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LETTER 84: GRACE HOLBROOK, CARPENTERS UNION LOCAL #46
(MITCHELL M. TSAI LAW FIRM)
Response to Comment 84-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 84-2
The comment does not specifically address the adequacy of the Draft EIR; however, the recommendation is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 84-3
The comment provides background on the CEQA process but does not specifically address the adequacy of the Draft EIR.
Response to Comment 84-4
The Draft EIR discusses the proposed project’s consistency with the Natomas Basin HCP throughout Chapter 4.4, Biological Resources, of the Draft EIR. As discussed therein, the eastern portion of the project site is located within the Natomas Basin HCP permit area. Chapter 4.4, Biological Resources, of the Draft EIR addresses potential impacts to multiple special-status wildlife species, many of which are covered species under the Natomas Basin HCP. Each impact statement within the chapter identifies if the species is covered by the Natomas Basin HCP and adequately mitigates potential impacts to such species through compliance with either applicable Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measures or additional mitigation measures, or a combination of both. Impact 4.4-14, beginning on page 4.4-70 of the Draft EIR, specifically addresses the proposed project’s consistency of the Natomas Basin HCP.
Therefore, the Draft EIR adequately addresses the proposed project’s consistency with the Natomas Basin HCP.
Response to Comment 84-5
The comment defines what is considered to be deferral of mitigation under CEQA and generally expresses the opinion that the Draft EIR includes such deferral. The specific claims of impermissible deferral of mitigation are addressed in detail below.
Response to Comment 84-6
As stated on page 4.8-28 in Chapter 4.8, Hydrology and Water Quality, of the Draft EIR, “Wood Rodgers has confirmed that the proposed project would result in reduced WSEs relative to existing conditions for the design storm event. Therefore, the proposed project would be consistent with applicable hydromodification requirements, and would not increase the rate or amount of runoff leaving the project site during the design storm event, or increase the base flood elevation off-site as a result of on-site grading. Because pre-development and post-development flows associated with the project site would be the same, the proposed project would not have the potential to impede or redirect flood flows.”
As such, based on the Preliminary Drainage Study prepared for the proposed project by Wood Rodgers, the proposed project would not modify the existing floodway such that a significant impact related to flooding would occur. The procurement of a Conditional Letter of Map Revision (CLOMR) is not required to bolster the conclusions of the Preliminary Drainage Study. Rather, the Final EIR
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approval of a CLOMR is required to certify that the grading designs are consistent with what was addressed in the analysis and that all applicable regulations are being followed. Contrary to the claim of the commenter, a CLOMR is not required to identify how the project would modify the existing floodway, as that analysis has already been provided in the Preliminary Drainage Study and summarized in the Draft EIR. Therefore, Mitigation Measure 4.8-5 would not be considered deferral.
Response to Comment 84-7
The comment summarizes the noise impact analysis in the Draft EIR and does not address the adequacy of the Draft EIR.
Response to Comment 84-8
As shown in Figure 4.10-5, Nighttime Noise Levels – Full Buildout of the Annexation Area (dBA L50), on page 4.10-22 in Chapter 4.10, Noise, of the Draft EIR, operational noise levels at the future residential uses north of the project site, across I-5, are predicted to be 48 dBA L50 which is below the City’s nighttime 50 dBA L50 noise level standard. As such, the comment is misleading in that it implies that a potentially significant impact related to the future residential uses north of the project site was identified in the Environmental Noise Assessment prepared for the proposed project, which is incorrect. Furthermore, as stated in the language cited by the commenter, “a much taller wall could be required here to shield noise from Interstate 5,” (emphasis added), indicating that any potential noise impacts to the future residential uses would be related to I-5 traffic and would not be associated with operation of the proposed project.
Response to Comment 84-9
Contrary to the claim of the commenter, Mitigation Measure 4.10-2 in Chapter 4.10, Noise, of the Draft EIR does require discretionary approval. Mitigation Measure 4.10-2 requires the required eight-foot-tall sound wall to be included in the final Improvement Plans for the nonparticipating parcels portion of the proposed project, subject to approval by the City’s Public Works Department. As such, it is the responsibility of the City’s Public Works Department to determine, based on the designs in the Improvement Plans and the analysis provided in the Environmental Noise Assessment, if the proposed sound wall would sufficiently reduce noise levels to below the applicable noise level standards. As shown in Figure 4.10-6, Nighttime Noise Levels with an EightFoot Wall – Full Buildout of the Annexation Area (dBA L50), on page 4.10-24 in Chapter 4.10, Noise, of the Draft EIR, the proposed sound wall would adequately reduce operational noise at the residential uses east of the site to below the applicable level of significance.
While not specifically stated in the mitigation, the entirety of the Draft EIR, including the noise analysis and Mitigation Measure 4.10-2, is subject to public comment and City approval as part of the CEQA process. Furthermore, contrary to the claim of the commenter, Mitigation Measure
4.10-2 does include performance criteria: as stated therein, the eight-foot-tall sound wall shall be constructed adequate to achieve the City’s nighttime 50 dBA L50 noise level standards. As such, Mitigation Measure 4.10-2 would not be considered deferred mitigation.
Response to Comment 84-10
See Response to Comment 84-9.
Response to Comment 84-11
As stated on page 4.4-69 in Chapter 4.4, Biological Resources, of the Draft EIR, potential impacts to protected trees would be mitigated through compliance with Sacramento City Code Chapter Final EIR
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12.56. Compliance with such relevant regulations would be considered sufficient mitigation.
Furthermore, as stated in Section 12.56.060 of the City Code, tree replacement plans required as part of obtaining a tree permit are required to include a 1:1 replacement ratio. In addition, any tree replacement plan that does not include payment of an in-lieu fee may require security to ensure that the replacement trees survive for the minimum establishment period, subject to City discretion.
Response to Comment 84-12
See Response to Comment 13-67.
Response to Comment 84-13
The comment is a conclusion statement summarizing the commenter’s critiques of the Draft EIR, the specifics of which have been addressed above.
Response to Comment 84-14
The comment provides informational attachments which do not specifically address the adequacy of the Draft EIR. Please see the Master Response.
3. Revisions to the Draft EIR Text
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3.1 INTRODUCTION
The Revisions to the Draft EIR Text chapter presents minor corrections, additions, and revisions made to the Draft EIR published by the Co-Lead Agencies (City of Sacramento and the Sacramento Local Agency Formation Commission [LAFCo]).
The changes represent minor clarifications/amplifications of the analysis contained in the Draft EIR and do not constitute significant new information that, in accordance with CEQA Guidelines, Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR.
3.2 DESCRIPTION OF CHANGES
New text is double underlined and deleted text is struck through. Text changes are presented in the page order in which they appear in the Draft EIR.
2 EXECUTIVE SUMMARY
2.5 AREAS OF CONTROVERSY
Areas of controversy that were identified in NOP comment letters, and are otherwise known for the region, include the following:
• Increase in light pollution on nearby residential areas. • Conversion of agricultural land to other uses.
• Construction and operational emissions of criteria pollutants and/or GHG emissions.
• Health concerns related to truck traffic/truck emissions and the proximity of emission sources to sensitive receptors.
• Loss of plant and wildlife habitat.
• Lighting, noise, and wildlife-human interactions.
• Removal of wetlands or protected plant and animals.
• Potential impacts related to the inadvertent discovery of cultural, historical, or tribal resources at the project site.
• Use of hazardous materials, including rodenticides.
• Degradation of water quality in area waterways.
• Sufficiency of stormwater management.
• Increased and/or exacerbation of flood hazards due to changes in drainage patterns.
• Incompatibility with surrounding land uses.
• Consistency with LAFCo and City Sphere of Influence procedures. • Consistency with City and County General Plans, and Airport Land Use Compatibility Plan.
• Increase in noise levels to nearby residential areas.
3. REVISIONS TO THE DRAFT
EIR TEXT
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• Annexation into the Regional Sanitation and Sacramento Area Sewer District service area.
• Supply and capacity of water and wastewater facilities. • Traffic increases in the project vicinity.
• Increased traffic delays and congestion during commute hours. • Cumulative traffic impacts on the local and regional transportation system. • Hazards for pedestrians and cyclists associated with increased truck traffic. • Potential cumulative impacts in combination with the Metro Air Park. • Growth-inducing impacts.
• Override of the boundaries of the Sacramento County Urban Policy Area (UPA) and Urban Service Boundary (USB).
For clarification purposes, Table 2-1 in Chapter 2, Executive Summary, of the Draft EIR is hereby revised to reflect minor revisions made to Mitigation Measures 4.2-1, 4.3-1(a), 4.3-1(b), 4.3-3,
4.4-3, 4.4-5(b), 4.4-10(a), and 4.4-10(c) as part of this Final EIR, as presented throughout this chapter. Rather than include the entirety of Table 2-1 with revisions shown where appropriate, only the mitigation measure that has been revised is presented in this chapter. The revisions to Table 2-1 are for clarification purposes only and do not change the conclusions of the Draft EIR.
Please refer to the end of this chapter for Table 2-1.
4.2 AGRICULTURAL RESOURCES
Mitigation Measure 4.2-1, beginning on page 4.2-18 of Chapter 4.2, Agricultural Resources, of the Draft EIR is hereby revised as follows:
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4.2-1 The City shall ensure that, prior to impacting agricultural/open space resources within the project site by the issuance of a grading permit, any and all project-related subdivision maps satisfy the On-Site Open Space and Off-Site Open Space requirements as defined herein. Open space dedications made pursuant to the Natomas Basin Habitat Conservation Plan (HCP) shall be made to the City and/or the Natomas Basin Conservancy and shall be located in the Natomas Basin. The remaining non-Natomas Basin HCP mitigation acreage may be located in unincorporated Sacramento County, Yolo County, and/or Sutter County, and may be held and managed by a qualified third-party entity with the approval of the City. Preservation shall be ensured in perpetuity via conservation easement, fee, or irrevocable offer of dedication to the satisfaction of the City. All mitigation acreage shall consist of land of comparable agricultural and habitat value as the agricultural/open space resources impacted by the proposed project, as determined by the City. a. On-Site Agricultural/Open Space Requirements: The following onsite open space properties are consistent with the mitigation requirements:
• 86 acres of detention basins.
• 37.9 acres of freeway buffer.
• 2.3 acres of canal buffers.
b. Off-site Agricultural/Open Space Requirements: The following OffSite Open Space properties:
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• 141.51 acres of currently unidentified agricultural/open spaced mitigation property to be located in the unincorporated Sacramento County and/or unincorporated Sutter County.
• 50-acre habitat mitigation property APN 225-0020-014. • 67.59-acre habitat mitigation property APN 225-0020-015. c. Phasing: The Airport South Industrial Project will develop in phases, as such, the amount of On-Site and Off-Site Open Space to be provided hereunder shall be in proportion to the amount of acreage proposed to be impacted by such development by the issuance of a grading permit therefor.
d. With respect to each unidentified open space property listed above, and any proposed substitution of an open space property listed above, the City must determine, in writing, that the proposed agricultural/open space property and/or acreage satisfies the requirements for agricultural/open space to be counted towards the requisite Off-Site Agricultural/Open Space acreage total.
e. Nothing in this Agricultural/Open Space Mitigation is intended to limit or restrict USFWS and CDFW in their consideration of Developer's applications for incidental take and/or other habitat mitigation permits or other entitlements under the federal Endangered Species Act and the California Endangered Species Act.
4.3 AIR QUALITY, GREENHOUSE GAS EMISSIONS, AND ENERGY
Table 4.3-1 on page 4.3-3 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, has been revised as follows:
Table 4.3-1
Ambient Air Quality Standards
Pollutant Averaging Time CAAQS
NAAQS
Primary Secondary
Ozone 1 Hour 0.09 ppm - Same as primary 8 Hour 0.070 ppm 0.070 ppm Carbon
Monoxide
8 Hour 9 ppm 9 ppm - 1 Hour 20 ppm 35 ppm
Nitrogen Dioxide
Annual Mean 0.030 ppm 53 ppb Same as primary
1 Hour 0.18 ppm 100 ppb -
Sulfur Dioxide
24 Hour 0.04 ppm - -
3 Hour - - 0.5 ppm
1 Hour 0.25 ppm 75 ppb -
Respirable
Particulate
Matter (PM10)
Annual Mean 20 ug/m3 - Same as primary
24 Hour 50 ug/m3 150 ug/m3
Fine Particulate
Matter (PM2.5)
Annual Mean 12 ug/m3 12 9 ug/m3 15 ug/m3
24 Hour - 35 ug/m3 Same as primary
Lead 30 Day Average 1.5 ug/m3 - -
Calendar Quarter - 1.5 ug/m3 Same as primary
Sulfates 24 Hour 25 ug/m3 - -
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Table 4.3-1
Ambient Air Quality Standards
Pollutant Averaging Time CAAQS
NAAQS
Primary Secondary
Hydrogen
Sulfide 1 Hour 0.03 ppm - -
Vinyl Chloride 24 Hour 0.010 ppm - -
Visibility
Reducing
Particles
8 Hour (see note) - -
ppm = parts per million
ppb = parts per billion
µg/m3 = micrograms per cubic meter
Note: Statewide Visibility Reducing Particle Standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 0.23 per kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.
Source: California Air Resources Board. Ambient Air Quality Standards. May 4, 2016. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf. Accessed February 2024.
The foregoing revision is for clarification purposes only.
The following paragraphs on page 4.3-39 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, are hereby revised as follows for disclosure purposes only:
It should also be noted that emissions associated with heavy-duty trucks travelling to and from the project site were calculated off-model using project-specific trip generation rates provided by DKS, trip length data provided by Fehr and Peers for the Metro Air Park Project located just north of the project site, and vehicle emission factors from the CARB’s mobile source emissions inventory (EMFAC2021) model. Consistent with the Travel Behavior Memorandum prepared by Fehr and Peers for the Metro Air Park Project, an average length of 44.80 miles was assumed for heavy truck trips.1 EMFAC2021 was used to calculate all mobile-sourced emissions associated with heavy-duty vehicles.
In addition, the current carbon uptake rate associated with on-site agricultural biomass and soils was estimated to be 63 MTCO2e per acre based on the combined soil and biomass carbon factors for General Agricultural lands included in the Sacramento County Landscape Carbon Assessment (December 2017). Such emissions were added to the project operational emissions to account for the loss of the agricultural carbon uptake onsite.
The estimated emissions from CalEEMod and EMFAC2021 were added together to represent total project emissions, and were compared to the standards of significance discussed above in order to determine the associated level of impact. All CalEEMod results and EMFAC2021 calculations are included in Appendix C to this EIR.
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Table 4.3-7 on page 4.3-41 of the Draft EIR is hereby revised as follows:
Table 4.3-7
Maximum Unmitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 89.34 89.97 lbs/day 85 lbs/day YES
ROG 63.65 64.45 lbs/day - NO
PM10 67.97 68.33 lbs/day and
4.58 4.62 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.17 lbs/day and
1.31 1.32 tons/yr
82 lbs/day and 15
tons/yr* NO
Full Buildout of the Annexation Area
NOX 100.2 lbs/day 85 lbs/day YES
ROG 51.28 lbs/day - NO
PM10 75.17 lbs/day and
5.49 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.5 lbs/day and
1.56 tons/yr
82 lbs/day and 15
tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.
Source: CalEEMod, February August 2024.
Mitigation Measures 4.3-1(a) and 4.3-1(b), beginning on page 4.3-42, in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, have been revised as follows:
4.3-1(a) The following SMAQMD’s Basic Construction Emissions Control Practices (BMPs) for dust control shall be included through a notation on all project grading plans prior to the issuance of grading permits, to the satisfaction of the City of Sacramento Community Development Department and SMAQMD.
• Water all exposed surfaces two times daily. Exposed surfaces include, but are not limited to soil piles, graded areas, unpaved parking areas, staging areas, and access roads;
• Cover or maintain at least two feet of free board space on haul trucks transporting soil, sand, or other loose material on the site.
Any haul trucks that would be traveling along freeways or major roadways should be covered;
• Use wet power vacuum street sweepers to remove any visible trackout mud or dirt onto adjacent public roads at least once a day.
Use of dry power sweeping is prohibited;
• Limit vehicle speeds on unpaved roads to 15 miles per hour (mph);
• All roadways, driveways, sidewalks, parking lots to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used;
• Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes [CCR Title 13, Final EIR
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Sections 2449(d)(3) and 2485]. Provide clear signage that posts this requirement for workers at the entrances to the site; • Provide current certificate(s) of compliance for CARB’s In-Use OffRoad Diesel-Fueled Fleets Regulation [CCR Title 13, Sections 2449 and 2449.1]. For more information contact CARB at 877- 593-6677, [email protected], or
www.arb.ca.gov/doors/compliance_ cert1.html.; and
• Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determine to be running in proper condition before it is operated.
4.3-1(b) Prior to approval of any Improvement Plans, the project applicant shall provide proof of compliance with the following to the satisfaction of the City of Sacramento Community Development Department and SMAQMD:
The project applicant shall show on the plans via notation that the contractor shall ensure that the heavy-duty off-road vehicles (50 horsepower or more) to be used in the construction of all project components (i.e., construction of the industrial park,
nonparticipating parcels, and off-site force main), including owned, leased, and subcontractor vehicles, shall be a
combination of engine Tier 3 or Tier 4 off-road construction equipment, or hybrid, electric, or alternatively fueled equipment (or any combination of the above), sufficient to achieve a fleetwide average reduction in construction-related NOX emissions to below the applicable SMAQMD thresholds of significance (85 lbs/day). For instance, the emissions presented in Table 4.3-8 of the Draft EIR were achieved by requiring all equipment used during construction to be engine Tier 4.
In addition, all off-road equipment operating at the construction site must be maintained in proper working condition according to manufacturer’s specifications. Idling shall be limited to five minutes or less in accordance with the In-Use Off-Road Diesel Vehicle Regulation as required by CARB. Clear signage regarding idling restrictions shall be placed at the entrances to the construction site.
Portable equipment over 50 horsepower must have either a valid SMAQMD Permit to Operate (PTO) or a valid statewide Portable Equipment Registration Program (PERP) placard and sticker issued by CARB.
Conformance with the foregoing requirements shall be included as notes and be confirmed through review and approval of grading plans by the City of Sacramento Community Development
Department.
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Table 4.3-8 on page 4.3-43 of the Draft EIR is hereby revised as follows:
Table 4.3-8
Maximum Mitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 65.13 65.76 lbs/day 85 lbs/day NO
ROG 61.5 62.3 lbs/day - NO
PM10 66.74 67.11 lbs/day and
4.5 4.54 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 17.41 lbs/day and
1.24 1.25 tons/yr
82 lbs/day and 15
tons/yr* NO
Full Buildout of the Annexation Area
NOX 75.98 lbs/day 85 lbs/day NO
ROG 49.13 lbs/day - NO
PM10 73.95 lbs/day and
5.42 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 11.21 lbs/day and
1.49 tons/yr
82 lbs/day and 15
tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.
Source: CalEEMod, February August 2024.
Table 4.3-9 on page 4.3-46 of the Draft EIR is hereby revised as follows:
Table 4.3-9
Maximum Unmitigated Project Operational Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 628.33 629.08 lbs/day 65 lbs/day YES
ROG 172.37 174.21 lbs/day 65 lbs/day YES
PM10 32.99 33.05 lbs/day and
5.36 5.37 tons/yr
80 lbs/day and 14.6
tons/yr NO
PM2.5 17.91 17.98 lbs/day and
2.74 2.75 tons/yr
82 lbs/day and 15
tons/yr NO
Full Buildout of the Annexation Area
NOX 738.56 lbs/day 65 lbs/day YES
ROG 214.49 lbs/day 65 lbs/day YES
PM10 45.84 lbs/day and
7.68 tons/yr
80 lbs/day and 14.6
tons/yr NO
PM2.5 19.52 lbs/day and
3.07 tons/yr
82 lbs/day and 15
tons/yr NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.
Source: CalEEMod, February August 2024.
The following paragraphs under Impact 4.3-3 on page 4.3-53 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, are hereby revised as follows:
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Nonparticipating Parcels
The project site also includes six nonparticipating parcels, comprised of approximately 83 acres, that would result in an additional approximately 1,404,800 sf future industrial uses within the site. As discussed above, the CARB Handbook provides recommended setback distances for sensitive land uses from major sources of TACs, including distribution centers.
DPM is behaves like a highly dispersive gas, and concentrations of DPM decline rapidly with distance.3 Based on the CARB’s Handbook, an 80 percent drop-off in pollutant concentrations occurs at approximately 1,000 feet from a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week). Therefore, the CARB Handbook’s recommended setback distance for sensitive land uses from distribution centers is 1,000 feet.
The foregoing revision is for clarification purposes only and does not affect the conclusion of the analysis.
Due to a staff-initiated change, Mitigation Measure 4.3-3 on page 4.3-56 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy is hereby revised as follows:
4.3-3 If Parcel 8 (the 64.3-acre nonparticipating parcel owned by Cayocca) is proposed to be developed with a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week) within 1,000 feet of a sensitive receptor, prior to the issuance of any building permit, a Health Risk Assessment (HRA) shall be conducted to calculate the cancer risk associated with on-site truck diesel particulate matter (DPM) emissions.
The HRA shall be prepared in accordance with SMAQMD guidelines, as well as the guidelines identified in the California Office of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments. If health risks associated with Parcel 8 are determined to exceed the applicable SMAQMD thresholds, a qualified air quality consultant shall identify measures sufficient to reduce the project’s health risks to below the SMAQMD’s thresholds of significance. Reduction measures may include, but are not limited to, relocation of loading docks to further than 1,000 feet from sensitive receptors, electrification of the heavy-duty truck fleet, and/or other options as they become available.
Conformance with the foregoing requirement, including implementation of identified reduction measures, shall be confirmed through review and approval of the HRA by the City of Sacramento Community Development Department.
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Table 4.3-13 on page 4.3-64 of the Draft EIR is hereby revised as follows:
Table 4.3-13
Maximum Unmitigated On-Site Construction GHG Emissions – Proposed Project (MTCO2e/yr)
GHG Emissions
Threshold of
Significance
Exceeds
Threshold?
5,422.54 5,478.47 1,100 YES
Source: CalEEMod, June 2023 August 2024 (see Appendix C).
Table 4.3-15 on page 4.3-65 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, is hereby revised as follows:
Table 4.3-15
Unmitigated Annual Operational GHG Emissions (MTCO2e/yr) Emission Source Proposed Project
Full Buildout of
Annexation Area
Area 0.24 0.26
Energy 15,810.63 16,073.94 20,241.33
Mobile1 41,607.79 48,833.4
Offroad 2,893.68 4,411.25
Waste 3,375.85 4,251.88
Water 1,729.94 1,730.03 2,193.65
Loss of Carbon Uptake 17,767.89 22,996.89
TOTAL ANNUAL GHG EMISSIONS 65,418.13 83,449.42 102,298.66 1 Mobile emissions include both passenger vehicle emissions estimated in CalEEMod, as well as heavyduty vehicle emissions calculated off-model using EMFAC2021.
Sources:
• CalEEMod, June 2023; August 2024 (see Appendix C).
• Sacramento County Landscape Carbon Assessment, December 2017.
The foregoing revision is for disclosure purposes only and does not affect the conclusions of the analysis.
4.4 BIOLOGICAL RESOURCES
Figure 4.4-1 Study Areas on page 4.4-2 of Chapter 4.4, Biological Resources, of the Draft EIR has been revised to include additional clarification, as recommended by CDFW. As shown therein, Figure 4.4-1 clearly presents areas of the project site that are within or outside of the Natomas Basin HCP permit area, including corresponding acreages. Please refer to the end of this chapter for Figure 4.4-1.
Table 4.4-2, beginning on page 4.4-12, of the Draft EIR has been revised to show that northwestern pond turtle is now a federal candidate for listing. Please refer to the end of this chapter for Table 4.4-2.
Mitigation Measure 4.4-3, beginning on page 4.4-47 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:
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Industrial Park and Nonparticipating Parcels
4.4-3(a) Prior to the issuance of any grading permit and commencement of grounddisturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measures have been implemented:
Natomas Basin HCP Section V.A.5.a:
1. Within the Natomas Basin, all construction activity involving disturbance of habitat, such as site preparation and initial grading, is restricted to the period between May 1 and September 30. This is the active period for the giant garter snake and direct mortality is lessened, because snakes are expected to actively move and avoid danger.
2. Pre-construction surveys for giant garter snake, as well as other NBHCP Covered Species, must be completed for all development projects by a qualified biologist approved by USFWS. If any giant garter snake habitat is found within a specific site, the following additional measures shall be implemented to minimize
disturbance of habitat and harassment of giant garter snake, unless such project is specifically exempted by USFWS.
3. Between April 15 and September 30, all irrigation ditches, canals, or other aquatic habitat should be completely dewatered, with no puddled water remaining, for at least 15 consecutive days prior to the excavation or filling in of the dewatered habitat. Make sure dewatered habitat does not continue to support giant garter snake prey, which could detain or attract snakes into the area. If a site cannot be completely dewatered, netting and salvage of prey items may be necessary. This measure removes aquatic habitat component and allows giant garter snake to leave on their own.
4. For sites that contain giant garter snake habitat, no more than 24- hours prior to start of construction activities (site preparation and/or grading), the project area shall be surveyed for the presence of giant garter snake. If construction activities stop on the project site for a period of two weeks or more, a new giant garter snake survey shall be completed no more than 24-hours prior to the re-start of construction activities.
5. Confine clearing to the minimal area necessary to facilitate construction activities. Flag and designate avoided giant garter snake habitat within or adjacent to the project as Environmentally Sensitive Areas. This area shall be avoided by all construction personnel.
6. Construction personnel completing site preparation and grading operations shall receive USFWS approved environmental
awareness training. This training instructs workers on how to identify giant garter snakes and their habitats, and what to do if a giant garter snake is encountered during construction activities.
During this training an on-site biological monitor shall be designated.
7. If a live giant garter snake is found during construction activities, immediately notify the USFWS and the project’s biological monitor. The biological monitor, or his/her assignee, shall do the following:
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a. Stop construction in the vicinity of the snake. Monitor the snake and allow the snake to leave on its own. The
monitor shall remain in the area for the remainder of the work day to make sure the snake is not harmed or if it
leaves the site, does not return. Escape routes for giant garter snake should be determined in advance of
construction and snakes should always be allowed to
leave on their own. If a giant garter snake does not leave on its own within 1 working day, further consultation with USFWS is required.
8. Upon locating dead, injured or sick threatened or endangered wildlife species, the project applicant must notify within 1 working day the Service’s Division of Law Enforcement (2800 Cottage Way, Sacramento CA 95825) or the Sacramento Fish and Wildlife Office (2800 Cottage Way, Room W2605, Sacramento, CA 95825, telephone 916 414-6600). Written notification to both offices must be made within 3 calendar days and must include the date, time, and location of the finding of a specimen and any other pertinent information.
9. Fill or construction debris may be used by giant garter snake as an over-wintering site. Therefore, upon completion of construction activities remove any temporary fill and/or construction debris from the site. If this material is situated near undisturbed giant garter snake habitat and it is to be removed between October 1 and April 30, it shall be inspected by a qualified biologist to assure that giant garter snake are not using it as hibernaculae.
10. No plastic, monofilament, jute, or similar erosion control matting that could entangle snakes will be placed on a project site when working within 200 feet of snake aquatic or rice habitat. Possible substitutions include coconut coir matting, tactified hydroseeding compounds, or other material approved by the Wildlife Agencies.
4.4-3(b) To address potential impacts to giant garter snake on-site, but outside of the Natomas Basin HCP permit area, the project applicant shall retain a qualified biologist to conduct pre-construction surveys for giant garter snake prior to the issuance of any grading permit and commencement of project-related ground-disturbing activities outside of the Natomas Basin HCP Permit Area. If giant garter snake habitat is not identified on-site and giant garter snakes are not detected, the project may commence as scheduled. If giant garter snake habitat is found and/or giant garter snake individuals are detected, in areas outside of the Natomas Basin HCP Permit Area that would be impacted by the project, the project applicant shall either:
(1) Provide on- and or off-site preservation of giant garter snake habitat at a ratio determined by USFWS and CDFW, and as subject to regulatory permitting requirements of the CDFW, USACE, and or RWQCB, as prescribed by Mitigation Measures 4.4-10(a) through 4.4- 10(c) and 4.4-11(a) through 4.4-11(d), as applicable. Applicant purchase of conservation easements or fee title of lands shall be acceptable if approved by the applicable permit-issuing regulatory Final EIR
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agency. Final mitigation requirements shall be determined by the permit-issuing regulatory agency.
OR
(2) Should a portion of the City’s surplus HCP coverage be made available to the proposed project, the project applicant for development projects less than 50-acres in size shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities; otherwise, off-site land dedication and payment of NBHCP fees are required for project greater than 50-acres in size.
Mitigation Measure 4.4-5(b), beginning on page 4.4-53 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:
4.4-5(b) To address potential impacts to Swainson’s hawk foraging habitat that occurs on-site, but outside of the Natomas Basin HCP permit area, the project applicant shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities, should a portion of the City’s surplus HCP coverage be made available to the proposed project. preserve Swainson’s hawk foraging habitat off-site at a 1:1 ratio, which shall consist of a minimum 0.5:1 ratio habitat preservation off-site plus 0.5:1 ratio as prescribed by Mitigation Measure
4.2-1. The preserved habitat shall be provided through applicant purchase of conservation easements or fee title of lands with suitable Swainson’s hawk foraging habitat as approved by CDFW (consistent with CDFW guidelines). Additionally, prior to the issuance of any grading permit and commencement of project-related ground-disturbing activities outside of the Natomas Basin HCP permit area the project applicant shall consult with CDFW for a Section 2081 Incidental Take Permit, or demonstrate to the City that none was required by CDFW.
OR
Pursuant to CDFW guidelines, the applicant shall preserve Swainson’s hawk foraging habitat at a 0.5:1 ratio. The preserved habitat shall be at a location approved by the CDFW. Preservation may occur through purchase of conservation easements or fee title of lands with suitable Swainson’s hawk foraging habitat (consistent with CDFW guidelines).
Should a portion of the City’s surplus HCP coverage be made available to the proposed project, the project applicant shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities for development projects less than 50-acres in size; otherwise off-site land dedication and payment of NBHCP fees are required for projects greater than 50-acres in size.
Mitigation Measure 4.4-10(c) on page 4.4-63 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:
4.4-10(c) If a Sensitive Natural Community or potentially jurisdictional aquatic resource is identified in a nonparticipating parcel for which a development Final EIR
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application has been submitted, the applicant shall implement Mitigation Measure 4.4-10(a).
The following paragraph under Impact 4.4-14 on page 4.4-74 through 4.4-75 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:
Swainson’s Hawk Foraging Habitat
Based on the analysis in this chapter, the proposed project would reduce the overall upland land cover in the Natomas Basin that is capable of providing foraging habitat for Swainson’s hawk by approximately 436.5 340 acres (which does not include the 37.9 acre Caltrans I5 fee title ROW portion of the project site that does not provide Swainson’s hawk foraging habitat). The majority of the project’s development area is currently zoned for agriculture.
In addition, nearly all of the project site is not within outside of the Swainson’s Hawk Zone established by the Natomas Basin HCP. A relatively small and narrow, less than 175 feet wide strip of the southwest corner of the project site is within the Swainson’s Hawk Zone established by the Natomas Basin HCP. The area of the proposed project within the Swainson’s Hawk Zone would consist of a drainage basin and does not include any urban hardscape development (i.e., a building or parking lot), nor would the proposed project necessitate the removal of any trees. In addition, the Swainson’s Hawk Zone located immediately south of the project site contains Powerline Road, a paved roadway, as well as a farmhouse on the adjacent parcel. The Swainson’s Hawk Zone, where it overlays the project site, would remain in open space use, consistent with City requirements.
The foregoing revisions are for clarification purposes only and do not affect the conclusions of the analysis.
4.8 HYDROLOGY AND WATER QUALITY
The following paragraph on page 4.8-2 of Chapter 4.8, Hydrology and Water Quality, of the Draft EIR is hereby revised as follows:
According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) for the project area, the entirety of the project site is located within Zone A, which is designated as a Special Flood Hazard Area (SFHA) (see Figure 4.8-2). However, it should be noted that due to the levee improvements described above, portions of the Natomas Basin are now classified as A-99 flood zones, including the eastern portion of the project site. A-99 is an interim designation that allows new development to proceed without elevation verification while the improvements needed to provide 100-year protection are under construction. Effective July 1, 2024, new construction in Zone A-99 shall require Elevation Certificate or Floodproofing Certificate. However, the A-99 flood zone is still a SFHA until construction of the levees is complete, and the levees are certified by FEMA.
The following paragraph under Impact 4.8-2 on page 4.8-21 of Chapter 4.8, Hydrology and Water Quality, of the Draft EIR is hereby revised as follows:
The on-site stormwater drainage system would be controlled by a pump station currently planned to be located near the intersection of the RD 1000 L Drain and the proposed Airport South Industrial Drive. The pump station discharge capacity would be 35 cfs, modeled as two 17.5-cfs pumps. A low-flow pump may also be incorporated to maintain the flood control depth needed in the basin for the winter months, or as needed to keep the basins drawn down in the summer months. Low flow pumps are typically not operated during flood Final EIR
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control operations. The two basin areas on the east side of the RD 1000 L Drain would interconnect from south to north.
