Sacramento City Council
November 18, 2025

3 - Alternatives
Upper Westside Specific Plan 3-33 PLNP2018-00284
Table ALT-4: Reduced Footprint
Land Use
Map
Symbol
Land Use Designation
(Density Range)
Net
Acres
Anticipated
Density/FAR
Dwelling Units/
Square Feet

RESIDENTIAL USES
VLDR Very Low Density Residential
(1.0-4.0 du/ac) 96.3 ac 1.2 du/ac 113 du
LDR Low Density Residential
(4.0-7.0 du/ac) 184.5 ac 5.5 du/ac 1,020 du
LMDR Low Medium Density Residential
(6.0-10.0 du/ac) 118.4 ac 8.0 du/ac 946 du
MDR Medium Density Residential
(8.0-20.0 du/ac) 52.7 ac 12.0 du/ac 631 du
HDR High Density Residential
(20.0-40.0 du/ac) 36.4 ac 25.0 du/ac 911 du
VHDR Very High Density Residential
(20.0-40.0 du/ac) 22.6 ac 35.0 du/ac 791 du
Subtotal 510.9 ac 4,412 du

COMMERCIAL USES
CMU
Commercial Mixed Use
(0.02-2.00+ FAR & 30.0-100.0+
du/ac)

76.8 ac 0.60 FAR

40.0 du/ac
3,023 du
2,007,245 SF
E/HC Employment/Highway
Commercial 52.9 ac 921,730 SF
Subtotal 129.7 ac 3,023 du
2,928,975 SF

PUBLIC, PARK & OPEN SPACE USES
K-8, HS, CC Schools 141.1 ac
P Parks 62.3 ac
GUF Greenbelt/Urban Farm 45.1 ac
OS Open Space – Canal 15.0 ac
OS Open Space – Lake Basins &
Buffers 109.1 ac
Subtotal 372.6 ac
3 - Alternatives
Upper Westside Specific Plan 3-34 PLNP2018-00284
Land Use
Map
Symbol
Land Use Designation
(Density Range)
Net
Acres
Anticipated
Density/FAR
Dwelling Units/
Square Feet

RIGHT-OF-WAY
Major Roads A 116.9 ac
Landscape Corridors 38.2 ac
Subtotal 155.1 ac
Subtotal Development Area 1,158.3 ac

AG BUFFER
AR Agricultural Residential7 86.1 ac --
AG Agricultural Cropland7 773.9 ac --
OS Open Space – Ag Buffer 32.8 ac
Major Road B – Ag Buffer 5.1 ac
Subtotal 897.9 ac
Total 2,066.2 ac 7,435 du
2,928,975 SF
NOTES: ac = acres; Ag Buffer = agricultural buffer; du = dwelling units; FAR = floor area ratio; SF = square feet
SOURCE: Wood Rodgers 2023

AGRICULTURAL RESOURCES
Impacts to agricultural resources land under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development under this alternative would be reduced by approximately 25 percent.

However, despite this reduction, the proposed UWSP’s significant and unavoidable impact with respect to the conversion of farmland to non-agricultural uses would still occur under Alternative 4 and the project’s mitigation measure to compensate for the loss of farmland would still be required under this alternative as farmland would still be converted to urban use.

Furthermore, the impact with respect to conflicts with existing agricultural use and zoning under Alternative 4 would remain less than significant, like the proposed UWSP, as an open space buffer would still be placed between proposed development and existing agricultural land to the west under this alternative and the County’s right-to-farm ordinance would continue to allow farming on adjacent land.

AIR QUALITY
Impacts related to air quality would be reduced under Alternative 4 when compared to the proposed UWSP, as residential and nonresidential development under Alternative 4 3 - Alternatives
Upper Westside Specific Plan 3-35 PLNP2018-00284
would be less than under the proposed UWSP, and thus air pollutant emissions would be correspondingly less under this alternative than under the proposed UWSP. Based upon the reduction in development, the proposed UWSP’s significant and unavoidable impacts (with mitigation) related to conflicts with an applicable air quality plan long-term operational emissions of criteria air pollutants and precursors, and toxic air contaminants would be lessened, but possibly not to a less-than-significant level.

Regardless, the alternative’s air pollutant emissions would still be less than the project as proposed, even if they were to remain significant and unavoidable. However, the reductions in air pollutant emissions that would seemingly be apparent under Alternative 4 could be less than expected because fewer employment and commercial opportunities would be available in the immediate vicinity compared to the proposed plan, and thus some project residents would be required to drive further to access those opportunities.

As a result, more air pollutant emissions would be generated on a per capita basis.

BIOLOGICAL RESOURCES
Impacts to biological resources are most driven by disturbance and removal of habitat, and because disturbance and removal of habitat under Alternative 4 would be approximately 25 percent less that the project as proposed, impacts to biological resources would accordingly be less. Greater areas of agricultural lands would be maintained under this alternative, and some species would benefit from this arrangement. Generally, the proposed UWSP’s less-than-significant impacts (with mitigation) related to sensitive species, riparian habitats, wetlands, wildlife movement, wildlife nursery sites, tree preservation, and conflicts with a habitat conservation plan would be lessened under this alternative.

CLIMATE CHANGE
Impacts related to GHG emissions and climate change would be reduced under Alternative 4 when compared to the proposed UWSP, as residential and nonresidential development under Alternative 4 would be less than under the proposed UWSP, and thus GHG emissions would be correspondingly less under this alternative. Based upon the reduction in development, the proposed UWSP’s less-than-significant impact (with mitigation) related to construction GHG emissions would be reduced.

Similarly, less-than-significant (with mitigation) impacts related to operational GHG emissions and conflicts with an applicable plan, policy, or regulation related to GHG emissions would also be reduced due to the reduction in development. However, the reductions in GHG emissions that would seemingly be apparent under Alternative 4 could be less than expected because fewer employment and commercial opportunities would be available in the immediate vicinity compared to the proposed plan, and thus some project residents would be required to drive further to access those opportunities.

As a result, more GHG emissions would be generated on a per capita basis.

CULTURAL RESOURCES
Impacts related to cultural resources under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development 3 - Alternatives
Upper Westside Specific Plan 3-36 PLNP2018-00284
under this alternative would be reduced by approximately 25 percent. However, despite this reduction, the proposed UWSP’s significant and unavoidable impacts related to historical resources, archaeological resources, and/or human remains would remain under Alternative 4, and the same mitigation as identified for the proposed UWSP would also still be required under this alternative, as the potential for the discovery of unknown historical resources, archaeological resources, and/or human remains during grounddisturbing activities associated with this alternative would remain the same, and as it may not be feasible to avoid these resources in some instances, they may be altered or destroyed.

ENERGY
Impacts related to energy consumption would be reduced under Alternative 4 when compared to the proposed UWSP, as residential and nonresidential development under Alternative 4 would be less than the proposed UWSP, and thus energy consumption would be correspondingly less under this alternative. Based upon the reduction in development, the proposed UWSP’s less-than-significant impacts related to energy use would also be reduced.

However, the reductions in energy use (particularly related to fuel and electric energy to power vehicles) that would seemingly be apparent under Alternative 4 could be less than expected as fewer employment and commercial opportunities would be available in the immediate vicinity, and thus some project residents would be required to drive further to access those opportunities. As a result, more energy would be consumed on a per capita basis

GEOLOGY, SOILS, AND PALEONTOLOGY
Impacts related to geology, soils, and paleontology under Alternative 4 would be reduced, as fewer residents, employees, and structures would be exposed to seismic risks, geologic hazards, and soil conditions found in the UWSP area as the amount of area set aside for new development under this alternative, and thus the amount of area to be disturbed, would be reduced by approximately 25 percent. However, the danger to residents, employees, and structures associated with seismic risks, geologic hazards, and soil conditions found in the UWSP area would not be eliminated under Alternative 4, and the same mitigation measures as identified for the proposed UWSP would also be required under this alternative to reduce impacts to a less-than-significant level.

Concerning paleontological resources, the impact related to these resources would also continue to be potentially significant under Alternative 4, as the potential for the discovery of unknown paleontological resources would remain the same, and thus the same mitigation as identified for the proposed UWSP would also be required under this alternative to reduce the impact to a less-than-significant level.

HAZARDS AND HAZARDOUS MATERIALS
Impacts related to hazards and hazardous materials under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development under this alternative would be reduced by approximately 25 percent. 3 - Alternatives
Upper Westside Specific Plan 3-37 PLNP2018-00284
However, despite this reduction in development, potential impacts related to hazards and hazardous materials would remain. For example, development under Alternative 4 would still result in the routine transport, use, or disposal of hazardous materials.

Furthermore, development under Alternative 2 could result in the accidental release of hazardous materials, and hazardous emissions or use of hazardous materials near schools. However, as development under this alternative would have to adhere to the same government regulations that regulate the use, storage, transport, and disposal of hazardous materials as the proposed UWSP, these impacts would remain less than significant.

Furthermore, the impact related to potential onsite contamination would remain potentially significant under Alternative 4, as potential contamination from pesticides, lead, arsenic, sumps/tanks, septic systems, ACM, LBP, and PCBs would remain present in site soils. However, the same mitigation as identified for the proposed UWSP would also be required under this alternative to reduce the impact to a less-thansignificant level.

Finally, the impact related to physically interfering with an adopted emergency response plan or emergency evacuation plan under Alternative 4 would also remain less than significant, as all development under this alternative, like the proposed UWSP, would be required to prepare a TCP, which would guarantee free flow of traffic through construction zones, and would still not substantially impair emergency response or evacuation in the event of a flood as the amount of area developed would be less.

HYDROLOGY AND WATER QUALITY
Impacts related to hydrology and water quality under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development under this alternative would be reduced by approximately 25 percent.

Specifically, Alternative 4 would entail a reduction of ground-disturbing earthwork, including soil excavation and filling, trenching, grading, and landscaping, and a reduction in the development of new impervious surfaces, such as paved streets, parking lots, and rooftops in comparison to the proposed plan.

However, despite this reduction in development, potential impacts related to violation of water quality standards, waste discharge requirements, or substantial degradation of surface or groundwater quality would not be eliminated, and adherence to the same regulations and mitigation measures as identified for the proposed UWSP would also be required under this alternative to reduce the impact to a less-than-significant level.

The proposed UWSP’s less-than-significant impacts related to groundwater supplies or management; flood risk; alteration of drainage patterns; addition of impervious surfaces resulting in erosion, siltation, increased runoff, impedance, or redirection of flood flows; and conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan would also occur under Alternative 4, but to a lesser extent due to the reduction in new development.
3 - Alternatives
Upper Westside Specific Plan 3-38 PLNP2018-00284

LAND USE
Alternative 4 would reduce the UWSP development area footprint by approximately 25 percent by shifting inward toward the Town Center from the north, east, and south edges. As with the proposed UWSP, development under Alternative 4 would be required to be consistent with applicable land use plans, policies, and regulations, including the Sacramento County 2030 General Plan and the Sacramento County Zoning Code. Therefore, Alternative 4 would result in less-than-significant impacts with respect to physical division of an established community or conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

NOISE
The impact related to construction noise under Alternative 4 would continue to be potentially significant, as the distance between proposed construction onsite and offsite sensitive receptors would remain the same under this alternative as with the proposed UWSP. As a result, the same mitigation as identified for the proposed UWSP would be required under this alternative to reduce this impact to a less-than-significant level.

Similarly, the impact related to construction vibration under Alternative 4 would continue to be potentially significant for the same reason, and the same mitigation as identified for the proposed UWSP would be required under this alternative to reduce this impact to a less-than-significant level.

Next, the impact related to traffic noise at nearby offsite receptors under Alternative 4 would be less severe than the impact described for the proposed UWSP, as the amount of area set aside for new development under this alternative would be reduced by approximately 25 percent. However, this impact would remain significant and unavoidable, and the same mitigation would be required, as the reduction in vehicle trips would likely not be enough to reduce traffic noise levels at nearby receptors to a level that would be below the applicable threshold.

Similarly, the impact related to stationary noise at nearby offsite receptors under Alternative 4 would be less severe than the impact described for the proposed UWSP for the same reason. However, noise from certain stationary sources, such as the proposed high school sports stadium and parks, would remain significant and unavoidable and the same mitigation would be required under Alternative 4, as the distance from these sources to offsite sensitive receptors would remain the same.

With respect to the exposure of people residing or working in the UWSP area to noise generated by aircraft arriving and/or departing from Sacramento International Airport, this impact would remain less than significant under Alternative 4, as all future residential development under this alternative, like the proposed UWSP, would be conditioned to provide noise insulation and disclose the potential for aircraft noise to create a nuisance to potential buyers.

As with offsite receptors, impacts related to traffic noise at proposed onsite receptors under Alternative 4 would be less severe than the impacts described for the proposed UWSP, as the amount of area set aside for new development under this alternative 3 - Alternatives
Upper Westside Specific Plan 3-39 PLNP2018-00284
would be reduced by approximately 25 percent. Specifically, future exterior and interior noise levels at these receptors due to project traffic would remain potentially significant under Alternative 4, as the distance from onsite roadways to onsite sensitive receptors would remain the same. While some residential uses would no longer be located adjacent to I-80 where they would have been exposed to non-CEQA noise impacts, residential uses would still be located near the adjacent existing Travel Plaza and the northern portions of I-80. However, as the same mitigation as identified for the proposed UWSP would also be required under this alternative, these impacts would be reduced to a less-than-significant level.

Finally, the impact related to stationary noise at future onsite receptors under Alternative 4 would be less severe than the impact described for the proposed UWSP for the same reason. However, like the proposed UWSP, noise from the proposed high school sports stadium would remain significant and unavoidable and the same mitigation would be required under Alternative 4, as the distance from these sources to future sensitive receptors would remain the same.

POPULATION AND HOUSING
Impacts related to population and housing under Alternative 4 would be less severe than those described for the proposed UWSP, as the amount of residential use under this alternative would be decreased by approximately 25 percent and the amount of commercial use under this alternative would be reduced by about 5 percent, thus resulting in fewer new residents to be housed within the UWSP area and fewer employees requiring housing elsewhere in the Sacramento region. However, impacts related to the inducement of substantial unplanned population growth in the area, either directly or indirectly, would remain significant and unavoidable as, like the proposed UWSP, development within the plan area under Alternative 4 was not anticipated in either the SACOG Blueprint or the current MTP/SCS. Next, impacts related to displacement of housing would remain less than significant, as no change to the agricultural residential homes located within the UWSP area would occur under this alternative, like the proposed UWSP.

PUBLIC SERVICES AND RECREATION
Impacts related to public services and recreation under Alternative 4 would be less severe than those described for the proposed UWSP, as the amount of residential use under this alternative would be decreased by approximately 25 percent and the amount of commercial use under this alternative would be reduced by about 5 percent, thus resulting in fewer demands for service from public service providers. Specifically, impacts related to the demand for police protection service, fire protection service, public schools, parks and recreation, and libraries would remain less than significant under Alternative 4, as substantially fewer calls for service, fewer students, and fewer residents would be generated under this alternative compared to the proposed UWSP.

TRANSPORTATION
Impacts related to transportation under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development under 3 - Alternatives
Upper Westside Specific Plan 3-40 PLNP2018-00284
this alternative would be reduced by approximately 25 percent, and thus less traffic would be generated. However, the impact related to the consistency with plans, ordinances, or policies addressing the circulation system would continue to be significant and unavoidable and the same mitigation would be required, as the County would still not be able to compel Caltrans and the City of Sacramento to construct likely bicycle and pedestrian at facilities under their jurisdictions.

Furthermore, VMT, which is based on trip length as opposed to number of trips, could increase under Alternative 4 as the amount of retail and employment uses under this alternative would be substantially lower, and thus new residents under this alternative may have to drive farther to access retail services and employment, and thus result in higher per capita VMT.

Next, like the proposed UWSP, the impact related to hazards due to design or incompatible uses under Alternative 4 would continue to be significant and unavoidable and the same mitigation would be required with respect to freeway off-ramp queues exceeding available storage, freeway on-ramp ramp meter queues exceeding available storage, and potential safety issues at the I-80/West El Camino Avenue interchange associated with the Sacramento 49er travel plaza truck stop, as the County would still not be able to compel Caltrans and the City of Sacramento to construct likely improvements at facilities under their jurisdictions.

Finally, the impact related to emergency access would remain less than significant under Alternative 4, as development under this alternative would also be required to comply with applicable fire code requirements for emergency evacuation.

TRIBAL CULTURAL RESOURCES
Impacts related to tribal cultural resources under Alternative 4 would be reduced when compared to the proposed UWSP, as the amount of area set aside for new development under this alternative would be reduced by approximately 25 percent.

However, despite this reduction, the impact related to tribal cultural resources would continue to be potentially significant under Alternative 4, as the potential for the discovery of these resources during ground-disturbing activities would remain. As a result, the same mitigation as identified for the proposed UWSP would be required under Alternative 4. However, even with the implementation of this mitigation, this impact would remain significant and unavoidable, like the proposed UWSP, as it may not be feasible to avoid these resources in some instances, and thus these resources may be altered or destroyed.

UTILITIES AND SERVICE SYSTEMS
The impact related to the provision of utility infrastructure to serve new development under Alternative 4 would be reduced as compared to the proposed UWSP and would remain less than significant, as the location and extent of water distribution, wastewater conveyance, stormwater conveyance, and electrical and natural gas distribution infrastructure would be less under this alternative due to its reduced footprint. Similarly, impacts related to demand for water supply, wastewater disposal, and solid waste disposal would be reduced under Alternative 4 and would remain less than significant, 3 - Alternatives
Upper Westside Specific Plan 3-41 PLNP2018-00284
as the amount of residential use under this alternative would be decreased by approximately 25 percent and the amount of commercial use under this alternative would be reduced by about 5 percent. As a result, fewer residents and employees demanding these services from utility providers would be generated under Alternative 4 compared to the proposed UWSP.

RELATIONSHIP TO PROJECT OBJECTIVES
Alternative 4 would meet or partially meet many of the objectives of the proposed UWSP.

However, due to the 25 percent reduction in the size of the development footprint compared to proposed UWSP, this alternative would reduce the achievement of several proposed UWSP objectives related to the provision of housing and employment opportunities and provision of parks and open space, including Objectives 1, 2, 3, 5, 6, 9, 11, 14, and 16.

OVERALL COMPARISON OF ALTERNATIVES
The analysis of the alternatives is summarized and compared in two tables:

Table ALT-5 provides a summary of impact levels within all environmental topic areas.

Table ALT-6 summarizes the ability of each alternative to meet the objectives for the proposed UWSP.

ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Based on the evaluation described in this chapter, Alternative 1: No Project/No Development, in which no building or development would occur in the UWSP area, would be the most environmentally superior alternative, as this alternative would avoid all significant impacts associated with the proposed UWSP. However, Alternative 1 would not meet any of the proposed UWSP objectives. Alternative 2, the No Project/Existing Zoning Alternative, which assumes that the proposed UWSP would not be approved or implemented, and that future development within the UWSP area would occur consistent with existing County zoning designations, would be the second-most environmentally superior alternative, as it could be expected to avoid all significant impacts associated with the proposed UWSP and would result in reduced less-thansignificant impacts compared to the proposed UWSP. However, all but one (Objective 5) of the proposed UWSP objectives would not be achieved under Alternative 2.

CEQA requires that a second alternative be identified when the “No Project” alternative if the environmentally superior alternative (CEQA Guidelines, Section 15126.6[e]).

Therefore, Alternative 4: Reduced Footprint would be the environmentally superior alternative for the purpose of this analysis. While none of the significant impacts of the proposed UWSP would be avoided under Alternative 4, due to its substantially reduced development footprint, this alternative would provide the greatest reduction in the magnitude of significant impacts while still meeting or partially meeting several of the proposed UWSP objectives.
3 - Alternatives
Upper Westside Specific Plan 3-42 PLNP2018-00284
Table ALT-5: Alternatives Impact Summary and Comparison Impact Category
Alternative 1:

No Project/No
Development
Alternative 2:

No Project/Existing
Zoning
Alternative 3:

Reduced Density
Alternative 4:

Reduced Footprint
Aesthetics No Impact  Less than Significant  Significant and Unavoidable /
Significant and
Unavoidable 
Agricultural Resources No Impact  Less than Significant  Significant and Unavoidable /
Significant and
Unavoidable 
Air Quality No Impact  Less than Significant  Significant and Unavoidable /
Significant and
Unavoidable /
Biological Resources No Impact  Less than Significant  Less than Significant / Less than Significant  Climate Change No Impact  Less than Significant  Less than Significant / Less than Significant / Cultural Resources No Impact  Significant and
Unavoidable /
Significant and
Unavoidable  /
Significant and
Unavoidable 
Energy No Impact  Less than Significant  Less than Significant / Less than Significant / Geology, Soils, and Paleontology No Impact  Less than Significant  Less than Significant  Less than Significant  Hazards and Hazardous Materials No Impact  Less than Significant  Less than Significant  Less than Significant  Hydrology and Water Quality No Impact  Less than Significant  Less than Significant / Less than Significant  Land Use No Impact  Less than Significant  Less than Significant / Less than Significant  Noise No Impact  Less than Significant  Significant and Unavoidable 
Significant and
Unavoidable 
Population and Housing No Impact  Less than Significant  Significant and Unavoidable 
Significant and
Unavoidable 
Public Services and Recreation No Impact  Less than Significant  Less than Significant  Less than Significant  3 - Alternatives
Upper Westside Specific Plan 3-43 PLNP2018-00284
Impact Category
Alternative 1:

No Project/No
Development
Alternative 2:

No Project/Existing
Zoning
Alternative 3:

Reduced Density
Alternative 4:

Reduced Footprint
Transportation No Impact  Less than Significant  Significant and Unavoidable 
Significant and
Unavoidable 
Tribal Cultural Resources No Impact  Significant and
Unavoidable /
Significant and
Unavoidable /
Significant and
Unavoidable /
Utilities and Service Systems No Impact  Less than Significant  Less than Significant  Less than Significant  NOTES:
 - The impact is less than the impact of the proposed UWSP.  - The impact is greater than the impact of the proposed UWSP. / - The impact is about the same as the impact of the proposed UWSP. 3 - Alternatives
Upper Westside Specific Plan 3-44 PLNP2018-00284
Table ALT-6: Ability of Alternatives to Meet Project Objectives Project Objective
Alternative 1:

No Project/
No
Development
Alternative 2:

No Project/
Existing
Zoning
Alternative 3:

Reduced
Density
Alternative 4:

Reduced
Footprint

1. Formulate a specific plan and related land use
planning documents and regulatory approvals for the
UWSP area as a means of expanding the USB and
UPA in an orderly manner and accommodating the
County’s share of future regional population growth.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

2. Create a land use plan that satisfies County policies, regulations, and expectations, as defined in the
General Plan, including Policies LU-114, LU-119, and
LU-120.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

3. Provide a comprehensively planned, high-quality,
large-scale, residential-based community in
northwestern Sacramento County, directly northwest
of the City of Sacramento, with a balanced mix of
uses, employment opportunities, a wide variety of
housing types, park, and open space, and supporting
public and quasi-public uses.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

4. Develop a master-planned community that can be
efficiently served by existing infrastructure or
proposed infrastructure that would encourage logical,
orderly development and would discourage leapfrog
or piecemeal development and sprawl.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

5. Provide residential housing within five miles of the existing job centers of downtown Sacramento and
West Sacramento, as well as in close proximity to
newly developing or proposed job centers.

