Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-13
22-14
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-14
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-15
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-15
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-15
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-15
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-15
Cont.
22-16
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-16
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-16
Cont.
22-17
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-17
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-17
Cont.
22-18
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-18
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-18
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-18
Cont.
22-19
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-19
Cont.
22-20
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-20
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-20
Cont.
22-21
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-21
Cont.
22-22
22-23
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-23
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-24
22-25
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-25
Cont.
22-26
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-26
Cont.
22-27
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-27
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-27
Cont.
22-28
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-28
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-28
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-28
Cont.
22-29
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-29
Cont.
22-30
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-30
Cont.
22-31
22-32
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-32
Cont.
22-33
22-34
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-34
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-35
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-35
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-36
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-36
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-37
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-37
Cont.
22-38
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-38
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-38
Cont.
Letter 22 Cont.
22-39
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-39
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-39
Cont.
22-40
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-40
Cont.
22-41
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-41
Cont.
22-42
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-42
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-43
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-43
Cont.
Letter 22 Cont.
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-43
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-43
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-44
22-45
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-45
Cont.
22-46
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-46
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-46
Cont.
22-47
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-47
Cont.
22-48
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-48
Cont.
22-49
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-49
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-49
Cont.
22-50
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-50
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-50
Cont.
22-51
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-51
Cont.
22-52
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-52
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-52
Cont.
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-52
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-52
Cont.
22-53
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-53
Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-53
Cont.
22-54
22-55
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-55
Cont.
22-56
22-57
22-58
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-58
Cont.
22-59
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 22 Cont.
22-60
22-61
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
22-61
Cont.
22-62
Letter 22 Cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 22: SIERRA CLUB, ENVIRONMENTAL COUNCIL OF
SACRAMENTO, FRIENDS OF SWAINSON’S HAWK (SOLURI
MESERVE)
Response to Comment 22-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.
Response to Comment 22-2
The commenter claims that the City and LAFCo cannot be “co-lead agencies” under CEQA for the project, arguing that certain provisions of CEQA and the CEQA Guidelines prohibit the City and LAFCo from acting as “co-lead agencies” to prepare a single EIR. The City and LAFCo disagree with the commenter’s interpretation of CEQA and the CEQA Guidelines and respond that their preparation of the Draft EIR complies with both the letter and the spirit of CEQA and the CEQA Guidelines. In addition, the comment does not address the adequacy of the Draft EIR.
Therefore, further response is not required. See the Master Response.
Response to Comment 22-3
See Response to Comment 22-2.
Response to Comment 22-4
See Response to Comment 22-2. The commenter also asserts that LAFCo’s analysis is insufficient under CEQA, because the Draft EIR does not consider potential impacts associated with inconsistencies with County General Plan policies regarding the County’s Urban Policy Area and Urban Services Boundary. The commenter further argues that this approach is inconsistent with a prior EIR for the Kammerer Road /Highway 99 SOIA project (“Kammerer SOIA EIR”). The commenter is incorrect. The commenter appears to misunderstand that the Kammerer SOIA EIR did not include any development proposal within the SOIA area, making future development in the area speculative and leaving the SOIA area to remain in the County’s jurisdiction upon approval.
Urban development has already been proposed by the City and represents reasonably foreseeable City-regulated urban development that must be considered as required by CEQA.
Furthermore, the proposed development of the project area is being considered by the City, to occur within the City’s jurisdiction, should LAFCo approve the sphere of influence amendment and annexation requests, and the City approve the prezoning and related entitlements. Without the approval of every one of these requests, development would not occur within the project area and inconsistency with a County General Plan policy would not occur. As a result, the analysis of consistency with County General Plan policies is not required. (See The Highway 68 Coalition v.
County of Monterey (2017) 14 Cal.App.5th 883, 893.)
Response to Comment 22-5
See Response to Comment 22-4.
Response to Comment 22-6
See Response to Comment 22-4.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 22-7
See Response to Comment around 13-27 to 13-31.
Response to Comment 22-8
See Response to Comment 22-2.
Response to Comment 22-9
Because development of the nonparticipating parcels is not currently proposed and because details of future buildout are not currently available, consistent with the requirements of the CEQA Guidelines, a programmatic review of future buildout of the nonparticipating parcels is included throughout the Draft EIR. Each impact statement in the technical chapters of the Draft EIR includes a header or headers that establishes if the analysis applies to buildout of the industrial park, the nonparticipating parcels, or both. As such, the Draft EIR presents an adequate programmatic review of future buildout of the nonparticipating parcels. Furthermore, as stated on page 3-8 of Chapter 3, Project Description, of the Draft EIR, any development proposed for these sites would require additional entitlement requests and review pursuant to CEQA. A subsequent environmental review would be conducted when parcel-specific development proposals are received that will address all potential impacts at an appropriate project-level consistent with the programmatic analysis included in the Draft EIR.
Response to Comment 22-10
The comment does not address the adequacy of the Draft EIR.
Response to Comment 22-11
See Response to Comment 22-9.
Response to Comment 22-12
As discussed on page 4.4-66 in Chapter 4.4, Biological Resources, of the Draft EIR, Mitigation Measure 4.4-11(e) requires an Aquatic Resources Delineation to be conducted in the nonparticipating parcels prior to any development. Mitigation Measure 4.4-11(f) requires further protective measures to be taken should State or federally protected wetlands be encountered. As such, future development of the nonparticipating parcels would be contingent on the results of the Aquatic Resources Delineation conducted pursuant to Mitigation Measure 4.4-11(e) and the protective measures required by Mitigation Measure 4.4-11(f); any development proposal that fails to comply with such mitigation would not be allowed to advance. By requiring compliance with the foregoing mitigation measures, the Draft EIR adequately addresses potential impacts related to the presence of aquatic resources within the nonparticipating parcels. In addition, the foregoing mitigation measures require compliance with specific performance standards and regulatory requirements, and also require implementation prior to project activities begin, and, thus, would not be considered deferral.
Furthermore, potential impacts to giant garter snake are addressed under Impact 4.4-3 in Chapter
4.4 of the Draft EIR. The discussion therein acknowledges that the project site, including the nonparticipating parcels, contains potential habitat for the species; potential impacts to the species are reduced to a less than significant level through implementation of Mitigation Measure
4.4-3, as amended in this Final EIR.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 22-13
Please see Response to Comment 9-3. Contrary to the claim of the commenter, the proposed Prezoning of the nonparticipating parcels to Industrial (M-1) does not allow industrial development “as a matter of right.” Warehouse development of the nonparticipating parcels, including Parcel 8, would not be “a matter of right” because, as stated on page 3-8 of Chapter 3, Project Description, of the Draft EIR, any development proposed for the nonparticipating parcels would require additional entitlement requests and review pursuant to CEQA.
Response to Comment 22-14
The modeling output for criteria air pollutant emissions is based on total maximum square footage which is known and can be modeled to represent a reasonable worst-case analysis. Similarly, the noise analysis prepared for the proposed project was based on reasonable worst-case assumptions in order to determine the height of sound walls that would be needed along the project site boundaries. Varying locations of loading docks and drive aisles would not significantly affect the criteria air pollutant emission impacts or the operational noise impacts associated with the nonparticipating parcels. Therefore, basing the criteria pollutant emissions, operational noise impacts, and mitigation measures on those reasonable worst-case assumptions is feasible and appropriate to ensure that impacts associated with the proposed project as a whole are adequately addressed. For example, while the use of sound walls represents a viable mitigation option to reduce operational noise impacts associated with the proposed project, constructing and reconstructing such walls as development on the nonparticipating parcels occurs in the future is not economically feasible.
However, given the highly dispersive nature of DPM emissions, health risk impacts are a function of concentration and need to be based on highly specific truck circulation routes and loading dock locations in order to provide a reasonable analysis. Because site planning for the nonparticipating parcels has not been conducted, the location of these features is not known. Therefore, by assuming that Parcel 8 could reasonably be developed with a distribution center within 1,000 feet of a sensitive receptor, and identifying a potentially significant health risk impact related to future development on Parcel 8, the Draft EIR provides a reasonable worst-case analysis. In addition, the Draft EIR includes Mitigation Measure 4.3-3, which requires an additional health risk analysis at the time that Parcel 8 is proposed for development, to ensure that health risks associated with Parcel 8 do not occur. Further, should a future applicant pursue development of Parcel 8 at a later date, such development application would need to be submitted to the City for review and approval, and, at minimum, the future development proposal would be required to undergo Site Plan and Design Review. At such time, the City would also review the development application to determine if the potential environmental impacts of the future development proposal are within the scope of what the EIR studied, or if any of the criteria included in CEQA Guidelines Section 15162 would be triggered, thus requiring subsequent environmental review.
Based on the above, a programmatic approach and implementation of a programmatic mitigation measure is appropriate and adequate to address the potential impact risk impacts associated with Parcel 8 for the purposes of the analysis included in the Draft EIR.
Response to Comment 22-15
See Responses to Comments 2-5 and 2-17. As shown therein, project mitigation has been revised to address potential impacts to biological resources outside of the Natomas Basin HCP permit area.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 22-16
As discussed on page 4.3-50 of the Draft EIR, an HRA was prepared to assess the increase in DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site.
DPM is considered a subset of PM2.5 emissions. As such, the estimated concentration of PM2.5 was used as a proxy to represent emissions of DPM. In addition, a total of 80 to 95 percent of DPM is made up of UFPs, and, as discussed on page 4.3-5 of the Draft EIR, UFP mass is a small portion of PM2.5. Thus, health risks associated with UFPs generated by heavy-duty diesel trucks travelling to and from the project site have been inherently considered within the HRA prepared for the proposed project. As shown 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 cancer risk and hazard index at the maximally exposed receptor below the applicable SMAQMD thresholds of significance. Consequently, health risks associated with UFPs are also considered to be below the applicable SMAQMD thresholds of significance and further analysis is not warranted.
Response to Comment 22-17
See Responses to Comments 13-79 and 13-81. As discussed therein, project construction noise levels would be below existing ambient noise levels in the project vicinity. Therefore, construction of the proposed project would not result in the creation of new or exacerbation of existing human health impacts associated with noise.
Response to Comment 22-18
See Response to Comment 13-87. The commenter asserts that the project objectives have been “manipulated” to avoid meaningful analysis of project alternatives. The North Coast Rivers Alliance case cited by the commenter involved a situation where the lead agency approved a pest control alternative that was excluded from discussion in the EIR because of an “artificially narrow” project objective regarding eradication of an invasive species. (North Coast Rivers Alliance v.
Kawamura (2016) 243 Cal.App.4th 647, 669.) That situation is not relevant to the proposed project. Chapter 7, Alternatives Analysis, of the Draft EIR fully analyzed three alternatives and discussed in some detail several others that were eliminated from further consideration as allowed by CEQA.
The commenter makes conclusory claims that the project objectives are “manipulated” but appears to ignore the actual analysis in the Draft EIR, such as the multi-page analysis of the No Project (No Build) Alternative presented on pages 7-7 to 7-10 of the Draft EIR, as well as the discussion of the potential for an Off-Site Alternative presented on page 7-5. The Draft EIR discussed the alternatives’ ability to meet project objectives as well as reduce significant impacts of the proposed project. As explained on page 7-4 of the Draft EIR, “the primary intent of the alternatives analysis is to disclose other ways that the objectives of the project could be attained, while reducing the magnitude of, or avoiding, one or more of the significant environmental impacts of the proposed project.” As such, the main focus of the alternatives analysis is to evaluate the ability of the alternatives to reduce or avoid significant environmental impacts identified for the proposed project, rather than fulfill the project objectives.
The commenter does not provide any evidence supporting commenter’s claims of manipulation.
While the project objectives are a component of CEQA, they 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.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 22-19
The comment fails to account for the additional factors that may be used to eliminate alternatives from detailed consideration, pursuant to Guidelines Section 15126.6(c): infeasibility or inability to avoid significant environmental impacts. A discussion of the alternatives considered but dismissed from further analysis is presented beginning on page 7-4 in Chapter 7, Alternatives Analysis, of the Draft EIR. As discussed therein, an Off-Site Alternative was determined to be infeasible because the project applicant does not own any off-site locations that could accommodate the proposed project.
Response to Comment 22-20
See Response to Comment around 13-27 to 13-31.
Response to Comment 22-21
The comment is a general conclusion statement and does not specifically address the adequacy of the Draft EIR.
Response to Comment 22-22
The comments included in the exhibits attached to the comment letter are addressed below.
Response to Comment 22-23
The comment includes the additional attachments to the comment letter and do not address the adequacy of the Draft EIR.
Response to Comment 22-24
The comment is an introduction statement and does not address the adequacy of the Draft EIR.
Response to Comment 22-25
The comment summarizes the analysis of the Draft EIR and does not specifically address the adequacy of the Draft EIR.
Response to Comment 22-26
The commentor correctly notes that the proposed VMT reduction strategy in the Draft EIR “is deferral of mitigation,” and that such deferral is “improper under CEQA unless there are practical reasons why such deferral is necessary.” The CEQA Guidelines allow for such a deferral of mitigation “provided that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the types of potential actions that can feasibly achieve that performance standard.” (CEQA Guidelines, §15126.4(a)(1)(B).) The DEIR meets these requirements.
Regarding the reasons deferral is necessary for the project, the impacts associated with increased VMT will result from unknown future tenants of the project site, not the construction of the project by the developer, and such users will be determined by market forces beyond the developer’s control. Thus, future tenants will need to determine which measures will be best suited for their operations, which may be different from one operator to the next, making it impractical to impose the same mitigation strategies uniformly on all future users.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
As for the requirements for the proper deferral of mitigation, the proposed mitigation strategy would meet all of the requirements outlined in the CEQA Guidelines, if the decisionmakers adopt the EIR and approve the project: (1) the proposed deferred mitigation strategy sets a clear performance standard, establishing a minimum 22 percent reduction in VMT prior to the issuance of a certificate of occupancy for all future users in the project; and (2) the deferred mitigation measure identifies several VMT-reduction measures recommended by CAPCOA, and supported by studies of the real-world efficacy of various strategies to reduce VMT, that are feasibly capable of mitigating the project’s VMT impacts to a less-than-significant level.
With respect to the commenter’s speculative assertion that the proposed mitigation strategies are unlikely to achieve full mitigation, and that the Draft EIR must propose additional and/or alternative mitigation or disclose that the VMT impact is significant and unavoidable, please see Response to Comment 22-27.
Response to Comment 22-27
The commentor claims that a memo from the applicant’s attorney proposing a mitigation strategy to agency staff is biased and inadequate, because the attorney “presents no credentials as a qualified engineer or planner expert….” The commentor further speculates that future users of the project site will operate in a certain manner that “far less than 100 percent of employees can be considered as realistic participants.” The commentor also reviews the various VMT-reducing mitigation measures proposed in the Draft EIR, arguing that the analysis in the memo overstates the effectiveness of these mitigation measures. The commentor appears to misunderstand how the mitigation measures were developed and how to calculate the potential VMT reduction capability of each of the measures.
First, the memo from the applicant’s attorney only proposes mitigation measures previously formulated and recommended by the CAPCOA. Each measure is supported by real-world studies of the efficacy of the transportation demand reduction program recommended in the CAPCOA Handbook.
Second, a Public Works Department memorandum inadvertently left out of Appendix Q of the Draft EIR demonstrates how City engineering staff completed an independent review of the measures and calculations provided by the applicant and determined (1) they were consistent with the guidance outlined in the CAPCOA Handbook, and (2) the project could feasibly achieve the proposed performance standard of a minimum 22 percent VMT reduction for the project.
Please see Appendix B of this Final EIR for a copy of the City’s review memo.
Regarding the feasibility of the VMT reduction measures, the commentor states that the applicant’s attorney memo is improperly biased because the calculations “always presume that 100 percent of the Project’s employees would be able to participate.” The claim of the commenter is incorrect. Pursuant to the CAPCOA Handbook referenced in the proposed mitigation strategy memo, the input for employee percentages is determined by the percentage of employees that the future employer determines would be eligible for each given program, not how many employees would participate.
For example, the commentor’s claim that it is unrealistic to assume that 100 percent of employees would be eligible for many of the VMT reduction measures is incorrect. CAPCOA Handbook expressly states that for many of the measures, the percentage of employees that would be Final EIR
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eligible to participate “will usually be 100 percent,” or do not rely on any user input at all. (See, e.g., CAPCOA Handbook, pp. 90, 93, and 107.) The calculation formula for each mitigation measure already accounts for reasonably foreseeable participation rates that are supported by real-world studies, each of which are referenced in the CAPCOA Handbook. (See, e.g., CAPCOA Handbook, “GHG Calculation Variables” tables, pp. 87, 90, 93, 96, 101, 105, and 110.) Furthermore, the commentor appears to misunderstand how the measures would be selected and implemented. As stated in the Draft EIR, each future user of the project site would need to develop a VMT reduction plan by selecting the measures most appropriate for their operation, determining the appropriate employee eligibility percentage, where appropriate, and submitting the plan to City staff for review and approval. Staff would then determine whether the assumptions and calculations (i) are consistent with the CAPCOA Handbook guidance and (ii) demonstrate the calculated VMT reduction meets the adopted performance standard.
Similarly, the commentor incorrectly claims that Trip Reduction Measure T-6 “Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring)” is “the sum of what can be achieved through implementing [Measures T-7 through T-11].” The maximum possible reduction percentage under Measure T-6 is 26 percent. The sum of Measures T-7 through T-11 equal a maximum 42.3 percent reduction (four percent, eight percent, 5.5 percent,
4.4 percent, and 20.4 percent, respectively). Thus, rather than establishing a simplistic system as suggested by the commentor, Measure T-6 in the CAPCOA Handbook recognizes the complexity of a holistic Trip Reduction Program, supported by real-world data, that accounts for the relative efficacy of each component when implemented together in a single organization.
Response to Comment 22-28
As stated by the commenter, under Cumulative conditions, which includes cumulative buildout of the area without the proposed project, queues at the intersection of Del Paso Road and northbound I-5 ramps would exceed the queue storage length during the AM peak hour, but not in the PM peak hour. As cited by the commenter, Caltrans Traffic Safety Bulletin 20-02-R1, dated December 18, 2020, states:
If the Project adds two or more car lengths to the ramp queue in the peak hour that will extend into the freeway mainline, then the location must be reviewed for traffic safety impacts […].
Traffic safety mitigation shall not be requested under conditions where queuing already exists on a freeway exit ramp. This includes:
• Conditions where freeway exit-ramp queuing currently spills back onto the mainline;
• Where queuing currently exceeds a freeway auxiliary lane length; or • Where freeway traffic volumes currently cause freeway exit ramp turning lanes to exceed capacity.