The following paragraph under Impact 4.8-3 on page 4.8-23 of Chapter 4.8, Hydrology and Water Quality, of the Draft EIR is hereby revised as follows:
Industrial Park and Nonparticipating Parcels
Upon annexation into the City as part of the proposed project, the City would be responsible for providing water to the project site the project site would be able to obtain water services from the City. The City’s water infrastructure network consists of two surface water treatment facilities, two pressure zones, and a supporting system of groundwater wells, pumping facilities, storage tanks, and distribution/transmission pipelines. As discussed in Chapter 4.11, Public Services, Utilities, and Service Systems, of this EIR, the City’s 2020 Urban Water Management Plan (UWMP) includes a water service reliability assessment of the City’s projected supplies and demands during normal, single dry, and five consecutive dry years. Under the various water year types, the total annual water supply sources available are compared to the total annual projected water use for the City’s water service area from 2025 to 2045 in five-year increments. As shown in Table 4.11-9 of this EIR, the City is projected to have a surplus of sufficient water supplies in all water year types through 2045. With respect to the demand anticipated to be generated by the proposed project, the Targeted Municipal Services Review (MSR) prepared for the proposed project incorporates results from the modeling conducted as part of the Preliminary Water Study prepared for the proposed project to estimate the project’s water demands, which are summarized in Table 4.11-10 of this EIR. As shown therein, the City’s existing water supplies would be able to accommodate the demand anticipated to be generated by the City’s existing commitments, as well as the water demand projected for the proposed project. Therefore, while a portion of the water supplied to the project site by the City would be obtained through groundwater resources, such groundwater usage would not substantially deplete groundwater supplies within the project area.
4.9 LAND USE AND PLANNING/POPULATION AND HOUSING
The analysis of the project’s consistency with LAFCo Policy I(6), beginning on page 4.9-21 in Table 4.9-6, Discussion of Relevant Sacramento LAFCo Policies, in Chapter 4.9-4, Land Use and Planning/Population and Housing, of the Draft EIR, is hereby revised as follows:
Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
Amendments to Spheres of Influence
6. Amendment proposals involving
Sphere expansion which contain
prime agricultural land will not be
approved by the LAFCo if there is
sufficient alternative land available
for annexation within the existing
Sphere of Influence.
As discussed in Chapter 4.2, Agricultural
Resources, of this EIR, Mitigation
Measure 4.2-1 requires the preservation
of off-site farmland at a ratio of one
Farmland acre converted to urban land
uses outside the Natomas Basin Habitat
Conservation Plan (HCP) policy area to
0.5-acre preserved, which, combined
with the biological resources mitigation
required by Mitigation Measure 4.4-5(b),
would result in an overall preservation at
a 1:1 ratio. However, while Mitigation
Measure 4.2-1 would preserve an
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Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
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. As such, the
proposed project would lead to an overall
loss of Farmland.
However, the proposed project is sited on
land in proximity to other similar industrial
uses (the Metro Air Park and Amazon
SMF-1 Fulfillment Center), and would not
require major extension of public services
and utilities, nor result in the deterioration
of existing service levels of providers that
would serve the project site. Furthermore,
due to the built-out nature of the City of
Sacramento, an alternate location within
the City City’s SOI is not currently
available to serve the proposed project.
As discussed further in Chapter 6,
Alternatives Analysis, of this EIR, the
location that comes closest to feasibility is
located northwest of the intersection of
Fruitridge Road and South Watt Avenue
in the southeast portion of the City, and
contains a portion of land already
designated for Industrial use by the
Sacramento General Plan. However, in
order to include a comparable amount of
acreage to the proposed project, the
alternative location would require the
demolition of several commercial
businesses, including, but not limited to, a
building materials store, furniture store,
and 7-Eleven convenience store. In
addition, approximately 117 acres of the
354 acres required of the alternative
would consist of land already set aside for
L and D Landfill. Furthermore, buildout of
the proposed project at the alternative
location would require a General Plan
Amendment (GPA) that would reduce the
amount of land designated for residential
development, as a portion of the site is
currently designated Traditional
Neighborhood Medium by the
Sacramento General Plan. As such,
buildout of the proposed project at an
alternative location within the City’s SOI is
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Table 4.9-6
Discussion of Relevant Sacramento LAFCo Policies
Policy Project Consistency
infeasible. Furthermore, buildout of the
site on alternative land outside, but
adjacent to, the City’s SOI would likely
result in similar conversion of Farmland
as the proposed project, given the
prevalence of agricultural land adjacent to
the City’s SOI. Therefore, sufficient
alternative land is not available for
Annexation within the City’s SOI to
accommodate the proposed project.
The above change is for clarification purposes and does not change the analysis or conclusions within the Draft EIR.
4.10 NOISE
The following paragraph under Impact 4.10-1 on page 4.10-16 in Chapter 4.10, Noise, of the Draft EIR is hereby revised as follows:
The noise increase during construction would be of short duration and would likely occur primarily during daytime hours. The City of Sacramento’s Noise Ordinance (Section 8.60.060 8.68.080[D] of the Municipal Code) exempts construction activities from the City’s noise standards, provided that construction takes place between the hours of 7:00 AM and 6:00 PM Monday through Saturday and 9:00 AM and 6:00 PM Sundays and holidays.
4.11 PUBLIC SERVICES, UTILITIES, AND SERVICE SYSTEMS
The following paragraph on page 4.11-6 of Chapter 4.11, Public Services, Utilities, and Service Systems, of the Draft EIR is hereby revised as follows:
Water Supply and Delivery Infrastructure
The project site is not currently provided potable water service, as the site does not contain structures necessitating water demand and has only limited utility infrastructure. Upon annexation into the City as part of the proposed project, the City would be responsible for providing water to the project site the project site would be able to obtain water services from the City. According to the Targeted MSR and as detailed in the City’s 2020 UWMP, the City of Sacramento is both a water retailer and a water wholesaler and maintains facilities that produce, treat, store, and deliver drinking water to customers. The City’s retail water service area is approximately 101 square miles and serves customers predominantly located within the City limits and foreseeable future City expansions. The City also serves a small number of customers outside its boundaries in an adjacent, unincorporated portion of Sacramento County.
been revised as follows:
Additionally, the City provides wholesale water service to other agencies from its entitlements, including the Sacramento County Water Agency (SCWA) (which includes the Final EIR
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Sacramento International Airport and SCWA Zone 40 41), Sacramento Suburban Water District, and California American Water.
The foregoing revision corrects a clerical error and is for clarification purposes only.
has been revised as follows:
With respect to groundwater, while the City’s wholesale agreements primarily rely on surface water, SCWA’s Sacramento International Airport and Metro Air Park service areas receive both surface water and groundwater from the City. The groundwater supply is pumped from the North American Subbasin.
The foregoing revision is for clarification purposes only.
The following paragraph under Impact 4.11-1 on pages 4.11-32 through 4.11-33 of Chapter 4.11, Public Services, Utilities, and Service Systems, of the Draft EIR, has been revised as follows:
General Plan Policies PFS-1.14, -1.15, and -1.16 establish the City’s commitment to ensuring the SFD has the necessary levels of facilities, apparatus, equipment, and staffing to provide adequate fire protection and emergency medical services within the department’s service area. The City funds the SFD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. In addition, new development within the City is subject to applicable development impact fees to ensure a fair-share contribution is made to finance the purchase of new or expansion of existing SFD facilities, apparatus, and equipment necessary for the purposes of maintaining adequate service levels. For example, the project site is currently contiguous with the City’s North Natomas Finance Plan Area. As part of project approval, the proposed project would be subject to the North Natomas Planning Area Development Fees. Pursuant to Sacramento City Code Section 18.24.050, the North Natomas Planning Area Public Facilities Fee is assessed at a rate of $238,272 per net acre for Convenience Commercial uses; $140,361 per net acre for Community Commercial uses; and between $49,752 and $57,527 per net acre for Light Industrial uses.
Thus, through payment of the North Natomas Planning Area Development Fees, buildout of the project site with the proposed uses would include a fair-share contribution to the City for the provision of SFD services to the site. As part of the project approval process, the proposed project must contribute its fair share to the City for fire facilities and equipment planned or constructed in the North Natomas Finance Plan area. This contribution will be based on the North Natomas fire fees and will be established in the Airport South Industrial Public Facilities Finance Plan.
The foregoing revision is for clarification purposes only.
The following paragraph under Impact 4.11-5 on page 4.11-39 of Chapter 4.11, Public Services, Utilities, and Service Systems, of the Draft EIR is hereby revised as follows:
It should be noted that as part of the proposed project, ownership and maintenance of 4700 linear feet of the existing 30-inch SCWA transmission main along the northern boundary of Parcel 5 would be transferred to the City of Sacramento. The transfer of the 30-inch water transmission main to the City from SCWA would require reimbursement to the County for the depreciated value of the transmission main. During plan review, additional discussion between the County, City, Sacramento International Airport, and the project applicant Final EIR
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would be required regarding the matter. If an agreement to which a parallel City water transmission main may need to be constructed as part of the development in lieu of acquiring the SCWA transmission main is not reached and the transfer of ownership of the 30-inch water transmission main does not occur, a revised design of the water system for the proposed project would be required.
The following paragraph under Impact 4.11-6 on page 4.11-44 of Chapter 4.11, Public Services, Utilities, and Service Systems, of the Draft EIR is hereby revised as follows:
Based on the data presented in Table 4.11-5, the Targeted MSR determined that the total average daily demand for the proposed project would be 313.54 AFY. As shown in Table
4.11-1, the City is anticipated to have a surplus of water supplies sufficient water supply in all hydrologic conditions through 2045, and the lowest projected surplus is expected to be 198,436 AFY in 2045 during the fifth consecutive year of drought. Therefore, given the substantial amount of surplus projected for the City’s water supplies in all hydrologic conditions, the City’s existing water supplies would be able to accommodate the demand anticipated to be generated by the City’s existing commitments, as well as the water demand projected for the proposed project.
APPENDIX L PRELIMINARY WATER STUDY
The title page of Appendix L to the Draft EIR, Airport South Industrial Preliminary Water Study, is hereby revised as follows:
NOTE TO FILE: The transfer of the 4700 linear feet of 30-inch water transmission main to the City from the Sacramento County Water Authority Agency will require reimbursement to the County for the depreciated value of the transmission main. As of January 19, 2024, the depreciated value of the water transmission main is estimated at $1,012,502.78. During plan review, additional discussion between the County, City, Sacramento International Airport and Developer will be required regarding this matter. If an agreement is not reached and the transfer of ownership of the 30-inch water t-main does not occur, a revised design of the water system for the Airport South Industrial will be required.
The foregoing revision is for clarification purposes only and does not affect the analysis of the Draft EIR.
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
4.2 Agricultural Resources
4.2-1 Impacts related to the conversion
of Prime Farmland, Unique
Farmland, or Farmland of
Statewide Importance to nonagricultural use.
S Industrial Park
4.2-1 The City shall ensure that, prior to impacting
agricultural/open space resources within the project
site by the issuance of a grading permit, any and all
project-related subdivision maps satisfy the On-Site
Open Space and Off-Site Open Space requirements
as defined herein. Open space dedications made
pursuant to the Natomas Basin Habitat Conservation
Plan (HCP) shall be made to the City and/or the
Natomas Basin Conservancy and shall be located in
the Natomas Basin. The remaining non-Natomas
Basin HCP mitigation acreage may be located in
unincorporated Sacramento County, Yolo County,
and/or Sutter County, and may be held and managed
by a qualified third-party entity with the approval of
the City. Preservation shall be ensured in perpetuity
via conservation easement, fee, or irrevocable offer
of dedication to the satisfaction of the City. All
mitigation acreage shall consist of land of
comparable agricultural and habitat value as the
agricultural/open space resources impacted by the
proposed project, as determined by the City.
a. On-Site Agricultural/Open Space
Requirements: The following on-site open
space properties are consistent with the
mitigation requirements:
• 86 acres of detention basins.
SU
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Table 2-1
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Impact
Level of
Significance
Prior to
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Level of
Significance
After
Mitigation
• 37.9 acres of freeway buffer.
• 2.3 acres of canal buffers.
b. Off-site Agricultural/Open Space
Requirements: The following Off-Site Open
Space properties:
• 141.51 acres of currently
unidentified agricultural/open
spaced mitigation property to be
located in the unincorporated
Sacramento County and/or
unincorporated Sutter County.
• 50-acre habitat mitigation property
APN 225-0020-014.
• 67.59-acre habitat mitigation
property APN 225-0020-015.
c. Phasing: The Airport South Industrial
Project will develop in phases, as such, the
amount of On-Site and Off-Site Open Space
to be provided hereunder shall be in
proportion to the amount of acreage
proposed to be impacted by such
development by the issuance of a grading
permit therefor.
d. With respect to each unidentified open
space property listed above, and any
proposed substitution of an open space
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
property listed above, the City must
determine, in writing, that the proposed
agricultural/open space property and/or
acreage satisfies the requirements for
agricultural/open space to be counted
towards the requisite Off-Site
Agricultural/Open Space acreage total.
e. Nothing in this Agricultural/Open Space
Mitigation is intended to limit or restrict
USFWS and CDFW in their consideration of
Developer's applications for incidental take
and/or other habitat mitigation permits or
other entitlements under the federal
Endangered Species Act and the California
Endangered Species Act.
4.3 Air Quality, Greenhouse Gas Emissions, and Energy
4.3-1 Conflict with or obstruct
implementation of the applicable
air quality plan during project
construction.
S 4.3-1(a) The following SMAQMD’s Basic Construction
Emissions Control Practices (BMPs) for dust control
shall be included through a notation on all project
grading plans prior to the issuance of grading
permits, to the satisfaction of the City of Sacramento
Community Development Department and
SMAQMD.
• Water all exposed surfaces two times daily.
Exposed surfaces include, but are not limited
to soil piles, graded areas, unpaved parking
areas, staging areas, and access roads;
• Cover or maintain at least two feet of free
board space on haul trucks transporting soil,
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
sand, or other loose material on the site. Any
haul trucks that would be traveling along
freeways or major roadways should be
covered;
• Use wet power vacuum street sweepers to
remove any visible trackout mud or dirt onto
adjacent public roads at least once a day. Use
of dry power sweeping is prohibited;
• Limit vehicle speeds on unpaved roads to 15
miles per hour (mph);
• All roadways, driveways, sidewalks, parking
lots to be paved should be completed as soon
as possible. In addition, building pads should
be laid as soon as possible after grading
unless seeding or soil binders are used;
• Minimize idling time either by shutting
equipment off when not in use or reducing the
time of idling to 5 minutes [CCR Title 13,
Sections 2449(d)(3) and 2485]. Provide clear
signage that posts this requirement for
workers at the entrances to the site;
• Provide current certificate(s) of compliance for
CARB’s In-Use Off-Road Diesel-Fueled
Fleets Regulation [CCR Title 13, Sections
2449 and 2449.1]. For more information
contact CARB at 877-593-6677,
[email protected], or
www.arb.ca.gov/doors/compliance_
cert1.html.; and
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
• Maintain all construction equipment in proper
working condition according to manufacturer’s
specifications. The equipment must be
checked by a certified mechanic and
determine to be running in proper condition
before it is operated.
4.3-1(b) Prior to approval of any Improvement Plans, the project applicant shall provide proof of compliance
with the following to the satisfaction of the City of
Sacramento Community Development Department
and SMAQMD:
The project applicant shall show on the plans via
notation that the contractor shall ensure that the
heavy-duty off-road vehicles (50 horsepower or
more) to be used in the construction of all project
components (i.e., construction of the industrial
park, nonparticipating parcels, and off-site force
main), including owned, leased, and
subcontractor vehicles, shall be a combination of
engine Tier 3 or Tier 4 off-road construction
equipment, or hybrid, electric, or alternatively
fueled equipment (or any combination of the
above), sufficient to achieve a fleet-wide average
reduction in construction-related NOX emissions
to below the applicable SMAQMD thresholds of
significance (85 lbs/day). For instance, the
emissions presented in Table 4.3-8 of the Draft
EIR were achieved by requiring all equipment
used during construction to be engine Tier 4.
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
In addition, all off-road equipment operating at the
construction site must be maintained in proper
working condition according to manufacturer’s
specifications. Idling shall be limited to five
minutes or less in accordance with the In-Use OffRoad Diesel Vehicle Regulation as required by CARB. Clear signage regarding idling restrictions
shall be placed at the entrances to the
construction site.
Portable equipment over 50 horsepower must
have either a valid SMAQMD Permit to Operate
(PTO) or a valid statewide Portable Equipment
Registration Program (PERP) placard and sticker
issued by CARB.
Conformance with the foregoing requirements
shall be included as notes and be confirmed
through review and approval of grading plans by
the City of Sacramento Community Development
Department.
4.3-3 Expose sensitive receptors to
substantial pollutant
concentrations.
S 4.3-3 If Parcel 8 (the 64.3-acre nonparticipating parcel owned by Cayocca) is proposed to be developed with
a distribution center (i.e., an industrial warehouse
that accommodates more than 100 heavy-duty trucks
per day, more than 40 trucks with operating transport
refrigeration units [TRUs] per day, or where TRU unit
operations exceed 300 hours per week) within 1,000
feet of a sensitive receptor, prior to the issuance of
any building permit, a Health Risk Assessment (HRA)
shall be conducted to calculate the cancer risk
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
associated with on-site truck diesel particulate matter (DPM) emissions.
The HRA shall be prepared in accordance with
SMAQMD guidelines, as well as the guidelines
identified in the California Office of Environmental
Health Hazard Assessment (OEHHA) Guidance
Manual for Preparation of Health Risk Assessments.
If health risks associated with Parcel 8 are
determined to exceed the applicable SMAQMD
thresholds, a qualified air quality consultant shall
identify measures sufficient to reduce the project’s
health risks to below the SMAQMD’s thresholds of
significance. Reduction measures may include, but
are not limited to, relocation of loading docks to
further than 1,000 feet from sensitive receptors,
electrification of the heavy-duty truck fleet, and/or
other options as they become available.
Conformance with the foregoing requirement,
including implementation of identified reduction
measures, shall be confirmed through review and
approval of the HRA by the City of Sacramento
Community Development Department.
4.4 Biological Resources
4.4-3 Have a substantial adverse
effect, either directly or through
habitat modifications, on giant
garter snake.
S Industrial Park and Nonparticipating Parcels
4.4-3(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the
project applicant shall ensure that the following
Natomas Basin HCP Take Avoidance, Minimization,
and Mitigation Measures have been implemented:
LS
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Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
Natomas Basin HCP Section V.A.5.a:
1. Within the Natomas Basin, all construction
activity involving disturbance of habitat, such
as site preparation and initial grading, is
restricted to the period between May 1 and
September 30. This is the active period for the
giant garter snake and direct mortality is
lessened, because snakes are expected to
actively move and avoid danger.
2. Pre-construction surveys for giant garter
snake, as well as other NBHCP Covered
Species, must be completed for all
development projects by a qualified biologist
approved by USFWS. If any giant garter
snake habitat is found within a specific site,
the following additional measures shall be
implemented to minimize disturbance of
habitat and harassment of giant garter snake,
unless such project is specifically exempted
by USFWS.
3. Between April 15 and September 30, all
irrigation ditches, canals, or other aquatic
habitat should be completely dewatered, with
no puddled water remaining, for at least 15
consecutive days prior to the excavation or
filling in of the dewatered habitat. Make sure
dewatered habitat does not continue to
support giant garter snake prey, which could
detain or attract snakes into the area. If a site
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
cannot be completely dewatered, netting and
salvage of prey items may be necessary. This
measure removes aquatic habitat component
and allows giant garter snake to leave on their
own.
4. For sites that contain giant garter snake
habitat, no more than 24-hours prior to start of
construction activities (site preparation and/or
grading), the project area shall be surveyed
for the presence of giant garter snake. If
construction activities stop on the project site
for a period of two weeks or more, a new giant
garter snake survey shall be completed no
more than 24-hours prior to the re-start of
construction activities.
5. Confine clearing to the minimal area
necessary to facilitate construction activities.
Flag and designate avoided giant garter snake
habitat within or adjacent to the project as
Environmentally Sensitive Areas. This area
shall be avoided by all construction personnel.
6. Construction personnel completing site
preparation and grading operations shall
receive USFWS approved environmental
awareness training. This training instructs
workers on how to identify giant garter snakes
and their habitats, and what to do if a giant
garter snake is encountered during
construction activities. During this training an
on-site biological monitor shall be designated.
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Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
7. If a live giant garter snake is found during
construction activities, immediately notify the
USFWS and the project’s biological monitor.
The biological monitor, or his/her assignee,
shall do the following:
a. Stop construction in the vicinity of
the snake. Monitor the snake and
allow the snake to leave on its own.
The monitor shall remain in the area
for the remainder of the work day to
make sure the snake is not harmed
or if it leaves the site, does not
return. Escape routes for giant garter
snake should be determined in
advance of construction and snakes
should always be allowed to leave
on their own. If a giant garter snake
does not leave on its own within 1
working day, further consultation
with USFWS is required.
8. Upon locating dead, injured or sick threatened
or endangered wildlife species, the project
applicant must notify within 1 working day the
Service’s Division of Law Enforcement (2800
Cottage Way, Sacramento CA 95825) or the
Sacramento Fish and Wildlife Office (2800
Cottage Way, Room W2605, Sacramento, CA
95825, telephone 916 414-6600). Written
notification to both offices must be made
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Table 2-1
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Level of
Significance
Prior to
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Level of
Significance
After
Mitigation
within 3 calendar days and must include the
date, time, and location of the finding of a
specimen and any other pertinent information.
9. Fill or construction debris may be used by
giant garter snake as an over-wintering site.
Therefore, upon completion of construction
activities remove any temporary fill and/or
construction debris from the site. If this
material is situated near undisturbed giant
garter snake habitat and it is to be removed
between October 1 and April 30, it shall be
inspected by a qualified biologist to assure
that giant garter snake are not using it as
hibernaculae.
10. No plastic, monofilament, jute, or similar
erosion control matting that could entangle
snakes will be placed on a project site when
working within 200 feet of snake aquatic or
rice habitat. Possible substitutions include
coconut coir matting, tactified hydroseeding
compounds, or other material approved by the
Wildlife Agencies.
4.4-3(b) To address potential impacts to giant garter snake on-site, but outside of the Natomas Basin HCP permit
area, the project applicant shall retain a qualified
biologist to conduct pre-construction surveys for giant garter snake prior to the issuance of any grading
permit and commencement of project-related grounddisturbing activities outside of the Natomas Basin HCP Permit Area. If giant garter snake habitat is not
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
identified on-site and giant garter snakes are not
detected, the project may commence as scheduled.
If giant garter snake habitat is found and/or giant
garter snake individuals are detected, in areas
outside of the Natomas Basin HCP Permit Area that
would be impacted by the project, the project
applicant shall either:
(1) Provide on- and or off-site preservation of giant
garter snake habitat at a ratio determined by
USFWS and CDFW, and as subject to
regulatory permitting requirements of the
CDFW, USACE, and or RWQCB, as prescribed
by Mitigation Measures 4.4-10(a) through 4.4-
10(c) and 4.4-11(a) through 4.4-11(d), as
applicable. Applicant purchase of conservation
easements or fee title of lands shall be
acceptable if approved by the applicable permitissuing regulatory agency. Final mitigation requirements shall be determined by the permitissuing regulatory agency.
OR
(2) Should a portion of the City’s surplus HCP
coverage be made available to the proposed
project, the project applicant for development
projects less than 50-acres in size shall pay the
Natomas Basin HCP mitigation fees for land
acquisition, enhancement, and management
and monitoring activities; otherwise, off-site land
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Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
dedication and payment of NBHCP fees are
required for project greater than 50-acres in
size.
4.4-5 Have a substantial adverse
effect, either directly or through
habitat modifications, on
Swainson’s hawk.
S Industrial Park and Nonparticipating Parcels
4.4-5(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the
project applicant shall ensure that the following
Natomas Basin HCP Take Avoidance, Minimization,
and Mitigation Measure has been implemented:
Natomas Basin HCP Section V.A.5.b:
Measures to Reduce Nest Disturbance
1. Prior to the commencement of development
activities, a pre-construction survey shall be
completed to determine whether any
Swainson’s hawk nest trees will be removed
on-site, or active Swainson’s hawk nest sites
occur on or within ½ mile of the development
site. These surveys shall be conducted
according to the Swainson’s Hawk Technical
Advisory Committee’s (May 31, 2000)
methodology or updated methodologies, as
approved by the Service and CDFG, using
experienced Swainson’s hawk surveyors.
2. If breeding Swainson’s hawks (i.e. exhibiting
nest building or nesting behavior) are
identified, no new disturbances (e.g., heavy
equipment operation associated with
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Table 2-1
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Prior to
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Level of
Significance
After
Mitigation
construction) will occur within ½ mile of an
active nest between March 15 and
September 15, or until a qualified biologist,
with concurrence by CDFG, has determined
that young have fledged or that the nest is no
longer occupied. If the active nest site is
located within 1/4 mile of existing urban
development, the no new disturbance zone
can be limited to the ¼ mile versus ½ mile.
Routine disturbances such as agricultural
activities, commuter traffic, and routine
facility maintenance activities within ½ mile of
an active nest are not restricted.
3. Where disturbance of a Swainson’s hawk
nest cannot be avoided, such disturbance
shall be temporarily avoided (i.e., defer
construction activities until after the nesting
season) and then, if unavoidable, the nest
tree may be destroyed during the nonnesting season. For purposes of this provision the Swainson's hawk nesting
season is defined as March 15 to September
15. If a nest tree (any tree that has an active
nest in the year the impact is to occur) must
be removed, tree removal shall only occur
between September 15 and February 1.
4. If a Swainson’s hawk nest tree is to be
removed and fledglings are present, the tree
may not be removed until September 15 or
until the California Department of Fish and
Game has concurred that the young have
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Table 2-1
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Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
fledged and are no longer dependent upon
the nest tree.
5. If construction or other project related
activities which may cause nest
abandonment or forced fledgling are
proposed within the ¼ mile buffer zone,
intensive monitoring (funded by the project
sponsor) by a Department of Fish and Game
approved raptor biologist will be required.
Exact implementation of this measure will be
based on specific information at the project
site.
4.4-5(b) To address potential impacts to Swainson’s hawk foraging habitat that occurs on-site, but outside of the Natomas Basin HCP permit area, the project
applicant shall pay the Natomas Basin HCP
mitigation fees for land acquisition, enhancement,
and management and monitoring activities, should a
portion of the City’s surplus HCP coverage be made
available to the proposed project. preserve
Swainson’s hawk foraging habitat off-site at a 1:1
ratio, which shall consist of a minimum 0.5:1 ratio
habitat preservation off-site plus 0.5:1 ratio as
prescribed by Mitigation Measure 4.2-1. The
preserved habitat shall be provided through applicant
purchase of conservation easements or fee title of
lands with suitable Swainson’s hawk foraging habitat
as approved by CDFW (consistent with CDFW
guidelines). Additionally, prior to the issuance of any grading permit and commencement of project-related
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
ground-disturbing activities outside of the Natomas
Basin HCP permit area the project applicant shall
consult with CDFW for a Section 2081 Incidental
Take Permit, or demonstrate to the City that none
was required by CDFW.
OR
Pursuant to CDFW guidelines, the applicant shall
preserve Swainson’s hawk foraging habitat at a 0.5:1
ratio. The preserved habitat shall be at a location
approved by the CDFW. Preservation may occur
through purchase of conservation easements or fee
title of lands with suitable Swainson’s hawk foraging
habitat (consistent with CDFW guidelines). Should a
portion of the City’s surplus HCP coverage be made
available to the proposed project, the project
applicant shall pay the Natomas Basin HCP
mitigation fees for land acquisition, enhancement,
and management and monitoring activities for
development projects less than 50-acres in size;
otherwise off-site land dedication and payment of
NBHCP fees are required for projects greater than
50-acres in size.
4.4-10 Have a substantial adverse effect
on any riparian habitat or other
Sensitive Natural Community
identified in local or regional
plans, policies, regulations or by
the CDFW or USFWS.
S Industrial Park
4.4-10(a) Prior to the commencement of ground-disturbing activities, the project applicant shall notify CDFW,
pursuant to CFGC Section 1600. The notification
shall include a description of all of the activities
associated with the proposed industrial park, not just
LS
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
those associated with the drainages and/or riparian
vegetation. Impacts shall be outlined in the
notification and are expected to be in substantial
conformance with the impacts to biological resources
outlined in the Biological Resources Assessment
prepared for the Airport South Industrial Project by
Bargas Environmental Consulting. Impacts for each
activity shall be broken down by temporary and
permanent impacts. A description of the proposed
mitigation for biological resource impacts shall be
outlined per activity and then by temporary and
permanent impact. Information regarding projectspecific drainage and hydrology changes resulting from project implementation shall be provided, as well
as a description of stormwater treatment methods.
Minimization and avoidance measures shall be
proposed, as appropriate, and may include
preconstruction species surveys and reporting,
protective fencing around avoided biological
resources, worker environmental awareness training,
seeding disturbed areas adjacent to open space
areas with native seed, and installation of projectspecific stormwater Best Management Practices (BMPs). Mitigation for impacts to Goodding’s willow –
red willow riparian woodland and forest, valley oak
riparian forest woodland, and California bulrush
marsh may include restoration or enhancement of
resources on- or off-site, or any other method
acceptable to CDFW. Mitigation shall not result in a
net loss of a Sensitive Natural Community.
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
If CDFW determines through the course of the CFGC
Section 1600 notification process that the project
does not require a Lake or Streambed Alteration
Agreement (LSAA) to address potential impacts to
Goodding’s willow – red willow riparian woodland and
forest, valley oak riparian forest woodland, and
California bulrush marsh, further mitigation regarding
the aforementioned vegetation communities shall not
be required. Written verification of the applicant’s
compliance with the Section 1600 LSAA process
shall be submitted to the City of Sacramento
Community Development Department.
Nonparticipating Parcels
4.4-10(b) As part of any application associated with
development of the nonparticipating parcels, the
applicant shall ensure that a qualified biologist has
reviewed areas proposed for disturbance to identify
vegetation communities that occur in the
development footprint and confirm the presence and
acreages of Sensitive Natural Communities. If a
Sensitive Natural Community would not be impacted,
further mitigation shall not be required. The qualified biologist shall detail any recommendations to avoid
impacts to identified Sensitive Natural Communities
in a report, which shall be submitted for review and
approval to the City of Sacramento Community
Development Department.
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 2-1
Summary of Impacts and Mitigation Measures
Impact
Level of
Significance
Prior to
Mitigation Mitigation Measures
Level of
Significance
After
Mitigation
4.4-10(c) If a Sensitive Natural Community or potentially jurisdictional aquatic resource is identified in a
nonparticipating parcel for which a development
application has been submitted, the applicant shall
implement Mitigation Measure 4.4-10(a).
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Figure 4.4-1
Study Areas
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Plants
Centromadia parryi ssp.
parryi
Pappose tarplant
-- CRPR 1B.2 No
Occurs in chaparral, coastal
prairie, marshes and swamps,
meadows and seeps, valley and
foothill grassland at elevations
ranging from sea level to 1,380
feet. Blooms from May to
November.
Low. Habitat within the project site is
considered low quality. The nearest
records of the species are 8.5 miles to
the southwest of the project site.
Ongoing agriculture-related site
disturbance limits the potential for
species to occur.
Lepidium latipes var.
heckardii
Heckard’s pepper-grass
-- CRPR 1B.2 No
Occurs in valley and foothill
grassland at elevations ranging
from five to 655 feet. Blooms from
March to May.
Low. Habitat within the project site is
considered low quality. The nearest
extant occurrence is 7.5 miles to the
southwest of the project site. Ongoing
agriculture-related site disturbance limits
the potential for species to occur.
Extriplex joaquinana
San Joaquin spearscale -- CRPR 1B.2 No
Occurs in chenopod scrub,
meadows and seeps, playas, and
valley and foothill grassland at
elevations ranging from five to
2,740 feet. Blooms from April to
October.
Low. Habitat within the project site is
considered low quality. The nearest
records are 7.5 miles to the west of the
project site. Ongoing agriculture-related
site disturbance limits the potential for
species to occur.
Hibiscus lasiocarpos var.
occidentalis
Woolly rose-mallow
-- CRPR 1B.2 No
Occurs in marshes and swamps
at elevations ranging from sea
level to 395 feet. Blooms from
June to September.
Low. Habitat within the project site is
considered low quality. The nearest
record is at the margins of a canal.
Ongoing agriculture-related site
disturbance limits the potential for
species to occur.
Chloropyron palmatum
Palmate-bracted bird’s
beak
FE CE, CRPR
1B.1
No Occurs in chenopod scrub, as
well as valley and foothill
grassland, at elevations ranging
from 15 to 510 feet. Blooms from
May to October.