Does not meet
objective
Partially meets
objective 
Meets
objective 
Meets
objective 

6. Create a development that has an overall positive
economic impact on Sacramento County and
achieves a neutral to positive fiscal impact on the
County’s finances and existing ratepayers.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 
3 - Alternatives
Upper Westside Specific Plan 3-45 PLNP2018-00284
Project Objective
Alternative 1:

No Project/
No
Development
Alternative 2:

No Project/
Existing
Zoning
Alternative 3:

Reduced
Density
Alternative 4:

Reduced
Footprint

7. Create a community that can be logically and
efficiently phased to allow the orderly build-out of the community.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective /

8. Provide a safe and efficient circulation system that interconnects land uses and promotes pedestrian and
bicycle circulation and transit options that will
encourage non-vehicular trips, thereby reducing
vehicle miles traveled (VMT).

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 

9. Incorporate parks and open space, including an urban farm-greenbelt and canal, into the project design in a
manner that provides community connectivity and
encourages walking and bicycle use.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 

10. Make efficient use of development opportunity as the project site is bordered on three sides by existing or
planned urban development.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 

11. Plan for enough units to provide housing choices in varying densities to respond to a range of market
segments, including opportunities for rental units and
affordable housing, and significant commercial uses,
consistent with the General Plan and Housing
Element.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

12. Design a land use plan where the development
footprint avoids impacts to wetland resources to the
extent feasible.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective /

13. Develop a specific plan that respects existing
agricultural land uses and operations to the west of
the proposed 1,532-acre Development Area.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective /
3 - Alternatives
Upper Westside Specific Plan 3-46 PLNP2018-00284
Project Objective
Alternative 1:

No Project/
No
Development
Alternative 2:

No Project/
Existing
Zoning
Alternative 3:

Reduced
Density
Alternative 4:

Reduced
Footprint

14. Provide for development that meets the seven
identified SACOG Blueprint principles, including
provision of transportation choice, compact
development, mixed use development, housing
choice and diversity, use of existing assets, natural
resource conservation, and quality design.

Does not meet
objective
Does not meet
objective
Meets
objective 
Meets
objective 

15. Develop the project and any associated on- and/or
off-site mitigation to complement the Natomas Basin
Habitat Conservation Plan and the Metro Airpark
Habitat Conservation Plan.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective /

16. Designate open space preserves along the south side of Fisherman’s Lake Slough or along the West
Drainage Canal (Witter Canal) that provide natural
buffer to these features, and along the westerly edge
of the proposed 1,532-acre Development Area to
provide a transition between residential and
agricultural designations to the west, which will
provide a regional benefit for habitat, resources, and
open space amenities.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 

17. Balance development with resource protection in an
inter-connected, permanent open space.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 

18. Create multi-functional habitat within open space
corridors that provide on-site habitat and contribute to water quality.

Does not meet
objective
Does not meet
objective
Meets
objective /
Meets
objective 
NOTE: / - The alternative is more/less aligned with the objective.

Upper Westside Specific Plan 4-1 PLNP2018-00284
4 AESTHETICS

INTRODUCTION
This chapter includes a description of the existing visual characteristics of the UWSP area and vicinity, the significance thresholds used to determine the significance of visual and aesthetic impacts, and an analysis of the effects the proposed UWSP could have on views and aesthetics in the project vicinity. The impact discussion evaluates potential impacts to aesthetic and visual resources that could result from implementation of the proposed UWSP compared to existing conditions.

The Notice of Preparation (NOP) for the EIR was circulated on October 5, 2020. No comments were received related to aesthetic, visual, or scenic resources.

The information and analysis included in this chapter was developed based on a review of the proposed UWSP, relevant policies of the Sacramento County 2030 General Plan, and a reconnaissance photographic survey of the UWSP area and vicinity.

ENVIRONMENTAL SETTING

VISUAL CHARACTER OF THE REGION
Sacramento County lies near the center of California’s Central Valley. Views of open spaces and undeveloped lands within the valley region are generally characterized by broad sweeping panoramas of flat agricultural lands and open space dotted with trees, divided by numerous rivers and creeks. To the east, the Sierra Nevada and their foothills form a distant background, and the Coast Ranges provide a backdrop on the distant western horizon.

VISUAL CHARACTER OF THE PROJECT AREA
The approximately 2,066-acre UWSP area is located in unincorporated Sacramento County adjacent to the existing city of Sacramento communities of North and South Natomas. The UWSP area is bounded by Fisherman’s Lake Slough to the north, the West Drainage Canal (Witter Canal) to the east, Interstate 80 (I-80) to the south, and Garden Highway to the west.

The UWSP area consists predominantly of nearly flat agricultural land, much of which is devoted to expansive fields of row crops that are largely devoid of structures, trees, or other above-ground visible features. Numerous unlined irrigation and drainage canals and ditches cross the UWSP area and are generally oriented north-south and east-west along section lines and parcel boundaries. Pole-mounted overhead electrical transmission lines, oriented north-south and east-west, and pockets of mature trees along roads and near residential uses are the primary above-ground visible elements of the UWSP area.

A radio broadcast tower is located in the northern part of the UWSP area, and a television broadcast tower is located in the southwestern portion of the area. 4 - Aesthetics
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Extending in a generally north-south direction along the western edge of the UWSP area, Garden Highway is a two-lane rural road that parallels the Sacramento River.

Generally unobstructed east-facing views of the UWSP area are available for travelers on Garden Highway. Views to the west of Garden Highway are generally dominated by mature trees and dense vegetation that parallel the Sacramento River.

Agricultural and rural residential homes are located within the northeastern portion of the UWSP area near El Centro Road and within the southwestern portion of the area along Garden Highway. Many of the residences are flanked by mature trees, which provide visual screening of the homes from adjacent roadways.

Commercial and service-oriented land uses are located within the UWSP area adjacent to the I-80/West El Camino Avenue interchange and include hotels, fast food and dinein restaurants, a self-storage facility, the 49er Travel Plaza, several commercial buildings, and a large-scale machine shop. The 49er Travel Plaza includes fuel stations, convenience stores, an automotive repair shop, and a car wash. The buildings in this area feature utilitarian and/or minimally decorative architectural styles typical of freeway-oriented commercial and service uses.

Residential uses within the North Natomas community are located to the north and east of the UWSP area, including the Sundance Lake neighborhood north of Fisherman’s Lake Slough, the Gateway West subdivision east of the West Drainage Canal (Witter Canal), and the River View subdivision west of El Centro Road. Similarly, residential uses within the South Natomas community, including the Willow Creek neighborhood, are located to the south of I-80. The Sacramento River and land in agricultural production in Yolo County are located to the west of Garden Highway.

PROJECT AREA VIEWS
Plate AE-1 shows the locations of photographic views of the UWSP area from publicly accessible locations. The photographic views are provided on Plates AE-2 through AE-8.

Views of the UWSP area from adjacent surrounding areas vary widely in terms of how much of the UWSP area is visible from these locations. In general, expansive views of the UWSP area are available from select locations on its immediate perimeter where these views are not obscured by intervening structures (e.g., residences or other buildings), stands of mature trees (often associated with residential uses), elevated freeway segments, sound walls, or other obstructions. For example, expansive views of the UWSP area from the north are available from certain locations along the southern edge of the Sundance Lake neighborhood, from the west from Garden Highway, and from the south from the I-80 bridge over the Sacramento River. By contrast, expansive views of the UWSP area from the east (such as from the Gateway West subdivision) are often substantially obscured by residential uses and stands of mature trees along El Centro Road within the UWSP area or by intervening structures, trees, or landforms along the western edge of the UWSP-adjacent neighborhoods. 5 80
Garden Highway
Arena Boulevard
W. El Camino Avenue
San Juan Road
El Centro Road
Fisherman’s
Lake Slough
Interstate
Interstate
West
Drainage
Canal
Farm Road
Radio Road Bryte Bend Road
Upper Westside Specic Plan EIR
Plate AE-1
Viewpoint Locations
SOURCE: Google Earth Pro, basemap, 2021; ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator 0 3000
Feet N UWSP Boundary
13 12 11
10 9
8 6 7
5 4
3 2
14 1
Upper Westside Specic Plan EIR
Plate AE-2
Viewpoints 1 and 2
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 1: View toward the northeastern portion of the UWSP area from near the intersection of Arena Boulevard and El Centro Road. Radio towers in the northern portion of the UWSP area and residential uses and associated mature trees along Garden Highway on the western edge of the UWSP area are visible in the far distance. View facing southwest.

Viewpoint 2: View toward the northeastern portion of the UWSP area from the Gateway West neighborhood located northeast and east of the UWSP area. The West Drainage Canal is visible in the foreground. Residential uses east of El Centro Road within the UWSP area are visible farther distant. View facing southwest.

Upper Westside Specic Plan EIR
Plate AE-3
Viewpoints 3 and 4
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 3: View toward the UWSP area from the Gateway West neighborhood. Residential uses east of El Centro Road within the UWSP area are visible immediately west of the West Drainage Canal. Pole-mounted overhead utility lines extend southward adjacent to the canal. Residential uses and associated mature trees east and west of El Centro Road within the Gateway West neighborhood are visible farther distant to the south. View facing southwest.

Viewpoint 4: View facing north on El Centro Road immediately south of Radio Road within the northern portion of the UWSP area. Residential uses, mature trees, and pole-mounted overhead utility lines ank the road to the west
and east.

Upper Westside Specic Plan EIR
Plate AE-4
Viewpoints 5 and 6
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 5: View toward the eastern portion of the UWSP area from San Juan Road. The West Drainage Canal is visible in the immediate foreground. Expansive crop-rowed elds are visible in the middle ground. Recreational (golf range), commercial, and service uses northwest of I-80 (within the UWSP area) and residential uses southeast of I-80 (outside and adjacent to the UWSP area) are visible farther distant. View facing south.

Viewpoint 6: View toward the 49er Travel Plaza (restaurant, convenience store, gas station, motel, and other services) at 2828 El Centro Road within the UWSP area. View facing east.

Upper Westside Specic Plan EIR
Plate AE-5
Viewpoints 7 and 8
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 7: View of the UWSP area facing west from the 49er Travel Plaza on El Centro Road within the UWSP area. Pole-mounted overhead utility lines and agricultural elds strewn with hay bales are visible in the middle ground, with residential uses and associated mature trees along Garden Highway further distant.

Viewpoint 8: Views of the UWSP area from the western edges of the Willow Creek neighborhood within the South Natomas community southeast of the UWSP area are almost entirely blocked by the elevated grade of I-80 and the sound wall (pictured above) that extends along the east side of I-80.

Upper Westside Specic Plan EIR
Plate AE-6
Viewpoints 9 and 10
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 9: View toward agricultural residential uses in the southwestern portion of the UWSP area from Garden Highway. View facing northeast.

Viewpoint 10: View toward agricultural residential uses in the southwestern portion of the UWSP area from Garden Highway. View facing northeast.

Upper Westside Specic Plan EIR
Plate AE-7
Viewpoints 11 and 12
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 11: View toward UWSP area from Garden Highway and San Juan Road. View facing east.

Viewpoint 12: View facing south from San Juan Road at Bryte Bend Road within the UWSP area. Agricultural elds

ank the canal that runs south along Bryte Bend Road.

Upper Westside Specic Plan EIR
Plate AE-8
Viewpoints 13 and 14
SOURCE: ESA, 2022
D150587.01 - Upper Westside Specic Plan EIR\05 Graphics-GIS-Modeling-USE AZURE\Illustrator Viewpoint 13: View toward the northwestern portion of the UWSP area from Garden Highway. Radio towers in the northern portion of the UWSP area are visible in the middle ground. The City of Sacramento skyline is visible in the far distance. View facing southeast.

Viewpoint 14: View toward the northern portion of the UWSP area from the Sundance Lake neighborhood located north of the UWSP area.
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With few exceptions, views of the UWSP area from the South Natomas communities to the southeast, such as from the Willow Creek neighborhood, are obscured entirely by the elevated grade of I-80 and/or the associated sound wall that extends along the western edge of these residential areas. In addition, even relatively open views of the UWSP area from surrounding areas and from within the UWSP area are limited by the generally flat topography of the site. However, views of distant features, such as the city of Sacramento skyline (to the southeast), the Sierra Nevada (to the east), and the Coast Ranges (to the west) are available across and from within the UWSP area when weather and air quality permit.

VISUAL RESOURCES
Visual resources are classified in two categories: scenic resources and scenic views.

Scenic resources include specific features of a viewing area (or viewshed) such as trees, rock outcroppings, and historic buildings. Scenic resources are specific features that act as the focal point of a viewshed that tend to draw the eye toward a specific point and are usually foreground elements. The UWSP area is generally characterized as open farmland, with distinct areas of rural residential and commercial development.

Prominent foreground elements or other scenic resources are generally absent.

Scenic views and scenic vistas differ from scenic resources in that they are elements of the broader viewshed such as mountain ranges, valleys, and ridgelines. They are usually background elements that can be seen from a range of viewpoints. Distant views of the Sierra Nevada and the Coast Ranges can be visible under clear conditions from the UWSP area. Also visible is the open farmland that makes up much of the UWSP area. These types of expansive and open views are a feature of the Central Valley and are considered part of the County’s visual heritage.

EXISTING LIGHT AND GLARE CONDITIONS
Nighttime lighting is necessary to provide and maintain safe, secure, and attractive environments. However, these lights have the potential to produce spillover light and glare, and if designed incorrectly, could be considered unattractive. Although nighttime light is a common feature of urban areas, spillover light can adversely affect lightsensitive uses, such as residential units at nighttime.

Glare results when a light source directly in the field of vision is brighter than the eye can comfortably accept. Squinting or turning away from a light source is an indication of glare. The presence of a bright light in an otherwise dark setting may be distracting or annoying, referred to as discomfort glare, or it may diminish the ability to see other objects in the darkened environment, referred to as disability glare. Reflective glare, such as the reflected view of the sun from a window or mirrored surface, can be distracting during the day.

The majority of the UWSP area consists of farm fields that are devoid of nighttime lighting and are dark at night. Rural residential uses in the northeastern and southwestern portions of the UWSP area and associated vehicular traffic on El Centro Road and Garden Highway produce minimal amounts of lighting or illumination. 4 - Aesthetics
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Illuminated signage, parking lot and security lighting, and vehicle headlights associated with commercial and service-oriented uses located within the UWSP area adjacent to the I-80/West El Camino Avenue interchange generate moderate levels of nighttime illumination. Overall, nighttime lighting and illumination levels within the UWSP area are low. Principal sources of nighttime lighting and illumination in the vicinity of the UWSP area include Sacramento International Airport (SMF) and Metro Air Park approximately three miles northwest of the UWSP area, residential and other urban uses within the North Natomas and South Natomas communities adjacent to the UWSP area, and headlights from vehicles traveling on I-80 and other area roadways. There are no major existing sources of glare within the UWSP area or vicinity.

AIRPORTS
The UWSP area is located within the SMF Airport Influence Area, as delineated and defined in the SMF Airport Land Use Compatibility Plan (ALUCP). The SMF ALUCP identifies specific Federal Aviation Administration (FAA) land use restrictions, including height restrictions and restrictions on visual hazards to aircraft, based on defined safety zones around the airport. As specified in the SMF ALUCP, visual hazards to aircraft include certain types of lights, sources of glare, and sources of dust, steam, or smoke (SACOG 2013). The UWSP area is more than one mile away from any delineated safety hazard zones identified in the SMF ALUCP (Wood Rodgers 2021).

REGULATORY SETTING

FEDERAL
There are no federal regulations that pertain to aesthetics or visual resources that are applicable to the proposed UWSP.

STATE

SCENIC HIGHWAY PROGRAM
The California Department of Transportation manages the California Scenic Highway Program. The goal of the program is to preserve and protect scenic highway corridors from changes that would affect the aesthetic value of the land adjacent to the highways.

The closest state-designated scenic highway to the UWSP area is State Route (SR) 160 from the Contra Costa County line to the southern city limit of Sacramento (Caltrans 2022). At the northernmost point, SR 160 is more than 10 miles south of the UWSP area. No other state-designated scenic highways are near the UWSP area.

TITLE 24 OUTDOOR LIGHTING STANDARDS
As published in Section 6 of the California Code of Regulations, Title 24 (also referred to as the California Green Building Standards Code [CALGreen]) is a broad set of requirements for energy conservation, green design, construction and maintenance, fire and life safety, and accessibility that apply to the structural, mechanical, electrical, and 4 - Aesthetics
Upper Westside Specific Plan 4-13 PLNP2018-00284
plumbing systems in a building. The code applies to all buildings in California. California updates its energy code every three years. Construction projects with permit applications applied for on or after January 1, 2023 must follow the 2022 Energy Code.

The 2022 Building Energy Efficiency Standards of Title 24 include regulations for outdoor lighting characteristics, such as maximum power and brightness, shielding, and sensor controls to turn lighting on and off. Different lighting standards are set by classifying areas by lighting zone (LZ), which are zones LZ0 through LZ4 (see Table 10-114-A of the 2022 Building Efficiency Standards).  LZ0: Very Low
 LZ1: Low
 LZ2: Moderate
 LZ3: Moderately High
 LZ4: High
Lighting regulations for areas of lower ambient lighting are stricter – providing lower wattage allowances – in order to protect those areas from new sources of light pollution and light trespass. According to the U.S. Census, the UWSP area is designated as rural.1 Therefore, the UWSP area is located within lighting zone LZ1 (low ambient illumination) 2 as defined in the 2022 Building Energy Efficiency Standards (CEC 2022).

Section 140.7, Prescriptive Requirements for Outdoor Lighting, in the 2022 Building Energy Efficiency Standards specifies wattage allowance per lighting application based on lighting zones (see Table 140.7-B of the 2022 Building Efficiency Standards).

1 The Census Bureau’s urban-rural classification is a delineation of geographic areas, identifying both individual urban areas and the rural area of the nation. The Census Bureau’s urban areas represent densely developed territory, and encompass residential, commercial, and other non-residential urban land uses. The Census Bureau delineates urban areas after each decennial census by applying specified criteria to decennial census and other data. Rural encompasses all population, housing, and territory not included within an urban area. For the 2020 Census, an urban area will comprise a densely settled core of census blocks that meet minimum housing unit density and/or population density requirements. This includes adjacent territory containing non-residential urban land uses. To qualify as an urban area, the territory identified according to criteria must encompass at least 2,000 housing units or have a population of at least 5,000.
2 As specified in Table 10-114-A of the 2022 Building Efficiency Standards, LZ1 includes single or dual family residential areas, parks, and agricultural zone districts, developed portions of government designated parks, recreation areas, and wildlife preserves. Those that are wholly contained within a higher lighting zone may be considered by the local government as part of that lighting zone. 4 - Aesthetics
Upper Westside Specific Plan 4-14 PLNP2018-00284
LOCAL
SACRAMENTO COUNTY 2030 GENERAL PLAN
The following policies from the Land Use Element of the Sacramento County 2030 General Plan (County of Sacramento 2011) are applicable to the proposed UWSP.

LU-16 Apply the “Community Design Guidelines” and design review authority to all long-range planning efforts, including but not limited to Specific Plans, Comprehensive Plans, Community Plans, and Commercial Corridor Plans.

LU-17 Support implementation of the design review program on a project-by-project basis to ensure that all development applications positively contribute to the immediate neighborhood and the surrounding community.

LU-18 Encourage development that complements the aesthetic style and character of existing development nearby to help build a cohesive identity for the area.

LU-19 Incompatible urban land uses should be buffered from one another by methods that retain community character, and do not consume large land areas or create pedestrian barriers.

LU-20 Planning processes for existing communities, commercial corridors, and new growth areas shall provide for distinct and identifying physical elements, which may include gateways, signage, public art, common site or street layout, shared design qualities of buildings or infrastructure, or prominent landmarks or destinations.

LU-31 Strive to achieve a natural nighttime environment and an uncompromised public view of the night sky by reducing light pollution.

In addition to the above policies, the General Plan Conservation Element states its primary goal as “Natural resources managed and protected for the use and enjoyment of present and future generations while maintaining the long-term ecological health and balance of the environment.” The concept of enjoyment includes appreciation of scenic resources and visual beauty.

SACRAMENTO COUNTY ZONING CODE
Chapter 3 (Use Regulations) and Chapter 5 (Development Standards) of the Sacramento County Zoning Code contains standards requiring that illumination of buildings, landscaping, signs, and parking and loading areas be shielded and directed so that no light trespasses onto adjacent properties. Chapter 5 (Development Standards) also requires that lighting shall be directed away from residential areas and public streets so that glare is not produced that could affect the general safety of vehicular traffic and the privacy and well-being of residents. 4 - Aesthetics
Upper Westside Specific Plan 4-15 PLNP2018-00284

IMPACTS AND ANALYSIS

SIGNIFICANCE CRITERIA
For purposes of this EIR and consistent with the criteria presented in Appendix G of the CEQA Guidelines, impacts related to aesthetics may be considered significant if implementation of the proposed UWSP would:
 Have a substantial adverse effect on a scenic vista;
 Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway;  In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings (public views are those that are experienced from publicly accessible vantage point). In an urbanized area, conflict with applicable zoning and other regulations governing scenic quality; or  Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

ISSUES NOT DISCUSSED IN IMPACTS
Substantially damage scenic resources within a state scenic highway – The UWSP area and surrounding environs do not include any designated state scenic highways.

Therefore, no impact would occur, and this issue is not evaluated further in this EIR.

METHODOLOGY AND ASSUMPTIONS
The information and analysis included in this section was developed based on a review of the proposed UWSP, the Sacramento County 2030 General Plan, and a reconnaissance photographic survey of the UWSP area and vicinity. Visual character is defined narrowly to include only analysis of viewsheds, physical site characteristics, and lighting. This analysis does not include a subjective evaluation of design characteristics such as colors, architectural styles, building materials, or other matters of personal preference.

Visual impacts are evaluated by describing the visual changes that would result from approval and implementation of the proposed UWSP and comparing those changes with existing visual character of the UWSP area and vicinity. The analysis assumes that open space and rural areas, such as the UWSP area, are typically of higher visual quality than urban areas, because the open character preserves visual continuity (the blending of visual elements) and a farther horizon of sight. Significance is determined based on consideration of relevant policies of the 2030 General Plan and in light of the 2030 General Plan EIR’s assumption that a substantial visual change is conservatively considered to be a significant impact.
4 - Aesthetics
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IMPACT AE-1: DEGRADATION OF EXISTING VIEWS
As described in Chapter 2, Project Description, the proposed UWSP would guide development on an approximately 2,066-acre site in unincorporated northwestern Sacramento County, which includes mostly agricultural cropland, along with rural residential and commercial uses. The UWSP would provide a mix of residential and non-residential land uses that accommodate 9,356 housing units with a mixture of densities, and over 3 million square feet of commercial, retail, and office uses.

Development of the UWSP area would convert agricultural and rural lands into an urban area consisting of buildings of different heights and densities, open space and recreational corridors, and urban roadway infrastructure.

As also described in Chapter 2, Project Description, and depicted on Plate PD-20, the proposed UWSP would also include a variety of offsite improvements, including road improvements to El Centro Road, Natomas Central Drive, and Arena Boulevard; road improvements to El Centro and San Juan roads; new roadway connections to Garden Highway at Radio Road, San Juan Road, Street 9, and Bryte Bend Road; a potential bike trail bridge crossing of the West Drainage Canal (Witter Canal); stormwater discharge facilities at two potential locations of the West Drainage Canal (Witter Canal); a new sewer force main from the UWSP area east to the New Natomas Pump Station (NNPS); potential improvements to the I-80/West El Camino Avenue interchange; and a new water supply connection to the existing City of Sacramento water distribution system along West River Drive. The proposed offsite improvements would occur within existing rights-of-way (ROWs) and would not include new structures that would substantially alter or obstruct scenic views, such as views of the Sierra Nevada and the Coast Ranges.