Based on the foregoing language, Caltrans Traffic Safety Bulletin 20-02-R1 implies that if a ramp queue would extend into the freeway mainline during any peak hour, the intersection is considered potentially impacted. Contrary to the claim of the commenter, the distinction between queues during the AM peak hour and the PM peak hour do not change whether or not traffic safety mitigation is required. Because queues at the intersection of Del Paso Road and northbound I-5 ramps would exceed the queue storage length during the day, regardless of the peak hour, Final EIR
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queueing is already considered to exist at the ramps. Because queue lengths would exceed the queue storage length under Cumulative conditions with or without buildout of the proposed project, traffic safety mitigation is not required.
Response to Comment 22-29
The commentor’s summary of the anticipated I-5 traffic conditions in the vicinity of the Del Paso Road interchange are consistent with the information presented in the Draft EIR. The commentor concludes from the analysis that the queueing would result in a shortened available weaving section on the I-5 mainline, resulting in increased braking and unsafe merging and weaving behavior. The commenter’s assertion is not backed with calculations. As noted in Response to Comment 3-4, microsimulation results become highly unstable when volume exceeds capacity for a given movement and the metric used of 95th percentile queueing is particularly susceptible to such variability. The proposed project would only cause a minor change in total traffic at the ramp as compared the Cumulative No Project scenario. Pursuant to Caltrans Safety Bulletin 20- 02-R1, project mitigations shall not be requested where queueing spills back onto the mainline freeway without the project.
Response to Comment 22-30
See Response to Comment 16-21. As stated therein, pursuant to California Code of Regulations Title 14 Section 15064.3, only automobile traffic need be considered for VMT analysis; the OPR guidelines clarify that automobile traffic means passenger vehicles only, which is consistent with CEQA regulations and guidance. In addition, trucks were not explicitly excised from the VMT Analysis prepared for the proposed project by DKS (Appendix P of the Draft EIR), 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 and for determining intersection queueing, heavy truck traffic was layered on post travel demand model for the LTA and for the queueing analysis. Operational analysis was completed using microsimulation in SimTraffic, which includes the vehicle fleet mix and, thus, the differential characteristics of trucks verses passenger vehicles are accounted for in the queue length assessment for intersection safety.
Response to Comment 22-31
The commentor refers to Table 10 of the Trip Generation and Distribution Memo prepared for the proposed project (Appendix O of the Draft EIR), which, as described in the Trip Generation and Distribution Memo, is the trip generation from the traffic demand model. Page 11 of the Trip Generation and Distribution Memo states the following:
Compared to the anticipated trip generation for these highway commercial uses adjacent to an interstate freeway, these estimates are extremely low. The travel model does not include land use categories/uses specific to intense highway commercial uses, such as a convenience store/gas station. The model trip generation is also unconstrained for employment uses, which reduces the number of trips attracted to a land use not adjacent to a developed area.
It is recommended that ITE trip generation rates be used for the highway commercial uses, and applied with a post-processor methodology to adjust the model estimates to reflect anticipated travel volumes. This is especially critical for the access management review along Metro Air Parkway near the I-5 interchange, and along Airport South Industrial Drive.
The recommended trip generation of the highway commercial uses is based upon Final EIR
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representative uses from the Institute of Transportation Engineers (ITE) Trip Generation Manual 11th Edition, Version 6.0.1, May 2022. Table 11 summarizes the land use on each parcel and the assumed ITE land use code and statistics.
Table 12 and Table 13 summarize the vehicle trip generation estimates for the highway commercial parcels. Parcel 6C was calculated based upon both fueling positions and convenience store size, with the results averaged. Pass-by percentages are based upon ITE data. Internal trips are limited to a maximum of 10 percent, with no trips assumed between restaurants. The appendix includes the trip generation calculations for highway commercial uses.
The highway commercial trip generation data in Tables 12 & 13 of the Trip Generation and Distribution Memo are the same values in Table 7 from the Traffic Impact Analysis prepared for the proposed project (Appendix N of the Draft EIR). The data in Table 10 of the Trip Generation and Distribution Memo were not used for trip generation rates. Instead, the recommended ITErates shown on Tables 12 and 13 in the Trip Generation and Distribution Memo were used for trip generation rates in the analysis.
Figure 3-3, Airport South Industrial Park – Preliminary Site Plan, on page 3-6 in Chapter 3, Project Description, of the Draft EIR contains the site plan and land use summary. The traffic study included all parcels including those labeled “future industrial” within the land use summary. For the purposes of transportation impact analysis, both participating and nonparticipating parcels were included in the analysis.
Response to Comment 22-32
See Response to Comment 3-4 for detail regarding volume redistribution between El Centro Road and East Commerce Way under cumulative conditions. Daily traffic counts were not collected on the requested segments for conducting traffic analysis. Based on the raw travel demand model daily results for the segments requested, the project traffic plus project redistribution effect results in only a very minor change in total daily traffic on the requested segments. The Travel Demand Model used is the most accurate tool available for forecasting the effects of both trip generation from the project and trip redistribution caused by improved roadway connections built by the project. Within the City General Plan and regional MTP/SCS modeling, a new roadway connection is planned between East Commerce Way and El Centro Road. This connection, along with the project improving the connection between Metro Air Parkway interchange and El Centro Road, results in some minor shifts in travel patterns. This shift results in forecast volumes of background traffic decreasing on El Centro Road south of the connection and increasing by a similar amount on East Commerce Way south of the connection. The resulting redistribution was more than the project added traffic to El Centro Road and, thus, a net decrease was shown.
Response to Comment 22-33
The comment does not address the adequacy of the Draft EIR. See Master Response.
Response to Comment 22-34
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.
Response to Comment 22-35
The comment does not address the adequacy of the Draft EIR.
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Response to Comment 22-36
The comment does not address the adequacy of the Draft EIR.
Response to Comment 22-37
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 22-38
The comment does not address the adequacy of the Draft EIR.
Response to Comment 22-39
The comment is an introductory statement describing to commentor’s opinion on initial “steps” to characterize the existing environmental setting for a site. The comment states that Step 1, biological surveys of the site, and Step 2, literature/database review, are incomplete and misleading. Chapter 4.4, Biological Resources, of the Draft EIR, which includes the information provided in the BRA prepared for the proposed project (Appendix E of the Draft EIR), thoroughly discusses the biological field surveys (commentor Step 1) and desktop literature/database reviews (commentor Step 2) conducted for the project. The introductory comment statement does not raise and specific issues on adequacy of the Draft EIR.
The commentor provides the opinion that the surveys conducted as part of the BRA are inadequate based on the commentor's equation model of species detected per hour of survey.
The equation model presented by the commentor is not an industry-accepted practice/standard or appropriate methodology for several reasons. The commentor’s model provides a biased result, likely greatly overstates the number of species that occur on the site, and infers that few species were detected each survey. When in fact, the majority of the species were detected repeatedly during each survey, which is a common result. The surveys conducted for the project were intentionally conducted between fall through summer to provide opportunity to capture resident and migratory wildlife species utilizing the site.
In response to the comment that the biological survey did not detect certain wildlife species identified by the Smallwood survey, the comment is misleading and does not accurately characterize the site. Many of Smallwood’s observations were avian “flyovers” of the site or species detected off-site. Merely because a bird flew over the site does not suggest the site is utilized or inhabited by that species. Unless the bird is observed hunting, foraging, perching, or preening, flyovers are generally not included in the list of avian species that inhabit a site.
The commentor’s statement about tricolored blackbird being detected on-site is unfounded, given that Bargas conducted several surveys on-site. If tricolored blackbird resided on-site, the species would have been detected during surveys of the site, but was not. Potential impacts to tricolored blackbird are addressed under Impact 4.4-7 in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, nesting habitat does not occur within the project site. Furthermore, in the unlikely event that tricolored blackbird would be present on-site, Mitigation Measures 4.4-9(a) and 4.4-9(b) require surveys, avoidance, and coordination with the City and CDFW if nesting birds and raptors protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC), which includes tricolored blackbird, are found actively nesting on-site. Therefore, the Draft EIR adequately addresses potential impacts to tricolored blackbird.
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As for site access and surveys on the nonparticipating parcels, Bargas was informed that they did not have permission to access these lands; thus, survey of these areas were conducted along the periphery with sight assistance via binoculars.
With respect to rare plants, Bargas's surveys were conducted during the appropriate timing to detect rare plants. The use of reference sites can be helpful, especially for determining magnitude of populations of rare plant expression. However, the use of reference site(s) is not a requirement for conducting presence/absence rare plant surveys, and often those off-site reference locations are not accessible due to lack of permissible access. Ultimately, based on the literature searches and desktop database queries, as well as the site-specific conditions, it was determined the site does not support habitat for special-status plants and that none are expect to occur such that would warrant focused rare plant surveys. The nearest records of rare plants were over five miles from the site.
Response to Comment 22-40
As presented in Section 3.1.2.1 of the BRA prepared for the proposed project by Bargas (Appendix E of the Draft EIR), the CNDDB records search area included the Regional Study Area, which was defined in Section 1.3 in the BRA as the project site and the surrounding five miles.
The desktop database searches (including use of CNDDB and other sources) are not the sole factor in determining presence/absence of special-status species. Therefore, Bargas supplemented the desktop database searches with field surveys of the site, which were intentionally performed by Bargas between fall to summer. Thus, the commentor’s claim that the analysis of special-status species occurrence is flawed is not true. Further, it is acknowledged that biologists are unlikely to observe all species that occur on a site through site surveys alone.
Thus, the BRA follows accepted practice to evaluate the potential for species to occur on-site by conducting site surveys and creating a list of species not observed but considered to have potential to occur based on on-site resources, including habitat types and vegetation communities, historic observations, species extents, geographic range, population sizes, and distribution, etc.
The commentor's use of iNaturalist can be helpful but is not a typical reliable source in the eyes of the State and Federal Wildlife Agencies. State and federal databases (i.e., USFWS, CDFW, etc.) serve as the primary sources of reliable data references for biological studies because they are species and sub-species specific, credible, vetted by specialists, and provide site- and observation-specific location information. Public websites such as eBird and iNaturalist may be referred to as secondary resources as they are considered citizen-based science efforts. Any member of the public can record an unverified observation, which may or may not be accurate.
Such observations from non-professional contributors may therefore be unreliable as to species and locational information. Additionally, even if accurate, the records provide general information, often not to the sub-species level, and depending on the species sensitivity, do not provide sitespecific or observation location information. The information on these sites may not be credible and they are not considered a credible primary resource by the City. Furthermore, while iNaturalist data often provides general information on a regional scale, the State and federal databases provide site-specific observation information that can be very useful when analyzing a specific property. Public databases are becoming more recognized as technology and screening advances, but currently there is still much uncertainty in the accuracy and validity of what is posted on those public forums.
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The evaluation by the commentor of species recorded up to 30 miles from the project site is misleading, unnecessary, and not applicable to the species that could likely occur on the project site. Simply because a species has been reported as occurring in the 30-mile region does not mean that they have a potential for presence at the project site, which would largely depend on whether suitable habitat is present.
Response to Comment 22-41
See Response to Comment 22-40. Using credible databases, reasonable distances, on-site conditions, and various database tools, Bargas focused the project analysis to those species with the reasonable potential to occur on-site. Doing so is standard technique purposely used to screen out species unlikely to occur in the target survey study area. In addition, to ensure thorough evaluation of special-status species, Bargas conducted multiple biological surveys at the project site over a nine-month span.
The commentor is misinterpreting the discussion presented in Section 3.1.3 of the BRA (Appendix E of the Draft EIR). The "further distinguished" is additional consideration and not the sole/primary factor of the analysis, as inferred and interpreted by the commentor. Biological surveys were intentionally conducted by Bargas between fall through summer to provide opportunity to capture resident, migratory, and transient, wildlife species utilizing the site.
The commenter’s claim that Bargas did not extend evaluation to the nonparticipating parcels is not correct. As explained on page 4.4-38 of the Draft EIR, the terminology in the BRA prepared by Bargas varies slightly from that of Chapter 4.4 of the Draft EIR, but the industrial park area and nonparticipating parcels area were evaluated at an appropriate level. Potential impacts to the industrial park and nonparticipating parcels were evaluated throughout Chapter 4.4 of the Draft EIR.
Response to Comment 22-42
See Response to Comment 22-40. The commentor suggests that white-faced ibis should be noted as present and/or using the site. The commenter is again misunderstanding and misrepresenting the data presented in the BRA. For clarity, Section 4.6.2.4 of the BRA prepared for the proposed project (Appendix E of the Draft EIR) acknowledges that white-faced ibis has the potential to occur within the on-site canals and adjacent agricultural areas. Potential impacts to white-faced ibis are addressed under Impact 4.4-7 in Chapter 4.4, Biological Resources, of the Draft EIR. As for loggerhead shrike, Section 4.6.2.4 of the BRA states that although the species does occur within the Natomas Basin, suitable scrubby habitat preferred by the species is not present on-site. Potential impacts to the species are addressed under Impact 4.4-8 of the Draft EIR. As discussed therein, implementation of Mitigation Measure 4.4-8 would be required to reduce potential impacts to loggerhead shrike to a less-than-significant level. Modesto song sparrow is also evaluated and described in Section 4.6.2.4 of the BRA as potentially occurring within the canals that border the site; however, the project site was found to contain limited low quality habitat for the species. Potential impacts to the species are addressed under Impact 4.4- 9 of the Draft EIR. Given that numerous biological surveys of the site were conducted by Bargas across a nine-month span, the foregoing species would have been detected if present. As stated within the BRA, white-faced ibis, loggerhead shrike, and Modesto song sparrow were not observed on-site.
Response to Comment 22-43
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The comment does not address the adequacy of the Draft EIR.
Response to Comment 22-44
See Responses to Comments 22-40 and 22-41. The determination that tricolored blackbird has low potential for occurrence within the study area is based on database records, site-specific conditions, and the result of the biological field surveys conducted across nine months. The commentor’s statement that bank swallow is difficult to identify is unfounded and solely the opinion of the commentor. The swallow species is very easily identifiable and distinguishable from other swallow species by their plumage and vocalizations. Given the extent of biological surveys of the site conducted by Bargas, bank swallow would have been easily detected, if present; none were observed.
Response to Comment 22-45
The comment is incorrectly inferring the "greater risk of bird-aircraft strike," which is not stated or suggested in the BRA prepared for the proposed project (Appendix E of the Draft EIR). The BRA states facts regarding the existing condition of the site and relationship with the airport and FAA zone. The BRA does not state or suggest that development of the site would result in fewer bird strikes. The commentor's opinion and request to measure and study bird flight heights in an experimental setting is typically not part of an effective project impact analysis under CEQA.
Furthermore, such study is neither necessary nor required for the Draft EIR and does not raise new or additional environmental issues concerning the adequacy of the Draft EIR.
Response to Comment 22-46
See Response to Comment 2-6. As discussed in Section 4.7.1 of the BRA prepared for the proposed project (Appendix E of the Draft EIR), implementation of the project would not result in significant habitat fragmentation or adversely affect wildlife corridors. Such impacts are also addressed under Impact 4.4-12 of the Draft EIR. As discussed therein, aquatic species could be affected by the proposed project; however, implementation of the proposed mitigation measures presented in Chapter 4.4, Biological Resources, of the Draft EIR would reduce the impact to less than significant. Furthermore, although the term “habitat fragmentation” is not used in the Draft EIR, as discussed under Impact 4.4-12, implementation of the project would not result in significant habitat fragmentation because habitats present that could provide sufficient shelter that would support typical wildlife movements/corridors are not present on-site. Suitable habitats exist off-site and beyond the project site that are larger contiguous habitats and could provide higher quality resources and serve as wildlife movement corridors.
Potential impacts to giant garter snake as a result of project implementation are discussed under Impact 4.4-3 in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, implementation of mitigation would reduce impacts to giant garter snake, including its habitat, to a less-than-significant level.
The comment suggests conducting survey/analysis of productive capacity for giant garter snake, which is acknowledged. However, the suggestion is a concluding opinion and such study is not necessary or required for the Draft EIR and does not raise new or additional environmental issues concerning the adequacy of the Draft EIR.
Response to Comment 22-47
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The commentor’s assumptions and predictions, as well as calculation by the commentor’s model, suggest that implementation of the project would deny the production of 11,361 birds per year to the State of California. The comment states that such loss would qualify as a significant project impact to birds that has not been quantitatively addressed in the Draft EIR. The commenter’s argument draws conclusions and speculation about the project site from studies (over 75 years old) in the mid-west portion of the United States that have no relation to the project site. The potential for the project site to support 3,564 bird nests per year is unlikely, speculative, and unsupported by substantial evidence. Additionally, the mathematical analysis used by the commenter to extrapolate bird nests and reproductive success for a particular site is misleading and inaccurate. The analysis is based on two studies which have no relation to and are not comparable to the project site. One study (i.e., Young 1948) relies on data from over 75 years ago that was taken from a single park site in Wisconsin, which is substantially different than the project site. The other study (i.e., Yahner 1982) presents data over 40 years old from farmsteads located in Minnesota, with row plantings of trees and shrubs, which is also substantially different habitat/vegetation than the project site. In addition to the location and age of this data, the bird species and associated habitats are different that those on the project site. The commentor’s opinion on future impacts, which is based on an unknown number of bird nests from habitat removal calculated using outdated or inapplicable surveys, is highly speculative and inappropriate. Such speculation is a misrepresentation of the site and is typically not part of an effective project impact analysis under CEQA.
Although nests were observed on-site during the biological surveys conducted by Bargas, the Draft EIR determined that potential impacts to nesting birds if construction were to occur during the nesting season would be reduced to a less-than-significant level with implementation of Mitigation Measures 4.4-9(a) and 4.4-9(b) in Chapter 4.4, Biological Resources, of the Draft EIR, consistent with the MBTA and CFGC.
Response to Comment 22-48
See Response to Comment 22-46. Section 4.7.1 of the BRA prepared for the proposed project (Appendix E of the Draft EIR) discusses habitat fragmentation. As discussed therein, the BRA finds that implementation of the project would not adversely affect wildlife corridors. Based on the biological surveys and setting of the project site, it was determined that the likelihood for quadruped movement to and from the site is low, and the site is not considered a wildlife corridor.