Low. Habitat within the project site is
considered low quality. The nearest
records are 7.5 miles to the west of the
project site. Ongoing agriculture-related
site disturbance limits the potential for
species to occur.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Sagittaria sanfordii
Sanford’s arrowhead -- CRPR 1B.2 Yes
Occurs in marshes and swamps
at elevations ranging from sea
level to 2,135 feet. Blooms from
May to October.
Low. Habitat within the project site is
considered low quality. The species is
known to occur along roadside ditches
and canals; however, all records are to
the east and southeast of the project site
and appear to be at the edge or outside
of the species’ distribution. Ongoing
agriculture-related site disturbance limits
the potential for species to occur.
Symphyotrichum lentum
Suisun marsh aster -- CRPR 1B.2 No
Occurs in marshes and swamps
at elevations ranging from sea
level to 10 feet. Blooms from May
to November.
No potential. Habitat is not present
within the project site.
Downingia pusilla
Dwarf downingia -- CRPR 2B.2 No
Occurs in valley and foothill
grassland and vernal pools at
elevations ranging from five to
1,460 feet. Blooms from March to
May.
No potential. Habitat is not present
within the project site.
Legenere limosa
Legenere -- CRPR 1B.1 Yes
Occurs in vernal pools at
elevations ranging from five to
2,885 feet. Blooms from April to
June.
No potential. Habitat is not present
within the project site.
Atriplex cordulata var.
cordulata
Heartsacle
-- CRPR 1B.2 No
Occurs in chenopod scrub,
meadows and seeps, and valley
and foothill grassland at
elevations ranging from sea level
to 1,835 feet. Blooms from April to
October.
No potential. Habitat is not present
within the project site.
Atriplex depressa
Brittlescale -- CRPR 1B.2
No Occurs in chenopod scrub,
meadows and seeps, playas,
valley and foothill grassland, and
vernal pools at elevations ranging
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
from five to 1,050 feet. Blooms
from April to October.
Astragalus tener var.
ferrisiae
Ferris' milk-vetch
-- CRPR 1B.1 No
Meadows and seeps and valley
and foothill grassland at
elevations ranging from five to
245 feet. Blooms from April to
May.
No potential. Habitat is not present
within the project site.
Astragalus tener var.
tener
Alkali milk-vetch
-- CRPR 1B.2 No
Occurs in playas, valley and
foothill grassland, and vernal
pools at elevations ranging from
five to 195 feet. Blooms from
March to June.
No potential. Habitat is not present
within the project site.
Lathyrus jepsonii var.
jepsonii
Delta tule pea
-- CRPR 1B.2 Yes
Occurs in marshes and swamps
at elevations ranging from sea
level to 15 feet. Blooms from May
to July.
No potential. Habitat is not present
within the project site.
Trifolium hydrophilum
Saline clover -- CRPR 1B.2 No
Occurs in marshes and swamps,
valley and foothill grassland, and
vernal pools at elevations ranging
from sea level to 985 feet. Blooms
from April to June.
No potential. Habitat is not present
within the project site.
Gratiola heterosepala
Boggs Lake hedgehyssop-- CE, CRPR
1B.2 Yes
Occurs in marshes and swamps
(lake margins), and vernal pools
at elevations ranging from 35 to
7,790 feet. Blooms from April to
August.
No potential. Habitat is not present
within the project site.
Neostapfia colusana
Colusa grass FT CE, CRPR
1B.1 Yes
Occurs in vernal pools at
elevations ranging from 15 to 655
feet. Blooms from May to August.
No potential. Habitat is not present
within the project site.
Orcuttia tenuis
Slender Orcutt grass FT CE, CRPR
1B.1 Yes
Occurs in vernal pools at
elevations ranging from 115 to
5,775 feet. Blooms from May to
September.
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Orcuttia viscida
Sacramento Orcutt grass FE CE, CRPR
1B.1 Yes
Occurs in vernal pools at
elevations ranging from 100 to
330 feet. Blooms from April to
July.
No potential. Habitat is not present
within the project site.
Puccinellia simplex
California alkali grass -- CRPR 1B.2 No
Occurs in chenopod scrub,
meadows and seeps, valley and
foothill grassland, and vernal
pools at elevations ranging from
five to 3,050 feet. Blooms from
March to May.
No potential. Habitat is not present
within the project site.
Invertebrates
Bombus crotchii
Crotch’s bumble bee -- CC No
Occurs in open grasslands and
scrub habitats. This species
occurs primarily in California,
including the Mediterranean
region, Pacific Coast, Western
Desert, Great Valley, and
adjacent foothills through most of
southwestern California. The
species was historically common
in the Central Valley of California,
but now appears to be absent
from most of the region,
especially in the center of its
historic range.
No potential. The ongoing agriculturerelated site disturbance precludes suitable habitat to accommodate the
species from occurring on-site.
Danaus plexippus
Monarch butterfly FC -- No
A migratory species that is most
prevalent in the Central Valley in
summer and early fall. Dependent
upon milkweed (Asclepias
species) plants as their exclusive
larval host.
Low. Habitat within the project site is
considered low quality. The nearest
records are 38 miles to the southwest of
the project site; however, as a migratory
species with flight capability, the
monarch butterfly has potential to occur
anywhere during movements. Ongoing
agriculture-related site disturbance and
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
lack of suitable host plants limit the
potential for species to occur.
Branchinecta lynchi
Vernal pool fairy shrimp FT -- Yes
Commonly observed in grass or
mud-bottomed swales, earth
sump, or basalt flow depression
pools in unplowed grasslands.
No potential. Habitat is not present
within the project site.
Branchinecta
mesovallensis
Midvalley fairy shrimp
-- -- Yes
Found in vernal pools, vernal
swales, and ephemeral wetlands
in the Central Valley.
No potential. Habitat is not present
within the project site.
Lepidurus packardi
Vernal pool tadpole
shrimp
FE -- Yes
Inhabits vernal pools and swales
containing clear to highly turbid
water.
No potential. Habitat is not present
within the project site.
Desmocerus californicus
dimorphus
Valley elderberry
longhorn beetle
FT -- Yes
Endemic to the Central Valley.
Found only in association with the
species’ host plant, the elderberry
(Sambucus spp.)
No potential. Habitat is not present
within the project site.
Fish
Acipenser medirostris
Green Sturgeon –
Southern DPS
FT CSC No
Originate from coastal watersheds
south of the Eel River, with the
only known spawning population
in the Sacramento River. Adults
begin spawning migrations in late
February. Spawning occurs from
March to July, with peak activity
from mid-April to mid-June.
No potential. Habitat is not present
within the project site.
Oncorhynchus mykiss
irideus
Central Valley steelhead
DPS
FT -- No
Anadromous species requiring
freshwater water courses with
gravelly substrates for breeding.
Originates below natural and
manmade, impassable barriers
from the Sacramento and San
Joaquin rivers and their
tributaries. The young remain in
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
freshwater areas before
migrating to estuarine and
marine environments.
Oncorhynchus
tshawytscha
Central Valley spring-run
chinook Salmon ESU
FT CT No
Adult Central Valley spring-run
chinook salmon leave the ocean
to begin their upstream migration
in late January and early February
and enter the Sacramento River
between March and September,
primarily in May and June.
Spawning normally occurs
between mid-August and early
October, peaking in September.
No potential. Habitat is not present
within the project site.
Oncorhynchus
tshawytscha
Sacramento River
winter-run chinook
Salmon ESU
FE CE No
Adult winter-run chinook salmon
upstream spawning migration
through the Sacramento/San
Joaquin Delta (Delta) and into the
lower Sacramento River occurs
from December through July, with
a peak during the period
extending from January through
April. Spawning occurs between
late-April and mid-August, with a
peak in June and July.
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Hypomesus
transpacificus
Delta smelt
FT CE No
Endemic to California and occurs
only in the San Francisco Estuary.
The Delta Smelt life cycle follows
the four seasons: spring spawning
in freshwater, summer
migration/rearing in the lowsalinity zone, fall maturation in the low-salinity zone, and winter
upstream migration shortly before
spawning.
No potential. Habitat is not present
within the project site.
Spirinchus thaleichthys
Longfin smelt FC CT No
In California, longfin smelt has
been historically found in the San
Francisco Estuary and the Delta,
Humboldt Bay, and the estuaries
of the Eel River and Klamath
River. Spawning occurs from
November through May, with a
peak from February through April.
No potential. Habitat is not present
within the project site.
Pogonichthys
macrolepidotus
Sacramento splittail
-- CSC No
Splittail depend both on brackishwater rearing habitats in the San Francisco Estuary and on
floodplain and river-edge
spawning habitats immediately
above the estuary. Most migrate
between the two habitat types on
a near annual basis. The
Sacramento splittail is endemic to
the Central Valley.
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Amphibians
Rana draytonii
California red-legged
frog
FT CSC No
Occurs along the Coast Ranges
from Mendocino County towards
the south and in portions of the
Sierra Nevada and Cascades
ranges, usually below 3936 feet.
Breeds in permanent to semipermanent aquatic habitats
including lakes, ponds, marshes,
creeks, and other drainages.
No potential. Habitat is not present
within the project site.
Spea hammondii
Western spadefoot toad -- CSC Yes
Ranges throughout the Central
Valley and adjacent foothills.
Occurs primarily in grasslands,
but occasional populations also
occur in valley-foothill hardwood
woodlands. Elevations of
occurrence extend from near sea
level to 4460 feet in the southern
Sierra Nevada foothills.
No potential. Habitat is not present
within the project site.
Ambystoma
californiense
California tiger
salamander
FE CE Yes
Commonly found in annual
grassland habitat, but also occurs
in the grassy understory of valley
foothill hardwood habitats, and
uncommonly along stream
courses in valley foothill riparian
habitats. The species occurs from
near Petaluma, east through the
Central Valley to Yolo and
Sacramento counties and south to
Tulare County; and from the
vicinity of San Francisco Bay
south to Santa Barbara County.
Occurs at elevations to 3,200 feet.
No potential. Habitat is not present
within the project site.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Reptiles
Thamnophis gigas
Giant garter snake FT CT Yes
Historically ranged in the
Sacramento and San Joaquin
valleys. Current range is much
reduced and apparently extirpated
south of Fresno County, except for
western Kern County. Primarily
associated with marshes and
sloughs, less with slow-moving
creeks, and absent from larger
rivers. Active from mid-March until
October.
Assumed PresentHigh Potential.
Habitat within the project site is
considered medium quality. Several
CNDDB records within the past 20 years
document the presence of giant garter
snake in the West Drainage Canal.
Habitat in the project site is unlikely to
support a permanent population, due to
the lack of suitable burrows and high
levels of vegetation management.
However, the marginal habitat provides
connectivity to occupied sites to the
north and south of the project site.
Actinemys marmorata
Northwestern pond turtle --FC CSC Yes
Associated with permanent or
nearly permanent water in a wide
variety of habitat types.
Uncommon to common in suitable
aquatic habitat throughout
California, west of the SierraCascade crest and absent from desert regions, except in the
Mojave Desert along the Mojave
River and its tributaries. Elevation
range extends from near sea level
to 4,690 feet.
Present. Habitat within the project site is
considered medium quality. The species
was detected during three field surveys
in Canal-2 and Canal-3 within the project
site. Individuals were observed sunning
on floating debris and/or vegetation
within the canals. Adjacent upland
habitats are marginal for the species.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Birds
Circus hudsonius
Northern harrier -- CSC No
Occurs from annual grassland up
to lodgepole pine and alpine
meadow habitats, as high as
10,000 feet. Breeds from sea level
to 5,700 feet in the Central Valley
and Sierra Nevada, and up to
3,600 feet in northeastern
California. Frequents meadows,
grasslands, open rangelands,
desert sinks, and fresh and
saltwater emergent wetlands.
Seldomly found in wooded areas.
Present. Habitat within the project site is
considered high quality. Northern harrier
was observed foraging on and flying
over the proposed industrial park
footprint of the project site during two
field surveys.
Buteo swainsoni
Swainson's hawk -- CT Yes
Breeds in stands with few trees in
juniper-sage flats, riparian areas,
and in oak savannah in the Central
Valley. Forages in adjacent
grasslands or suitable grain or
alfalfa fields, or livestock pastures.
Present. Foraging habitat within the
project site is considered high quality.
Swainson’s hawk was observed during
April and May field surveys. Nesting
activity was not detected. Nesting habitat
is limited in the project site.
Elanus leucurus
White-tailed kite -- CFP No
Common to uncommon, yearlong
resident in coastal and valley
lowlands. Rarely found away from
agricultural areas. Inhabits
herbaceous and open stages of
most habitats, mostly in
cismontane California.
HighPresent. Habitat within the project
site is considered high quality. The
industrial park footprint of the project site
contains foraging habitat that could
support the species; however, nesting
habitat is limited and composed of the
relatively few Goodding’s black willow,
valley oak, and other trees along the
canal and ditch banks.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Athene cunicularia
Burrowing owl -- CSC Yes
A yearlong resident of open, dry
grassland and desert habitats, and
in grass, forb and open shrub
stages of pinyon-juniper and
ponderosa pine habitats.
Moderate. Habitat within the project site
is considered high quality. Most regional
records are east of State Route (SR) 99.
However, recent CNDDB records
document the species as having
occurred within the vicinity of the
Sacramento International Airport. The
project site contains some open
disturbed areas that provide marginal
habitat; however, existing suitable
burrows and ground squirrels were not
observed.
Branta hutchinsii
leucopareia
Aleutian cackling goose
-- -- Yes
Preferred habitats include
lacustrine, fresh emergent
wetlands, and moist grasslands,
croplands, pastures, and
meadows. The species occurs
mainly in the foregoing habitats
during winter in Del Norte County,
the San Francisco Bay-Delta, and
southern Central Valley.
Low. Habitat within the project site is
considered low quality. The nearest
record is 28 miles to the north of the
project site. The species has not been
recorded within the Natomas Basin.
Sometimes occurs with more numerous
Canada Geese, which will often feed in
agricultural fields, especially during
winter months.
Plegadis chihi
White-faced ibis -- -- Yes
Uncommon summer resident in
sections of Southern California.
Rare visitor in the Central Valley
and more widespread in migration.
Prefers to feed in fresh emergent
wetland, shallow lacustrine waters,
muddy ground of wet meadows,
and irrigated or flooded pastures
and croplands. Nests in dense,
fresh emergent wetland.
Low. Habitat within the project site is
considered low quality. The nearest
records are eight miles to the west of the
project site. Has potential to be observed
on the industrial park footprint of the
project site at the margins of canals or
adjacent agricultural areas for foraging.
Nesting habitat does not occur.
Lanius ludovicianus
Loggerhead shrike -- CSC Yes Common resident and winter visitor in lowlands and foothills Low. Habitat within the project site is
considered low quality. The nearest
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
throughout California. Prefers
open habitats with scattered
shrubs, trees, posts, fences, utility
lines, or other perches. Highest
density occurs in open-canopied
valley foothill hardwood, valley
foothill hardwood-conifer, valley
foothill riparian, pinyon-juniper,
juniper, desert riparian, and
Joshua Tree habitats.
records are more than 50 miles from the
project site. Occurs sparingly in the
Natomas Basin. Unlikely to be present
on the industrial park footprint of the
project site due to lack of scrubby
habitat, which is normally present in
preferred areas.
Melospiza melodia
Song sparrow "Modesto"
population
-- CSC No
Avoids higher mountains and
occurs only locally in southern
deserts. In winter, most leave
montane habitats; more abundant
and widespread than in lowlands
and deserts. Prefers riparian, fresh
or saline emergent wetland, and
wet meadow habitats. Breeds in
riparian thickets of willows, other
shrubs, vines, tall herbs, and in
fresh or saline emergent
vegetation.
Low. Habitat within the project site is
considered low quality. This resident
form of the song sparrow has been
recorded in sparsely vegetated margins
of canals, such as those bordering the
industrial park footprint of the project
site, which contains limited habitat that
could support nesting.
Agelaius tricolor
Tricolored blackbird -- CT, CSC Yes
Occurs locally throughout Central
Valley and in coastal districts.
Breeds near freshwater, preferably
in emergent wetland with tall,
dense cattails or tules, but also in
thickets of willow, blackberry, wild
rose, and tall herbs. Feeds in
grassland and cropland habitats.
Breeds locally in northeastern
California.
Low. Habitat within the project site is
considered low quality. Appropriate
breeding habitat is not present; however,
the species will often forage in
agricultural fields, especially in winter.
(Continues on next page)
Final EIR
Airport South Industrial Project
March 2025
Chapter 3 – Revisions to the Draft EIR Text
Table 4.4-1
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Vireo bellii pusillus
Least Bell's vireo FE CE No
Winter in southern Baja
California, Mexico, where they
occupy a variety of habitats,
including mesquite scrub within
arroyos, palm groves, and
hedgerows bordering agricultural
and residential areas. The birds
generally arrive in southern
California breeding areas by midMarch to early April, with males arriving before females. Generally
remains on the breeding grounds
until late September, although
some post-breeding migration
may begin as early as late July.
No potential. Habitat is not present
within the project site.
Riparia riparia
Bank swallow -- CT Yes
Found primarily in riparian and
other lowland habitats in
California west of the deserts
during the spring-fall period. In
summer, restricted to riparian,
lacustrine, and coastal areas with
vertical banks, bluffs, and cliffs
with fine-textured or sandy soils.
No potential. Habitat is not present
within the project site.
Status Codes:
CC: CDFW Candidate for Listing CT: CDFW Threatened
CE: CDFW Endangered FE: Federally Endangered
CFP: CDFW Fully Protected FT: Federally Threatened
CRPR: California Rare Plant Rank FC: Federal Candidate for Listing CSC: CDFW Species of Concern
Source: Bargas Environmental Consulting, 20234.
4. Mitigation Monitoring and
Reporting Program
Final EIR
Airport South Industrial Park Project
March 2025
Chapter 4 – Mitigation Monitoring and Reporting Program
4.1 INTRODUCTION
Section 15097 of the California Environmental Quality Act (CEQA) requires all State and local agencies to establish monitoring or reporting programs for projects approved by a public agency whenever approval involves the adoption of either a “mitigated negative declaration” or specified environmental findings related to environmental impact reports.
The following is the Mitigation Monitoring and Reporting Program (MMRP) for the Airport South Industrial Park Project (proposed project). The intent of the MMRP is to ensure implementation of the mitigation measures identified within the EIR for the proposed project. Unless otherwise noted, the cost of implementing the mitigation measures as prescribed by this MMRP shall be funded by the applicant.
4.2 COMPLIANCE CHECKLIST
The MMRP contained herein is intended to satisfy the requirements of CEQA as they relate to the EIR prepared for the proposed project. This MMRP is intended to be used by City of Sacramento staff, and mitigation monitoring personnel to ensure compliance with mitigation measures during project implementation. Mitigation measures identified in this MMRP were developed in the EIR.
The EIR presents a detailed set of mitigation measures that will be implemented throughout the lifetime of the project. Mitigation is defined by CEQA Guidelines, Section 15370, as a measure that:
• Avoids the impact altogether by not taking a certain action or parts of an action; • Minimizes impacts by limiting the degree or magnitude of the action and its implementation;
• Rectifies the impact by repairing, rehabilitating, or restoring the impacted environment; • Reduces or eliminates the impact over time by preservation and maintenance operations during the life of the project; or
• Compensates for the impact by replacing or providing substitute resources or environments.
The intent of the MMRP is to ensure the implementation of adopted mitigation measures. The MMRP will provide for monitoring of construction activities as necessary and in-the-field identification and resolution of environmental concerns.
Monitoring and documenting the implementation of mitigation measures will be coordinated by the City of Sacramento. The table attached to this report identifies the mitigation measures, the monitoring action for each mitigation measure, the responsible party for the monitoring action, and timing of the monitoring action. The applicant will be responsible for fully understanding and
4. MITIGATION MONITORING
AND REPORTING PROGRAM
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March 2025
Chapter 4 – Mitigation Monitoring and Reporting Program
effectively implementing the mitigation measures contained within the MMRP. The City will be responsible for monitoring compliance.
4.3 MITIGATION MONITORING AND REPORTING PROGRAM
The following table indicates the mitigation measure number, the impact the measure is designed to address, the measure text, the monitoring agency, implementation schedule, and an area for sign-off indicating compliance.
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Impact
Number Impact Mitigation Measures Monitoring Agency
Implementation
Schedule Sign-off
4.2 Agricultural Resources
4.2-1 Impacts related to the
conversion of Prime
Farmland, Unique
Farmland, or Farmland
of Statewide Importance
to non-agricultural use.
Industrial Park
4.2-1 The City shall ensure that, prior to impacting
agricultural/open space resources within the
project site by the issuance of a grading
permit, any and all project-related subdivision
maps satisfy the On-Site Open Space and OffSite Open Space requirements as defined herein. Open space dedications made
pursuant to the Natomas Basin Habitat
Conservation Plan (HCP) shall be made to the
City and/or the Natomas Basin Conservancy
and shall be located in the Natomas Basin.
The remaining non-Natomas Basin HCP
mitigation acreage may be located in
unincorporated Sacramento County, Yolo
County, and/or Sutter County, and may be
held and managed by a qualified third-party
entity with the approval of the City.
Preservation shall be ensured in perpetuity via
conservation easement, fee, or irrevocable
offer of dedication to the satisfaction of the
City. All mitigation acreage shall consist of land
of comparable agricultural and habitat value as
the agricultural/open space resources
impacted by the proposed project, as
determined by the City.
a. On-Site Agricultural/Open Space
Requirements: The following on-site
open space properties are consistent
with the mitigation requirements:
• 86 acres of detention basins.
City of
Sacramento
Community
Development
Department
Prior to issuance of
a grading permit
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• 37.9 acres of freeway buffer.
• 2.3 acres of canal buffers.
b. Off-site Agricultural/Open Space
Requirements: The following Off-Site
Open Space properties:
• 141.51 acres of currently
unidentified agricultural/open
spaced mitigation property to
be located in the
unincorporated Sacramento
County and/or unincorporated
Sutter County.
• 50-acre habitat mitigation
property APN 225-0020-014.
• 67.59-acre habitat mitigation
property APN 225-0020-015.
c. Phasing: The Airport South Industrial
Project will develop in phases, as
such, the amount of On-Site and OffSite Open Space to be provided hereunder shall be in proportion to the
amount of acreage proposed to be
impacted by such development by the
issuance of a grading permit therefor.
d. With respect to each unidentified open
space property listed above, and any
proposed substitution of an open
space property listed above, the City
must determine, in writing, that the
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proposed agricultural/open space
property and/or acreage satisfies the
requirements for agricultural/open
space to be counted towards the
requisite Off-Site Agricultural/Open
Space acreage total.
e. Nothing in this Agricultural/Open
Space Mitigation is intended to limit or
restrict USFWS and CDFW in their
consideration of Developer's
applications for incidental take and/or
other habitat mitigation permits or
other entitlements under the federal
Endangered Species Act and the
California Endangered Species Act.
4.2-5 Impacts related to
cumulative loss of
agricultural land.
4.2-5 Implement Mitigation Measure 4.2-1. See Mitigation Measure 4.2-1
See Mitigation
Measure 4.2-1
4.3 Air Quality, Greenhouse Gas Emissions, and Energy
4.3-1 Conflict with or obstruct
implementation of the
applicable air quality plan
during project
construction.
4.3-1(a) The following SMAQMD’s Basic Construction
Emissions Control Practices (BMPs) for dust
control shall be included through a notation on
all project grading plans prior to the issuance
of grading permits, to the satisfaction of the
City of Sacramento Community Development
Department and SMAQMD.
• Water all exposed surfaces two times
daily. Exposed surfaces include, but
are not limited to soil piles, graded
areas, unpaved parking areas, staging
areas, and access roads;
City of
Sacramento
Community
Development
Department
SMAQMD
Prior to issuance of
grading permits
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• Cover or maintain at least two feet of
free board space on haul trucks
transporting soil, sand, or other loose
material on the site. Any haul trucks
that would be traveling along freeways
or major roadways should be covered;
• Use wet power vacuum street
sweepers to remove any visible
trackout mud or dirt onto adjacent
public roads at least once a day. Use
of dry power sweeping is prohibited;
• Limit vehicle speeds on unpaved
roads to 15 miles per hour (mph);
• All roadways, driveways, sidewalks,
parking lots to be paved should be
completed as soon as possible. In
addition, building pads should be laid
as soon as possible after grading
unless seeding or soil binders are
used;
• Minimize idling time either by shutting
equipment off when not in use or
reducing the time of idling to 5 minutes
[CCR Title 13, Sections 2449(d)(3)
and 2485]. Provide clear signage that
posts this requirement for workers at
the entrances to the site;
• Provide current certificate(s) of
compliance for CARB’s In-Use OffRoad Diesel-Fueled Fleets Regulation [CCR Title 13, Sections 2449 and
2449.1]. For more information contact
CARB at 877-593-6677,
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[email protected], or
www.arb.ca.gov/doors/compliance_
cert1.html.; and
• Maintain all construction equipment in
proper working condition according to
manufacturer’s specifications. The
equipment must be checked by a
certified mechanic and determine to
be running in proper condition before
it is operated.
4.3-1(b) Prior to approval of any Improvement Plans,
the project applicant shall provide proof of
compliance with the following to the
satisfaction of the City of Sacramento
Community Development Department and
SMAQMD:
The project applicant shall show on the
plans via notation that the contractor shall
ensure that the heavy-duty off-road
vehicles (50 horsepower or more) to be
used in the construction of all project
components (i.e., construction of the
industrial park, nonparticipating parcels,
and off-site force main), including owned,
leased, and subcontractor vehicles, shall
be a combination of engine Tier 3 or Tier 4
off-road construction equipment, or hybrid,
electric, or alternatively fueled equipment
(or any combination of the above),
sufficient to achieve a fleet-wide average
reduction in construction-related NOX
emissions to below the applicable
City of
Sacramento
Community
Development
Department
SMAQMD
Prior to the approval
of any Improvement
Plans
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SMAQMD thresholds of significance (85
lbs/day). For instance, the emissions
presented in Table 4.3-8 of the Draft EIR
were achieved by requiring all equipment
used during construction to be engine Tier
4. In addition, all off-road equipment
operating at the construction site must be
maintained in proper working condition
according to manufacturer’s
specifications. Idling shall be limited to five
minutes or less in accordance with the InUse Off-Road Diesel Vehicle Regulation as required by CARB. Clear signage
regarding idling restrictions shall be placed
at the entrances to the construction site.
Portable equipment over 50 horsepower
must have either a valid SMAQMD Permit
to Operate (PTO) or a valid statewide
Portable Equipment Registration Program
(PERP) placard and sticker issued by
CARB.
Conformance with the foregoing
requirements shall be included as notes
and be confirmed through review and
approval of grading plans by the City of
Sacramento Community Development
Department.
4.3-2 Conflict with or obstruct
implementation of the
4.3-2 Prior to the approval of project improvement
plans for both the industrial park and
nonparticipating parcels, the project applicant
City of
Sacramento
Community
Prior to the approval
of project
Improvement Plans
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applicable air quality plan
during project operation.
shall comply with the provisions of the Air
Quality Management Plan prepared for the
proposed project (see Appendix D), and
incorporate all requirements into the Airport
South Industrial Project conditions of approval.
The measures included in the AQMP include
the following:
1. Natural gas use shall be prohibited in
all land uses, with the exception of the
restaurant kitchen.
2. The project shall implement a
Transportation Management
Association (TMA), such as Jibe North
Natomas (for more information, visit
https://jibe.org/). The TMA must
comply with the following criteria, and
is subject to approval by the City of
Sacramento and SMAQMD:
a. The TMA must be legally
constituted as a non-profit
organization,
Property/Business
Improvement District (PBID),
or a government entity with a
non-revocable funding
mechanism, such as a
community finance district,
dedicated to TMA operations
and services; and
b. The TMA must provide a
minimum level of TDM
services to employees and
residents within the area
Development
Department
for both the
industrial park and
nonparticipating
parcels
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March 2025
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covered by the AQMP
sufficient to achieve the
emission reductions claimed
by the measure. Services
must be enumerated and
funded to the satisfaction of
the lead agency and
SMAQMD.
3. The project applicant shall require all
tenants of the on-site industrial uses to
use zero-emission forklifts.
4. The project applicant shall require that
4.5 percent of the heavy-duty vehicle
fleet be zero emission by full buildout
of the annexation area. It should be
noted that in the event there is a
disruption in the manufacturing of zero
emission vehicles/trucks or that
sufficient vehicles/trucks are not
commercially available for the
intended application, the “clean fleet
requirements” may be adjusted as
minimally as possible by the City’s
Community Development Department
to accommodate the manufacturing
disruption or unavailability of
commercially available
vehicles/trucks.
5. The project shall provide complete
sidewalks separated from roadway
throughout the project site and
pedestrian crossing at intersections
on-site to ensure employees and
visitors can walk between land
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March 2025
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uses/businesses. The project shall
also connect the pedestrian network
on-site to the adjacent properties offsite (including South Bayou Way, Power Line Road and potential future
connections) as indicated on the
preliminary site plan when those
portions of the site develop.
6. Provide EV Ready parking spaces at
the ratio with which the current
CalGreen Tier 2 standards require EV
Capable spaces.
4.3-3 Expose sensitive
receptors to substantial
pollutant concentrations.
4.3-3 If Parcel 8 (the 64.3-acre nonparticipating
parcel owned by Cayocca) is proposed to be
developed with a distribution center (i.e., an
industrial warehouse that accommodates more
than 100 heavy-duty trucks per day, more than
40 trucks with operating transport refrigeration
units [TRUs] per day, or where TRU unit
operations exceed 300 hours per week) within
1,000 feet of a sensitive receptor, prior to the
issuance of any building permit, a Health Risk
Assessment (HRA) shall be conducted to
calculate the cancer risk associated with onsite truck diesel particulate matter (DPM) emissions.
The HRA shall be prepared in accordance with
SMAQMD guidelines, as well as the guidelines
identified in the California Office of
Environmental Health Hazard Assessment
(OEHHA) Guidance Manual for Preparation of
Health Risk Assessments. If health risks
associated with Parcel 8 are determined to
City of
Sacramento
Community
Development
Department
As part of the
application for any
development on
Parcel 8
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exceed the applicable SMAQMD thresholds, a
qualified air quality consultant shall identify
measures sufficient to reduce the project’s
health risks to below the SMAQMD’s
thresholds of significance. Reduction
measures may include, but are not limited to,
relocation of loading docks to further than
1,000 feet from sensitive receptors,
electrification of the heavy-duty truck fleet,
and/or other options as they become available.
Conformance with the foregoing requirement,
including implementation of identified reduction
measures, shall be confirmed through review
and approval of the HRA by the City of
Sacramento Community Development
Department.
4.3-6 Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is in nonattainment under an
applicable federal or
State ambient air quality
standard (including
releasing emissions
which exceed
quantitative thresholds
for ozone precursors).
4.3-6 Implement Mitigation Measure 4.3-2. See Mitigation Measure 4.3-2
See Mitigation
Measure 4.3-2
4.3-7 Generation of GHG
emissions that may have
a significant impact on
the environment or
conflict with an
Construction
4.3-7(a) Prior to the initiation of construction of the industrial park, the project applicant shall
demonstrate that construction-related GHG
emissions would be reduced to 935 MTCO2e/yr
City of
Sacramento
Community
Prior to the initiation
of construction of
the industrial park
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applicable plan, policy or
regulation of an agency
adopted for the purpose
of reducing the
emissions of GHGs.
and shall submit proof to the City of
Sacramento Community Development
Department. In addition, prior to the initiation of
construction of the nonparticipating parcels,
the future applicant of all future development
proposals on such parcels shall demonstrate
that construction-related GHG emissions
would be reduced to 165 MTCO2e/yr and shall
submit proof to the City of Sacramento
Community Development Department.
Construction-related GHG emissions can be
reduced through several options. The
SMAQMD recommends the following options
for reducing greenhouse gas emission from
construction projects:
• Modify the construction schedule to
reduce the intensity of construction to
lower emissions;
• Ensure that phases of development do
not overlap;
• Use of renewable diesel for
construction fuel rather than diesel;
• Improve fuel efficiency from
construction equipment by:
o Minimizing idling time either
by shutting equipment off
when not in use or reducing
the time of idling to no more
than three minutes (fiveminute limit is required by the state airborne toxics control
measure [Title 13, sections
Development
Department
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2449(d)(3) and 2485 of the
California Code of
Regulations]). Provide clear
signage that posts this
requirement for workers at the
entrances to the site; and
o Using equipment with new
technologies (repowered
engines, electric drive trains).
• Perform on-site emission reductions
such as implementing on-site material
hauling with trucks equipped with onroad engines (if determined to be less emissive than the off-road engines) or
real, quantifiable, permanent,
verifiable, and enforceable on-site
emission reductions;
• Use alternative fuels for generators at
construction sites such as propane or
solar, or use electrical power;
• Use a CARB-approved low carbon
fuel for construction equipment; (NOX
emissions from the use of low carbon
fuel must be reviewed and increases
mitigated.)
