment does not specifically address the adequacy of the Draft EIR and is noted for the record.

Response to Comment 11-8
The comment notes a statement in the Draft EIR, but does not specifically address the adequacy of the Draft EIR. The comment is noted for the record. Please note that land use considerations, as required by CEQA, are addressed in Chapter 4.9 of the Draft EIR.

Response to Comment 11-9
In response to the comment, page 2-5 in Chapter 2, Executive Summary, of the Draft EIR is hereby revised as follows:

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2.5 AREAS OF CONTROVERSY
Areas of controversy that were identified in NOP comment letters, and are otherwise known for the region, include the following:
• Increase in light pollution on nearby residential areas. • Conversion of agricultural land to other uses.
• Construction and operational emissions of criteria pollutants and/or GHG emissions.
• Health concerns related to truck traffic/truck emissions and the proximity of emission sources to sensitive receptors.
• Loss of plant and wildlife habitat.
• Lighting, noise, and wildlife-human interactions.
• Removal of wetlands or protected plant and animals.
• Potential impacts related to the inadvertent discovery of cultural, historical, or tribal resources at the project site.
• Use of hazardous materials, including rodenticides.
• Degradation of water quality in area waterways.
• Sufficiency of stormwater management.
• Increased and/or exacerbation of flood hazards due to changes in drainage patterns.
• Incompatibility with surrounding land uses.
• Consistency with LAFCo and City Sphere of Influence procedures. • Consistency with City and County General Plans, and Airport Land Use Compatibility Plan.
• Increase in noise levels to nearby residential areas. • Annexation into the Regional Sanitation and Sacramento Area Sewer District service area.
• Supply and capacity of water and wastewater facilities. • Traffic increases in the project vicinity.
• Increased traffic delays and congestion during commute hours. • Cumulative traffic impacts on the local and regional transportation system. • Hazards for pedestrians and cyclists associated with increased truck traffic. • Potential cumulative impacts in combination with the Metro Air Park. • Growth-inducing impacts.
• Override of the boundaries of the Sacramento County Urban Policy Area (UPA) and Urban Service Boundary (USB).

The focus of CEQA and the Draft EIR is limited to the “significant environmental effects” of a project. Contrary to the claim of the commenter, the Draft EIR does address the development of the proposed project outside of the County’s Urban Policy Area (UPA) and Urban Service Boundary (USB) in that the physical impacts to the environment are addressed. Potential impacts associated with inconsistency with a UPA or USB (beyond the physical impacts to the environment at the project site) would be associated with inducing unplanned growth. However, the potential growth-inducing impacts associated with the proposed project are addressed in Chapter 6, Statutorily Required Sections, of the Draft EIR. In addition, page 4.9-20 in Table 4.9- 6, Discussion of Relevant Sacramento LAFCo Policies, in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR, states, “The proposed project currently lies outside the Sacramento County USB. The USB and the City of Sacramento boundaries represent the limit of the Sacramento County service areas for SacSewer.” As such, the Draft EIR does not confuse the USB with the City boundaries, but, rather, indicates that both represent the limit of Final EIR
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the SacSewer service area. Furthermore, consistent with Sacramento LAFCo Policy B.3, the proposed project would require approval of annexation into the City prior to approval of annexation of the project site into the service area for SacSewer.

It is noted that a cumulative impact analysis is included in each technical chapter of the Draft EIR, which evaluates potential impacts of the proposed project in combination with reasonably anticipated development in the project vicinity.

Response to Comment 11-10
Please see the Master Response. The focus of CEQA and the Draft EIR is limited to the physical impacts of a project, and thus, does not evaluate the need for the proposed development.

Furthermore, although Chapter 7, Alternatives Analysis, of the Draft EIR does not specifically address the potential for an Off-Site Alternative within the Metro Air Park, an Off-Site Alternative is discussed on page 7-5. As discussed therein, sites considered for an Off-Site Alternative are limited to those that do not require the City to annex land or expand its Sphere of Influence. The Metro Air Park is located outside the City’s Sphere of Influence, would require Annexation, and, unlike the project site, was not included as a “Special Study Area” in Map LUP-1 of the City’s 2040 General Plan. Therefore, the Metro Air Park was not considered, and would not be appropriate for consideration, as the Off-Site Alternative location. For the foregoing reasons and the reasons presented on page 7-5 of the Draft EIR, the Off-Site Alternative was dismissed from further review.

Response to Comment 11-11
Please see the Master Response. A determination of General Plan consistency does not require consistency with virtually every policy included in the General Plan, only compliance with those applicable policies that are related to mitigating environmental impacts. The proposed project’s compliance with applicable 2040 General Plan policies is addressed under Impact 4.9-3 and in Table 4.9-7, City of Sacramento 2040 General Plan, in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR. As such, the Draft EIR provides analysis of the project’s compliance with the Sacramento 2040 General Plan polices. The decision makers will determine whether the proposed project is consistent with the General Plan as a whole.

Response to Comment 11-12
As stated on page 4.12-21 in Chapter 4.12, Transportation, of the Draft EIR, Mitigation Measure

4.12-3 requires that “The VMT Reduction Plan shall be submitted to the City’s Department of Public Works and Community Development Department for review and approval.” Therefore, the City of Sacramento shall be responsible for monitoring and enforcing implementation of the VMT mitigation. It is noted that, pursuant to the CEQA Guidelines, the analysis of the Draft EIR assumes that all applicable laws and regulations shall be fully complied with, and that mitigation measures shall be implemented to the fullest extent. In addition, as noted in Mitigation Measure

4.12-3, the Draft EIR included as Appendix Q a VMT Mitigation Memorandum prepared by Avdis & Cucci. The VMT Mitigation Memorandum provides evidence of the feasibility and effectiveness of achieving the reductions required by the mitigation measure.

Response to Comment 11-13
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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12-1
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LETTER 12: HEATHER FARGO AND SUSAN HERRE, ENVIRONMENTAL

COUNCIL OF SACRAMENTO
Response to Comment 12-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 12-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 12-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 12-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 12-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

It should be noted that potential impacts related to air quality and transportation are addressed in Chapters 4.3 and 4.12 of the Draft EIR, respectively.

Response to Comment 12-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 12-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

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Letter 13
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LETTER 13: ENVIRONMENTAL COUNCIL OF SACRAMENTO
Response to Comment 13-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 13-2
The comment expresses concern regarding the administrative CEQA process, but does not specifically address the adequacy of the Draft EIR analysis of potential impacts on the environment. Please see the Master Response.

Response to Comment 13-3
Applicable federal regulations are included in the Regulatory Context section of each technical chapter, where relevant. When federal plans and regulations are relevant to the analysis, they are discussed and analyzed. For example, potential impacts to federally protected special-status species are identified in Chapter 4.4, Biological Resources, of the Draft EIR, and applicable federal standards of significance are presented in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. The National Environmental Policy Act (NEPA) process is separate from CEQA and would be conducted at such a time that any federal nexus occurs (including permits). Applications for federal permits have not been filed by the applicant and the project does not include any federal funding. Therefore, NEPA is not required at this time.

Response to Comment 13-4
Potential impacts of the proposed project related to the Natomas Basin HCP are addressed throughout Chapter 4.4, Biological Resources, of the Draft EIR, most specifically under Impact

4.4-14 beginning on page 4.4-70.

Response to Comment 13-5
Mitigation measures are included when relevant throughout Chapter 4.4, Biological Resources, of the Draft EIR, which, as revised in this Final EIR, are sufficient to reduce potential impacts to a less than significant level. As such, additional mitigation is not required.

Response to Comment 13-6

Land Use and Planning/Population and Housing, of the Draft EIR, states, “The proposed project currently lies outside the Sacramento County USB. The USB and the City of Sacramento boundaries represent the limit of the Sacramento County service areas for SacSewer.” Therefore contrary to the comment, the Draft EIR does not ignore the USB. Furthermore, the focus of CEQA and the Draft EIR is limited to the significant environmental effects of a project; the comment does not address or relate to any potentially significant environmental effects from building the proposed project outside of the County’s UPA and USB. Please see the Master Response.

Response to Comment 13-7
Potential impacts associated with future buildout of the nonparticipating parcels are analyzed throughout the Draft EIR, including air quality, noise, and aesthetics. Each impact statement in each technical chapter includes headers that identify if the analysis is focused on the industrial park, the nonparticipating parcels, and/or the full buildout of the project site.

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Response to Comment 13-8
Because project-specific plans have not yet been prepared for the nonparticipating parcels, the Draft EIR provides a program-level analysis of future development of the nonparticipating parcels.

As such, an Aquatic Resources Delineation (ARD) was not conducted for the nonparticipating parcels, including Parcel 8. Nonetheless, the Draft EIR does provide adequate level of analysis of potential impacts associated with future buildout of the nonparticipating parcels. The Draft EIR concludes that a potential impact could occur and includes Mitigation Measure 4.4-11(e), which requires that an ARD be conducted for the nonparticipating parcels prior to any development. In addition, Mitigation Measure 4.4-11(f) requires proper actions be taken if protected aquatic resources are identified. As such, any impacts related to aquatic resources and any associated special-status species that may occur at the time of future buildout of Parcel 8 would be adequately mitigated to a less-than-significant level by the proposed project.

Response to Comment 13-9
As discussed under Impact 4.8-2 in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR, adequate detention basins would be provided to serve the proposed project; the analysis therein presents all relevant and necessary information to support the conclusion. Furthermore, the Draft EIR includes a discussion of the potential for the proposed stormwater retention/detention areas to attract avian species and expose them to collisions with aircraft associated with the Sacramento International Airport under Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR.

Response to Comment 13-10
Potential impacts related to water quality are addressed under Impacts 4.8-1 and 4.8-2 in Chapter

4.8, Hydrology and Water Quality, of the Draft EIR. In addition, cumulative impacts related to water quality are addressed under Impact 4.8-6. As discussed therein, impacts related to such would be less than significant with implementation of mitigation.

Response to Comment 13-11
See Response to Comment 9-6.

Response to Comment 13-12
See Response to Comment 13-7.

Response to Comment 13-13
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

It should be noted that Parcel 8, if not included in the annexation, would still have the southern boundary adjacent to unincorporated county land and thus would not result in an “island”.

Response to Comment 13-14
As discussed on page 1-2 of the Draft EIR, because the proposed project would not approve any development of the nonparticipating parcels at this time, the Draft EIR includes a program-level analysis of the environmental impacts associated with the proposed entitlements for the nonparticipating parcels, pursuant to CEQA Guidelines Section 15168. For example, page 3-8 of the Project Description chapter of the Draft EIR provides the following:

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Nonparticipating Parcels
The proposed project includes several nonparticipating parcels comprised of approximately 83 acres, which would receive first-tier entitlements, such as the proposed SOI Amendment to amend the City of Sacramento SOI and Annexation of the site into the City limits and SacSewer service area, for future industrial uses of approximately 1,404,800 sf. These future development areas include six existing parcels controlled by separate owners, which are summarized as follows:
• Parcel 8: 64.3 acres (Cayocca);
• Parcel 9: 6.5 acres (Campbell);
• Parcel 10: 4.6 acres (Isgur Trust); and
• Parcel 11: 0.7-acre (Patel).

In addition, the nonparticipating parcels include 6.9 acres of Caltrans Remnant ROW. The Caltrans Remnant ROW has been included as developable because it may be a candidate for future private acquisition. The parcels would receive General Plan and Prezoning designations as part of the City process. Any development proposed for these sites would require additional entitlement requests and review pursuant to CEQA.

Contrary to the comment, the Draft EIR discloses potential impacts related to existing sensitive receptors in proximity to Parcel 8. For instance, the analysis under Impact 4.3-3, which starts on page 4.3-48 of the Draft EIR, includes a health risk assessment of potential impacts related to diesel particulate matter (DPM). The Draft EIR concludes that future development of Parcel 8 could expose sensitive receptors to excess concentrations of DPM, and as a result, requires Mitigation Measure 4.3-3. With implementation of Mitigation Measure 4.3-3, which requires completion of a Health Risk Assessment (HRA) in accordance with SMAQMD guidelines, as well as the guidelines identified in the California Office of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments. If health risks associated with Parcel 8 are determined to exceed the applicable SMAQMD thresholds, Mitigation Measure 4.3-3 requires a qualified air quality consultant to identify measures sufficient to reduce the project’s health risks to below the SMAQMD’s thresholds of significance. Thus, the Draft EIR concludes that with implementation of Mitigation Measure 4.3-3, a less-than-significant impact would occur. Therefore, the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR, including those related to Parcel 8, are adequate.

Similarly, potential impacts related to noise-level increases and groundborne vibration (see Impacts 4.10-1, 4.10-2, and 4.10-3, which start on pages 4.10-15, 4.10-16, and 4.10-25, respectively, of the Draft EIR) are evaluated relative to noise levels and vibration levels that would be experienced as a result of project construction and operation at the nearest sensitive receptors.

As discussed on page 4.10-3 of the Draft EIR, the nearest noise sensitive receptor to the project site is identified as the single-family residences adjacent to Parcel 8 and the Paso Verde K-8 School. Impacts 4.10-1 (noise-level increases due to project construction) and 4.10-3 (groundborne vibration) are concluded to result in a less-than-significant impact. However, because full buildout of the annexation area, including Parcel 8, would exceed the City’s nighttime 50 dBA L50 noise level standard, the Draft EIR requires implementation of Mitigation Measure

4.10-2, which would ensure that the final improvement plans include an eight-foot-tall sound wall along the eastern project boundary of Parcel 8, which would reduce nighttime noise levels to being compliant with the City’s nighttime 50 dBA L50 noise level standard. Thus, the analyses and conclusions in the Noise chapter of the Draft EIR, including those related to Parcel 8, are adequate.

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The Draft EIR similarly includes evaluation of potential environmental impacts related to transportation and light and glare that would result from full buildout of the project site with the proposed uses in the Transportation and Aesthetics chapters of the Draft EIR, respectively.

Please see the analyses and conclusions contained therein.

Response to Comment 13-15
Parcel 8, along with the other nonparticipating parcels (see page 3-8 of the Draft EIR), is included in the analyses of potential environmental impacts in the Draft EIR that could occur as a result of full buildout of the project site with the proposed uses. Full buildout of the project site, including future development of the nonparticipating parcels, is addressed in the cumulative analysis within each technical chapter of the Draft EIR. For the analysis of potential impacts to federally and State-protected wetlands, including those that would occur through development of Parcel 8, please see Impact 4.4-11, which starts on page 4.4-64 of the Draft EIR.

For the analysis of potential impacts related to drainage facilities, including those that would occur through development of Parcel 8, please see Impacts 4.8-1, 4.8-2, and 4.8-4, which start on pages

4.8-14, 4.8-17, and 4.8-24 of the Draft EIR, respectively.