Regarding development of the UWSP area, the proposed UWSP includes Development Standards and Design Guidelines to direct the buildout of the 1,532-acre Development Area to ensure high quality design and visual cohesion and consistency. The UWSP Development Standards and Design Guidelines are based on the Countywide Design Guidelines but enable varied development and a distinctive character specific to the UWSP area. Where the UWSP Development Standards and Design Guidelines are silent on a topic, the standard would default to the requirements of the Countywide Design Guidelines. While the proposed UWSP includes adoption of Design Guidelines and Development Standards aimed to ensure high quality design and visual cohesion and consistency, development of the UWSP area would result in the construction of buildings, structures, and landscaping elements that would block distant views of the horizons in all directions from most areas within the UWSP area. While available from certain locations, distant views of the Sierra Nevada and the Coast Ranges that are currently visible under clear conditions from the UWSP area would no longer be available from most areas of the UWSP area with implementation of the proposed UWSP. To sensitive viewer groups, particularly existing residents within and on the periphery of the UWSP area, this blockage of views would be considered a substantial adverse effect on a scenic vista and a significant impact. Aside from implementation of development standards and design guidelines already required for the proposed UWSP, 4 - Aesthetics
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no other feasible mitigation is available to reduce the magnitude of the visual changes that would occur. Therefore, this impact would be significant and unavoidable.

MITIGATION MEASURES
No feasible measures available.

IMPACT AE-2: SUBSTANTIALLY DEGRADE EXISTING VISUAL CHARACTER OR

QUALITY
As discussed above under Impact AE-1, implementation of the proposed UWSP would result in the development of residential, commercial, mixed use, office, school, park, open space, roadways, and other urban uses, as well as creation of an agricultural buffer area on an approximately 2,066-acre site in unincorporated northwestern Sacramento County, which currently comprises mostly agricultural cropland, along with rural residential and commercial uses. The proposed UWSP would also include a variety of offsite improvements as previously described under Impact AE-1. The proposed offsite improvements would occur within existing ROWs (e.g., within existing roadway corridors, facility footprints, and/or underground) and would not include new structures or other physical elements that would substantially degrade existing visual character or quality.

Regarding development of the UWSP area, while the proposed UWSP includes adoption of Design Guidelines and Development Standards aimed to ensure high quality design and visual cohesion and consistency, the change in visual character would be permanent and drastic, regardless of whether or not the new development community would be visually appealing. To sensitive viewer groups, particularly existing residents within and on the periphery of the UWSP area, this could be perceived as a substantial degradation of visual character and quality and a significant impact. Aside from implementation of development standards and design guidelines already required for the proposed UWSP, no other feasible mitigation is available to reduce the magnitude of the visual changes that would occur. As a result, this impact would be significant and unavoidable.

MITIGATION MEASURES
No feasible measures available.

IMPACT AE-3: NEW SOURCES OF LIGHT OR GLARE
Upon full buildout, implementation of the UWSP would result in the urbanization of up to 1,532 acres with up to 9,356 housing units; more than 3 million square feet of commercial, retail, and office uses; as well as schools, parks, and associated roadways and parking lots.

New uses and associated automobiles would introduce new sources of light to an area with relatively few lighting sources. In addition to new sources of light, the urbanization of up to 1,532 acres of sparsely developed land would also introduce new sources of glare from reflective elements such as glass and rooftop photovoltaic (PV) solar panels. 4 - Aesthetics
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As previously discussed, the UWSP area is within a rural area that has minimal lighting and is designated as an LZ1 zone (low ambient illumination) as defined in the 2022 Building Energy Efficiency Standards of California Code of Regulations, Title 24 (CALGreen). Because the UWSP area is in an LZ1 zone, the lighting restrictions are more robust than if the UWSP area were in a more urban environment. Section 140.7, Prescriptive Requirements for Outdoor Lighting, in the 2022 Building Energy Efficiency Standards specifies wattage allowance per lighting application based on lighting zones (see Table 140.7-B of the 2022 Building Efficiency Standards).

The proposed UWSP would also include a variety of offsite improvements as previously described under Impact AE-1. The proposed offsite improvements comprise roadway, utility, and infrastructure improvements within existing ROWs and would not include substantial new sources of adverse light or glare.

Regarding development of the UWSP area, the UWSP includes Development Standards and Design Guidelines based on the Countywide Design Guidelines and Chapter 5 of the Zoning Code, which require that outdoor lighting shall be directed away from adjacent areas to minimize light pollution caused by glare or spillage into neighboring properties, and which meet the objective of General Plan Policy LU-31 to achieve a natural nighttime environment and an uncompromised public view of the night sky by reducing light pollution. The UWSP Development Standards and Design Guidelines also incorporate Title 24 energy efficiency standards for outdoor lighting for both the public and private sector and which regulate lighting characteristics such as maximum power and brightness and shielding,
A new high school that would be located southeast of the intersection of Bryte Bend Road and Radio Road within the UWSP area (see discussion of Schools in Chapter 2, Project Description) would likely include a stadium with pole-mounted outdoor lighting fixtures to illuminate scheduled nighttime athletic events and other activities. Outdoor lighting for the stadium or other new school uses within the UWSP area would be required to comply with Countywide Design Guidelines and Commercial Lot and Commercial and Institutional Project Development Standards in Chapter 5 of the Zoning Code, which direct that lighting fixtures shall be constructed with full shielding and/or recessed to reduce light trespass to adjoining properties.

Regarding light or glare hazards to aircraft operations, as previously discussed, the nearest airport to the UWSP area is SMF, which is approximately three miles northwest of the UWSP area. The UWSP area is more than one mile away from any delineated safety hazard zones identified in the SMF ALUCP, and implementation of the proposed UWSP would not result in creation of light or glare hazards to aircraft operations as defined in the SMF ALUCP. In addition, the County Zoning Code (Section 3.6.6.C) requires that all PV panels be oriented on rooftops or other hardscape areas to avoid unreasonable glare from solar panels onto adjacent properties.

Although spillover lighting, excessive lighting, and glare would be minimized due to the strict lighting standards that would be adopted as part of the project, implementation of the UWSP would introduce a substantial amount of new lighting to an area that is 4 - Aesthetics
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currently rural and contains minimal lighting, thereby adversely affecting nighttime views of the area. Due to the amount of development and lighting proposed, this would be a significant impact.

Implementation of Mitigation Measure AE-3 would ensure that outdoor lighting associated with development allowed under the proposed UWSP is designed in accordance with Section 140.7, Prescriptive Requirements for Outdoor Lighting, in the 2022 Building Energy Efficiency Standards, which specifies wattage allowance per lighting application based on lighting zones (see Table 140.7-B of the 2022 Building Efficiency Standards).

However, because the proposed plan complies with applicable policies and standards aimed at minimizing adverse light and glare, and because of the scale of proposed development, no additional feasible mitigation is available to further reduce this impact.

For this reason, this impact would be significant and unavoidable.

MITIGATION MEASURES
AE-3 The UWSP shall be amended to require all lighting applications subject to 2022 Building Efficiency Standards Section 140.7 to use fixtures approved by DarkSky International.
3 3 DarkSky International, formerly the International Dark Sky Association, is a United States-based non-profit organization incorporated in 1988. The mission of DarkSky is to preserve and protect the nighttime environment through quality outdoor lighting.

Upper Westside Specific Plan 5-1 PLNP2018-00284
5 AGRICULTURAL RESOURCES

INTRODUCTION
This chapter describes existing agricultural resources within the UWSP area and evaluates effects to agricultural resources that could occur with implementation of the proposed UWSP.

The Notice of Preparation (NOP) for the EIR was circulated on October 5, 2020. The County received several comments related to agricultural resources from state and local public agencies as well as the general public. Comments included requests for the EIR to identify and include mitigation for the direct and indirect conversion of agricultural land that would result with implementation of the proposed UWSP; the recommended use of permanent agricultural conservation easements as compensation for the loss of agricultural land; identification of project impacts on any current and future agricultural operations in the project vicinity; identification of potential contract resolutions for land in agricultural preserve and/or enrolled in a Williamson Act contract; requests for reconsideration of the designation for the area along the Garden Highway to be open space with agriculture as an allowable use; concern regarding the potential loss of agricultural land on the ability for the Natomas Basin Habitat Conservation Plan requirements to be met; and a request that the interface between the planned urban uses and existing and ongoing natural uses be assessed for any setback required by the state and the Sacramento County agricultural commissioner between the UWSP area and sensitive uses, including residences and schools.

The information and analysis included in this chapter was developed based on a review of applicable information and documents, including the proposed UWSP; the Sacramento County 2030 General Plan; information and geospatial data related to agricultural resources available from the U.S. Department of Agriculture (USDA), the Natural Resources Conservation Service (NRCS), and Sacramento County; and other relevant sources.

ENVIRONMENTAL SETTING

SACRAMENTO COUNTY AGRICULTURAL VALUE
In 2022, Sacramento County ranked 21 in gross value of agricultural production among all California Counties with a gross valuation of approximately $603 million. In 2022, wine grapes had the highest crop value ($189 million) followed by milk ($91 million), pears ($56 million), poultry ($33 million), aquaculture ($33 million), and corn silage 5 - Agricultural Resources
Upper Westside Specific Plan 5-2 PLNP2018-00284
($24 million). In total, 128,596 acres of field crops1 were harvested in the County in 2022 (Sacramento County Agricultural Commission 2022).

FARMLAND CLASSIFICATION
The State of California maps and classifies farmland through the California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP). Classifications are based on a combination of physical and chemical characteristics of the soil and climate that determines the degree of suitability of the land for crop production. The minimum land use mapping unit is 10 acres unless specified (California Department of Conservation 2024a). The classifications under the FMMP are as follows:
 Prime Farmland: Farmland with the best combination of physical and chemical features able to sustain long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
 Farmland of Statewide Importance: Farmland similar to Prime Farmland but with minor shortcomings, such as greater slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
 Unique Farmland: Farmland of lesser quality soils used for the production of the state's leading agricultural crops. This land is usually irrigated but may include non-irrigated orchards or vineyards as found in some climatic zones in California.

Land must have been cropped at some time during the four years prior to the mapping date.
 Farmland of Local Importance: Land of importance to the local agricultural economy.
 Grazing Land: Land on which the existing vegetation is suited to the grazing of livestock.
 Urban and Built-Up Land: Land occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10-acre parcel.

This land is used for residential, industrial, commercial, construction, institutional, public administration, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes.
 Other Land: Land not included in any other mapping category. Common examples include low density rural developments; brush, timber, wetland, and riparian areas not suitable for livestock grazing; confined livestock, poultry, or aquaculture facilities; strip mines, borrow pits; and water bodies smaller than

1 Field crops only include corn, hay, oats, rice, ryegrass, safflower, sudangrass, triticale, wheat, barley, dry beans, hops, etc.
5 - Agricultural Resources
Upper Westside Specific Plan 5-3 PLNP2018-00284
forty acres. Vacant and nonagricultural land surrounded on all sides by urban development and greater than 40 acres is mapped as Other Land.

In 2010, Sacramento County had 97,477 acres of Prime Farmland, 45,263 acres of Farmland of Statewide Importance, 15,076 acres of Unique Farmland, 53,929 acres of Farmland of Local Importance, and 155,824 acres of Grazing Land. By 2020, each of those categories had decreased, excluding Unique Farmland and Farmland of Local Importance. Table AG-1 shows the change over time in acreage of farmland from 2010 to 2020 (California Department of Conservation 2024b).

Table AG-1: Farmland in Sacramento County
Land Use
Category
Acreage by Category 2010-2020 Net
Change
2010-
2020
(acres)
Percent
Change
2010-
2010 2012 2014 2016 2018 2020 2020
Prime Farmland 97,477 93,916 91,568 90,691 86,963 84,684 -12,793 -13.1% Farmland of
Statewide
Importance
45,263 43,580 43,105 43,342 44,003 43,825 -1,438 -3.2%
Unique Farmland 15,076 15,060 15,125 15,540 15,579 15,642 566 3.8% Farmland of Local
Importance 53,929 56,981 58,852 57,910 55,049 56,275 2,346 4.4% Important
Farmland
Subtotal
211,745 209,537 208,650 207,483 201,594 200,426 -11,319 -5.3% Grazing Land 155,824 154,744 153,452 153,174 149,987 147,789 -8,035 -5.2% Agricultural Land
Subtotal 367,569 364,281 362,102 360,657 351,581 348,215 -19,354 -5.3% Urban and Built-Up
Land 178,784 180,246 181,296 182,237 183,975 185,537 6,753 3.8% Other Land 71,585 73,401 74,558 75,069 83,619 85,437 13,852 19.4% Water Area 18,147 18,148 18,120 18,116 16,910 16,896 -1,251 -6.9% Total Area
Inventoried 636,085 636,076 636,076 636,079 636,085 636,085 0 0.0% SOURCE: California Department of Conservation 2024b. Historic Land Use Conversion. Available:
https://www.conservation.ca.gov/dlrp/fmmp/Pages/Index.aspx. Accessed June 13, 2024.

As shown on Plate AG-1, the UWSP area currently contains approximately 1,805 acres of Important Farmland. This includes approximately 1,207 acres of Prime Farmland, 593 acres of Farmland of Local Importance, three acres of Farmland of Statewide Importance, and two acres of Unique Farmland (California Department of Conservation 2023a).

Path: U:\GIS\GIS\Projects\15xxxx\D150587_NatomasNorthSP\03_MXDs_Projects\UpperWestSide_EIR.aprx Plate AG-1_ImportantFarmland, EPimentel 6/21/2024 SOURCE: MAXAR 2022; FMMP, 2020; ESA, 2024 Upper Westside Specific Plan EIR Plate A*-
Important Farmland
Radio Road
Farm Road
Bryte Bend Road
El Centro Road
Garden Highway
W El Camino Avenue
San Juan Road
Arena Boulevard
West Drainage Canal
Fisherman's
Lake Slough
5 80
Yolo County, Maxar
N
0 2,000
Feet
Project Area
,PSoUWDnW)DUPODnG
)armland oI /ocal ,mSortance

5 254 ac

Prime )armland
120 ac

)armland oI 6tatewide ,mSortance

2 ac

8niTue )armland
211 ac

2WKHU/DnG8VHV
8rEan and %uilt-8S /and
1024 ac

2ther /and
1555 ac

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Upper Westside Specific Plan 5-5 PLNP2018-00284
Other land uses defined by the FMMP within the UWSP area include approximately 107 acres of Urban and Built-Up Land and about 154 acres of Other Land. Important Farmland within the UWSP area comprises less than one percent of the total Important Farmland within Sacramento County.

EXISTING AND ADJACENT LAND USES
The UWSP area is nearly flat and consists primarily of agricultural land. Elevation within the UWSP area ranges from approximately 12 feet above mean sea level (msl) along the eastern border of the area to approximately 27 feet above msl along the western border of the area. The UWSP area predominantly consists of graded agricultural land, including row crops and dry farming. Several large agricultural residences are located along the southwestern border and northeastern corner of the UWSP area. Numerous unlined drainage canals and ditches cross the agricultural portions of the UWSP area and are generally oriented north-south and east-west along section lines and parcel boundaries to provide irrigation water and drainage.

Residential uses within the North Natomas community are located to the north of Fisherman’s Lake Slough and, except for the River View Subdivision, which is located on both sides of El Centro Road to north of San Juan Road, to the east of the West Drainage Canal (Witter Canal). Similarly, residential uses within the South Natomas community are located to the south of I-80. Residential uses within the Garden Highway Special Planning Area and the Sacramento River are located to the west of Garden Highway. Commercial land uses are located adjacent to the I-80/West El Camino interchange and include a truck stop, gas stations, restaurants, hotels, self-storage, construction equipment sales, and offices.

EXISTING LAND USE DESIGNATIONS AND ZONING
Current Sacramento County 2030 General Plan land use designations for the UWSP area include Agricultural Cropland (1,858.3 acres), Agricultural Residential (97.0 acres), Recreation (58.8 acres), and Commercial and Offices (52.2 acres).

Current Zoning designations for the UWSP area include Agricultural 20 (148.6 acres), Agricultural 40 (1,737.1 acres), AG-Residential 1 (16.7 acres), AG-Residential 2 (108.3 acres), AG-Residential 5 (6.0 acres), General Commercial (17.8 acres), and Highway Travel Commercial (31.8 acres).

EXISTING AGRICULTURAL OPERATIONS
As described in the Land Use Element of the Sacramento County 2030 General Plan, agricultural cropland has at least some of the following attributes: deep to moderately deep soils, abundant to ample water supply, distinguishable geographic boundaries, absence of incompatible residential uses, absence of topographical constraints, good to excellent crop yields, and large to moderate sized farm units. The Land Use Element identifies that these attributes indicate the need for ambitious preservation policies and techniques.
5 - Agricultural Resources
Upper Westside Specific Plan 5-6 PLNP2018-00284
As noted above, the UWSP area predominantly consists of graded agricultural land, including row crops and dry farming. There are a total of five farms within the UWSP area covering approximately 1,200 acres, three of which farm most of the land (about 1,170 acres). The primary crops under cultivation within the UWSP area include wheat, safflower, corn, tomatoes, and strawberries, with strawberries comprising the smallest portion of these crops. Bell peppers, cabbage, melons, and blueberries are also grown in small portions of the UWSP area and in substantially less volume compared to the main crops noted above. In addition, some farmers within the UWSP area farm their own land, albeit on a smaller scale than the larger operations described above. In addition, there are small storefront booths within the UWSP area (on El Centro Road between San Juan Road and Farm Road) where vendors sell produce directly to customers.

As is the case for anywhere commercial agriculture occurs, crop values in the UWSP area can change year to year and can even modulate during a given season due to numerous factors, including market demand and conditions for a specific crop, weather factors, and labor and transportation costs. Notwithstanding these variables, tomatoes are currently most likely to produce the highest gross receipt per acre in the UWSP area, with wheat currently most likely to produce the lowest gross receipt per acre within the UWSP area.

WILLIAMSON ACT PARCELS
The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space uses.

When the County enters into a contract with the landowners under the Williamson Act, the landowner agrees to limit the use of the land to agriculture and compatible uses for a period of at least ten years and the County agrees to tax the land at a rate based on the agricultural production of the land, rather than its real estate market value. The County has designated areas as agricultural preserves within which the County will enter into contracts for the preservation of the land in agriculture.

As of 2023, there are approximately 1,933 total parcels under Williamson Act contracts in Sacramento County (Sacramento County 2023). Plate AG-2 shows parcels under Williamson Act contracts within and adjacent to the UWSP area. The UWSP area includes one parcel (APN 225-0190-024) under a Williamson Act contract (California Department of Conservation 2023b). As shown on Plate AG-2, this parcel is located in the northwestern portion of the UWSP area between Radio Road and San Juan Road.

Per the Sacramento County Assessor Parcel Viewer, this parcel comprises approximately 30.42 acres (Sacramento County 2024).

Path: U:\GIS\GIS\Projects\15xxxx\D150587_NatomasNorthSP\03_MXDs_Projects\UpperWestSide_EIR.aprx Plate AG-2_WilliamsonActLand, EPimentel 6/21/2024 SOURCE: MAXAR 2022; FMMP, 2023; ESA, 2024 Upper Westside Specific Plan EIR Plate A*-2
Williamson Act Land
Radio Road
Farm Road
Bryte Bend Road
El Centro Road
Garden Highway
W El Camino Avenue
San Juan Road
Arena Boulevard
West Drainage Canal
Fisherman's
Lake Slough
5 80
Yolo County, Maxar
N
0 2,000
Feet
Project Area
:iOOiDPVon$FW/DnG
Prime Agriculture /and
1onSrime Agriculture /and
5 - Agricultural Resources
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NATURAL RESOURCES CONSERVATION SOIL SURVEY
The USDA provides the NRCS Soil Survey, which contains a wide range of information on the soils of an area. Soils are classified by type and how they can be used for agricultural uses.

STORIE INDEX
The Storie Index is a semi-quantitative method of rating soils used mainly for irrigated agriculture based on crop productivity data collected from major California soils in the 1920s and 1930s. The Storie Index assesses the productivity of a soil from the following characteristics: the degree of soil profile development, surface texture, slope, and other conditions. A score ranging from 1 to 100 percent is determined for each factor, and the scores are then multiplied together to generate an index rating. Since 2005, the NRCS has published Storie Index ratings generated from the University of California revised Storie Index method (O’Geen et al. 2008). Soils are classified by the revised Storie Index numerical ratings into six classes as follows:
 Grade 1: Excellent (81 to 100)
 Grade 2: Good (61 to 80)
 Grade 3: Fair (41 to 60)
 Grade 4: Poor (21 to 40)
 Grade 5: Very poor (11 to 20)
 Grade 6: Nonagricultural (10 or less)

LAND CAPABILITY
Land capability classification shows, in a general way, the suitability of soils for most kinds of field crops. The soils are grouped according to their limitations for field crops, the risk of damage if they are used for crops, and the way they respond to management. The criteria used in grouping the soils does not include major and generally expensive land forming that would change slope, depth, or other characteristics of the soils, nor do they include possible but unlikely major reclamation projects. Capability classification is not a substitute for interpretations that show suitability and limitations of groups of soils for rangeland, for woodland, or for engineering purposes.

In the capability system, soils are generally grouped at three levels: capability class, subclass, and unit. Capability classes, the broadest groups, are designated by the numbers 1 through 8. The numbers indicate progressively greater limitations and narrower choices for practical use. The classes are defined as follows:
 Class 1 soils have few limitations that restrict their use.  Class 2 soils have moderate limitations that reduce the choice of plants or that require moderate conservation practices.
 Class 3 soils have severe limitations that reduce the choice of plants or that require special conservation practices, or both.
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 Class 4 soils have very severe limitations that reduce the choice of plants or that require very careful management, or both.
 Class 5 soils are subject to little or no erosion but have other limitations, impractical to remove, that restrict their use mainly to pasture, rangeland, forestland, or wildlife habitat.
 Class 6 soils have severe limitations that make them generally unsuitable for cultivation and that restrict their use mainly to pasture, rangeland, forestland, or wildlife habitat.
 Class 7 soils have very severe limitations that make them unsuitable for cultivation and that restrict their use mainly to grazing, forestland, or wildlife habitat.
 Class 8 soils and miscellaneous areas have limitations that preclude commercial plant production and that restrict their use to recreational purposes, wildlife habitat, watershed, or esthetic purposes.

Plate AG-3 shows the types and locations of soils within the UWSP area. Table AG-2 provides the descriptions, ratings, and acreages of the soils within the UWSP area.

REGULATORY SETTING

FEDERAL
No federal plans, policies, regulations, or laws related to agricultural resources are applicable to the proposed UWSP.

STATE

CALIFORNIA DEPARTMENT OF CONSERVATION FARMLAND MAPPING AND

MONITORING PROGRAM
The California Department of Conservation’s FMMP was established in 1984 to document the location, quality, and quantity of agricultural lands and conversion of those lands over time. The program provides impartial analysis of agricultural land use changes throughout California. The FMMP is tasked with mapping and monitoring important farmlands for most of the state’s agricultural areas. The maps are prepared based on soil survey information and land inventory and monitoring criteria developed by the USDA NRCS. The FMMP prepares and maintains an automated map and database system to record and report changes in the use of agricultural lands every two years on even numbered calendar years. As of the publication of this Draft EIR, the most recent Sacramento County Important Farmland Map is for 2020 and was published in July 2023 (California Department of Conservation 2023).