• Encourage and provide carpools,
shuttle vans, transit passes and/or
secure bicycle parking for construction
worker commutes;
• Reduce electricity use in the
construction office by using LED
bulbs, powering off computers every
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day, and replacing heating and cooling
units with more efficient ones;
• Recycle or salvage non-hazardous
construction and demolition debris
(goal of at least 75 percent by weight);
• Use locally sourced or recycled
materials for construction materials
(goal of at least 20 percent based on
costs for building materials, and based
on volume for roadway, parking lot,
sidewalk and curb materials). Wood
products utilized should be certified
through a sustainable forestry
program;
• Minimize the amount of concrete for
paved surfaces or utilize a low carbon
concrete option;
• Produce concrete on-site if
determined to be less emissive than
transporting ready mix;
• Use SmartWay certified trucks for
deliveries and equipment transport;
and
• Develop a plan to efficiently use water
for adequate dust control.
The project applicant may elect to implement
any combination of the foregoing measures to
reduce construction-related GHG emissions.
All GHG emissions reductions must be
quantified. Compliance with the
aforementioned measures shall be ensured by
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the City of Sacramento Community
Development Department.
If the quantified reduction measures do not
reduce construction-related GHG emissions to
below 935 MTCO2e/yr for the industrial park
and 165, MTCO2e/yr for the nonparticipating
parcels, offsite carbon credits may be
purchased to make up the difference. The
purchase of off-site mitigation credits shall be
negotiated with the City and SMAQMD at the
time that credits are sought. Off-site mitigation
credits shall be real, quantifiable, permanent,
verifiable, enforceable, and additional,
consistent with the standards set forth in
Health and Safety Code section 38562,
subdivisions (d)(1) and (d)(2). The offsets shall
be retired, and emissions must be offset
through the year 2045. Such credits shall be
based on CARB-approved protocols that are
consistent with the criteria set forth in
subdivision (a) of Section 95972 of Title 17 of
the California Code of Regulations, and shall
not allow the use of offset projects originating
outside of California, except to the extent that
the quality of the offsets, and their sufficiency
under the standards set forth herein, can be
verified by the City of Sacramento and/or the
SMAQMD. Such credits must be purchased
through one of the following: (i) a CARBapproved registry, such as the Climate Action Reserve, the American Carbon Registry, and
the Verified Carbon Standard; (ii) any registry
approved by CARB to act as a registry under
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the California Cap and Trade program; or (iii)
any registry established by SMAQMD.
Operations
4.3-7(b) Prior to the approval of any building permits, the applicant shall implement the following
measures:
1. The proposed project shall be
designed such that all project
components, with the exception of the
on-site restaurant kitchens, are built
all-electric. The kitchens shall include
pre-wiring to allow for the future retrofit
of all natural gas appliances with allelectric appliances. If the kitchens are electrically powered and do not use
natural gas, further mitigation is not
required; and
2. If natural gas is installed in the
kitchens, the applicant shall reduce
GHG emissions associated with onsite restaurant kitchens at a rate of 158.77 MTCO2e/yr through any
combination of the following on-site
mitigation options:
o Requiring on-site renewable
energy generation in excess
of Code requirements.
o Increasing the number of EV
charging stations.
o Constructing on-site or fund
off-site carbon sequestration
City of
Sacramento
Community
Development
Department
SMAQMD
Prior to approval of
any building permits
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projects (such as tree
plantings or reforestation
projects).
o Implementing a
Transportation Demand
Management Program.
o Should new and quantifiable
GHG emission reduction
technology become available,
the applicant may otherwise
achieve the required GHG
emissions reduction through
other means, subject to
review and approval by the
City of Sacramento and the
SMAQMD.
The project applicant may elect to
implement any combination of the
foregoing measures to reduce
operational GHG emissions. All GHG
emissions reductions must be
quantified.
If it is determined that the above onsite mitigation options are not sufficient to achieve the required GHG
reduction, subject to the discretion of
the City of Sacramento and the
SMAQMD, off-site carbon credits may
be purchased to make up the
difference. The purchase of off-site
mitigation credits shall be negotiated
with the City and SMAQMD at the time
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that credits are sought. Off-site
mitigation credits shall be real,
quantifiable, permanent, verifiable,
enforceable, and additional,
consistent with the standards set forth
in Health and Safety Code section
38562, subdivisions (d)(1) and (d)(2).
The offsets shall be retired, and
emissions must be offset through the
year 2045. Such credits shall be
based on CARB-approved protocols
that are consistent with the criteria set
forth in subdivision (a) of Section
95972 of Title 17 of the California
Code of Regulations, and shall not
allow the use of offset projects
originating outside of California,
except to the extent that the quality of
the offsets, and their sufficiency under
the standards set forth herein, can be
verified by the City of Sacramento
and/or the SMAQMD. Such credits
must be purchased through one of the
following: (i) a CARB-approved
registry, such as the Climate Action
Reserve, the American Carbon
Registry, and the Verified Carbon
Standard; (ii) any registry approved by
CARB to act as a registry under the
California Cap and Trade program; or
(iii) any registry established by
SMAQMD.
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Compliance with the aforementioned
measures shall be ensured by the City of
Sacramento Community Development
Department.
4.3-7(c) Consistent with SMAQMD’s GHG BMP-2, prior
to the approval of project improvement plans,
the applicant shall indicate that EV Ready
parking spaces shall be installed throughout
the project site at the ratio with which the
current CalGreen Tier 2 standards require EV
Capable spaces. Compliance with this
measure shall be ensured by the City of
Sacramento Community Development
Department.
4.3-7(d) Implement Mitigation Measure 4.12-3.
City of
Sacramento
Community
Development
Department
See Mitigation
Measure 4.12-
3 Prior to the approval
of project
Improvement Plans
See Mitigation
Measure 4.12-3
4.4 Biological Resources
4.4-1 Impacts to special-status
plant species, either
directly (e.g., threaten to
eliminate a plant
community) or through
substantial habitat
modifications.
Industrial Park and Nonparticipating Parcels
4.4-1(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities
associated with development of the industrial
park footprint and nonparticipating parcels, the
following Natomas Basin Habitat Conservation
Plan (HCP) Take Avoidance, Minimization,
and Mitigation Measures shall be
implemented, as applicable:
Natomas Basin HCP Section V.A.1:
Not less than 30 days or more than 6 months
prior to commencement of construction
City of
Sacramento
Community
Development
Department
U.S. Fish and
Wildlife
Service
(USFWS)
California
Department of
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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activities, a pre-construction survey of the
portion of the site to be disturbed shall be
conducted to determine the status and
presence of, and likely impacts to, all Covered
Species on the site. However, pre-construction
surveys for an individual species may be
completed up to one year in advance if the sole
period for reliable detection of that species is
between May 1 and December 31. The project
proponent will be responsible for contracting
with qualified biological consultants to carry
out the pre-construction surveys, and as
necessary, to implement specific take
minimization, and other Conservation
Measures set forth in the Natomas Basin HCP
and approved by the Wildlife Agencies.
The results of the pre-construction surveys
along with recommended take minimization
measures shall be documented in a report and
shall be submitted to the City, USFWS, CDFG
and the Natomas Basin Conservancy. Based
upon the survey results, the City will identify
applicable take avoidance and other sitespecific Conservation Measures, consistent with the Natomas Basin HCP, required to be
carried out on the site. The approved preconstruction survey documents and list of Conservation Measures will be submitted by
the developer to the City to demonstrate
compliance with the Natomas Basin HCP.
Fish and
Wildlife
(CDFW)
Natomas
Basin
Conservancy
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Natomas Basin HCP Section V.A.5.o:
If Sanford’s arrowhead plants are identified
through a pre-construction survey, the City
shall provide notice to USFWS, CDFG and the
California Native Plant Society. Under such
circumstances, the development proponent
shall allow the transplantation of plants prior to
site disturbance.
Natomas Basin HCP Section V.A.5.p:
Prior to issuance of a grading permit, the City
shall require a pre-construction survey. If such
survey determines Boggs Lake hedge-hyssop,
Sacramento orcutt grass, Slender orcutt grass,
Colusa grass, or legenere are present, the City
shall require the developer to consult with
USFWS to determine appropriate measures to
avoid and minimize loss of individuals.
4.4-1(b) With respect to special-status plant species
not covered under the Natomas Basin HCP,
prior to the commencement of construction
activities associated with the nonparticipating
parcels, a qualified biologist shall conduct
preconstruction protocol-level surveys for
special-status plants with potential to occur onsite. The surveys may be conducted concurrently with the preconstruction surveys
set forth by Mitigation Measure 4.4-1(a). The
results of the surveys shall be submitted for
review and approval to the City of Sacramento
Community Development Department and
City of
Sacramento
Community
Development
Department
CDFW
USFWS
Prior to the
commencement of
construction
activities associated
with the
nonparticipating
parcels
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shall be valid for two years. If special-status
plant species are not found, further mitigation
shall not be required.
If any special-status plants are located during
the foregoing surveys, the appropriate agency
(i.e., CDFW and/or USFWS, depending on the
species) shall be consulted to develop
appropriate mitigation for the proposed project
for expected impacts. If special-status plants
would be impacted, as determined by the
qualified biologist, a mitigation plan shall be
developed in coordination with the appropriate
agency and submitted for review and approval
to the City of Sacramento Community
Development Department. Mitigation shall
include that if special-status perennial species
are found in areas proposed for disturbance,
the plants shall be dug up and transplanted
into a suitable avoided area on-site prior to
construction. If the plant found is an annual,
then mitigation shall consist of collecting seedbearing soil and spreading it into a suitable location.
4.4-3 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
giant garter snake.
Industrial Park and Nonparticipating Parcels
4.4-3(a) Prior to the issuance of any grading permit and commencement of ground-disturbing
activities, the project applicant shall ensure
that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation
Measures have been implemented:
Natomas Basin HCP Section V.A.5.a:
City of
Sacramento
Community
Development
Department
USFWS
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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1. Within the Natomas Basin, all
construction activity involving
disturbance of habitat, such as site
preparation and initial grading, is
restricted to the period between May 1
and September 30. This is the active
period for the giant garter snake and
direct mortality is lessened, because
snakes are expected to actively move
and avoid danger.
2. Pre-construction surveys for giant
garter snake, as well as other NBHCP
Covered Species, must be completed
for all development projects by a
qualified biologist approved by
USFWS. If any giant garter snake
habitat is found within a specific site,
the following additional measures
shall be implemented to minimize
disturbance of habitat and harassment
of giant garter snake, unless such
project is specifically exempted by
USFWS.
3. Between April 15 and September 30,
all irrigation ditches, canals, or other
aquatic habitat should be completely
dewatered, with no puddled water
remaining, for at least 15 consecutive
days prior to the excavation or filling in
of the dewatered habitat. Make sure
dewatered habitat does not continue
to support giant garter snake prey,
which could detain or attract snakes
into the area. If a site cannot be
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completely dewatered, netting and
salvage of prey items may be
necessary. This measure removes
aquatic habitat component and allows
giant garter snake to leave on their
own.
4. For sites that contain giant garter
snake habitat, no more than 24-hours
prior to start of construction activities
(site preparation and/or grading), the
project area shall be surveyed for the
presence of giant garter snake. If
construction activities stop on the
project site for a period of two weeks
or more, a new giant garter snake
survey shall be completed no more
than 24-hours prior to the re-start of
construction activities.
5. Confine clearing to the minimal area
necessary to facilitate construction
activities. Flag and designate avoided
giant garter snake habitat within or
adjacent to the project as
Environmentally Sensitive Areas. This
area shall be avoided by all
construction personnel.
6. Construction personnel completing
site preparation and grading
operations shall receive USFWS
approved environmental awareness
training. This training instructs workers
on how to identify giant garter snakes
and their habitats, and what to do if a
giant garter snake is encountered
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during construction activities. During
this training an on-site biological
monitor shall be designated.
7. If a live giant garter snake is found
during construction activities,
immediately notify the USFWS and
the project’s biological monitor. The
biological monitor, or his/her
assignee, shall do the following:
a. Stop construction in the
vicinity of the snake. Monitor
the snake and allow the snake
to leave on its own. The
monitor shall remain in the
area for the remainder of the
work day to make sure the
snake is not harmed or if it
leaves the site, does not
return. Escape routes for giant
garter snake should be
determined in advance of
construction and snakes
should always be allowed to
leave on their own. If a giant
garter snake does not leave
on its own within 1 working
day, further consultation with
USFWS is required.
8. Upon locating dead, injured or sick
threatened or endangered wildlife
species, the project applicant must
notify within 1 working day the
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Service’s Division of Law Enforcement
(2800 Cottage Way, Sacramento CA
95825) or the Sacramento Fish and
Wildlife Office (2800 Cottage Way,
Room W2605, Sacramento, CA
95825, telephone 916 414-6600).
Written notification to both offices
must be made within 3 calendar days
and must include the date, time, and
location of the finding of a specimen
and any other pertinent information.
9. Fill or construction debris may be used
by giant garter snake as an overwintering site. Therefore, upon completion of construction activities
remove any temporary fill and/or
construction debris from the site. If this
material is situated near undisturbed
giant garter snake habitat and it is to
be removed between October 1 and
April 30, it shall be inspected by a
qualified biologist to assure that giant
garter snake are not using it as
hibernaculae.
10. No plastic, monofilament, jute, or
similar erosion control matting that
could entangle snakes will be placed
on a project site when working within
200 feet of snake aquatic or rice
habitat. Possible substitutions include
coconut coir matting, tactified
hydroseeding compounds, or other
material approved by the Wildlife
Agencies.
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4.4-3(b) To address potential impacts to giant garter
snake on-site, but outside of the Natomas
Basin HCP permit area, the project applicant
shall retain a qualified biologist to conduct preconstruction surveys for giant garter snake prior to the issuance of any grading permit and
commencement of project-related grounddisturbing activities outside of the Natomas Basin HCP Permit Area. If giant garter snake
habitat is not identified on-site and giant garter
snakes are not detected, the project may
commence as scheduled. If giant garter snake
habitat is found and/or giant garter snake
individuals are detected, in areas outside of
the Natomas Basin HCP Permit Area that
would be impacted by the project, the project
applicant shall either:
(1) provide on- and or off-site
preservation of giant garter snake
habitat at a ratio determined by
USFWS and CDFW, and as subject
to regulatory permitting requirements
of the CDFW, USACE, and or
RWQCB, as prescribed by Mitigation
Measures 4.4-10(a) through 4.4-
10(c) and 4.4-11(a) through 4.4-
11(d), as applicable. Applicant
purchase of conservation easements
or fee title of lands shall be
acceptable if approved by the
applicable permit-issuing regulatory
agency. Final mitigation
City of
Sacramento
Community
Development
Department
USFWS
CDFW
U.S. Army
Corps of
Engineers
(USACE)
Central Valley
Regional
Water Quality
Control Board
(RWQCB)
Prior to issuance of
any grading permit
and commencement
of project-related
ground-disturbing
activities outside of
the Natomas Basin
HCP
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requirements shall be determined by
the permit-issuing regulatory agency.
OR
(2) Should a portion of the City’s surplus
HCP coverage be made available to
the proposed project, the project
applicant for development projects
less than 50-acres in size shall pay
the Natomas Basin HCP mitigation
fees for land acquisition,
enhancement, and management and
monitoring activities; otherwise, offsite land dedication and payment of NBHCP fees are required for project
greater than 50-acres in size.
4.4-4 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
northwestern pond turtle.
Industrial Park and Nonparticipating Parcels
4.4-4(a) Prior to the issuance of any grading permit and commencement of ground-disturbing
activities, the project applicant shall ensure
that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation
Measure has been implemented:
Natomas Basin HCP Section V.A.5.j:
1. Take of the northwestern pond turtle
as a result of habitat destruction
during construction activities,
including the removal of irrigation
ditches and drains, and during ditch
and drain maintenance, will be
minimized by the dewatering
City of
Sacramento
Community
Development
Department
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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requirement described above for giant
garter snake (see Section 5.a.(3)).
4.4-4(b) Implement Mitigation Measure 4.4-1(a). See Mitigation Measure 4.4-
1(a)
See Mitigation
Measure 4.4-1(a)
4.4-5 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
Swainson’s hawk.
Industrial Park and Nonparticipating Parcels
4.4-5(a) Prior to the issuance of any grading permit and commencement of ground-disturbing
activities, the project applicant shall ensure
that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation
Measure has been implemented:
Natomas Basin HCP Section V.A.5.b:
Measures to Reduce Nest Disturbance
1. Prior to the commencement of
development activities, a preconstruction survey shall be completed to determine whether any
Swainson’s hawk nest trees will be
removed on-site, or active Swainson’s
hawk nest sites occur on or within ½
mile of the development site. These
surveys shall be conducted according
to the Swainson’s Hawk Technical
Advisory Committee’s (May 31, 2000)
methodology or updated
methodologies, as approved by the
Service and CDFG, using
experienced Swainson’s hawk
surveyors.
City of
Sacramento
Community
Development
Department
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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2. If breeding Swainson’s hawks (i.e.
exhibiting nest building or nesting
behavior) are identified, no new
disturbances (e.g., heavy equipment
operation associated with
construction) will occur within ½ mile
of an active nest between March 15
and September 15, or until a qualified
biologist, with concurrence by CDFG,
has determined that young have
fledged or that the nest is no longer
occupied. If the active nest site is
located within 1/4 mile of existing
urban development, the no new
disturbance zone can be limited to the
¼ mile versus ½ mile. Routine
disturbances such as agricultural
activities, commuter traffic, and
routine facility maintenance activities
within ½ mile of an active nest are not
restricted.
3. Where disturbance of a Swainson’s
hawk nest cannot be avoided, such
disturbance shall be temporarily
avoided (i.e., defer construction
activities until after the nesting
season) and then, if unavoidable, the
nest tree may be destroyed during the
non-nesting season. For purposes of
this provision the Swainson's hawk
nesting season is defined as March 15
to September 15. If a nest tree (any
tree that has an active nest in the year
the impact is to occur) must be
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removed, tree removal shall only
occur between September 15 and
February 1.
4. If a Swainson’s hawk nest tree is to be
removed and fledglings are present,
the tree may not be removed until
September 15 or until the California
Department of Fish and Game has
concurred that the young have fledged
and are no longer dependent upon the
nest tree.
5. If construction or other project related
activities which may cause nest
abandonment or forced fledgling are
proposed within the ¼ mile buffer
zone, intensive monitoring (funded by
the project sponsor) by a Department
of Fish and Game approved raptor
biologist will be required. Exact
implementation of this measure will be
based on specific information at the
project site.
4.4-5(b) To address potential impacts to Swainson’s
hawk foraging habitat that occurs on-site, but
outside of the Natomas Basin HCP permit
area, the project applicant shall preserve
Swainson’s hawk foraging habitat off-site at a
1:1 ratio, which shall consist of a minimum
0.5:1 ratio habitat preservation off-site plus
0.5:1 ratio as prescribed by Mitigation
Measure 4.2-1. The preserved habitat shall be
provided through applicant purchase of
conservation easements or fee title of lands
City of
Sacramento
Community
Development
Department
CDFW
Prior to the
issuance of any
grading permit and
commencement of
project-related
ground-disturbing
activities outside of
the Natomas Basin
HCP permit area
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with suitable Swainson’s hawk foraging habitat
as approved by CDFW (consistent with CDFW
guidelines). Additionally, prior to the issuance
of any grading permit and commencement of
project-related ground-disturbing activities
outside of the Natomas Basin HCP permit area
the project applicant shall consult with CDFW
for a Section 2081 Incidental Take Permit, or
demonstrate to the City that none was required
by CDFW.
OR
Should a portion of the City’s surplus HCP
coverage be made available to the proposed
project, the project applicant shall pay the
Natomas Basin HCP mitigation fees for land
acquisition, enhancement, and management
and monitoring activities for development
projects less than 50-acres in size; otherwise
off-site land dedication and payment of
NBHCP fees are required for projects greater
than 50-acres in size.
4.4-6 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
burrowing owl.
Industrial Park and Nonparticipating Parcels
4.4-6 Prior to the issuance of any grading permit and
commencement of ground-disturbing
activities, the project applicant shall ensure
that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation
Measure has been implemented:
Natomas Basin HCP Section V.A.5.h:
City of
Sacramento
Community
Development
Department
USFWS
CDFW
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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1. Prior to the initiation of grading or
earth disturbing activities, the
applicant/developer shall hire a CDFG
approved qualified biologist to perform
a pre-construction survey of the site to
determine if any burrowing owls are
using the site for foraging or nesting.
The pre-construction survey shall be
submitted to the City prior to the
developer’s commencement of
construction activities and a mitigation
program shall be developed and
agreed to by the City and developer
prior to initiation of any physical
disturbance on the site.
2. Occupied burrows shall not be
disturbed during nesting season
(February 1 through August 31) unless
a qualified biologist approved by the
CDFG verifies through non-invasive
measures that either: 1) the birds have
not begun egg-laying and incubation;
or 2) that juveniles from the occupied
burrows are foraging independently
and are capable of independent
survival.
3. If nest sites are found, the USFWS
and CDFG shall be contacted
regarding suitable mitigation
measures, which may include a 300
foot buffer from the nest site during the
breeding season (February 1 - August
31), or a relocation effort for the
burrowing owls if the birds have not
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begun egg-laying and incubation or
the juveniles from the occupied
burrows are foraging independently
and are capable of independent
survival. If on-site avoidance is
required, the location of the buffer
zone will be determined by a qualified
biologist. The developer shall mark the
limit of the buffer zone with yellow
caution tape, stakes, or temporary
fencing. The buffer will be maintained
throughout the construction period.
4. If relocation of the owls is approved for
the site by USFWS and CDFG, the
developer shall hire a qualified
biologist to prepare a plan for
relocating the owls to a suitable site.
The relocation plan must include: (a)
the location of the nest and owls
proposed for relocation; (b) the
location of the proposed relocation
site; (c) the number of owls involved
and the time of year when the
relocation is proposed to take place;
(d) the name and credentials of the
biologist who will be retained to
supervise the relocation; (e) the
proposed method of capture and
transport for the owls to the new site;
(f) a description of the site
preparations at the relocation site
(e.g., enhancement of existing
burrows, creation of artificial burrows,
one-time or long-term vegetation
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control, etc.); and (g) a description of
efforts and funding support proposed
to monitor the relocation.
Relocation options may include
passive relocation to another area of
the site not subject to disturbance
through one way doors on burrow
openings, or construction of artificial
burrows in accordance with the
CDFG’s October 17, 1995, Staff
Report on Burrowing Owls Mitigation
(see Appendix D).
5. Where on-site avoidance is not
possible, disturbance and/or
destruction of burrows shall be offset
through development of suitable
habitat on TNBC upland reserves or in
other suitable preserved uplands.
Such habitat shall include creation of
new burrows with adequate foraging
area (a minimum of 6.5 acres) or 300
feet radii around the newly created
burrows. Additional habitat design and
mitigation measures are described in
CDFW’s March 7, 2012, Staff Report
on Burrowing Owl Mitigation.
4.4-8 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
loggerhead shrike.
Industrial Park and Nonparticipating Parcels
4.4-8 Prior to the issuance of any grading permit and
commencement of ground-disturbing
activities, the project applicant shall ensure
that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation
Measure has been implemented:
City of
Sacramento
Community
Development
Department
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities
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Natomas Basin HCP Section V.A.5.g:
1. Prior to issuance of a grading permit,
the City shall require a preconstruction survey.
2. If surveys identify an active
loggerhead shrike nest that will be
impacted by development, the
developer shall install brightly colored
construction fencing that establishes a
boundary 100 feet from the active
nest. No disturbance associated with
development shall occur within the
100 foot fenced area during the
nesting season of March 1 through
July 31. A qualified biologist, with
concurrence of USFWS must
determine young have fledged or that
the nest is no longer occupied prior to
disturbance of the nest site.
USFWS
4.4-9 Have a substantial
adverse effect, either
directly or through
habitat modifications, on
northern harrier, whitetailed kite, song sparrow,
and other nesting birds
and raptors protected
under the MBTA and
CFGC.
Industrial Park and Nonparticipating Parcels
4.4-9(a) Raptors: If ground disturbance or other
construction activities are proposed during the
nesting season (February 1 to August 31), a
focused survey for nesting raptors protected
under the California Fish and Game Code
(CFGC) and Migratory Bird Treaty Act (MBTA)
shall be conducted by a qualified biologist
within seven days prior to the beginning of
construction activities in order to identify active
nests. The survey shall be conducted within
the proposed construction area and all
accessible areas within 0.5-mile. A report
City of
Sacramento
Community
Development
Department
If ground
disturbance or other
construction
activities are
proposed during the
nesting season
(February 1 to
August 31)
Final EIR
Airport South Industrial Park Project
March 2025
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summarizing the results of the survey shall be
submitted for review and approval to the City
of Sacramento Community Development
Department. If active nests are not found
during the focused survey(s), additional
mitigation shall not be required. For any period
of project inactivity of more than seven days,
the qualified biologist shall conduct a field
check of the previously surveyed area before
construction activities recommence to confirm
nesting raptors have not entered during the
interim.
If active raptor nests are found within 0.5-mile
of a construction area, construction shall not
commence within 0.5-mile of the nest until a
qualified biologist determines that the young
have fledged, or the biologist has determined
that the nesting attempt has failed. If
construction activities within 0.5-mile of the
nest are necessary, the qualified biologist shall
be consulted to determine if the nest buffer can
be reduced. The applicant and qualified
biologist shall jointly determine the nest
avoidance buffer, and what (if any) nest
monitoring is necessary.
If an active raptor nest is found within the
project area prior to construction and is in a
tree that is proposed for removal, then the
project applicant shall implement additional
mitigation recommended by a qualified
biologist based on CDFW guidelines and
obtain any required permits from CDFW.
Final EIR
Airport South Industrial Park Project
March 2025
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4.4-9(b) Songbirds: If ground disturbance or other
construction activities are proposed during the
nesting season (February 1 to August 31), a
focused survey for birds protected under the
MBTA shall be conducted by a qualified
biologist within seven days prior to the
beginning of construction activities in order to
identify active nests. The survey shall be
conducted within the proposed construction
area and all accessible areas within 500 feet.
A report summarizing the results of the survey
shall be submitted for review and approval to
the City of Sacramento Community
Development Department. If active nests are
not found during the focused survey(s),
additional mitigation shall not be required. For
any period of project inactivity of more than
seven days, the qualified biologist shall
conduct a field check of the previously
surveyed area before construction activities
recommence to confirm nesting songbirds
have not entered during the interim.
If active special-status species nests/nesting
colonies are located during the survey, the
project applicant shall work with a qualified
biologist to determine a suitable avoidance
buffer and the extent and duration of nest
monitoring needed. The perimeter of the
protected area shall be indicated by bright
orange temporary fencing and signage.
Construction activities and/or personnel shall
not enter the protected area, except with
City of
Sacramento
Community
Development
Department
If ground
disturbance or other
construction
activities are
proposed during the
nesting season
(February 1 to
August 31)
Final EIR
Airport South Industrial Park Project
March 2025
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approval of the biologist. If trees containing
nests or burrows must be removed as a result
of project implementation, removal shall be
completed during the nonbreeding season
(late September to January 31).
If active songbird nests are found, a qualified
biologist shall establish a 100-foot nondisturbance buffer. The non-disturbance buffers may be reduced based on consultation
and approval by the City of Sacramento
Community Development Department. The
perimeter of the protected area shall be
indicated by bright orange temporary fencing.
Construction activities or personnel shall not
enter the protected area, except with approval
of the biologist. If trees containing nests must
be removed as a result of project
implementation, removal shall be completed
during the nonbreeding season (late
September to January 31) or after the adults
and young are not dependent on the nest site,
as determined by a qualified biologist.
4.4-10 Have a substantial
adverse effect on any
riparian habitat or other
Sensitive Natural
Community identified in
local or regional plans,
policies, regulations or
by the CDFW or
USFWS.
Industrial Park
4.4-10(a)Prior to the commencement of grounddisturbing activities, the project applicant shall notify CDFW, pursuant to CFGC Section 1600.
The notification shall include a description of
all of the activities associated with the
proposed industrial park, not just those
associated with the drainages and/or riparian
vegetation. Impacts shall be outlined in the
notification and are expected to be in
substantial conformance with the impacts to
City of
Sacramento
Community
Development
Department
CDFW
Prior to the
commencement of
ground-disturbing
activities within
Industrial Park
Final EIR
Airport South Industrial Park Project
March 2025
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biological resources outlined in the Biological
Resources Assessment prepared for the
Airport South Industrial Project by Bargas
Environmental Consulting. Impacts for each
activity shall be broken down by temporary and
permanent impacts. A description of the
proposed mitigation for biological resource
impacts shall be outlined per activity and then
by temporary and permanent impact.
Information regarding project-specific drainage
and hydrology changes resulting from project
implementation shall be provided, as well as a
description of stormwater treatment methods.
Minimization and avoidance measures shall be
proposed, as appropriate, and may include
preconstruction species surveys and reporting,
protective fencing around avoided biological
resources, worker environmental awareness
training, seeding disturbed areas adjacent to
open space areas with native seed, and
installation of project-specific stormwater Best
Management Practices (BMPs). Mitigation for
impacts to Goodding’s willow – red willow
riparian woodland and forest, valley oak
riparian forest woodland, and California
bulrush marsh may include restoration or
enhancement of resources on- or off-site, or
any other method acceptable to CDFW.
Mitigation shall not result in a net loss of a
Sensitive Natural Community.
If CDFW determines through the course of the
CFGC Section 1600 notification process that
the project does not require a Lake or
Final EIR
Airport South Industrial Park Project
March 2025
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Streambed Alteration Agreement (LSAA) to
address potential impacts to Goodding’s willow
– red willow riparian woodland and forest,
valley oak riparian forest woodland, and
California bulrush marsh, further mitigation
regarding the aforementioned vegetation
communities shall not be required. Written
verification of the applicant’s compliance with
the Section 1600 LSAA process shall be
submitted to the City of Sacramento
Community Development Department.
Nonparticipating Parcels
4.4-10(b)As part of any application associated with
development of the nonparticipating parcels,
the applicant shall ensure that a qualified
biologist has reviewed areas proposed for
disturbance to identify vegetation communities
that occur in the development footprint and
confirm the presence and acreages of
Sensitive Natural Communities. If a Sensitive
Natural Community would not be impacted,
further mitigation shall not be required. The
qualified biologist shall detail any
recommendations to avoid impacts to
identified Sensitive Natural Communities in a
report, which shall be submitted for review and
approval to the City of Sacramento Community
Development Department.
4.4-10(c)If a Sensitive Natural Community or potentially jurisdictional aquatic resource is identified in a
nonparticipating parcel for which a
development application has been submitted,
City of
Sacramento
Community
Development
Department
See Mitigation
Measure 4.4-
10(a)
As part of any
application
associated with
development of the
nonparticipating
parcels
If a Sensitive
Natural Community
is identified in a
nonparticipating
Final EIR
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March 2025
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the applicant shall implement Mitigation
Measure 4.4-10(a).
parcel for which a
development
application has
been submitted
4.4-11 Have a substantial
adverse effect on State
or federally protected
wetlands (including, but
not limited to, marsh,
vernal pool, coastal, etc.)
through direct removal,
filling, hydrological
interruption, or other
means.
Industrial Park
4.4-11(a)Prior to the issuance of grading permits, the
project applicant shall submit the Aquatic
Resources Delineation (ARD) prepared for the
proposed project by Bargas Environmental
Consulting to the U.S. Army Corps of
Engineers (USACE) for a Preliminary
Jurisdictional Determination and obtain
authorization for the fill of jurisdictional waters
of the U.S. through the Clean Water Act (CWA)
Section 404 permitting process. Timing for
compliance with the specific conditions of the
Section 404 permit shall be pursuant to the
conditions specified by USACE as part of
permit issuance. Proof of compliance with the
requirements established herein shall be
submitted for review and approval to the City
of Sacramento Community Development
Department.
4.4-11(b)Prior to construction in any areas containing
wetlands or waters of the U.S. and/or State,
the project applicant shall obtain a water
quality certification pursuant to Section 401 of
the CWA. Any measures required as part of
the issuance of the water quality certification
shall be implemented.
4.4-11(c)Prior to construction in any areas containing
wetlands or waters of the U.S. and/or State,
City of
Sacramento
Community
Development
Department
USACE
RWQCB
RWQCB
Prior to the
issuance of grading
permits
Prior to construction
in any areas
containing wetlands
or waters of the
U.S. and/or State
Prior to construction
in any areas
Final EIR
Airport South Industrial Park Project
March 2025
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the project applicant shall file a report of waste
discharge with the Central Valley Regional
Water Quality Control Board (RWQCB) for
activities affecting wetlands or waters of the
State that are not also under USACE
jurisdiction, if applicable.
4.4-11(d)Implement Mitigation Measure 4.4-10(a).