Response to Comment 13-16
As stated in the comment, the project site is located outside of the Sacramento County’s USB, and a substantial discussion of such is not included in the Draft EIR. As discussed in Chapter 1, Introduction, of the Draft EIR, the Sacramento LAFCo and the City of Sacramento are both the Lead Agencies for the proposed project. Because Sacramento County is not a Lead Agency, the Draft EIR is not required to address compliance with County policies, and the proposed project is not subject to compliance with the County policies because the project would be annexed into the City of Sacramento, should all entitlements be approved by the LAFCo Commissions and City Council.

Response to Comment 13-17
See Response to Comment 13-16. Please also see the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR for an analysis of project impacts related to air quality and greenhouse gas emissions.

Response to Comment 13-18
See Response to Comment 13-16.

Response to Comment 13-19
See Response to Comment 13-16.

Response to Comment 13-20
See Response to Comment 13-16. In addition, it is noted that potential impacts related to the project site’s annexation into utilities service districts are addressed in Chapter 4.11, Public Services and Utilities, of the Draft EIR.

Response to Comment 13-21
See Response to Comment 13-16.

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Response to Comment 13-22
As stated on page 4.0-4 in Chapter 4.0, Introduction to the Analysis, of the Draft EIR, “The cumulative setting for the proposed project is generally considered to be a summary of projections contained in the City of Sacramento 2040 General Plan and the Sacramento County General Plan.” The cumulative setting for the proposed project is defined further beginning on page 6-5 of Chapter 6, Statutorily Required Sections, of the Draft EIR, and includes all relevant development.

Response to Comment 13-23
See Response to Comment 2-4.

Response to Comment 13-24
The Draft EIR includes an analysis of effects on the Natomas Basin HCP that could result from implementation of the proposed project under Impact 4.4-14. As detailed therein, the proposed project would not affect the effectiveness of the 0.5:1 mitigation ratio for the 17,500 acres of urban development authorized by the Natomas Basin HCP. Changes in land use outside of an existing Natomas Basin Conservancy reserve because of the development of the proposed project are unlikely to necessitate changes to existing Site-Specific Management Plans (SSMPs). The effects of the proposed project on Swainson’s hawk foraging habitat would not alter the viability of any of the populations of Natomas Basin HCP Covered Species.

Response to Comment 13-25
See Response to Comment 13-24. Potential impacts to Swainson’s hawk are discussed under Impact 4.4-5 in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, with implementation of mitigation, potential impact would be reduced to a less-than-significant level.

Response to Comment 13-26
As noted on pages 4.4-56 and 4.4-57 in Chapter 4.4, Biological Resources, of the Draft EIR, Aleutian Canada goose and white-faced Ibis are not expected to occur on-site. Impacts to the foregoing species were determined to be less than significant, in part, because of implementation of Mitigation Measure 4.7-5. Measure 4.7-5 requires preparation of a Wildlife Hazard Management Plan to specifically address the potential for waterfowl and other bird species to interact with the project’s proposed detention basins. The Wildlife Hazard Management Plan would be prepared and carried out in coordination with wildlife hazard specialists and airport personnel, with detailed measures regarding reducing bird attractants and adaptive management to ensure long-term success.

Response to Comment 13-27
As discussed on page 4.4-75 in Chapter 4.4, Biological Resources, of the Draft EIR, the success of the Natomas Basin HCP does not require a certain amount of agricultural land remaining in the basin. While the Natomas Basin HCP discussed the potential for land in the basin to remain in agricultural land uses, the success of the Natomas Basin HCP did not rely on any particular number of acres, outside of the Natomas Basin HCP required reserves, remaining in agriculture.

Response to Comment 13-28
As discussed further under Response to Comment 13-31, the Draft EIR did not preclude the potential for obtaining an incidental take permit, and listed both USFWS and CDFW as agencies Final EIR
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from which the project would require approvals or permits. In fact, Mitigation Measure 4.2-1 mentions that developers may apply for incidental take or other habitat permits. In addition, Mitigation Measures 4.4-3 and 4.4-5(b) have been revised under Response to Comment 2-5 of this Final EIR to provide for the potential need for an incidental take permit. Thus, a failure to disclose has not occurred.

Nonetheless, context is needed for the document colloquially referred to as “the Levi decision”.

U.S. District Court Judge David F. Levi rendered a Memorandum of Opinion and Order in the matter of NWF v. Norton on September 7, 2005. The lengthy opinion granted summary judgment for defendants USFWS and Secretary Gale Norton, thus upholding the validity of the revised Natomas Basin HCP.

The case of NWF v. Norton was the second time the U.S. District Court had been asked to review an HCP for the Natomas Basin. In the September 7, 2005 Memorandum of Opinion, the court found the revised Natomas Basin HCP satisfied the Endangered Species Act and rejected plaintiffs’ claims to the contrary. Among other things, plaintiffs in that case argued that the USFWS failed to consider cumulative impacts of other potential future development projects in the basin.

The court discussed the potential for future development in the basin, and observed that considerable local, state, and federal approvals would be required in order for other land to be developed in the basin.

In Comment 13-29, commenter cites from footnote 13 of the Memorandum of Opinion, regarding the “uphill battle” future development in the Natomas Basin might face. The text immediately preceding this footnote provides important context:

The Service, and the court, are entitled to assume at this point that future development will not be permitted if sufficient mitigation land is unavailable and the development will result in jeopardy.

In context, it becomes clear that the court had confidence in the ability of the wildlife permitting agencies to evaluate future development requests as they may arise in the future. While the court may have opined, in a footnote, about an “uphill battle,” the District Court’s task in 2005 was to evaluate the legality of the USFWS actions when approving the Natomas Basin HCP and issuing incidental take permits, not to prospectively bind the hands of USFWS or any other agency as to future permitting decisions it may make or to pre-judge the legality of any future development actions in the basin.

As discussed further under Response to Comment 13-31, the City is not proposing that this project would exceed the 8,050 acres of Authorized Development acreage allotted to the City under the Natomas Basin HCP and related permits, rendering the 2005 Memorandum of Order even less relevant to the City’s evaluation of the proposed project.

Particularly in light of this important context, the commenter is incorrect in asserting that the Memorandum of Opinion “clearly states” that any additional development in the Basin beyond the 15,517 acres (City 8,050 acres and Sutter County 7,467 acres) would be a per se significant impact on the Natomas Basin HCP or that a separate ITP/2081 is the only way to avoid such an impact. The Memorandum of Opinion does not contains any such statements.

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Response to Comment 13-29
Chapter I of the Natomas Basin HCP describes the plan formulation process in great detail. While the original desire for basin-wide habitat management arose out of flood control plans in the early 1990s, flood control plans such as the Natomas Levee Improvement Project ultimately obtained separate incidental take coverage, and none of the water or flood control agencies signed onto the Natomas Basin HCP. (See NBHCP, pages I-23 to I-27; NLIP Programmatic Biological Opinion 2008.) Thus, the applicability of the Natomas Basin HCP is not connected to flood control.

As discussed under Response to Comment 13-28, the portions of the NWF v. Norton Memorandum of Opinion cited by commenter are addressing whether the USFWS should have evaluated the potential cumulative effects of the 2002 “Joint Vision MOU” between the City and County of Sacramento. The court explained the tentative and general nature of the MOU, and broadly summarized portions of the USFWS Biological Opinion related to cumulative effects.

Importantly, the Biological Opinion did not state that any future development in the Natomas Basin would be a federal action. Rather, in the context of discussing potential cumulative effects, it said that “any activities in the Natomas Basin that result in take of listed animal species would require either: (1) a Section 10 permit, a federal action... or (2) a Section [7] consultation with the Service if a federal action is involved.” (Biological Opinion pages 200-201, emphasis added.) In any event, as stated on pages 4.4-64 through 4.4-64 of the Draft EIR, the proposed project could have impacts to waters that are potentially subject to the Clean Water Act Section 404 jurisdiction of the USACE. Thus, should a 404 permit be required, the project would require federal action.

The commenter quotes from the NWF v. Norton Memorandum of Opinion regarding the analysis in the Biological Opinion, not, as commenter suggests, the Biological Opinion itself. For example, in the second full paragraph on page 11 of the comment letter, the commenter quotes from pages 10 and 11 of the Memorandum of Opinion, where the court summarized some of the discussion within the Biological Opinion, but did not quote the Biological Opinion itself. Based on the foreseeable development at the time the Natomas Basin HCP was approved, the Biological Opinion noted that substantial amounts of Swainson’s hawk foraging habitat, including mitigation lands, would likely remain in the basin after implementation of the Natomas Basin HCP, and also noted the abundant foraging habitat in Yolo County for Swainson’s hawks that nest in or near the Natomas Basin. (Biological Opinion, p. 184.) Like the Biological Opinion, the Natomas Basin HCP itself discussed the likelihood, at the time of the HCP’s approval, that other acreage in the Natomas Basin would remain in agricultural uses for quite some time but clarified that such “baseline foraging habitat” was not mitigation. (See Natomas Basin HCP, IV-13; Draft EIR p. 4.4-

75.)
Again, in the context of discussing the potential effects of the Joint Vision MOU on the Natomas Basin HCP, the court observed that future development proposals would be subject to environmental review. (See Memorandum of Opinion page 30.) The footnote regarding an “uphill battle” is discussed further under Response to Comment 13-28, but ultimately, it is up to the USFWS and CDFW to determine whether a particular development beyond the 17,500 acres of Authorized Development covered by the Natomas Basin HCP would result in jeopardy to a listed species. Even so, the Draft EIR explains on page 4.4-71 that the project could be approved without exceeding the City’s 8,050-acre Authorized Development acreage limit, and thus without Final EIR
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exceeding 17,500 acres of development (including the acreage of Metro Airpark HCP) basin-wide.

Furthermore, the Draft EIR concluded on page 4.4-82 that the potential incremental contribution of the project to overall loss of habitat for special status species would be reduced to a less than cumulatively considerable level with implementation of the project-specific mitigation measures required in the EIR.

As discussed under Response to Comment 13-27, as explained in the Draft EIR, the success of the Natomas Basin HCP does not require a certain amount of agricultural land remaining in the basin.

As noted herein, the Draft EIR does address these important topics. The Draft EIR also refers on page 4.4-30 to “jeopardy,” in the context of CDFW’s permitting discretion to determine whether jeopardy would occur. Chapter 4.4, Biological Resources, of the Final EIR has been prepared to:
a) clarify that the USFWS also has the permitting discretion to determine whether jeopardy would occur and b) outline the potential for the project applicant to seek separate incidental take coverage (as applicable) for the portion of the site that is currently outside the mapped “Permit Area” in the event coverage is not available under the City’s unallocated Authorized Development acreage.

Response to Comment 13-30
As discussed on page 4.4-41 of the Draft EIR, according to the City’s letter to the U.S. Fish and Wildlife Service’s (USFWS) Sacramento Fish and Wildlife Office, CDFW, and Natomas Basin Conservancy, dated April 3, 2024, the City reports that of the 8,050 acres anticipated for development within the City’s portion of the HCP permit area, 6,791.94 acres have been authorized for grading. While, as alluded to by the commenter, the Natomas Basin Conservancy reports in its 2023 Implementation Annual Report that authorized grading in the City’s portion of the HCP permit area totals approximately 6,991.16 acres, the 2023 Implementation Annual Report notes on page 21 the following:

The Conservancy is reporting City of Sacramento fee-paid acres as 6,991.16. However, a small difference exists between the Conservancy’s and the City’s numbers. The Conservancy and the City agree on this difference which is due to prepaid acres that have not yet been graded. See City of Sacramento’s 2023 Annual Report of Urban Development for details.

As further detailed on page 4.4-41 of the Draft EIR, starting in 2009, the City’s Annual Reports began including a graphic that showed “HCP Fee Areas Remaining.” The graphic shows lands remaining to pay fees under the Natomas Basin HCP, including 121.68 acres of the project area (2023 Annual Report, Attachment E). Over the years since 2009, similar attachments to the City’s annual reports have shown that the total area graded under the HCP, plus the identified fee areas remaining, totaled less than 8,050 acres. In other words, the City’s records show a surplus of acreage of HCP coverage not attributed to a particular project or parcel. The current 2023 HCP Annual Report shows a surplus of 358 acres not attributed to a particular project or parcel. The DEIR discussion of “surplus” acreage referred to this unallocated Authorized Development acreage, not the “surplus approved mitigation land” described in the Conservancy’s annual reports. Due to this surplus acreage, the City could approve the project without exceeding the 8,050-acre development acreage limit. Additionally, the Draft EIR includes an analysis of effects on the Natomas Basin HCP that could result from implementation of the proposed project under Impact 4.4-14, which concludes that a less-than-significant impact would occur.

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Response to Comment 13-31
As discussed under Response to Comment 13-30, the Draft EIR referenced unallocated Authorized Development acreage, and did not refer to the Conservancy’s “surplus approved mitigation lands.” Thus, diversion of lands already conserved would not occur.

The project is expected to seek coverage under the Natomas Basin HCP within the 8,050 acres of Authorized Development allotted to the City of Sacramento under that HCP. In the event such coverage is not available for some reason, the EIR’s analysis would not preclude the potential for the project to seek a separate incidental take permit (or applicable permitting) from CDFW. In fact, the Draft EIR lists CDFW and USFWS on page 3-14 as agencies that may be involved in granting approvals or coordinating with other agencies with regard to the project. (see also page 4.2-19 of the Draft EIR, noting that the EIR’s agricultural and open space mitigation is not “intended to limit or restrict USFWS and CDFW in their consideration of Developer’s applications for incidental take and/or other habitat mitigation permits or other entitlements under the federal Endangered Species Act and the California Endangered Species Act.”) Chapter 4.4 of the Final EIR clarifies the potential for the project applicant to seek separate incidental take coverage for the portion of the site that is currently outside the mapped “Permit Area” in the event coverage is not available under the City’s unallocated Authorized Development acreage.

The City is not proposing to approve urban development beyond the 8,050 acres of Authorized Development allowed under the Natomas Basin HCP. Nonetheless, the Draft EIR evaluated the potential effects of the proposed project on the Natomas Basin HCP conservation strategy on pages 4.4-71 to 4.4-76. Should unallocated acreage within the 8,050 acres not be available to the project, the wildlife agencies may require additional analysis to support a separate permitting approach.

See Responses to Comments 13-28 and 13-29, above, regarding the NWF v. Norton decision.

Response to Comment 13-32
See Response to Comment 13-31. Pages 4.4-71 through 4.4-77 of Chapter 4.4, Biological Resources, of the Draft EIR include an extensive discussion of the project’s potential effects upon the Natomas Basin HCP Conservation Strategy and concluded that the project would not reduce the effectiveness of the HCP’s operating conservation program or conflict with the provisions of an adopted plan.

Response to Comment 13-33
While the Greenbriar Project is located in a similar location to the proposed project and required similar entitlements, the currently proposed project is not required to use the same mitigation measures included in that analysis. The comment does not address the adequacy of the Draft EIR.