In addition, given the lack of natural habitats present on-site that provide sufficient shelter to support typical wildlife movements or corridors, implementation of the project is not expected to result in habitat fragmentation. The BRA does acknowledge contiguous habitats are present beyond the project site that could provide higher quality resources and serve as wildlife movement corridors. The BRA, as well as the discussion under Impact 4.4-12 in Chapter 4.4, Biological Resources, of the Draft EIR, states that aquatic species on-site could be potentially impacted by project buildout; however, implementation of the proposed mitigation measures would reduce the impact to a less-than-significant level.
Response to Comment 22-49
The commentor’s opinion and prediction that the project would result in over 9,000 road kills per year is highly speculative, misleading, and presents a misrepresentation of the site. The study used by the commentor to predict road kills is from an extremely highly traveled and known dangerous roadway (Vasco Road - Wikipedia), which does not reflect the conditions at the project site. Thus, the magnitude of such an impact is not known and to presume such a significant impact Final EIR
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based on a stretch of road in Contra Costa County is inappropriate, misleading, and not directly relatable to the proposed project. The fatality rates presented by the commenter are neither supportable by professional standards nor supportable by standard CEQA review practices.
Wildlife mortality as a result of collisions with vehicle traffic is a known risk and will not be exacerbated by the project. Given the project is not creating a new arterial roadway and is not anticipated to generate significant traffic impacts, significant wildlife mortality is not expected.
Furthermore, the project would not widen the size of existing off-site roads and new off-site roadways would not be constructed. The project site is not considered a wildlife corridor, and there is little expectation that wildlife is not expected to predominantly cross the roads used by project traffic in the area. Given the nature of the proposed project and the results of the technical reports related to traffic prepared for the proposed project, which determined the project would have minimal contribution to existing roadway volumes, a substantial adverse effect to wildlife species would not occur. Additional analysis of such impacts is not required by standard CEQA review practices for approval of the Draft EIR.
Response to Comment 22-50
See Responses to Comments 13-30, 22-15, and 22-46.
Response to Comment 22-51
See Response to Comment 22-15.
Response to Comment 22-52
The comment does not address the adequacy of the Draft EIR. See the Master Response.
Response to Comment 22-53
The Draft EIR discusses the proposed project’s consistency with the Natomas Basin HCP throughout Chapter 4.4, Biological Resources, of the Draft EIR; the analysis therein is consistent with the requirements of the CEQA Guidelines. The recommendations of the commenter have been noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 22-54
See Response to Comment 22-50. While the development of the proposed project would preclude the use of the project as preserved habitat for the Natomas Basin HCP, as discussed under Response to Comment 13-30, adequate acreage exists elsewhere. In addition, the discussion of the No Project (No Build) Alternative’s impact related to biological resources, as presented beginning on page 7-8 of Chapter 7, Biological Resources, of the Draft EIR, acknowledges that the Alternative would not have any other impacts to such resources, and, by extension, would be beneficial in terms of achieving the goals of the Natomas Basin HCP. Nonetheless, because the Natomas Basin HCP would not receive funds under the No Project (No Build) Alternative, which would hinder the HCP’s ability to operate as compared to operations with the funds generated by the proposed project, the potential impact to the Natomas Basin HCP would be slightly greater under the Alternative.
Response to Comment 22-55
See Response to Comment 22-50. As discussed on page 4.4-82 in Chapter 4.4, Biological Resources, of the Draft EIR, the proposed project’s contribution to the significant cumulative impact would be cumulatively considerable; however, with the implementation of mitigation, the impact would be reduced to a less than cumulatively considerable level. As such, the Draft EIR Final EIR
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adequately addresses such impacts. Furthermore, the Draft EIR adequately addresses the role of the proposed project in meeting the overall goals of the HCP.
Response to Comment 22-56
See Responses to Comments 2-5, 2-17, and 22-47. As discussed in Responses to Comments 2- 5 and 2-17, mitigation measures in Chapter 4.4, Biological Resources, of the Draft EIR have been revised to address potential impacts to special-status species located outside of the Natomas Basin HCP permit area. The commenter falsely mischaracterizes the mitigation measures included in the Draft EIR for biological resources as only requiring preconstruction surveys. For example, subsequent to preconstruction surveys, Mitigation Measure 4.4-1(a) requires transplantation of special-status plant species and/or consultation with USFWS to determine appropriate measures to avoid and minimize loss of individual special-status plant species within the Natomas Basic HCP area, and Mitigation Measure 4.4-1(b) requires the project applicant to consult with the appropriate agency to develop appropriate mitigation for impacts to special-status plant species. Furthermore, contrary to the claim of the commenter, Mitigation Measures 4.4-9(a) and 4.4-9(b) in Chapter 4.4, Biological Resources, of the Draft EIR, establish specific protocols to address potential impacts to nesting songbirds and raptor species protected under the MBTA and CFGC that are discovered on-site during preconstruction surveys, such as delaying construction activities until the young have fledged and establishing appropriate avoidance buffers, consistent with the MBTA and CFGC. Therefore, the claim of the commenter that the Draft EIR does not include adequate mitigation to address potential impacts to special-status species is inaccurate.
Furthermore, contrary to the claim of the commenter, page 4.4-78 of Chapter 4.4, Biological Resources, of the Draft EIR explicitly states the following regarding cumulative impacts:
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.
In addition, as stated on page 4.4-82:
As further discussed in Chapter 6 of this EIR, CEQA Guidelines Section 15064, Subdivision (h)(5) states, “[…]the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.” Therefore, even where cumulative impacts are significant, any level of incremental contribution is not necessarily deemed cumulatively considerable (see also CEQA Guidelines Section 15130). In addition, the courts have explicitly rejected the notion that a finding of significance is required simply because a proposed project would result in a net loss of habitat. “[M]itigation need not account for every square foot of impacted habitat to be adequate. What matters is that the unmitigated impact is no longer significant,” (Save Panoche Valley v. San Benito County [2013] 217 Cal.App.4th 503, 528, quoting Banning Ranch Conservancy v. City of Newport Beach [2012] 211 Cal.App.4th 1209, 1233).
The above discussion provides substantial evidence that, while the combined effects on the habitats of special-status species resulting from approved/planned development Final EIR
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throughout the cumulative setting may be considered significant, the proposed project’s incremental contribution to the potentially significant cumulative effect would be reduced with implementation of the project-specific mitigation measures required in this EIR.
The Draft EIR does not say that mitigation would negate the cumulative impacts of the proposed project, but would rather reduce the significance of such impacts to a less than cumulatively considerable level.
Response to Comment 22-57
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 the case 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 compliance with specific performance standards and regulatory requirements, and also require implementation prior to project activities begin. Therefore, the proposed mitigation is considered adequate.
Response to Comment 22-58
The commenter’s argument draws conclusions and speculation about the project site from studies that have no relation to the project site. The commentor’s opinion on future impacts, which is based on inapplicable surveys, is highly speculative and inappropriate. Such speculation is a misrepresentation of the site and is typically not part of an effective project impact analysis under CEQA.
Response to Comment 22-59
See Responses to Comments 22-56 and 22-57.
Response to Comment 22-60
See Response to Comment 22-56. Contrary to the claim of the commenter, the Draft EIR includes mitigation that requires the direct and indirect preservation of off-site habitat to mitigate for the project. For example, Mitigation Measure 4.4-5(b), as amended under Response to Comment 2- 5, requires either the preservation of Swainson’s hawk foraging habitat at a 1:1 ratio, which would be direct preservation, or the payment of Natomas Basin HCP fees for the preservation of off-site Swainson’s hawk foraging habitat, which would be considered indirect preservation.
Response to Comment 22-61
See Responses to Comments 2-5, 22-46, 22-56, and 22-57. With respect to mitigation for potential impacts to burrowing owl, the proposed project includes Mitigation Measure 4.4-6, which requires implementation of the applicable Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measure, which is the most current and relevant mitigation available. Therefore, reliance on the Natomas Basin HCP is considered adequate mitigation for the impact. With Final EIR
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respect to mitigation for giant garter snake and northwestern pond turtle, the commenter neglects to mention that Mitigation Measure 4.4-3 requires construction activities to halt upon the discovery of such species until they leave the area, as stated on page 4.4-48 of Chapter 4.4, Biological Resources, of the Draft EIR. In addition, Mitigation Measure 4.4-3 requires the determination of escape routes for giant garter snake in advance of construction and snakes should always be allowed to leave on their own.
Potential impacts to monarch butterfly are addressed under Impact 4.4-2 and potential impacts to Aleutian cackling goose, white-faced ibis, and tricolored blackbird are discussed under Impact
4.4-7 in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, the project site contains low or unsuitable habitat for the foregoing species and, thus, the species are unlikely to occur on-site. Therefore, mitigation for the foregoing species is not required.
Response to Comment 22-62
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.
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Chapter 2.0 – Responses to Comments
Letter 23
23-1
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Letter 23 Cont.
23-1
Cont.
23-2
23-3
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Letter 23 Cont.
23-3
Cont.
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Letter 23 Cont.
23-4
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Letter 23 Cont.
23-4
Cont.
23-5
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Letter 23 Cont.
23-5
Cont.
23-6
23-7
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Letter 23 Cont.
23-7
Cont.
23-8
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Letter 23 Cont.
23-8
Cont.
23-9
23-10
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Letter 23 Cont.
23-10
Cont.
23-11
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Letter 23 Cont.
23-11
Cont.
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Letter 23 Cont.
23-11
Cont.
23-12
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Letter 23 Cont.
23-12
Cont.
23-13
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Letter 23 Cont.
23-13
Cont.
23-14
23-15
23-16
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Letter 23 Cont.
23-16
Cont.
23-17
23-18
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Letter 23 Cont.
23-18
Cont.
23-19
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Letter 23 Cont.
23-19
Cont.
23-20
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Letter 23 Cont.
23-20
Cont.
23-21
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Letter 23 Cont.
23-22
Cont.
23-23
23-24
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Letter 23 Cont.
23-24
Cont.
23-25
23-26
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Letter 23 Cont.
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Chapter 2.0 – Responses to Comments
LETTER 23: KEVIN CARMICHAEL, SACRAMENTO RESIDENTS FOR
RESPONSIBLE DEVELOPMENT (ADAMS BROADWELL
JOSEPH AND CARDOZO)
Response to Comment 23-1
The comment provides a description of the proposed project. The comment does not address the adequacy of the Draft EIR.
Response to Comment 23-2
The comment is an expression of dissatisfaction with the analysis of the Draft EIR, the specific criticisms of which are addressed in more detail below.
Response to Comment 23-3
The comment describes the interests of Sacramento Residents for Responsible Development.
The comment does not address the adequacy of the Draft EIR.
Response to Comment 23-4
The comment describes the purpose of CEQA. The comment does not address the adequacy of the Draft EIR.
Response to Comment 23-5
As discussed on page 1-2 of the Draft EIR, because the proposed project would not include 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. With respect to the development of the remainder of the project site, the project applicant has submitted parcelspecific information regarding the proposed development, allowing for a project-level analysis of the potential environmental impacts that would result from such development, pursuant to CEQA Guidelines Section 15161. Therefore, the project description for the proposed project includes all available information and is adequate pursuant to the requirements of CEQA.
Response to Comment 23-6
See Response to Comment 23-5.
Response to Comment 23-7
The trip generation for industrial uses was estimated utilizing an extensive data set of actual trip generation rates for existing warehouse, E-commerce, and manufacturing facilities similar to the project as proposed by the applicant. City staff and the transportation consultant evaluated the data set and determined that it reasonably reflects the foreseeable land uses for the project. The rate was calculated according to methodologies described within the ITE Trip Generation Manual 11th Edition. The calculated industrial trip generation rate was found to be comparable to industrial rates available in the ITE Trip Generation Manual 11th Edition and represented a reasonably foreseeable estimate of project trips.
The commentor also notes that vehicle trips for the Amazon SMF5 facility in Metro Airpark generates a higher rate of trips per 1,000 square feet than is presumed for the project. Unlike the commentor’s Amazon SMF5 example, which represents a single heavy user with a higher than Final EIR
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Chapter 2.0 – Responses to Comments
average trip generation rate, the project’s assumed trip generation rate represents an average of a range of different user types that are reasonably anticipated to occupy the project site.
Based on the above, because the analysis of the Draft EIR is based on accurate trip generation calculations, the analysis of GHG and VMT impacts is also accurate.
Response to Comment 23-8
The trip rate in the transportation analysis prepared for the proposed project, 12,794 trips per day, is based on full buildout of the proposed annexation area and was used for the calculation of operational emissions associated with the Full Buildout of the Annexation Area Scenario. By contrast, the average daily trip rate of 10,093.73 in the air quality modeling for the Proposed Project Scenario applies only to operation of the proposed industrial park, and does not include operation of the nonparticipating parcels. The different trip rates were used to evaluate different buildout scenarios of the proposed project, i.e., full buildout of the annexation area as compared to only buildout of the proposed industrial park. The air quality modeling conducted for the Full Buildout of the Annexation Area Scenario used the 12,794 trips per day daily trip rate.
Because the future tenants of the proposed industrial uses are not currently known, the exact hours of operation of the proposed project have not yet been determined. However, there is nothing in the Draft EIR that would suggest that the proposed project would operate 24 hours per day, 365 days per year; the assumption that such operations would occur is speculative and is not based on any information provided for the project. The assumption of operation for 300 days of the year is based on the reasonable assumption that operations would cease on national holidays and weekends.
Response to Comment 23-9
See Responses to Comments 23-7 and 23-8. Based on the conclusions therein, recirculation of the Draft EIR is not required.
Response to Comment 23-10
The proposed project could include installation of emergency generators; however, the project applicant would be required to obtain a permit from SMAQMD for operation of any such emergency generators. As part of the permitting process, the generators would be regulated and monitored to ensure any associated emissions are under specified limitations. In addition, the generators would be intended to be used only for emergency situations in order to provide continuous power operation during utility power outages. Periodic testing of the generators would also occur throughout the year at limited time intervals. However, the generators would not be used regularly and would be limited to a maximum operation time for maintenance and testing of 100 hours per year, as required by the USEPA. It is noted that the data cited by the commenter stating that approximately 806 Public Safety Power Shutoff (PSPS) events occurred in October 2019 applies to the entire State of California and, thus, is misleading as far as the applicability to the proposed project. Given the number quoted is statewide, the Sacramento area would subject to much fewer PSPS events.
In order to ensure that potential emergency generators on-site would not result in any impacts to nearby sensitive receptors, an HRA was conducted to assess the increase in DPM emissions associated with use of one emergency generator for each proposed building within the proposed industrial park, for a total of five emergency generators on-site, for 100 hours per year (see Final EIR
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Appendix C of this Final EIR). The DPM emissions associated with such emergency generator usage was then combined with the increase in DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site. It is noted that the HRA did not include potential generators associated with future buildout of the nonparticipating parcels because the assumption of the use of generators would be speculative at this time.
As shown in Table 2-1, the increase in DPM emissions associated with use of five emergency generators on-site for 100 hours per year, in combination with DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site would not result in an cancer or non-cancer hazard risks above the SMAQMD thresholds. In reality, the cancer and non-cancer hazard risks shown in Table 2-1 above are likely an overestimate, as it is unlikely that the emergency generators would run for 100 hours each year. Nonetheless, given the above, the conclusions included in the Draft EIR would not change, and additional analysis is not warranted.
Table 2-1
Maximum Cancer Risk and Hazard Index Associated with HeavyDuty Diesel Trucks Cancer Risk
(per million
persons)
Acute Hazard
Index
Chronic
Hazard Index
At Maximally Exposed Receptor 9.75 0.00 0.00
Thresholds of Significance 10 1.0 1.0
Exceed Thresholds? NO NO NO
Sources: EMFAC, AERMOD, and HARP 2 RAST, May 2023/July 2024.
Response to Comment 23-11
See Response to Comment 23-10. The emergency generators associated with the proposed project include those that would potentially be used for cold storage warehouses.
Response to Comment 23-12
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 terms and conditions of the proposed development agreement is not required for purposes of CEQA, and moreover, the final text of the proposed Development Agreement, has not yet been prepared.
Once the terms of the Development Agreement are agreed upon, the City shall review the Development Agreement to ensure that new additional impacts beyond what is considered in the Draft EIR will not occur.
Response to Comment 23-13
See Response to Comment 23-12. Furthermore, the commenter’s claim that mitigation measures outlined in the Draft EIR will cease to be effective with respect to the impacts of the Development Agreement is speculative and is not supported by any evidence.
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Chapter 2.0 – Responses to Comments
Response to Comment 23-14
Pursuant to the CEQA Guidelines, the purpose of the Draft EIR is to evaluate the potential physical environmental impacts of the proposed project. As such, the public benefits of the proposed project are not required to be analyzed as part of the CEQA process. In addition, consideration of the benefits of the proposed project will be addressed in a Statement of Overriding Considerations considered by the Sacramento LAFCo Commission and Sacramento City Council. Furthermore, the Development Agreement will be available for public review prior to Planning Commission and City Council actions.
Response to Comment 23-15
See Response to Comment 23-12.
Response to Comment 23-16
The comment does not provide specifics regarding the asserted inadequacies of the Draft EIR.
See the Master Response.
Response to Comment 23-17
The comment does not address the adequacy of the Draft EIR.
Response to Comment 23-18
See Responses to Comments 23-8 and 23-10.
Response to Comment 23-19
See Response to Comment 16-18. As discussed therein, 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 off-site measures, achieve a 35 percent reduction in ozone precursors generated by mobile sources over the baseline conditions anticipated. The SMAQMD’s intent for the purpose of AQMPs is to, “satisfy the ‘all feasible measures’ mitigation requirements under CEQA for operation impacts.”10 Accordingly, the AQMP prepared for the project represents all quantifiable and feasible mitigation to reduce the project’s operational air quality impact. Additionally, on June 19, 2024, Air District Staff provided a verification letter identifying the adequacy of the AQMP. The verification letter is attached as Appendix A to this Final EIR and hereby added to the record. 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 23-20
See Response to Comment 23-19.
Response to Comment 23-21
See Response to Comment 23-19.
Response to Comment 23-22
See Response to Comment 23-19.
10 Sacramento Metropolitan Air Quality Management District. Model Air Quality Plan “Project X”. September 20, 2007.
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Chapter 2.0 – Responses to Comments
Response to Comment 23-23
See Response to Comment 23-19.
Response to Comment 23-24
Consideration of the benefits of the proposed project that may outweigh the project’s significant and unavoidable impacts will be addressed in a Statement of Overriding Considerations considered by the Sacramento LAFCo and Sacramento City Council.
Response to Comment 23-25
See Response to Comment 23-24. The analysis presented in the Draft EIR with respect to potentially significant impacts, mitigation measures, and alternatives is adequate pursuant to the requirements of the CEQA Guidelines.