Nonparticipating Parcels
4.4-11(e)As part of any application associated with
development of the nonparticipating parcels,
the applicant shall ensure that a qualified
biologist has conducted an Aquatic Resources
Delineation (ARD) for areas proposed for
disturbance to identify potential waters of the
U.S. and/or State. The ARD shall be
conducted in accordance with the minimum
standards set forth by the USACE South
Pacific Division and Sacramento District
Regulatory Program, as well as the Corps of
Engineers Wetlands Delineation Manual,
Regional Supplement to the Corps of
Engineers Wetland Delineation Manual: Arid
West Region, and A Field Guide to the
Identification of the Ordinary High Water Mark
(OHWM) in the Arid West Region of the
Western United States or any manuals that
supplement or replace these manuals.
See Mitigation
Measure 4.4-
10(a)
City of
Sacramento
Community
Development
Department
USACE
containing wetlands
or waters of the
U.S. and/or State
See Mitigation
Measure 4.4-10(a)
As part of any
application
associated with
development of the
nonparticipating
parcels
Final EIR
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March 2025
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If potential waters of the U.S. and/or State are
not identified, further mitigation shall not be
required. The ARD shall be submitted for
review and approval to the City of Sacramento
Community Development Department and
USACE Sacramento District Regulatory
Division.
4.4-11(f) If waters of the U.S. and/or State are identified within areas proposed for disturbance, the
project applicant shall implement Mitigation
Measures 4.4-11(a) through 4.4-11(d), as
applicable.
See Mitigation
Measures 4.4-
11(a) through
4.4-11(d)
If waters of the U.S.
and/or State are
identified within
areas proposed for
disturbance
4.4-12 Interfere substantially
with the movement of
any native resident or
migratory fish or wildlife
species or with
established native
resident or migratory
wildlife corridors, or
impede the use of native
wildlife nursery sites.
4.4-12 Implement Mitigation Measure 4.4-3. See Mitigation Measure 4.4-3
See Mitigation
Measure 4.4-3
4.4-13 Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance.
Industrial Park
4.4-13(a) Prior to the issuance of any grading permit
and commencement of ground-disturbing
activities, the project applicant shall hire a
qualified arborist to evaluate all trees within
areas proposed for disturbance to confirm if
the trees meet the definition of a Private
Protected Tree, as set forth by Sacramento
City Code Section 12.56.020. Results of the
tree survey shall be submitted for review
and approval to the City of Sacramento
City of
Sacramento
Community
Development
Department
Prior to the
issuance of any
grading permit and
commencement of
ground-disturbing
activities within
Industrial Park
Final EIR
Airport South Industrial Park Project
March 2025
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Department of Public Works’ Urban
Forestry section. Should any on-site tree
that would be potentially impacted by the
proposed project be found to qualify as a
Private Protected Tree, the project applicant
shall obtain a Tree Permit from the City of
Sacramento Community Development
Department and comply with the permit
requirements in effect at the time of project
grading for removal, pruning, or soil
disturbance within the canopy dripline of a
Private Protected Tree.
Nonparticipating Parcels
4.4-13(b) As part of any application associated with
development of the nonparticipating
parcels, the applicant shall hire a qualified
arborist to conduct a tree survey of areas
proposed for disturbance to identify any
trees that meet the definition of a Private
Protected Tree, as established by
Sacramento City Code Section 12.56.020.
A report detailing the results of the survey
shall be submitted for review and approval
to the City of Sacramento Community
Development Department. If protected trees
are not identified, further mitigation shall not
be required.
4.4-13(c)If protected trees are identified in areas
proposed for disturbance of nonparticipating
parcels, the applicant shall implement
Mitigation Measure 4.4-13(a).
City of
Sacramento
Community
Development
Department
See Mitigation
Measure 4.4-
13(a)
As part of any
application
associated with
development of the
nonparticipating
parcels
If protected trees
are identified in
areas proposed for
Final EIR
Airport South Industrial Park Project
March 2025
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disturbance of nonparticipating parcels
4.4-15 Cumulative loss of
habitat for special-status
species.
Industrial Park
4.4-15(a)Implement Mitigation Measures 4.4-1(a) and
4.4-1(b), 4.4-3, 4.4-4(a), 4.4-5(a) and 4.4-5(b),
4.4-6, 4.4-8, 4.4-9(a) and 4.4-9(b), 4.4-10(a),
4.4-11(a) through 4.4-11(c), and 4.4-13(a).
Nonparticipating Parcels
4.4-15(b)Implement Mitigation Measures 4.4-1(a) and
4.4-1(b), 4.4-3, 4.4-4(a), 4.4-5(a) and 4.4-5(b),
4.4-6, 4.4-8, 4.4-9(a) and 4.4-9(b), 4.4-10(b)
and 4.4-10(c), 4.4-11(e) and 4.4-11(f), and 4.4-
13(b) and 4.4-13(c).
See Mitigation
Measures 4.4-
1(a) and 4.4-
1(b), 4.4-3,
4.4-4(a), 4.4-
5(a) and 4.4-
5(b), 4.4-6,
4.4-8, 4.4-9(a)
and 4.4-9(b),
4.4-10(a), 4.4-
11(a) through
4.4-11(c), and
4.4-13(a).
See Mitigation
Measures 4.4-
1(a) and 4.4-
1(b), 4.4-3,
4.4-4(a), 4.4-
5(a) and 4.4-
5(b), 4.4-6,
4.4-8, 4.4-9(a)
and 4.4-9(b),
4.4-10(b) and
4.4-10(c), 4.4-
11(e) and 4.4-
11(f), and 4.4-
13(b) and 4.4-
13(c)
See Mitigation
Measures 4.4-1(a)
and 4.4-1(b), 4.4-3,
4.4-4(a), 4.4-5(a)
and 4.4-5(b), 4.4-6,
4.4-8, 4.4-9(a) and
4.4-9(b), 4.4-10(a),
4.4-11(a) through
4.4-11(c), and 4.4-
13(a).
See Mitigation
Measures 4.4-1(a)
and 4.4-1(b), 4.4-3,
4.4-4(a), 4.4-5(a)
and 4.4-5(b), 4.4-6,
4.4-8, 4.4-9(a) and
4.4-9(b), 4.4-10(b)
and 4.4-10(c), 4.4-
11(e) and 4.4-11(f),
and 4.4-13(b) and
4.4-13(c)
4.5 Cultural Resources
Final EIR
Airport South Industrial Park Project
March 2025
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4.5-2 Cause a substantial
adverse change in the
significance of a unique
archeological resource
pursuant to CEQA
Guidelines, Section
15064.5 or disturb
human remains,
including those interred
outside of dedicated
cemeteries.
4.5-2 The following requirements shall be included
through a notation on all project grading plans
prior to the issuance of grading permits, to the
satisfaction of the City Engineer.
In the event subsurface deposits believed to
be cultural or human in origin are discovered
during construction, all work shall halt within a
50-foot radius of the discovery. A qualified
professional archaeologist, meeting the
Secretary of the Interior’s Professional
Qualification Standards for precontact and
historic archaeologist, shall be retained to
evaluate the significance of the find, and shall
have the authority to modify the no-work radius
as appropriate, using professional judgment.
The following notifications shall apply,
depending on the nature of the find:
• If the professional archaeologist
determines that the find does not
represent a cultural resource, work
may resume immediately, and agency
notifications are not required.
• If the professional archaeologist
determines that the find does
represent a cultural resource from any
time period or cultural affiliation, he or
she shall immediately notify the City of
Sacramento and applicable
landowner. The project applicant shall
consult on a finding of eligibility and
implement appropriate treatment
measures, if the find is determined to
Sacramento
City Engineer
Sacramento
County
Coroner
Native
American
Heritage
Commission
(NAHC)
Prior to issuance of
grading permits
Final EIR
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March 2025
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be a Historical Resource under CEQA,
as defined in Section 15064.5(a) of the
CEQA Guidelines. Appropriate
treatment measures that preserve or
restore the character and integrity of a
find may be, but are not limited to,
processing materials for reburial,
minimizing handling of historical
objects, leaving objects in place within
the landscape, construction
monitoring of further construction
activities, and/or returning objects to a
location within the project area where
they will not be subject to future
impacts. Work shall not resume within
the no-work radius until the applicant,
through consultation, as appropriate,
determines that the site either: 1) is
not a historical resource under CEQA,
as defined in Section 15064.5(a) of the
CEQA Guidelines; or 2) that the
treatment measures have been
completed to the City’s satisfaction.
• If the find includes human remains, or
remains that are potentially human, he
or she shall ensure reasonable
protection measures are taken to
protect the discovery from disturbance
(Assembly Bill [AB] 2641). The
archaeologist shall notify the City of
Sacramento and the Sacramento
County Coroner (per Section 7050.5
of the Health and Safety Code). The
provisions of Section 7050.5 of the
Final EIR
Airport South Industrial Park Project
March 2025
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California Health and Safety Code,
Section 5097.98 of the California
PRC, and AB 2641 shall be
implemented. If the Coroner
determines the remains are Native
American and not the result of a crime
scene, the Coroner shall notify the
NAHC, which then shall designate a
Native American Most Likely
Descendant (MLD) for the proposed
project (Section 5097.98 of the PRC).
The designated MLD shall have 48
hours from the time access to the
property is granted to make
recommendations concerning
treatment of the remains. If the
landowner does not agree with the
recommendations of the MLD, the
NAHC shall mediate (Section 5097.94
of the PRC). If an agreement is not
reached, the landowner shall rebury
the remains where they shall not be
further disturbed (Section 5097.98 of
the PRC). The burial shall also include
either recording the site with the
NAHC or the appropriate information
center, using an open space or
conservation zoning designation or
easement, or recording a reinternment
document with Sacramento County
(AB 2641). Work shall not resume
within the no-work radius until the City,
through consultation as appropriate,
determines that the treatment
Final EIR
Airport South Industrial Park Project
March 2025
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measures have been completed to
their satisfaction.
4.6 Geology and Soils
4.6-3 Be located on a
geological unit or soil
that is unstable, or that
would become unstable
as a result of the project,
and potentially result in
on or off-site landslide,
lateral spreading,
subsidence, liquefaction,
or collapse, or be located
on expansive soil, as
defined in Table 18-1B of
the Uniform Building
Code.
4.6-3 Prior to issuance of grading permits, the
grading plans shall incorporate the
geotechnical recommendations specified in
the Preliminary Geotechnical Exploration
prepared for the proposed project, including,
but not limited to, earthwork
recommendations, foundation wall
recommendations, pavement
recommendations, exterior flatwork
recommendations, and the preparation of a
design-level geotechnical report. All grading
and foundation plans for the development
must be reviewed and approved by the City
Engineer and Chief Building Official, or their
representative(s), prior to issuance of grading
and building permits in order to ensure that
recommendations in the Preliminary
Geotechnical Exploration are properly
incorporated and utilized in the project design.
Sacramento
City Engineer
City of
Sacramento
Chief Building
Official
Prior to issuance of
grading permits
4.6-4 Directly or indirectly
destroy a unique
paleontological resource
or site or unique geologic
feature.
4.6-4 Should construction or grading activities result
in the discovery of unique paleontological
resources, all work within 100 feet of the
discovery shall cease. The City of Sacramento
Community Development Department shall be
notified, and the resources shall be examined
by a qualified archaeologist, paleontologist, or
historian, at the developer’s expense, for the
purpose of recording, protecting, or curating
the discovery as appropriate. The
archaeologist, paleontologist, or historian shall
submit to the City of Sacramento Community
City of
Sacramento
Community
Development
Department
Should construction
or grading activities
result in the
discovery of unique
paleontological
resources
Final EIR
Airport South Industrial Park Project
March 2025
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Development Department for review and
approval a report of the findings and method of
curation or protection of the resources. Work
may only resume in the area of discovery when
the preceding work has occurred.
4.7 Hazards and Hazardous Materials
4.7-2 Create a significant
hazard to the public or
the environment through
reasonably foreseeable
upset and accident
conditions involving the
likely release of
hazardous materials into
the environment.
4.7-2(a) Prior to approval of grading permits, a surficial soil sample laboratory analysis shall be
conducted on the project site. Once the soils
are collected, the soils shall be tested for
OCPs, lead, and asbestos. If soil contaminates
are not found, further action is not required;
however, if OCPs, lead, or asbestos is found
to be higher than the allowable thresholds, the
assessment shall include the appropriate
mitigation including, but not limited to, soil
remediation to an acceptable total threshold
limit concentration (TTLC) level per applicable
State and federal regulations by excavation of
the contaminated soil, and subsequent
transportation and disposal off-site at an
appropriate Class I or Class II facility permitted
by DTSC; or by properly capping the
contaminated soil, in compliance with DTSC
regulations (e.g., placing soils underneath
project roadways, etc.). All recommended
mitigation measures shall be implemented by
the project applicant, subject to review and
approval by the City of Sacramento
Community Development Department.
4.7-2(b) Prior to approval of grading permits for Parcel 1 and/or Parcel 6A, samples of the soil
stockpiles on-site shall be obtained for
City of
Sacramento
Community
Development
Department
City of
Sacramento
Community
Prior to approval of
grading permits
Prior to approval of
grading permits for
Parcel 1 and/or
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analysis of contaminants of concern and
comparison with applicable regulatory
screening levels (i.e., Environmental
Screening Levels, California Human Health
Screening Levels, Regional Screening Levels,
etc.). If soil contaminates are not found, further
action is not required. However, where the soil
contaminant concentrations exceed the
applicable regulatory screening levels, the
impacted soil shall be excavated and disposed
of off-site at a licensed landfill facility to the
satisfaction of the City of Sacramento
Community Development Department.
Development
Department
Parcel 6A
4.7-5 For a project located
within an airport land use
plan or, where such a
plan has not been
adopted, within two miles
of a public airport or
public use airport, would
the project result in a
safety hazard or
excessive noise for
people residing or
working in the project
area.
4.7-5(a) To ensure that the final location and design of the detention basins are consistent with the
recommendations of the Airport Land Use
Commission (ALUC) regarding wildlife
hazards to aviation, the project applicant shall
prepare a design and management plan for
this proposed drainage feature. This plan shall
be prepared in coordination with the
Sacramento International Airport Operations
Manager before commencement of
construction. The plan shall determine an
appropriate size and location for the detention
basins and incorporate specific design
measures deemed sufficient by Sacramento
County Airport System (SCAS) and the ALUC
to minimize bird strikes and other wildliferelated airspace safety hazards in the vicinity of the project area. The plan shall include
information sufficient to satisfy requirements
for preparation of a Wildlife Hazard
Management Plan and shall be prepared by a
Sacramento
International
Airport
Operations
Manager
Sacramento
County Airport
System
(SCAS)
Airport Land
Use
Commission
(ALUC)
Prior to
commencement of
construction
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qualified wildlife hazard damage biologist. The
project applicant shall submit a detailed design
drawing of the proposed detention basins to
SCAS for review.
To reduce bird attractants associated with the
detention basins, the Wildlife Hazards
Management Plan for the detention basins and
surrounding landscape shall include the
following:
• Any vegetation planted in the vicinity
of the detention basins shall consist of
plant species that do not provide birds
with opportunities for cover, nesting,
perching, or feeding. A detailed design
plan for landscaping surrounding the
detention basins shall be submitted to
SCAS for view;
• Signs shall be placed at regular
intervals around the perimeter of the
detention basins prohibiting the public
from feeding any wildlife. The project
applicant, and any subsequent
property owner shall maintain such
signs in good order and replace such
signs as necessary. This responsibility
shall transfer to the Property
Management Association and shall be
articulated in the covenants,
conditions, and restrictions (CC&Rs);
• The CC&Rs shall specify that the
project proponent and project
applicant shall be responsible for
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ensuring trash receptacles with covers
are provided and properly emptied on
a regular basis and replaced as
needed;
• Installation of structures near the
detention basins that could serve as
perches for gulls and other birds shall
be minimized. The CC&Rs, or other
mechanism, shall prohibit the future
installation of such structures.
• The project applicant shall prohibit all
activities and uses that could conflict
with implementation of the wildlife
hazard management program.
An Adaptive Management Plan shall be
prepared and incorporated into the Wildlife
Hazard Management Plan. The Adaptive
Management Plan shall provide for the longterm management of nuisance birds around the detention basins. The management plan
shall involve monitoring and employment of
various techniques for controlling birds using
adaptive information and bird control products.
The Property Management Association, or if
none exists, the property owner shall be
responsible for ensuring the implementation
and continued enforcement of the Adaptive
Management Plan and provision of adequate
funding. This requirement shall be specified in
the CC&Rs or other mechanism. The Adaptive
Management Plan shall include the following
components:
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• Bird control program that involves use
of the most efficient and effective bird
control techniques available that are
practicable and compatible with
surrounding land uses.,
• Monitoring program that involves
patrolling of the detention basins and
assessment of the effectiveness of
bird control measures, the presence of
potential bird attractants, and the need
for modifying or increasing bird control
measures,
• Funding mechanism such as use of an
endowment fund or assessment
district to fund the long-term
monitoring and adaptive management
program.
• Any use of the detention basins that
conflicts with the wildlife control
program shall be prohibited.
• The Adaptive Management Plan shall
include the best available information
on various bird control techniques, an
explanation of the situations in which
various techniques are best
employed, and instructions for
implementing such techniques. The
entity responsible for implementing
the management plan shall employ a
qualified and experienced Wildlife
Damage Biologist/Manager
(Manager) who shall be responsible
for determining which bird control
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techniques to implement based on
information provided in the
management plan and the best
scientific and commercial information
available. The Manager shall be
trained in bird control techniques by
the U.S. Department of AgricultureWildlife Services (USDA). The initial cost of such training shall be borne by
the project applicant. The cost of
subsequent training shall be borne by
the Property Management
Association. The Manager shall have
the discretion to use new technologies
or information regarding bird control
provided they are practicable and
within the management budget, and
do not conflict with surrounding land
uses or storm water control functions
of the detention basins.
The monitoring and maintenance portion of the
Adaptive Management Plan shall include the
following:
• Patrol to ensure the detention basin
areas are kept clean and free of refuse
and other such material that may
attract birds;
• Patrol to ensure the public is abiding
by rules prohibiting feeding of birds;
• Control of vegetative growth around
the detention basins to minimize any
vegetation that would attract birds for
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purpose of cover, nesting, perching, or
food;
• Remove all nesting material prior to
completion of nest if any birds attempt
to nest in areas surrounding the
detention basins. All nest removal
activities must comply with provisions
of the Migratory Bird Treaty Act, the
California Endangered Species Act,
and the federal Endangered Species
Act;
• Inspect the detention basin areas to
determine whether additional
measures are needed to reduce bird
use of the detention basins; and
• Aggressively haze wildlife to
discourage use of the basins.
If monitoring efforts reveal that additional
control efforts are necessary, the Bird Control
Program Manager may implement one or more
control techniques outlined in the Adaptive
Management Plan, or other techniques based
on best available scientific and commercial
information. Bird control techniques currently
being used at airports, on agricultural lands,
and in other areas where birds pose a hazard
or nuisance shall be described in the Adaptive
Management Plan. The Bird Control Program
Manager shall have discretion of using any
one or more of the techniques based on the
need, practicability, and land use compatibility.
These techniques may include, but are not
limited to, allowing grass to grow over 8 inches
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in height (currently being employed at some
airports).
In addition to these control techniques, the
Adaptive Management Plan shall outline an
education program for the Property
Management Association to implement
ensuring that the public is aware of the
importance of eliminating bird attractants from
the area around the lake. The public shall be
prohibitive from feeding birds around the
detention basins and engaging in any other
activities within the boundaries of the
development project which may attract wildlife
hazards to aircraft operations. The public shall
be made aware of the purpose and importance
of various bird control measures being
implemented by the Bird Control Program
Manager.
All activities and uses of the detention basins
that may conflict with the wildlife control
program shall be expressly prohibited.
If the SCAS determines that conditions in the
Airport South Industrial Project Development
are not consistent with the above listed
Management Program, SCAS may take the
following actions:
• Notify the property owner that the
wildlife control measures are out of
compliance;
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• County Airport System may, at its
option, initiate control measures at the
site, with the costs of such measures
billed to the owner; and
• In the event of an immediate threat to
aircraft safety, County Airport System
personnel can take immediate action
to remedy the air hazard emergency.
To reduce attractants for Canada geese,
American coots, or gulls associated with the
detention basins and surrounding landscape
the Management Plan shall include the
following:
• Signs shall be posted and identify that
feeding birds is prohibited.
• Any nest building activity associated
with birds shall be removed including
all nesting materials.
• To prevent the establishment of
resident populations of Canada geese
on the project site, the Bird Control
Program Manager shall take the
following, but not limited to, actions:
o Chase birds from site,
o Use of noise generators (e.g.,
pyrotechnic devices, blank
cartridges),
o Use of visual devices (e.g.,
flags, scarecrows, water
sprays)
o Use of chase dogs,
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o Live trapping or netting,
and/or
o Use of chemical repellants.
4.8 Hydrology and Water Quality
4.8-1 Violate any water quality
standards or waste
discharge requirements
or otherwise substantially
degrade surface or
ground water quality
during construction.
4.8-1 Prior to issuance of any grading permits, the
contractor shall prepare a Storm Water
Pollution Prevention Plan (SWPPP) for review
and approval by the Central Valley RWQCB.
The contractor shall file the Notice of Intent
(NOI) and associated fee to the SWRCB. The
SWPPP shall serve as the framework for
identification, assignment, and implementation
of BMPs. The contractor shall implement
BMPs to reduce pollutants in stormwater
discharges to the maximum extent practicable.
Construction (temporary) BMPs for the project
may include, but are not limited to: fiber rolls,
straw bale barrier, straw wattles, storm drain
inlet protection, velocity dissipation devices,
silt fences, wind erosion control, stabilized
construction entrance, hydroseeding,
revegetation techniques, and dust control
measures. The SWPPP shall be submitted to
both the City Director of Public Works, and the
City Engineer for review and approval and
shall remain on the project site during all
phases of construction. Following
implementation of the SWPPP, the contractor
shall subsequently demonstrate the SWPPP’s
effectiveness and provide for necessary and
appropriate revisions, modifications, and
improvements to reduce pollutants in
stormwater discharges to the maximum extent
practicable.
RWQCB
City of
Sacramento
Director of
Public Works
Sacramento
City Engineer
Prior to issuance of
any grading permits
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4.8-2 Violate any water quality
standards or waste
discharge requirements
or otherwise substantially
degrade surface or
ground water quality
during operations.
4.8-2 Prior to approval of final project improvement
plans for any on-site development, the project
applicant shall submit a detailed Best
Management Practice (BMP) and water quality
maintenance plan to the City for review and
approval. The BMP and water quality
maintenance plan shall meet the standards of
the City’s NPDES Permit, the California
Stormwater Quality Association (CASQA)
Stormwater BMP Handbook for New
Development and Redevelopment, and the
Stormwater Quality Design Manual for the
Sacramento region. Site design measures,
source control measures, hydromodification
management, and Low Impact Development
(LID) standards, as necessary, shall be
incorporated into the design and shown on the
improvement plans.
City of
Sacramento
Community
Development
Department
Prior to approval of
final project
Improvement Plans
for any on-site
development
4.8-5 Substantially alter the
existing drainage pattern
of the site or area,
including through the
alteration of the course
of a stream or river or
through the addition of
impervious surfaces, in a
manner which would
impede or redirect flood
flows, or in flood hazard,
tsunami, or seiche zone,
risk release of pollutants
due to project inundation.
4.8-5 Prior to approval of any grading permits, the
applicant shall obtain from the Federal
Emergency Management Agency (FEMA), a
Conditional Letter of Map Revision (CLOMR)
or Conditional Letter of Map Revision based on
Fill (CLOMR-F) for fill within a Special Flood
Hazard Area, if required. A copy of the letter
shall be provided to the Engineering Services
Division. A Letter of Map Revision (LOMR), or
a Letter of Map Revision based on Fill (LOMRF) from FEMA shall be provided to the City Engineer prior to acceptance of grading
permits as complete.
City of
Sacramento
Engineering
Services
Division
Sacramento
City Engineer
Prior to approval of
any grading permits
4.10 Noise
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4.10-2 Generation of a
substantial permanent
increase in ambient
noise levels in the vicinity
of the project in excess
of standards established
in the local general plan
or noise ordinance, or
applicable standards of
other agencies.
4.10-2 Prior to approval by the City’s Public Works
Department of the final Improvement Plans for
the nonparticipating parcels portion of the
proposed project, the Improvement Plans shall
include the following requirements:
• An eight-foot-tall sound wall shall be
constructed along the eastern project
boundary, in the location indicated in
4.10-6 and the Environmental Noise
Assessment prepared for the
proposed project by Saxelby
Acoustics, in order to achieve the
City’s nighttime 50 dBA L50 noise
level standards.
• Noise barrier walls shall be
constructed of concrete panels,
concrete masonry units, earthen
berms, or any combination of these
materials that achieve the required
total height. Wood is not
recommended due to eventual
warping and degradation of acoustical
performance.
City of
Sacramento
Public Works
Department
Prior to approval of
the final
Improvement Plans
for the
nonparticipating
parcels
4.12 Transportation
4.12-2 Conflict with a program,
plan, ordinance, or policy
addressing the
circulation system during
operations.
4.12-2 The following requirements shall be noted on
project improvement plans, subject to review
and approval by the City of Sacramento
Community Development Department:
• The project should construct
pedestrian and bicycle facilities along
its frontage to City Standards.
City of
Sacramento
Community
Development
Department
Prior to the approval
of project
Improvement Plans
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• Class IV separated bicycle facilities
shall be accommodated within the
proposed cross section to provide
separation between cyclists and
heavy truck traffic.
• The bicycle network shall be
connected to the existing and planned
City and County bikeway system,
including, but not limited to, Bayou
Way at the northeast corner of the site,
the Class I bikeway at the southeast
corner of the site, and Metro Air
Parkway north of I-5.
• • The off-street Class IV cycle
track shown on the eastern side of the
site in the City Bikeway Master Plan
shall be accommodated in the
proposed plans.
4.12-3 Conflict or be
inconsistent with CEQA
Guidelines Section
15064.3, subdivision (b).
4.12-3 Prior to the certificate of occupancy for each
on-site industrial building, the owner/operator
of each building shall be required to prepare
and implement a VMT Reduction Plan that
includes a sufficient selection of CAPCOA Trip
Reduction Programs (T-6 through T-13) to
reduce VMT by at least 22 percent, consistent
with the VMT Mitigation Memorandum
prepared by the City’s Public Works
Department for the proposed project (see
Appendix Q to the EIR). CAPCOA Trip
Reduction Programs T-6 through T-13 include
measures such as implementing a commute
trip reduction program and/or marketing,
providing a rideshare program, implementing a
subsidized or discounted transit program,
City of
Sacramento
Department of
Public Works
City of
Sacramento
Community
Development
Department
Prior to the
certificate of
occupancy for each
on-site industrial
building
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providing end-of-trip bicycle facilities, providing
employer-sponsored vanpool, pricing
workplace housing, and implementing
employee parking cash-out. The VMT
Reduction Plan shall be submitted to the City’s
Department of Public Works and Community
Development Department for review and
approval.
4.13 Tribal Cultural Resources
4.13-1 Cause a substantial
adverse change in the
significance of a tribal
cultural resource, defined
in PRC Section 21074.
4.13-1(a)Conduct Cultural Resources Sensitivity
and Awareness Training Prior to GroundDisturbing Activities The City shall require the applicant/contractor
to provide a tribal cultural resources sensitivity
and awareness training program (Worker
Environmental Awareness Program [WEAP])
for all personnel involved in project
construction, including field consultants and
construction workers. The WEAP will be
developed in coordination with culturally
affiliated Native American tribes. The WEAP
shall be conducted before any project-related
construction activities begin at the project site.
The WEAP will include relevant information
regarding sensitive tribal cultural resources,
including applicable regulations, protocols for
avoidance, and consequences of violating
State laws and regulations.
The WEAP will also describe appropriate
avoidance and impact minimization measures
for tribal cultural resources that could be
located at the project site and will outline what
City of
Sacramento
Community
Development
Department
Before any projectrelated construction
activities begin at
the project site
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to do and who to contact if any potential tribal
cultural resources are encountered. The
WEAP will emphasize the requirement for
confidentiality and culturally appropriate
treatment of any discovery of significance to
Native Americans and will discuss appropriate
behaviors and responsive actions, consistent
with Native American tribal values.
4.13-1(b)In the Event that Tribal Cultural Resources
are Discovered During Construction,
Implement Procedures to Evaluate Tribal
Cultural Resources and Implement
Avoidance and Minimization Measures to
Avoid Significant Impact.
If tribal cultural resources (such as structural
features, unusual amounts of bone or shell,
artifacts, or human remains) are encountered
at the project site during construction, work
shall be suspended within 100 feet of the find
(based on the apparent distribution of cultural
materials), and the construction contractor
shall immediately notify the project’s City
representative. Avoidance and preservation in
place is the preferred manner of mitigating
impacts to tribal cultural resources. This will be
accomplished, if feasible, by several
alternative means, including:
• Planning construction to avoid tribal
cultural resources, archaeological
sites and/or other cultural resources;
incorporating cultural resources within
City of
Sacramento
Community
Development
Department
Culturally
affiliated
Native
American
tribes and
other
appropriate
agencies
During construction
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parks, green-space or other open
space; covering archaeological
resources; deeding a cultural resource
to a permanent conservation
easement; or other preservation and
protection methods agreeable to
consulting parties and regulatory
authorities with jurisdiction over the
activity.
• Recommendations for avoidance of
tribal cultural resources will be
reviewed by the City representative,
interested culturally affiliated Native
American tribes and other appropriate
agencies, in light of factors such as
costs, logistics, feasibility, design,
technology and social, cultural and
environmental considerations, and the
extent to which avoidance is
consistent with project objectives.
Avoidance and design alternatives
may include realignment within the
project site to avoid tribal cultural
resources, modification of the design
to eliminate or reduce impacts to tribal
cultural resources or modification or
realignment to avoid highly significant
features within a cultural resource or
tribal cultural resource.
• Native American representatives from
interested culturally affiliated Native
American tribes will be notified to
review and comment on these
analyses and shall have the
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opportunity to meet with the City
representative and its representatives
who have technical expertise to
identify and recommend feasible
avoidance and design alternatives, so
that appropriate and feasible
avoidance and design alternatives can
be identified.
• If the discovered tribal cultural
resource can be avoided, the
construction contractor(s), will install
protective fencing outside the site
boundary, including a 100-foot buffer
area, before construction restarts. The
boundary of a tribal cultural resource
will be determined in consultation with
interested culturally affiliated Native
American tribes and tribes will be
notified to monitor the installation of
fencing. Use of temporary and
permanent forms of protective fencing
will be determined in consultation with
Native American representatives from
interested culturally affiliated Native
American tribes.
• The construction contractor(s) will
maintain the protective fencing
throughout construction to avoid the
site during all remaining phases of
construction. The area will be
demarcated as an “Environmentally
Sensitive Area”.
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If a tribal cultural resource cannot be avoided,
the following performance standard shall be
met prior to continuance of construction and
associated activities that may result in damage
to or destruction of tribal cultural resources:
• Each resource will be evaluated for
California Register of Historical
Resources- (CRHR) eligibility through
application of established eligibility
criteria (California Code of Regulations
15064.636), in consultation with
consulting Native American tribes, as
applicable.
If a tribal cultural resource is determined to be
eligible for listing in the CRHR, the City will
avoid damaging effects to the resource in
accordance with California PRC Section
21084.3, if feasible. The City shall coordinate
the investigation of the find with a qualified
archaeologist (meeting the Secretary of the
Interior’s Professional Qualifications
Standards for Archeology) approved by the
City and with interested culturally affiliated
Native American tribes that respond to the
City’s notification. As part of the site
investigation and resource assessment, the
City and the archaeologist shall consult with
interested culturally affiliated Native American
tribes to assess the significance of the find,
make recommendations for further evaluation
and treatment as necessary and provide
proper management recommendations should
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potential impacts to the resources be
determined by the City to be significant. A
written report detailing the site assessment,
coordination activities, and management
recommendations shall be provided to the City
representative by the qualified archaeologist.
These recommendations will be documented
in the project record. For any
recommendations made by interested
culturally affiliated Native American tribes that
are not implemented, a justification for why the
recommendation was not followed will be
provided in the project record.
Native American representatives from
interested culturally affiliated Native American
tribes and the City representative will also
consult to develop measures for long-term
management of any discovered tribal cultural
resources. Consultation will be limited to
actions consistent with the jurisdiction of the
City and taking into account ownership of the
subject property. To the extent that the City
has jurisdiction, routine operation and
maintenance within tribal cultural resources
retaining tribal cultural integrity shall be
consistent with the avoidance and
minimization standards identified in this
mitigation measure.
If the City determines that the project may
cause a significant impact to a tribal cultural
resource, and measures are not otherwise
identified in the consultation process, the
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following are examples of mitigation capable of
avoiding or substantially lessening potential
significant impacts to a tribal cultural resource
or alternatives that would avoid significant
impacts to the resource. These measures may
be considered to avoid or minimize significant
adverse impacts and constitute the standard
by which an impact conclusion of less-than
significant may be reached:
• Avoid and preserve resources in
place, including, but not limited to,
planning construction to avoid the
resources and protect the cultural and
natural context, or planning
greenspace, parks, or other open
space, to incorporate the resources
with culturally appropriate protection
and management criteria.