Response to Comment 13-34
Contrary to the claim of the commenter, as discussed under Impact 4.4-5 in Chapter 4.4, Biological Resources, of the Draft EIR, to ensure overall preservation of Swainson’s hawk foraging habitat at a 1:1 ratio, the proposed project would be subject to Mitigation Measure 4.2-1, which is Final EIR
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detailed in the Agricultural Resources chapter of the Draft EIR and necessitates preservation of off-site farmland at a ratio of one Farmland acre converted to urban land uses outside the Natomas Basin HCP policy area to 0.5-acre preserved. Combined with the requirements of Mitigation Measure 4.4-5(b), the proposed project would preserve Swainson’s hawk foraging habitat at a 1:1 ratio.

Response to Comment 13-35
The commenter seems to be referring to Mitigation Measure 4.2-1, which allows for a portion of the project’s mitigation for impacts to agricultural lands to occur outside the Natomas Basin. While such lands could also provide foraging habitat for Swainson’s hawk and other special-status species, the agricultural mitigation acreage is not connected to the mitigation requirements of the Natomas Basin HCP, and therefore, the project would not conflict with the Natomas Basin HCP on this point.

Response to Comment 13-36
The commenter does not clearly explain how their belief that the reference to CDFW guidelines for Swainson’s hawk foraging habitat is in conflict with the Natomas Basin HCP.

The 1994 “Staff Report Regarding Mitigation for Impacts to Swainson’s Hawks (Buteo swainsoni) in the Central Valley of California” includes mitigation ratios for Swainson’s hawk foraging habitat ranging from 0.5:1 to 1:1 depending on the distance between the impacted habitat and an active nest tree. Thus, 0.5:1 is within the range described in the Staff Report, and in the event an individual permit is needed, a higher ratio requirement would be within the discretion of CDFW.

Unlike the Greenbriar project, at least a portion of the proposed project is within the mapped Natomas Basin HCP Permit Area, and the entire project could be completed without the City exceeding its allocated 8,050 acres of Authorized Development. Thus, mitigation ratios employed for Greenbriar are not applicable here.

Response to Comment 13-37
See Response to Comment 2-5.

Response to Comment 13-38
See Response to Comment 2-4.

Response to Comment 13-39
See Response to Comment 13-38. Mitigation for project impacts to Swainson’s hawk are described under Impact 4.4-5 in Chapter 4.4, Biological Resources, of the Draft EIR. Additional mitigation is not required.

Response to Comment 13-40
See Response to Comment 2-8.

Response to Comment 13-41
See Response to Comment 13-40. Cumulative impacts of the proposed project related to biological resources, including Swainson’s hawk, are evaluated under Impact 4.4-15 beginning on page 4.4-78 in Chapter 4.4, Biological Resources, of the Draft EIR.

Final EIR
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Chapter 2.0 – Responses to Comments

Response to Comment 13-42
As discussed under Impact 4.3-7 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, SMAQMD’s threshold of significance for operational GHG emissions are qualitative in nature. As such, even with consideration of carbon sequestration loss due to the land use changes that would occur as a result of the proposed project, the conclusions within the Draft EIR would not change. Furthermore, the CEQA Guidelines do not require an analysis of the loss of carbon sequestration associated with the proposed project. Nonetheless, Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, is hereby revised as follows for disclosure purposes only:

It should also be noted that emissions associated with heavy-duty trucks travelling to and from the project site were calculated off-model using project-specific trip generation rates provided by DKS, trip length data provided by Fehr and Peers for the Metro Air Park Project located just north of the project site, and vehicle emission factors from the CARB’s mobile source emissions inventory (EMFAC2021) model. Consistent with the Travel Behavior Memorandum prepared by Fehr and Peers for the Metro Air Park Project, an average length of 44.80 miles was assumed for heavy truck trips.1 EMFAC2021 was used to calculate all mobile-sourced emissions associated with heavy-duty vehicles.

In addition, the current carbon uptake rate associated with on-site agricultural biomass and soils was estimated to be 63 MTCO2e per acre based on the combined soil and biomass carbon factors for General Agricultural lands included in the Sacramento County Landscape Carbon Assessment (December 2017). Such emissions were added to the project operational emissions to account for the loss of the agricultural carbon uptake onsite.

The estimated emissions from CalEEMod and EMFAC2021 were added together to represent total project emissions, and were compared to the standards of significance discussed above in order to determine the associated level of impact. All CalEEMod results and EMFAC2021 calculations are included in Appendix C to this EIR.

Table 4.3-15 of the Draft EIR is hereby revised as follows:

Table 4.3-15
Unmitigated Annual Operational GHG Emissions
(MTCO2e/yr)
Emission Source Proposed Project
Full Buildout of
Annexation Area
Area 0.24 0.26
Energy 15,810.63 16,073.94 20,241.33
Mobile1 41,607.79 48,833.4
Offroad 2,893.68 4,411.25
Waste 3,375.85 4,251.88
Water 1,729.94 1,730.03 2,193.65
Loss of Carbon Uptake 17,767.89 22,996.89
TOTAL ANNUAL GHG EMISSIONS 65,418.13 83,449.42 102,298.66 1 Mobile emissions include both passenger vehicle emissions estimated in CalEEMod, as well as heavy-duty vehicle emissions calculated off-model using EMFAC2021.

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Sources:
• CalEEMod, June 2023; August 2024 (see Appendix C).
• Sacramento County Landscape Carbon Assessment, December 2017.

The foregoing revisions are for disclosure purposes only and do not affect the conclusions of the analysis.

Response to Comment 13-43
Although the proposed project would result in the loss of on-site agricultural land, thus resulting in the loss of on-site carbon sequestration, pursuant to Mitigation Measures 4.2-1 and 4.4-5(b), farmland would be preserved off-site at a 1:1 ratio. Because such land would not be developed and the farmland would be protected, the proposed project would contribute towards the overall carbon sequestration on a regional scale. As such, potential impacts associated with air quality and GHG emissions related to the loss of on-site farmland are adequately addressed in the Draft EIR. In addition, see Response to Comment 13-42.

Response to Comment 13-44
See Response to Comment 13-27.

Response to Comment 13-45
As discussed under Impact 4.2-5 in Chapter 4.2, Agricultural Resources, of the Draft EIR, the proposed project would result in a cumulatively considerable and significant and unavoidable impact related to conversion of important farmland. The loss of important farmland associated with buildout of each individual reasonably foreseeable future development in the cumulative setting of the proposed project would not change the significance of the conclusion of the analysis.

Furthermore, potential impacts associated with the reasonably foreseeable future development related to the loss of important farmland would be addressed as part of the analysis of such projects. In addition, the City’s 2040 General Plan MEIR and the County’s General Plan EIR, as well as the other reasonably foreseeable development that consist of the cumulative setting for the agricultural analysis of the proposed project, contain estimates of how much important farmland is anticipated to be lost. Because such anticipated development is not guaranteed to occur, determining the exact acreage of cumulative loss of farmland would be difficult and speculative. Furthermore, because the Draft EIR concluded that the cumulative impact would be cumulatively considerable and significant and unavoidable, an accurate estimate would not significantly contribute to the analysis of or change the conclusion. Therefore, the information provided in the Draft EIR is adequate for the analysis, pursuant to the CEQA Guidelines.

Response to Comment 13-46
SMAQMD was provided the AQMP for review. On June 19,2024 Air District Staff provided a verification letter confirming the adequacy of the AQMP. The verification letter is attached as Appendix A to this Final EIR and hereby added to the record.

Response to Comment 13-47
Please see Response to Comment 9-3.

Response to Comment 13-48
The source of the one-in-a-million threshold referenced in the comment is unclear. SMAQMD does not have a “stationary source permitting rule” specifically. Rather, the rules included under Final EIR
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SMAQMD Regulation 2 – Permits include permitting requirements for stationary sources.

However, none of the SMAQMD rules related to permitting reference the one-in-a-million threshold for the imposition of T-BACT.

In addition, the commenter fails to provide evidence as to why the referenced one-in-a-million threshold used specifically for the imposition of T-BACT for stationary sources should be applied, rather than the SMAQMD’s threshold of significance established specifically for the review of local community risk and hazard impacts included in their CEQA Guidance (see Chapter 5 of the SMAQMD CEQA Guide). While the SMAQMD’s cancer risk threshold of 10 in one million people is intended for stationary sources, such thresholds are consistent with the thresholds used for Assembly Bill (AB) 2588 risk assessment procedures, as established by the State.

Furthermore, SMAQMD provided a comment letter on the Draft EIR (see Comment Letter 9) and did not comment on the use of the established cancer risk threshold of 10 in one million people.

Thus, the use of the cancer risk threshold of 10 in one million people in the Draft EIR is adequate, and additional analysis is not warranted.

Response to Comment 13-49
The comment cites regulations of the South Coast AQMD which do not apply to the project site.

The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 13-50
As stated on page 1-6 of Chapter 1, Introduction, of the Draft EIR, “The baseline condition for this EIR is the physical condition that exists when the NOP is published. The NOP for the proposed project was published on March 4, 2022. […] According to CEQA Guidelines Section 15125(d), the EIR shall discuss any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans. An ‘applicable’ plan is a plan that has already been adopted and, thus, legally applies to a project; draft plans need not be evaluated.1 ” The physical
condition that exists when the NOP is published is understood to include all applicable plans adopted at the time that the NOP was published. Please see also Response to Comment 9-6.

Response to Comment 13-51
The assumption that the proposed restaurants would use char broilers is speculative. In addition, all commercial kitchens and cooking areas are required to comply with State and local regulations associated with cooking equipment and controls, such as grease filtration and removal systems, exhaust hood systems, and blowers to move air into the hood systems, through air cleaning equipment, and then outdoors. Such equipment would ensure that pollutants associated with smoke and exhaust from cooking surfaces would be captured and filtered, allowing only filtered air to be released into the atmosphere. For instance, Article 2, Ventilation, and Article 4, Refuse, of the California Retail Food Code, set standards for mechanical exhaust ventilation equipment to reduce emissions associated with commercial kitchens and cooking areas.2
1 Stephen L. Kostka and Michael H. Zischke. Practice Under the California Environmental Quality Act, Volume 1.

Continuing Education of the Bar: March 2022, Section 12.27. 2 California Health and Safety Code: Division 104. Environmental Health, Part 7. California Retail Food Code.

January 1, 2020.

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Response to Comment 13-52
Please see Response to Comment 9-3. In addition, presenting the cancer risk results as “chances per million” versus “per million persons” does not change the conclusion of the Draft EIR. It should also be noted that the exposure duration was set to 30 years in the HRA conducted for the Draft EIR.

Response to Comment 13-53
Please see Response to Comment 9-3.

Response to Comment 13-54
The suggested revision to the description of DPM included in the Draft EIR does not affect the conclusions of the Draft EIR. Nonetheless, in response to the comment, page 4.3-53 of the Draft EIR is revised as follows:

Nonparticipating Parcels
The project site also includes six nonparticipating parcels, comprised of approximately 83 acres, that would result in an additional approximately 1,404,800 sf future industrial uses within the site. As discussed above, the CARB Handbook provides recommended setback distances for sensitive land uses from major sources of TACs, including distribution centers.

DPM is behaves like a highly dispersive gas, and concentrations of DPM decline rapidly with distance.3 Based on the CARB’s Handbook, an 80 percent drop-off in pollutant concentrations occurs at approximately 1,000 feet from a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week). Therefore, the CARB Handbook’s recommended setback distance for sensitive land uses from distribution centers is 1,000 feet.

The foregoing revision is for clarification purposes only.

Response to Comment 13-55
Please see Response to Comment 22-16.

Response to Comment 13-56
The potential for construction of the proposed project to exceed SMAQMD’s 1,100 MTCO2e/yr threshold is addressed under Impact 4.3-7 on page 4.3-64 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR.

Response to Comment 13-57
The quote cited by the commenter is incomplete. The full sentence on page 4.0-4 in Chapter 4.0, Introduction to the Analysis, of the Draft EIR states, “As discussed in detail in Chapter 6, Statutorily Required Sections, of the EIR, the cumulative setting for the proposed project is generally considered to be a summary of projections contained in the City of Sacramento 2040 General Plan and the Sacramento County General Plan.” (Emphasis added). As stated on page 6-5 in Chapter 6, Statutorily Required Sections, of the Draft EIR, both the Upper West Side Specific Final EIR
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Plan and the Grandpark Specific Plan are included in the cumulative setting for the proposed project.

Response to Comment 13-58
As stated on page 6-5 in Chapter 6, Statutorily Required Sections, of the Draft EIR, “Limited situations exist where the geographic setting differs for certain CEQA topics.” For example, with respect to air quality, the cumulative geographic setting is the Sacramento Valley Air Basin (SVAB). The commenter does not provide evidence that the South Sutter County development would have a cumulative environmental impact such that it should be specifically evaluated as part of the cumulative setting for the environmental analysis of the proposed project. Nonetheless, while not explicitly stated, all development relevant to the cumulative analysis of the proposed project has been included in the Draft EIR.

Response to Comment 13-59
The Draft EIR includes a discussion of the potential for the proposed stormwater retention/detention areas to attract avian species and expose them to collisions with aircraft associated with the Sacramento International Airport under Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR. As discussed therein, implementation of Mitigation Measure 4.7-5 would ensure the proposed project is consistent with the recommendations of the ALUC regarding wildlife hazards to aviation, and, thus, the impact would be less-than-significant.

The commenter does not provide evidence to support the claim that mitigating such impacts would be impossible or to contradict the efficacy of Mitigation Measure 4.7-5.

Response to Comment 13-60
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 13-61
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 13-62
According to Wood Rodgers, Inc., on-site groundwater monitoring wells were completed in December of 2022. Groundwater measurements have been taken on a bi-monthly basis since that time. A summary of the data is provided in Figure 2.0-2 through Figure 2.0-5, below. As shown therein, groundwater elevations have ranged from elevation 2.5 to elevation 10.5. The groundwater elevations track consistently with the elevation of the Sacramento River (Sacramento River ABV Sac Weir Stage in Figure 2.0-4) and regional storm events (SMF Station Precipitation in Figure 2.0-5). During the winter season, groundwater is predicted to be above the bottom of the proposed detention basins, which will be mitigated through the incorporation of a low flow pump system to keep the basin dry and detention basin storage available. The incorporation and use of such a pump system is common practice in the Natomas area for other detention basins.

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Figure 2.0-2
Monitoring Well 1 – Groundwater Level Monitoring
Source: Wood Rodgers, Inc., 2024.

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Figure 2.0-3
Monitoring Well 2 – Groundwater Level Monitoring
Source: Wood Rodgers, Inc., 2024.