Path: U:\GIS\GIS\Projects\15xxxx\D150587_NatomasNorthSP\03_MXDs_Projects\UpperWestSide_EIR.aprx Plate AG-3_Soils, EPimentel 6/21/2024 SOURCE: MAXAR 2022; SSURGO, 2024; ESA, 2024 Upper Westside Specific Plan EIR Plate A*-
Soils
Radio Road
Farm Road
Bryte Bend Road
El Centro Road
Garden Highway
W El Camino Avenue
San Juan Road
Arena Boulevard
West Drainage Canal
Fisherman's
Lake Slough
5 80
11
11 141
20
128
221
12
1
20
24
115
Yolo County, Maxar
N
0 2,000
Feet
Project Area
6oiO7\SHV
Clear /aNe clay hardSan suEstratum
drained 0 to 1 Sercent sloSes
ColumEia sandy loam clayey
suEstratum Sartially drained 0 to 2
Sercent sloSes
Cosumnes silt loam drained 0 to 2
Sercent sloSes
Cosumnes silt loam Sartially
drained 0 to 2 Sercent sloSes
'uri[eralIs 0 to 1 Sercent sloSes
(gEert clay Sartially drained 0 to 2
Sercent sloSes
-acNtone clay drained 0 to 2
Sercent sloSes
6ailEoat silt loam Sartially drained
0 to 2 Sercent sloSes 0/RA 1
6an -oaTuin-;erarents comSle[
leveled 0 to 1 Sercent sloSes
:ater
115
11 128
12
1
141
11
221
20
24
5 - Agricultural Resources
Upper Westside Specific Plan 5-11 PLNP2018-00284
Table AG-2: Agricultural Soil Evaluation
Map
Unit Soil Type
Storie
Index
Rating
Land
Class
Capability
Rating
Farmland
Classification
Acres
in
Plan
Area
Percent
of Plan
Area
115
Clear Lake clay,
hardpan substratum,
drained, 0 to 1
percent slopes
Grade 5 Class 3 Prime farmland if
irrigated 307.8 14.9%
119
Columbia sandy
loam, clayey
substratum, partially
drained, 0 to 2
percent slopes
Grade 4 Class 3 Prime farmland if
irrigated 40.2 1.9%
127
Cosumnes silt loam,
partially drained, 0
to 2 percent slopes
Grade 4 Class 3 Prime farmland if
irrigated 1,401.4 67.8%
128
Cosumnes silt loam,
drained, 0 to 2
percent slopes
Grade 2 Class 3 Prime farmland if
irrigated 71.1 3.4%
137 Durixeralfs, 0 to 1
percent slopes Grade 5 Class 4 Not prime farmland 13.3 0.6% 141
Egbert clay, partially
drained, 0 to 2
percent slopes
Grade 5 Class 3 Prime farmland if
irrigated 7.3 0.4%
161
Jacktone clay,
drained, 0 to 2
percent slopes
Grade 6 Class 3
Farmland of
statewide
importance

17.2 0.8%
206
Sailboat silt loam,
partially drained, 0
to 2 percent slopes,
MLRA 16
Grade 2 Class 3 Prime farmland if
irrigated 200.0 9.7%
221
San JoaquinXerarents complex,
leveled, 0 to 1
percent slopes
NA Class 3
Farmland of
statewide
importance

7.3 0.4%
247 Water NA NA NA 0.2 0.0%
SOURCE: NRCS 2024.
5 - Agricultural Resources
Upper Westside Specific Plan 5-12 PLNP2018-00284
CALIFORNIA LAND CONSERVATION ACT OF 1965
The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space uses.

When the County enters into a contract with the landowners under the Williamson Act, the landowner agrees to limit the use of the land to agriculture and compatible uses for a period of at least ten years and the County agrees to tax the land at a rate based on the agricultural production of the land, rather than its real estate market value. The County has designated areas as agricultural preserves within which the County will enter into contracts for the preservation of the land in agriculture.

CALIFORNIA PUBLIC RESOURCES CODE
California Public Resources Code Section 21060.1 defines “agricultural land” as prime farmland, farmland of statewide importance, or unique farmland, as defined by the USDA land inventory and monitoring criteria, as modified for California.

CALIFORNIA CODE OF REGULATIONS
California Code of Regulations sections 6690-6692 govern the use of pesticides near school sites. This regulation restricts specific pesticide applications Monday through Friday between 6 a.m. and 6 p.m. based on type of application, distance from a school or daycare, and requires agricultural operators to notify schools, if their agricultural operation is within a quarter mile from the school boundary, of all pesticides to be used during the school year.

CORTESE-KNOX-HERTZBERG LOCAL GOVERNMENT REORGANIZATION ACT Section 56064 of the Cortese-Knox-Hertzberg Local Government Reorganization Act defines “prime agricultural land” as an area of land, whether a single parcel or contiguous parcels, that has not been developed for a use other than an agricultural use and that meets any of the following qualifications:
a) Land that qualifies, if irrigated, for rating as class I or class II in the USDA NRCS land use capability classification, whether or not land is actually irrigated, provided that irrigation is feasible.
b) Land that qualifies for rating 80 through 100 Storie Index Rating. c) Land that supports livestock used for the production of food and fiber and that has an annual carrying capacity equivalent to at least one animal unit per acre as defined by the USDA in the National Range and Pasture Handbook, Revision 1, December 2003.
d) Land planted with fruit or nut-bearing trees, vines, bushes, or crops that have a nonbearing period of less than five years and that will return during the commercial bearing period on an annual basis from the production of unprocessed agricultural plant production not less than four hundred dollars ($400) per acre.
5 - Agricultural Resources
Upper Westside Specific Plan 5-13 PLNP2018-00284
e) Land that has returned from the production of unprocessed agricultural plant products an annual gross value of not less than four hundred dollars ($400) per acre for three of the previous five calendar years.

LOCAL
SACRAMENTO COUNTY 2030 GENERAL PLAN
The following policies from the Land Use, Agricultural, and Conservation elements of the Sacramento County 2030 General Plan are applicable to the proposed UWSP.

Please note that select policies below have been updated to reflect proposed General Plan Text Amendments requested by the project applicant (see Appendix PD-1).

Changes to the text of the policies are shown by either strikethrough where text has been deleted, or double underline where new text has been inserted.

LAND USE
LU-2 The County shall maintain an Urban Services Boundary (USB) that defines the long-range plans (beyond twenty-five years) for urbanization and extension of public infrastructure and services and defines important areas for protecting as open space and agriculture.

AGRICULTURAL
AG-1 The County shall protect prime, statewide importance, unique, and local importance farmlands located outside of the USB from urban encroachment consistent with General Plan policies authorizing amendment of the Land Use Diagram in the interest of the public health, safety, and welfare of the residents of Sacramento County (see LU-114, LU-119 – LU-128).

AG-2 The County shall not accept applications for General Plan amendments outside the USB redesignating prime, statewide importance, unique and local importance farmlands or lands with intensive agricultural investments to agricultural/residential or urban use (i.e., residential, commercial, industrial) unless the applicant demonstrates that the request is consistent with the General Plan Agriculture-Residential expansion policies (please refer to Land Use Element Policies regarding Agriculture-Residential uses).

AG-3 The County shall permit agricultural uses on buffers, provided such uses are conducted in a manner compatible with urban uses. Buffers shall be used to separate farming practices incompatible with adjacent urban uses. Any homeowners' association or similar entity within the development shall assist in determining compatible use. Buffers shall not adversely conflict with agricultural uses on adjoining property.

AG-4 Prospective buyers of property adjacent to agricultural land shall be notified through the title report that they could be subject to inconvenience or discomfort resulting from accepted farming activities as per provisions of the County’s right-to-farm ordinance.
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AG-5 Projects resulting in the conversion of more than fifty (50) acres of farmland shall be mitigated within Sacramento County, except as specified in the paragraph below, based on a 1:1 ratio, for the loss of the following farmland categories through the specific planning process or individual project entitlement requests to provide in-kind or similar resource value protection (such as easements for agricultural purposes):
 prime, statewide importance, unique, local importance, and grazing farmlands located outside the USB; and
 prime, statewide importance, unique, and local importance farmlands located inside the USB.

The Board of Supervisors retains the authority to override set aside the inCounty mitigation requirement for impacts to Unique, Local, and Grazing farmlands, but not with respect to Prime and Statewide farmlands.

However, if that land is also required to provide mitigation for impacts to special-status species pursuant to a Sacramento County endorsed or approved Habitat Conservation Plan (HCP), then the Board of Supervisors may consider on a case by case basis the mitigation land provided required to mitigate for impacts to special-status species in accordance with the HCP as meeting the requirements of this section, including land outside of Sacramento County.

Note: This policy is not tied to any maps contained in the Agricultural Element. Instead, the most current Important Farmland map from the Department of Conservation should be used to calculate mitigation.

AG-6 If a property owner is required to mitigate for the loss of farmland under Policy AG-5, and the approved master plan or community plan includes land permanently set aside for an urban farm, a 1:1 farmland credit will be given to projects that incorporate urban farming within the project that permanently preserves farmland. Urban farms may qualify for credit for the proposed master plan or community plan and will be considered as part of the master plan or community plan process subject to the following criteria:
 The required minimum urban farm size to qualify for the credit shall be at least 5 acres;
 Only land that is fully available for farming shall count towards the credit.

Ancillary facilities such as education buildings, farmer’s markets, and parking areas shall not be included in the acreage calculation;  Community gardens shall not count toward the credit;
 The zoning shall be a permanent agricultural zone, or similar zone, that ensures the permanency of the agricultural use;
 An appropriate source of water shall be identified and provided; 5 - Agricultural Resources
Upper Westside Specific Plan 5-15 PLNP2018-00284
 A permanent agricultural easement shall be recorded over the site. The agricultural easement shall be dedicated to the County of Sacramento or an organization approved by the County to preserve the farmland; and  If there is a separate farm management entity, a recorded farming management agreement shall be required between the landowner and the farm manager.

Any reversion to a non-farming use on an urban farm site that received farmland credit shall trigger farmland mitigation regardless of the size. The mitigation shall be equivalent to the mitigation required at the time of the original project approval. In addition, the mitigation shall be based on the farmland category at the time of original project approval; however, in the event the farmland category has been upgraded to a higher category as shown on the latest Important Farmland Map from the Department of Conservation, that farmland category shall be used as the basis in determining equivalent mitigation.

CONSERVATION
CO-51 Direct development away from prime or statewide importance farmlands or otherwise provide for mitigation as required by AG-5 slowing the loss of additional farmland conversion to other uses.

SACRAMENTO COUNTY LOCAL AGENCY FORMATION COMMISSION
Local agency formation commissions (LAFCos) are state-mandated quasi-judicial countywide commissions whose purview is to oversee boundary changes of cities and special districts, the formation of new agencies, including the incorporation of new cities and districts, and the consolidation or reorganization of special districts and/or cities.

The proposed UWSP would be subject to the standards related to agricultural resources from Sacramento County LAFCo’s Policies, Standards, and Procedures Manual (1990) as amended in April 2024. LAFCo may make exceptions to these general and specific standards if it determines that such exceptions are necessary because of unique circumstances, are required to resolve conflicts between general and specific standards, result in improved quality or lower cost of services available, or there exists no feasible or logical alternative.

CHAPTER IV, SELECTED GENERAL STANDARDS, STANDARD E. AGRICULTURAL LAND

CONSERVATION
LAFCo will exercise its powers to conserve agricultural land pursuant to the following standards:
 Standard E.1. LAFCo will approve a change of organization or reorganization which will result in the conversion of prime agricultural land in open space use to other uses only if the Commission finds that the proposal will lead to the planned, orderly, and efficient development of an area. For purposes of this standard, a proposal leads to the planned, orderly, and efficient development of an area only if all of the following criteria are met:
5 - Agricultural Resources
Upper Westside Specific Plan 5-16 PLNP2018-00284
a. The land subject to the change of organization or reorganization is contiguous to either lands developed with an urban use or lands which have received all discretionary approvals for urban development.
b. The proposed development of the subject lands is consistent with the Spheres of Influence Plan, including the Master Services Element of the affected agency or agencies.
c. Development of all, or a substantial portion of, the subject land is likely to occur within five years. In the case of very large developments, annexation should be phased whenever feasible. If the Commission finds phasing infeasible for the specific reasons, it may approve annexation if all or a substantial portion of the subject land is likely to develop within a reasonable period of time.
d. Insufficient vacant non-prime lands exists within the applicable Spheres of Influence that are planned, accessible, and developable for the same general type of use.
e. The proposal will have no significant adverse effect on the physical and economic integrity of other agricultural lands. In making this determination, LAFCo will consider the following factors:
(1) The agricultural significance of the subject and adjacent areas relative to other agricultural lands in the region.
(2) The use of the subject and adjacent areas.
(3) Whether public facilities related to the proposal would be sized or situated so as to facilitate the conversion of adjacent to nearby agricultural land, or will be extended through or adjacent to, any other agricultural lands which lie between the project site and existing facilities.
(4) Whether natural or man-made barriers serve to buffer adjacent or nearby agricultural lands from the effects of the proposed development. (5) Applicable provisions of the General Plan open space and land use elements, applicable growth management policies, or other statutory provisions designed to protect agriculture.

IMPACTS AND ANALYSIS

SIGNIFICANCE CRITERIA
For purposes of this EIR and consistent with the criteria presented in Appendix G of the CEQA Guidelines, impacts on agricultural resources may be considered significant if implementation of the proposed UWSP would:
 Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the 5 - Agricultural Resources
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Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use;
 Conflict with existing zoning for agricultural use or a Williamson Act contract;  Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g));
 Result in the loss of forest land or conversion of forest land to non-forest use;  Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use.

California Public Resources Code Section 21060.1(a) defines “agricultural land” as prime farmland, farmland of statewide importance or unique farmland, as defined by the USDA land inventory and monitoring criteria, as modified for California. In addition, Sacramento County 2030 General Plan Policy AG-5 specifies that projects resulting in the conversion of more than 50 acres of farmland shall be mitigated within Sacramento County, except as specified by the policy, based on a 1:1 ratio, for the loss of the following farmland categories through the specific planning process or individual project entitlement requests to provide in-kind or similar resource value protection (such as easements for agricultural purposes):
 prime, statewide importance, unique, local importance, and grazing farmlands located outside the USB; and
 prime, statewide importance, unique, and local importance farmlands located inside the USB.

Accordingly, the analysis in this chapter defines “Farmland” as Prime Farmland, Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance as defined by the California Department of Conservation. As shown on Plate AG-1, there is no Grazing Land within the UWSP area.

ISSUES NOT DISCUSSED IN IMPACTS
Conflict with existing zoning for forest land or timberland or result in the loss of forest land or conversion of forest land to non-forest use – There are no forested areas or timberlands in the UWSP area; none of the parcels within the area are zoned for timberland production. Tree resources within the UWSP area are limited to scattered trees, most of which are associated with existing homes and outbuildings. For these reasons, no impact would occur, and these issues are not evaluated further in the EIR.

METHODOLOGY AND ASSUMPTIONS
The evaluation of potential impacts related to agricultural resources was based on a review of applicable information and documents, including the proposed UWSP; the 5 - Agricultural Resources
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Sacramento County 2030 General Plan; information and geospatial data related to agricultural resources available from the USDA, the NRC, and Sacramento County; and other state regulations as presented above.

SACRAMENTO COUNTY LAFCO CRITERIA
The proposed UWSP would be subject to standards related to agricultural resources contained in the Sacramento County LAFCo Policies, Standards, and Procedures Manual (1990) as amended in April 2024. As specified in Standard E.1 in Chapter IV, Selected General Standards, Standard E. Agricultural Land Conservation, LAFCo will approve a change of organization or reorganization which will result in the conversion of prime agricultural land in open space use to other uses only if LAFCo finds that the proposal will lead to the planned, orderly, and efficient development of an area. For purposes of this standard, a proposal leads to the planned, orderly, and efficient development of an area only if specified criteria are met, including a determination that the proposal will have no significant adverse effect on the physical and economic integrity of other agricultural lands. In making this determination, LAFCo considers the factors provided in Standard E.1. An evaluation of the proposed UWSP with respect to these factors is provided below.
 Factor 1. The agricultural significance of the subject and adjacent areas relative to other agricultural lands in the region.
 Analysis: The value of agricultural production within the UWSP area is proportional to the production value of all agricultural land in Sacramento County. As previously noted, Important Farmland within the UWSP area (approximately 1,805 acres) comprises less than one percent of the total Important Farmland within Sacramento County (200,426 acres). Prime Farmland within the UWSP area (about 1,207 acres) comprises 1.4 percent of the total Prime Farmland within Sacramento County (84,684 acres). As discussed under Impact AG-1 below, implementation of the proposed UWSP would result in the conversion of approximately 1,372 acres of Important Farmland to nonagricultural uses, which would comprise less than one percent of the total Important Farmland within Sacramento County. Impacts related to the conversion of farmland to nonagricultural uses that would result from implementation of the UWSP are evaluated under Impact AG-1 below.  Factor 2. The use of the subject and adjacent areas.
 Analysis: As described above, most of the UWSP area is in current agricultural use. Surrounding uses within the County include residential and urban uses to the north, east, and south, as well as additional agricultural to the north and east. Surrounding uses outside the County include agricultural uses across the Sacramento River to the west in Yolo County.  Factor 3. Whether public facilities related to the proposal would be sized or situated so as to facilitate the conversion of adjacent to nearby agricultural land, 5 - Agricultural Resources
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or will be extended through or adjacent to, any other agricultural lands which lie between the UWSP area and existing facilities.
 Analysis: If approved, the proposed UWSP would include the extension of utilities to serve the UWSP area only. The capacity of proposed utilities would not be sized to facilitate the extension of services into unplanned growth areas. Further discussion of the growth-inducing effects of the proposed UWSP are addressed in Chapter 23, Growth Inducement and Urban Decay.  Factor 4. Whether natural or man-made barriers serve to buffer adjacent or nearby agricultural lands from the effects of the proposed development.  Analysis: As part of the proposed UWSP, a 534-acre agricultural buffer is proposed to the west of the Development Area, which is intended to allow for the continuation of existing agricultural, ag-residential, and mitigation uses. To buffer proposed residential uses near the western edge of the Development Area from continued agricultural activity within the agricultural buffer, an open space buffer corridor is proposed along the western edge of the Development Area. The corridor would vary in width from 30 to 50 feet and include a hedgerow of tree plantings adjacent to planned residential uses and a farm fence adjacent to existing agricultural/ag-residential uses.  Factor 5. Applicable provisions of the General Plan open space and land use elements, applicable growth management policies, or other statutory provisions designed to protect agriculture.
 Analysis: General Plan Policy LU-2 states that the County shall maintain a USB that defines the long-range plans (beyond twenty-five years) for urbanization and extension of public infrastructure and services and defines important areas for protecting as open space and agriculture. In addition, General Plan Policy AG-1 states that the County shall protect prime, statewide importance, unique, and local importance farmlands located outside of the USB from urban encroachment while General Plan Policy AG-2 states that the County shall not accept applications for General Plan amendments outside the USB redesignating prime, statewide importance, unique and local importance farmlands, or lands with intensive agricultural investments to agricultural / residential or urban use (i.e., residential, commercial, industrial) unless the applicant demonstrates that the request is consistent with the General Plan Agriculture-Residential expansion policies.

As discussed in Chapter 14, Land Use, of this Draft EIR, the proposed UWSP establishes a development framework for land use, community design and character, infrastructure improvements, and orderly development that is consistent with the objectives and policies in the Sacramento County 2030 General Plan that guide expansion of the Urban Policy Area (UPA) and USB. In addition, General Plan Policy AG-5 requires applicants to mitigate agricultural land conversion. The proposed project’s compliance with Policy AG-5 is discussed under Impact AG-1 below.
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IMPACT AG-1: CONVERSION OF FARMLAND TO NONAGRICULTURAL USES As described in Chapter 2, Project Description, the proposed UWSP would guide development on 2,066 acres of unincorporated land in northwestern Sacramento County. Under existing conditions, the UWSP area predominantly consists of graded agricultural land, including row crops and dry farming. Under existing conditions, several large agricultural residences are located along the southwestern border and northeastern corner of the UWSP area. The proposed UWSP would provide a mix of residential and non-residential land uses to accommodate 9,356 housing units with a mixture of densities that supports all population segments, and over 3.1 million square feet of commercial, retail, and office uses that serve the community’s needs. Key features of the proposed UWSP would include a mixed-use Town Center, 10 active parks, and an extensive system of greenbelts and multi-use trails with linkages to downtown Sacramento. Development would be limited to a 1,532-acre Development Area.

As part of the proposed UWSP, a 534-acre agricultural buffer is proposed to the west of the Development Area, which is intended to allow for the continuation of existing agricultural, ag-residential, and mitigation uses. To buffer proposed residential uses near the western edge of the Development Area from continued agricultural activity within the agricultural buffer, an open space buffer corridor is proposed along the western edge of the Development Area. The corridor would vary in width from 30 to 50 feet and include a hedgerow of tree plantings adjacent to planned residential uses and a farm fence adjacent to existing agricultural/ag-residential uses.

As also described in Chapter 2, Project Description, and depicted on Plate PD-21, the proposed UWSP would also include a variety of offsite improvements, including road improvements to El Centro Road, Natomas Central Drive, and Arena Boulevard; road improvements to El Centro and San Juan roads; new roadway connections to Garden Highway; a potential bike trail bridge crossing of the West Drainage Canal (Witter Canal); stormwater discharge facilities at two potential locations of the West Drainage Canal (Witter Canal); a new sewer force main from the UWSP area east to the New Natomas Pump Station; potential improvements to the I-80/El Camino Avenue interchange; and a new water supply connection to the existing City of Sacramento water distribution system along West River Drive. The proposed offsite improvements would occur within existing rights-of-way and would not convert farmland to nonagricultural uses.

As discussed in Chapter 14, Land Use, of this Draft EIR, the proposed UWSP establishes a development framework for land use, community design and character, infrastructure improvements, and orderly development that is consistent with the objectives and policies in the Sacramento County 2030 General Plan that guide expansion of the UPA and USB.

With regard to conversion of farmland to nonagricultural uses that would occur with implementation of the proposed UWSP, General Plan Policy AG-5 specifies that projects resulting in the conversion of more than 50 acres of farmland shall be 5 - Agricultural Resources
Upper Westside Specific Plan 5-21 PLNP2018-00284
mitigated, except as specified by the policy, based on a 1:1 ratio for the loss of Prime Farmland, Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance. As shown on Plate AG-1, the UWSP area currently contains approximately 1,805 acres of farmland as defined by General Plan Policy AG-5. This includes about 1,207 acres of Prime Farmland, 593 acres of Farmland of Local Importance, three acres of Farmland of Statewide Importance, and two acres of Unique Farmland (California Department of Conservation 2023a).