Response to Comment 23-26
The comment is a conclusion statement and does not specifically address the adequacy of the Draft EIR. See the Master Response.
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Chapter 2 – Responses to Comments
24-1
Letter 24
24-2
24-3
24-4
24-5
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LETTER 24: JONATHAN BURKE, WESTLAKE MASTER ASSOCIATION
Response to Comment 24-1
The comment is an introduction statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 24-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 24-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Potential impacts to wildlife are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 24-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 24-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It should be noted that the comment is incorrect regarding the conclusions of the Draft EIR. The Draft EIR identifies significant and unavoidable impacts for the following areas only: change in visual character/quality of the site, loss of agriculture, and criteria air pollutant emissions. All other potential impacts, including traffic, noise, air pollutant concentrations, and biological resources (including habitat loss) would be reduced to a less-than-significant level with incorporation of mitigation measures. Furthermore, property value impacts are not a physical impact on the environment required to be analyzed under CEQA.
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Chapter 2.0 – Responses to Comments
Letter 25
25-1
25-2
25-3
25-4
25-5
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Letter 25 Cont.
25-5
Cont.
25-6
25-7
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Letter 25 Cont.
25-7
Cont
25-8
25-9
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Letter 25 Cont.
25-10
25-9
Cont
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LETTER 25: MATTHEW ALDEN
Response to Comment 25-1
Please see the Master Response.
In addition, it should be noted that the Draft EIR does not conclude that the potential impact would result in significant and unavoidable impacts related to light pollution (which is evaluated under Impact 4.1-4, starting on page 4.1-24) or health risks associated with air pollution (which is evaluated under Impact 4.3-3, starting on page 4.3-48). Rather, the Draft EIR concludes under Impact 4.1-3 (see page 4.1-16 of the Draft EIR) that the project would substantially degrade the existing visual character or quality of public views of the site and its surroundings, and concludes under Impact 4.3-2 (see page 4.3-44 of the Draft EIR) that the project would conflict with or obstruct implementation of the applicable air quality plan during project operation, with mitigation unavailable for both impacts to reduce either impact to a less-than-significant level. Due to the project’s significant and unavoidable impacts related to aesthetics and air quality (among others), a statement of overriding considerations has been prepared separately by LAFCo and the City, which will need to be adopted should the project be approved.
Response to Comment 25-2
Please see the Biological Resources chapter of the Draft EIR, which evaluates all potential impacts that could occur to protected plant and wildlife species and their habitat as a result of the proposed project and concludes that with implementation of the mitigation measures set forth therein, all potential impacts would be reduced to a less-than-significant level.
Response to Comment 25-3
Please see the Transportation and Effects Not Found to be Significant chapters of the Draft EIR, which evaluate the project’s potential to result in inadequate emergency access or substantially impair an adopted emergency response plan or emergency evacuation plan. As concluded therein, a less-than-significant impact would occur.
With respect to effects of the proposed project on traffic volumes, as discussed in the Transportation chapter on page 4.12-13, impact significance in the Draft EIR is based upon vehicle miles traveled (VMT), whereas the results of the Traffic Impact Analysis related to level of service (LOS) (i.e., effects of project-generated traffic volumes on roadway segment and intersection operations) will be used by the City, separate from the analysis in the Draft EIR, to address consistency with Sacramento 2040 General Plan goals and policies related to transportation, including adopted LOS policies.
Response to Comment 25-4
The analyses and conclusions in the Biological Resources chapter of the Draft EIR, which includes evaluation of potential impacts to protected wildlife species, clearly identify the regulations with which the proposed project must comply. The Biological Resources chapter also details specific standards in the mitigation measures set forth therein that the project is required to meet, which would ensure potential impacts are reduced to a less-than-significant level. For example, Mitigation Measure 4.4-9(a) necessitates that a preconstruction focused survey for nesting raptors protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) must be conducted by a qualified biologist within seven days prior to construction activities, if ground disturbance or other activities are proposed during the nesting Final EIR
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season. If active raptor nests are found within 0.5-mile of a construction area, Mitigation Measure
4.4-9(a) further requires non-disturbance buffers within 0.5-mile of the nest until a qualified biologist determines that the young have fledged. If an active raptor nest is found within the project area prior to construction and is in a tree that is proposed for removal, the mitigation mandates that the project applicant implement additional mitigation recommended by a qualified biologist based on California Department of Fish and Wildlife (CDFW) guidelines and obtain any required permits from CDFW. Mitigation Measure 4.4-9(b) contains similar requirements for nesting songbirds. Additionally, the Draft EIR requires compliance with the Natomas Basin Habitat Conservation Plan (HCP) for all species covered under the Natomas Basin HCP, including covered avian species.
The commenter also expresses a general opinion that mitigation that requires preservation of similar habitat elsewhere for impacted habitat will not prevent the deaths of protected wildlife, but does not provide specific examples as evidence. Thus, the comment constitutes speculation, which according to CEQA Guidelines Section 15145, is not covered under CEQA. Furthermore, for all potentially significant impacts to protected species and habitat that would occur as a result of the proposed project, the Draft EIR includes mitigation measures, such as the examples explained above, that subject the proposed project to requirements beyond simply preserving habitat elsewhere.
Overall, the analyses and conclusions contained in the Draft EIR on protected wildlife species, including avian species and protected habitat, are adequate.
Response to Comment 25-5
The comment suggests generally that the project will have adverse air quality impacts, but does not specifically address the adequacy of the Draft EIR’s analysis related to air quality. Please see the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR, which evaluates potential increases in emissions as a result of project construction and operation under Impacts
4.3-1 and 4.3-2, respectively.
Similarly, the comment suggests generally that the project will have adverse traffic impacts, but does not specifically address the adequacy of the Draft EIR’s analysis related to transportation hazards. Please see the Transportation chapter of the Draft EIR, which evaluates the project’s potential to substantially increase traffic hazards under Impact 4.12-4.
Response to Comment 25-6
Although the proposed industrial park would include stormwater retention/detention areas, primarily along the western and southern project site boundaries, which could attract avian species and expose them to collisions with aircraft associated with the Sacramento International Airport, the project includes a Wildlife Hazard Management Plan to prevent such aviation hazards from occurring, as required by Mitigation Measure 4.7-5(a) in the Hazards and Hazardous Materials chapter of the Draft EIR. The Wildlife Hazard Management Plan would be prepared by a qualified wildlife hazard damage biologist, subject to review by the Sacramento County Airport System, and include various provisions to reduce bird attractants within the retention/detention areas, such as refuse and birdfeed. As concluded under Impact 4.7-5 on page 4.7-22 of the Draft EIR, through incorporation of the Wildlife Hazard Management Plan, potential airspace safety hazards due to birds would be reduced to a less-than-significant level.
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March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 25-7
The proposed project’s potential to create a new source of substantial light or glare that would adversely affect day or nighttime views in the area is evaluated under Impact 4.1-4, which starts on page 4.1-24 of the Draft EIR. As discussed therein, the project could introduce additional sources of light and glare from the proposed industrial and commercial uses. However, the project would be required to comply with the proposed Planned Unit Development (PUD) Guidelines and Sacramento City Code Chapter 15.148 and Section 17.608.040, which would ensure signs installed as part of the project do not exceed the maximum allowed height, light levels from the proposed structures and signs are zero foot-candles at the property lines of the project site, LED fixtures are faced downward, and exterior lighting for project parking areas is shielded or otherwise designed to avoid spillover onto adjacent roadways and land areas. Because the proposed project would be required to comply with applicable standards and regulations established by the City of Sacramento, including the foregoing provisions detailed above, the Draft EIR concludes that a less-than-significant impact would occur. Thus, the analyses and conclusions in the Draft EIR related to new sources of light and glare are adequate.
Response to Comment 25-8
Please see Response to Comment 25-7.
Response to Comment 25-9
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 25-10
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response. The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
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Chapter 2.0 – Responses to Comments
26-1
Letter 26
Final EIR
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Chapter 2.0 – Responses to Comments
LETTER 26: BHUPINDER BAL
Response to Comment 26-1
As discussed on page 3-7 of the Draft EIR, in accordance with the Cortese-Knox-Hertzberg Local Government Reorganization Act (see Government Code Section 56375), City of Sacramento zoning designations would be applied to the industrial park footprint and nonparticipating parcels through Prezoning. The industrial park portion of the project site would be Prezoned to include 317.9 acres of Industrial PUD (M-1-PUD) zoning and 13.4 acres Highway Commercial PUD (HCPUD) zoning. The nonparticipating parcels would be Prezoned to include 83 acres of Industrial (M-1). Thus, approval of the proposed Prezoning as part of annexation of the project site into the City of Sacramento would render the proposed project consistent with site’s zoning.
Additionally, as discussed under Impact 4.9-3 on page 4.9-25 of the Draft EIR, the project would comply with all requirements in the Sacramento Planning and Development Code including, but not limited to, parking, setbacks (such as those that would pertain to Parcel 5 to ensure adequate distance between the proposed warehouse building and the neighboring residences), and landscaping. As a result, the Draft EIR concludes that the project’s impact related to compliance with the Sacramento Zoning Code would be less than significant.
Based on the above, the analyses and conclusions in the Draft EIR are adequate.
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March 2025
Chapter 2.0 – Responses to Comments
Letter 27
27-1
27-2
27-3
27-4
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LETTER 27: CHRYS BARRANTI AND JOY PIKE
Response to Comment 27-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment will be forwarded to the decision-makers for their consideration.
Response to Comment 27-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment will be forwarded to the decision-makers for their consideration.
Response to Comment 27-3
The comment does not specifically address the adequacy of the Draft EIR’s analysis related to air pollutant emissions, increases in existing ambient noise levels due to project-generated noise, and transportation hazards. Please see the Air Quality, Greenhouse Gas Emissions, and Energy; Noise, and Transportation chapters of the Draft EIR, which evaluate potential impacts related to the foregoing topics. Please also see the Master Response.
Response to Comment 27-4
The comment does not specifically address the adequacy of the Draft EIR. Please see the Master Response, as well as the analysis under Impact 4.9-2, which starts on page 4.9-16 of the Draft EIR and includes an evaluation of the proposed project’s consistency with applicable Sacramento LAFCo policies. The comment will be forwarded to the decision-makers for their consideration.
Final EIR
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March 2025
Chapter 2.0 – Responses to Comments
Letter 28
28-1
28-2
28-3
28-4
Final EIR
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Chapter 2.0 – Responses to Comments
LETTER 28: CHRYS BARRANTI AND JOY PIKE
Response to Comments 28-1 through 28-4
The letter is a duplicate of Letter 27. Please see Responses to Comments 27-1 through 27-4 above.
Final EIR
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Chapter 2.0 – Responses to Comments
Letter 29
29-1
29-2
29-3
29-4
Final EIR
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Chapter 2.0 – Responses to Comments
LETTER 29: CHRYS BARRANTI AND JOY PIKE
Response to Comments 29-1 through 29-4
The letter is a duplicate of Letter 27. Please see Responses to Comments 27-1 through 27-4 above.
Final EIR
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Chapter 2.0 – Responses to Comments
30-1
Letter 30
30-2
30-3
30-4
30-5
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Letter 30
Cont. 30-5
Cont.
30-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 30: ROBERT BURNESS
Response to Comment 30-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 30-2
The comment does not address the adequacy of the Draft EIR.
Response to Comment 30-3
The comment summarizes a portion of the significant and unavoidable impacts identified in the Draft EIR and does not address the adequacy of the Draft EIR.
Response to Comment 30-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Due to the project’s significant and unavoidable impacts, which are identified in various technical chapters of the Draft EIR and summarized in Chapter 5, Statutorily Required Sections, a statement of overriding considerations will be required to be adopted by the LAFCo Commission and the Sacramento City Council should they vote to approve the project.
Response to Comment 30-5
The comment does not specifically address the adequacy of the Draft EIR’s analyses related to conversion of farmland to non-agricultural uses and compliance with the Natomas Basin HCP.
Please see the analyses and conclusions under Impacts 4.2-1 (see page 4.2-16 of the Draft EIR) and Impact 4.4-14 (see page 4.4-70 of the Draft EIR), which evaluate potential impacts related to the foregoing topics, respectively.
Response to Comment 30-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. The comment will be forwarded to the decision-makers for their consideration.
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
31-1
Letter 31
31-2
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Letter 31
Cont.
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Letter 31
Cont.
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Chapter 2.0 – Responses to Comments
Letter 31
Cont.
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Letter 31
Cont.
31-3
31-4
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Letter 31
Cont.
31-4
Cont.
31-5
31-6
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March 2025
Chapter 2.0 – Responses to Comments
Letter 31
Cont.
31-6
Cont.
31-7
31-8
31-9
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Airport South Industrial Project
March 2025
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Letter 31
Cont.
31-10
31-11
31-12
31-13
31-14
31-15
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 31: LEO CHAN
Response to Comment 31-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response. The comment will be forwarded to the decision-makers for their consideration.
Response to Comment 31-2
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
In addition, the excerpts included in the comment are from the Transportation Impact Analysis, attached as Appendix N to the Draft EIR. As discussed in the Transportation chapter on page
4.12-13, impact significance in the Draft EIR is based upon VMT, whereas the results of the Traffic Impact Analysis referenced by the commenter are related to LOS (i.e., effects of projectgenerated traffic volumes on roadway segment and intersection operations) and will be used by the City, separate from the analysis in the Draft EIR, to address consistency with Sacramento 2040 General Plan goals and policies related to transportation, including adopted LOS policies.
Response to Comment 31-3
Please see the Master Response and Response to Comment 31-2.
Response to Comment 31-4
As discussed on page 4.12-11 of the Draft EIR, based on the current practice of the City of Sacramento, transportation impacts are considered significant if the proposed project would result in a VMT per capita or office VMT per employee above 85 percent of the regional average, consistent with technical guidance published by Governor’s Office of Planning and Research (OPR). The OPR guidance does not specify a particular significance threshold for industrial employment and recommends that local jurisdictions determine this threshold based on local conditions. Some jurisdictions in the Sacramento region have determined that the significance threshold for industrial employment is 100 percent of the regional average. The City of Sacramento Transportation Impact Analysis Guidelines do not specify a significance threshold for industrial land uses. Therefore, consistent with a May 21, 2021 memo provided to the City of Sacramento for the Florin Perkins Distribution Center, the significance threshold for industrial employment in the Draft EIR is 100 percent of the regional average.
As further discussed under Impact 4.12-3 on page 4.12-20 of the Draft EIR, a regional baseline (2016) average VMT per employee metric was used to establish the 100 percent of the regional average threshold and determined to be 17.33. Based on the Sacramento Area Council of Governments (SACOG) SACSIM 19 travel demand model, the on-site M-1-PUD uses are anticipated to generate 22.21 VMT per employee, which is 128 percent of the regional average and above the 100 percent significance threshold established for the proposed project. To reduce VMT associated with the proposed project, the Draft EIR requires Mitigation Measure 4.12-3 to ensure implementation of a VMT Reduction Plan. The Draft EIR concludes that Mitigation Measure 4.12-3 would achieve a 22 percent reduction in VMT, and thus, a less-than-significant impact would occur.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
With respect to comment’s assertion that the 128 percent calculation is low and not accurate, please see Responses to Comments 31-5 and 31-6.
Response to Comment 31-5
The comment cites discussion under the Vehicle Miles Traveled Assessment on page 4.12-14 of the Draft EIR and does not specifically address the adequacy of the Draft EIR.
Response to Comment 31-6
The comment refers to page 4 of OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA,1 which contains technical recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures in response Senate Bill (SB) 743, which established VMT as the metric for determining transportation impact significance under CEQA.
An analysis of VMT from heavy truck trips is not required pursuant to SB 743 and the CEQA Guidelines and, thus, was not included in the Draft EIR. Section 1 of SB 743 reads:
“[w]ith the adoption of Chapter 728 of the Statutes of 2008, popularly known as the Sustainable Communities and Climate Protection Act of 2008 [SB 375], the Legislature signaled its commitment to encouraging land use and transportation planning decisions and investments that reduce vehicle miles traveled and contribute to the reductions in greenhouse gas emissions required in the California Global Warming Solutions Act of 2006 [AB 32]”
As demonstrated in the excerpt above, SB 743 directly states that the analysis of VMT is required to achieve the goals established in SB 375, which is based on the greenhouse gas (GHG) emissions goals set forth in Assembly Bill (AB) 32. Section 1(b) of SB 375, enacted in 2008, states that:
“[i]n 2006, the Legislature passed and the Governor signed Assembly Bill 32 (Chapter 488 of the Statutes of 2006; hereafter AB 32), which requires the State of California to reduce its greenhouse gas emissions to 1990 levels no later than 2020. According to the State Air Resources Board, in 1990 greenhouse gas emissions from automobiles and light trucks were 108 million metric tons, but by 2004 these emissions had increased to 135 million metric tons.”
Likewise, Section 1(c) of SB 375 states that:
“[g]reenhouse gas emissions from automobiles and light trucks can be substantially reduced by new vehicle technology and by the increased use of low carbon fuel. However, even taking these measures into account, it will be necessary to achieve significant additional greenhouse gas reductions from changed land use patterns and improved transportation. Without improved land use and transportation policy, California will not be able to achieve the goals of AB 32.”
As such, SB 375 was focused on reducing GHG emissions through changing land use patterns and transportation policy in a way that reduces automobile and light truck use, rather than by reducing the use of heavy trucks for the movement of goods. Based on the above, the legislative 1 Governor’s Office of Planning and Research. Technical Advisory: On Evaluation Transportation Impacts in CEQA.
December 2018.
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
intent of SB 743 and the associated CEQA Guidelines Section 15064.3 is to ensure that lead agencies analyze VMT for passenger car and light truck trips related to land use projects. CEQA Guidelines Section 15064.3 does not specifically state what type of vehicles are to be included or excluded from the VMT analysis, and merely states “[f]or the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project[,]” (14 CCR Section 15064.3[a]).
On the question of what types of vehicles are to be included in the VMT analysis, OPR stated in its 2018 technical advisory that:
“[p]roposed Section 15064.3, subdivision (a), states, ‘For the purposes of this section, “vehicle miles traveled” refers to the amount and distance of automobile travel attributable to a project.’ Here, the term ‘automobile’ refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for example, where models or data provide combined auto and heavy truck VMT).”
Accordingly, OPR advises that the term “automobile” was not meant to include heavy trucks, but lead agencies could include heavy trucks where doing so was convenient under the applicable traffic model.