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Figure 2.0-4
Monitoring Wells 1 and 2 – Groundwater Level Monitoring and Sacramento River Stage Height Source: Wood Rodgers, Inc., 2024.

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Figure 2.0-5
Monitoring Wells 1 and 2 – Groundwater Level Monitoring and Precipitation Source: Wood Rodgers, Inc., 2024.

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As shown in Figure 2.0-6, which is an excerpt from the North Natomas Development Impact Fee Nexus Study and Financing Plan Update (2017), the North Natomas Community Plan contains 13 drainage basin areas. Each of the drainage basin areas has a detention basin. Of the 13 detention basins shown, eight (Basins 1, 2, 3, 4, 5, 6, 7A, and 9) incorporate a drainage pump station. Each of the drainage pump stations include a low flow pump system (on the order of fivecubic-feet per second) to ensure availability of the full storage capacities before storm events.

During the summer season (approximately April 15 through October), groundwater may be allowed to partially fill the proposed detention basins. Whether or not groundwater will be allowed to partially fill the detention basins will be dependent on compatibility with the Wildlife Hazard Management Plan prepared in conjunction with the Sacramento County Department of Airports and the City of Sacramento Department of Utilities.

Response to Comment 13-63
The comment does not specifically address the adequacy of the Draft EIR. Please see the Master Response. See also Response to Comment 13-59.

Response to Comment 13-64
The reference by the commenter to FAA Advisory Circular 150/5200-33C is taken out of context.

As stated in Section 3, Application, of the FAA Advisory Circular 150/5200-33C, “This [Advisory Circular (AC)] does not constitute a regulation, is not mandatory, and is not legally binding in its own right. It will not be relied upon as a separate basis by the FAA for affirmative enforcement action or other administrative penalty. Conformity with this AC is voluntary, and nonconformity will not affect rights and obligations under existing statutes and regulations […]”.3 Contrary to the claim of the commenter, the language included in Advisory Circular 150/5200-33C is not a federal standard, but is a series of recommendations to be considered to minimize wildlife hazards associated with various land uses, including new stormwater management facilities.

The recommendations in Advisory Circular 150/5200-33C are also intended to be examined with other best-management practices in consultation with the City of Sacramento and the Sacramento County Department of Airports; in the case of the proposed project, through the preparation of a Wildlife Hazard Management Plan as required by Mitigation Measure 4.7-5. The plan will identify the best management practices for the detention basin operations to minimize wildlife hazards to the Sacramento International Airport.

The recently approved Greenbriar Project located directly north and east of the project site includes approximately 40 acres of permanent lakes that are operated in conformance with an approved Wildlife Hazard Management Plan. The lakes also lie within the 10,000-foot separation zone. A similar collaborative approach of determining the best management practices will be used for the proposed project.
3 U.S. Department of Transportation Federal Aviation Administration. Advisory Circular 150/5200-33C, Hazardous Wildlife Attractants on or near Airports. February 21, 2020.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Figure 2.0-6
North Natomas Drainage Basins Figure
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 13-65
See Responses to Comments 13-62 and 13-64. Furthermore, as discussed under Impact 4.8-4 in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR, following development, the proposed detention basins would keep storm drainage runoff below existing runoff rates for the 10-year and 100-year storm events. Any existing limitations in the West Drainage Canal and RD 1000 levee pumps would not be affected by the proposed project. Furthermore, consistent with City of Sacramento requirements, the proposed pump stations would include back-up generators in the event of a power outage; RD 1000 also incorporates back-up power based on need and availability. Finally, contrary to the claim of the commenter, it will not be impossible to keep the proposed detention basins dry. Consistent with the methods used in other detention basins and pump stations in the Natomas area, some of which are deeper than the proposed detention basins, groundwater intrusion into the proposed basins would be controlled by a proposed low flow pumping system.

Response to Comment 13-66
As acknowledged by the commenter, the intention of Mitigation Measure 4.7-5 is to discourage birds from remaining in the vicinity of the detention basins. If food and locations to perch are not readily available in the vicinity of the detention basins, then waterfowl would not be attracted to the area and, thus, would not be attracted to the detention basins. Therefore, the measures taken to ensure that waterfowl are not attracted to the vicinity of the detention basins would, by extension, discourage waterfowl from being present within the detention basins themselves.

Furthermore, the language included in Mitigation Measure 4.7-5 should be understood to apply to the basins themselves, as applicable. For example, as shown on page 4.7-25 in Chapter 4.7, Hazards and Hazardous Materials, Mitigation Measure 4.7-5 includes language stating that the monitoring and maintenance portion of the Adaptive Management Plan shall include the inspection of “the detention basin areas to determine whether additional measures are needed to reduce bird use of the detention basins.”
Response to Comment 13-67
Although preliminary designs of the on-site detention basins have been completed, final designs have not yet been certified to account for the possibility that project designs need to be altered following public review or City revision. Consistent with Mitigation Measure 4.7-5, the final location and design of the detention basins will be determined prior to the commencement of construction in order to ensure the stormwater system is consistent with the standards anticipated in the preliminary analysis. In this case, the provided mitigation has clear, enforceable performance standards and is not deferred mitigation.

Compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact to the specified performance standards (CEQA Guidelines Section 15126.4.) In Center for Biological Diversity v.

California Department of Conservation, etc. (2019), the court explains that “[g]enerally, it is improper to defer the formulation of mitigation measures…However, an exception to this general rule applies when the agency has committed itself to specific performance criteria for evaluating the efficacy of the measures to be implemented in the future, and the future mitigation measures are formulated and operational before the project activity that they regulate begins.” (36 Cal.App.5th 210, 239.) The court determined both conditions were met and upheld the deferred mitigation measures. Similarly, the mitigation measures presented in the Draft EIR require Final EIR
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compliance with specific performance standards and regulatory requirements, and also require implementation prior to project activities begin. Therefore, the proposed mitigation would not be considered deferral.

Response to Comment 13-68
See Response to Comment 13-67.

Response to Comment 13-69
See Responses to Comments 13-64, 13-65, and 13-67.

Response to Comment 13-70
Although Mitigation Measure 4.7-5 does not explicitly incorporate the information provided in the Preliminary Drainage Study prepared for the proposed project by Wood Rogers, Inc., as stated on page 4.7-23 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, Mitigation Measure 4.7-5 states that “The project applicant shall submit a detailed design drawing of the proposed detention basins to [Sacramento County Airport System] for review.” The detailed design drawing would logically draw details from the Preliminary Drainage Study. Through the foregoing review and approval process, efficacy of the detention basins with respect to preventing bird strikes will be ensured.

Response to Comment 13-71
See Responses to Comments 13-64 and 13-66. Mitigation Measure 4.7-5 includes all feasible measures to dissuade waterfowl from spending long amounts of time within the project site.

Furthermore, birds currently do and will continue to fly above the project site; multiple other bodies of water exist within the 10,000-foot separation zone, similar to the proposed detention basins.

The proposed detention basins are not a particularly bird-attracting use, and would not result in an increased number of airborne waterfowl in the project site vicinity.

Response to Comment 13-72
As stated on page 4.7-25 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, Mitigation Measure 4.7-5 requires the preparation of an Adaptive Management Plan that may include the use of noise generators to prevent the establishment of resident populations of Canada geese on the project site. The language of the mitigation measure includes the use of noise generators as a potential option to scare away geese, but does not specifically require the use of such measures to reduce attractants for bird species. If the use of noise generators is not deemed necessary, they will not be used.

The purpose of the Adaptive Management Plan required by Mitigation Measure 4.7-5 is to prevent avian species from settling on the on-site detention basins, and to encourage such species to settle elsewhere, including the Natomas Basin Conservancy’s wildlife preserve. Furthermore, if noise generators are used during project operation, the Bird Control Program Manager would still be required to comply with the City’s noise ordinance. Any use of noise generators that would exceed the City’s allowable exterior noise level limit for residential uses of 55 dBA L50 and 75 dBA Lmax during daytime (7:00 AM to 10:00 PM) hours and 50 dBA L50 and 70 dBA Lmax during nighttime hours (10:00 PM to 7:00 AM), as established by Section 8.68.060 of the Sacramento Municipal Code, would not be allowed. As such, noise from the optional use of noise generators would not reach significant levels beyond the boundaries of the project site, and, thus, would not adversely affect the Natomas Basin Conservancy habitat preserve.

Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 13-73
See Response to Comment 13-72. In addition, similar to the project site, the Natomas Basin Conservancy’s wildlife preserve is located within the Sacramento International ALUCP’s 10,000- foot FAA Separation Area for Wildlife Attractants. As such, measures similar to those required for the proposed project by Mitigation Measure 4.7-5 are already in place for the wildlife preserve.

Thus, the proposed project would not result in new significant or significantly increased impacts to the wildlife preserve.

Response to Comment 13-74
The commenter raises concerns about Mitigation Measure 4.12-3 proposed in the Draft EIR to address VMT impacts for the project, asserting that it represents deferred mitigation that is not allowed under CEQA. In addition, the commenter asserts that CAPCOA’s guidance is inappropriate because: (i) it “is used for dense, office rich, employment projects”; and (ii) the project cannot support rideshare programs due to the “presence of shifts and variable shift assignments,” and the project’s “isolated location.”
See Responses to Comments 22-26 and 22-27 below, which include detailed responses to the claims that the VMT mitigation qualifies as deferral.

Regarding assertions that CAPCOA’s VMT reduction measures are inappropriate for the project, the commenter does not provide any substantial evidence or supporting documentation for their claims. Furthermore, CAPCOA’s proposed transportation-related mitigation measures expressly state that they are applicable in the “Urban, suburban” locational context (see, e.g., CAPCOA Handbook, pages 86, 89, and 92), which is consistent with the project site location. The project is proposed to be developed on a project site located immediately adjacent to existing urban/suburban development to the east and to the north. The project site has direct access via an existing interchange across Interstate 5 to the Metro Air Park to the north and urban/suburban residential and mixed-use development to the northeast. The claim that the project is “isolated” is incorrect.

The claims that CAPCOA measures can only be applied to “office rich employment projects,” and cannot be used for projects that incorporate “shifts and variable shift work” are similarly unsupported and incorrect. For instance, in CAPCOA Measure T-8 “Ridesharing Program” (CAPCOA Handbook, pages 92-94), the measure takes into account that some businesses may have employees working nighttime shifts, as well as those who would not be able to participate due to specific job duties. In addition, the list of possible VMT-reducing measures available provide for several other non-rideshare options, and none of the proposed measures preclude its application based on any type of job-center development, such as the project, when it is located within an urban or suburban context. Furthermore, because the operators of the buildings to be built for the project are unknown at this time, whether those operators will have night-time shifts, or “variable shift assignments,” is speculative.

Response to Comment 13-75
Although a Storm Water Pollution Prevention Plan (SWPPP) has not yet been prepared for the proposed project, pursuant to Mitigation Measure 4.8-1, as defined on page 4.8-17 of Chapter

4.8, Hydrology and Water Quality, of the Draft EIR, impacts related to water quality would be addressed through implementation of a SWPPP that would be reviewed and approved by the Final EIR
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Central Valley Regional Water Quality Control Board (RWQCB). Similarly, Mitigation Measure

4.8-2, as defined on page 4.8-22, would require the project applicant to submit a detailed Best Management Practice (BMP) and water quality maintenance plan to the City for review and approval to address potential impacts to water quality during project operations. The provided mitigation has clear, enforceable performance standards and is not deferred mitigation.

See Response to Comment 13-67. As discussed therein, compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact to the specified performance standards (CEQA Guidelines Section 15126.4.). The mitigation measures presented in the Draft EIR require compliance with specific performance standards and regulatory requirements, and also require implementation prior to project activities begin. Therefore, the proposed mitigation would not be considered deferral.

Response to Comment 13-76
Construction noise associated with the proposed project would be required to comply with the requirements of Policy ERC-10.1 of the City of Sacramento 2040 General Plan Environmental Constraints Element, as presented on page 4.10-9 in Chapter 4.10, Noise, of the Draft EIR. In addition, as presented on page 4.10-11, the City of Sacramento Municipal Code, Section 8.68.060 establishes an allowable exterior noise level limit of 55 dBA L50 and 75 dBA Lmax during daytime (7:00 AM to 10:00 PM) hours and 50 dBA L50 and 70 dBA Lmax during nighttime (10:00 PM to 7:00 AM) hours for sources of noise which occur for more than 30 minutes per hour (L50). Furthermore, as stated on page 4.10-16, the City of Sacramento’s Noise Ordinance exempts construction activities from the City’s noise standards, provided that construction takes place between the hours of 7:00 AM and 6:00 PM Monday through Saturday and 9:00 AM and 6:00 PM Sundays and holidays. Because the project site is proposed to be annexed into the City of Sacramento, construction of the proposed project is subject to the requirements and exemptions of the City’s 2040 General Plan and Municipal Code.

Response to Comment 13-77
See Response to Comment 13-76.

Response to Comment 13-78
See Response to Comment 13-76. In response to the comment, page 4.10-16 in Chapter 4.10, Noise, of the Draft EIR is hereby revised as follows:

The noise increase during construction would be of short duration and would likely occur primarily during daytime hours. The City of Sacramento’s Noise Ordinance (Section

8.60.060 8.68.080[D] of the Municipal Code) exempts construction activities from the City’s noise standards, provided that construction takes place between the hours of 7:00 AM and 6:00 PM Monday through Saturday and 9:00 AM and 6:00 PM Sundays and holidays.

Response to Comment 13-79
Most jurisdictions, including the City of Sacramento and Sacramento County, exempt all projects from noise restrictions. The City’s noise ordinance Section does not contain any language that limits the exemption based on the size or duration of the project. The City does place limits on allowable days and time of day, while also requiring that all engines used in the construction process be fitted with suitable silencers, as is standard practice for all construction equipment.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

The commentor appears to be under the impression that the entirety of the proposed project would be constructed at one time. However, construction phasing generally consists of grading, site preparation, infrastructure trenching and installation, paving, and building. The proposed project in particular includes the development of the proposed industrial park and future development of the nonparticipating parcels. Even if the proposed buildings were constructed concurrently, cumulative construction noise levels would not combine in a substantial way due to the distance between the various proposed buildings. For example, the proposed building on Parcel 5 is closest to the nearest existing residential uses to the east. During project construction, the distance from the center of the site would be approximately 1,000 feet. While some construction activity could occur at closer distance, much of the activity would also occur at greater distances. Therefore, the center of the project site is used for the basis of the analysis. As noted on page 4.10-15 in Chapter 4.10, Noise, of the Draft EIR, construction equipment noise levels are predicted to range between 76 to 90 dBA Lmax at 50 feet. Assuming the use of the loudest piece of construction equipment, the maximum construction noise level at the aforementioned residence would be 64 dBA Lmax. Based upon the ambient noise monitoring conducted for the project, existing daytime maximum noise levels in the project area were found to range between 74 to 79 dBA Lmax. Therefore, construction on the parcel closest to existing residential uses would typically be expected to be 10 dBA less than existing ambient conditions. Finally, even if construction were to occur simultaneously on Parcel 4, the distance to the existing residential to the east would be approximately 3,700 feet from the center of the parcel. Due to the hemispherical spreading of sound, construction noise levels would attenuate by 6 dB per doubling of distance from the noise source. Therefore, construction noise levels would be approximately 11 dB lower than those generated by construction on Parcel 5. Due to the logarithmic nature of the decibel scale, these noise levels would not add to the noise levels from Parcel 5 construction.