To quantify the types and acres of farmland that would be converted to nonagricultural uses with implementation of the proposed UWSP, a georeferenced shapefile (i.e., polygon2) of the 1,532-acre Development Area was digitally imposed over the current (2020) Important Farmland map data from the California Department of Conservation (California Department of Conservation 2023a), enabling a calculation of the types and acres of farmland that would be converted. Based on this calculation, and as shown in Table AG-3, implementation of the UWSP would result in the conversion of approximately 1,372 acres of farmland subject to mitigation pursuant to General Plan Policy AG-5. This total includes conversion of approximately 940 acres of Prime Farmland, 429 acres of Farmland of Local Importance, three acres of Farmland of Statewide Importance, and less than one acre of Unique Farmland.

Table AG-3: UWSP Farmland Conversion
Farmland Classification Acres
Prime 939.74
Local 428.95
Statewide 2.67
Unique 0.69
Total 1,372.05
SOURCE: California Department of Conservation. 2023a. Sacramento County Important Farmland 2020. Map published July 2023. Available:
https://www.conservation.ca.gov/dlrp/fmmp/Pages/Sacramento.aspx.

Accessed June 17, 2024.

In addition, as specified in General Plan Policy AG-6, if a property owner is required to mitigate for the loss of farmland under Policy AG-5, and the approved master plan or community plan includes land permanently set aside for an urban farm, a 1:1 farmland credit will be given to projects that incorporate urban farming within the project that permanently preserves farmland. As further specified in General Plan Policy AG-6, any reversion to a non-farming use on an urban farm site that received farmland credit shall trigger farmland mitigation regardless of the size. The mitigation shall be equivalent to the mitigation required at the time of the original project approval. The proposed UWSP

2 Polygons are used in Geographical Information Systems (GIS) to measure the area and perimeter of a particular location or feature, such as a project site or development footprint. 5 - Agricultural Resources
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does not propose urban farm uses as defined in the General Plan Agricultural Element.3 However, should specified urban farm uses be identified or proposed in an amended plan, the provisions of this policy would be applied as applicable.

Therefore, as described above, the proposed UWSP would result in the loss of approximately 1,372 acres of farmland subject to mitigation pursuant to General Plan Policy AG-5. Implementation of Mitigation Measure AG-1 would require preservation of farmland at a 1:1 ratio. Under the currently adopted General Plan Policy AG-5, the preservation of farmland at a 1:1 ratio must typically be located within Sacramento County. However, as provided in Appendix PD-1, Proposed General Plan Text Amendments, of this EIR, the UWSP proposes revisions to General Plan Policy AG-5 that would clarify when out-of-county mitigation for agricultural land impacts might be considered. These text amendments would be implemented with approval of a General Plan amendment proposed as part of the UWSP. The proposed revisions provide that the Board of Supervisors would retain the authority to set aside the in-County mitigation requirement for impacts to unique, local, and grazing farmlands, but not with respect to prime and statewide farmlands unless the mitigation land is also providing mitigation for impacts to special-status species. Under those circumstances, revised Policy AG-5 explains, the Board of Supervisors may consider, on a case-by-case basis, the mitigation land required to mitigate for impacts to special-status species as also meeting the requirements of for mitigating impacts for loss of farmland, including land outside of Sacramento County. Therefore, Mitigation Measure AG-1 below requires that the project proponent shall mitigate the loss of farmland that would result from implementation of the proposed UWSP at a 1:1 ratio consistent with General Plan Policy AG-5, as amended.

However, even with this mitigation, there would be a substantial net loss of agricultural production within Sacramento County as a result of the proposed UWSP, and this impact would be significant and unavoidable.

3 The Sacramento County 2030 General Plan Agricultural Element (page 8) provides the following definition. Urban Farm: Urban farming generally involves income-earning or food producing activities such as planting, growing, harvesting, processing, and distributing field and vegetable crops in or around a village, town, or city to meet the daily demands of the consumers. Small scale breeding and raising of livestock could be allowed on a limited basis. In addition, incidental activities may include culinary and dietary education facilities, produce stands, and farmer’s markets. Agricultural practices should include organic farming which focuses on maximum yields from a minimum area, while simultaneously improving the soil. The goal is long-term sustainability of both the soil and agricultural operations. For the purpose of this definition, urban farms are separate and distinct from community gardens. In addition, urban farm sites must be located within the UPA. 5 - Agricultural Resources
Upper Westside Specific Plan 5-23 PLNP2018-00284

MITIGATION MEASURES
AG-1 The project proponent shall mitigate the loss of farmland within the plan area, except as otherwise specified in General Plan Policy AG-5 (as amended with UWSP approval), based on a 1:1 ratio through the specific planning process or individual project entitlement requests to provide in-kind or similar resource value protection (such as easements for agricultural purposes). The impact acreage requiring offset shall be based on the most current Farmland Mapping and Monitoring Program at the time of the County’s approval.

Preservation land must be in-kind or of similar resource value.

IMPACT AG-2: CONFLICT WITH EXISTING AGRICULTURAL USE AND ZONING The proposed UWSP would amend the Sacramento County General Plan Land Use Diagram to change the land use designations within the UWSP area from Agricultural Cropland (1,858.3 acres), Agriculture Residential (97.0 acres), Recreation (58.8 acres), and Commercial and Offices (52.2 acres) to Low Density Residential (1,186.8 acres), Medium Density Residential (48.9 acres), High Density Residential (29.7 acres), Commercial and Office (61.2 acres), Mixed Use (114.6 acres), Public/Quasi‐Public (100.4 acres), Recreation (18.7 acres), Agricultural Cropland (418.8 acres), and Agricultural Residential (87.2 acres).

The proposed changes to the land use designations and allowable uses within the UWSP area would be permitted with approval of a General Plan amendment and approval of related amendments to the County Code. Because the entitlements requested as components of the proposed UWSP would change the zoning to make it consistent with the proposal, the proposed UWSP would not conflict with zoning for agricultural use within the UWSP area. In addition, as discussed in Chapter 14, Land Use, of this Draft EIR, the proposed UWSP establishes a development framework for land use, community design and character, infrastructure improvements, and orderly development that is consistent with the objectives and policies in the Sacramento County 2030 General Plan that guide expansion of the UPA and USB.

As previously described, the proposed UWSP would also include a variety of offsite improvements that would occur within existing rights-of-way and would not conflict with existing agricultural use and zoning.

Though a significant portion of land in the UWSP area would be rezoned toward nonagricultural uses, such rezoning would not conflict with agricultural uses. As described above, the proposed UWSP includes a 30- to 50-foot-wide open space buffer corridor along the western perimeter of the Development Area to help alleviate future conflicts between agricultural operation and future urban uses.

With regard to land within a Williamson Act contract, Sacramento County requires land within a Williamson Act contract to be zoned for agricultural use. The UWSP area includes one parcel (APN 225-0190-024) under a Williamson Act contract. As shown on Plate AG-2, this parcel is located in the northwestern portion of the UWSP area that would continue to be designated as Agricultural Cropland with implementation of the 5 - Agricultural Resources
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UWSP and would be within the proposed agricultural buffer as described above.

Implementation of the proposed UWSP would not affect the zoning, contract status, or viability of the parcel under a Williamson Act contract within or in the vicinity of the UWSP area. For the reasons stated above, the proposed UWSP would not conflict with existing agricultural use and zoning, and this impact would be less than significant.

MITIGATION MEASURES
None required.

IMPACT AG-3: OTHER CHANGES WHICH COULD RESULT IN CONVERSION OF

FARMLAND TO NONAGRICULTURAL USE
The proposed UWSP would not indirectly result in the conversion of agricultural land outside of the UWSP area. As previously described under Impact AG-1, the proposed UWSP would include offsite improvements that would occur within existing rights-of-way and would not convert farmland to nonagricultural uses or conflict with existing agricultural uses. The existing land use designations for parcels adjacent to the UWSP area include, amongst others, agricultural-residential and agricultural cropland, which limit the allowed density of development. Such land uses would limit the conversion of adjacent land to nonagricultural use. While implementation of the proposed UWSP would place new residents near existing farmlands and agricultural uses, the proposed plan would include an open space buffer corridor to enable continued agricultural operations within the 534-acre agricultural buffer to the west of the Development Area.

In addition, the proposed UWSP includes a request to amend the UPA and USB. The amended UPA and USB would specifically exclude the aforementioned adjacent agricultural lands. In addition, for any new development north or south of the UWSP area that would propose to convert farmland to nonagricultural use, the land would need to be rezoned and entitled under a separate process requiring substantial effort.

The proposed UWSP emphasizes policies that support the long-term preservation of agriculture and ensure that development pressures are avoided to the maximum extent feasible. For example, UWSP Policy 3-EE specifies the implementation and maintenance of the aforementioned agricultural buffer to the west of the Development Area to preserve existing agricultural uses and farming operations, to allow visual separation between the Development Area and the Garden Highway/Sacramento River, and to create a transition to habitat mitigation areas located to the northwest. UWSP 3-FF specifies that the agricultural buffer would be outside of the County’s UPA and USB. UWSP Policy 3-GG specifies that uses within the agricultural buffer should be limited to those compatible with the rural character of the area, consistent with UWSP Section 3.4.4, Agricultural Buffer Uses, and the County’s Zoning Code.

As previously discussed, proposed high density residential uses would be concentrated near the center of the UWSP area, and development allowed under the proposed UWSP would gradually transition to low density residential uses towards the agricultural buffer zone. This gradual dispersal of residential density would reduce pressure to urbanize areas adjacent to, as well as to the north and south of, the agricultural buffer. 5 - Agricultural Resources
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Finally, development consistent with the proposed UWSP would concentrate development within the Development Area and would not extend infrastructure to areas beyond the identified growth boundary, Furthermore, infrastructure would not be sized to serve development offsite. Therefore, this impact would be less than significant.

MITIGATION MEASURES
None required.

Upper Westside Specific Plan 6-1 PLNP2018-00284
6 AIR QUALITY

INTRODUCTION
This chapter describes the existing ambient air quality environment in and around the UWSP area. It evaluates changes to air quality conditions that could result from implementation of the proposed UWSP.

Specifically, this chapter assesses the potential air quality effects caused by stationary, mobile, and area sources related to construction and operation of the proposed UWSP, as well as the potential for the proposed UWSP to generate objectionable odors, in consideration of the updated 2023 CEQA Guidelines questions. This chapter also describes the climate and meteorology in the UWSP area; existing air quality conditions in the UWSP area for criteria air pollutants and toxic air contaminants (TACs); odors; and applicable federal, state, and regional air quality standards. Mitigation is provided, where necessary and appropriate, to address any significant impacts identified. For a discussion of the proposed UWSP’s potential contributions to global greenhouse gas (GHG) emissions, see Chapter 8, Climate Change.

The County received comments on the Notice of Preparation (NOP) related to air quality, which are addressed in this chapter to the extent they pertain to the impacts of the proposed UWSP. NOP comments relevant to this chapter include requests for the County to evaluate construction and operational air quality impacts and to include an air quality mitigation plan (AQMP) to address operational emissions, consistent with guidance from the Sacramento Metropolitan Air Quality Management District (SMAQMD). This has been addressed in the analysis below.

This chapter relies in part on the Air Quality Technical Report prepared by Raney Planning & Management Inc. (Raney 2024) in support of the project (see Appendix AQ1), which was independently peer reviewed by Environmental Science Associates, in addition to the other technical resources that are referenced herein. The analysis included in this chapter was developed based on project-specific construction and operational features and assumptions, data provided in the Administrative Draft Upper Westside Specific Plan (County of Sacramento 2021), the Air Quality and Greenhouse Gas Impact Analysis (Raney 2024), and traffic information provided by the traffic consultant (see Chapter 18, Transportation). The impacts were assessed consistent with the guidance provided by the SMAQMD’s Guide to Air Quality Assessment in Sacramento County (SMAQMD 2020a).

ENVIRONMENTAL SETTING
Air quality is affected by the rate, type, and location of pollutant emissions and the associated meteorological conditions that influence pollutant movement and dispersal.

Wind speed, wind direction, barometric pressure, and air temperature combined with 6 - Air Quality
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geographic features such as mountains and valleys determine how air pollutant emissions affect local air quality.

CLIMATE AND TOPOGRAPHY
The UWSP area is located within the County of Sacramento, which lies within the Sacramento Valley Air Basin (SVAB) and is within the jurisdictional boundaries of the SMAQMD. The SVAB includes topographic features that regulate the climate including the Coast Ranges to the west, the Sierra Nevada to the east, and the Cascade Range to the north. These mountain ranges channel winds through the SVAB but also inhibit the dispersion of pollutant emissions. The SVAB, including Sacramento, is characterized by a Mediterranean climate that includes mild, rainy winter weather from November through March and warm to hot, dry weather from May through September.

During the summer, the Sacramento Valley has an average high temperature of 92 degrees Fahrenheit (°F) and an average low temperature of 58°F. In the winter, the average high temperature is 58°F and the average low is 40°F. The average annual rainfall is approximately 20 inches.

Wind directions in the Sacramento Valley are influenced by the predominant wind flow pattern associated with each season. The predominant annual and summer wind pattern in the Sacramento Valley is the full sea breeze, commonly referred to as the “Delta breeze.” These cool winds originate from the Pacific Ocean and flow through the Carquinez Strait, a sea-level gap in the Coast Ranges. In the winter (December to February), northerly winds predominate. During about half the days from July through September, however, a phenomenon called the “Schultz Eddy,” a large isotropic vertical-axis eddy on the north side of the Carquinez Strait, prevents the Delta breezes from transporting pollutants north and out of the Sacramento Valley and causes the wind pattern to circle back to the south, all of which tends to keep air pollutants in the Sacramento Valley. The effect of this phenomenon exacerbates the pollutant levels in the area and increases the likelihood of violations of state and federal air quality standards during this period.

The vertical and horizontal movement of air is an important atmospheric component involved in the dispersion and subsequent dilution of air pollutants. Without atmospheric movement, air pollutants can collect and concentrate in a single area, increasing the associated health hazards. For example, inversions occur frequently in the SVAB, especially during the fall and early winter, and restrict the vertical dispersion of pollutants released near ground level.

AIR POLLUTANTS OF CONCERN
Air pollutants of concern within the SVAB include criteria air pollutants and TACs.

CRITERIA AIR POLLUTANTS
Criteria air pollutants are a group of six common air pollutants for which the U.S.

Environmental Protection Agency (USEPA) has set ambient air quality standards. 6 - Air Quality
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Criteria air pollutants include ground-level ozone, carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), particulate matter (PM) in size fractions of 10 microns or less in diameter (PM10) and 2.5 microns or less in diameter (PM2.5), and lead. Most of the criteria air pollutants are primary pollutants and are directly emitted from sources. Ozone, however, is a secondary pollutant that is formed in the atmosphere by a chemical reaction between nitrogen oxides (NOX) and reactive organic gases (ROG) in the presence of sunlight. In addition to the criteria air pollutants identified by the USEPA, California regulates four additional criteria air pollutants:
visibility-reducing particulates, sulfates, hydrogen sulfide, and vinyl chloride.

Criteria air pollutants of concern in the SVAB include ozone, PM10, and PM2.5, as concentrations of these pollutants have been above state and/or national ambient air quality standards in the past three years (see Section 4.2.2). NO2, CO, SO2, lead, visibility-reducing particulates, sulfates, hydrogen sulfide, and vinyl chloride concentrations are well below state and national ambient air quality standards and are not air pollutants of concern in the SVAB. Table AQ-1 lists the health effects associated with the criteria air pollutants of concern.

Table AQ-1: Health Effects of Main Criteria Pollutants
Pollutant Adverse Effects
Ozone
 People most at risk from breathing air containing ozone include people with asthma, children, older adults, and people who are active outdoors, especially outdoor workers.

In addition, people with certain genetic characteristics, and people with reduced intake of certain nutrients (such as Vitamins C and E) are at greater risk from ozone exposure.  Breathing ozone can trigger a variety of health problems including chest pain, coughing, throat irritation, and airway inflammation. It also can reduce lung function and harm lung tissue. Ozone can worsen bronchitis, emphysema, and asthma, leading to increased medical care.
 Ozone affects sensitive vegetation and ecosystems, including forests, parks, wildlife refuges, and wilderness areas. In particular, ozone harms sensitive vegetation during the growing season.

Carbon
Monoxide
 When inhaled at high concentrations, CO combines with hemoglobin in the blood and reduces the oxygen-carrying capacity of the blood. This results in reduced oxygen reaching the brain, heart, and other body tissues and is especially dangerous for people with cardiovascular diseases, chronic lung disease, or anemia, as well as for fetuses.  The most common effects of CO exposure are fatigue, headaches, confusion, and dizziness due to inadequate oxygen delivery to the brain.  At very high concentrations, which are possible indoors or in other enclosed environments, CO can cause dizziness, confusion, unconsciousness, and death.

Nitrogen
Dioxide
 Breathing air with a high concentration of NO2 can irritate airways in the human respiratory system. Such exposures over short periods can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms (such as coughing, wheezing, or difficulty breathing), hospital admissions, and visits to emergency rooms.

Longer exposures to elevated concentrations of NO2 may contribute to the development of asthma and potentially increase susceptibility to respiratory infections. People with asthma, as well as children and the elderly, are generally at greater risk for the health effects of NO2.
6 - Air Quality
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Pollutant Adverse Effects
 NO2, along with other NOX, reacts with other chemicals in the air to form both PM and ozone. Both of these are also harmful when inhaled due to effects on the respiratory system.

Sulfur
Dioxide
 Short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. Health effects are those of asthma exacerbation, including bronchoconstriction accompanied by symptoms of respiratory irritation such as wheezing, shortness of breath and chest tightness, especially during exercise or physical activity.
 Exposure at elevated levels of SO2 (above 1 ppm) results in increased incidence of pulmonary symptoms and disease, decreased pulmonary function, and increased risk of mortality (CARB 2024a).

Particulate
Matter
(PM10 and
PM2.5)
 Particulate matter (PM) contains microscopic solids or liquid droplets that are so small that they can be inhaled and cause serious health problems. Particles less than 10 micrometers in diameter pose the greatest problems, because they can get deep into your lungs, and some may even enter the bloodstream. Of these, particles less than

2.5 micrometers in diameter, also known as fine particles or PM2.5, pose the greatest risk to health.
 Exposure to such particles can affect both your lungs and your heart. Numerous scientific studies have linked particle pollution exposure to a variety of problems, including premature death in people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggravated asthma, decreased lung function, and increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty breathing.  Fine particles (PM2.5) are the main cause of reduced visibility (haze) in parts of the United States, including many national parks and wilderness areas.

Lead
 Lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems, and the cardiovascular system, and affects the oxygen carrying capacity of blood.
 The lead effects most commonly encountered in current populations are neurological effects in children, such as behavioral problems and reduced intelligence, anemia, and liver or kidney damage.
 Excessive lead exposure in adults can cause reproductive problems in men and women, high blood pressure, kidney disease, digestive problems, nerve disorders, memory and concentration problems, and muscle and joint pain.

NOTES: CO = carbon monoxide; NO2 = nitrogen dioxide; NOX = oxides of nitrogen; PM2.5 = particulate matter 2.5 microns or less in diameter; ppm = parts per million; SO2 = sulfur dioxide SOURCES: CARB 2023a, 2023b, 2023c; USEPA 2021a, 2021b, 2021c, 2021d, 2022.

GROUND-LEVEL OZONE
As discussed above, ground-level ozone is a secondary air pollutant produced in the atmosphere through a complex series of photochemical reactions involving the ozone precursors, which are ROG (also referred to as volatile organic compounds [VOCs]), NOX, and sunlight. The main sources of ROG in the SVAB are the evaporation of solvents, paints, and fuels; the main sources of NOX are combustion processes (including motor vehicle engines). Ozone is a regional air pollutant because its precursors are transported and diffused by wind concurrently with ozone production 6 - Air Quality
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through a photochemical reaction process. Ozone causes eye irritation, airway constriction, and shortness of breath, and can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema.

CARBON MONOXIDE
CO is an odorless, colorless gas usually formed as the result of the incomplete combustion of fuels. The single largest source of CO is motor vehicle engines; the highest emissions levels occur during low travel speeds, stop-and-go driving, cold starts, and hard acceleration. Exposure of humans to high concentrations of CO reduces the oxygen-carrying capacity of the blood and can cause headaches, nausea, dizziness, and fatigue; impaired central nervous system function; and angina (chest pain) in persons with serious heart disease. Very high concentrations of CO can be fatal.

PARTICULATE MATTER
PM is frequently classified by particle size, where PM10 consists of PM that is 10 microns or less in diameter and PM2.5 consists of the subset of PM10 that is 2.5 microns or less in diameter (a micron is one-millionth of a meter). PM10 and PM2.5 represent the fractions of PM that can be inhaled into air passages and the lungs and can cause adverse health effects. Some sources of PM (such as wood burning in fireplaces, demolition, and construction activities) are more local, while others (such as vehicular traffic) have a more regional effect. Very small particles of certain substances (e.g., sulfates and nitrates) can cause lung damage directly, or can contain adsorbed gases (e.g., chlorides or ammonium) that may be injurious to health. Particulates also can damage materials, such as statues and monuments, and reduce visibility.

Large dust particles (diameter greater than 10 microns) settle out rapidly and are easily filtered by human breathing passages. This large dust is of more concern as a soiling nuisance than as a health hazard. The remaining fine particulate matter, PM10 and PM2.5, is a health concern, particularly at levels above the federal and state ambient air quality standards. PM2.5 (including diesel exhaust particles) has greater effects on health because these particles are small enough to penetrate to the deepest parts of the lungs.

Short-term (up to 24 hours’ duration) exposure to PM10 has been associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive pulmonary disease, leading to hospitalization and emergency department visits. The effects of long-term (months or years) exposure to PM10 are less clear, although studies suggest a link between long-term PM10 exposure and respiratory mortality, and the International Agency for Research on Cancer published a review in 2015 that concluded that particulate matter in outdoor air pollution causes lung cancer (IARC 2015).

Mortality studies conducted since the 1990s have shown a statistically significant direct association between mortality (premature deaths) and daily concentrations of particulate matter in the air. Despite important gaps in scientific knowledge and continued reasons for some skepticism, a comprehensive evaluation of the research findings provides persuasive evidence that exposure to fine particulate air pollution has adverse effects on cardiopulmonary health and can lead to premature death (Pope and Dockery 2006). 6 - Air Quality
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VISIBILITY-REDUCING PARTICLES
Visibility-reducing particles are any particles in the atmosphere that obstruct the range of visibility by creating haze (CARB 2022). These particles vary in shape, size, and chemical composition, and come from a variety of natural and human-made sources including windblown metals, soil, dust, salt, and soot. Other haze-causing particles are formed in the air from gaseous pollutants (e.g., sulfates, nitrates, organic carbon particles), which are the major constituents of fine PM, such as PM2.5 and PM10, and are caused from the combustion of fuel. The California Air Resources Board (CARB) standard for visibility-reducing particles is based not on health effects, but rather on welfare effects, such as reduced visibility and damage to materials, plants, forests, and ecosystems. The health impacts associated with PM2.5 and PM10 are discussed above under Particulate Matter.

NITROGEN DIOXIDE
NO2 is a reddish-brown gas that is a byproduct of combustion processes. Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to ozone formation, NO2 can increase the risk of acute and chronic respiratory disease and reduce visibility. NO2 may be visible as a coloring component on high-pollution days, especially in conjunction with high ozone levels.

OTHER CRITERIA AIR POLLUTANTS
Other criteria air pollutants include SO2 and lead, which are not air pollutants of concern in the SVAB. SO2 is a combustion product of sulfur or sulfur-containing fuels such as coal and diesel. SO2 is also a precursor to the formation of particulate matter, atmospheric sulfate, and atmospheric sulfuric acid formation that could precipitate downwind as acid rain. The maximum SO2 concentrations recorded in the vicinity of the UWSP area are well below federal and state standards.