• Treat the resource with culturally
appropriate dignity taking into account
the Tribal cultural values and meaning
of the resource, including, but not
limited to, the following:
o Protect the cultural character
and integrity of the resource.
o Protect the traditional use of
the resource.
o Protect the confidentiality of
the resource.
o Establish permanent
conservation easements or
other interests in real
property, with culturally
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appropriate management
criteria for the purposes of
preserving or using the
resources or places.
o Protect the resource.
4.13-1(c)Implement Procedures in the Event of the
Inadvertent Discovery of Native American
Human Remains.
If an inadvertent discovery of human remains
is made at any time during project-related
construction activities or project planning, the
City will implement the procedures listed
above. The following performance standards
shall be met prior to implementing or
continuing actions such as construction, which
may result in damage to or destruction of
human remains. In accordance with the
California Health and Safety Code (HSC), if
human remains are encountered during
ground-disturbing activities, the City shall
immediately halt potentially damaging
excavation in the area of the remains and
notify the Sacramento County Coroner and a
professional archaeologist to determine the
nature of the remains. The Coroner is required
to examine all discoveries of human remains
within 48 hours of receiving notice of a
discovery on private or State lands (HSC
Section 7050.5[b]).
If the human remains are of historic age and
are determined to be not of Native American
City of
Sacramento
Community
Development
Department
Sacramento
County
Coroner
NAHC
If an inadvertent
discovery of human
remains is made at
any time during
project-related
construction
activities or project
planning
Final EIR
Airport South Industrial Park Project
March 2025
Chapter 4 – Mitigation Monitoring and Reporting Program
MITIGATION MONITORING AND REPORTING PROGRAM
Airport South Industrial Park Project
Impact
Number Impact Mitigation Measures Monitoring Agency
Implementation
Schedule Sign-off
origin, the City will follow the provisions of the
HSC Section 7000 (et seq.) regarding the
disinterment and removal of non-Native
American human remains.
If the Coroner determines that the remains are
those of a Native American, he or she must
contact the Native American Heritage
Commission (NAHC) by phone within 24 hours
of making that determination (HSC Section
7050[c]). After the Coroner’s findings have
been made, the archaeologist and the NAHCdesignated Most Likely Descendant (MLD), in consultation with the landowner, shall
determine the ultimate treatment and
disposition of the remains. The responsibilities
of the City for acting upon notification of a
discovery of Native American human remains
are identified in California PRC Section 5097.9
et seq.
Appendix A
777 12th Street, Ste. 300 • Sacramento, CA 95814
Tel: 279-207-1122 • Toll Free: 800-880-9025
AirQuality.org
June 19, 2024
Rod Stinson
Raney Planning & Management, Inc
1501 Sports Drive, Suite A
Sacramento, CA 95834
Subject: Airport South Industrial Park Project AQMP Verification Dear Rod Stinson:
Thank you for providing the May 2024 Air Quality Mitigation Plan (AQMP) for Airport South Industrial Park Project (Project).
By way of this letter, District staff are 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.
Please contact me at [email protected] or 916-704-4552 if you have any questions regarding this verification of technical adequacy.
Sincerely,
Roberto
Roberto Ramirez
Air Quality Planner / Analyst
c: Paul Philley, AICP, Program Supervisor, Sac Metro Air District Attachment:
Airport South Industrial Park AQMP
Appendix B
New City Hall | 915 I Street Room 2000 | Sacramento, CA 95814-2064 | 916-808-6738
DRAFT MEMORANDUM
DATE: September 5, 2023
TO: Pelle Clarke, Senior Engineer
FROM: Matthew Ilagan, Assistant Engineer
CC: David Edrosolan, City Traffic Engineer
SUBJECT: P21-017 Airport South Industrial - VMT Mitigation Measures Introduction & Background
The intent of this memo is to outline the P21-017 Airport South Industrial Vehicle Miles Traveled (VMT) mitigations and corresponding calculations for the project. The project is proposing to develop approximately 470 acres of vacant land into industrial and commercial uses in North Natomas that would be annexed into the City of Sacramento. The project is located south of I-5 and west of the Westlake community. The project would be connecting to the I-5 Metro Air Parkway interchange as well as Powerline Road to the west and Bayou Way to the east.
Per the DKS Draft VMT Analysis dated March 10, 2023, the proposed project would result in an average VMT calculated as 128% of the regional average and is considered an impact. Since Office of Planning and Research (OPR) does not specify a particular significance threshold for industrial employment, OPR recommends local jurisdictions to determine this threshold based on local conditions. Local jurisdictions in the region such as Sacramento County and City of Rancho Cordova have determined the significant threshold for industrial employment is 100% of regional average. In consistency with nearby jurisdictions, the City has established the significance threshold of 100% of regional average for industrial uses. With the 100% significance threshold, the project is required to mitigate 22% (1-1.00/1.28 = 0.22) to achieve a lessthan significant impact for VMT of 100%. Consistent with SB 743, OPR’s Technical Advisory, and California Air Pollution Control Officers Association (CAPCOA), the project is required to mitigate VMT through CAPCOA’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity dated December 2021.
CAPCOA Transportation Quantitative GHG Reduction Measures CAPCOA’s 2021 Handbook outlines the quantitative reduction measures that can be used to mitigation VMT. There are 6 categories within the Transportation section with corresponding subsections for quantifying VMT mitigation measures.
Below are the 6 categories:
1. Land Use
2. Trip Reduction Programs
3. Parking or Road Pricing/Management
4. Neighborhood Design
5. Transit
6. Clean Vehicles and Fuels
New City Hall | 915 I Street Room 2000 | Sacramento, CA 95814-2064 | 916-808-6738 Given the largely industrial nature of the project and no existing or planned transit within the project’s vicinity, all but the Trip Reduction Programs category can be eliminated when identifying applicable VMT mitigation measures for the project. Below are the following mitigation options within the Trip Reduction Program category with its subsequent maximum percentages to reduce VMT:
• T-5 Implement Commute Trip Reduction Program (Voluntary) – 4% • T-6 Implement Commute Trip Reduction Program (Mandatory Implementation & Monitoring) – 26% • T-7 Implement Commute Trip Reduction Marketing – 4%
• T-8 Provide Ridesharing Program – 8%
• T-9 Implement Subsidized or Discounted Transit Program – 5.5% • T-10 Provide End-of-Trip Bicycle Facilities – 4.4%
• T-11 Provide Employer-Sponsored Vanpool – 20.4%
• T-12 Price Workplace Parking – 20%
• T-13 Implement Employee Parking Cash-Out – 12%
• T-23 Provide Community-Based Travel Planning – 11.9%
While the Trip Reduction Programs allows for mitigating VMT up to a maximum of 45%, it also identifies additional limitations for quantifying the mitigation percentages to reduce VMT. Each subsector of mitigation options identifies mitigation options that have mutually exclusive measures as well as expanded mitigation options. The mutually exclusive measures identifies which measures cannot be credited together as it would be considered double counting.
Based on the mutually exclusive measures and expanded mitigation options, the following section details quantifying T-6 as the applicable mitigation measures that contain no mutually exclusive measures while limiting the Trip Reduction Programs at a maximum of 45%.
Trip Reduction Programs – T-6
As identified in CAPCOA’s 2021 Handbook, T-6 requires the implementation of a Commute Trip Reduction (CTR) Program that allows for a maximum of 26% for mitigating VMT. Within the implementation requirements, it explicitly outlines T-7 through T-11 cannot be used with this option. The mandatory CTR includes T-7 through T-11 and therefore cannot be added if T-6 is used. The expanded mitigation options for T-6 are identified to be T-12 or T-13 (cannot be both). Below is a list of implementation requirements for T-7 through T-11:
• T-7 Implement Commute Trip Reduction Marketing
o Onsite or online commuter information services
o Employee transportation coordinators
o Onsite or online transit pass sales
o Guaranteed ride home services
• T-8 Provide Ridesharing Program
o Ridesharing must be promoted through a multifaceted approach o Designating a certain percentage of desirable parking spaces for ridesharing vehicles o Designating adequate passenger loading and unloading and waiting areas for ridesharing vehicles o Providing an app or website for coordinating rides
• T-9 Implement Subsidized or Discounted Transit Program New City Hall | 915 I Street Room 2000 | Sacramento, CA 95814-2064 | 916-808-6738 o The project should be accessible either within 1 mile of high-quality transit service, 0.5 mile of local or less frequent transit service, or along a designated shuttle route providing last-mile connections to rail service
• T-10 Provide End-of-Trip Bicycle Facilities
o End-of trip facilities should be installed at a size proportional to the number of commuting bicyclists and regularly maintained
• T-11 Provide Employer-Sponsored Vanpool
o Vanpool programs are more appropriate for the building occupant or tenant to implement and monitor than the building owner or developer
GHG Calculations for T-6
Following the GHG formula and variables for T-6, the following calculations are provided below with representation of the corresponding variables:
𝐺𝐺𝐺𝐺𝐺𝐺 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝐹𝐹 𝐹𝐹𝐹𝐹 𝐹𝐹𝐹𝐹: 𝐴𝐴 = 𝐵𝐵 𝑥𝑥 𝐶𝐶 𝑥𝑥 𝐷𝐷 ID Variable Value Unit Source
A Percent reduction in GHG emissions from
project/site employee commute VMT
0 – 26.0 % calculated
B Percent of employees eligible for program 0 – 100 % User input C Percent reduction in vehicle mode share in
employee commute trips
-26 % Nelson\Nygaard Consulting
Associates 2015
D Adjustment from vehicle mode share to
commute VMT
1 unitless assumed
𝐴𝐴 = 100% 𝑥𝑥 (−26%) 𝑥𝑥 1 = −𝟐𝟐𝟐𝟐%
With the recommendation in CAPCOA for 100% for variable B, the resulting percentage for reduction is -26% for mitigating VMT.
With the -26% from T-6, the total GHG calculation would be -26%. As defined in CAPCOA’s handbook, the -26% is within the Trip Reduction Programs subsector maximum of -45%.
Conclusion
Based on the CAPCOA calculations for T-6 under the Trip Reduction Programs subsector, the project would be able to mitigate the 128% VMT impact to be less-than significant through the Trip Reduction Program with a -26% mitigation reduction. The project applicant shall be required to implement a Trip Reduction Program that includes commute trip reduction marketing, ridesharing, subsidized/discounted transit, end-of-trip bicycle facilities, and employee-sponsored vanpool to reduce the VMT impact to be less-than-significant. Please see attached Appendices for excerpts from the CAPCOA Handbook for additional guidance on the calculations presented in this memo. The full Transportation of CAPCOA can be found through the following link:
https://www.caleemod.com/handbook/chapter_3_1transportation.html.
Appendices
A. Excerpts from CAPCOA Handbook 2021
B. DKS VMT Analysis 3/10/23
Attachment A: CAPCOA Handbook 2021
TRANSPORTATION | 62
Transportation
Fossil-fuel powered vehicles are the primary
source of GHG emissions within the
transportation sector. On-road vehicles
traditionally use gasoline and diesel fuel and
release emissions based on the amount of fuel
combusted and the emission factor of the engine.
Cleaner-fueled and electric powered vehicles can
also generate GHG emissions, but often at far
lower intensities.
Transportation emissions can be reduced by
improving the emissions profile of the vehicle fleet
or by reducing VMT. Most of the measures quantified in this Handbook aim to reduce VMT and encourage mode shifts from single-occupancy vehicles to shared (e.g., transit) or active modes of transportation (e.g., bicycle). This can be accomplished by coordinating trip reduction or incentive programs; optimizing the land use of the project study area; enhancing road, bike and pedestrian networks; implementing parking policies; or improving transit systems.
Most of the emission reductions are determined by
evaluating the elasticity of a measure relative to the
amount of VMT that may be reduced by the measure.
A few transportation measures are aimed at
improving the emissions profile of the vehicle fleet.
These measures promote alternative fuels and vehicle
types. The emission reductions from these measures
are based on the improved emission factors and on
changes to the assumed vehicle fleet mix.
This section provides guidance for combining
emission reductions from transportation measures
and adjusting VMT reductions to expected GHG savings. The measure factsheets and quantification methods for individual measures follow. Use the graphic on the following page to click on an individual measure to navigate directly to the measure’s factsheet.
Selecting and Combining Transportation Measures
Depending on how VMT has been quantified for a project or program, users should exercise caution when selecting transportation measures to avoid double counting VMT benefits that may already be accounted for in the model used to produce the unmitigated or baseline VMT estimate.
For example, regional travel demand models are generally sensitive to built environment and transit service variables (e.g., density, proximity to transit). VMT estimates developed for a project or program that use such models may, therefore, already account for VMT reductions associated with certain measures in this Handbook (e.g., T-1, Increase Residential Density).
WHAT’S ELASTICITY?
Elasticity refers to how much one
variable changes, relative to a change
in another variable. For example, the
elasticity of a VMT reduction measure
would measure how much VMT is
reduced in proportion to the increase
in bicycle lanes.
TRANSPORTATION | 63
Interactions between transportation measures are complex and sometimes counterintuitive, whereby combining measures can have a substantive impact on reported emission reductions. To safeguard the accuracy and reliability of the methods, while maintaining their ease of use, the following rules should be followed when combining reductions achieved by transportation measures.
Combining Measures Across Scales
The first level of organization for the transportation measures is the scale of application. There are 16 quantified measures at the Project/Site scale that can be combined with each other and 17 quantified measures at the Plan/Community scale that can be combined with each other.4 The GHG reductions of transportation measures from different scales of application should never be combined. While it may be possible that a user’s project involves measures that affect vehicle trips or VMT at both scales, it is likely that combining the percent reduction from measures of different scales would not be valid. This rule does not apply to non-transportation measures that calculate the emissions reduction in terms of absolute emissions. 4 There is one additional quantified transportation measure: Measure T-30, Use Cleaner-Fuel Vehicles. All below discussion related to combining measures and determining maximums does not apply to this measure, which is part of the Clean Vehicles and Fuels subsector.
TRANSPORTATION | 64
Combining Measures within a Subsector
The second level of organization for the transportations measures is the subsector. Transportation measures are separated into six subsectors: Land Use, Neighborhood Design, Trip Reduction Programs, Parking Management, Transit, Parking or Road Pricing/Management, and Clean Vehicles and Fuels.
Effectiveness levels for multiple measures within a subsector may be multiplied to determine a combined effectiveness level. Because the combination of measures and independence of measures are complicated, this Handbook recommends that measure reductions within a subsector be multiplied unless the user can provide substantial evidence indicating that emission reductions are independent of one another and that they should therefore be added. This will take the following form:
Reductionsubsector = 1 − [(1 − A) × (1 − B) × (1 − C)]
Where A, B, and C are the individual measure reduction percentages for the measures to be combined in each subsector.
Each measure has a maximum allowable reduction, discussed in the quantification methods for each measure. The user should calculate the reduction from each measure, compare it to the individual measure maximum, and use the lower value of the two in the equation above.
In addition, each subsector has a maximum allowable reduction. These were derived by combining the maximum allowable reduction of each individual non–mutually-exclusive measure within the subsector using the above formula (see table below for more details). The subsector maximum is intended to ensure that emissions are not double counted when measures within the subsector are combined. The subsector maximums are provided in the below table by scale of application.
Scale Subsector Quantified Measures a Subsector Maximum b, c, d, e, f P/S Land Use 4 65%
Neighborhood Design — —
Trip Reduction Programs 9 45% commute VMT
Parking or Road Pricing/
Management
3 35%
Transit — —
P/C Land Use 1 30%
Neighborhood Design 9 10%
Trip Reduction Programs 1 2.3% commute VMT
Parking or Road Pricing/
Management
1 30%
Transit 5 15%
P/S = project/site; P/C = plan/community; VMT = vehicle miles traveled. a
Excludes Measure T-30, Use Cleaner-Fuel Vehicles, within the Clean Vehicles and Fuels subsector and all supporting or nonquantified measures from other subsectors. b — = no measure within the subsector at the specified scale. c
Where a subsector consists of only one measure, the subsector maximum listed is the individual measure maximum. d
Most maximums were conservatively rounded down to the nearest multiple of five or whole number.
TRANSPORTATION | 65
e
Measure T-1 and Measure T-2 were assumed to be mutually exclusive for the purpose of deriving a project’s single land use type maximum emissions reduction. More specifically, residential density (T-1) only applies to residential development, and job density only applies to commercial development (T-2). Similarly, Measure T-26 and Measure T-27 were assumed to be mutually exclusive with Measure T-28 for the purpose of deriving a plan/community’s total transit-related emissions reduction. Measure T-28 accounts for the VMT reduction associated with increased transit frequency (T-26) and decreased transit travel time from transit supportive roadway treatments (T-27). It was assumed that bus rapid transit (BRT) (T-28) would cover all of the community’s transit routes, and therefore no additional frequency or time improvements would be attainable (T-26 and T-27). f
Measures within the Trip Reduction Programs primarily reduce VMT from employee commute trips, whereas all other measures reduce VMT from all trips associated with the relevant land use type.
The user should calculate the reduction from each subsector, compare it to the corresponding sector maximum, and use the lower value of the two.
Combining Measures Across Subsectors
There is limited research directly analyzing the combined VMT impact on a project/site or plan/community from implementation of all, or a majority, of the non–mutually-exclusive transportation sector measures provided in this Handbook. However, a University of California, Davis study compared household VMT across different place types in California and found that the difference in average VMT in single-family suburban neighborhoods and central city neighborhoods was approximately 70 percent.5 Central city neighborhoods are more likely to have implemented transportation strategies like those measures included in the Handbook, when compared to suburban neighborhoods. The Handbook therefore adopts 70 percent as a maximum for the combined VMT impact from the following four subsectors: Land Use, Neighborhood Design, Parking or Road Pricing/Management, and Transit.
Reductionmulti-subsector = 1 − [(1 − Land) × (1 − Design) × (1 − Parking) × (1 − Transit)] ≤ 70% Note that this multi-subsector maximum purposefully excludes the Trip Reduction Program subsector. This is because measures in the Trip Reduction Program subsector are often implemented at the Project/Site scale based on the individual employer and are not as directly correlated with place type as the other subsectors. For example, all central city neighborhoods have a high residential and commercial density (i.e., Measure T-1 and Measure T-2 from the Land Use subsector), and most single-family suburban neighborhoods have low density. Conversely, not all employers in a central city neighborhood provide their employees with discounted transit passes (Measure T-9 from the Trip Reduction Program subsector), and the same is equally likely for the much smaller group of employers in a single-family suburban neighborhood.
Limitations of Maximums and Caps
The words maximum and cap are used interchangeably to describe either the highest percent reduction in GHG emissions or the highest expected value for a variable in the GHG reduction formula. Each subsector has a maximum allowable reduction and individual measures have a maximum allowable reduction, which is often based on one or more of the capped GHG reduction variables. In most instances, these values are a rule of thumb, or practical approximation, to limit the unrealistic influence of multiplicative measure variables. Where the 5 Salon, D. 2014. Quantifying the Effect of Local Government Actions on VMT. Institute of Transportation Studies, University of California, Davis. Prepared for the California Air Resources Board and the California Environmental Protection Agency. February.
Available: https://ww2.arb.ca.gov/sites/default/files/classic/research/apr/past/09-343.pdf. Accessed: October 2021.
TRANSPORTATION | 66
maximum is derived based on a more precise methodology (e.g., research results), the source is cited. Users should always confirm the appropriateness of these maximums for their project.
Adjusting VMT Reductions to Emission Reductions
Most of the transportation measures in this Handbook reduce GHG emissions and criteria pollutants (co-benefit) by reducing the source metric of VMT.6 The below equation highlights the main variables used to calculate VMT in a study area. Note that VMT decreases if any of the following occurs: (1) vehicle ownership declines, (2) vehicle trips are reduced, (3) vehicle trip lengths are reduced, or (4) any combination of these three variables.
VMT =
vehicles
study area ×
trips
vehicle∙day ×
distance (miles)
trip =
miles
study area∙day
Vehicles emit pollutants during all hours of the day. The magnitude of these emissions varies with the activity phase, such as running on the road, idling while stationary, sitting outside in the sun (evaporative), or starting up. The quantification methods presented in this Handbook account for emissions that occur during the three major emission processes of running, evaporation, and starting.7 Emissions generated by these processes are determined, in part,8 by the above VMT variables: (1) emissions from evaporation are a factor of vehicle ownership, (2) emissions from starting are a factor of vehicle ownership and number of vehicle starts (i.e., trips), and (3) emissions from running are a factor of vehicle ownership and number of vehicle trips and distance per trip (i.e., VMT).
Emissionstotal = Emissionsevap + Emissionsstart + Emissionsrun Emissionsevap =
vehicles
study area ×
pollutant mass (grams)
vehicle∙day =
grams
study area∙day
Emissionsstart =
vehicles
study area ×
trips
vehicle∙day ×
pollutant mass (grams)
trip∙day =
grams
study area∙day
Emissionsrun =
vehicles
study area ×
trips
vehicle∙day ×
miles
trip ×
pollutant mass (grams)
distance (miles)
=
grams
study area∙day
GHG and criteria pollutant reductions achieved by transportation measures are primarily presented in terms of a percent reduction, where the total emissions reduction was determined based on a ratio comparison to the VMT reduction. In other words, if a measure reduces VMT by some percent, the total emissions are reduced by the same percent (or a fraction of that percent, as described below). As discussed above, VMT can be reduced by decreasing any of the three variables of vehicle ownership, number of vehicle trips, and trip distance. The ratio comparison between reductions in VMT and emissions depends on the pollutant and which VMT variable(s) decrease with implementation of a transportation measure. 6 Exceptions include Measures T-14, Provide Electric Charging Infrastructure, and T-30, Use Cleaner-Fuel Vehicles. 7 A fourth emission process is idling. EMFAC estimates idle exhaust emissions only for heavy-duty vehicles that idle for extended periods of time while loading or unloading goods. This document analyzes emissions primarily from passenger vehicles and thus focuses on the three relevant emission processes of evaporation, starting, and running. 8 Vehicle emissions are also a function of the chosen analysis year, project location, and fleet mix. When using EMFAC, future year emissions decline over time, reflecting assumed changes in fleet mix for the location and cleaner engine and fuel technologies.
TRANSPORTATION | 67
1. Less vehicle ownership. If a transportation measure reduces VMT by decreasing vehicle ownership, the measure would decrease running, starting, and evaporative emissions by the same rate.9 The measures where this applies are Measures T-15, Limit Residential Parking Supply, and T-16, Unbundle Residential Parking Costs from Property Cost, where the VMT reduction is a function of avoided vehicle ownership in residents disincentivized to park offsite or pay the separate cost of parking for a vehicle. For these measures, there is a 1:1 relationship between reductions in VMT and emissions because these measures reduce all emission processes at the same rate, not just running emissions.
2. Fewer vehicle trips. If a transportation measure reduces VMT by decreasing the number of vehicle trips, the measure would decrease running emissions and starting emissions by approximately the same rate. This applies to all transportation measures except Measures T-14, Provide Electric Vehicle Charging Infrastructure; T-15, Limit Residential Parking Supply; T-16, Unbundle Residential Parking Costs from Property Cost; and T-30, Use Cleaner-Fuel Vehicles.
This is because each measure would result in, at minimum,10 fewer vehicle trips by promoting alternative modes of transportation in place of single-occupancy vehicles.
These measures would not decrease evaporative emissions, which are a function of vehicle ownership. However, this does not affect the ratio comparison between reductions in VMT and GHG emissions because there are no evaporation GHG emissions (i.e., 100 percent of CO2, CH4, and nitrous oxide (N2O) from vehicles are from running and starting). This is also true for nitrogen oxides (NOx) particulate matter (PM2.5 and PM10), carbon monoxide (CO), and sulfur dioxide (SOx). Therefore, for these measures and pollutants, there is a 1:1 relationship between reductions in VMT and emissions.
Reactive organic gases (ROG) from vehicles include not only running and starting emissions, but also evaporative emissions.11 Running and starting ROG emissions represent approximately 87 percent of total ROG emissions in passenger vehicles.12 This adjustment factor should be applied when converting the percent GHG reduction to the percent reduction in total ROG emission.
% reduction in ROG emissions = % reduction in GHG × 87% This is noted in the co-benefits section of Improved Air Quality for each applicable transportation measure.
3. Shorter vehicle trips. If a transportation measure reduces VMT by only decreasing the distance of vehicle trips, the measure would not reduce starting or evaporative emissions. There are no transportation measures in this Handbook where this scenario occurs and, therefore, an adjustment factor is not developed.
9 Assuming emission factor variables are held constant. 10 Many of these measures also result in shorter vehicle trips. In these instances, the VMT reduction is either largely a function of the reduction in vehicle trips or is an equal function of the reduction in vehicle trips and the reduction in trip distances. There are no measures where the VMT reduction is largely a function of the reduction in trip distances with a lesser contribution from the reduction in vehicle trips.
11 See EMFAC2017 User’s Guide for more detail on these emission processes. Available:
https://ww3.arb.ca.gov/msei/downloads/emfac2017-volume-i-users-guide.pdf. 12 Combined emissions from the EMFAC vehicle types of LDA, LDT1, and LDT2.
TRANSPORTATION | 68
The criteria pollutants CO, NO2, SO2, and PM are local pollutants that can potentially affect populations near the emissions source. Accordingly, measures that reduce localized criteria pollutant emissions can improve ambient air quality. Measures that reduce emissions of ozone precursors (NOx and ROG), which are regional pollutants, can improve regional air quality.
Note that the Handbook’s use of a ratio comparison of VMT reduction to GHG and criteria pollutant reductions makes two key assumptions that may not be valid for every user’s project. It is important users consider the validity of these assumptions on a project-by-project basis and either (1) perform any post-processing to the emissions reductions achieved by the transportation measures to better reflect their project conditions, or (2) provide a qualitative disclaimer about the accuracy of the estimated reductions considering the below assumptions.
1. Vehicle class is assumed to remain unchanged with implementation of a measure. Say a user is interested in calculating the plan/community-level GHG reduction from Measure T-22-B, Implement Electric Bikeshare Program. The user has community-level VMT without the measure and elects to calculate community-wide mobile emissions using EMFAC. The user calculates in EMFAC that the existing percent of the community VMT by vehicle class is 75 percent light-duty vehicles and 25 percent non-light-duty vehicles. In this example, the average emission factor for light-duty vehicles is 250 grams CO2 per mile and for non–light-duty vehicles is 400 grams CO2 per mile. The average community emission factor, as weighted by VMT, would be 288 grams per mile [(75% X 250 grams CO2 per mile) + (25% X 400 grams CO2 per mile)]. Users then estimate vehicle emissions prior to implementation of Measure T-22-B by applying this average vehicle emission factor to their community-level VMT.
The user then implements Measure T-22-A, Implement Pedal (Non-Electric) Bikeshare Program, and reduces GHG emissions from vehicle travel by 4 percent by replacing vehicle trips with bikeshare trips. The majority of those replaced vehicle trips are private trips as lightduty vehicles. As a result, the percent of the community VMT by vehicle class is now 70 percent light-duty vehicles and 30 percent non–light-duty vehicles, effectively increasing the community average vehicle emission factor, as weighted by VMT, from 288 grams per mile to 295 grams per mile [70% X 250 grams CO2 per mile) + (30% X 400 grams CO2 per mile)].
This increase in the community average vehicle emission factor lessens the GHG reduction that would be achieved from reduced vehicle trips.
Conversely, the circumstances could be such that a measure increases the GHG reduction that would be achieved from reduced vehicle trips. For example, Measure T-22-A may replace existing vehicle trips that are primarily from more emissions-intensive non–light-duty vehicles (e.g., transit buses). In this case, the percent of the community VMT by the less– emissions-intensive light-duty vehicle would be higher, reducing the community average vehicle emission factor. This decrease in the community average vehicle emission factor would increase the GHG reduction that would be achieved from reduced vehicle trips.
The Handbook method cannot predict or know how each measure could affect the user’s specific fleet mix. Therefore, the fleet mix is assumed to remain constant before and after implementation of all transportation measures.
TRANSPORTATION | 69
2. Vehicle speeds are assumed to remain unchanged with implementation of a measure. The logic of this assumption is similar to the first assumption. Say a user is interested in calculating the plan/community-level GHG reduction from Measure T-20, Expand Bikeway Network. The user elects to calculate community-wide mobile emissions prior to implementation of the measures using EMFAC and aggregated vehicle speeds. In this example, EMFAC aggregates the vehicle speeds in the user’s community at approximately 30 miles per hour (mph).13 The user implements Measure T-20 and expansion of the bikeway network reduces the average vehicle speed to approximately 25 mph. Because vehicles are slightly more GHG emissions-intensive at 25 mph compared to 30 mph, the GHG reduction achieved by the measure would be less if the impact of vehicle speeds were included in the quantification method.
Conversely, the circumstances could be such that a measure increases the GHG reduction that would be achieved from reduced vehicle trips. For example, Measure T-11, Provide Employer-Sponsored Vanpool, replaces private vehicle trips with shared vanpool trips, reducing the number of cars on the road. If roadways are currently congested and causing vehicles to move at low speeds, implementation of this measure could alleviate roadway congestion and increase vehicle speeds to a speed in which they are less GHG emissions intensive. The decrease in the community average vehicle emission factor would increase the GHG reduction that would be achieved from reduced vehicle trips.
The Handbook method cannot predict or know how each measure could affect vehicle speeds under the various use cases. Therefore, the vehicle speeds are assumed to remain constant before and after implementation of all transportation measures.
Use of Transportation Quantification Methodologies for Senate Bill 375 Compliance
As described in Appendix B, Federal and State Planning Framework, Senate Bill (SB) 375 requires metropolitan planning organizations (MPOs) to incorporate a SCS in their regional transportation plans (RTPs) and submit it to the California Air Resources Board (CARB) for review. The goal of the SCS is to reduce regional passenger vehicle VMT and associated GHG emissions through land use and transportation planning. CARB requires MPOs quantify the passenger vehicle VMT reductions achieved by their SCSs using a specific method. It is therefore not recommended that MPOs use the transportation measure quantification methodologies found in this Handbook when preparing their SCSs.
13 Vehicle running emission factors are, in part, dependent on vehicle speed. Vehicles are generally more emissions-intensive at speeds that are very low (e.g., 5 mph) and very high (e.g., greater than 70 mph), though this varies by pollutant and vehicle class.
TRANSPORTATION | 86
T-6. Implement Commute Trip Reduction Program
(Mandatory Implementation and Monitoring)
GHG Mitigation Potential
Up to 26.0% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
Commute trip reduction programs could
result in less traffic, potentially reducing
congestion or delays on major roads during
peak AM and PM traffic periods. When this
reduction occurs during extreme weather
events, it better allows emergency
responders to access a hazard site. Lower
transportation costs would also increase
community resilience by freeing up resources
for other purposes.
Health and Equity Considerations
Design of CTR programs needs to consider
existing mobility options in diverse
communities and ensure equitable access
and benefit to all employees.
Measure Description
This measure will implement a mandatory CTR program with employers. CTR programs discourage single-occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
The mandatory CTR program must include all other elements (i.e., Measures T-7 through T-11) described for the voluntary program (Measure T-5) plus include mandatory trip reduction requirements (including penalties for non-compliance) and regular monitoring and reporting to ensure the calculated VMT reduction matches the observed VMT reduction.
Cost Considerations
Employer costs may include recurring, direct costs for transit subsidies, capital and maintenance costs for alternative transportation infrastructure, and labor costs for staff to manage the program. If the local municipality has a mandatory VMT reduction ordinance, additional employer costs could include noncompliance penalties if the municipality fines CTR programs that do not meet a VMT goal. Municipal costs may include the labor costs for government staff to track the efficacy of the program, which may be outweighed by revenue generated from fines collected from non-compliant businesses.
Expanded Mitigation Options
This program typically serves as a complement to the more effective workplace CTR measures, such as pricing workplace parking (Measure T-12) or implementing employee parking “cashout” (Measure T-13). 26%
Photo Credit: University of Manitoba, 2018
TRANSPORTATION | 87
T-6. Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring)
GHG Reduction Formula
A = B × C × D
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
project/site employee commute VMT
0–26.0 % calculated
User Inputs
B Percent of employees eligible for program 0–100 % user input Constants, Assumptions, and Available Defaults
C Percent reduction in vehicle mode share of
employee commute trips
-26 % Nelson\Nygaard
Consulting
Associates 2015
D Adjustment from vehicle mode share to
commute VMT
1 unitless assumed
Further explanation of key variables:
▪ (B) – This refers to the percent of employees that would be able to participate in the program. This will usually be 100 percent. Employees who might not be able to participate could include those who work nighttime hours when transit and rideshare services are not available or employees who are required to drive to work as part of their job duties. This input does not refer to the percent of employees who participate in the program. ▪ (C) – A multiyear study of mode share on Genentech’s South San Francisco campuses tracked the long-run change in employee commute mode share with implementation of mandatory CTR. Between 2006 and 2014, employee vehicle mode share (includes single-occupied vehicles and carpools) decreased from approximately 90 percent to 64 percent, which is a 26 percent reduction (Nelson\Nygaard Consulting Associates 2015). ▪ (D) – The adjustment factor from vehicle mode share to commute VMT is 1. This assumes that all vehicle trips will average out to typical trip length. Thus, it can be assumed that a percentage reduction in vehicle trips will equal the same percentage reduction in VMT.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The maximum GHG reduction from this measure is 26 percent. This maximum scenario is presented in the below example quantification.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
TRANSPORTATION | 88
T-6. Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring)
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for Measure T-5, which represents the same implementation activities as Measure T-5, except that the CTR program would be mandatory. Users should select either Measure T-5 or T-6.