Response to Comment 13-80
See Response to Comment 13-79. As discussed therein, the proposed project is predicted to generate noise levels below existing ambient noise levels at the sensitive receptors in the project area, even during construction on Parcel 5. Additionally, neither the City of Sacramento nor Sacramento County have established noise standards for wildlife which may be located in the project area. Finally, while the total duration of the project construction would span multiple years, single receptors would not be exposed to peak noise levels for the entire project duration. Due to the hemispherical spreading of sound, noise levels would be loudest at existing residential receptors during the construction on Parcel 5, but would decrease by up to 15 dBA during construction of Parcel 1 and, therefore, would be substantially below existing measured ambient noise levels. As such, significant impacts related to exposing humans and/or wildlife species to substantial, prolonged noise would not occur.

Response to Comment 13-81
See Response to Comment 13-79. As discussed therein, typical construction activities are expected to be 10 dBA less than existing ambient noise levels, assuming the use of the loudest piece of construction equipment. If ten of the loudest pieces of construction equipment were used simultaneously, noise levels would increase to 100 dBA at 50 feet and 74 dBA Lmax at the nearest residential uses. The increased noise levels would be equal to the existing ambient noise conditions of 74 to 79 dBA Lmax and, thus, would not be a substantial increase in noise levels.

Average noise levels for construction activity are variable due to intermittent use of equipment.

However, it is estimated that typical average (Leq) noise levels would typically be 20 dBA less than Final EIR
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maximum levels, or 54 dBA Leq at the nearest residential uses. Existing average noise levels in the project area were found to range between 54 to 69 dBA Leq. Therefore, cumulative project construction noise levels are not predicted to exceed existing ambient noise levels.

Assuming continuous construction activity between 7:00 AM to 6:00 PM, day/night average (Ldn) noise levels would be expected to be approximately 3 dBA less than average (Leq) values.

Therefore, day/night average (Ldn) noise levels for construction are predicted to be less than or equal to 51 dBA Ldn at the nearest residential uses. Existing ambient noise levels were found to range between 58 to 64 dBA Ldn at the nearest residential uses. Therefore, the project is not predicted to cause a substantial increase to existing day/night average (Ldn) noise levels.

Response to Comment 13-82
Please see Responses to Comments 13-79 and 13-81. As discussed therein, construction of the proposed project is not predicted to substantially increase existing noise levels. Furthermore, neither the City of Sacramento nor Sacramento County maintain specific noise standards applicable to waterfowl, nor is it understood whether waterfowl are sensitive to increased noise.

Please also refer to Response to Comment 13-72.

Response to Comment 13-83
As stated on page 1-6 in Chapter 1, Introduction, of the Draft EIR, “According to CEQA Guidelines Section 15125(d), the EIR shall discuss any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans. An “applicable” plan is a plan that has already been adopted and, thus, legally applies to a project; draft plans need not be evaluated.” Given that the NOP for the proposed project was published on March 4, 2022, consistent with Section 15126.2(a) of the CEQA Guidelines, the environmental baseline for the analysis of the proposed project includes the adopted General Plan at the time that the NOP was published. It is noted that the analysis of the Draft EIR has been updated to reflect the 2040 General Plan. Nonetheless, a Natomas Basin Study has not yet been conducted as of the publishing date of the 2040 General Plan. Therefore, the analysis of the proposed project adequately incorporates information from all “applicable” plans and is not required to rely on the findings of a future Natomas Basin Study.

Response to Comment 13-84
The scope of an EIR is limited to a lead agency’s evaluation of potentially significant environmental impacts of a project (PRC Section 21060.5; CEQA Guidelines Section 15360). The analysis of economic impacts unrelated to a physical change is not included within an EIR because such potential impacts are not considered to be effects on the environment (CEQA Guidelines Sections 15064[e], 15131[a], 15358[b], 15382). Therefore, potential economic impacts that do not contribute to, or are not caused by, physical impacts on the environment, are not substantial evidence of a significant environmental effect (PRC Section 21080[e][2]; CEQA Guidelines Section 15064[f][6]). California courts have routinely dismissed challenges to projects under CEQA when premised on potential economic impacts. (see Clews Land & Livestock, LLC v. City of San Diego [2017] 19 Cal.App.5th 161, 196 [potential effect of project’s noise on nearby business’s economic viability not reviewable under CEQA]; Chico Advocates for a Responsible Economy v. City of Chico [2019] 40 Cal.App.5th 839, 846–48 [loss of close and convenient shopping not an environmental issue subject to CEQA review]; City of Hayward v. Board of Trustees of the California State University [2015] 242 Cal.App.4th 833, 840–47 [project’s potential economic impacts on costs of providing public services not a cognizable environmental impact Final EIR
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under CEQA]; Maintain Our Desert Environment v. Town of Apple Valley [2004] 124 Cal.App.4th 430, 446 [“social, economic and business competition concerns are not relevant to CEQA analysis unless it is demonstrated that those concerns will have a significant effect on the physical environment”]; Preserve Poway v. City of Poway [2016] 245 Cal.App.4th 560, 576–82 [change in community character is a social and psychological impact not reviewable under CEQA]).

Based on the above, the potential economic impacts of the proposed project, such as increasing the value of land in the Natomas Basin, are not required to be addressed in the Draft EIR.

Response to Comment 13-85
Potential growth-inducing impacts of the proposed project are addressed beginning on page 6-1 in Chapter 6, Statutorily Required Sections, of the Draft EIR. Pursuant to CEQA Guidelines Section 15126.2(e), the analysis presented therein examines the following potential growthinducing impacts related to implementation of the proposed project and assesses whether these effects are significant and adverse:

1. Foster population and economic growth, or the construction of housing.

2. Eliminate obstacles to population growth.

3. Affect service levels, facility capacity, or infrastructure demand.

4. Encourage or facilitate other activities that could significantly affect the environment.

The potential for the proposed project to inspire other property owners to seek designation changes for other sites within the Natomas Basin is speculative, is not relevant to any of the foregoing growth-inducing impacts and, thus, is not required by CEQA to be addressed in the Draft EIR.

Response to Comment 13-86
As stated on page 7-1 in Chapter 7, Alternatives Analysis, of the Draft EIR, Section 15126.6(f) of CEQA Guidelines states, “The range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice.” Section 15126.6(f) of CEQA Guidelines further states:

The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determined could feasibly attain most of the basic objectives of the project.

In addition, an EIR is not required to analyze alternatives when the effects of the alternative “cannot be reasonably ascertained and whose implementation is remote and speculative.” With respect to the selection of alternatives, CEQA only requires “‘enough of a variation to allow informed decision-making.’” (Santa Cruz, supra, 177 Cal.App.4th at p. 988, quoting Mann v.

Community Redevelopment Agency (1991) 233 Cal.App.3d 1143, 1151 (“Mann”).) As stated on page 7-5 of the Draft EIR, various potential sites were reviewed for an Off-Site Alternative, and only one was determined to be feasible. As discussed therein, the Off-Site Alternative was dismissed from further consideration because buildout of the off-site alternative at the location would require the project applicant to either redesign the proposed project to build around existing commercial businesses or reduce the amount of land designated for residential development Final EIR
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while simultaneously demolishing existing businesses, which would cause the Off-Site Alternative to be in direct conflict with the project objectives concerning improvement of the job and housing balance in the City and the region. In addition, the project applicant does not own the identified alternative site.

Based on the above, the Draft EIR includes adequate evaluation of an off-site alternative. The commenter’s assertion that the other off-site alternative locations would result in fewer environmental impacts as compared to the proposed project is speculative.

Response to Comment 13-87
See Response to Comment 13-86. Project objectives are intended to identify the goals of the project, as proposed by the project applicant. The project objectives are generally defined by the applicant with input from the lead agency. While some project objectives are more specific than others, none of the alternatives evaluated in the Draft EIR are expected or required to meet all project objectives. The more specific project objectives would inherently hold less weight in the alternatives evaluation given that most alternatives would not meet those objectives. Thus, the analysis focuses on the alternatives’ compliance with the remaining project objectives.

Response to Comment 13-88
The comment consists of the commenter’s questions about the project objectives. The comment does not directly address the adequacy of the environmental analysis of the Draft EIR. The comment has been noted for the record and will be forwarded to the decision-makers as part of their consideration of the proposed project.

Response to Comment 13-89
As discussed in Chapter 7, Alternatives Analysis, of the Draft EIR, because the No Project (No Build) Alternative would not fulfill any of the Project Objectives, the lead agency may conclude that the Alternative is not feasible within the meaning of CEQA. Furthermore, it is the responsibility of that elected decision-making body to determine if the benefits of the proposed project outweigh the significant environmental impacts. The comment has been noted for the record and will be forwarded to the decision-makers as part of their consideration of the proposed project.

Response to Comment 13-90
See Response to Comment 13-89. In addition, under CEQA, the Draft EIR should focus on the significant environmental effects of a project. Contrary to the claim of the commenter, as noted on page 7-7 in Chapter 7, Alternatives Analysis, of the Draft EIR, the No Project (No Build) Alternative would not meet any of the Project Objectives.

Response to Comment 13-91
Development of the project site with the proposed industrial uses does not preclude the preservation of other land in order to meet the criteria established by Executive Order N-82-20.

In fact, pursuant to Mitigation Measures 4.2-1 and 4.4-5(b), farmland would be preserved off-site at a 1:1 ratio. Because such land would not be developed and the farmland would not be removed, the proposed project would contribute towards the State’s preservation goal.

Response to Comment 13-92
See Response to Comment 13-42.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 13-93
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 13-94
See Response to Comment 13-43.

Response to Comment 13-95
See Responses to Comments 13-42 and 13-43.

Response to Comment 13-96
The comment provides informational attachments and does not address the adequacy of the Draft EIR. Please see the Master Response.

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Chapter 2.0 – Responses to Comments

14-1
Letter 14
14-2
14-3
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14-3 Cont.
14-4
14-5
14-6
14-7
14-8
Letter 14 Cont.

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14-9
Letter 14 Cont.

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LETTER 14: JAMES P. PACHL AND JUDITH L. LAMARE, FRIENDS OF THE SWAINSON’S HAWK
Response to Comment 14-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 14-8
The Draft EIR does not contain any language implying that any portion of the project site is located within the boundaries of the North Natomas Community Plan. Please see the Master Response.

Response to Comment 14-9
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

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Letter 15
15-1
15-2
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Letter 15 Cont.
15-3
15-4
15-5
15-6
15-7
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Letter 15 Cont.
15-8
15-9
15-10
15-11
15-12
15-13
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Letter 15 Cont.
15-13
Cont.

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LETTER 15: JAMES P. PACHL AND JUDITH L. LAMARE, FRIENDS OF THE SWAINSON’S HAWK
Response to Comment 15-1
The comment endorses other commenters and does not directly address the adequacy of the Draft EIR. The commenter is referred to the response to comment letter 22.

Response to Comment 15-2
Given that site-specific development plans or designs have not been proposed for Parcel 8, the analysis of future development of the parcel is programmatic. As stated on page 3-8 in Chapter 3, Project Description, of the Draft EIR, “The parcels would receive General Plan and Prezoning designations as part of the City process. Any development proposed for these sites would require additional entitlement requests and review pursuant to CEQA.” As such, any potential impacts associated with buildout of Parcel 8 that require additional project-level analysis would be addressed in a subsequent CEQA analysis. As such, the public will have adequate opportunity to comment on future development specifics. Furthermore, the Draft EIR does include a programmatic analysis of future development of Parcel 8, and includes mitigation that applies to such development. For example, the Draft EIR includes Mitigation Measure 4.3-3, in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, which requires that if Parcel 8 is proposed to be developed with a distribution center within 1,000 feet of a sensitive receptor, prior to the issuance of any building permit, a HRA be conducted to calculate the cancer risk associated with on-site truck DPM emissions and implementation of emission reduction options are required.

Response to Comment 15-3
As shown in Figure 4.4-2, Natomas Basin Habitat Conservation Plan 2023 Permit Area, on page

4.4-4 in Chapter 4.4, Biological Resources, of the Draft EIR, the easternmost portion of the project site, which includes Parcels 5 and 8, is already within the boundaries of the Natomas Basin HCP permit area.

Response to Comment 15-4
See Response to Comment 15-3 and the Master Response.

Response to Comment 15-5
See Response to Comment 15-4.

Response to Comment 15-6
See Response to Comment 15-4.

Response to Comment 15-7
See Response to Comment 15-3. Furthermore, potential environmental impacts associated with development of the project site have been analyzed throughout the Draft EIR.

Response to Comment 15-8
See Response to Comment 13-32.

Final EIR
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Chapter 2.0 – Responses to Comments

Response to Comment 15-9
The comment does not specifically address the adequacy of the Draft EIR. However, Impact 4.7- 5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, addresses compatibility with the ALUCP requirements related to bird strikes.

Response to Comment 15-10
See Response to Comment 13-66.

Response to Comment 15-11
See Response to Comment 13-64.

Response to Comment 15-12
See Response to Comment 13-65.

Response to Comment 15-13
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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LETTER 16: GOLDEN STATE ENVIRONMENTAL JUSTICE ALLIANCE
(BLUM, COLLINS & HO LLP)
Response to Comment 16-1
The comment consists of an introductory statement and a summary of the proposed project. The comment does not address the adequacy of the Draft EIR.

Response to Comment 16-2
Contrary to the claim of the commenter, a site plan for the proposed project is included as Figure 3-3 on page 3-6 in Chapter 3, Project Description, of the Draft EIR.

Response to Comment 16-3
Pursuant to the CEQA Guidelines, an EIR is required to demonstrate how a project would comply with all applicable regulations related to avoiding potentially significant environmental impacts, and is required to provide all documentation necessary to do so. Where specific information is not yet available, such as parking locations, the worst-case conditions are assumed so as to provide a conservative analysis. As such, although the information mentioned in the comment would provide for a more detailed analysis, the analysis presented in the Draft EIR adequately addresses the worst-case scenario with respect to project buildout. Furthermore, the proposed project will be evaluated for compliance with all applicable standards. Therefore, the Draft EIR is considered to be adequate. It should be noted that parking and loading dock areas can be identified and inferred based on the Site Plan.