Leaded gasoline (phased out in the United States beginning in 1973), lead-based paint (on older houses and cars), smelters (metal refineries), and manufacture of lead storage batteries have been the primary sources of lead released into the atmosphere. Lead has a range of adverse neurotoxic health effects, which puts children at special risk.

Some lead-containing chemicals cause cancer in animals. Lead levels in the air have decreased substantially since leaded gasoline was eliminated. Ambient lead concentrations are only monitored on an as-warranted, site-specific basis in California.

TOXIC AIR CONTAMINANTS
TACs are State of California–designated airborne substances that are capable of causing short-term (acute) and long-term (chronic or carcinogenic, i.e., cancer-causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic chemical substances and may be emitted from a variety of common sources including gasoline stations, automobiles, diesel engines, dry cleaners, industrial operations, and painting operations. TACs of concern for the proposed UWSP include diesel particulate matter (DPM) and asbestos. DPM would occur from construction equipment and on-road diesel construction trucks, operational on-road diesel trucks, and 6 - Air Quality
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operations of emergency back-up diesel generators. Asbestos fibers could be released and suspended in ambient air during demolition activities (discussed further below).

DIESEL PARTICULATE MATTER
The exhaust from diesel engines includes hundreds of different gaseous and particulate components, many of which are toxic carcinogens. Mobile sources such as trucks and buses are among the primary sources of diesel emissions, and concentrations of DPM are higher near heavily traveled highways and rail lines with diesel locomotive operations.

CARB identified DPM as a TAC in 1998, primarily based on evidence demonstrating cancer effects in humans (CARB 2023d). It is estimated that about 70 percent of total known cancer risk related to air toxics in California is attributable to DPM (CARB 2023d). More than 90 percent of DPM is less than 1 microgram in diameter and thus is largely a subset of PM2.5; therefore, DPM also contributes to the same non-cancer health effects as PM2.5 exposure (see Table AQ-1). DPM may also facilitate the development of new allergies.

Regulation of diesel engines and fuels has decreased DPM levels by 68 percent since 1990. Furthermore, CARB estimates that emissions of DPM in 2035 will be less than half those in 2010, even with increasing vehicle miles traveled (CARB 2023d).

Nonetheless, based on 2012 estimates of statewide exposure, DPM is estimated to increase statewide cancer risk by 520 cancers per million residents exposed over a lifetime.

PM2.5
A large body of scientific evidence indicates that both long-term and short-term exposure to PM2.5 can cause a wide range of health effects (e.g., aggravating asthma and bronchitis), causing visits to the hospital for respiratory and cardiovascular symptoms, and contributing to heart attacks and deaths (CARB 2023e). PM2.5 (including diesel exhaust particles) is thought to have greater effects on health because these particles are very small and therefore can penetrate to the deepest parts of the lungs.

According to CARB, both PM10 and PM2.5 can be inhaled with some deposition throughout the airways. PM10 is more likely to deposit on the surfaces of the larger airways of the upper region of the lung while PM2.5 is more likely to travel into and deposit on the surface of the deeper parts of the lung, which can induce tissue damage, and lung inflammation.

Short-term exposure to PM2.5 has been associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted-activity days.

Long-term exposure to PM2.5 has been linked to premature death, particularly in people who have chronic heart or lung diseases, and reduced lung function growth in children.

According to CARB, populations most likely to experience adverse health effects with exposure to PM10 and PM2.5 include older adults with chronic heart or lung disease, children, and asthmatics. Children and infants are susceptible to harm from inhaling pollutants such as PM10 and PM2.5 as compared to healthy adults because they inhale 6 - Air Quality
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more air per pound of body weight than do adults, spend more time outdoors, and have developing immune systems that are more susceptible to external toxins (CARB 2024b).

ASBESTOS
Asbestos is a fibrous mineral and used as a processed component of building materials.

Because asbestos has been proven to cause serious adverse health effects, including asbestosis and lung cancer, it is strictly regulated based on its natural widespread occurrence and its use as a building material. When building materials containing asbestos are disturbed, asbestos fibers may be released and suspended in ambient air.

Asbestos is also naturally occurring in ultramafic rock (a rock type commonly found in California), but it is unlikely to occur within the UWSP area (CARB 2005).

EXISTING CONDITIONS
The UWSP area is in unincorporated Sacramento County adjacent to the existing City of Sacramento communities of North and South Natomas. The proposed UWSP is bounded by Fisherman’s Lake Slough to the north, the West Drainage Canal (Witter Canal) to the east, Interstate 80 (I-80) to the south, and Garden Highway to the west.

The 2,066-acre site is outside of the County’s Urban Policy Area and Urban Services Boundary in the Natomas community and Natomas Vision Area, and is predominantly agricultural land with existing commercial uses, including a truck stop, restaurants, gas stations, and hotels located west of the I-80 off-/on-ramps.

Surrounding existing land uses include the Sacramento River to the south and west; agricultural land to the west; I-80, multi-family residences, and a business park to the east; and single-family residences to the east, west, north, and south.

The Sacramento County General Plan designates the site as Agricultural Cropland, Agricultural Residential, Commercial/Office, and Recreation and the site is zoned Agricultural, Agricultural Residential, General Commercial, and Highway Travel Commercial.

EXISTING AMBIENT AIR QUALITY
Air quality is monitored by CARB at various locations to determine which air quality standards are being violated to determine attainment status of the region and to direct emission reduction efforts, such as developing attainment plans and rules, incentive programs, etc. The nearest local air quality monitoring stations to the UWSP area are the Bercut Drive (100 Bercut Drive) and Sacramento–T Street (1309 T Street) monitoring stations. The Bercut Drive monitoring station provides the nearest representative measurement of CO and is approximately 2.5 miles southeast of the UWSP area. The Sacramento–T Street station provides the nearest representative measurement of NO2, ozone, PM2.5, and PM10 and is approximately 4 miles southeast of the UWSP area.

Table AQ-2 presents a three-year summary of air pollutant concentration data collected at these monitoring stations for ozone, PM10, PM2.5, NO2, and CO, as well as the number of days the applicable standards were exceeded during the given year. National and state regulatory standards are discussed in detail in the Regulatory Setting below. 6 - Air Quality
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Table AQ-2: Summary of Air Quality Monitoring Data (2020-2022) Pollutant
National/
State
Standard 2020 2021 2022
OZONE
Maximum 1-hour concentration, ppm 0.09 1 0.112 0.091 0.106 Number of days above state 1-hour standard 1 0 1
Maximum 8-hour concentration, ppm 0.070/0.070 0.076 0.080 0.079 Number of days above national 8-hour standard 3 1 3

CARBON MONOXIDE
Maximum 1-hour concentration, ppm 35/20 4.3 2.2 2.0
Number of days above national or state 1-hour
standard 0 0 0

NITROGEN DIOXIDE
Annual average concentration, ppm 0.053/0.030 0.008 0.007 0.008 Maximum 1-hour concentration, ppm 0.100/0.18 0.054 0.055 0.050 Number of days above national 1-hour standard 0 0 0
Number of days above state 1-hour standard 0 0 0
PARTICULATE MATTER (PM10)
Annual average concentration, µg/m3 20 1 31.2 23.5 21.0 Maximum 24-hour concentration
(national/state), µg/m3 150/50 298.7/292.8 132.6/142.6 60.2/61.3 Estimated number of days above national
24-hour standard 3 4.0 0.0 0.0
Estimated number of days above state 24-hour
standard 3 59.0 13.3 6.1
PARTICULATE MATTER (PM2.5)
Annual average concentration, µg/m3 12.0/12.0 13.1/13 9.3/9.4 8.5/8.6 Maximum 24-hour concentration, µg/m3 35 2 111.0/150.4 89.1 33.1 Estimated number of days above national
24-hour standard 3 17.1 4.0 0.0
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NOTES:
µg/m3 = micrograms per cubic meter; ppm = parts per million.

Number of days exceeded is for all days in a given year, except for particulate matter. PM10 and PM2.5 are monitored every six days. 2020–2022 monitoring data for ozone, nitrogen dioxide, PM10, and PM2.5 are from the Sacramento-T Street station (CARB 2024c). 2020–2022 monitoring data for carbon monoxide are from the Sacramento-Bercut Drive station (USEPA 2024). The California Air Resources Board and U.S. Environmental Protection Agency use different methods to calculate the emissions for certain criteria air pollutants for comparisons to the state and national standards.

Bold values are in excess of applicable standard.
1 State standard, not to be exceeded.
2 National standard, not to be exceeded.
3 Particulate matter sampling schedule of one out of every six days, for a total of approximately 60 samples per year. Estimated days exceeded mathematically estimates of how many days concentrations would have been greater than the level of the standard had each day been monitored.

SOURCES: CARB 2024c; USEPA 2024
As described in Table AQ-2, ozone levels in the vicinity of the UWSP area have resulted in numerous violations of ambient air quality standards from 2020-2022. During the three-year study period, concentrations of ozone in the vicinity of the UWSP area have only exceeded the one-hour state standard twice from 2020-2022 but have exceeded the eight-hour state and national standards seven times from 2020-2022.

Monitoring data for PM10 in the vicinity of the UWSP area indicate that the 24-hour national standard was exceeded four times in 2020. In 2021 and 2022, the PM10 24-hour national standard was not exceeded. For PM2.5, the study area was estimated to have exceeded the 24-hour national standard approximately 17 times in 2020 and four times in 2021. In 2022 the PM2.5 24-hour national standard was not exceeded.

ODORS
Odors are generally regarded as an annoyance rather than a health hazard.

Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). The ability to detect odors varies considerably among the population and overall is quite subjective.

People may have different reactions to the same odor. An odor that is offensive to one person may be perfectly acceptable to another (e.g., coffee roaster). An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition only occurs with an alteration in the intensity. The occurrence and the severity of odor impacts depend on the nature, frequency, and intensity of the source, wind speed and direction, and the sensitivity of receptors.

Odoriferous compounds could be generated from a variety of source types including both construction and operational activities. Examples of common land use types that 6 - Air Quality
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typically generate significant odor impacts include wastewater treatment plants; sanitary landfills; composting/green waste facilities; recycling facilities; petroleum refineries; chemical manufacturing plants; painting/coating operations; rendering plants; and food packaging plants. The UWSP area is not located in the vicinity of any land use types that are known to generate significant odor impacts.

SENSITIVE RECEPTORS
Air quality concerns do not affect individuals or groups within the population in the same way, and some groups are more sensitive to adverse health effects caused by exposure to air pollutants than others. Population subgroups sensitive to the health effects of air pollutants include the elderly and the young, those with higher rates of respiratory disease such as asthma and chronic obstructive pulmonary disease, and with other environmental or occupational health exposures (e.g., indoor air quality) that affect cardiovascular or respiratory diseases.

Land uses such as schools, children’s day care centers, hospitals, and nursing and convalescent homes are the most sensitive to poor air quality because the population groups associated with these uses have increased susceptibility to respiratory distress.

Parks and playgrounds are considered moderately sensitive to poor air quality because persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality; however, exposure times are generally far shorter in parks and playgrounds than in residential locations and schools, which typically reduces the overall health risk associated with exposure to pollutants. Residential areas are considered more sensitive to air quality conditions than commercial and industrial areas because people generally spend longer periods of time at their residences, with associated greater exposure to ambient air quality conditions. Workers are not considered sensitive receptors because all employers are required to follow regulations set forth by the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) to ensure the health and well-being of their employees.

The northeastern and southeastern boundaries of the UWSP area are characterized by residential land uses. There are also low-density residences to the west along the Sacramento River waterfront. Thus, in the project vicinity, the nearest sensitive receptors are primarily residences, as well as public schools. The following residential sensitive receptors are located within a 1,000-foot radius of the UWSP area:
 Natomas Estates Park, located within the northeast portion of the UWSP area boundary.
 River View Park neighborhood, located approximately 50 feet from the UWSP area boundary in the center of the area.
 Gateway West neighborhood, located approximately 200 feet to the east of the UWSP area.
 Willow Creek neighborhood, located approximately 300 feet to the southeast of the UWSP area.
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 Garden Highway riverfront residences, located approximately 100–900 feet to the west of the UWSP area.
 Sundance Lake neighborhood, located approximately 500 feet to the north of the UWSP area.

Additionally, the following non-residential sensitive receptors are located near the UWSP area:
 Witter Ranch Elementary School, located approximately 800 feet to the east of the UWSP area.
 Sunlake Daycare LLC, located approximately 800 feet to the north of the UWSP area.
 Two Rivers Elementary School, located approximately 1,400 feet to the east of the UWSP area.
 Merryhill Preschool, located approximately 1,000 feet to the northeast of the UWSP area.

BASELINE CONDITIONS
The UWSP area is predominantly agricultural land with existing commercial uses, including a truck stop, restaurants, gas stations, and hotels located west of the I-80 off-/ on-ramps at West El Camino Avenue. The existing conditions for operational emissions were estimated using the California Emissions Estimator Model (CalEEMod) v. 2020.4.0. Existing land use inputs and vehicle trip generation rate inputs for the model were consistent with the trip generation memorandum that was prepared by Fehr and Peers. Therefore, baseline conditions conservatively assume the associated existing air pollutant emissions.

REGULATORY SETTING

FEDERAL

CRITERIA AIR POLLUTANTS
The USEPA is required by the federal Clean Air Act (CAA) to identify and establish national ambient air quality standards (NAAQS) to protect public health and the environment. The federal CAA identifies two types of NAAQS: primary and secondary.

Primary standards provide public health protection, including protecting the health of sensitive populations such as those with pre-existing respiratory conditions, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.

The USEPA has set NAAQS for six principal pollutants, called criteria air pollutants.

These criteria air pollutants include ozone, NO2, SO2, CO, PM, and lead. As discussed previously, PM is separated into two different criteria pollutants based on particle 6 - Air Quality
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fraction size; these separate standards are in terms of PM10 and PM2.5. Table AQ-3 presents the current NAAQS (and state ambient air quality standards) and provides a brief discussion of the principal sources for each pollutant.

Table AQ-3: National and California Ambient Air Quality Standards and Major Sources
Pollutant
Averaging
Time
State
Standard
National
Standard Major Pollutant Sources
Ozone
1 hour 0.09 ppm --- Formed when reactive organic gases
and NOX react in the presence of
sunlight. Major sources include onroad motor vehicles, solvent evaporation, and commercial/
industrial mobile equipment.
8 hour 0.070 ppm 0.070 ppm
Carbon Monoxide
1 hour 20 ppm 35 ppm Internal combustion engines, primarily gasoline-powered motor vehicles. 8 hour1 9.0 ppm 9 ppm
Nitrogen Dioxide
1 hour 0.18 ppm 100 ppb Motor vehicles, petroleum refining operations, industrial sources,
Annual Avg. 0.030 ppm 0.053 ppm aircraft, ships, and railroads.

Sulfur Dioxide
1 hour 0.25 ppm 75 ppb Fuel combustion, chemical plants, sulfur recovery plants, and metal
processing.
3 hour --- 0.5 ppm 2
24 hour 0.04 ppm 0.14 ppm
Annual Avg. --- 0.030 ppm
Respirable
Particulate Matter
(PM10)
24 hour 50 µg/m3 150 µg/m3 Dust and fume-producing industrial and agricultural operations,
combustion, atmospheric
photochemical reactions, and natural
activities (e.g., wind-raised dust and
ocean sprays).

Annual Avg. 20 µg/m3---
Fine Particulate
Matter
(PM2.5)
24 hour --- 35 µg/m3 Fuel combustion in motor vehicles, equipment, and industrial sources;
residential and agricultural burning;
also formed from photochemical
reactions of other pollutants,
including NOX, sulfur oxides, and
organics.

Annual Avg. 12 µg/m3 12.0 µg/m3
Lead
Monthly Avg. 1.5 µg/m3--- Present source: lead smelters, battery manufacturing, and recycling
facilities. Past source: combustion of
leaded gasoline.

Quarterly --- 1.5 µg/m3
Hydrogen Sulfide 1 hour 0.03 ppm No National
Standard
Geothermal power plants, petroleum
production, and refining
Sulfates 24 hour 25 µg/m3 No National
Standard
Produced by the reaction in the air of
SO2.
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Pollutant
Averaging
Time
State
Standard
National
Standard Major Pollutant Sources
Visibility-Reducing
Particles
8 hour Extinction of

0.23/km;
visibility of 10
miles or more
No National
Standard
See PM2.5.

Vinyl Chloride 24 hour 0.01 ppm No National
Standard
Polyvinyl chloride and vinyl
manufacturing.

NOTES: µg/m3 = micrograms per cubic meter; km = kilometer; NOX = nitrogen oxides; ppb = parts per billion; ppm = parts per million.
“---" means there is no standard.
1 A more stringent 8-hour carbon monoxide state standard exists around Lake Tahoe (6 ppm). 2 Secondary national standard.

SOURCE: CARB 2016
The USEPA classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether or not the NAAQS had been achieved.

The classification is determined by comparing monitoring data with the standards (please refer to Table AQ-3 above). “Unclassified” is defined by the federal CAA as any area that cannot be classified, on the basis of available information, as meeting or not meeting the national primary or secondary ambient air quality standard for the pollutant.

Furthermore, an area may be designated attainment with a maintenance plan (also known as a maintenance area), which means that an area was previously classified as nonattainment for a criteria air pollutant but has since been redesignated as attainment.

These areas have demonstrated through modeling that they have sufficient controls in place to meet and maintain the NAAQS.

The Sacramento region’s attainment status for the criteria air pollutants is summarized in Table AQ-4 (state designations are also provided). The Sacramento region is considered a federal nonattainment area for ozone and PM2.5 and an attainmentmaintenance area for the federal CO and PM10 standards. Sacramento County has been designated nonattainment for the state one-hour ozone, state eight-hour ozone, and state PM10 standards. The County is designated attainment or unclassified for all other state and federal standards.

The federal CAA requires each state to prepare an air quality control plan, referred to as a State Implementation Plan (SIP). The SIP is a living document that is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of air basins as reported by the agencies with jurisdiction over them. The USEPA has responsibility to review all state SIPs to determine whether they conform to the mandates of the federal CAA and will achieve air quality goals when implemented. 6 - Air Quality
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Table AQ-4: Sacramento County Attainment Status
Pollutant and Averaging Time
Designation/Classification
State Standards Federal Standards
Ozone (1-hour) Nonattainment Nonattainment1
Ozone (8-hour) Nonattainment Nonattainment/Moderate
Carbon Monoxide (1-hour) Attainment Attainment/Maintenance Carbon Monoxide (8-hour) Attainment Attainment/Maintenance Nitrogen Dioxide (1-hour) Attainment Unclassified/Attainment Nitrogen Dioxide (Annual) Attainment Unclassified/Attainment Sulfur Dioxide (1-hour) Attainment Unclassified/Attainment Sulfur Dioxide (24-hour) Attainment No Federal Standard Respirable Particulate Matter (PM10) (24-hour) Nonattainment Attainment Respirable Particulate Matter (PM10) (Annual) Nonattainment No Federal Standard Fine Particulate Matter (PM2.5) (24-hour) Attainment Nonattainment2 Fine Particulate Matter (PM2.5) (Annual) Attainment Attainment Lead Attainment Unclassified/Attainment
Visibility-Reducing Particles Unclassified No Federal Standard Sulfates Attainment No Federal Standard
Hydrogen Sulfide Unclassified No Federal Standard
Vinyl Chloride Unclassified No Federal Standard
NOTES: The California Air Resources Board (CARB) makes area designations for 10 criteria pollutants (ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, particulate matter 10 microns or less in diameter, particulate matter 2.5 microns or less in diameter, lead, visibility-reducing particles, sulfates, and hydrogen sulfide). CARB does not designate areas according to the vinyl chloride standard. 1 The U.S. Environmental Protection Agency (USEPA) issued a Determination of Attainment on October 18, 2012 (77 Federal Register [FR] 64036), but the Sacramento Federal Ozone Nonattainment Area has not yet redesignated the Attainment. 2 USEPA issued a Determination of Attainment on May 10, 2017 (82 FR 21711), but the Sacramento Federal PM2.5 Nonattainment Area has not yet redesignated the Attainment.

SOURCE: SMAQMD 2022

HAZARDOUS AIR POLLUTANTS
Federal laws use the term “hazardous air pollutants” (HAPs) to refer to the same types of compounds that are referred to as TACs under state law. Currently, 187 substances are regulated as HAPs. The federal CAA requires the USEPA to identify the National Emission Standards for Hazardous Air Pollutants (NESHAPs) to protect public health and welfare. NESHAPs potentially applicable to the proposed UWSP include the National Emission Standard for Asbestos (Code of Federal Regulations Title 40, Part 61, Subpart M).
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STATE

CRITERIA AIR POLLUTANTS
At the state level, CARB oversees California’s air quality policies and regulations.

California had adopted its own air quality standards (California ambient air quality standards [CAAQS]), as shown in Table AQ-3. California’s ambient standards are required to be at least as protective as the NAAQS and in some cases are more stringent.

In 1988, California passed the California Clean Air Act (California Health and Safety Code Sections 39600 et seq.), which, like its federal counterpart, called for the designation of areas as attainment or nonattainment, based on state ambient air quality standards rather than the federal standards. The California Clean Air Act requires each air district in which state air quality standards are exceeded to prepare a plan that documents reasonable progress toward attainment. If an air basin (or portion thereof) exceeds the CAAQS for a particular criteria air pollutant, it is considered to be nonattainment for that criteria air pollutant until the area can demonstrate compliance.

As indicated in Table AQ-4, Sacramento County is classified as nonattainment and moderate nonattainment for the 8-hour and 1-hour state ozone standards, respectively, and is nonattainment for the 24-hour and annual state PM10 standard.

TOXIC AIR CONTAMINANTS
The State Air Toxics Program was established in 1983 under Assembly Bill (AB) 1807.

A total of 243 substances have been designated TACs under California law; they include the 187 (federal) HAPs adopted in accordance with state law. The Air Toxics “Hot Spots” Information and Assessment Act of 1987 (AB 2588) seeks to identify, quantify, and evaluate risk from air toxics sources; however, AB 2588 does not regulate air toxics emissions.

In 2000, CARB approved a comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from both new and existing diesel-fueled vehicles and engines. Further regulations of diesel emissions by CARB include the On-Road Heavy Duty Diesel Vehicle (In-Use) Regulation, the On-Road Heavy Duty (New) Vehicle Program, the InUse Offroad Diesel Vehicle Regulation, and the New Offroad Compression Ignition Diesel Engines and Equipment Program. All of these regulations and programs have timetables by which manufacturers must comply and existing operators must upgrade their diesel-powered equipment.

In 2004, CARB adopted a measure to limit idling of diesel-fueled commercial motor vehicles. Heavy-duty diesel vehicles with a Gross Vehicle Weight Rating of 10,000 pounds (lbs.) or heavier are prohibited from idling for more than two minutes within California’s borders. Exceptions to the rule apply for certain circumstances. 6 - Air Quality
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CARB AIR QUALITY AND LAND USE HANDBOOK
The Air Quality and Land Use Handbook: A Community Health Perspective (CARB 2005) (CARB Handbook), which is advisory rather than regulatory, includes the following recommendations that may apply to the project:
 Avoid siting new sensitive land uses within 500 feet of urban roads carrying 100,000 vehicles per day.
 Avoid siting new sensitive land uses within 300 feet of a large gasoline station (gasoline dispensing facility [GDF]) (defined as a facility with a throughput of

3.6 million gallons per year or greater). A 50-foot separation is recommended for typical GDFs.
 Avoid siting new sensitive land uses within 300 feet of any dry-cleaning operation using perchloroethylene. For operations with two or more machines, provide 500 feet. For operations with three or more machines, consult the local air district. Do not site new sensitive land uses in the same building with drycleaning operations that use perchloroethylene.  Obtain facility-specific information where there are questions about siting a sensitive land use close to an industrial facility, including the amount of pollutant emitted and its toxicity, distance to nearby receptors, and types of emissions controls in place.