Overall, SB 743 and the associated CEQA Guidelines Section 15064.3 were established in order to reduce statewide GHG emissions, and do not require an analysis of VMT related to heavy truck use for the movement of goods. The City of Sacramento has not yet adopted transportation analysis guidelines for heavy trucks, but other jurisdictions in the State have supported the exclusion of heavy truck trips from VMT analysis. As such, the Draft EIR does not include heavy truck trips in the VMT analysis.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration. Importantly, non-transportation effects of heavy truck VMT are evaluated where appropriate in the Draft EIR, such as air quality and GHG emissions.
Response to Comment 31-7
Please see Response to Comment 31-6.
Response to Comment 31-8
Please see Response to Comment 31-6.
Response to Comment 31-9
Please see Response to Comment 31-6.
Response to Comment 31-10
Please see Response to Comment 31-6.
Response to Comment 31-11
Please see Response to Comment 31-6.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Response to Comment 31-12
Please see the Master Response.
Response to Comment 31-13
Please see Response to Comment 31-6.
Response to Comment 31-14
Please see Response to Comment 31-4 and 31-6.
Response to Comment 31-15
The comment is a closing 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 32
32-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 32: PAMELA DAVIS
Response to Comment 32-1
Cumulative impacts of the proposed project are summarized in the Statutorily Required Sections chapter of the Draft EIR. Regarding the commenter’s opposition to the proposed project, please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 33
33-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 33: PAMELA DAVIS
Response to Comment 33-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
34-1
Letter 34
34-2
34-3
34-4
34-5
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March 2025
Chapter 2.0 – Responses to Comments
34-5 Letter 34 Cont.
Cont.
34-6
34-7
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Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 34: JACQELYN DONAHUE
Response to Comment 34-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 34-2
As discussed on page 3-9 of the Draft EIR, the proposed project would include abandonment of the existing South Bayou Way within the project site boundaries and replacement with a new internal roadway system. Concurrent with abandonment, an access easement would be dedicated over the eastern segment of South Bayou Way (from a proposed cul-de-sac to the new round-a-bout) to serve future industrial Parcels 9 through 11 and the California Department of Transportation (Caltrans) Remnant right-of-way (ROW).
In order to guide truck traffic directly to Interstate 5 (I-5) and limit traffic impacts to Bayou Way east of the project site (referred to as “El Centro” in the comment), the project would be served by a new internal roadway system including Airport South Industrial Drive, a modified two-lane Local Industrial roadway with a 75-foot-wide ROW, that would bisect the property west to east by connecting Power Line Road to a future street (labeled “A” Drive in Figure 3-3 in the Project Description chapter of the Draft EIR) that would run north along the site’s eastern border and connect to a proposed round-a-bout where Bayou Way meets the project site.
It is anticipated that the round-a-bout will have signage and be configured to prohibit off-site truck traffic from the project site, east and south along Bayou Way/El Centro Road to Del Paso Road.
Metro Air Parkway, a modified four-lane Local Industrial roadway with a 97-foot-wide ROW, would be extended south from the existing I-5 interchange to the proposed Airport South Industrial Drive, providing a direct connection for trucks.
Response to Comment 34-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 34-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 34-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 34-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
In addition, please see the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy; Biological Resources; Noise; and Transportation chapters of the Draft EIR.
Response to Comment 34-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 35
35-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 35: LYNN DUARTE
Response to Comment 35-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy; Biological Resources; Noise; and Transportation chapters of the Draft EIR.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 36
36-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 36: LYNN DUARTE
Response to Comment 36-1
The letter is a duplicate of Letter 35. Please see Response to Comment 35-1 above.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 37
37-1
37-2
37-3
37-4
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 37: MEGAN ELSEA
Response to Comment 37-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 37-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Please see the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy; Hydrology and Water Quality; and Transportation chapters of the Draft EIR.
Response to Comment 37-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 37-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
Letter 38
38-1
38-2
38-3
38-4
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March 2025
Chapter 2.0 – Responses to Comments
Letter 38 Cont.
38-4
Cont
38-5
38-6
38-7
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 38: CORINNE GARTNER
Response to Comment 38-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analysis related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use under Impact 4.2-1, which starts on page 4.2-16 of the Draft EIR.
Response to Comment 38-2
With respect to potential impacts to protected farmland, the relevant threshold is whether the proposed project would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. Thus, whether or not a portion of the site is actively being farmed, while noteworthy, is not the determiner of significance.
As discussed under Impact 4.2-1, which starts on page 4.2-16 of the Draft EIR, the portions of the site that qualify as Important Farmland (i.e., Prime Farmland, Unique Farmland, or Farmland of Statewide Importance) are generally located in the northeastern corner of the project site, within the portion of the site planned for development of the industrial park. Because construction activities associated with the proposed project would result in conversion of approximately 31.3 acres of Prime Farmland and approximately 12.1 acres of Farmland of Statewide Importance, the Draft EIR requires Mitigation Measure 4.2-1, but concludes that even with implementation of mitigation, the impact would remain significant and unavoidable. Thus, the analyses and conclusions in the Draft EIR are adequate.
Furthermore, as discussed on page 1-6 of the Draft EIR, CEQA Guidelines Section 15126.2(a) states in pertinent part:
An EIR shall identify and focus on the significant environmental effects of the proposed project. In assessing the impact of a proposed project on the environment, the Lead Agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the time environmental analysis is commenced.
The baseline condition for the Draft EIR is the physical condition that existed when the Notice of Preparation (NOP) was published. The NOP for the proposed project was published on March 4, 2022. Therefore, conditions existing at that time are the baseline against which changes that would result from the proposed project are evaluated in the Draft EIR. According to the Phase I Environmental Site Assessment prepared for the proposed project (attached as Appendix H to the Draft EIR), which included a reconnaissance of the project site, the site was “vacant, fallow agricultural land” at the time of the site reconnaissance, which was completed on September 2, 2022. If true that farming activities have resumed within Parcel 5 since the NOP was published, the analysis and conclusions presented within the Draft EIR remain applicable.
Response to Comment 38-3
The commenter expresses the opinion that the Draft EIR minimizes the deaths per year that could occur due to the project’s emissions of particulate matter 2.5 micrometers in diameter (PM2.5) and ozone, but does not provide specific evidence supporting this assertion, which would allow for a detailed response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
As presented under Impact 4.3.3, which starts on page 4.3-48 of the Draft EIR, the Sacramento Metropolitan Air Quality Management District (SMAQMD) has prepared two tools that are intended for use in analyzing health risks from criteria pollutants. Considering the proposed project would result in overall emissions which exceed the SMAQMD’s thresholds of significance, the Draft EIR uses the Strategic Area Project Health Screening Tool, which is meant for larger projects with emissions between two and six times greater than SMAQMD’s adopted thresholds.
Table 4.3-12 of the Draft EIR (see page 4.3-55) presents the health risks associated with operational criteria pollutant emissions resulting from implementation of the proposed project, including future development of the non-participating parcels. As alluded to by the commenter, the maximum number of emissions that can be input into the Strategic Area Project Health Screening Tool for all criteria pollutants is 656 pounds per day (lbs/day). Because operation of the proposed project under the Full Buildout of the Annexation Area Scenario would result in 738.56 lbs/day of NOX emissions, the Draft EIR discloses that the proposed project’s actual unmitigated health impacts associated with criteria pollutant emissions would be slightly higher than what is presented in Table 4.3-12. Thus, the Draft EIR does not grossly minimize the health risks associated with the proposed project. Furthermore, with implementation of Mitigation Measure 4.3-2, the proposed project’s operational emissions and associated criteria pollutant health impacts would be reduced as compared to what is presented in Table 4.3-12. Finally, the Draft EIR concludes that future development of Parcel 8 could expose sensitive receptors to excess concentrations of diesel PM (DPM), and as a result, requires Mitigation Measure 4.3-3.
With implementation of Mitigation Measure 4.3-3, which requires completion of 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.
Response to Comment 38-4
The Draft EIR focuses on air quality impacts on the nearest sensitive receptors, including the Paso Verde K-8 School, which, given its adjacent location to the project site, is substantially nearer to the project site than the Natomas Pacific Pathways Prep (NP3) School. Such an approach provides a more conservative emissions concentration estimate from which a determination of potential environmental impacts is derived. Therefore, all sensitive receptors further away would experience a lower concentration of emissions than the adjacent sensitive receptors.
Response to Comment 38-5
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 particular residences are not required to be evaluated under CEQA. Nonetheless, the concerns expressed by the commenter shall be forwarded to the decision-makers for their consideration.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
With respect to effects of the proposed project on property values, please see the Master Response.
Response to Comment 38-6
As discussed under Impact 4.10-2, which starts on page 4.10-16 of the Draft EIR, operational noise associated with the industrial park is anticipated to range from 40 to 48 dBA L50, which would comply with the City’s noise level standards. In addition, operational noise associated with the restaurant buildings and fueling station/carwash in the proposed Highway Commercial PUD (HCPUD) zones is not anticipated to result in substantial increases to the existing ambient noise levels at existing receptors in the project vicinity, given the distance from the Paso Verde K-8 School (nearest receptor) to the closest boundary of a HC-PUD zone (3,500 feet). Furthermore, noise from on-site HC-PUD uses would be shielded by the proposed Parcel 3, Parcel 4, and Parcel 5 warehouse buildings, further attenuating HC-PUD noise at existing sensitive receptors.
However, because full buildout of the annexation area would exceed the City’s nighttime 50 dBA L50 noise level standard at various locations along the eastern boundary (as shown in Figure 4.10- 5 of the Draft EIR, and includes only those residences located along the southerly half of the site’s eastern boundary), Mitigation Measure 4.10-2 requires installation of an eight-foot-tall sound wall to reduce noise levels to a state of compliance at the residences located along the southerly half of the site’s eastern boundary. Because noise levels would not exceed the standards of significance elsewhere along the site’s eastern boundary, the proposed sound wall does not need to be extended beyond the proposed footprint.
Response to Comment 38-7
As discussed on page 7-1 of the Draft EIR, CEQA Guidelines Section 15126.6(a) provides that the primary intent of the alternatives evaluation in an EIR is to “[…] describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” An EIR must include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. The alternatives analysis is not required to consider every project alternative but is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice (see CEQA Guidelines Section 15126.6[a]).
As discussed on page 7-15 of the Draft EIR, in comparison to the proposed project, the Reduced Footprint Alternative would result in a reduction of 419,809.4 sf of industrial buildings and would preserve approximately 51.3 acres of agricultural land and 18 acres of other land, including the wetlands contained within Parcels 10 and 11, for a total of 69.3 acres of preserved land. Given the substantial reduction in building sf relative to that which would be developed as part of the proposed project, the Reduced Footprint Alternative would substantially result in less effects on the environment than the proposed project. In addition, because the Reduced Footprint Alternative would include development of the project site with the proposed uses for the majority of the parcels, the project objectives would be met. Thus, the Reduced Footprint Alternative allows for meaningful evaluation, analysis, and comparison with the proposed project, and is, thus, adequate and consistent with CEQA Guidelines Section 15126.6(a).
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
The commenter’s request to modify the Reduced Footprint Alternative (should the City of Sacramento choose to pursue the alternative rather than the proposed project) to preserve Parcel 5 as agricultural land 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
Letter 39
39-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2.0 – Responses to Comments
LETTER 39: DAVID GRANDSTAFF
Response to Comment 39-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
40-1
Letter 40
40-2
40-3
40-4
40-5
40-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 40: PAMELA HARDER
Response to Comment 40-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 40-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 40-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 40-4
As discussed under Impact 4.4-14, which starts on page 4.4-70 of the Draft EIR, the Natomas Basin HCP’s Operating Conservation Plan (OCP) is based upon the City limiting total development to 8,050 acres within the City’s portion of the HCP permit area. Approval by the City of future urban development beyond the 8,050 acres would trigger a re-evaluation of the Natomas Basin HCP, a new effects analysis, potential amendments and/or revisions to the Natomas Basin HCP and incidental take permits, a separate conservation strategy, and the need for the City to obtain a new incidental take coverage for that additional development. The City’s annual reports have shown surplus acreage available within the 8,050 acres of development allowed under the City’s incidental take permit. 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.
Response to Comment 40-5
As discussed under Impact 4.9-3 on page 4.9-25 of the Draft EIR, the project would comply with all requirements in the Sacramento Planning and Development Code including, but not limited to, parking, setbacks (such as those that would pertain to the proposed structures to ensure adequate distance between the new warehouse buildings and the neighboring residences and Paso Verde K-8 School), and landscaping. As a result, the Draft EIR concludes that the project’s impact related to compliance with the Sacramento Zoning Code would be less than significant.
Response to Comment 40-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
41-1
Letter 41
41-2
41-3
Final EIR
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March 2025
Chapter 2 – Responses to Comments
41-3
Cont.
41-4
Final EIR
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March 2025
Chapter 2 – Responses to Comments
LETTER 41: JARED HARRIS
Response to Comment 41-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 41-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 41-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on the regional roadway network are addressed in Chapter
4.12, Transportation, of the Draft EIR.
Response to Comment 41-4
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
42-1
Letter 42
42-2
42-3
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 42: LINN HOM
Response to Comment 42-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 42-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 42-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
43-1
Letter 43
43-2
43-3
43-4
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 43: KAREN JACQUES
Response to Comment 43-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 43-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 43-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on the regional roadway network, including VMT, are addressed in Chapter 4.12, Transportation, of the Draft EIR.
Response to Comment 43-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
44-1
Letter 44
44-2
44-3
44-4
44-6
44-5
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
44-6,
cont.
44-7
44-8
44-9
44-10
44-11
44-12
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 44: KAREN JACQUES
Response to Comment 44-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 44-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on farmland, special-status wildlife species and their habitats, greenhouse gas (GHG) emissions and particulate matter emissions, and flooding on- and off-site are addressed in Chapters 4.2, Agricultural Resources, 4.4, Biological Resources, 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, and 4.8, Hydrology and Water Quality, of the Draft EIR.
Response to Comment 44-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The regional context for each environmental issue area is explained in each chapter of the Draft EIR. For example, the project’s consistency with the applicable General Plan policies is addressed in Chapter 4.9, Land Use and Planning/Population and Housing within Table 4.9-7. It should be noted that policy compliance is often a matter of interpretation. The policy evaluation within the Draft EIR should be viewed as preliminary, with the ultimate decision to be made by the appropriate appointed and elected officials.
The project’s consistency with the City’s Climate Action and Adaptation Plan (CAAP) and SMAQMD goals are addressed under Impacts 4.3-1 and 4.3-2 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. Similarly, the project’s relationship to the Natomas Basin HCP is evaluated under Impact 4.4-14 in Chapter 4.4, Biological Resources, of the Draft EIR. Finally, the project’s potential effect on VMT is evaluated under Impact 4.12-3 in Chapter 4.12, Transportation, of the Draft EIR.
Response to Comment 44-4
The comment serves as an introduction to more detailed comments on the Draft EIR and does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 44-5
The comment does not identify a specific asserted inadequacy of the Draft EIR. As discussed on page 4.1-1 in Chapter 4.1, Aesthetics, of the Draft EIR, with respect to aesthetic impacts, consistent with the CEQA Guidelines, the analysis of the Draft EIR is focused on 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 is not required to be evaluated under CEQA. However, as noted by the commenter, the Draft EIR does conclude that the proposed project would result in a significant and unavoidable impact related to degradation of the character and quality of public views of the site.
Response to Comment 44-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
However, the potential effects of the project on farmland and flooding on- and off-site are Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
addressed in Chapters 4.2, Agricultural Resources, and 4.8, Hydrology and Water Quality, of the Draft EIR.
Response to Comment 44-7
As discussed under Impact 4.3-3 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, construction and operation of the proposed project would result in pollutant concentrations and associated health risks below the SMAQMD thresholds of significance; impacts related to such were determined to be less than significant with implementation of mitigation. Therefore, as demonstrated by the Draft EIR, the proposed project would not expose sensitive sites in the project vicinity, such as the nearby school, to substantial concentrations of harmful emissions.
Response to Comment 44-8
As discussed throughout Chapter 4.4, Biological Resources, of the Draft EIR, potential impacts to special-status species would be mitigated to a less-than-significant level through compliance with Natomas Basin HCP requirements and implementation of the required measures for avoidance and/or relocation of special-status species, as well as off-site compensation, when appropriate. As demonstrated therein, potential impacts to special-status species and habitat have been addressed and mitigated.
Response to Comment 44-9
As discussed under Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, Mitigation Measure 4.7-5 requires the proposed project to comply with the recommendations of the Airport Land Use Commission (ALUC) regarding wildlife hazards to aviation. Pursuant to the CEQA Guidelines, the mitigation has been determined to be sufficient to reduce potential impacts related to hazardous wildlife attractants to a less-than-significant level. Therefore, the Draft EIR’s analysis of the impact is considered to be adequate.
Response to Comment 44-10
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
However, the potential effects of the project related to flooding on- and off-site is addressed in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR.
Response to Comment 44-11
Please see the Master Response. The project’s consistency with the applicable General Plan policies is addressed in Chapter 4.9, Land Use and Planning/Population and Housing within Table
4.9-7. It should be noted that policy compliance is often a matter of interpretation. The policy evaluation within the Draft EIR should be viewed as preliminary, with the ultimate decision to be made by the appropriate appointed and elected officials. It is noted that potential environmental impacts associated with the proposed project related to flood risks are addressed in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR, and potential environmental impacts related to special-status species and compliance with the Natomas Basin HCP are addressed in Chapter
4.4, Biological Resources, of the Draft EIR. With respect to carbon sequestration, see Response to Comment 13-42.
Response to Comment 44-12
The project’s potential effects on VMT are evaluated under Impact 4.12-3 in Chapter 4.12, Transportation, of the Draft EIR. As discussed therein, heavy-duty truck and delivery vehicle VMT, Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
as well as alternative mode VMT, are not considered in the VMT analysis, consistent with the Governor’s Office of Planning and Research (OPR) guidelines. Because the VMT analysis in the Draft EIR was conducted consistent with the applicable requirements, the analysis is considered to be adequate under the CEQA Guidelines.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
45-1
45-2
Letter 45
45-3
45-4
45-5
45-6
45-7
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
45-7,
cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 45: ALAN JANG
Response to Comment 45-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 45-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on open spaces, including a discussion on the proposed project’s relationship to the Natomas Basin HCP and farmland are addressed in Chapter 4.4, Biological Resources, and Chapter 4.2, Agricultural Resources of the Draft EIR, respectively.
Response to Comment 45-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The project’s potential impacts related to traffic are evaluated in Chapter 4.12, Transportation, of the Draft EIR, and potential impacts related to pollution are addressed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR.