If this measure is selected, the user may not also take credit for Measures T-7 through T-11.
Measure T-6 accounts for the combined GHG reductions achieved by each of these individual measures. To combine the GHG reductions from T-6 with any of these measures would be considered double counting. However, the user may take credit for Measure T-12 and T-13 within the larger CTR subcategory, so long as the combined VMT reduction does not exceed 45 percent, as noted above.
Example GHG Reduction Quantification
The user reduces employee commute VMT by requiring that the employer of the proposed project offer a mandatory CTR program to their employees. In this example, the percent of employees eligible (B) is 100 percent, which would reduce GHG emissions from employee commute VMT by 26 percent.
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
Sources
▪ Nelson/Nygaard Consulting Associates. 2015. Genentech–South San Francisco Campus TDM and Parking Report. June. Available: http://ci-ssfca.granicus.com/MetaViewer.php?view_id=2&clip_id=859&meta_id=62028. Accessed: January 2021.
A = 100% × -26% × 1= -26%
TRANSPORTATION | 89
T-7. Implement Commute Trip Reduction Marketing
GHG Mitigation Potential
Up to 4.0% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
Commute trip reduction programs could
result in less traffic, potentially reducing
congestion or delays on major roads during
peak AM and PM traffic periods. When this
reduction occurs during extreme weather
events, it better allows emergency
responders to access a hazard site. Lower
transportation costs would also increase
community resilience by freeing up
resources for other purposes.
Health and Equity Considerations
Design of CTR programs needs to consider
existing mobility options in diverse
communities and ensure equitable access and
benefit to all employees. CTR programs may
need to include multi-language materials.
Measure Description
This measure will implement a marketing strategy to promote the project site employer’s CTR program. Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
The following features (or similar alternatives) of the marketing strategy are essential for effectiveness.
▪ Onsite or online commuter information services.
▪ Employee transportation coordinators.
▪ Onsite or online transit pass sales.
▪ Guaranteed ride home service.
Cost Considerations
Employer costs include labor and materials for development and distribution of survey and marketing materials to promote the program and educate potential participants.
Expanded Mitigation Options
This measure could be packaged with other commute trip
reduction measures (Measures T-8 through T-13) as a
comprehensive CTR program (Measure T-5 or T-6).
4%
Photo Credit: Sacramento Area Council of
Governments, 2012
T-7. Implement Commute Trip Reduction Marketing TRANSPORTATION | 90 GHG Reduction Formula
A = B × C × D
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
project/site employee commute VMT
0–4.0 % calculated
User Inputs
B Percent of employees eligible for program 0–100 % user input Constants, Assumptions, and Available Defaults
C Percent reduction in employee commute
vehicle trips
-4 % TRB 2010
D Adjustment from vehicle trips to VMT 1 unitless assumed Further explanation of key variables:
▪ (B) – This refers to the percent of employees that would be able to participate in the program. This will usually be 100 percent. Employees who might not be able to participate could include those who work nighttime hours when transit and rideshare services are not available or employees who are required to drive to work as part of their job duties. This input does not refer to the percent of employees who actually participate in the program.
▪ (C) – A review of studies measuring the effect of transportation demand management measures on traveler behavior notes that the average empirically-based estimate of reductions in vehicle trips for full-scale, site-specific employer support programs is 4 to 5 percent. To be conservative, the low end of the range is cited (TRB 2010). ▪ (D) – The adjustment factor from vehicle trips to VMT is 1. This assumes that all vehicle trips will average out to typical trip length (“assumes all trip lengths are equal”). Thus, it can be assumed that a percentage reduction in vehicle trips will equal the same percentage reduction in VMT.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The maximum GHG reduction from this measure is 4 percent. This maximum scenario is presented in the below example quantification.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
T-7. Implement Commute Trip Reduction Marketing TRANSPORTATION | 91 Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for either Measure T-5 or T-6.
However, this measure may be implemented alongside other individual CTR measures (Measures T-8 through T-13). The efficacy of individual programs may vary highly based on individual employers and local contexts.
Example GHG Reduction Quantification
The user reduces employee commute VMT by requiring that employers of a project market to employees travel options for modes alternative to single-occupied vehicles. In this example, the percent of employees eligible (B) is 100 percent, which would reduce GHG emissions from employee commute VMT by 4 percent.
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
Sources
▪ Transportation Research Board (TRB). 2010. Traveler Response to Transportation System Changes Handbook, Third Edition: Chapter 19, Employer and Institutional TDM Strategies. June. Available:
http://www.trb.org/Publications/Blurbs/163781.aspx. Accessed: January 2021.
A = 100% × -4% × 1 = -4%
TRANSPORTATION | 92
T-8. Provide Ridesharing Program
GHG Mitigation Potential
Up to 8.0% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
Ridesharing programs could result in less
traffic, potentially reducing congestion or
delays on major roads during peak AM and
PM traffic periods. When this reduction
occurs during extreme weather events, it
better allows emergency responders to
access a hazard site. Lower transportation
costs would also increase community
resilience by freeing up resources for
other purposes.
Health and Equity Considerations
Program should include all onsite workers,
such as contractors, interns, and service
workers. Because ridesharing is vehiclebased, and some employees may not be in areas with feasible rideshare networks,
design of programs need to ensure
equitable benefits to those with and without
access to rideshare opportunities.
Measure Description
This measure will implement a ridesharing program and establish a permanent transportation management association with funding requirements for employers. Ridesharing encourages carpooled vehicle trips in place of single-occupied vehicle trips, thereby reducing the number of trips, VMT, and GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
Ridesharing must be promoted through a multifaceted approach.
Examples include the following.
▪ Designating a certain percentage of desirable parking spaces for ridesharing vehicles.
▪ Designating adequate passenger loading and unloading and waiting areas for ridesharing vehicles.
▪ Providing an app or website for coordinating rides.
Cost Considerations
Costs of developing, implementing, and maintaining a rideshare program in a way that encourages participation are generally borne by municipalities or employers. The beneficiaries include the program participants saving on commuting costs, the employer reducing onsite parking expenses, and the municipality reducing cars on the road, which leads to lower infrastructure and roadway maintenance costs.
Expanded Mitigation Options
When providing a ridesharing program, a best practice is to establish funding by a non-revocable funding mechanism for employer-provided subsidies. In addition, encourage use of lowemission ridesharing vehicles (e.g., shared Uber Green).
This measure could be paired with any combination of the other commute trip reduction strategies (Measures T-7 through T-13) for increased reductions.
8%
T-8. Provide Ridesharing Program TRANSPORTATION | 93
GHG Reduction Formula
A = B × C
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
project/site employee commute VMT
0–8.0 % calculated
User Inputs
B Percent of employees eligible for program 0–100 % user input Constants, Assumptions, and Available Defaults
C Percent reduction in employee commute VMT Table T-8.1 % SANDAG 2019 Further explanation of key variables:
▪ (B) – This refers to the percent of employees that would be able to participate in the program. This will usually be 100 percent. Employees who might not be able to participate could include those who work nighttime hours when transit and rideshare services are not available or employees who are required to drive to work as part of their job duties. This input does not refer to the percent of employees who actually participate in the program.
▪ (C) – The percent reduction in employee commute VMT by place type is provided in Table T-8.1 in Appendix C. The reduction differs by place type because the willingness and ability to participate in carpooling is higher in urban areas than in suburban areas. Note that this measure is not applicable for implementation in rural areas (SANDAG 2019).
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The maximum GHG reduction from this measure is 8 percent.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for either Measure T-5 or T-6.
However, this measure may be implemented alongside other individual CTR measures (Measures T-7 and T-9 through T-13). The efficacy of individual programs may vary highly based on individual employers and local contexts.
T-8. Provide Ridesharing Program TRANSPORTATION | 94
Example GHG Reduction Quantification
The user reduces employee commute VMT by requiring that employers of a project provide a ridesharing program to their employees. In this example, the percent of employees eligible (B) at a packaging and distribution center is 50 percent and the place type of the project is urban (C). GHG emissions from employee commute VMT would be reduced by 4 percent.
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
Sources
▪ San Diego Association of Governments (SANDAG). 2019. Mobility Management VMT Reduction Calculator Tool–Design Document. June. Available: https://www.icommutesd.com/docs/defaultsource/planning/tool-design-document_final_7-17-19.pdf?sfvrsn=ec39eb3b_2. Accessed: January 2021.
A = 50% × -8% = -4%
TRANSPORTATION | 95
T-9. Implement Subsidized or Discounted Transit
Program
GHG Mitigation Potential
Up to 5.5% of emissions from
employee/resident vehicles
accessing the site
Co-Benefits (icon key on pg. 34)
Climate Resilience
Subsidized and discounted transit programs
increase the capacity of low-income
populations to use transit to evacuate or
access resources during an extreme weather
event. They could also incentivize more people
to use transit, resulting in less traffic and better
allowing emergency responders to access a
hazard site during an extreme weather event.
Lower overall out-of-pocket costs would also
help increase community resilience by freeing
up resources for other purposes.
Health and Equity Considerations
Program should include all onsite workers,
such as contractors, interns, and service
workers.
Measure Description
This measure will provide subsidized or discounted, or free transit passes for employees and/or residents. Reducing the out-of-pocket cost for choosing transit improves the competitiveness of transit against driving, increasing the total number of transit trips and decreasing vehicle trips. This decrease in vehicle trips results in reduced VMT and thus a reduction in GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
The project should be accessible either within 1 mile of highquality transit service (rail or bus with headways of less than 15 minutes), 0.5 mile of local or less frequent transit service, or along a designated shuttle route providing last-mile connections to rail service. If a well-established bikeshare service (Measure T-22-A) is available, the site may be located up to 2 miles from a highquality transit service.
If more than one transit agency serves the site, subsidies should be provided that can be applied to each of the services available. If subsidies are applied for only one service, all variable inputs below should also pertain only to the service that is subsidized.
Cost Considerations
The employer cost is the recurring, direct cost for transit subsidies.
The subsidies will lower the per capita income of the transit service, decreasing the revenue of the local transit agency. This cost may be offset by increased revenue from increased ridership.
The beneficiaries include the program participants saving on commuting cost, the employer reducing onsite parking expenses, and the municipality reducing cars on the road, which leads to lower infrastructure and roadway maintenance costs.
Expanded Mitigation Options
This measure could be paired with any combination of the other commute trip reduction strategies (Measures T-7 through T-13) for increased reductions.
5.5 %
T-9. Implement Subsidized or Discounted Transit Program TRANSPORTATION | 96 GHG Reduction Formula
A =
C
B
× G × D × E × F × H × I
GHG Calculation Variables
If subsidies or discounts target employees, the GHG reduction from this measure may be limited to work-related employee trips only (i.e., home-to- work) and work-to-other, where at least one trip end is work). If residents are targeted, the GHG reductions extend to all trips.
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
employee/resident vehicles accessing the site
0–5.5 % calculated
User Inputs
B Average transit fare without subsidy [ ] $ user input C Subsidy amount [ ] $ user input
D Percent of employees/residents eligible for
subsidy
0–100 % user input
E Percent of project-generated VMT from
employees/residents
0–100 % user input
Constants, Assumptions, and Available Defaults
F Transit mode share of all trips or work trips Table T-3.1 or Table T-9.1
% FHWA 2017
G Elasticity of transit boardings with respect to
transit fare price
-0.43 unitless Taylor et al.
2008
H Percent of transit trips that would otherwise
be made in a vehicle
50 % Handy &
Boarnet 2013
I Conversion factor of vehicle trips to VMT 1.0 unitless assumption Further explanation of key variables:
▪ (B and C) – The average transit fare and subsidy amount can be presented as either a fare per ride, or the cost of a monthly pass for typical transit service near the site. Pricing should be based on the expected means of subsidy implementation; for instance, if a monthly pass is provided to all residents, prices should be input on a monthly basis. ▪ (D) – The percentage of employees/residents associated with the site who have access to the subsidy. If subsidy is provided as an employee benefit, care should be taken to account for any contract or temporary workers who do not receive such benefits. ▪ (E) – The percentage of project-generated VMT from employees/residents is used to adjust the percent reduction in GHG emissions from the scale of employee and/or resident-generated VMT to project-generated VMT. If subsidies or discounts target employees at an office development, this value would simply be 100 percent. If the project site is a multifamily development with no onsite workers, this value would also be T-9. Implement Subsidized or Discounted Transit Program TRANSPORTATION | 97 100 percent. If the project site is a retail development, this value would be less than 100 percent, as it does not account for retail shopper trips to the site. The share of total VMT generated by employees for visitor-intensive uses, such as retail or medical offices, can be roughly estimated by multiplying the total number of employees by two (to account for both arrival and departure), divided by the total number of daily trips. ▪ (F) – Ideally, the user will calculate transit mode share for work trips or all trips of a Project/Site at a scale no larger than a census tract. Potential data sources include the U.S. Census, California Household Travel Survey (preferred), or local survey efforts.
Care should be taken not to present the reported commute mode share as retrieved from the American Community Survey (ACS), unless the land use is office or employment based and the tables are based on work location (rather than home location). If the subsidies or discounts target employees and their commute trips, then the mode share should use the home-to-work trip purpose. If the user is not able to provide a project-specific value using one of the data sources described above, they have the option to input the transit mode share for one of the six most populated CBSAs in California. The transit mode share for work trips by CBSA is presented in Table T-9.1 in Appendix C (FHWA 2017). The transit mode share for all trips is provided in Table T3.1 in Appendix C. ▪ (G) – A cross-sectional analysis of transit use in 265 urbanized areas in the U.S. found that a 0.43 percent decrease in transit boardings occurs for every 1 percent increase in transit fare price (Taylor et al. 2008). A policy brief summarizing the results of transit service strategies found this analysis to fall in the mid-point of observed, short-term values (Handy & Boarnet 2013). Price elasticities of transit demand vary based on both long-term and short-term demand, service type, and service location (Litman 2020 and Handy & Boarnet 2013).
▪ (H) – Not all new transit trips replace a vehicle trip. The share of transit trips that would otherwise be made by private vehicle ranges from less than 5 percent to 50 percent across studies. This assumption is based on observed values for high quality BRT service under the assumption that this measure is implemented alongside marketing measures and is targeted primarily at reducing vehicle commute trips. (Handy & Boarnet 2013).
Note that this study looked at service improvements rather than fare changes and is used as a proxy variable. If project-specific or location-specific information is available, it should be substituted for this assumptive variable.
▪ (I) – The adjustment factor from vehicle trips to VMT is 1. This assumes that all vehicle trips will average out to typical trip length (“assumes all trip lengths are equal”). Thus, it can be assumed that a percentage reduction in vehicle trips will equal the same percentage reduction in VMT. Subsidies or discounts targeting commute trips may have a higher factor as they are generally longer than the trip lengths for other purposes.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The GHG reduction is capped at 5.5 percent, which is based on the following assumptions:
▪ (C=B) – The subsidy coverage is capped at 100 percent of the typical transit fare. ▪ (D) – All employees are eligible for the subsidy.
T-9. Implement Subsidized or Discounted Transit Program TRANSPORTATION | 98 ▪ (E) – All project-generated VMT is from employee-generated VMT. ▪ (F) – Employees at an office development in the San Francisco-Oakland-Hayward CBSA have a default transit mode share for work trips of 25.60 percent.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for either Measure T-5 or T-6.
However, this measure may be implemented alongside other individual CTR measures (Measures T-7, T-8, T-10 through T-13). The efficacy of individual programs may vary highly based on individual employers and local contexts.
Example GHG Reduction Quantification
In this example, the user reduces VMT by providing all employees (D) of a proposed office development in the San Francisco-Oakland-Hayward CBSA a 100 percent transit subsidy in the form of a $100 monthly transit pass (C=B). The user would reduce GHG emissions from VMT by 5.5 percent.
A = (
$100
$100 × -0.43) × 100% × 100% × 25.60% × 50% × 1 = -5.5%
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
T-9. Implement Subsidized or Discounted Transit Program TRANSPORTATION | 99 Sources
▪ Federal Highway Administration (FHWA). 2017. National Household Travel Survey–2017 Table Designer. Travel Day PMT by TRPTRANS by HH_CBSA, Workers by WRKTRANS by HH_CBSA.
Available: https://nhts.ornl.gov/. Accessed: January 2021. ▪ Handy, L. and S. Boarnet. 2013. Impacts of Transit Service Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions. Available:
http://www.arb.ca.gov/cc/sb375/policies/transitservice/transit_brief.pdf. Accessed: January 2021. ▪ Litman, T. 2020. Transit Price Elasticities and Cross-elasticities. Victoria Transport Policy Institute. April.
Available: https://www.vtpi.org/tranelas.pdf. Accessed: January 2021. ▪ Taylor, B., D. Miller, H. Iseki, and C. Fink. 2008. Nature and/or Nurture? Analyzing the Determinants of Transit Ridership Across US Urbanized Areas. Transportation Research Part A: Policy and Practice, 43(1), 60-77. Available:
https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.367.5311&rep=rep1&type=pdf.
Accessed: January 2021.
TRANSPORTATION | 100
T-10. Provide End-of-Trip Bicycle Facilities
GHG Mitigation Potential
Up to 4.4% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
End-of-trip bicycle facilities could take more
cars off the road, resulting in less traffic and
better allowing emergency responders to
access a hazard site during an extreme
weather event. They could also make it
easier for bicycle users to access resources in
an extreme weather event.
Health and Equity Considerations
Facilities should be inclusive of all gender
identities and expressions. Consider
including gender-neutral, single-occupancy
options to allow for additional privacy for
those who want it.
Measure Description
This measure will install and maintain end-of-trip facilities for employee use. End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
End-of-trip facilities should be installed at a size proportional to the number of commuting bicyclists and regularly maintained.
Cost Considerations
Employer costs include capital and maintenance costs for construction and maintenance of facilities and potentially labor and materials costs for staff to monitor facilities and provide marketing to encourage use of new facilities. The beneficiaries include the program participants saving on commuting cost, the employer reducing onsite parking expenses, and the municipality reducing cars on the road, which leads to lower infrastructure and roadway maintenance costs.
Expanded Mitigation Options
Best practice is to include an onsite bicycle repair station and post signage on or near secure parking and personal lockers with information about how to reserve or obtain access to these amenities.
This measure could be paired with any combination of the other commute trip reduction strategies (Measures T-7 through T-13) for increased reductions.
4.4%
T-10. Provide End-of-Trip Bicycle Facilities TRANSPORTATION | 101 GHG Reduction Formula
A =
C × (E − (B × E))
D × F
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
employee project/site commute VMT
0.1–4.4 % calculated
User Inputs
None
Constants, Assumptions, and Available Defaults
B Bike mode adjustment factor 1.78 or
4.86 unitless Buehler 2012
C Existing bicycle trip length for all trips in
region
Table
T-10.1
miles FHWA 2017a
D Existing vehicle trip length for all trips in
region
Table
T-10.1
miles FHWA 2017a
E Existing bicycle mode share for work trips
in region
Table
T-10.2
% FHWA 2017b
F Existing vehicle mode share for work trips
in region
Table
T-10.2
% FHWA 2017b
Further explanation of key variables:
▪ (B) – The bike mode adjustment factor should be provided by the user based on type of bike facility. A study found that commuters with showers, lockers, and bike parking at work are associated with 4.86 times greater likelihood to commute by bicycle when compared to individuals without any bicycle facilities at work. Individuals with bike parking, but no showers and lockers at the workplace, are associated with 1.78 times greater likelihood to cycle to work than those without trip-end facilities (Buehler 2012). ▪ (C and D) – Ideally, the user will calculate bicycle and auto trip length for a Project/Site at a scale no larger than a census tract. Potential data sources include the U.S. Census, California Household Travel Survey (preferred), or local survey efforts. If the user is not able to provide a project-specific value using one of these data sources, they have the option to input the trip lengths for bicycles and vehicles for one of the six most populated CBSAs in California, as presented in Table T-10.1 in Appendix C (FHWA 2017a). Trip lengths are likely to be longer for areas not covered by the listed CBSAs, which represent the denser areas of the state.
▪ (E and F) – Ideally, the user will calculate bicycle and auto mode share for work trips for a Project/Site at a scale no larger than a census tract. Potential data sources include the U.S. Census, California Household Travel Survey (preferred), or local survey efforts. If the user is not able to provide a project-specific value using one of these data sources, they have the option to input the regional average mode shares for bicycle and vehicle T-10. Provide End-of-Trip Bicycle Facilities TRANSPORTATION | 102 work trips for one of the six most populated CBSAs in California, as presented in Table T-10.2 in Appendix C (FHWA 2017b). If the project study area is not within the listed CBSAs or the user is able to provide a project-specific value, the user should replace these regional defaults in the GHG reduction formula. For areas not covered by the listed CBSAs, which represent the denser areas of the state, bicycle mode share is likely to be lower and vehicle share higher than presented in Table T-10.2.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The maximum GHG reduction from this measure is 4.4 percent. This maximum scenario is presented in the below example quantification.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for either Measure T-5 or T-6.
However, this measure may be implemented alongside other individual CTR measures (Measures T-7, T-8, T-9, and T-11 through T-13). The efficacy of individual programs may vary highly based on individual employers and local contexts.
Example GHG Reduction Quantification
The user reduces VMT by providing end-of-trip facilities for the project’s employees, which encourages bicycle trips in place of vehicle trips. In this example, the type of bike facility provided by the project is parking with showers, bike lockers, and personal lockers (B). The project is within San Jose-Sunnyvale-Santa Clara CBSA, and the user does not have project-specific values for trip lengths and mode shares and for bicycles and vehicles. Per Tables T-10.1 and T-10.2 in Appendix C, inputs for these variables are 2.8 miles, 11.5 miles, 4.1 percent, and 86.6 percent, respectively (C, D, E, and F). GHG emissions from employee commute VMT would be reduced by 4.4 percent.
A =
2.8 miles × (4.1% − (4.86 × 4.1%))
11.5 miles × 86.6% = -4.4%
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be T-10. Provide End-of-Trip Bicycle Facilities TRANSPORTATION | 103 calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
Sources
▪ Buehler, R. 2012. Determinants of bicycle commuting in the Washington, DC region: The role bicycle parking, cyclist showers, and free car parking at work. Transportation Research Part D, 17, 525–531.
Available: http://www.pedbikeinfo.org/cms/downloads/DeterminantsofBicycleCommuting.pdf.
Accessed: January 2021.
▪ Federal Highway Administration (FHWA). 2017a. National Household Travel Survey–2017 Table Designer. Travel Day PT by TRPTRANS by HH_CBSA. Available: https://nhts.ornl.gov/. Accessed:
January 2021.
▪ Federal Highway Administration (FHWA). 2017b. National Household Travel Survey–2017 Table Designer.
Workers by WRKTRANS by HH_CBSA. Available: https://nhts.ornl.gov/. Accessed: January 2021.
TRANSPORTATION | 104
T-11. Provide Employer-Sponsored Vanpool
GHG Mitigation Potential
Up to 20.4% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
Employer-sponsored vanpools could result in
less traffic, potentially reducing congestion
or delays on major roads during peak AM
and PM traffic periods. When this reduction
occurs during extreme weather events, it
better allows emergency responders to
access a hazard site.
Health and Equity Considerations
Consider using zero-emission or plug-in
electric vehicles (PHEVs) for additional
emission reduction benefits.
Measure Description
This measure will implement an employer-sponsored vanpool service. Vanpooling is a flexible form of public transportation that provides groups of 5 to 15 people with a cost-effective and convenient rideshare option for commuting. The mode shift from long-distance, single-occupied vehicles to shared vehicles reduces overall commute VMT, thereby reducing GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban, rural
Scale of Application
Project/Site
Implementation Requirements
Vanpool programs are more appropriate for the building
occupant or tenant (i.e., employer) to implement and monitor than the building owner or developer.
Cost Considerations
Employer costs primarily include the capital costs of vehicle acquisition and the labor costs of drivers, either through incentives to current employees or the hiring of dedicated drivers. The beneficiaries include the program participants saving on commuting cost, the employer reducing onsite parking expenses, and the municipality reducing cars on the road, which leads to lower infrastructure and roadway maintenance costs.
Expanded Mitigation Options
When implementing a vanpool service, best practice is to subsidize the cost for employees that have a similar origin and destination and provide priority parking for employees that vanpool.
This measure could be paired with any combination of the other commute trip reduction strategies (Measures T-7 through T-13) for increased reductions.
20.4%
Photo Credit: UCLA Transportation/Flickr, 2021
T-11. Provide Employer-Sponsored Vanpool TRANSPORTATION | 105 GHG Reduction Formula
A =
((1 − B) × C × F) + (B × D
E
× G)
((1 − B) × C × F) + (B × D × F)
− 1
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
project/site employee commute VMT
3.4–20.4 % calculated
User Inputs
None
Constants, Assumptions, and Available Defaults
B Percent of employees that participate in
vanpool program
2.7 % SANDAG 2019
C Average length of one-way vehicle
commute trip in region
Table
T-11.1
miles per trip FHWA 2017
D Average length of one-way vanpool
commute trip
42.0 miles per trip SANDAG 2019
E Average vanpool occupancy (including
driver)
6.25 occupants SANDAG 2019
F Average emission factor of average
employee vehicle
307.5 g CO2e per mile CARB 2020
G Vanpool emission factor 763.4 g CO2e per mile CARB 2020 Further explanation of key variables:
▪ (B) – The percent of employees that would participate in a vanpool program is based on a survey of commuters in San Diego County (SANDAG 2019). If the project is not within San Diego County or the user is able to provide a project-specific value for within San Diego County, the user should replace the default employee participation rate in the GHG reduction formula.
▪ (C) – Ideally, the user will calculate auto commute trip lengths for a Project/Site at a scale no larger than a census tract. Potential data sources include the U.S. Census, California Household Travel Survey (preferred), or local survey efforts. If the user is not able to provide a project-specific value using one of these data sources, they have the option to input the regional average one-way auto commute trip length for one of the six most populated CBSAs in California, as presented in Table T-11.1 in Appendix C (FHWA 2017). Trip lengths are likely to be longer for areas not covered by the listed CBSAs, which represent the denser areas of the state.
▪ (D and E) – The average one-way vanpool commute trip length and occupancy are based on data from the San Diego Association of Government’s regional vanpool program (SANDAG 2019). If the project is not within San Diego County or the user is T-11. Provide Employer-Sponsored Vanpool TRANSPORTATION | 106 able to provide a project-specific value for within San Diego County, the user should replace these defaults in the GHG reduction formula.
▪ (F and G) – The average GHG emission factors for employee commute and vanpool vehicles were calculated in terms of CO2e per mile using EMFAC2017 (v1.0.3). The model was run for a 2020 statewide average using diesel and gasoline fuel. The average of the light-duty automobile (LDA) and light duty truck (LDT1/LDT2) vehicle categories represents employee non-vanpool vehicles and the light-heavy duty truck (LHDT1) vehicle category conservatively represents a large cargo vanpool vehicle. The running emission factors for CO2, CH4, and N2O (CARB 2020) were multiplied by the corresponding 100-year GWP values from the IPCC’s Fourth Assessment Report (IPCC 2007). If the user can provide a project-specific value (i.e., for a future year and project location), the user should run EMFAC to replace the defaults in the GHG reduction formula.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) For projects in San Diego County that use default CBSA data from Table T-11.1 and (Bmax), the maximum percent reduction in GHG emissions (A) is 20.4 percent. This maximum scenario is presented in the below example quantification. (Bmax) The percent of employees that participate in the vanpool program is capped at 15 percent, which is based on the high end of vanpool participation survey data for several successful programs in the U.S. (SANDAG 2019).
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for either Measure T-5 or T-6.
However, this measure may be implemented alongside other individual CTR measures (Measures T-7 through T-10, T-12, and T-13). The efficacy of individual programs may vary highly based on individual employers and local contexts.
Example GHG Reduction Quantification
The user reduces employee commute VMT by requiring that the employer of the project to sponsor a vanpool program. In this example, the project is in the San Diego-Carlsbad CBSA and would have an average vehicle commute trip length of 14.52 miles (C). The percent of employees that participate in the vanpool program is 15 percent (Bmax). GHG emissions from employee commute would be reduced by 20.4 percent.
T-11. Provide Employer-Sponsored Vanpool TRANSPORTATION | 107 Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption (H) can be calculated using the GHG reduction formula except that (F) and (G) should be replaced by (I) and (J), as follows.
Fuel Use Reduction Formula
H =
((1 − B) × C × I) + (B × D
E
× J)
((1 − B) × C × I) + (B × D × I)
− 1
Fuel Use Reduction Calculation Variables
ID Variable Value Unit Source
Output
H Percent reduction in fuel use from
project/site employee commute VMT
4.7–21.4 % calculated
User Inputs
None
Constants, Assumptions, and Available Defaults
I Fuel efficiency of average employee
vehicle
0.03639 gallon (gal)
per mile
CARB 2020
J Fuel efficiency of vanpool vehicle 0.08328 gal per mile CARB 2020 Further explanation of key variables:
▪ (I and J) – The average fuel efficiencies for employee commute and vanpool vehicles were calculated using EMFAC2017 (v1.0.3). The model was run for a 2020 statewide average using diesel and gasoline fuel. The average of the LDA, A=
((1 − 15%) × 14.52 miles
trip × 307.5 g CO2e
miles ) + (15% ×
42 miles
trip
6.25 occupants × 763.4 g CO2e
miles )
((1 − 15%) × 14.52 miles
trip × 307.5 g CO2e
miles ) + (15% × 42 miles
trip × 307.5 g CO2e
miles )
𝑒
− 1 = -20.4%
T-11. Provide Employer-Sponsored Vanpool TRANSPORTATION | 108 LDT1, and LDT2 vehicle categories represents employee non-vanpool vehicles, and the LHDT1 vehicle category conservatively represents a large cargo vanpool vehicle. If the user can provide a project-specific value (i.e., for a future year and project location), the user should run EMFAC to replace the defaults in the fuel use reduction formula.
▪ Please refer to the GHG Calculation Variables table above for definitions of variables that have been previously defined.
VMT Reductions
The percent reduction in VMT can be calculated using a modified version of the GHG reduction formula, as shown below.
% VMT Reduction =
((1 − B) × C) + (B × D
E
)
C − 1
Sources
▪ California Air Resources Board (CARB). 2020. EMFAC2017 v1.0.3. August. Available:
https://arb.ca.gov/emfac/emissions-inventory. Accessed: January 2021. ▪ Federal Highway Administration (FHWA). 2017. National Household Travel Survey–2017 Table Designer. Travel Day VT by HH_CBSA by TRPTRANS by TRIPPURP. Available: https://nhts.ornl.gov/.
Accessed: January 2021.
▪ Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K. B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 996 pp. Available: https://www.ipcc.ch/report/ar4/wg1/.
Accessed: January 2021.
▪ San Diego Association of Governments (SANDAG). 2019. Mobility Management VMT Reduction Calculator Tool–Design Document. June. Available: https://www.icommutesd.com/docs/default-source/planning/tooldesign-document_final_7-17-19.pdf?sfvrsn=ec39eb3b_2. Accessed: January 2021.
TRANSPORTATION | 109
T-12. Price Workplace Parking
GHG Mitigation Potential
Up to 20.0% of GHG
emissions from project/site
employee commute VMT
Co-Benefits (icon key on pg. 34)
Climate Resilience
Priced workplace parking could incentivize
increased use of public transit and thus
result in less traffic, potentially reducing
congestion or delays on major roads during
peak AM and PM traffic periods. When this
reduction occurs during extreme weather
events, it better allows emergency
responders to access a hazard site.
Health and Equity Considerations
Parking pricing should include hourly and
daily options so part-time staff do not need
a monthly pass. If the project includes lowwaged employees that have fewer transportation choices or time and resource
constraints, it is instead recommended to
consider implementing Measure T-13,
Implement Employee Parking Cash-Out, or
other transportation subsidy.
Measure Description
This measure will price onsite parking at workplaces. Because free employee parking is a common benefit, charging employees to park onsite increases the cost of choosing to drive to work. This is expected to reduce single-occupancy vehicle commute trips, resulting in decreased VMT, thereby reducing associated GHG emissions.
Subsector
Trip Reduction Programs
Locational Context
Urban, suburban
Scale of Application
Project/Site
Implementation Requirements
Implementation may include the following.
▪ Explicitly charging for employee parking.
▪ Implementing above-market rate pricing.
▪ Validating parking only for invited guests (or not providing parking validation at all).
▪ Not providing employee parking and transportation
allowances.
In addition, this measure should include marketing and education regarding available alternatives to driving.
Cost Considerations
Parking fees would be a direct, recurring cost for employees.
Employer costs include labor costs for program management and monitoring, but this may be offset by revenue generated by the program.