TITLE 24 – CALIFORNIA ENERGY EFFICIENCY STANDARDS
Energy consumption for new residential and nonresidential buildings is regulated by California Code of Regulations Title 24, Part 6, Building Energy Efficiency Standards (the California Energy Code), which was established in 1978 in response to a legislative mandate to reduce California’s energy consumption and make for development of healthier buildings. The standards are updated periodically (typically every three years) to allow for consideration and possible incorporation of new energy-efficiency technologies and cleaner building methods. The current standards became effective on January 1, 2023, and require that all new residential construction now install Minimum Efficiency Reporting Value (MERV) 13 filters to reduce particulate impacts on indoor air quality.

SB 350 - CLEAN ENERGY AND POLLUTION REDUCTION ACT OF 2015 Senate Bill (SB) 350, known as the Clean Energy and Pollution Reduction Act of 2015, was enacted on October 7, 2015, and provides a new set of objectives in clean energy, clean air, and pollution reduction by 2030. The objectives include the following:
 To increase from 33 percent to 50 percent, the procurement of our electricity from renewable sources.
 To double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation. 6 - Air Quality
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CALIFORNIA AIR RESOURCES BOARD ADVANCED CLEAN CAR PROGRAM The Advanced Clean Cars emissions-control program was approved by CARB in 2012 and is closely associated with the Pavley regulations. The program requires a greater number of zero-emission vehicle models for years 2015 through 2025 to control mobile sources emissions, smog, soot, and GHG emissions. This program includes the LowEmissions Vehicle regulations to reduce criteria pollutant and GHG emissions from light- and medium-duty vehicles; and the Zero-Emissions Vehicle regulations to require manufactures to produce an increasing number of pure zero-emissions vehicles (meaning battery and fuel cell electric vehicles) with the provision to produce plug-in hybrid electric vehicles between 2018 and 2025. The Advanced Clean Cars II Regulations require that all new passenger cars, trucks, and SUVs sold in California be zero emissions by 2035. CARB adopted the Advanced Clean Cars II regulations on August 25, 2022.

CALIFORNIA AIR RESOURCES BOARD MOBILE SOURCE STRATEGY
The Mobile Source Strategy (2016) includes an expansion of the Advanced Clean Cars program (which further increases the stringency of emissions for all light-duty vehicles, and 4.2 million zero-emission and plug-in hybrid light-duty vehicles by 2030). It also calls for more stringent GHG requirements for light-duty vehicles beyond 2025 as well as GHG reductions from medium-duty and heavy-duty vehicles and increased deployment of zero-emission trucks primarily for classes 3–7 “last-mile” delivery trucks in California. Statewide, the Mobile Source Strategy would result in a 45 percent reduction in GHG emissions and a 50 percent reduction in the consumption of petroleum-based fuels and associated criteria pollutants. CARB’s Mobile Source Strategy includes measures to reduce total light-duty vehicle miles traveled by 15 percent compared to business as usual in 2050.

CARB is developing the 2020 Mobile Source Strategy to take an integrated planning approach to identify the level of transition to cleaner mobile-source technologies needed to achieve all of California’s targets. The 2020 Mobile Source Strategy was heard by the Board on October 28, 2021, and was forwarded to the appropriate policy and fiscal committees of the California Legislature as required by California SB 44. The programs and concepts in the 2020 Mobile Source Strategy will be incorporated in other planning efforts, including the SIP, the 2022 Climate Change Scoping Plan Update, and community emissions reduction plans developed as a part of AB 617’s Community Air Protection Program. CARB translated the concepts in the 2020 Mobile Source Strategy into federally enforceable SIP measures and commitments included in the 2022 State SIP Strategy to support attainment of federal ozone standards across the State.

CALIFORNIA AIR RESOURCES BOARD ADVANCED CLEAN TRUCKS REGULATION The Advanced Clean Trucks regulation was approved on June 25, 2020, and has two main components: a manufacturer’s zero-emissions-vehicle sales requirement and a one-time reporting requirement for large entities and fleets. Manufacturers who certify Class 2b–8 chassis or complete vehicles with combustion engines are required to sell zero-emissions trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emissions truck/chassis sales need to be 55 percent of 6 - Air Quality
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Class 2b–3 truck sales, 75 percent of Class 4–8 straight truck sales, and 40 percent of truck tractor sales.

PORTABLE EQUIPMENT REGISTRATION PROGRAM
The Portable Equipment Registration Program is a statewide program created by CARB to register portable equipment designed to move from one location to another throughout California. Equipment registered under this program may operate in multiple local air districts, including the SVAB. CARB is responsible for the Portable Equipment Registration Program and issues program registrations for eligible equipment, such as portable engines and portable equipment powered by engines rated 50 horsepower or greater, and portable equipment units that emit particulate matter greater than 2 lbs./day.

The SMAQMD enforces the requirements of the program at the local level.

LOCAL

SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT SMAQMD is the regional agency responsible for air quality regulation within Sacramento County. The agency regulates air quality through its planning and review activities and has permit authority over most types of stationary emission sources and can require operators of stationary sources to obtain permits, can impose emission limits, set fuel or material specifications, and establish operational limits to reduce air emissions. SMAQMD regulates new or modified stationary sources of criteria air pollutants and TACs.

All areas designated as nonattainment are required to prepare plans showing how the area would meet the air quality standards by its attainment dates. The following are the most recent air quality plans applicable to the area of the proposed UWSP:
 Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan (SMAQMD 2013a)
 SMAQMD’s Triennial Report and Air Quality Plan Revision (SMAQMD 2015)  PM10 Implementation/Maintenance Plan and Redesignation Request for Sacramento County (SMAQMD 2010).
 PM2.5 Maintenance Plan and Redesignation Request (SMAQMD 2013b)  2004 Revision to the California State Implementation Plan for CO (SMAQMD 2004)
The construction phase of the proposed UWSP would be subject to the applicable SMAQMD regulations with regard to construction and stationary equipment, particulate matter generation, architectural coatings, and paving materials. Equipment used during construction would be subject to the applicable requirements of SMAQMD Regulation 2 (Permits), Rule 201 (General Permit Requirements); and Regulation 4 (Prohibitory Rules), Rule 401 (Ringelmann Chart/Opacity), Rule 402 (Nuisance), Rule 403 (Fugitive Dust), Rule 404 (Particulate Matter), Rule 405 (Dust and Condensed Fumes), Rule 420 (Sulfur Content of Fuels), and construction practices would be subject to Rule 442 6 - Air Quality
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(Architectural Coatings), and Rule 453 (Cutback and Emulsified Asphalt Paving Materials). Demolition activities would be in compliance with all SMAQMD rules associated with demolition and construction.

The operational phase of the proposed UWSP would be subject to SMAQMD Rule 201, which requires any business or person to obtain an authority to construct and a permit to operate prior to installing or operating new equipment or processes that may release or control air pollutants to ensure that all SMAQMD rules and regulations are considered.

Potentially applicable stationary pollutant sources that would be installed as part of the proposed UWSP include multiple new boilers, natural gas burning fire pits, diesel emergency generators, and potentially other equipment. A permit is required for all boilers, process heaters, and steam generators with a rated heat input capacity of 1 million British thermal units (Btu) per hour or greater, or boilers, process heaters, and steam generators of any size that are not fired exclusively on purchased quality natural gas, liquid petroleum gas, or any combination thereof. A permit is required if the aggregate rated heat input capacity of all boilers, process heaters, and steam generators used in the same process is 1 million Btu per hour or greater. SMAQMD Rule 414 applies to boilers rated less than 1 million Btu per hour.

SACRAMENTO AREA COUNCIL OF GOVERNMENTS
The Sacramento Area Council of Governments (SACOG) is the Metropolitan Planning Organization (MPO) for the site of the proposed UWSP. SACOG’s jurisdiction covers six counties in the Sacramento region (El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba). One of the main responsibilities of SACOG is to maintain and develop comprehensive transportation planning for the region through metropolitan transportation plans (MTPs) and federal transportation improvement programs. These transportation planning documents are intended to improve future transportation networks and options for residents. SACOG is tasked with determining conformity under the federal CAA for projects, plans, and programs. SACOG is responsible for the analysis of transportation activities to determine conformity with the federal CAA.

METROPOLITAN TRANSPORTATION PLAN/SUSTAINABLE COMMUNITIES STRATEGY SACOG's Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) is the long-range transportation plan for the region. The MTP/SCS designates the region using five “community types” (Center and Corridor Community, Developing Community, Established Community, Rural Residential Community, and Natural Resource Lands [Lands Not Identified for Development in the MTP/SCS Planning Period]).

The 2020 MTP/SCS does not presently fully account for all growth anticipated within the proposed UWSP area (Glover, pers. comm., 2017). However, the MTP/SCS is updated every four years to include additional amendments to county and city general plans and take into account approved projects and new specific plans, such as the proposed UWSP.
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SACRAMENTO COUNTY GENERAL PLAN
The following goals and policies from the Air Quality, Circulation, Energy, and Land Use elements of the Sacramento County 2030 General Plan (County of Sacramento 2011) are applicable to the proposed UWSP.

AIR QUALITY
AQ-1 New development shall be designed to promote pedestrian/bicycle access and circulation to encourage community residents to use alternative modes of transportation to conserve air quality and minimize direct and indirect emission of air contaminants.

AQ-2 Support Regional Transit’s efforts to secure adequate funding so that transit is a viable transportation alternative. Development shall pay its fair share of the cost of transit facilities required to serve the project.

AQ-3 Buffers and/or other appropriate mitigation shall be established on a projectby-project basis and incorporated during review to provide for protection of sensitive receptors from sources of air pollution or odor. The California Air Resources Board’s “Air Quality and Land Use Handbook: A Community Health Perspective,” and the [SMAQMD’s] approved Protocol (Protocol for Evaluating the Location of Sensitive Land uses Adjacent to Major Roadways) shall be utilized when establishing these buffers.

AQ-4 Developments which meet or exceed thresholds of significance for ozone precursor pollutants, and/or Greenhouse Gases (GHG) as adopted by the Sacramento Metropolitan Air Quality Management District (SMAQMD), shall be deemed to have a significant environmental impact. An Air Quality Mitigation Plan and/or a Greenhouse Gas Reduction Plan shall be submitted to the County of Sacramento prior to project approval, subject to review and recommendation as to technical adequacy by the Sacramento Metropolitan Air Quality Management District.

AQ-4B Land uses with sensitive receptors (such as residences, schools, senior care facilities and day care centers) which are proposed within 500 feet of a freeway or other high volume roadway (defined as an urban roadway with more than 100,000 average daily trips or a rural roadway with more than 50,000 average daily trips), a railyard or an active railroad shall incorporate exposure reduction measures consistent with the guidance listed in Air Quality Element policy AQ-3.

AQ-5 Reduce emissions associated with vehicle miles travelled and evaporation by reducing the surface area dedicated to parking facilities; reduce vehicle emissions associated with “hunting” for on-street parking by implementing innovative parking solutions including shared parking, elimination of minimum parking requirements, creation of maximum parking requirements, and utilize performance pricing for publicly owned parking spaces both on- and offstreet, as well as creating parking benefit districts. 6 - Air Quality
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AQ-6 Provide incentives for the use of transportation alternatives, including a program for the provision of financial incentives for builders that construct ownership housing within a quarter mile of existing and proposed light rail stations.

AQ-8 Promote mixed-use development and provide for increased development intensity along existing and proposed transit corridors to reduce the length and frequency of vehicle trips.

AQ-10 Encourage vehicle trip reduction and improved air quality by requiring development projects that exceed the SMAQMD’s significance thresholds for operational emissions to provide on-going, cost-effective mechanisms for transportation services that help reduce the demand for existing roadway infrastructure.

AQ-11 Encourage contractors operating in the county to procure and to operate lowemission vehicles, and to seek low emission fleet status for their off-road equipment.

AQ-12 Minimize air pollutant emissions from Sacramento County facilities and operations.

AQ-13 Use California State Air Resources Board (ARB) [CARB] and SMAQMD guidelines for Sacramento County facilities and operations to comply with mandated measures to reduce emissions from fuel consumption, energy consumption, surface coating operations, and solvent usage.

AQ-14 Support SMAQMD's development of improved ambient air quality monitoring capabilities and the establishment of standards, thresholds and rules to more adequately address the air quality impacts of plans and proposals proposed by the County.

AQ-16 Prohibit the idling of on- and off-road engines when the vehicle is not moving or when the off-road equipment is not performing work for a period of time greater than five minutes in anyone-hour period.

AQ-17 Promote optimal air quality benefits through energy conservation measures in new development.

AQ-19. Require all feasible reductions in emissions for the operation of construction vehicles and equipment on major land development and roadway construction projects.

AQ-20 Promote Cool Community strategies to cool the urban heat island, reduce energy use and ozone formation, and maximize air quality benefits by encouraging four main strategies including, but not limited to: plant trees, selective use of vegetation for landscaping, install cool roofing, and install cool pavements.
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AQ-21 Support SMAQMD’s particulate matter control measures for residential wood burning and fugitive dust.

CIRCULATION
CI-40 Whenever possible, the applicant/developer of new and infill development projects shall be conditioned to fund, implement, operate and/or participate in TSM [Transportation Systems Management] programs to manage travel demand associated with the project.

CI-41 Consider TSM programs that increase the average occupancy of vehicles and divert automobile commute trips to transit, walking, and bicycling.

CI-43 The County shall promote transit-supportive programs in new development, including employer-based trip-reduction programs (employer incentives to use transit or non-motorized modes), “guaranteed ride home” for commute trips, and car-share or bike-share programs.

CI-67 When feasible, incorporate lighter colored (higher albedo) materials and surfaces, such as lighter-colored pavements, and encourage the creation of tree canopy to reduce the built environment’s absorption of heat to reduce the urban “heat island” effect.

ENERGY
EN-5 Reduce travel distances and reliance on the automobile and facilitate increased use of public transit through appropriate land use plans and regulations.

LAND USE
LU-27 Provide safe, interesting and convenient environments for pedestrians and bicyclists, including inviting and adequately-lit streetscapes, networks of trails, paths and parks and open spaces located near residences, to encourage regular exercise and reduce vehicular emissions.

LU-37 Provide and support development of pedestrian and bicycle connections between transit stations and nearby residential, commercial, employment or civic uses by eliminating physical barriers and providing linking facilities, such as pedestrian overcrossings, trails, wide sidewalks and safe street crossings.

LU-40 Employ appropriate traffic calming measures in areas where pedestrian travel is desirable but made unsafe by a high volume or excessive speed of automobile traffic. Preference shall be given to measures that slow traffic and improve pedestrian safety while creating the least amount of conflict with emergency responders.

LU-42 Master planning efforts for new growth areas shall provide for separated sidewalks along all arterials and thoroughfares to make walking a safer and more attractive transportation option.
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SACRAMENTO COUNTY CLIMATE ACTION PLAN
On November 9, 2011, the County of Sacramento adopted the Climate Action Plan – Strategy and Framework document, which presented a framework for reducing GHG emissions and developing a second phase of the Climate Action Plan (CAP). On September 11, 2012, the Board of Supervisors adopted the Climate Action Plan – Government Operations, which identifies GHG emissions associated with government operations and develops sector-level measures to reduce these GHG emissions. The County is currently working to develop the Communitywide CAP to address communitywide emissions. While the County of Sacramento CAP focuses specifically on reducing GHGs, many of the plan’s measures have the potential to improve air quality as well. The County is currently in the process of updating the CAP after a hearing at the Board of Supervisors held in September 2022. The County also is preparing a Subsequent EIR to analyze the potential impacts associated with the revisions to the September 2022 CAP.

IMPACTS AND ANALYSIS

SIGNIFICANCE CRITERIA
For purposes of this EIR and consistent with the criteria presented in Appendix G of the CEQA Guidelines, impacts related to air quality may be considered significant if implementation of the proposed UWSP would:
 Conflict with or obstruct implementation of the applicable air quality plan;  Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard;
 Expose sensitive receptors to substantial pollutant concentrations; or  Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

SMAQMD has developed significance thresholds to help lead agencies determine whether a project may have a significant air quality impact. Projects whose emissions are expected to exceed the recommended significance criteria will have a potentially significant adverse impact on air quality. SMAQMD is delegated by CARB to manage air quality in the SVAB and the recommended thresholds are considered reasonable and appropriate for this project.

CRITERIA AIR POLLUTANTS
SMAQMD has established mass emissions thresholds for ozone precursors (i.e., NOX and ROG), PM10, and PM2.5 as the Sacramento region does not meet the state and federal ozone and state particulate matter (PM10 and PM2.5) ambient air quality standards.
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For purposes of this EIR, and consistent with SMAQMD guidance, impacts related to air quality may be considered significant if development allowed under the proposed UWSP would result in the following:
 Short-term (construction) emissions of NOX above 85 lbs./day;  Short-term (construction) emissions of PM10 above zero lbs./day without implementation of all best management practices (BMPs) and above 80 lbs./day or 14.6 tons per year after implementation of all BMPs;  Short-term (construction) emissions of PM2.5 above zero lbs./day without implementation of all BMPs and above 82 lbs./day or 15 tons per year after implementation of all BMPs;
 Long-term (operational) emissions of NOX or ROG above 65 lbs./day;  Long-term (operational) emissions of PM10 above zero lbs./day without implementation of all BMPs and above 80 lbs./day or 14.6 tons per year after implementation of all BMPs;
 Long-term (operational) emissions of PM2.5 above zero lbs./day without implementation of all BMPs and above 82 lbs./day or 15 tons per year after implementation of all BMPs;
 CO concentrations that exceed the 1-hour state ambient air quality standard (i.e.,

20.0 ppm) or the 8-hour state ambient standard (i.e., 9.0 ppm)

TOXIC AIR CONTAMINANTS
The construction or operation of any project with the potential to expose sensitive receptors to substantial levels of TACs (such as DPM) would be deemed to have a potentially significant impact. In the absence of adopted SMAQMD TAC significance thresholds for land use development projects such as the UWSP, this analysis uses the following Bay Area Air Quality Management District (BAAQMD) significance thresholds to determine whether the project would result in a significant health risk impact (BAAQMD 2022):
 An increase in cancer risk greater than 10.0 in one million;  An increase in Hazard Index1 greater than 1.0; or
 An increase in PM2.5 annual average concentration greater than 0.3 micrograms per cubic meter (µg/m3).

1 Non-cancer adverse health risk, both for acute (short-term) and chronic (long-term) risk, is measured against a hazard index, which is defined as the ratio of the predicted incremental exposure concentration from a proposed project to a published reference exposure level that could cause adverse health effects as established by Office of Environmental Health Hazard Assessment. The ratio (referred to as the Hazard Quotient) of each non-carcinogenic substance that affects a certain organ system is added to produce an overall hazard index for that organ system. 6 - Air Quality
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In addition, based on the programmatic nature of the proposed UWSP, impacts associated with TACs are analyzed based on buffer zones between sensitive receptors and existing and proposed land uses that emit TACs in accordance with the recommendations provided in CARB’s Air Quality and Land Use Handbook:

A Community Health Perspective. For locating sensitive receptors (residences, schools, day care centers, and medical facilities) along a major roadway, SMAQMD has established a screening protocol whereby new residential uses located more than 500 feet from the nearest high-traffic-volume roadway (defined as a freeway or urban roadway with greater than 100,000 vehicles per day) would meet the CARB guidance distance and no further roadway-related air quality evaluations are recommended (SMAQMD 2011).

ODORS
Odor impacts are addressed in a qualitative manner based on screening distances and odor complaints, as recommended in SMAQMD guidance. This includes a discussion of whether a project would result in excessive nuisance odors, or whether proposed sensitive land uses would be exposed to substantial odors.

ISSUES NOT DISCUSSED
Expose sensitive receptors to substantial concentrations of CO emissions – Due to the designation of the SVAB as an attainment/maintenance area with respect to the CO standards, SMAQMD no longer requires modeling of project CO emissions for comparison with the ambient air quality standard. According to SMAQMD guidance, in general, land use development projects do not typically have the potential to result in localized concentrations of criteria air pollutants including CO that expose sensitive receptors to substantial pollutant concentrations. This is because these emissions are predominantly generated in the form of mobile-source exhaust from vehicle trips associated with the land use development project that occur throughout a paved network of roads. Associated exhaust emissions therefore are not generated in a single location where high concentrations could be formed (SMAQMD 2009). For these reasons, CO impacts that could occur under development allowed under the proposed UWSP would be considered less than significant, and this issue is not evaluated further in this EIR.

METHODOLOGY AND ASSUMPTIONS
The following analysis is based on guidance from the SMAQMD provided in the Guide to Air Quality Assessment in Sacramento County (SMAQMD 2020a). The air district’s guidelines identify different approaches to analyzing plans versus projects. Methodology for emissions calculations and determination of impacts were qualified by Raney in its technical report and inform the analysis for this EIR chapter (see Appendix AQ-1).

Project-related air quality impacts fall into two categories: short-term impacts due to construction and long-term impacts due to project operation. The proposed UWSP would be constructed in phases over the course of approximately 20 years.

Construction under the UWSP would begin with Phase 1, which is anticipated to be 6 - Air Quality
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constructed over approximately seven years. Subsequent phasing for the remaining project areas would occur in response to market demand; therefore, the timing of the subsequent phases is unknown. Nevertheless, to disclose the total project construction emissions, emissions associated with Phase 1 and the subsequent phases were estimated.

Construction activities associated with development allowed under the proposed UWSP would generate criteria air pollutants primarily from the combustion of fuel in construction equipment and vehicle trips associated with worker commutes, material delivery, and material hauling. In addition, construction activities would increase local particulate concentrations due to fugitive dust generated from ground disturbance activities and vehicle travel on unpaved surfaces. Once the UWSP area is fully developed, operational emissions would occur. These would result primarily from motor vehicle trips generated by the land uses developed under the proposed UWSP.

Operational emissions would also be generated from natural gas combustion and area sources such as landscaping and consumer product use. The single-family residential uses portion of the proposed UWSP would not include natural gas infrastructure but this analysis assumes natural gas infrastructure may be included for the high-density residential uses. In addition, the commercial uses and the high school and community college components are proposed to be served with natural gas.

CONSTRUCTION IMPACTS
The emissions generated from construction activities include the following:
 Exhaust emissions from fuel combustion for mobile heavy-duty diesel and gasoline-powered equipment (including construction equipment and employee vehicles).
 Particulate matter from soil disturbance and site preparation and grading activity (also known as fugitive dust).
 Evaporative emissions of ROG from paving activity and the application of architectural coatings.

Construction emissions were estimated using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. Project-specific inputs to the model included types and sizes of land uses proposed for construction, site area, demolition area, infill and off haul volumes, and starting year and duration of construction. CalEEMod defaults were used for duration of the various construction phases, types, number and activity level of equipment used under each phase as well as worker and truck trips associated with each phase.