Response to Comment 45-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 45-5
See Response to Comment 45-2 above.
Response to Comment 45-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Alternatives to the proposed project, including off-site alternatives, are addressed in Chapter 7, Alternatives Analysis, of the Draft EIR. As discussed, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible for the reasons detailed therein.
Response to Comment 45-7
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
46-1
46-2
Letter 45
46-3
46-4
46-5
46-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
46-6,
cont.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 46: ALEX JANG
Response to Comment 46-1
See Response to Comment 45-2.
Response to Comment 46-2
See Response to Comment 45-3.
Response to Comment 46-3
See Response to Comment 45-4.
Response to Comment 46-4
See Response to Comment 45-2.
Response to Comment 46-5
See Response to Comment 45-6.
Response to Comment 46-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
47-1
Letter 47
47-2
47-3
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 47: NANCY KAPELLAS
Response to Comment 47-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 47-2
The comment does not specifically address the adequacy of the Draft EIR. As discussed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible.
Response to Comment 47-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
48-1
Letter 48
48-2
48-3
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 48 Cont.
48-3 Cont.
48-4
48-5
48-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 48: LYNN LENZI
Response to Comment 48-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 48-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 48-3
The comment reiterates the findings of the Draft EIR and does not address the adequacy of the Draft EIR analysis.
Response to Comment 48-4
The comment does not specifically address the adequacy of the Draft EIR. The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR. In addition, the commenter is referred to Mitigation Measure 4.2-1, which lists specific properties as potential off-site mitigation sites as well as the criteria for any potential non-listed properties. As listed in the mitigation measure, the City is responsible for ensuring that any mitigation properties meet the requisite criteria.
Response to Comment 48-5
The comment does not specifically address the adequacy of the Draft EIR. As discussed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible.
Response to Comment 48-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
49-1
Letter 49
49-2
49-3
49-4
49-5
49-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 49: ARCHANA MANIAR
Response to Comment 49-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 49-2
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR. As discussed under Impact 4.4-12 therein, the overall project site largely does not function as a wildlife corridor to terrestrial wildlife, as the site is bounded by physical barriers (i.e., roads, urban development, agricultural fields). The Draft EIR determined that implementation of mitigation would sufficiently reduce potential impacts related to fragmenting habitat to a less-than-significant level. In addition, as discussed under Impact 4.4-14, a portion of the project site is within the Natomas Basin HCP permit area, which includes portions of both the proposed industrial park and the nonparticipating parcels. The project site is not considered to be protected habitat in the sense that development is forbidden; rather, development is permitted given compliance with all applicable Natomas Basin HCP requirements. Therefore, all development facilitated by the proposed project is subject to the applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to address direct impacts to Covered Species that could occur as a result of project construction activities.
The proposal for development first comes from the landowner through an application to the City and LAFCo. The City and LAFCo are required by State law to give due process to any application for private development.
Response to Comment 49-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It is noted that cumulative impacts of the proposed project related to visual quality are addressed under Impact 4.1-5 in Chapter 4.1, Aesthetics, of the Draft EIR. In addition, it is noted that potential economic impacts of the proposed project, such as effects on property values in the area, are not required to be addressed under CEQA.
Response to Comment 49-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Potential impacts related to air quality are addressed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, and potential impacts related to traffic are addressed in Chapter 4.12, Transportation. The Draft EIR addressed potential health risk impacts associated with air quality on the adjacent neighborhood and school. The health risk assessment concluded that the proposed project would have a less-than-significant impact on the surrounding sensitive receptors. It should be noted that the proposed project would abandon Bayou Way and truck access routes would require truck circulation to use Metro Air Parkway.
Response to Comment 49-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The Draft EIR was prepared in compliance with all applicable provisions of CEQA related to the required review period.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Response to Comment 49-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It is noted that strip of land between the project boundaries and the development to the east is owned by the City and not a part of the proposed project. The comment 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 – Responses to Comments
Letter 50
50-2
50-1
50-3
50-4
50-5
50-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 50: MARGARET MCCARTHY
Response to Comment 50-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 50-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on land use and planning, including population growth and the construction of housing, are addressed in Chapter 4.9, Land Use and Planning, of the Draft EIR.
Response to Comment 50-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 50-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 50-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 50-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 51
51-2
51-1
51-3
51-4
51-5
51-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 51: MARGARET MCCARTHY
Response to Comment 51-1 through 51-6
The letter is a duplicate of Letter 50. Please see Responses to Comments 50-1 through 50-6.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 52
52-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 52: SANJAY MENGI
Response to Comment 52-1
Please see the Master Response. In addition, it should be noted that potential conflicts with the City’s zoning ordinance are discussed in Impact 4.9-2 of the Draft EIR. As discussed therein, based on the existing Sacramento County General Plan zoning designations for the project site, residential development was not anticipated at the project site. As discussed further in Table 4.9- 7, the proposed project would be consistent with the City of Sacramento 2040 General Plan and Planning and Development Code. Therefore, the proposed project would not cause a significant environmental impact due to a conflict with applicable zoning standards.
It should be noted that policy compliance is often a matter of interpretation. The policy evaluation within the Draft EIR should be viewed as preliminary, with the ultimate decision to be made by the appropriate appointed and elected officials.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 53
53-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 53: NONA MOUNIR
Response to Comment 53-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 54
54-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 54: PAM O’DELL
Response to Comment 54-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 55
55-1
55-2
55-3
55-4
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
55-5
55-6
55-7
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
55-8
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
55-9
55-10
55-11
55-13
55-12
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
55-13,
cont.
55-14
55-15
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
55-16
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 55: KAREN O’HAIRE
Response to Comment 55-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 55-2
The comment does not address the adequacy of the Draft EIR. 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. However, the project’s potential effects to land use and planning issues are addressed in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR.
Response to Comment 55-3
The comment serves as an introduction to more detailed comments on the Draft EIR to follow.
Please see the responses below to the detailed comments. It should be noted that the comment does misrepresent the significant impacts identified by the Draft EIR. The commenter is referred to Chapter 6, Statutorily Required Sections, wherein the significant and unavoidable impacts of the proposed project are summarized. The significant impacts include impacts related to aesthetics, loss of agricultural land, and operational emissions of criteria air pollutants. All other potential impacts are reduced to a less-than-significant level with inclusion of mitigation measures.
Response to Comment 55-4
The comment reiterates conclusions of the Draft EIR and does not address the adequacy of the Draft EIR analysis. Please see the Master Response.
Response to Comment 55-5
The project’s potential effects to land use and planning issues are addressed in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR. 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 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 residential 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. In addition, it is noted that economic and social impacts of the proposed project, such as home values, are not required to be analyzed under CEQA.
Response to Comment 55-6
As discussed under Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, Mitigation Measure 4.7-5 requires the proposed project to comply with the recommendations of the ALUC regarding wildlife hazards to aviation. The mitigation has been determined to be sufficient to reduce potential impacts related to hazardous wildlife attractants to a less-thansignificant level. Therefore, the Draft EIR’s analysis of the impact is considered to be adequate.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Response to Comment 55-7
Potential impacts related to operational noise associated with the proposed project are addressed under Impact 4.10-2 in Chapter 4.10, Noise, of the Draft EIR. The analysis therein evaluates all operational noise generated by the proposed project and concludes that implementation of mitigation would reduce the potential impact to a less-than-significant level. In addition, any noise generating strategies that may be implemented as an avian deterrent associated with Mitigation Measure 4.7-5(a) would be subject to the City’s noise ordinance, which ensures that any operation that exceeds the City’s standards would be prohibited. As such, the analysis included in the Draft EIR is considered to be adequate.
Response to Comment 55-8
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The proposed project’s consistency with the Natomas Basin HCP is addressed under Impact 4.4- 14 in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 55-9
See Response to Comment 55-1 above.
Response to Comment 55-10
See Response to Comment 55-2 above.
Response to Comment 55-11
See Response to Comment 55-3 above.
Response to Comment 55-12
See Response to Comment 55-4 above.
Response to Comment 55-13
See Response to Comment 55-5 above.
Response to Comment 55-14
See Response to Comment 55-6 above.
Response to Comment 55-15
See Response to Comment 55-7 above.
Response to Comment 55-16
See Response to Comment 55-8 above.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Letter 56
56-2
56-1
56-3
56-4
56-5
56-6
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 56: CHRIS PAROS
Response to Comment 56-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 56-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
As discussed therein, the scope of an EIR is limited to an evaluation of potentially significant environmental impacts of a project, which are, by definition, limited to physical conditions. The determination that the proposed project is consistent or inconsistent with LAFCo policies is ultimately the decision of the LAFCo Commission.
Response to Comment 56-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on the existing utility infrastructure in the vicinity are addressed in Chapter 4.11, Public Services and Utilities, of the Draft EIR. As discussed therein, the proposed project would not require or result in the relocation or construction of new or expanded water or wastewater facilities, the construction or relocation of which could cause significant environmental effects. It should be noted that economic factors, such as financial cost, is not considered a physical effect to be considered under CEQA.
Response to Comment 56-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Nonetheless, it is noted that, as discussed on page 1-2 in Chapter 1, Introduction, of the Draft EIR, because the proposed project would not include 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. As such, potential impacts related to future development of the nonparticipating parcels have been adequately addressed pursuant to the CEQA Guidelines.
Response to Comment 56-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The proposed project’s consistency with the Natomas Basin HCP is addressed under Impact 4.4- 14 in Chapter 4.4, Biological Resources, of the Draft EIR. In addition, potential impacts related to GHG emissions are discussed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy of the Draft EIR, including consistency with the City’s Climate Action & Adaptation Plan.
Response to Comment 56-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
57-1
57-2
57-3
57-4
57-5
57-6
57-7
57-8
57-9
57-10
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
57-10,
cont.
57-11
57-12
57-13
57-14
57-17
57-19
57-20
57-21
57-16
57-15
57-22
57-23
57-24
57-25
57-26
57-18
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
57-27
57-28
57-29
57-30
57-31
57-32
57-33
57-34
57-35
57-36
57-37
57-38
57-39
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 57: CHRIS PAROS
Response to Comment 57-1
The comment is introductory and does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 57-2
The comment alludes to the conclusion under Impact 4.3-2, but does not specifically address the adequacy of the analysis contained therein. It should be noted that the comment mistakenly cites the Draft EIR as concluding that the proposed project would result in a significant and unavoidable impact related to GHG emissions. To the contrary, the Draft EIR evaluates the proposed project’s potential to result in the generation of GHG emissions that may have a significant impact on the environment or conflict with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs under Impact 4.3-7, which begins on page 4.3-63.
As detailed therein, with implementation of Mitigation Measures 4.3-7(a) through 4.3-7(d), the project would result in a less-than-significant impact.
Response to Comment 57-3
Regarding the comment’s allusion to Mitigation Measures 4.3-7(a) and 4.3-7(b), which are set forth on pages 4.3-72 to 4.3-75 of the Draft EIR, the purchase of carbon credits are a strategy recommended by SMAQMD for the purposes of mitigating GHG emissions that would occur above applicable thresholds as a result of new development. According to Chapter 4 of the SMAQMD Guide to Air Quality Assessment in Sacramento County, facilities may purchase emission-reduction credits to offset emissions. Therefore, the provisions of Mitigation Measures
4.3-7(a) and 4.3-7(b), which allow the project applicant to purchase off-site carbon credits to make up the difference in GHG emissions that remain above the applicable threshold following implementation of the quantified reduction measures set forth therein, are adequate.
Response to Comment 57-4
See Response to Comment 19-19.
Response to Comment 57-5
The comment reiterates the conclusions of the Draft EIR and does not address the adequacy of the Draft EIR.
Response to Comment 57-6
The comment does not address the adequacy of the Draft EIR. 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.
Response to Comment 57-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It should be noted that “leapfrog” development would entail a development far removed from the City’s boundaries. The proposed project is adjacent to the existing City Limits and would technically not be considered “leapfrog” development. In addition, the project’s potential effects to land use and planning issues are addressed in Chapter 4.9, Land Use and Planning/Population and Housing, of the Draft EIR.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Response to Comment 57-8
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Alternatives to the proposed project, including off-site alternatives, are addressed in Chapter 7, Alternatives Analysis, of the Draft EIR. As discussed therein, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible. For example, in order for an off-site alternative consisting of multiple sites to be feasible, the project applicant would need to own all of the sites being evaluated; that is not the case with the currently proposed project.
Response to Comment 57-9
As discussed on page 7-20 in Chapter 7, Alternatives Analysis, of the Draft EIR, Section 15126(e)(2) of the CEQA Guidelines requires that an environmentally superior alternative be designated and states, “If the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” Therefore, the Draft EIR identifies the Reduced Footprint Alternative as the Environmentally Superior Alternative.
Response to Comment 57-10
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Pursuant to the CEQA Guidelines, 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. Therefore, the Draft EIR is not required to analyze potential social and economic impacts of the proposed project.
Response to Comment 57-11
Chapter 2, Executive Summary, states on page 2-1 that the project site is located outside of the City of Sacramento SOI and goes on to state that the project requires LAFCo approval of a Sphere of Influence (SOI) Amendment on page 2-2.
Response to Comment 57-12
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Nonetheless, pursuant to the City Code, the purpose of the M-1 zone is to permit the manufacture or treatment of goods, with a variety of permitted uses, including the proposed industrial uses.
Furthermore, the Draft EIR adequately addresses the proposed use as well as the potential uses at the non-participating properties, as required under CEQA.
Response to Comment 57-13
The responsible parties for implementation of and monitoring compliance with mitigation measures established in the Draft EIR, including those that apply to the nonparticipating parcels, are clearly stated for each measure. Furthermore, the mitigation measures and associated monitoring agencies are collected in Chapter 4.0, Mitigation Monitoring and Reporting Program, of this Final EIR.
Response to Comment 57-14
The comment does not provide specific criticisms of the adequacy of the Draft EIR. Please see the Master Response. A program-level review of potential impacts of future buildout of the nonparticipating parcels is included throughout the Draft EIR, when applicable.
Final EIR
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March 2025
Chapter 2 – Responses to Comments
Response to Comment 57-15
As detailed in Table 4.3-11 on page 4.3-51 of the Draft EIR, the maximum cancer risk associated with DPM from project operation at the maximally exposed receptor would not exceed the applicable threshold of significance of 10 people per million persons, as the calculations are not rounded to the nearest whole number. Even in the event that the cancer risk was determined to be 10 people per million persons, a significant impact would still not occur, as such a conclusion would require the project’s excess to exceed the threshold of significance. Furthermore, the 9.53 people per million persons calculation represents a conservative analysis, as the foregoing cancer risk is limited only to those houses grouped within the darkest portion of the red overlay shown in Figure 4.3-3 of the Draft EIR (see page 4.3-52). Thus, the analyses and conclusions related to DPM risks in the Draft EIR are adequate.
As shown in Figure 3-3 in the Project Description chapter of the Draft EIR (see page 3-6), the proposed HC-PUD zones would be centrally located in the western half of the project site, and the fueling station/car wash would not be located in proximity to existing sensitive receptors. The proposed warehouse structures would also shield existing receptors to the east and south of the project site from emissions generated by idling vehicles at the proposed fueling station/car wash, further limiting cancer and health risks from vehicles visiting the site. Thus, the fueling station is not anticipated to result in DPM-related impacts at existing receptors, and the analysis and conclusion in the Draft EIR related to DPM risks are adequate.
Response to Comment 57-16
The assumption related to trips generated by the proposed highway commercial uses made by the Draft EIR is consistent with OPR guidance. As noted on page 4.12-20, the HC-PUD uses are considered to be local-serving retail, and consistent with OPR guidance, would result in a lessthan-significant impact related to VMT. Therefore, the analysis is considered to be adequate.
Response to Comment 57-17
Table 4.3-11 of the Draft EIR presents the calculated cancer risk associated with the proposed industrial park. Impacts related to future buildout of the nonparticipating parcels are addressed separately on page 4.3-53 of the Draft EIR, consistent with the appropriate regulations and standard methods of analysis. Therefore, Table 4.3-11 does not need to be modified.
Response to Comment 57-18
As discussed under Impact 4.7-5 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, Mitigation Measure 4.7-5 requires the proposed project to comply with the recommendations of the ALUC regarding wildlife hazards to aviation. Pursuant to the CEQA Guidelines, the mitigation has been determined to be sufficient to reduce potential impacts related to hazardous wildlife attractants to a less-than-significant level. Therefore, the Draft EIR’s analysis of the impact is considered to be adequate.
Response to Comment 57-19
Potential impacts related to operational noise associated with the proposed project, including noise generated through deterring birds from the site, are addressed under Impact 4.10-2 in Chapter 4.10, Noise, of the Draft EIR. The analysis therein evaluates all operational noise generated by the proposed project and concludes that implementation of mitigation would reduce the potential impact to a less-than-significant level. In addition, any noise generating strategies that may be implemented as an avian deterrent associated with Mitigation Measure 4.7-5(a) would Final EIR
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be subject to the City’s noise ordinance, which ensures that any operation that exceeds the City’s standards would be prohibited. As such, the analysis included in the Draft EIR is considered to be adequate.
Response to Comment 57-20
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 57-21
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 57-22
The water demand of the entire proposed project is presented in Table 4.11-5 on page 4.11-44 in Chapter 4.11, Public Services and Utilities, of the Draft EIR. An evaluation of the proposed project’s water demand in comparison to the available water supply is also presented therein.
Response to Comment 57-23
See Response to Comment 57-12.
Response to Comment 57-24
The CEQA Guidelines do not require an EIR to evaluate water demand under the conditions described by the commenter. Impacts related to the proposed project’s water demand were addressed consistent with the requirements of the CEQA Guidelines under Impact 4.11-6 in Chapter 4.11, Public Services and Utilities, of the Draft EIR.
Response to Comment 57-25
The Environmental Noise Assessment prepared for the proposed project by Saxelby Acoustics, LLC. was prepared in compliance with all applicable regulations and using methods standard for the industry. All relevant factors, including wind impacts, were included when preparing the analysis.
Response to Comment 57-26
As discussed under Impact 4.10-2 in Chapter 4.10, Noise, of the Draft EIR, according to the Environmental Noise Assessment prepared for the proposed project, development of the eightfoot-tall sound wall, as required by Mitigation Measure 4.10-2, would be sufficient to reduce potential impacts related to operational noise to a less-than-significant level.
Response to Comment 57-27
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 57-28
Please see the Master Response. The commenter presents their opinion about the bicycle facilities needed to support the proposed project, but does not present evidence supporting the validity of their opinion. Nonetheless, the comment shall be forwarded to the decision-makers for their consideration.