Expanded Mitigation Options
Best practice is to ensure that other transportation options are available, convenient, and have competitive travel times (i.e., transit service near the project site, shuttle service, or a complete active transportation network serving the site and surrounding community), and that there is not alternative free parking available nearby (such as on-street). This measure is substantially less effective in environments that do not have other modes available or where unrestricted street parking or other offsite parking is available nearby and has adequate capacity to accommodate project-related vehicle parking demand.
20%
T-12. Price Workplace Parking TRANSPORTATION | 110
GHG Reduction Formula
For calculating effectiveness of pricing residential parking, see Measure T-16, Unbundle Residential Parking Costs from Property Cost. For calculating effectiveness of pricing parking at visitor-intensive land uses, see Measure T-24, Implement Market Price Public Parking (On-Street).
A =
B − C
C
× E × D × F
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
employee commute VMT
0–20.0 % calculated
User Inputs
B Proposed parking price [ ] $ user input
C Baseline parking price [ ] $ user input
D Share of employees paying for parking [ ] % user input Constants, Assumptions, and Available Defaults
E Elasticity of parking demand with
respecting to parking price
-0.4 unitless Lehner &
Peer 2019
F Ratio of vehicle trip reduction to VMT 1 unitless assumption Further explanation of key variables:
▪ (B) – Parking price can be provided on an hourly, daily, or monthly basis. Monthly pricing is less effective than requiring daily or hourly payment since the price signal is diluted to only once a month.
▪ (C) – If baseline parking price is $0 (that is, if parking is typically free), set C = ¼ B, allowing for the maximum 50 percent increase in price. Alternatively, for locations that are located within 0.5 mile of transit service, set C = average transit fare to/from the location.
▪ (D) – Many organizations allow some employees free parking benefits. VMT reductions should be adjusted based on the share of employees that would be paying for parking. ▪ (E) – A meta-analysis of parking price studies found that a 0.40 percent decrease in parking demand occurs for every 1 percent increase in parking price (Lehner & Peer 2019). Price elasticity of parking demand varies by location, day of the week, and time of day.
▪ (F) – The adjustment factor from vehicle trips to VMT is 1. This assumes that all vehicle trips will average out to typical trip length (“assumes all trip lengths are equal”). Thus, it can be assumed that a percentage reduction in vehicle trips will equal the same percentage reduction in VMT. Subsidies or discounts targeting commute trips may have a higher factor as they are generally longer than the trip lengths for other purposes.
T-12. Price Workplace Parking TRANSPORTATION | 111
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The GHG reduction from priced workplace parking is capped at 20 percent. This maximum scenario is presented in the below example quantification. (
B−C
C max
) The percent increase in parking price is capped at 50 percent.
Subsector Maximum
( ∑ AmaxT-5 through T-13 ≤45%) This measure is in the Trip Reduction Programs subsector. This subcategory includes Measures T-5 through T-13. The employee commute VMT reduction from the combined implementation of all measures within this subsector is capped at 45 percent.
Mutually Exclusive Measures
If this measure is selected, the user may not also take credit for Measure T-13, Implement Employee Parking Cash-Out. While both measures focus on providing a price signal for employees to consider other modes for their work commute, this measure actively charges all employees to park, while Measure T-13 reimburses employees who do not park. Users should select either Measure T-12 or T-13.
Example GHG Reduction Quantification
The user reduces VMT by increasing the price of a monthly parking permit. In this example, the permit fee is increased from $50 (C) to $75 (B). If 100 percent of employees are subject to parking pricing (D), the user would reduce GHG emissions from VMT by 20 percent.
Quantified Co-Benefits
Improved Local Air Quality
The percent reduction in GHG emissions (A) would be the same as the percent reduction in NOX, CO, NO2, SO2, and PM. Reductions in ROG emissions can be calculated by multiplying the percent reduction in GHG emissions (A) by an adjustment factor of 87 percent. See Adjusting VMT Reductions to Emission Reductions above for further discussion.
Energy and Fuel Savings
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in GHG emissions (A).
A =
$75 − $50
$50 × -0.4 × 100% × 1 = -20%
T-12. Price Workplace Parking TRANSPORTATION | 112
VMT Reductions
The percent reduction in VMT would be the same as the percent reduction in GHG emissions (A).
Sources
▪ Lehner, S., Peer, S. 2019. The Price Elasticity of Parking: A Meta-analysis. Transportation Research Part A: Policy and Practice 121 2019. Available:
http://sustainabletransportationsc.org/garage/pdf/parking_elasticity.pdf. Accessed: January 2021.
Attachment B: DKS VMT Analysis 3/10/23
DRAFT VMT ANALYS IS
DATE: March 10, 2023
TO: Matthew Ilagan, Pelle Clarke | City of Sacramento
FROM: Sean Carney, David Tokarski, Vic Maslanka | DKS Associates SUBJECT: Airport South Industrial VMT Analysis Project #19179-024
INTRODUCTION
In accordance with Senate Bill 743 (SB 743) and the resulting changes to the California Environmental Quality Act (CEQA) Guidelines published by the Natural Resources Agency, local agencies may no longer use measures of vehicle delay such as Level of Service (LOS) to quantify transportation impacts on the environment. VMT is a systemic metric and is a useful indicator of overall land use and transportation efficiency, where the most efficient system is one that minimizes VMT by encouraging shorter vehicle trip lengths, more walking and biking, or increased carpooling and transit. Vehicle miles traveled (VMT) has been codified in the CEQA Guidelines as the most appropriate measure for measuring transportation impacts under CEQA. This change went into effect statewide on July 1, 2020. The City of Sacramento’s draft transportation impact guidelines are consistent with OPR’s recommendation of using VMT as a metric.
INDUSTRIAL USES
Based on 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% of the regional average, consistent with technical guidance published by the 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 (including Sacramento County (adopted) and the City of Rancho Cordova (adopted)) have determined that the significance threshold for industrial employment is 100% of regional average. The reasoning for this less restrictive threshold for industrial uses compared to other employment types is rooted in improving overall VMT efficiency of all future development in aggregate. Industrial uses generally have more zoning restrictions and are generally less densely developed than other employment types making them less desirable within urban areas. By keeping these uses outside of urban centers, the land that they would occupy can instead be used for higher density land development that can see a greater benefit from being located in VMT efficient areas. This inherently means industrial uses will have higher VMT per employee than other employment types because they are A IRPORT SO UTH I ND US TR IA L • VMT A NA LYS IS • MARCH 10 , 2023 2 located further from a good mix of housing and services which are necessary to achieve lower VMT levels. The draft City of Sacramento Transportation Impact Analysis Guidelines do not specify a significance threshold for industrial land uses. For consistency with other nearby jurisdictions and after discussion with City staff, this analysis applies the significance threshold of 100% of regional average for industrial uses.
HIGHWAY COMMERCIAL USES
Because new retail development often redistributes trips rather than creating new travel demand, the OPR guidance recommends that lead agencies analyze the net change in VMT to indicate the transportation impact of retail projects.1
The potential for VMT impacts, according to this approach, hinges on whether the project can be considered local-serving or regional. By adding retail opportunities within existing neighborhoods, local-serving retail projects can shorten trips and reduce overall VMT. In contrast, regional destination retail projects would draw customers from larger trade areas, potentially substituting for shorter trips and increasing VMT. The OPR guidance suggests that any retail projects including stores larger than 50,000 square feet might be considered regional serving retail.
This approach has been applied to the highway commercial uses. As discussed below, the individual uses were reviewed to determine whether they can be considered regional “destination” uses which would attract vehicle trips from a large area and potentially increase VMT, or whether the uses duplicate other existing projects in the nearby area and could reduce VMT.
VMT SCREENING
VMT SCREENING CRITERIA
Pursuant to SB 743 and technical guidance published by OPR, there are several screening procedures to potentially streamline project analysis (i.e., provide a presumptive non-impact finding and obviate the need for a VMT analysis). The various screening options are listed below with a brief determination of whether a given screen is triggered by the proposed project. Project Size: Projects that generate fewer than 110 trips per day can be presumed to have a less than significant transportation impact. Based on the trip generation data presented in the Transportation Analysis (in a separate document prepared by DKS), the proposed project does not meet this screening criteria.
Proximity to High Quality Transit: Residential or office projects within one-half mile of an existing major transit station or stop along an existing high-quality transit corridor can be 1 Governor’s Office of Planning and Research, Technical Advisory on Evaluating Transportation Impacts in CEQA. (New York: Free Press, December 2018), 15–16.
A IRPORT SO UTH I ND US TR IA L • VMT A NA LYS IS • MARCH 10 , 2023 3 presumed to have a less than significant transportation impact. The proposed project is not currently served by transit. The project does not meet this screening criteria. Affordable Housing Development: The proposed project does not include the provision of housing. The proposed project does not meet this screening criteria. Locally Serving Retail: Typically less than 50,000 square feet. The Highway Commercial component of the project could potentially meet this screening criteria, as discussed below. Infrastructure: Projects that would not likely lead to a substantial or measurable increase in vehicle travel are presumed to be VMT neutral and generally presumed to have a less than significant transportation impact (i.e., induced VMT). These include: Roadway Maintenance and Rehab Projects; Signal Timing / Synchronization / Adaptive Signal Control /Signal Preemption Improvements; Intersection Control Type and Turn Lane Channelization Improvements; Widening for Local or Local Collector Streets; and Transit / Bicycle / Pedestrian Infrastructure Improvements. The proposed project does not contain any substantial infrastructure improvements that meet this screening criteria.
Project Location: Projects that fall within an identified location (in this case SACOG’s hexagon methodology is used for screening purposes) that demonstrates VMT per Capita for residential projects below 85% of the regional average for that metric, or VMT per Employee for employment-based projects below 100% of the regional average for that metric. As discussed below, the industrial portion of the project does not meet this screening criteria.
INDUSTRIAL VMT ANALYSIS
VMT EMPLOYMENT SCREENING MAP
Figure 1 illustrates SACOG’s VMT Employment Screening Map for the project vicinity. As the hexagons are based upon 2016 conditions, and the project site was vacant, there are no applicable hexagons that apply to the entirety of the project. On the northeast corner of the project site, the hexagon which includes the northwest (employment) corner of Westlake, the VMT per employee is shown as 103% of the regional average.
A IRPORT SO UTH I ND US TR IA L • VMT A NA LYS IS • MARCH 10 , 2023 4 FIGURE 1: VMT EMPLOYMENT SCREENING MAP
Near the northwest corner of the project site, several hexagons are located at and adjacent to Sacramento International Airport. The VMT per employee is shown as 178% of the regional average. The SACOG screening map does not provide information for most of Metro Airpark, as the calculations are based upon 2016 conditions. Based upon this information, the industrial portion of the project does not meet the screening criteria.
TRAVEL DEMAND MODEL ANALYSIS
TRAVEL DEMAND MODEL
The CEQA VMT analysis is based on the latest SACOG SACSIM-19 activity-based travel demand model (ABM) including scripts prepared by SACOG for this very analysis purpose. The analysis is tour‐based, meaning that the analysis fully accounts for trips that are linked to trips that start or end at the project. This means that intermediate trips, such as those occurring after someone has left the project area, such as a trip to pick‐up lunch while at work, are accounted for in this analysis.
Based on the latest SACOG model scripts, SACSIM-19 also reflects the entire trip length, including the portion of the trip that occurs outside the SACOG region. External‐internal and internal‐external A IRPORT SO UTH I ND US TR IA L • VMT A NA LYS IS • MARCH 10 , 2023 5 VMT is calculated via a script file provided by SACOG and included in their model for VMT post‐processing. The post-processor determines the added VMT that occurs outside the SACOG region (i.e., for trips that either start or end outside of the region). This interregional VMT is then added to the internal-internal VMT to determine the total VMT. Consistent with OPR guidelines, only automobile trips are considered as a part of this analysis. Heavy-duty truck and delivery vehicle VMT as well as alternative mode VMT (transit vehicles) are not reflected.
PROJECT USE (VMT PER EMPLOYEE METRIC)
For work-based land uses of the proposed project, SACSIM-19 was used with a modified version of the SACOG script to meet guidance from the Office of Planning and Research (OPR) as previously discussed. A regional baseline (2016) average VMT per employee metric was used to establish the threshold set at 100% of the regional average.
For the industrial portion of the project, the average VMT is calculated as 128% of the regional average.
HIGHWAY COMMERCIAL VMT ANALYSIS
The highway commercial area of the project includes the uses shown in Table 1.
A IRPORT SO UTH I ND US TR IA L • VMT A NA LYS IS • MARCH 10 , 2023 6 TABLE 1: HIGHWAY COMMERCIAL LAND USE SUMMARY
Source: Wood Rodgers, June 20, 2022.
The proposed uses are ubiquitous throughout the area, with many competitors at nearby I-5 interchanges (Del Paso Road and Arena Boulevard). This includes restaurants, fueling stations, carwashes, convenience stores, and hotels.
The highway commercial uses would serve travelers and employees associated with Sacramento International Airport. These trips could reduce VMT by potentially diverting a trip from a destination located farther from the airport.
The highway commercial uses would also serve the industrial uses of the project, as well as the development of Metro Airpark. These trips could reduce VMT by potentially diverting a trip from a destination located farther from the project and Metro Airpark. With the exception of the hotel, all of the projects are less than 50,000 square feet, which is a “rule of thumb” for VMT screening of retail projects.
VMT IMPACT
INDUSTRIAL USES
The travel model VMT analysis estimates the average VMT of the industrial uses as 128% of the regional average. This is a significant impact.
HIGHWAY COMMERCIAL USES
Based upon the nature of the highway commercial uses, it is concluded that the highway commercial uses meet the retail screening criteria. This is a less-than-significant impact.
PARCEL USE PARCEL SIZE (ACRES) BUILDING SIZE
(SQUARE FEET)
6A Restaurant 2.1 3,900
6B Restaurant 1.5 3,900
6C Fueling Station /
Carwash 3.0 8,100
7A Hotel 4.0 73,400
7B Restaurant 1.5 3,900
7C Restaurant 1.3 5,000
Appendix C
AERMOD Model Options
Model Options
Pathway Keyword Description Value
CO TITLEONE Project title 1 Airport South Industrial Project CO TITLETWO Project title 2
CO MODELOPT Model options DFAULT,CONC,NODRYDPLT,NOWETDPLT CO AVERTIME Averaging times 1,ANNUAL
CO URBANOPT Urban options
CO POLLUTID Pollutant ID PM25 H1H
CO HALFLIFE Half life
CO DCAYCOEF Decay coefficient
CO FLAGPOLE Flagpole receptor heights 1.8
CO RUNORNOT Run or Not RUN
CO EVENTFIL Event file F
CO SAVEFILE Save file F
CO INITFILE Initialization file
CO MULTYEAR Multiple year option N/A
CO DEBUGOPT Debug options N/A
CO ERRORFIL Error file F
SO ELEVUNIT Elevation units METERS
SO EMISUNIT Emission units N/A
RE ELEVUNIT Elevation units METERS
ME SURFFILE Surface met file I:\Projects\Reference Material\Air Quality Assessment\_HRA Guidance_2023 \Meteorological Data for AERMOD\Sac International Airport.SFC ME PROFFILE Profile met file I:\Projects\Reference Material\Air Quality Assessment\_HRA Guidance_2023 \Meteorological Data for AERMOD\Sac International Airport.PFL ME SURFDATA Surf met data info. 93225 2014
ME UAIRDATA U-Air met data info. 23230 2014
ME SITEDATA On-site met data info.
ME PROFBASE Elev. above MSL 8.2
ME STARTEND Start-end met dates
ME WDROTATE Wind dir. rot. adjust.
ME WINDCATS Wind speed cat. max.
ME SCIMBYHR SCIM sample params
EV DAYTABLE Print summary opt. N/A
OU EVENTOUT Output info. level N/A
Report for "ASIP.ami" Page 1 of 5
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 Source Parameter Tables
OU DAYTABLE Print summary opt.
All Sources
Source ID /
Pollutant ID Source Type Description UTM Elev. Emiss. Rate Emiss. Units Release
Height
East (m) North (m) (m) (m)
LUN1H01R POINT V1 624356.6 4280909.1 0 2.68225E-05 (g/s) 3.84048 LUN1H01S POINT HL1 624356.6 4280909.8 0 2.68225E-05 (g/s) 0.18288 LUN1H01T POINT HH1 624358.3 4280909.8 0 2.68225E-05 (g/s) 3.84048 LUN1H01U POINT V2 624380.8 4280497.5 0 3.64222E-05 (g/s) 3.84048 LUN1H01V POINT HL2 624383.7 4280500.4 0 3.64222E-05 (g/s) 0.18288 LUN1H01W POINT HH2 624380.8 4280500.4 0 3.64222E-05 (g/s) 3.84048 LUN1H01X POINT V3 625169.3 4280921.1 0 2.11757E-05 (g/s) 3.84048 LUN1H01Y POINT HL3 625169.3 4280921.1 0 2.11757E-05 (g/s) 0.18288 LUN1H020 POINT HH3 625169.3 4280923.2 0 2.11757E-05 (g/s) 3.84048 LUN1H021 POINT V4 625296.3 4280517.5 0 3.64222E-05 (g/s) 3.84048 LUN1H022 POINT HL4 625293.2 4280520.6 0 3.64222E-05 (g/s) 0.18288 LUN1H023 POINT HH4 625293.2 4280520.6 0 3.64222E-05 (g/s) 3.84048 LUN1H024 POINT V5 626021 4280895.4 0 0.0000213169 (g/s) 3.84048 LUN1H025 POINT HL5 626017.9 4280898.5 0 0.0000213169 (g/s) 0.18288 LUN1H026 POINT HH5 626017.9 4280901.6 0 0.0000213169 (g/s) 3.84048 8J30S000 POINT 624299.8 4280908.8 0 0.00005250 (g/s) 3.66 8J30S001 POINT 625114.2 4280923.2 0 0.00005250 (g/s) 3.66 8J30S002 POINT 625939.4 4280908.8 0 0.00005250 (g/s) 3.66 8J30S003 POINT 624325 4280505.2 0 0.00005250 (g/s) 3.66 8J30S004 POINT 625225.9 4280526.8 0 0.00005250 (g/s) 3.66 LUN1H002 VOLUME 626109.4 4280840.8 0 1.404589E-05 (g/s) 2.3 LUN1H003 VOLUME 626057.4 4280840.5 0 1.404589E-05 (g/s) 2.3 LUN1H004 VOLUME 626005.4 4280840.2 0 1.404589E-05 (g/s) 2.3 LUN1H005 VOLUME 625953.4 4280839.9 0 1.404589E-05 (g/s) 2.3 LUN1H006 VOLUME 625901.4 4280839.6 0 1.404589E-05 (g/s) 2.3 LUN1H007 VOLUME 625849.4 4280839.3 0 1.404589E-05 (g/s) 2.3 LUN1H008 VOLUME 625797.4 4280839.1 0 1.404589E-05 (g/s) 2.3 LUN1H009 VOLUME 625745.4 4280838.8 0 1.404589E-05 (g/s) 2.3 LUN1H00A VOLUME 625693.4 4280838.5 0 1.404589E-05 (g/s) 2.3 LUN1H00B VOLUME 625641.4 4280838.2 0 1.404589E-05 (g/s) 2.3 LUN1H00C VOLUME 625589.4 4280837.9 0 1.404589E-05 (g/s) 2.3 LUN1H00D VOLUME 625537.4 4280837.6 0 1.404589E-05 (g/s) 2.3 LUN1H00E VOLUME 625485.4 4280837.4 0 1.404589E-05 (g/s) 2.3 LUN1H00H VOLUME 625431.9 4280833.8 0 5.063473E-05 (g/s) 2.3 Report for "ASIP.ami" Page 2 of 5
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 LUN1H00I VOLUME 625379.9 4280834.5 0 5.063473E-05 (g/s) 2.3 LUN1H00J VOLUME 625327.9 4280835.2 0 5.063473E-05 (g/s) 2.3 LUN1H00K VOLUME 625275.9 4280836.0 0 5.063473E-05 (g/s) 2.3 LUN1H00L VOLUME 625223.9 4280836.7 0 5.063473E-05 (g/s) 2.3 LUN1H00M VOLUME 625171.9 4280837.4 0 5.063473E-05 (g/s) 2.3 LUN1H00N VOLUME 625119.9 4280838.1 0 5.063473E-05 (g/s) 2.3 LUN1H00O VOLUME 625067.9 4280838.9 0 5.063473E-05 (g/s) 2.3 LUN1H00P VOLUME 625015.9 4280839.6 0 5.063473E-05 (g/s) 2.3 LUN1H00Q VOLUME 624963.9 4280840.3 0 5.063473E-05 (g/s) 2.3 LUN1H00R VOLUME 624912.0 4280841.1 0 5.063473E-05 (g/s) 2.3 LUN1H00S VOLUME 624860.0 4280841.8 0 5.063473E-05 (g/s) 2.3 LUN1H00T VOLUME 624808.0 4280842.5 0 5.063473E-05 (g/s) 2.3 LUN1H00U VOLUME 624756.0 4280843.2 0 5.063473E-05 (g/s) 2.3 LUN1H00V VOLUME 624704.0 4280844.0 0 5.063473E-05 (g/s) 2.3 LUN1H00W VOLUME 624652.0 4280844.7 0 5.063473E-05 (g/s) 2.3 LUN1H00Z VOLUME 624614.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H010 VOLUME 624562.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H011 VOLUME 624510.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H012 VOLUME 624458.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H013 VOLUME 624406.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H014 VOLUME 624354.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H015 VOLUME 624302.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H016 VOLUME 624250.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H017 VOLUME 624198.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H018 VOLUME 624146.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H019 VOLUME 624094.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H01A VOLUME 624042.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H01B VOLUME 623990.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H01C VOLUME 623938.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H01D VOLUME 623886.4 4280844.7 0 4.224243E-05 (g/s) 2.3 LUN1H01G VOLUME 624662.7 4281390.2 0 0.0001034244 (g/s) 2.3 LUN1H01H VOLUME 624661.6 4281338.2 0 0.0001034244 (g/s) 2.3 LUN1H01I VOLUME 624660.6 4281286.2 0 0.0001034244 (g/s) 2.3 LUN1H01J VOLUME 624659.5 4281234.2 0 0.0001034244 (g/s) 2.3 LUN1H01K VOLUME 624658.4 4281182.2 0 0.0001034244 (g/s) 2.3 LUN1H01L VOLUME 624657.4 4281130.3 0 0.0001034244 (g/s) 2.3 LUN1H01M VOLUME 624656.3 4281078.3 0 0.0001034244 (g/s) 2.3 LUN1H01N VOLUME 624655.3 4281026.3 0 0.0001034244 (g/s) 2.3 LUN1H01O VOLUME 624654.2 4280974.3 0 0.0001034244 (g/s) 2.3 LUN1H01P VOLUME 624653.1 4280922.3 0 0.0001034244 (g/s) 2.3 LUN1H01Q VOLUME 624652.1 4280870.3 0 0.0001034244 (g/s) 2.3 Point Sources
Source ID /
Pollutant ID Description
UTM Elev. Emiss. Rate Stack
Height
Stack
Temp
Stack
Velocity
Stack
Diameter
Report for "ASIP.ami" Page 3 of 5
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 East (m) North (m) (m) (g/s) (m) (K) (m/s) (m)
LUN1H01R V1 624356.6 4280909.1 0 2.68225E-05 3.84048 366 51.71 0.1 LUN1H01S HL1 624356.6 4280909.8 0 2.68225E-05 0.18288 366 0.001 0.1 LUN1H01T HH1 624358.3 4280909.8 0 2.68225E-05 3.84048 366 0.001 0.1 LUN1H01U V2 624380.8 4280497.5 0 3.64222E-05 3.84048 366 51.71 0.1 LUN1H01V HL2 624383.7 4280500.4 0 3.64222E-05 0.18288 366 0.001 0.1 LUN1H01W HH2 624380.8 4280500.4 0 3.64222E-05 3.84048 366 0.001 0.1 LUN1H01X V3 625169.3 4280921.1 0 2.11757E-05 3.84048 366 51.71 0.1 LUN1H01Y HL3 625169.3 4280921.1 0 2.11757E-05 0.18288 366 0.001 0.1 LUN1H020 HH3 625169.3 4280923.2 0 2.11757E-05 3.84048 366 0.001 0.1 LUN1H021 V4 625296.3 4280517.5 0 3.64222E-05 3.84048 366 51.71 0.1 LUN1H022 HL4 625293.2 4280520.6 0 3.64222E-05 0.18288 366 0.001 0.1 LUN1H023 HH4 625293.2 4280520.6 0 3.64222E-05 3.84048 366 0.001 0.1 LUN1H024 V5 626021 4280895.4 0 0.0000213169 3.84048 366 51.71 0.1 LUN1H025 HL5 626017.9 4280898.5 0 0.0000213169 0.18288 366 0.001 0.1 LUN1H026 HH5 626017.9 4280901.6 0 0.0000213169 3.84048 366 0.001 0.1 8J30S000 624299.8 4280908.8 0 0.00005250 3.66 739.8 45.3 0.183 8J30S001 625114.2 4280923.2 0 0.00005250 3.66 739.8 45.3 0.183 8J30S002 625939.4 4280908.8 0 0.00005250 3.66 739.8 45.3 0.183 8J30S003 624325 4280505.2 0 0.00005250 3.66 739.8 45.3 0.183 8J30S004 625225.9 4280526.8 0 0.00005250 3.66 739.8 45.3 0.183 Volume Sources
Source ID /
Pollutant ID Description UTM Elev. Emiss. Rate Release
Height
Init. Lat.
Dim.
Init. Vert.
Dim.
East (m) North (m) (m) (g/s) (m) (m) (m)
LUN1H002 626109.4 4280840.8 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H003 626057.4 4280840.5 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H004 626005.4 4280840.2 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H005 625953.4 4280839.9 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H006 625901.4 4280839.6 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H007 625849.4 4280839.3 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H008 625797.4 4280839.1 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H009 625745.4 4280838.8 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00A 625693.4 4280838.5 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00B 625641.4 4280838.2 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00C 625589.4 4280837.9 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00D 625537.4 4280837.6 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00E 625485.4 4280837.4 0 1.404589E-05 2.3 24.18605 2.139535 LUN1H00H 625431.9 4280833.8 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00I 625379.9 4280834.5 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00J 625327.9 4280835.2 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00K 625275.9 4280836.0 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00L 625223.9 4280836.7 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00M 625171.9 4280837.4 0 5.063473E-05 2.3 24.18605 2.139535 Report for "ASIP.ami" Page 4 of 5
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 LUN1H00N 625119.9 4280838.1 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00O 625067.9 4280838.9 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00P 625015.9 4280839.6 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00Q 624963.9 4280840.3 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00R 624912.0 4280841.1 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00S 624860.0 4280841.8 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00T 624808.0 4280842.5 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00U 624756.0 4280843.2 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00V 624704.0 4280844.0 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00W 624652.0 4280844.7 0 5.063473E-05 2.3 24.18605 2.139535 LUN1H00Z 624614.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H010 624562.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H011 624510.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H012 624458.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H013 624406.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H014 624354.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H015 624302.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H016 624250.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H017 624198.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H018 624146.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H019 624094.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H01A 624042.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H01B 623990.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H01C 623938.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H01D 623886.4 4280844.7 0 4.224243E-05 2.3 24.18605 2.139535 LUN1H01G 624662.7 4281390.2 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01H 624661.6 4281338.2 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01I 624660.6 4281286.2 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01J 624659.5 4281234.2 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01K 624658.4 4281182.2 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01L 624657.4 4281130.3 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01M 624656.3 4281078.3 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01N 624655.3 4281026.3 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01O 624654.2 4280974.3 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01P 624653.1 4280922.3 0 0.0001034244 2.3 24.18605 2.139535 LUN1H01Q 624652.1 4280870.3 0 0.0001034244 2.3 24.18605 2.139535 Report for "ASIP.ami" Page 5 of 5
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 BREEZE AERMOD Model Results
Max. Annual ( 4 YEARS) Results of Pollutant: PM25 (ug/m**3) Group ID High Avg. Conc.
UTM Elev. Hill Ht. Flag Ht.
Rec. Type Grid ID
East (m) North (m) (m) (m) (m)
ALL 1ST 0.01127 624559.90 4281781.00 0.00 0.00 1.80 DC
2ND 0.01035 624409.90 4281781.00 0.00 0.00 1.80 DC
3RD 0.00979 624709.90 4281781.00 0.00 0.00 1.80 DC
4TH 0.00851 624259.90 4281781.00 0.00 0.00 1.80 DC
5TH 0.00778 624859.90 4281781.00 0.00 0.00 1.80 DC
6TH 0.00693 624109.90 4281781.00 0.00 0.00 1.80 DC
7TH 0.00613 625009.90 4281781.00 0.00 0.00 1.80 DC
8TH 0.00572 623959.90 4281781.00 0.00 0.00 1.80 DC
9TH 0.00527 626200.20 4280755.20 0.00 0.00 1.80 DC
10TH 0.00527 626200.20 4280760.20 0.00 0.00 1.80 DC
Highest Results of Pollutant: PM25
Avg.
Per.
Grp
ID High Type Val Units
Date UTM Elev.
Hill
Ht.
Flag
Ht. Rec.
Type
Grid
ID
YYMMDDHH East (m)
North
(m) (m) (m) (m)
1-HR ALL 1ST Avg.
Conc. 0.40649 ug/m**3 15010423 626198.70 4280894.40 0.00 0.00 1.80 DC Summary of Total Messages
# Message Type
0 Fatal Error Message(s)
11 Warning Message(s)
996 Informational Message(s)
43680 Hours Were Processed
452 Calm Hours Identified
544 Missing Hours Identified ( 1.25 Percent)
Error & Warning Messages
Msg. Type Pathway Ref. # Description
WARNING CO W276 Special proc for 1h-NO2/SO2 24hPM25 NAAQS disabled PM25 H1H WARNING CO W363 Multiyr 24h/Ann PM25 processing not applicable for PM25 H1H WARNING SO W320 Input Parameter May Be Out-of-Range for Parameter VS WARNING SO W320 Input Parameter May Be Out-of-Range for Parameter VS Report for "ASIP.ami" Page 1 of 2
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 www.breeze-software.com
WARNING SO W320 Input Parameter May Be Out-of-Range for Parameter VS WARNING SO W320 Input Parameter May Be Out-of-Range for Parameter VS WARNING SO W320 Input Parameter May Be Out-of-Range for Parameter VS WARNING ME W186 THRESH_1MIN 1-min ASOS wind speed threshold used 0.50 Report for "ASIP.ami" Page 2 of 2
file:///C:/ProgramData/Breeze/AERMOD/20240724135036/ReportsTemp.htm 7/24/2024 *HARP - HRACalc v22118 7/24/2024 4:33:28 PM - Cancer Risk - Input File: C:\Users\jfahrney\Desktop\HARP Results\ASIP - Generator_100 Hrs_HRAInput.hra INDEX GRP1 GRP2 POLID POLABBREV CONC RISK_SUM SCENARIO DETAILS INH_RISK SOIL_RISK DERMAL_RISK MMILK_RISK WATER_RISK FISH_RISK CROP_RISK BEEF_RISK DAIRY_RISK PIG_RISK CHICKEN_RISK EGG_RISK 1ST_DRIVER 2ND_DRIVER PASTURE_CONC FISH_CONC WATER_CONC 1 9901 DieselExhPM 0.01127 9.75E-06 30YrCancerHighEnd_Inh_FAH16to70 * 9.75E-06 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 NA NA 0.00E+00 0.00E+00 0.00E+00 *HARP - HRACalc v22118 7/24/2024 4:33:28 PM - Acute Risk - Input File: C:\Users\jfahrney\Desktop\HARP Results\ASIP - Generator_100 Hrs_HRAInput.hra INDEX GRP1 GRP2 POLID POLABBREV CONC SCENARIO CV CNS IMMUN KIDNEY GILV REPRO/DEVEL RESP SKIN EYE BONE/TEETH ENDO BLOOD ODOR GENERAL 1 9901 DieselExhPM 0.40649 NonCancerAcute 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 *HARP - HRACalc v22118 7/24/2024 4:33:28 PM - Chronic Risk - Input File: C:\Users\jfahrney\Desktop\HARP Results\ASIP - Generator_100 Hrs_HRAInput.hra INDEX GRP1 GRP2 POLID POLABBREV CONC SCENARIO CV CNS IMMUN KIDNEY GILV REPRO/DEVEL RESP SKIN EYE BONE/TEETH ENDO BLOOD ODOR GENERAL DETAILS INH_CONC SOIL_DOSE DERMAL_DOSE MMILK_DOSE WATER_DOSE FISH_DOSE CROP_DOSE BEEF_DOSE DAIRY_DOSE PIG_DOSE CHICKEN_DOSE EGG_DOSE 1ST_DRIVER 2ND_DRIVER 3RD_DRIVER PASTURE_CONC FISH_CONC WATER_CONC 1 9901 DieselExhPM 0.01127 NonCancerChronicHighEnd_Inh 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.25E-03 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 * 1.13E-02 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 INHALATION NA NA 0.00E+00 0.00E+00 0.00E+00