Response to Comment 16-4
See Response to Comment 16-3. The information requested by the commenter is not required to be provided as part of the Draft EIR, pursuant to the CEQA Guidelines. Furthermore, as discussed in Chapter 3, Project Description, of the Draft EIR, the proposed project would be subject to approval of the proposed Planned Unit Development (PUD) Guidelines. As stated on page 3-7 of the Draft EIR, “The proposed project includes PUD Guidelines related to the proposed M-1-PUD and HC-PUD zoning. The PUD Guidelines include regulations and standards for permitted/prohibited uses, site design, building design, landscaping/visual screening, signage, and lighting.” If the design of the proposed project is not consistent with the PUD Guidelines decided upon by the project applicant and the City, the project would be denied, and development would not occur. As such, the inclusion of architectural building elevations are not required to be included in the Draft EIR to ensure that the design of the proposed project would be consistent with the applicable requirements and regulations.

Response to Comment 16-5
See Responses to Comments 16-3 and 16-4. The analysis of the Draft EIR is based on the information provided by the project applicant that approximately 304,000 cubic yards of soil would be imported during grading. The amount of soil required to be imported for the proposed project is a worst-case assumption in order to allow for a conservative analysis of the potential impacts of the proposed project. As discussed under Impact 4.6-2 in Chapter 4.6, Geology and Soils, of the Draft EIR, pursuant to Chapter 15.88 of the City Code, the proposed project is required to submit an application for review by the City, including a final grading plan, prior to approval of a grading permit. As such, a final grading plan is not yet available for public review. If the amount of soil required to be imported according to a final grading plan prepared for the proposed project Final EIR
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is inconsistent with the assumptions of the Draft EIR, then the project would be denied, and the environmental analysis would need to be redone. However, at this time, cause has not been given for revision of the Draft EIR.

Response to Comment 16-6
See Response to Comment 16-4. To be legally adequate, a project description must depict the project accurately and not minimize its environmental effects, include reasonably foreseeable activities associated with the project, and be consistent throughout the EIR. (14 Cal.Code Regs.

Sec. 15124.) More specifically, a project description must include the precise location and boundaries of the proposed project, a detailed map and a map showing the project’s location in a regional perspective, a statement of project objectives, a general description of the project’s technical, economic, and environmental characteristics, and a statement describing the intended uses of the EIR including a list of agencies expected to use the EIR and a list of approvals for which the EIR will be used. Chapter 3, Project Description, of the Draft EIR sets forth a detailed description of proposed project meeting all of the requirements of CEQA, and lists the proposed development agreement as one of several entitlements required for the project.

While CEQA requires an EIR to include a list of all permits and other approvals that are required to implement a project and are known to the lead agency, a detailed discussion of those permits and approvals is not required. (See East Sacramento Partnership for a Livable City v. City of Sacramento (2016) [analysis of development agreement not required]; Native Sun/Lyon Communities v. City of Escondido (1993) 15 Cal.App.4th 892, 909 [EIR listing of development agreement adequate and detailed discussion of development agreement not required]; see also Rialto Citizens for Responsible Growth v. City of Rialto (2012) 208 Cal.App.4th 899 [city’s failure to include development agreement in list of approvals found nonprejudicial].) Therefore, the information requested by the commenter is not required for the purposes of CEQA.

Response to Comment 16-7
See Response to Comment 16-6. Contrary to the commenter’s claim that the proposed project does not comply with PUC Section 21676(b), SACOG prepared an ALUC Preliminary Review and provided conditions of approval for the project’s compatibility with the Sacramento International Airport’s ALUCP. As such, the proposed project has been provisionally approved for compatibility with the ALUCP by the SACOG ALUC. If the design of the proposed project is not consistent with the conditions of approval decided upon by the SACOG ALUC, the project would be denied, and development would not occur.

Response to Comment 16-8
As defined on page 4.9-4 of Chapter 4.9-4, Land Use and Planning/Population and Housing, of the Draft EIR, the Employment Mixed-Use land use designation provides for a range of light industrial and high technology uses and generally applies to industrial areas that are next to residential neighborhoods. As defined by the City of Sacramento 2040 General Plan, allowable uses under the Employment Mixed-Use designation include light/advanced manufacturing, production, distribution, repair, testing, printing, research, and development; service commercial uses that do not generate substantial noise or odors; accessory office uses; and retail and service uses that provide support to employees. While the future tenants of the proposed industrial buildings are not currently known, the proposed industrial park is anticipated to be used by regional suppliers, such as Amazon and Walmart, that deliver goods directly to consumers. Such uses would be considered as “distribution,” which is explicitly allowable under the Employment Final EIR
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Mixed-Use land use designation. In fact, the commenter acknowledges that the anticipated uses are within the definition of the light industrial category. Furthermore, future tenants of the proposed industrial buildings would be required to demonstrate consistency with the allowable uses under the project site’s proposed General Plan land use and zoning designations; uses that would not comply with the applicable regulations and/or would be inconsistent with the site’s designation(s) would not be permitted to occupy the site. Therefore, the commenter’s assertion that the project site should be designated as Industrial Mixed Use is without basis, and does not require revision of the Draft EIR.

The project site’s existing Agricultural Cropland land use designation allows for single-family dwelling units at a density no greater than 40 acres per unit. However, the primary purpose of the Agricultural Cropland land use designation is to allow for agricultural activities; any residential uses associated with the Agricultural Cropland land use designation are presumed to be associated with such agricultural activities. As such, while residential uses are allowable under the Agricultural Cropland land use designation, the designation is not considered to be residential.

Therefore, the language related to the Housing Crisis Act of 2019 cited by the commenter is not relevant to the proposed project, and revision to the Draft EIR is not required.

Response to Comment 16-9
See Response to Comment 16-8. Because the proposed project would not require the development of replacement residential units, deferral of environmental analysis related to such would not occur.

Response to Comment 16-10
In response to the comment, the analysis of the project’s consistency with LAFCo Policy I(6), beginning on page 4.9-21 in Table 4.9-6, Discussion of Relevant Sacramento LAFCo Policies, in Chapter 4.9-4, Land Use and Planning/Population and Housing, of the Draft EIR, is hereby revised as follows:

Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
Amendments to Spheres of Influence

6. Amendment proposals involving
Sphere expansion which contain
prime agricultural land will not be
approved by the LAFCo if there is
sufficient alternative land available
for annexation within the existing
Sphere of Influence.

As discussed in Chapter 4.2, Agricultural
Resources, of this EIR, Mitigation
Measure 4.2-1 requires the preservation
of off-site farmland at a ratio of one
Farmland acre converted to urban land
uses outside the Natomas Basin Habitat
Conservation Plan (HCP) policy area to

0.5-acre preserved, which, combined
with the biological resources mitigation
required by Mitigation Measure 4.4-5(b),
would result in an overall preservation at
a 1:1 ratio. However, while Mitigation
Measure 4.2-1 would preserve an
equivalent acreage of Farmland
elsewhere, the proposed project would
result in the conversion of agricultural
land to urban uses, and would not create
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Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
new agricultural land. As such, the
proposed project would lead to an overall
loss of Farmland.

However, the proposed project is sited on
land in proximity to other similar industrial
uses (the Metro Air Park and Amazon
SMF-1 Fulfillment Center), and would not
require major extension of public services
and utilities, nor result in the deterioration
of existing service levels of providers that
would serve the project site. Furthermore,
due to the built-out nature of the City of
Sacramento, an alternate location within
the City City’s SOI is not currently
available to serve the proposed project.

As discussed further in Chapter 6,
Alternatives Analysis, of this EIR, the
location that comes closest to feasibility is
located northwest of the intersection of
Fruitridge Road and South Watt Avenue
in the southeast portion of the City, and
contains a portion of land already
designated for Industrial use by the
Sacramento General Plan. However, in
order to include a comparable amount of
acreage to the proposed project, the
alternative location would require the
demolition of several commercial
businesses, including, but not limited to, a
building materials store, furniture store,
and 7-Eleven convenience store. In
addition, approximately 117 acres of the
354 acres required of the alternative
would consist of land already set aside for
L and D Landfill. Furthermore, buildout of
the proposed project at the alternative
location would require a General Plan
Amendment (GPA) that would reduce the
amount of land designated for residential
development, as a portion of the site is
currently designated Traditional
Neighborhood Medium by the
Sacramento General Plan. As such,
buildout of the proposed project at an
alternative location within the City’s SOI is
infeasible. Furthermore, buildout of the
site on alternative land outside, but
adjacent to, the City’s SOI would likely
result in similar conversion of Farmland
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Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
as the proposed project, given the
prevalence of agricultural land adjacent to
the City’s SOI. Therefore, sufficient
alternative land is not available for
Annexation within the City’s SOI to
accommodate the proposed project.

The above change is for clarification purposes and does not change the analysis or conclusions within the Draft EIR.

Response to Comment 16-11
See Response to Comment 16-6.

Response to Comment 16-12
The proposed project’s compliance with applicable 2040 General Plan policies is addressed under Impact 4.9-3 and in Table 4.9-7, City of Sacramento 2040 General Plan and SMF Land Use Compatibility Plan Policy Discussions, in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR. As such, the Draft EIR provides analysis of the project’s compliance with such. In addition, page 12 of the TIA prepared for the proposed project (Appendix N of the Draft EIR) erroneously mischaracterizes the proposed development within Parcel 6C of the project site as an 8,100-sf convenience store. As correctly stated on page 4 of the TIA, as well as on page 3-8 of Chapter 3, Project Description, of the Draft EIR, the entire proposed fueling station/carwash would be comprised of 8,100 sf, with the associated convenience store being only a portion of that square footage. Development of the project site would be required to comply with all applicable regulations, including the land uses allowable within the site’s zoning designation; any development inconsistent with such requirements would not be allowed.

Response to Comment 16-13
Consistent with the CEQA Guidelines, population growth itself does not constitute a significant physical environmental effect. Rather, the determination of significance is based on whether population growth associated with a project has been previously planned for, and whether such growth could result in indirect impacts from associated development. As discussed under Impact

4.9-4 in Chapter 4.9, Land Use and Planning/Population and Housing, as well as in Section 6.2, Growth-Inducing Impacts, which starts on page 6-1 of Chapter 6, Statutorily Required Sections, of the Draft EIR, the proposed project would not increase population such that service levels, facility capacity, or infrastructure demand would require construction of new facilities that could cause significant environmental impacts. Therefore, the Draft EIR adequately addresses the environmental impacts associated with population growth that would occur as a result of the proposed project, and additional analysis is not required.

Response to Comment 16-14
See Response to Comment 16-13. As discussed in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR, the City of Sacramento 2040 General Plan enables residential growth and identifies the necessary infrastructure improvements needed to keep pace with that growth by providing a plan for future roads, utilities, and government services to support future growth. While not anticipated by the City, the new industrial uses provided by Final EIR
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the proposed project would not exceed the City of Sacramento 2040 General Plan and SACOG’s growth estimates for the City of Sacramento and for the region. Furthermore, the commenter’s claim that all 4,000 new employees associated with the proposed project would be new to the Sacramento region is speculative and is not based on evidence or fact. Even conservatively assuming that all 4,000 employees would be new to the region and would be fully buildout and operating at fully capacity by 2035, as stated on page 4.9-28, the project’s contribution to the overall population increase by 2035 would only be approximately 3.5 percent. With respect to construction employment opportunities, as cited by the commenter, the Draft EIR states that construction would be temporary. As such, regardless of where the employee base is from, due to the temporary nature of the construction activities, employees would not settle in the area, and, thus, would not result in population growth.

Response to Comment 16-15
Please see the Master Response and Response to Comment 11-11.

Response to Comment 16-16
See Response to Comment 16-7. Contrary to the claim of the commenter, analysis of the proposed project’s consistency with the Sacramento International Airport’s ALUCP is provided throughout the Draft EIR, where relevant. For example, Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, addresses compatibility with the ALUCP requirements related to bird strikes, and noise impacts associated with the Sacramento International Airport are addressed under Impact 4.10-4 in Chapter 4.10, Noise, of the Draft EIR.

Response to Comment 16-17
The proposed hotel would primarily draw patronage from the nearby airport or the adjacent freeway. Airport-based patrons who stay in the hotel would typically either rent a vehicle at the airport or take a ride share vehicle from the airport to the hotel. The trips would both be very short as the hotel is within two miles of the airport. Destinations for hotel patrons from the airport would exist whether or not the proposed hotel was built in the proposed location. Freeway-based patrons would likely be drivers on I-5 who are looking for a place to stay on their way somewhere else.

Such trips represent “pass-by” trips where vehicles would be on the highway anyways but decide to exit for services such as hotel or commercial uses near the freeway interchange. The only added VMT that such trips would represent would be the VMT between the highway interchange and the hotel. Based on both of the foregoing considerations (hotel as airport serving and Interstate serving), the hotel can be considered as local serving, or ubiquitous, as it does not represent a new and unique use and does not generate new longer distance trips.

The proposed mitigation strategy relies on measures developed and recommended by the California Air Pollution Control Officers Association (CAPCOA). Each measure is supported by real-world studies of the efficacy of the transportation demand reduction programs recommended in the CAPCOA Handbook. See Responses to Comments 22-26 and 22-27 for additional detail on the evidence supporting the efficacy of the measures developed by CAPCOA. Regarding compliance through the life of the project, the VMT Reduction Plan required by Mitigation Measure

4.12-3 of the Draft EIR must be reviewed and approved by the City’s Public Works Department and Community Development Department and is subject to ongoing monitoring and enforcement by City staff to ensure continued compliance.

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Response to Comment 16-18
The SMAQMD has developed the Draft Recommended Guidance for Land use Emission Reductions Version 5.0,
4 dated January 2023, to instruct project proponents how to quantify, apply, and comply with various measures for projects within the SMAQMD jurisdictional area. As discussed on page 4.3-46 of the Draft EIR, for land development projects that are anticipated to exceed the SMAQMD’s operational emissions thresholds of significance for criteria pollutants, such as the proposed project, SMAQMD requires that the project proponent develop an Air Quality Mitigation Plan (AQMP) describing what features the project will incorporate to reduce operational criteria pollutant emissions from baseline conditions. The SMAQMD’s intent for the purpose of AQMPs is to, “satisfy the ‘all feasible measures’ mitigation requirements under CEQA for operation impacts.” 5 Accordingly, preparation of an AQMP represents a reasonable quantification of feasible mitigation to reduce a project’s operational air quality impact, provided that the AQMP demonstrates a 15 percent reduction of ozone precursors below baseline emissions for projects considered in the SIP and 35 percent for projects not considered in the SIP.

As the proposed project was not anticipated by the City in its current General Plan or other community plan, development of the project is not included in the growth assumptions of the SIP.

As such, a reduction of 35 percent below baseline emissions of ozone precursors is required for the proposed project. According to SMAQMD, a project’s ozone precursor emissions reductions goals should be based on mobile emissions only; however, reductions of ozone precursors from non-mobile emission reduction measures (e.g., natural gas or energy reductions) may still be accounted for and applied towards the emission reduction targets.