Response to Comment 57-29
Please see Response to Comment 57-15.
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Chapter 2 – Responses to Comments
Response to Comment 57-30
Table 4.3-10, AQMP Operational Criteria Pollutant Emissions Reduction Summary (tons/yr), presents the information relevant to the SMAQMD’s operational emissions thresholds of significance for criteria pollutants, as discussed on page 4.3-46 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. Therefore, the information presented therein is appropriate and adequate for the purposes of the analysis.
Response to Comment 57-31
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Pursuant to the CEQA Guidelines, 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. Therefore, the Draft EIR is not required to analyze potential social and economic impacts of the proposed project.
Response to Comment 57-32
The commenter does not provide any evidence to support their conclusions. As discussed throughout Chapter 4.11, Public Services and Utilities, of the Draft EIR, adequate capacity exists to serve the public services and utilities needs of the proposed project.
Response to Comment 57-33
The physical environmental impacts associated with construction of the proposed project, including potential impacts resulting from installation of off-site utilities infrastructure, have been identified and analyzed throughout the Draft EIR. Impacts related to such were adequately assessed and were determined to be less than significant.
Response to Comment 57-34
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Analysis of police response times is not required under CEQA. However, an evaluation of whether the proposed project would result in substantial adverse physical impacts associated with the provision of new or physically altered police protection services and/or facilities, the construction of which could cause significant environmental impacts, was evaluated in impact 4.11-2 of the Draft EIR.
Response to Comment 57-35
The cumulative setting for air quality and noise assessments are noted in the cumulative impacts section of each technical chapter of the Draft EIR. Pursuant to CEQA requirements, all reasonably foreseeable surrounding development is accounted for, as appropriate.
Response to Comment 57-36
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.
Response to Comment 57-37
As discussed on page 4.4-1 in Chapter 4.4, Biological Resources, of the Draft EIR, the Biological Resources Assessment and the Aquatic Resources Delineation Report prepared for the proposed Final EIR
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project by Bargas Environmental Consulting evaluated the entire project site at an appropriate level. As such, the nonparticipating parcels were included in the biological impacts analysis. In addition, all mitigation for potential impacts to special-status species requiring mitigation are delineated by “Industrial Park” and “Nonparticipating Parcels” as appropriate.
Response to Comment 57-38
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 57-39
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
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Chapter 2 – Responses to Comments
Letter 58
58-2
58-1
58-3
58-4
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LETTER 58: JEFF PHILLIPS
Response to Comment 58-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
As discussed therein, project-related traffic and its effect on the regional roadway network is evaluated in Chapter 4.12, Transportation, of the Draft EIR.
Response to Comment 58-2
See Response to Comment 24-1 above.
Response to Comment 58-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Nonetheless, it is noted that an Off-Site Alternative was addressed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, and was dismissed from analysis due to the Alternative’s infeasibility.
Response to Comment 58-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 59
59-2
59-1
59-3
59-4
59-5
59-6
59-7
59-8
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LETTER 59: PATRICIA AND LAWRENCE ROUEN
Response to Comment 59-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 59-2
The comment does not specifically address the adequacy of the Draft EIR. Please see the Master Response. Potential impacts associated with the proposed project related to air quality and traffic are addressed in Chapters 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, and 4.12, Transportation, respectively, of the Draft EIR.
Response to Comment 59-3
See Response to Comment 59-2. It is noted that potential impacts associated with the proposed project related to noise are addressed in Chapter 4.10, Noise, of the Draft EIR.
Response to Comment 59-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on wildlife species and their required habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 59-5
See Response to Comment 59-2.
Response to Comment 59-6
The comment does not specifically address the adequacy of the Draft EIR. Potential impacts related to construction noise associated with the proposed project are addressed under Impact
4.10-1 in Chapter 4.10, Noise, of the Draft EIR; as discussed therein, compliance with the City’s permitted construction noise hours would ensure that impacts would be less than significant.
Similarly, potential impacts related to increase dust associated with construction of the proposed project are addressed under Impact 4.3-4 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. As discussed therein, compliance with all applicable SMAQMD rules and regulations for construction would ensure that such impacts would be less than significant.
Response to Comment 59-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on local hydrology and water quality, including flooding on- or off-site, are addressed in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR. As discussed therein, the proposed project is not anticipated to result in the impediment or redirection of flood flows such that on- or off-site structures would be exposed to flood risk. However, a Conditional Letter of Map Revision (CLOMR) would be required by Mitigation Measure 4.8-5 prior to grading permit approval in order to ensure the project’s compliance with existing regulations.
Response to Comment 59-8
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Chapter 2 – Responses to Comments
Letter 60
60-2
60-1
60-3
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LETTER 60: MYRNA RUDMAN
Response to Comment 60-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 60-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 60-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 61
61-1
61-2
61-3
61-4
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61-5
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LETTER 61: LOLLY SANGSTER
Response to Comment 61-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 61-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The alternatives were developed to reduce the identified significant impacts for the proposed project. The evaluation of the impacts associated with each alternative is discussed, but in less detail than the significant effects of the project as proposed, pursuant to CEQA Guidelines Section 15126.6(d).
Response to Comment 61-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The undeveloped parcels associated with an alternative evaluation resulting in blight is speculative. The commenter does not provide evidence to support the assertion that blight could occur suffect for a more detailed response.
Response to Comment 61-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Nonetheless, the suggestion shall be forwarded to the decision-makers for their consideration.
Response to Comment 61-5
The comment is a concluding statement that summarizes the preceding comments. Please see the responses above.
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Letter 62
62-1
62-2
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62-2,
cont.
62-3
62-4
62-5
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62-5,
cont.
62-6
62-7
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62-8
62-9
62-10
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62-11
62-12
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62-12,
cont.
62-13
62-14
62-15
62-16
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62-16,
cont.
62-17
62-18
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62-18,
cont.
62-19
62-20
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62-20,
cont.
62-21
Final EIR
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Final EIR
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Chapter 2 – Responses to Comments
Final EIR
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Chapter 2 – Responses to Comments
Final EIR
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Final EIR
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Chapter 2 – Responses to Comments
LETTER 62: JAN SCHORI AND CASE BUTTERMAN
Response to Comment 62-1
The comment is an introductory statement and summary of more detailed comments to follow.
Please see the Master Response.
Response to Comment 62-2
As discussed on page 4.3-34 of the Draft EIR, to assess the potential impacts of toxic air contaminants (TACs), the SMAQMD maintains thresholds of significance for the review of local community risk and hazard impacts. The thresholds are designed to assess the impact of new sources of TACs on existing sensitive receptors. Based on the SMAQMD thresholds, the proposed project would result in a significant impact related to TACs if nearby sensitive receptors would experience an increased cancer risk of greater than or equal to 10 in one million people, or experience a chronic or acute hazard index of greater than or equal to 1.0.2 Given that the proposed project would result in a cancer risk of 9.53, which is below the SMAQMD threshold of significance, the Draft EIR concluded that a less-than-significant impact would occur. The assumptions used for the health risk assessment are presented in the Method of Analysis section starting on page 4.3-39 of the Draft EIR. In addition, the modeling outputs are included in Appendix C to the Draft EIR.
Response to Comment 62-3
The comment is referring to a separate analysis that was conducted in the Draft EIR related to health effects associated with criteria pollutants, not health effects related to TAC emissions. For further detail regarding the analysis included in the Draft EIR related to health effects associated with criteria pollutants, please see Response to Comment 19-20.
Response to Comment 62-4
Please see Response to Comment 9-3.
Response to Comment 62-5
As discussed on page 4.1-1 of the Draft EIR, with respect to aesthetic impacts, consistent with the CEQA Guidelines, the analysis of the Draft EIR is focused on 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 is not required to be evaluated under CEQA. In addition, it is noted that potential economic impacts of the proposed project, such as effects on property values in the area, are not required to be addressed under CEQA.
Response to Comment 62-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 62-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response. 2 Sacramento Metropolitan Air Quality Management District. Guide to Air Quality Assessment in Sacramento County: Toxic Air Contaminants. April 2020.
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Chapter 2 – Responses to Comments
Response to Comment 62-8
Please see the Master Response. At the time that the Notice of Preparation (NOP) for the Draft EIR was published, the project site was not in use as active agricultural land. Consistent with CEQA Guidelines, the Draft EIR treats the state of the project site at the time when the NOP was published as the baseline for the analysis; therefore, the site description included in the Draft EIR remains accurate for the purposes of evaluation under CEQA. Furthermore, the analysis presented throughout Chapter 4.2, Agricultural Resources, is based on the California Department of Conservation (DOC) and LAFCo definitions of farmland; whether or not the land is in active use is not relevant. Therefore, the analysis of potential impacts related to agricultural resources presented within the Draft EIR is adequate.
Response to Comment 62-9
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 62-10
The Environmental Noise Assessment prepared for the proposed project by Saxelby Acoustics, LLC. was prepared in compliance with all applicable regulations and using methods standard for the industry. Potential impacts related to operational noise associated with the proposed project and daytime/nighttime warehouse operations, are addressed under Impact 4.10-2 in Chapter
4.10, Noise, of the Draft EIR. The analysis therein evaluates all operational noise generated by the proposed project and concludes that implementation of mitigation would reduce the potential impact to a less-than-significant level. The required sound wall placement is based on the noise modeling results (see Figure 4.10-6). In addition, any noise generating strategies that may be implemented as an avian deterrent associated with Mitigation Measure 4.7-5(a) would be subject to the City’s noise ordinance, which ensures that any operation that exceeds the City’s standards would be prohibited. As such, the analysis included in the Draft EIR is considered to be adequate.
Response to Comment 62-11
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Potential impacts associated with the proposed project related to traffic are addressed in Chapter
4.12, Transportation, of the Draft EIR.
Response to Comment 62-12
The comment does not address the adequacy of the Draft EIR. 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.
Response to Comment 62-13
Because the future tenants of the proposed industrial park are not yet known, the exact uses of the project site cannot be determined. However, as discussed throughout the Draft EIR, the analysis of the proposed project conservatively addresses potential impacts associated with the most adverse allowable uses permitted for the site per the City’s Municipal Code and 2040 General Plan, as well as the Development Agreement and PUD established for the project site.
Furthermore, as stated on page 4.7-19 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR, “while not currently anticipated, in the event that future operations associated with the proposed warehouses involve the routine use, transport, or disposal of hazardous materials, such materials would be safely managed in accordance with applicable regulations and would be subject to City review depending on the type or quantity of chemicals proposed for use.” As such, Final EIR
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the City of Sacramento would be responsible for ensuring that future tenants of the project site with the potential to result in impacts upon the nearby school related to hazardous materials would not be permitted, or would be designed such that adverse impacts would not occur.
Response to Comment 62-14
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It is noted that a Findings of Fact and Statement of Overriding Considerations for the proposed project is forthcoming and typically made available for public review prior to project hearings.
Response to Comment 62-15
As discussed on page 7-20 in Chapter 7, Alternatives Analysis, of the Draft EIR, Section 15126(e)(2) of the CEQA Guidelines requires that an environmentally superior alternative be designated and states, “If the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” Therefore, the Draft EIR identifies the Reduced Footprint Alternative as the Environmentally Superior Alternative. 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.
Response to Comment 62-16
Please see the Master Response. The focus of CEQA and the Draft EIR is limited to the physical impacts of a project, and thus, is not required to analyze social and economic impacts of the proposed project.
Response to Comment 62-17
Alternatives to the proposed project, including off-site alternatives, are addressed in Chapter 7, Alternatives Analysis, of the Draft EIR. As discussed therein, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible. For example, in order for an off-site alternative consisting of multiple sites to be feasible, the project applicant would need to own all of the sites being evaluated; that is not the case with the currently proposed project. The lack of ability to implement the suggested off-site alternative renders the alternative infeasible, and therefore, not required to be evaluated under CEQA.
Response to Comment 62-18
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The suggested alternative will be provided to the decision-makers for their consideration.
Response to Comment 62-19
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 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 residential 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.
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Response to Comment 62-20
As discussed on page 7-6 in Chapter 7, Alternatives Analysis, of the Draft EIR, the 100 Percent Electric Fleet Alternative was dismissed from detailed evaluation because “requiring a fully electric fleet of any future tenants would limit the pool of potential tenants to such a degree that extensive vacancies could occur, or that the project site would be unable to develop the parcels consistent with the project objectives.” Based on the foregoing information, the Draft EIR adequately demonstrates why the 100 Percent Fleet Alternative was dismissed from analysis.
Response to Comment 62-21
The comment is a concluding statement and does not address the adequacy of the Draft EIR.
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Chapter 2 – Responses to Comments
Letter 63
63-2
63-1
63-3
63-4
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LETTER 63: DANA J. SCHWARTZ
Response to Comment 63-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 63-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 63-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 63-4
The comment expresses a general opinion that more appropriate land (as compared to the project site) that could be developed with the proposed uses is located near the project site, but does not provide specific examples that would allow for a detailed response. Furthermore, the Alternatives Analysis chapter of the Draft EIR includes consideration of an Off-Site Alternative. As detailed on page 7-5 of the Draft EIR, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible.
Please see the Master Response.
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Chapter 2 – Responses to Comments
Letter 64
64-2
64-1
64-3
64-4
64-5
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LETTER 64: DANA J. SCHWARTZ
Response to Comment 64-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 64-2
See Response to Comment 63-1 above.
Response to Comment 64-3
See Response to Comment 63-2 above.
Response to Comment 64-4
See Response to Comment 63-3 above.
Response to Comment 64-5
See Response to Comment 63-4 above.
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Letter 65
65-2
65-1
65-3
65-4
65-5
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LETTER 65: STEVE SCHWEIGERDT
Response to Comment 65-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 65-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
As discussed therein, the scope of an EIR is limited to an evaluation of potentially significant environmental impacts of a project, which are, by definition, limited to physical conditions. The determination of whether the proposed project is consistent or inconsistent with LAFCo and City policies is ultimately the decision of the Sacramento LAFCo Commission and Sacramento City Council.
Response to Comment 65-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on local agricultural resources, including farmland, are addressed in Chapter 4.2, Agricultural Resources, of the Draft EIR.
Response to Comment 65-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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-thansignificant impact would occur.
Response to Comment 65-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Chapter 2 – Responses to Comments
Letter 66
66-1
66-2
66-3
66-4
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66-4,
cont.
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LETTER 66: STEVE SCHWEIGERDT
Response to Comment 66-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 66-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 66-3
As discussed throughout the Biological Resources chapter of the Draft EIR, although only a portion of the industrial park footprint and nonparticipating parcels are within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to special-status plant and wildlife species with potential to occur on-site, including those not covered under the Natomas Basin HCP.
In addition, as discussed under Impact 4.4-14, which starts on page 4.4-70 of the Draft EIR, the Natomas Basin HCP’s Operating Conservation Plan (OCP) is based upon the City limiting total development to 8,050 acres within the City’s portion of the HCP permit area. Approval by the City of future urban development beyond the 8,050 acres would trigger a re-evaluation of the Natomas Basin HCP, a new effects analysis, potential amendments and/or revisions to the Natomas Basin HCP and incidental take permits, a separate conservation strategy, and the need for the City to obtain a new incidental take coverage for that additional development. The City’s annual reports have shown surplus acreage available within the 8,050 acres of development allowed under the City’s incidental take permit. 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.
Based on the above, through adherence to the mitigation measures established by the Draft EIR, the proposed project would be consistent with the Natomas Basin HCP.
Response to Comment 66-4
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, 6,791.83 acres have been authorized for grading. Such information is reliable because the City is the land use agency that issues the grading permits and documents those acreages over time in the annual reports.
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 Final EIR
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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.
As noted under Response to Comment 66-3, 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 proposed project would not affect the Natomas Basin Conservancy’s ability to buffer future wetland uses from the project site within the existing reserve lands pursuant to the Natomas Basin HCP. The proposed project would not affect habitat connectivity. 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. Finally, implementation of the proposed project would not prevent the Natomas Basin Conservancy from establishing 8,750 acres of reserves in the Natomas Basin, as identified in the Natomas Basin HCP, as the project site constitutes only 0.89 percent of the acreage in the Natomas Basin and the Natomas Basin Conservancy is well on its way to securing all the reserve lands required to meet its obligations. Thus, the Draft EIR concludes that the proposed project would not conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan, and a less-than-significant impact would occur.
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Letter 67
67-2
67-1
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LETTER 67: CARMEN AND ROBERTO SEGOVIA
Response to Comment 67-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 67-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on special-status species are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
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Letter 68
68-2
68-1
68-3
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LETTER 68: MARGIT SPENCER
Response to Comment 68-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 68-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on the existing noise environment, including airport noise, are addressed in Chapter 4.10, Noise, of the Draft EIR.
Response to Comment 68-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 69
69-2
69-1
69-3
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LETTER 69: DOLEE SPURGEON
Response to Comment 69-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 69-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 69-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 70
70-1
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LETTER 70: DOLEE SPURGEON
Response to Comment 70-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 71 71-3
71-1
71-2
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LETTER 71: MARCELLA STEELE
Response to Comment 71-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 71-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on local agricultural resources, including farmland, are addressed in Chapter 4.2, Agricultural Resources, of the Draft EIR. In addition, the potential effects of the project on special-status species and their habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 71-3
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 72
72-3
72-1
72-2
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LETTER 72: MARCELLA STEELE
Response to Comment 72-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 72-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on local agricultural resources, including farmland, are addressed in Chapter 4.2, Agricultural Resources, of the Draft EIR. In addition, the potential effects of the project on special-status species and their habitat are addressed in Chapter 4.4, Biological Resources, of the Draft EIR. Potential impacts related to transportation are addressed in Chapter 4.12, Transportation, of the Draft EIR.
Response to Comment 72-3
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
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Letter 73
73-1
73-2
73-3
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73-4
73-3,
cont.
73-5
73-6
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73-7
73-8
73-9
73-10
73-11
73-12
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73-12,
cont.
73-13
73-14
73-16
73-17
73-18
73-15
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73-18,
cont.
73-19
73-21
73-20
73-22
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73-23
73-24
73-25
73-26
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73-27
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LETTER 73: HARRIET STEINER
Response to Comment 73-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 73-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
In addition, please see the analyses and conclusions in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, which assesses the project’s potential impacts related to GHG emissions.