Mitigation Measure 4.3-2 of the Draft EIR requires preparation and implementation of a projectspecific AQMP. The AQMP (see Appendix D of the Draft EIR) was prepared using assumptions associated with full buildout of the annexation area, to represent a worst-case scenario. As shown in Table 4.3-10 of the Draft EIR, the proposed project would meet the 35 percent reduction target with implementation of Mitigation Measure 4.3-2, which represents all feasible mitigation.

In addition, SMAQMD reviewed the AQMP prepared for the proposed project, and provided a letter on June 19, 2024, verifying that the proposed project AQMP will, through on-site and offsite measures, achieve a 35 percent reduction in ozone precursors generated by mobile sources over the baseline conditions anticipated. Thus, additional mitigation measures are not required to be implemented to further reduce ROG and NOX emissions beyond what is presented in the Draft EIR.

Response to Comment 16-19
See Response to Comment 13-85. As stated on page 6-5 in Chapter 6, Statutorily Required Sections, of the Draft EIR, consistent with CEQA Guidelines Section 15130, the Draft EIR uses the projection approach for the cumulative analysis, which is based upon a summary of projections contained in the City of Sacramento 2040 General Plan and the Sacramento County General Plan. As such, the buildout conditions of the 2040 General Plan are incorporated by reference into the Draft EIR, and are addressed and analyzed therein, as well as other planned 4 Sacramento Metropolitan Air Quality Management District. DRAFT Recommended Guidance for Land Use Emission Reductions Version 5.0 (for Operational Emissions). January 2023. 5 Sacramento Metropolitan Air Quality Management District. Model Air Quality Plan “Project X”. September 20, 2007 Final EIR
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and reasonably foreseeable developments such as the Sacramento County WattEV Innovative Freight Terminal Project, the Northlake (Greenbriar) Project, the Metro Air Park Project, the Elkhorn Boulevard Extension Project, the Upper West Side Specific Plan, the Sacramento International Airport Master Plan, and the Grandpark Specific Plan.

Response to Comment 16-20
See Response to Comment 16-17.

Response to Comment 16-21
Pursuant to California Code of Regulations Title 14 Section 15064.3, only automobile traffic need be considered for VMT analysis; the Governor’s Office of Planning and Research (OPR) guidelines clarify that automobile traffic means passenger vehicles only, which is consistent with CEQA regulations and guidance. In addition, as was noted in the VMT Analysis prepared for the proposed project by DKS (Appendix P of the Draft EIR), the SACOG SACSIM-19 model was used for the purposes of VMT analysis. Trucks were not explicitly excised from the analysis, but the travel demand model does underestimate the share of heavy vehicle traffic associated with the specific industrial land uses associated with the proposed project. For the purposes of determining local traffic design compliance heavy truck traffic was layered on post model for the LTA, which is not part of the findings for CEQA impacts.

Response to Comment 16-22
The comment consists of a quote from the Draft EIR and does not address the adequacy of the environmental analysis.

Response to Comment 16-23
See Response to Comment 16-17. In addition, as noted in Mitigation Measure 4.12-3, the Draft EIR included as Appendix Q a VMT Mitigation Memorandum prepared by Avdis & Cucci. The VMT Mitigation Memorandum provides evidence of the feasibility of achieving the reductions required by the mitigation measure.

Response to Comment 16-24
The project does not include the approval of individual site plans, which would be necessary to provide the level of detail necessary for the analysis of the possibility of the project to substantially increase hazards to a geometric design feature, related to maneuvering and queuing of heavy vehicles. Project approval on a parcel-by-parcel basis will be subject to approval by the City regarding safe access, including heavy vehicle and automobile maneuvering and queueing.

Approval of such will be based on the applicable City standards and guidelines in place at the time of review, as well as industry standards, and the particular project characteristics. Relevant standards include City driveway spacing and circulation standards. Because site-specific approvals are not currently being processed, site-specific review of such details is not required at this time. The project description does not contain any specifics which would preclude meeting circulation standards in the future.

Response to Comment 16-25
Analysis of horizontal and vertical sight distance at street and driveway intersections is not typical for an EIR, particularly when specific site plans are not being approved. The construction of all streets and driveways is subject to City review, including City street guidelines and standards.

Such standards include clear sight triangles at all intersections. The project description does not Final EIR
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contain anything which would specifically preclude meeting such standards in the future, especially given the undeveloped nature of the site and relatively flat terrain.

Response to Comment 16-26
See Responses to Comments 16-13 and 16-14.

Response to Comment 16-27
See Responses to Comments 16-13, 16-14, and 16-19.

Response to Comment 16-28
As stated on page 7-1 in Chapter 7, Alternatives Analysis, of the Draft EIR, Section 15126.6(f) of CEQA Guidelines states, “The range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice.” Section 15126.6(f) of CEQA Guidelines further states:

The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determined could feasibly attain most of the basic objectives of the project.

In addition, an EIR is not required to analyze alternatives when the effects of the alternative “cannot be reasonably ascertained and whose implementation is remote and speculative.” The language included therein is not an invitation for a commenter to formulate an alternative that then needs to be addressed by the lead agency in a Draft EIR. In addition, with respect to the selection of alternatives, CEQA only requires “‘enough of a variation to allow informed decision-making.’” (Santa Cruz, supra, 177 Cal.App.4th at p. 988, quoting Mann v. Community Redevelopment Agency (1991) 233 Cal.App.3d 1143, 1151 (“Mann”).)
Furthermore, as shown in Table 7-1, Comparison of Environmental Impacts for Project Alternatives, in Chapter 7, Alternatives Analysis, of the Draft EIR, consistent with the recommendations of the commenter, the 20 Percent Electric Fleet and Reduced Footprint Alternatives addressed in the Draft EIR would result in reductions in the significant and unavoidable impacts identified for the proposed project related to air quality and agricultural resources.

Response to Comment 16-29
The comment is a conclusion statement and does not specifically address the adequacy of the Draft EIR beyond what has been discussed above.

Response to Comment 16-30
The comment is an introductory statement and summarizes the project components, as well as the commenter’s concerns regarding the air quality and health risk impacts analyzed within the EIR. Please see Responses to Comments 16-30 to 16-45 below for responses to the commenter’s detailed concerns.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 16-31
The comment includes a general description of the California Emissions Estimator Model (CalEEMod) modeling software, and does not address the adequacy of the Draft EIR.

Response to Comment 16-32
The comment summarizes SWAPE’s approach to analysis with regard to their review of the CalEEMod modeling conducted for the proposed project, as well as the commenter’s concerns regarding the CalEEMod modeling. Please see Responses to Comments 16-33 to 16-34 below for responses to the commenter’s detailed concerns on the CalEEMod modeling.

Response to Comment 16-33
The comment is in regard to the construction modeling conducted to assess the effectiveness of Mitigation Measure 4.3-1(b) of the Draft EIR, implementation of which would reduce the proposed project’s NOX emissions generated during construction activities of the Industrial Park portion of the proposed project. The commenter is correct in that the mitigated construction emissions modeling includes a typo related to the square footage of the hotel. It should be noted that the unmitigated modeling conducted for the Industrial Park portion of the proposed project also includes this typo. All other modeling prepared for the proposed project considered the correct square footage associated with the proposed hotel, and, thus, all other emissions presented in the Draft EIR, including all emissions associated with Full Buildout of the proposed project, are correct. Nonetheless, both the unmitigated and mitigated modeling associated with the Industrial Park portion of the proposed project was revised to account for the correct hotel square footage.

Table 4.3-7 of the Draft EIR is hereby revised as follows to present the updated unmitigated construction-related criteria pollutant emissions calculated within the revised modeling:

Table 4.3-7
Maximum Unmitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 89.34 89.97 lbs/day 85 lbs/day YES
ROG 63.65 64.45 lbs/day - NO
PM10 67.97 68.33 lbs/day and

4.58 4.62 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.17 lbs/day and

1.31 1.32 tons/yr
82 lbs/day and 15
tons/yr* NO
Full Buildout of the Annexation Area
NOX 100.2 lbs/day 85 lbs/day YES
ROG 51.28 lbs/day - NO
PM10 75.17 lbs/day and

5.49 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.5 lbs/day and

1.56 tons/yr
82 lbs/day and 15
tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.

Source: CalEEMod, February August 2024.

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Chapter 2.0 – Responses to Comments

Table 4.3-8 of the Draft EIR is hereby revised as follows to present the updated mitigated construction-related criteria pollutant emissions calculated within the revised modeling:

Table 4.3-8
Maximum Mitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 65.13 65.76 lbs/day 85 lbs/day NO
ROG 61.5 62.3 lbs/day - NO
PM10 66.74 67.11 lbs/day and

4.5 4.54 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 17.41 lbs/day and

1.24 1.25 tons/yr
82 lbs/day and 15
tons/yr* NO
Full Buildout of the Annexation Area
NOX 75.98 lbs/day 85 lbs/day NO
ROG 49.13 lbs/day - NO
PM10 73.95 lbs/day and

5.42 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 11.21 lbs/day and

1.49 tons/yr
82 lbs/day and 15
tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.

Source: CalEEMod, February August 2024.

Table 4.3-9 of the Draft EIR is hereby revised as follows to present the updated operational criteria pollutant emissions calculated within the revised modeling:

Table 4.3-9
Maximum Unmitigated Project Operational Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 628.33 629.08 lbs/day 65 lbs/day YES
ROG 172.37 174.21 lbs/day 65 lbs/day YES
PM10 32.99 33.05 lbs/day and

5.36 5.37 tons/yr
80 lbs/day and 14.6
tons/yr NO
PM2.5 17.91 17.98 lbs/day and

2.74 2.75 tons/yr
82 lbs/day and 15
tons/yr NO
Full Buildout of the Annexation Area
NOX 738.56 lbs/day 65 lbs/day YES
ROG 214.49 lbs/day 65 lbs/day YES
PM10 45.84 lbs/day and

7.68 tons/yr
80 lbs/day and 14.6
tons/yr NO
PM2.5 19.52 lbs/day and

3.07 tons/yr
82 lbs/day and 15
tons/yr NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.

Source: CalEEMod, February August 2024.

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Chapter 2.0 – Responses to Comments

Table 4.3-13 of the Draft EIR is hereby revised as follows to present the updated constructionrelated GHG emissions calculated within the revised modeling:

Table 4.3-13
Maximum Unmitigated On-Site Construction GHG Emissions – Proposed Project (MTCO2e/yr)
GHG Emissions
Threshold of
Significance
Exceeds
Threshold?
5,422.54 5,478.47 1,100 YES
Source: CalEEMod, June 2023 August 2024 (see Appendix C).

Table 4.3-15 of the Draft EIR is hereby revised as follows to present the updated operational GHG emissions calculated within the revised modeling:

Table 4.3-15
Unmitigated Annual Operational GHG Emissions (MTCO2e/yr) Emission Source
Proposed Project
Full Buildout of
Annexation
Area
Area 0.24 0.26
Energy 15,810.63 16,073.94 20,241.33
Mobile1 41,607.79 48,833.4
Offroad 2,893.68 4,411.25
Waste 3,375.85 4,251.88
Water 1,729.94 1,730.03 2,193.65
TOTAL ANNUAL GHG EMISSIONS 65,418.13 65,681.53 79,931.77 1 Mobile emissions include both passenger vehicle emissions estimated in CalEEMod, as well as heavy-duty vehicle emissions calculated off-model using EMFAC2021.

Source: CalEEMod, June 2023 August 2024 (see Appendix C).

As presented in the revisions to the tables above, the difference in emissions when considering the corrected emissions modeling as compared to the emissions presented in the Draft EIR would be negligible. Thus, the foregoing revisions are for clarification purposes only, and do not affect the conclusions of the Draft EIR.

Response to Comment 16-34
Construction information, including the anticipated length of construction phases, was provided by the project applicant. Because project-specific information was provided by the applicant, the default construction phase lengths were adjusted to match the actual anticipated construction schedule for the project. Thus, the information used within the Draft EIR represents a more accurate depiction of project construction, as opposed to the CalEEMod defaults that are based on a survey conducted by an air district with jurisdiction over a portion of the State located approximately 380 miles away from the project site. Considering that the construction phase lengths used in the emissions modeling are project-specific, the commenter’s comparison of the percentage increase in phase lengths from the CalEEMod default values, as well as the related percentage increase in emissions, does not provide useful information regarding the accuracy of the emissions analysis prepared for the project. Further, as stated in the comment, SMAQMD does not currently have a threshold for construction-related ROG emissions. Therefore, the increase in ROG emissions noted in the comment is irrelevant to the analysis included in the Draft EIR.

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Chapter 2.0 – Responses to Comments

Based on the above, the emissions modeling included as Appendix C of the Draft EIR was not revised, and the assumptions included in the Draft EIR regarding construction timing are adequate.

Response to Comment 16-35
See Response to Comment 16-18.

Response to Comment 16-36
The comment summarizes the health risk assessment (HRA) conducted as part of the Draft EIR and generally states that the Draft EIR’s evaluation of the project’s potential health risk impacts, as well as the subsequent less than significant conclusion of the Draft EIR is incorrect for four reasons. Please see Responses to Comments 16-37 to 16-39 below for responses to the commenter’s detailed concerns on the HRA.

Response to Comment 16-37
As discussed on page 4.3-39 of the Draft EIR, DPM concentrations resulting from project implementation were estimated using the American Meteorological Society/Environmental Protection Agency (AMS/EPA) Regulatory Model (AERMOD). The associated cancer risk and non-cancer hazard index were calculated using the CARB’s Hotspot Analysis Reporting Program Version 2 (HARP 2) Risk Assessment Standalone Tool (RAST), which calculates the cancer and non-cancer health impacts using the risk assessment guidelines of the 2015 Office of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments.6 The modeling was performed in accordance with the USEPA’s User’s Guide for the AERMOD7 and the 2015 OEHHA Guidance Manual.

Based on the USEPA’s User’s Guide for the AERMOD and the 2015 OEHHA Guidance Manual, the HRA assumed that residents would be exposed for the lifetime of the project (assumed to be 30 years for industrial/commercial land uses) and exposure would begin during the third trimester of pregnancy. The Draft EIR also states that considering both schools and residences exist in proximity to the area of disturbance, the estimation of health risks conservatively assumed that nearby receptors would be continuously exposed to pollutants from heavy-duty trucks at the maximum estimated concentrations. This assumption would represent a scenario whereby a resident living nearby also attends one of the nearby schools and is therefore exposed to pollutants both at home and at school.

Response to Comment 16-38
Health risks resulting from exposure to toxic air contaminants (TACs) are dependent both on dosage and the exposure period. Both factors were considered when assessing the potential impacts resulting from emission of diesel particulate matter (DPM) during project construction.

Pages 4.3-49 through 4.3-50 present a discussion of the limited duration of potential exposure, as well as the existing regulations that would reduce the emission of DPM during construction activities. For instance, project construction would be limited to a six-year period, and all off-road 6 Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots Program Risk Assessment Guidelines [pg. 8-18]. February 2015. 7 U.S. Environmental Protection Agency. User’s Guide for the AMS/EPA Regulatory Model (AERMOD). December 2016.

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equipment operating at the site would be subject to the In-Use Off-Road Diesel Vehicle Regulation, which requires increasingly stringent emissions standards be met by off-road equipment. Thus, nearby receptors would not be exposed to emissions from on-site construction equipment for a substantial amount of time, and emissions from on-site construction equipment must be reduced in compliance with the existing statewide regulations related to off-road diesel vehicles.

In addition, a key finding of the CARB’s Air Quality and Land Use Handbook: A Community Health Perspective is that emissions of DPM are highly dispersive, and concentrations diminish rapidly with distance from the source. Because DPM is highly dispersive, the fact that construction equipment would operate intermittently throughout the entire approximately 474.4-acre project site would have a large effect on the potential for project construction to result in health-related impacts through emissions of DPM. The large area of the project site would allow DPM to disperse and concentrations to decrease prior to exposure of receptors at the nearest residences. Such dispersal reduces the likelihood that the proposed project would result in health-related impacts.

Furthermore, as discussed under Impact 4.3-3 of the Draft EIR, an operational HRA was conducted for the proposed project to assess the increase in DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site. The operational HRA assumed that residents would be exposed for the lifetime of the project (assumed to be 30 years for industrial/commercial land uses) and exposure would begin during the third trimester of pregnancy. Given the locations of the truck routes and the idling points (i.e., loading docks), as well as the 30-year exposure period assumed in the operational HRA, DPM exposure that would occur during operation of the proposed project, and the subsequent cancer risk, is anticipated to be greater than the DPM exposure and associated cancer risk that would occur during project construction activities. As presented in Table 4.3-11 of the Draft EIR, operation of heavy-duty diesel-powered trucks on roadways and within the project site would result in a cancer risk at the maximally exposed receptor of 9.53 per million persons, which is below the applicable SMAQMD threshold of significance. Thus, construction of the proposed project can also be reasonably assumed to result in cancer risks below the applicable SMAQMD threshold of significance.

Based on the above and consistent with the discussion presented in Impact 4.3-3 of the Draft EIR, a quantitative analysis of health risks related to project construction is not warranted, as the specific details of project construction have been analyzed and determined not to represent a significant risk to public health.

Response to Comment 16-39
While the California Department of Justice does recommend preparing a quantitative HRA in accordance with OEHHA and local air district guidelines, the document referenced by the commenter does not specify that the HRA must assess construction-related impacts. Consistent with California Department of Justice (DOJ) recommendations, all topics related to projectgenerated DPM emissions were considered in the Draft EIR. More specifically, as discussed in Response to Comment 16-37 above, an HRA was conducted as part of the Draft EIR to evaluate impacts from exposure to TACs generated by diesel-powered trucks during project operation.

Response to Comment 16-40
Please see Response to Comment 16-35. In addition, the proposed project includes Mitigation Measure 4.3-1(b), which requires the use of Tier 4 final engine off-road equipment during Final EIR
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construction activities. Therefore, even if a construction HRA was conducted, and the cancer risks calculated therein were combined with operational cancer risks that would occur during the same time period that construction would occur, the potential health risk increase would not be significant.

Response to Comment 16-41
In order to prepare a screening-level HRA SWAPE prepared a CalEEMod run that differed significantly from the CalEEMod run prepared for the proposed project. As discussed in Response to Comment 16-33, the emissions estimation prepared for the proposed project was based on project-specific information provided by the project applicant. The changes implemented by SWAPE, such as the use of default construction phase lengths, are not justified and have likely been implemented to artificially increase project-related emissions. Furthermore, by ignoring project-specific information SWAPE further invalidates their own analysis. Because the screening-level HRA presented by SWAPE is based on the emissions that SWAPE incorrectly estimated, the results in the screening-level HRA prepared by SWAPE may be summarily rejected as invalid and not representative of the project. Notwithstanding the above, the technical approach and conclusions of SWAPE’s screening-level HRA are further analyzed to determine the validity of SWAPE’s remaining assumptions and methodology.

DPM is the solid material in diesel exhaust, because more than 90 percent of such material is less than one micrometer in diameter, DPM is a subset of the PM2.5 category of pollutants.

Despite DPM being a subset of PM2.5, SWAPE has used PM10 as a proxy to estimate emissions of DPM. PM10 includes larger size classes of particles, those particles equal to or less than 10 micrometer in diameter, as well as the smaller size classes included in PM2.5. By assuming all PM10 emissions represent DPM, SWAPE has inflated the amount of DPM emissions occurring due to the project. For instance, according to SWAPE’s own construction modeling, maximum annual exhaust emissions of PM10 would be 0.16 tons per year (tons/yr) while maximum annual exhaust emissions of PM2.5 would be 0.15 tons/yr. Given the sensitive nature of DPM emissions and dispersion analyses, even a slight discrepancy in the total emissions can lead to large changes in health risks. Without further justification for the use of PM10 rather than the more accurate PM2.5, the veracity of SWAPE’s conclusions regarding project-related health risks is further diminished. In addition, despite review of SWAPE’s CalEEMod outputs, the method by which SWAPE arrives at an estimate of 1,451 pounds of DPM emitted over the construction period is unclear. Without the ability to replicate SWAPE’s assumptions regarding DPM emissions, the accuracy of the emissions calculations used by SWAPE in the HRA, and the resulting estimation of health risks, cannot be verified.

Based on the information provided above, the screening-level HRA prepared by SWAPE is fatally flawed by erroneous methodologies used to estimate emissions. The basic flaw in SWAPE’s analysis is then compounded by an overestimation of DPM emissions, unsupported conclusions related to average DPM emissions, and erroneous modeling parameters. Consequently, the results of SWAPE’s screening-level HRA cannot be relied upon to accurately represent the potential health risks resulting from implementation of the project, and the conclusions presented in the Draft EIR related to health risks remain valid.

Final EIR
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March 2025
Chapter 2.0 – Responses to Comments

Response to Comment 16-42
The comment provides a general introduction related to their more detailed comments regarding feasible mitigation measures associated with the proposed project. Please see Responses to Comment 16-35.

Response to Comment 16-43
Please see Response to Comment 16-35.

Response to Comment 16-44
Please see Response to Comment 16-35.

Response to Comment 16-45
The comment is a conclusion and does not address the adequacy of the Draft EIR.

Response to Comment 16-46
The comment consists of the technical attachments to the comment letter and do not address the adequacy of the Draft EIR.

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Letter 17
17-1
17-2
17-3
Final EIR
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Letter 17 Cont.
17-4
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LETTER 17: TOM RAMOS, METRO AIR PARK PROPERTY OWNERS

ASSOCIATION
Response to Comment 17-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 17-2
The comment does not address the adequacy of the Draft EIR. The comment has been noted and referred to the decision-makers for consideration in their deliberations for approval or denial of the project.

Response to Comment 17-3
The comment does not address the adequacy of the Draft EIR. The comment regarding the MAP Public Facilities Master & Finance Plan has been noted and referred to the decision-makers for consideration in their deliberations for approval or denial of the project. Please see the Master Response.

Response to Comment 17-4
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.

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Letter 18
18-1
18-2
18-3
18-4
18-5
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Letter 18 Cont.
18-6
18-7
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LETTER 18: LISA PRAY, NORTH NATOMAS COMMUNITY COALITON
Response to Comment 18-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.

Response to Comment 18-2
As discussed on page 4.1-1 in Chapter 4.1, Aesthetics, of the Draft EIR, consistent with the CEQA Guidelines, the analysis of the Draft EIR is focused on aesthetic impacts to public views, such as those available to drivers on nearby roadways, rather than private views, including those seen from privately owned lands such as residences. As such, impacts related to visual quality of the project site from adjacent neighborhoods are not required to be evaluated under CEQA. With respect to effects of the proposed project on property values, as well as the other environmental impacts mentioned in the comment, please see the Master Response. In addition, noise impacts from the proposed project are addressed in Chapter 4.10, Noise, of the Draft EIR wherein all potential impacts to the surrounding neighborhood are reduced to a less-than-significant level.

The Draft EIR was prepared using assumptions associated with full buildout of the annexation area, to represent a reasonable worst-case scenario. Therefore, even if the future tenants are currently unknown, the impacts of the proposed project can be evaluated adequately.

Response to Comment 18-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 18-4
As discussed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, the Mixed-Use Residential Alternative would include the development of Parcels 5 and 8, which are located immediately adjacent to the proposed industrial park, with residential uses. As discussed therein, placing the proposed industrial uses in such close proximity to the residential units would result in potential impacts due to the incompatible uses. By contrast, the proposed project would include the development of industrial and commercial uses that are located much further from the nearest incompatible uses than would be the case under the Mixed-Use Residential Alternative. Potential impacts related to the proximity of the project site to adjacent uses are addressed throughout the Draft EIR.

Response to Comment 18-5
General economic and social impacts of the proposed project, such as home values, are not required to be analyzed under CEQA. Please see the Master Response.

Response to Comment 18-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 18-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.

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Chapter 2.0 – Responses to Comments

Letter 19
19-1
19-2
19-3
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Letter 19 Cont.
19-3
Cont.
19-4
19-5
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Letter 19 Cont.
19-5
Cont.
19-6
19-7
19-8
19-9
19-10
19-11
19-12
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Letter 19 Cont.
19-13
19-14
19-15
19-16
19-17
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Letter 19 Cont.
19-18
19-19
19-20
19-21
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Letter 19 Cont.
19-21
Cont.
21 19-22
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Letter 19 Cont.
19-22
Cont.
19-23
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Letter 19 Cont.
19-23
Cont.

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Letter 19 Cont.
19-24
19-25
19-26
19-27
19-28
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Letter 19 Cont.
19-28
Cont.
19-29
19-30
19-31
19-32
19-33
19-34
19-35
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Letter 19 Cont.
19-35
Cont.

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Chapter 2.0 – Responses to Comments

LETTER 19: SACRAMENTO CITIZENS FOR EQUITABLE DEVELOPMENT Response to Comment 19-1
The comment is an introduction to more detailed comments to follow.

Response to Comment 19-2
See Response to Comment 13-38.

Response to Comment 19-3
See Response to Comment 2-4.

Response to Comment 19-4
See Response to Comment 13-38.

Response to Comment 19-5
Potential impacts of the proposed project to Swainson’s hawk, as well as Swainson's hawk foraging habitat, is discussed under Impact 4.4-5 in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, implementation of Mitigation Measures 4.4-5(a) and 4.4-5(b) would reduce potential impacts to the species, both within and outside the Natomas Basin HCP permit area, to a less-than-significant level.

Response to Comment 19-6
The comment cites Public Resource Code and CEQA case law, but does not specifically address the adequacy of the Draft EIR. Please see the Master Response.

Response to Comment 19-7
Cumulative air quality impacts of the proposed project are addressed under Impact 4.3-6 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. As discussed therein, because the project’s individual air quality impacts were determined to be significant and unavoidable, cumulative air quality impacts were determined to be cumulatively considerable and significant and unavoidable. As such, both project-specific and cumulative impacts of the proposed project were addressed in the Draft EIR.

Response to Comment 19-8
See Response to Comment 19-7.

Response to Comment 19-9
As stated on page 4.3-37 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, “The analysis protocol and guidance provided by the SMAQMD’s CEQA Guide, including screening criteria and pollutant thresholds of significance, was used to analyze the proposed project’s air quality impacts.” All the modeling results from the quantitative air quality analysis is included in Appendices C and D of the Draft EIR. Therefore, the air quality analysis of the Draft EIR was prepared in full compliance with the applicable guidelines.

Response to Comment 19-10
See Response to Comment 19-9. In addition, as noted on page 4.3-39 of the Draft EIR, “The [Health Risk Assessment] modeling was performed in accordance with the USEPA’s User’s Guide Final EIR
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for the AERMOD29 and the 2015 OEHHA Guidance Manual.” All the modeling results from the quantitative air quality analysis, including the results of the Health Risk Assessment, are included in Appendices C of the Draft EIR.

Response to Comment 19-11
As stated on page 4.3-40 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, “activity related to implementation of the proposed project is required to comply with all SMAQMD rules and regulations.” As part of the permitting process for the proposed project, the City shall require compliance with SMAQMD regulations; therefore, compliance with such is not required to be enforced with a mitigation measure. Furthermore, SMAQMD is the implementing authority for compliance with CARB regulations and requirements.

Response to Comment 19-12
As discussed on page 4.3-38 of the Draft EIR, emissions associated with heavy-duty trucks travelling to and from the project site were calculated off-model using project-specific trip generation rates provided by DKS, trip length data provided by Fehr and Peers for the Metro Air Park Project located just north of the project site, and vehicle emission factors from the CARB’s mobile source emissions inventory (EMFAC2021) model. Consistent with the Travel Behavior Memorandum prepared by Fehr and Peers for the Metro Air Park Project, an average length of

44.80 miles was assumed for heavy truck trips. The Draft EIR analysis does not assume that trips would end at the edge of the air basin, but rather bases trip length on the foregoing data sources, regardless of air basin boundaries. EMFAC2021 was used to calculate all mobile-sourced emissions associated with heavy-duty vehicles.

Response to Comment 19-13
The estimated emission associated with the proposed project were not discounted based on participation in California’s Cap-and-Trade program. All reasonably foreseeable GHG emissions associated with the proposed project were accounted for within the project modeling, and analyzed within the Draft EIR (see Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy of the Draft EIR, as well as Appendix C to the Draft EIR). The commenter does not provide sufficient detail in their comment to warrant a detailed response regarding any additional reasonably foreseeable GHG emissions sources that would result from the proposed project, and does not provide any examples as to any sources in which they are referring. In addition, the proposed project includes Mitigation Measures 4.3-7(a) and 4.3-7(b) which require the proposed project to reduce GHG emissions during construction and operation of the proposed project through a number of on-site reduction measures, or to pay fees in order to offset such emissions.

Payment of fees would be part of California’s Cap-and-Trade program. However, including payment of fees through California’s Cap-and-Trade program as a feasible mitigation option does not discount the estimated emissions associated with the proposed project.

Response to Comment 19-14
Contrary to the commenter’s claim, the Draft EIR does not include a mitigation measure related to traffic signage.

Response to Comment 19-15
The aesthetic impacts of the proposed sound wall are addressed on page 4.1-22 in Chapter 4.1, Aesthetics, of the Draft EIR. As discussed therein, even without the inclusion of the sound wall, the impact to the existing visual character and quality of public views of the site would be Final EIR
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