Response to Comment 73-3
The wording of CEQA Guidelines Section 15125(d) is important. CEQA does not require an EIR to “…provide a consistency analysis with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect.” However, similar to many EIRs, the analysis of plan inconsistency in the Draft EIR is set forth in the individual chapters’ analysis of environmental impacts. For example, as discussed in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR, the project is evaluated for consistency with the applicable air quality plan under Impact 4.3-1 (see page 4.3-40 of the Draft EIR) and Impact 4.3- 2 (see page 4.3-44 of the Draft EIR), as well as for consistency with the applicable GHG-reduction plan under Impact 4.3-7 (see page 4.3-63 of the Draft EIR). As discussed in the Biological Resources chapter of the Draft EIR, the project is evaluated for consistency with the Natomas Basin HCP under Impact 4.4-14 (see page 4.4-70 of the Draft EIR). Similarly, the Draft EIR evaluates potential inconsistencies with applicable plans, policies, and regulations related to other issue areas in the specific technical chapters related to the issue areas.
Additionally, the Draft EIR evaluates the potential for the proposed project to cause a significant environmental impact due to a conflict with any Sacramento LAFCo plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect under Impact 4.9-2, which starts on page 4.9-16. Table 4.9-6 within the analysis lists the proposed project’s consistency with applicable Sacramento LAFCo policies related to land use and planning, including those policies and standards associated with annexation, reorganization, and SOI Amendments, which are found in Chapter V of the Sacramento LAFCo Policy, Standards and Procedures Manual. As discussed therein, the SOI Amendment and Annexation of the project site appear to be generally consistent with the Sacramento LAFCo policies regarding land use and planning. However, policy compliance is often a matter of interpretation. The LAFCo commissioners are the ultimate arbiters of LAFCo policy for the proposed project, and their judgment regarding the project and a specific policy may be different from that set forth in the Draft EIR.
The Draft EIR evaluates the potential for the proposed project to cause a significant environmental impact due to a conflict with any City of Sacramento land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect under Impact 4.9-3, which starts on page 4.9-23. As discussed therein, the standard for analysis used in the Draft EIR is based on general agreement with the policy language and furtherance of the policy intent (as determined by a review of the policy context). The determination that the proposed project is consistent or inconsistent with the City of Sacramento 2040 General Plan policies or other City plans and Final EIR
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policies is ultimately the decision of the Sacramento City Council. As discussed in detail in Table
4.9-7 of the analysis, the proposed project would be consistent with the City of Sacramento 2040 General Plan and Planning and Development Code.
Furthermore, although the Draft EIR may identify some areas of general inconsistency with Sacramento LAFCo and City policies, Sacramento 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.
Response to Comment 73-4
Pursuant to CEQA Guidelines Section 15088.5(a), a lead agency is required to recirculate a Draft EIR if significant new information is added after the Draft EIR is circulated but before certification.
Significant new information is defined as information that changes a Draft EIR “…in a way that deprives the public of a meaningful opportunity to comment on…” a significant impact, a feasible way to mitigate an impact, or a feasible way to avoid an impact. The following identifies circumstances that may be considered “significant new information” and may trigger recirculation:
• Information that shows a new significant impact;
• Information that shows a substantial increase in the severity of an impact (unless mitigation measures are identified to reduce it to acceptable levels); • Information that identifies a feasible new alternative or mitigation measure considerably different from other analyzed alternatives or mitigation measures that would clearly lessen project impacts and the applicant declines to implement the measure; and/or • Information that demonstrates that the Draft EIR was fundamentally flawed, basically inadequate, and conclusory in nature, thus, precluding meaningful public review and comment.
Pursuant to CEQA Guidelines Section 15088.5(b), recirculation is not required if the information added to an EIR merely clarifies, amplifies, or makes insignificant modifications. As established by the Responses to Comments and Revisions to the Draft EIR Text chapters of this Final EIR, significant new information, as defined by the CEQA Guidelines, has not been added to the Draft EIR, as the revisions contained herein only clarify, amplify, or make insignificant modifications to the analyses contained in the Draft EIR, which are consistent with the Draft EIR’s analyses or conclusions. Thus, recirculation is not necessary.
Response to Comment 73-5
The comment expresses a general opinion that the Project Description; Agricultural Resources; Air Quality, Greenhouse Gas Emissions, and Energy; Biological Resources; Noise; Transportation; and Statutorily Required Sections chapters of the Draft EIR require revisions “to accurately reflect the impacts of” the proposed project, but does not provide specific examples that would allow for a detailed response. Please see the analyses and conclusions contained in the foregoing chapters of the Draft EIR.
Response to Comment 73-6
Nonparticipating Parcels
The proposed project includes several nonparticipating parcels comprised of approximately 83 acres, which would receive first-tier entitlements, such as the proposed Final EIR
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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.
As discussed on page 1-2 of the Draft EIR, because the proposed project would not include 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 and future buildout of approximately 1,404,808 sf of industrial uses, pursuant to CEQA Guidelines Section 15168. Thus, the Project Description chapter of the Draft EIR is adequate and the assumptions used to evaluate full buildout of the project are appropriate.
Furthermore, each technical chapter of the Draft EIR includes a programmatic analysis of future buildout of the nonparticipating parcels with the anticipated industrial uses.
Response to Comment 73-7
See Response to Comment 22-18. With respect to the proposed project’s consistency with applicable plans, please see Response to Comment 73-3.
Response to Comment 73-8
As discussed on page 7-20 of the Draft EIR, the No Project (No Build) Alternative would be considered the environmentally superior alternative, because the project site is assumed to remain in its current condition under the alternative. However, Section 15126(e)(2) of the CEQA Guidelines states, “[i]f the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” As further detailed on page 7-21 of the Draft EIR, because the Reduced Footprint Alternative would result in fewer impacts than the proposed project related to nine of the 13 issue areas, and would result in similar impacts as the proposed project for the remaining four issue areas for which project impacts were identified, the Reduced Footprint Alternative would be considered the environmentally superior alternative, as the 20 Percent Electric Fleet Alternative would result in fewer impacts related only to air quality, greenhouse gas emissions, and energy. Thus, the analyses and conclusions in the Alternatives Analysis chapter of the Draft EIR are adequate.
Response to Comment 73-9
The Draft EIR includes consideration of the No Project (No Build) Alternative, which assumes that the current conditions of the project site, agricultural operations, would remain. Thus, the Draft EIR evaluates an alternative generally similar to that which is proposed by the comment.
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Furthermore, as discussed on page 7-1 of the Draft EIR, CEQA Guidelines Section 15126.6(a) provides that the primary intent of the alternatives evaluation in an EIR is to “[…] describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” An EIR must include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. The alternatives analysis is not required to consider every project alternative but is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice (see CEQA Guidelines Section 15126.6[a]). The intent of the project alternatives chosen for the Draft EIR was to develop alternatives to the proposed project that would accomplish most of the basic project objectives while avoiding or lessening the potential impacts of the proposed project. Thus, the analyses and conclusions in the Alternatives Analysis chapter of the Draft EIR are adequate.
Response to Comment 73-10
As discussed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, an Off-Site Alternative was considered but dismissed from detailed analysis due to a determination of infeasibility based on a preliminary evaluation. Please see the analysis and conclusion contained therein, as well as Response to Comment 73-9.
Response to Comment 73-11
The Draft EIR evaluates the proposed project’s potential to convert Prime Farmland, Unique Farmland, and/or Farmland of Statewide Importance to non-agricultural uses under Impact 4.2-1, which starts on page 4.2-16. As discussed therein, the existing land uses within the industrial park are predominantly agricultural and contain approximately 31.3 acres of Prime Farmland and approximately 12.1 acres of Farmland of Statewide Importance. To address the project’s conversion of the foregoing acreage to non-agricultural uses, the Draft EIR sets forth Mitigation Measure 4.4-5(b), as revised, which requires the project applicant to identify appropriate lands off-site to be set aside in permanent conservation easement at a ratio of one acre of habitat located within the Natomas Basin HCP policy area converted to urban land uses to 0.5-acre of habitat preserved. The mitigation similarly requires the 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, which overall, would result in preservation at a 1:1 ratio. The revised language of Mitigation Measure 4.4-5(b) includes the requirement that off-site preserved habitat shall be “suitable Swainson’s hawk foraging habitat.” Furthermore, Mitigation Measure 4.2-1, as revised in this Final EIR, stipulates that all mitigation acreage shall consist of land of equal agricultural and habitat value as the agricultural/open space resources impacted by the proposed project. However, because Mitigation Measure 4.4-5(b) 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 new agricultural land, which would lead to an overall loss of Farmland. Therefore, the Draft EIR concludes the potentially significant impact would remain significant and unavoidable. Thus, the analyses and conclusions in the Agricultural Resources chapter of the Draft EIR are adequate.
Response to Comment 73-12
As discussed under Response to Comment 73-11, Mitigation Measure 4.2-1, as revised in this Final EIR, stipulates that all mitigation acreage shall consist of land of equal agricultural value and habitat type as the agricultural/open space resources impacted by the proposed project. In addition, the revised language of Mitigation Measure 4.4-5(b) includes the requirement that off- Final EIR
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site preserved habitat shall be “suitable Swainson’s hawk foraging habitat.” As such, the Draft EIR, as revised, includes provisions to ensure that the agricultural land developed as part of the proposed project would be mitigated with land of equal value.
Response to Comment 73-13
Within the Draft EIR’s overall analysis of the proposed project’s compliance with the Natomas Basin HCP, which starts under Impact 4.4-14 on page 4.4-70, the Draft EIR includes the following with respect to the minimum habitat block sizes necessary for the Natomas Basin Conservancy to establish 8,750 acres of reserves in the Natomas Basin:
With regard to habitat blocks of at least 400 acres, as shown on Figure 4.4-5 [of the Draft EIR], the nearest Natomas Basin HCP habitat blocks to the project site include the Rosa East, Rosa Central, Souza, and Natomas Farms reserves totaling approximately 301 acres, and the Cummings and Rudin reserves, totaling approximately 109 acres.
The project site does not include the property lying between the aforementioned two nearby clusters of reserve land and would not preclude the future acquisition of connectivity between the two areas by the Natomas Basin Conservancy.
However, contrary to the commenter’s assertion, the Draft EIR includes a comprehensive analysis of effects on the Natomas Basin HCP that could result from implementation of the proposed project under Impact 4.4-14. The Draft EIR concludes that the proposed project would not conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan, and a less-than-significant impact would occur. Thus, the analyses and conclusions in the Draft EIR are adequate. Please see Responses to Comments 66-3 and 66-4.
Response to Comment 73-14
The Natomas Basin HCP is specifically designed to address potential impacts to biological resources on a cumulative scale within the basin. The Natomas Basin HCP is a multi-species conservation program adopted for the purposes of minimizing and mitigating the loss of habitat values and incidental take of Covered Species resulting from urban development, operation and maintenance of irrigation and drainage systems, and various activities associated with the Natomas Basin Conservancy’s management of reserves established under the Natomas Basin HCP. Through compliance with applicable Take Avoidance, Minimization, and Mitigation Measures, the Natomas Basin Conservancy has previously concluded that potential impacts to biological resources covered under the Natomas Basin HCP within the permit area would be reduced to a less-than-significant level.
As discussed under Impact 4.4-14 of the Draft EIR, which begins on page 4.4-70, all development facilitated by the proposed project would be subject to the applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to address direct impacts to Covered Species that could occur as a result of project construction activities, regardless of when such activities occur. While full buildout of the project site with the proposed uses could occur over a period of time, the requirements for mitigating the full buildout of the site are not analyzed through a piecemeal approach in the Draft EIR, as the Draft EIR evaluates the potential impacts from development of both the industrial park and the nonparticipating parcels.
In other words, the Draft EIR adequately evaluates the whole of the proposed action, consistent with CEQA Guidelines Sections 15003(g) and 15378.
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With respect to payment of the Natomas Basin HCP mitigation fees, only site development occurring within the Natomas Basin HCP permit area would be required to pay the fees. However, to ensure the proposed project addresses potential impacts to Swainson’s hawk foraging habitat in on-site areas outside of the Natomas Basin HCP permit area, the Draft EIR includes Mitigation Measure 4.4-5(b), which requires the project applicant to pay the mitigation fees, should a portion of the City’s surplus HCP coverage acreage be made available to the project.
Furthermore, all CEQA mitigation and project conditions of approval shall be tracked and enforced by the City of Sacramento throughout construction and phasing of the entire annexation area.
Please also see Responses to Comments 66-3 and 66-4.
Response to Comment 73-15
Please see the analysis and conclusion under Impact 4.4-15, which starts on page 4.4-78 of the Draft EIR, as well as the Statutorily Required Sections chapter of the Draft EIR and Responses to Comments 66-3, 66-4, 73-11, and 73-14.
Response to Comment 73-16
Please see Response to Comment 73-3.
Response to Comment 73-17
Please see the Statutorily Required Sections Chapter of the Draft EIR. Growth-inducing impacts are addressed beginning on page 6-1.
Response to Comment 73-18
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 73-19
See Responses to Comments 13-42 and 13-43. The Draft EIR evaluates the proposed project’s potential to result in the generation of GHG emissions that may have a significant impact on the environment or conflict with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs under Impact 4.3-7, which begins on page 4.3-63.
The evaluation includes a quantitative analysis of the proposed project’s maximum unmitigated construction- and operations-related GHG emissions (see Tables 4.3-13, 4.3-14, and 4.3-15, on pages 4.3-64 through 4.3-65 of the Draft EIR), as well as discussions on the project’s consistency with the City of Sacramento CAAP and CARB’s 2022 Scoping Plan. As detailed therein, with implementation of Mitigation Measures 4.3-7(a) through 4.3-7(d) (including Mitigation Measure
4.3-7[b], which includes provisions for carbon sequestration), the project would result in a lessthan-significant impact.
Response to Comment 73-20
Please see Response to Comment 31-6.
Response to Comment 73-21
The comment expresses a general opinion that the Draft EIR undercounts PM-related health risks, but does not provide specific examples that would allow for a detailed response.
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Response to Comment 73-22
Please see Response to Comment 73-6.
Response to Comment 73-23
Please see the analyses and conclusions under Impact 4.3-3, which begins on page 4.3-48 of the Draft EIR, and includes evaluation of potential impacts that could occur from buildout of the nonparticipating parcels related to exposing sensitive receptors to substantial pollutant concentrations. In addition, please see Response to Comment 73-6.
Response to Comment 73-24
Please see the analyses and conclusions in the Draft EIR, which includes evaluation of the project’s potential impacts on the existing physical environment, including to sensitive receptors in the project vicinity such as residences and the Paso Verde K-8 School.
Response to Comment 73-25
Please see Response to Comment 73-23 and the analyses and conclusions under Impacts 4.10- 1 and 4.10-2, which begin, respectively, on pages 4.10-15 and 4.10-16 of the Draft EIR and evaluate potential noise impacts on existing sensitive receptors in the project vicinity, such as residences and the Paso Verde K-8 School.
Response to Comment 73-26
Please see the various responses to comments associated with Letter 73 and the Master Response.
Response to Comment 73-27
The comment is a closing statement and does not address the adequacy of the Draft EIR.
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Letter 74
74-1
74-3
74-4
74-5
74-6
74-2
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LETTER 74: MURIEL STRAND
Response to Comment 74-1
As discussed on page 7-20 of the Draft EIR, the No Project (No Build) Alternative would be considered the environmentally superior alternative, because the project site is assumed to remain in its current condition under the alternative. However, Section 15126(e)(2) of the CEQA Guidelines states, “[i]f the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” As further detailed on page 7-21 of the Draft EIR, because the Reduced Footprint Alternative would result in fewer impacts than the proposed project related to nine of the 13 issue areas, and would result in similar impacts as the proposed project for the remaining four issue areas for which project impacts were identified, the Reduced Footprint Alternative would be considered the environmentally superior alternative, as the 20 Percent Electric Fleet Alternative would result in fewer impacts related to only one issue area (Air Quality, Greenhouse Gas Emissions, and Energy). Thus, the analyses and conclusions in the Alternatives Analysis chapter of the Draft EIR are adequate.
Response to Comment 74-2
Please see Response to Comment 74-1.
Response to Comment 74-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 74-4
Please see Response to Comment 74-1 and the Master Response.
Response to Comment 74-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 74-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. Please see the Master Response.
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75-3
75-1
75-2
Letter 75
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LETTER 75: EDITH THACHER
Response to Comment 75-1
Contrary to the commenter’s assertion and as detailed in the Notice of Availability (NOA) published on the City of Sacramento’s website, the 45-day public review period for the Draft EIR was from May 31, 2024 to July 17, 2024, in accordance with the requirements established by CEQA Guidelines Section 15105(a). The public review period additionally included public hearings to receive comments on June 12, 2024 (held by Sacramento LAFCo) and June 26, 2024 (held by the City of Sacramento).
Response to Comment 75-2
Sacramento LAFCo and the City of Sacramento will hold meetings, prior to each agency’s consideration of approving the project and certifying the EIR, where members of the public and other interested parties will be provided the opportunity to provide comments on the proposed project and analyses and conclusions of the Draft EIR.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 75-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses of potential cumulative impacts within the various technical chapters of the Draft EIR.
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
76-3
Letter 76
76-4
76-5
76-6
76-7
76-8
76-2
76-1
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 76: BRIAN THORNTON
Response to Comment 76-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 76-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Aesthetics; Air Quality, Greenhouse Gas Emissions, and Energy; and Noise chapters of the Draft EIR.
Response to Comment 76-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 76-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential for the proposed project to expose sensitive receptors, including schools, to substantial pollutant concentrations, is addressed under Impact 4.3-3 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR. In addition, the potential for the project to emit hazardous emissions or handle hazardous materials, substances, or waste within 0.25- mile of a school is addressed under Impact 4.7-3 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR.
Response to Comment 76-5
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the project on bicycle facilities and traffic safety are addressed in Chapter
4.12, Transportation, of the Draft EIR.
Response to Comment 76-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 76-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The potential effects of the proposed project on protected wildlife species and their habitats are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 76-8
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment 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 – Responses to Comments
Letter 77
77-1
77-2
77-3
77-4
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
LETTER 77: CAROL TURGEON
Response to Comment 77-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response. The potential effects of the project on protected wildlife species and their required habitats, including wildlife movement corridors, are addressed in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 77-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 77-3
The recommendations are noted for the record and will be forwarded to the decision-makers for their consideration. As discussed throughout the Draft EIR, the proposed project would be required to comply with applicable federal, State, and local regulations, including requirements established by the City of Sacramento 2040 General Plan Sacramento City Code related to open space and park acreage and new tree plantings, as well as Title 24 requirements related to energy efficiency.
Response to Comment 77-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.