Accordingly, the Phase 1 construction modeling assumed the following:
 Construction would occur over an approximately seven-year period.  Approximately 122,570 cubic yards of material would be exported during site preparation.
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 The timing of each phase of construction was adjusted based on applicantprovided information.  The amount of construction equipment was doubled to account for the size of the construction area and the construction timing.

As noted above, construction of Phase I of the proposed UWSP would represent the most emissions-intensive phase, and construction of the remainder of the proposed UWSP would occur in response to market demand. Thus, the construction timing of subsequent phases is unknown. Nonetheless, to disclose total construction emissions from the proposed UWSP, modeling was conducted to represent build-out of the remainder of the proposed UWSP. The modeling assumed construction of all remaining land uses, excluding those built during Phase I. The construction modeling of the remainder of the project assumed the following:
 Construction would commence in August 2030 and would occur over an approximately 14-year period.
 The timing of each phase of construction was based on the applicant-provided timing for Phase I, and proportionally scaled to occur over the 14-year construction period.
 The amount of construction equipment was doubled to account for the size of the construction area and the construction timing.

Table AQ-5 provides the specific timeline assumptions used to model UWSP construction emissions. As shown in the table, the timeline modeling assumptions for Phase 1 and the subsequent phases do not overlap, and combined duration of UWSP construction activities was modeled over an approximately 21.5-year period. This modeled period amounts to a slightly longer period than the 20-year build-out period described for the UWSP in the Phasing discussion in Chapter 2, Project Description.

Table AQ-5: Construction Emissions Modeling Timeline Assumptions Construction Phase Start Date End Date Duration
Phase 1 June 1, 2023 July 31, 2030 7.2 years
Subsequent Phases August 1, 2030 November 30, 2044 14.3 years All Construction Phases June 1, 2023 November 30, 2044 21.5 years SOURCE: Raney 2024.

As indicated in Table AQ-5, the modeled start date for Phase 1 has already occurred.

The actual start date for Phase 1 would occur at some future date, and all subsequent dates would extend out relative to the phase duration; however, given that modeled emissions tend to decrease year over year due to increased equipment and vehicle efficiencies, the outdated modeled emissions represent a conservative analysis. 6 - Air Quality
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Other project-specific assumptions and default CalEEMod settings used to estimate emissions can be found in the CalEEMod outputs included in the Raney technical report (see Appendix A of Appendix AQ-1). Estimated construction-related emissions of criteria air pollutants are then compared to SMAQMD’s applicable regional significance thresholds to determine impacts.

OPERATIONAL IMPACTS
Operation of development allowed under the proposed UWSP would increase emissions of ozone precursors (ROG and NOX), PM10, and PM2.5, from vehicle trips and area sources (e.g., landscape maintenance and consumer products such as cleaning products). Operational emissions for the UWSP were estimated for a single year associated with existing conditions in 2045 and with full build-out of the proposed UWSP in 2045, using CalEEMod version 2020.4.0. The difference in emissions between these two scenarios represents the incremental increase in criteria pollutant emissions associated with the proposed UWSP. To model existing conditions associated with area, energy, mobile, waste, and water sources, existing land use characteristics and vehicle trip generation rates from the Trip Generation Memorandum prepared by Fehr and Peers were utilized. To model the proposed UWSP, the proposed land uses and associated vehicle trip generation rates from the Trip Generation Memorandum prepared by Fehr and Peers were utilized (Fehr and Peers 2022).

Compliance with the 2022 California Green Building Standards Code (CALGreen) and the adopted Model Water Efficiency Landscape Ordinance was assumed in the modeling. Estimated operational emissions are compared to the appropriate SMAQMD significance thresholds for operation. Also, in recognition of the California Supreme Court’s Friant Ranch decision, SMAQMD’s Strategic Area Project Health Screening Tool (SMAQMD 2020b) was used to quantify health effects that would result from the emissions of criteria pollutants that would be generated during operation of the project.

HEALTH RISK ASSESSMENTS
Although there are no sensitive receptors currently within the proposed UWSP Phase I area, there would be new, on-site receptors including residences and/or schools present as the build-out of each phase occurs. Construction and operation health risk assessments (HRAs) were prepared for the project. An HRA is a quantitative analysis of a project’s TAC emissions and the resulting health risks associated with exposure of nearby sensitive receptors to these TAC emissions. The HRAs follow the latest Air Toxics Hot Spots Program Guidance protocol from the Office of Environmental Health Hazard Assessment (OEHHA) (2015). The HRAs calculate health risks resulting from the project consistent with SMAQMD guidelines, using technical information from the SMAQMD, California Air Pollution Control Officers Association, CARB, OEHHA, BAAQMD, and USEPA. Consistent with guidelines and recommendations from these agencies, the HRAs evaluate the estimated increase in lifetime cancer and hazard index risks from exposure to emissions of TACs, such as DPM that would be emitted by project-related sources, including off-road construction equipment and on-road haul trucks. Based on guidance from BAAQMD, the HRAs also evaluate the increase in PM2.5 annual average concentrations from project sources. 6 - Air Quality
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SMAQMD recommends that lead agencies make an effort to obtain detailed projectspecific information to accurately disclose all potential TAC-related impacts of a project.

However, the SMAQMD understands that the information needed to prepare a projectlevel HRA may not be available at the time of analysis (SMAQMD 2020a).

CONSTRUCTION
A worst-case scenario was modeled using construction emissions associated with the construction of Phase 1, and off-site sensitive receptors were assumed to be along the perimeter of the Phase 1 construction area. An additional receptor was placed in the center of the Phase 1 construction area to represent new, on-site sensitive receptors that would be exposed to emissions associated with subsequent phases of the proposed UWSP in combination with the Phase 1 construction. The combination of the two receptor locations represents the maximum possible exposure to any one receptor, between existing off-site and new on-site, through the course of the 20-year development associated with the proposed UWSP. Although these are hypothetical receptor locations, they represent sensitive receptor locations where exposure to the most emissions-intensive phase of construction could occur. The total PM2.5 exhaust emissions from the construction of Phase 1 were estimated to analyze the potential health risks from DPM to nearby receptors. DPM concentrations were estimated using AERMOD. Associated cancer risk and non-cancer hazard index were calculated following the 2015 OEHHA Guidance Manual for Preparation of Health Risk Assessments using CARB’s Hotspot Analysis Reporting Program Version 2 (HARP 2) Risk Assessment Standalone Tool (RAST).

Only the off-site sensitive receptor locations with the highest pollutant concentrations along the perimeter of the Phase 1 construction area were used when calculating the cancer risks, hazard indices, and PM2.5 concentrations. The sensitive receptor along the perimeter of the Phase 1 construction area that would experience the highest estimated pollutant concentrations is the off-site maximally exposed individual receptor (MEIR) and would experience the highest potential health risks among the sensitive receptors along the perimeter of the Phase 1 construction area. Health risks to all other off-site receptors along the perimeter of the site would be lower than the health risks to the MEIR, because all other receptors would be exposed to lower concentrations of construction-related pollutants as compared to the off-site MEIRs.

Additionally, considering that both schools and residences would exist near the construction area, the HRA conservatively assumes that sensitive nearby receptors would be continuously exposed to pollutants from construction at the maximum estimated concentrations. This assumption would represent a scenario whereby a resident living nearby also attends one of the nearby schools and is therefore exposed to pollutants both at home and at school. In reality, exposure to pollutants at nearby schools would be much less than the exposure of pollutants at the MEIR locations due to the decreased amount of time people tend to spend at schools compared to time spent at home. Due to the difference in pollutant concentrations at the MEIR locations and nearby schools, a single receptor would not be anticipated to be continuously exposed to the maximum level of pollutant concentrations both at home and at school.

Nevertheless, by using the maximum estimated concentrations and assuming 6 - Air Quality
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continuous exposure to pollutants, the estimated health risks presented below are considered a worst-case estimate of potential health risks, and actual health risks to sensitive receptors in the UWSP area would be lower than the levels presented below.

OPERATION
An operational HRA was also prepared for the project. It evaluates the health risks that would be associated with project-related operational sources (mobile sources of TAC emissions). Health risks associated with the operation of land uses allowed under the proposed UWSP were assessed by estimated TAC emissions from I-80.

Based on the SMAQMD’s Mobile Sources Air Toxics Protocol Tool, the estimated cancer risk per million persons and annual average PM2.5 concentrations from I-80 were estimated at the nearest sensitive receptor locations (SMAQMD 2023). The annual average PM2.5 concentration was used as input in the HARP 2 RAST software, over an assumed 30-year exposure period, to estimate the chronic hazard index at the sensitive receptors near I-80.

SMAQMD’s Mobile Sources Air Toxics Protocol Tool uses car and truck emission factors from the CARB’s EMission FACtor database, known as EMFAC, for vehicles within Sacramento County and assumes future emission reductions due to technological advancements.

Although the SMAQMD has not adopted a specific TAC or health risk threshold from land use projects, due to the proposed proximity of sensitive receptors to I-80, the proposed UWSP would be required to comply with the SMAQMD’s Landscaping Guidance for Improving Air Quality Near Roadways as a condition of project approval (SMAQMD 2020c).

IMPACT AQ-1: CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF AN

APPLICABLE AIR QUALITY PLAN
Development allowed under the proposed UWSP would be required to be consistent with Sacramento County policies, including Policies AQ-3, AQ-4, AQ-10, AQ-13, AQ-14, and AQ-21, because all recommended SMAQMD mitigation measures would be implemented during construction and operation, including the preparation and implementation of an AQMP as discussed below. Therefore, this analysis focuses on the potential for the project to conflict with or obstruct implementation of an applicable SMAQMD air quality plan.

The Sacramento Regional 2008 8-Hour Ozone Attainment and Reasonable Further Progress Plan (SMAQMD 2017a) addresses attainment of the federal 8-hour ozone standard, while the Triennial Report and Air Quality Plan Revision (SMAQMD 2015) and the 2016 Annual Progress Report (SMAQMD 2017b) address attainment of the California 1-hour and 8-hour ozone standards. These are the latest plans issued by the SMAQMD, and they incorporate land use assumptions and travel demand modeling from SACOG. The project’s estimated emissions associated with construction and 6 - Air Quality
Upper Westside Specific Plan 6-32 PLNP2018-00284
operations are presented and discussed in further detail below, because this is how the impact relative to the air quality plan is evaluated.

CONSTRUCTION
According to the SMAQMD, land use development projects that exceed emissions of 85 lbs./day of NOX or 65 lbs./day of ROG during construction would have the potential to obstruct the success of the regional ozone attainment plans and would therefore be considered significant and require mitigation. It is noted that the project would be required to comply with all SMAQMD rules and regulations for construction, which would be noted on County-approved construction plans, with compliance ensured as a condition of approval for the proposed UWSP. The applicable rules and regulations would include, but would not be limited to, the following:
 Rule 403 related to Fugitive Dust.
 Rule 404 related to Particulate Matter.
 Rule 407 related to Open Burning.
 Rule 442 related to Architectural Coatings.
 Rule 453 related to Cutback and Emulsified Asphalt Paving Materials.  Rule 460 related to Adhesives and Sealants.

To apply the PM10 and PM2.5 thresholds presented under Significance Criteria above, projects must implement all feasible SMAQMD Best Available Control Technologies (BACTs) and BMPs related to dust control. In the case of construction activities, projects are required to implement the SMAQMD’s identified Basic Construction Emissions Control Practices, which are considered by the SMAQMD to be the applicable construction BMPs. The following Basic Construction Emissions Control Practices are considered feasible and would be applicable to development allowed under the proposed UWSP for dust control:
 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.  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. 6 - Air Quality
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 Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to five minutes (California Code of Regulations, Title 13, Sections 2449[d][3] and 2485). Provide clear signage that posts this requirement for workers at the entrances to the site.
2  Provide current certificate(s) of compliance for CARB’s In-Use Off-Road DieselFueled Fleets Regulation (California Code of Regulations, Title 13, Sections 2449 and 2449.1).3
 Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determined to be running in proper condition before it is operated.

The control of fugitive dust during construction is required by SMAQMD Rule 403 and enforced by SMAQMD staff. Emissions of ROG, NOX, PM10, and PM2.5 from construction are discussed below under the heading Impact: Construction Emissions of Criteria Air Pollutants and Precursors. As shown in Tables AQ-6 and AQ-8 below, project construction NOX emissions would exceed the applicable significance threshold.

Therefore, the construction impact would be potentially significant. Mitigation Measure AQ-1a, as detailed below, includes requirements to be implemented during construction activities, including idling restrictions, engine maintenance requirements, use of low-emissions engines (i.e., Tier 4 Final), and a requirement that all portable equipment over 50 horsepower have either a valid SMAQMD permit or a valid statewide Portable Equipment Registration Program placard and sticker issued by CARB. As shown in Table AQ-7 below, mitigated NOX emissions would not be expected to exceed the applicable significance thresholds. Therefore, the proposed UWSP’s construction impact would be mitigated to less than significant.

OPERATION
As discussed above, due to the nonattainment designations of the area, the SMAQMD has developed plans to attain the state and federal standards for ozone and particulate matter. The current applicable air quality plan for the UWSP area is the Sacramento Regional 2008 NAAQS 8-Hour Ozone Attainment and Reasonable Further Progress Plan (Ozone Attainment Plan), updated July 24, 2017. The Ozone Attainment Plan demonstrates how existing and new control strategies would provide the necessary future emission reductions to meet the CAA requirements, including the NAAQS.

Adopted SMAQMD rules and regulations, as well as the thresholds of significance, have been developed with the intent to ensure continued attainment of the CAAQS and NAAQS, or to work toward attainment of the CAAQS and NAAQS for which the area is currently designated nonattainment, consistent with the applicable air quality plan. Thus, if a project’s operational emissions exceed the SMAQMD’s mass emission thresholds, a

2 This BMP for dust control specifically applies to diesel-powered equipment. Non-diesel vehicles are not required to limit idling time.
3 This BMP for dust control specifically applies to diesel-powered equipment. 6 - Air Quality
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project would be considered to conflict with or obstruct implementation of the SMAQMD’s air quality planning efforts.

For operations, land use development projects that exceed emissions of 65 lbs./day of ROG or NOX during operational activities would have the potential to obstruct the success of the regional ozone attainment plans and would therefore be considered significant and require mitigation.

The estimated net new operational emissions associated with proposed UWSP are discussed below under the heading Impact: Long-Term Operational Emissions of Criteria Air Pollutants and Precursors. It should be noted that development allowed under the proposed UWSP would not involve installation or operation of any pieces of equipment that would require implementation of SMAQMD’s BACTs; therefore, individual projects would only be subject to SMAQMD’s mass emissions thresholds for PM10 and PM2.5.
4 Overall, net new unmitigated operational emissions associated with the proposed UWSP would exceed the applicable thresholds of significance for all criteria pollutants (see Table AQ-9, below). Therefore, operation of the proposed UWSP would be considered to conflict with or obstruct implementation of the SMAQMD’s air quality planning efforts, and this impact would be potentially significant.

When operational emissions exceed significance thresholds, the Sacramento County General Plan requires the development of an AQMP to minimize impacts, with guidance and suggested measures included in the Recommended Guidance for Land Use Emission Reductions Version 4.0 (for Operational Emissions) (SMAQMD 2021a). As discussed previously in the Regulatory Setting above, the Sacramento County General Plan includes Policy AQ-4, which requires preparation of an AQMP to address potentially significant impacts that would be associated with the proposed UWSP. This can be found in the appendix of the Raney technical report, which applied this standard.

The AQMP has been reviewed and deemed technically adequate by the SMAQMD (SMAQMD 2024) and has been approved by the County.

Mitigation Measure AQ-1b, as detailed below, would require that the project applicant comply with the provisions of the AQMP, and provides a list of all feasible measures that the proposed UWSP can implement to reduce operational emissions. However, as shown in Table AQ-10, below, emission levels would still exceed the applicable thresholds of significance for all analyzed pollutants even with the implementation of the AQMP; therefore, the impact would remain significant and unavoidable.

4 Although not anticipated, should the proposed UWSP include land uses or pieces of equipment that would require implementation of SMAQMD’s BACTs (e.g., boiler, crematory, automotive spray painting, dry cleaning, pharmaceutical manufacturing), each stationary source would require an operational permit issued by SMAQMD. As part of the permitting process, compliance with the identified BACTs would be required. Thus, the thresholds of significance for PM emissions remain applicable. 6 - Air Quality
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MITIGATION MEASURES
AQ-1a Prior to the initiation of ground disturbance, the project applicant shall ensure that all heavy-duty off-road diesel-powered equipment to be used in the construction of the project (including owned, leased, and subcontractor equipment) shall be CARB Tier 4 Final or cleaner. Portable equipment over 50 horsepower must have either a valid District Permit to Operate or a valid statewide Portable Equipment Registration Program placard and sticker issued by CARB for equipment tracking purposes. These requirements shall also be included on improvement plans and submitted for review and approval by Sacramento County.

AQ-1b Prior to the approval of project improvement plans, the project applicant shall comply with the provisions of the SMAQMD AQMP prepared for the proposed UWSP and incorporate all requirements into the UWSP’s conditions of approval. The measures included in the AQMP are summarized as follows:
 Natural gas use shall be prohibited in all residential land uses; and  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 Sacramento County and SMAQMD:
- The TMA must be legally constituted as a non-profit organization, a Property/Business Improvement District, or a government entity with a non-revocable funding mechanism, such as a community finance district, dedicated to TMA operations and services.
- The TMA must provide a minimum level of transportation demand management services to employees and residents within the area 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.

In addition to the measures identified in the AQMP, the following measures shall also be implemented:
 Super-Compliant VOC Architectural Coatings during Operation.

Project sponsors shall include in all building rules and/or building operation plans (as applicable, depending on the parcel) a requirement that all future interior and exterior spaces be repainted only with “super-compliant” VOC (i.e., ROG) architectural coatings beyond SMAQMD requirements (i.e., Rule 442: Architectural Coatings). “Supercompliant” coatings refer to paints that meet the more stringent regulatory limits in South Coast Air Quality Management District Rule 1113, which requires a standard of 10 grams VOC per liter or less
(http://www.aqmd.gov/home/regulations/compliance/architecturalcoatings/super-compliant-coatings). Project sponsors shall be required to submit documentation to the County demonstrating compliance with this 6 - Air Quality
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measure. With regard to third-party occupant owners and tenants, compliance with this measure shall be enforced through homeowner association rules and bylaws and tenant agreements that identify this project requirement.
 Best Available Emissions Controls for Stationary Emergency Generators. To reduce emissions of ROG, NOX, and TACs associated with operation of future projects, project applicants shall implement the following measures. These features shall be submitted to the County for review and approval, and shall be included on the project drawings submitted for the construction-related permit(s) or on other documentation submitted to the County prior to the issuance of any building permits:
- Permanent stationary emergency generators installed on-site shall have engines that meet or exceed CARB Tier 4 Off-Road Compression Ignition Engine Standards (California Code of Regulations Title 13, Section 2423). If CARB adopts future emissions standards that exceed the Tier 4 requirement, the emissions standards resulting in the lowest ROG and DPM emissions shall apply.
- As non-diesel-fueled emergency generator technology becomes readily available and cost effective in the future, and subject to the review and approval of the County fire department for safety purposes, non-diesel-fueled generators shall be installed in new buildings, provided that alternative fuels used in generators, such as biodiesel, renewable diesel, natural gas, or other biofuels or other non-diesel emergency power systems, are demonstrated to reduce ROG, NOX, and DPM emissions compared to diesel fuel.
- For each new diesel backup generator permit submitted to the air district, project applicants shall submit the anticipated location and engine specifications to the planning department for review and approval prior to issuance of a permit for the generator. Once operational, all diesel backup generators shall be maintained in good working order for the life of the equipment, and any future replacement of the diesel backup generators must be consistent with these emissions specifications. The operator of the facility at which the generator is located shall maintain records of the testing schedule for each diesel backup generator for the life of that diesel backup generator and shall provide this information for review to the planning department within three months of requesting such information.  Promote Use of Green Consumer Products. To reduce ROG emissions associated with future projects, project sponsors shall provide education for residential and commercial tenants concerning green consumer products. Prior to receipt of any certificate of occupancy, project sponsors shall develop electronic correspondence to be distributed by email annually and upon any new lease signing to residential and/or commercial tenants of each building on the project site that encourages the purchase of 6 - Air Quality
Upper Westside Specific Plan 6-37 PLNP2018-00284
consumer products that generate lower than typical VOC emissions. The correspondence shall encourage environmentally preferable purchasing.  Operational Truck Emissions Reduction. Project sponsors shall incorporate the following measures into the project design and construction contracts (as applicable) to reduce ROG and NOX emissions associated with operational trucks, along with the potential health risk caused by exposure to TACs. These features shall be submitted to the planning department for review and approval prior to the issuance of building permits and shall be included on the project drawings submitted for the construction-related permit or on other documentation submitted to the County. Emissions from project-related diesel trucks shall be reduced by implementing the following measures:
- Equip all truck delivery bays with electrical hook-ups for diesel trucks at loading docks to accommodate plug-in electric truck transport refrigeration units (TRUs) or auxiliary power units during project operations.
- Provide a notice on the lease to all new tenants or owners of the project or any portion thereof requiring any truck-intensive uses on the site, such as large grocery stores or distribution facilities with their own fleet of trucks, to use TRUs and auxiliary power units that are electric plug-in capable and trucks that use advanced exhaust technology (e.g., hybrid) or alternative fuels.
- Encourage the use of trucks equipped with diesel TRUs to meet U.S.

Environmental Protection Agency Tier 4 emission standards. - Prohibit TRUs from operating at loading docks for more than 30 minutes, and post signs at each loading dock presenting this TRU limit. - Prohibit trucks from idling for more than two minutes, and post “no idling” signs at the site entry point, at all loading locations, and throughout the project site.
 Electric Vehicle Charging Infrastructure. Prior to the issuance of a certificate of occupancy for any project structure with parking, the project applicant shall demonstrate compliance with the 2022 CALGreen Tier 2 voluntary electric vehicle (EV) charging requirements or the mandatory requirements of the most recently adopted version of the County building code, whichever is more stringent. The installation of all EV charging equipment shall be included on project drawings submitted for construction-related permit(s) or on other documentation submitted to the County.
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IMPACT AQ-2: CONSTRUCTION EMISSIONS OF CRITERIA AIR POLLUTANTS

AND PRECURSORS
Construction activities associated with the proposed UWSP have the potential to create air quality impacts through heavy-duty construction equipment operation, construction workers’ vehicle trips, truck hauling trips, and vendor truck trips. In addition, fugitive dust emissions would result from site disturbance activities such as grading, excavation, and vehicle travel on unpaved roads. Fugitive ROG emissions would result from the application of architectural coatings and paving. Mobile equipment such as excavators, graders, backhoes, loaders, crushing equipment, pavers, water trucks, and forklifts would be used for demolition, excavation, and grading, as well as for building construction and hardscape and landscape materials installation.

The proposed UWSP would be required as a County condition of approval to comply with the following SMAQMD rules and regulations for construction:
 Rule 403 related to Fugitive Dust.
 Rule 404 related to Particulate Matter.
 Rule 407 related to Open Burning.
 Rule 442 related to Architectural Coatings;
 Rule 453 related to Cutback and Emulsified Asphalt Paving Materials.  Rule 460 related to Adhesives and Sealants.

In addition, all construction associated with the proposed UWSP would be required to comply with all SMAQMD Basic Construction Emissions Control Practices.

Construction emissions were estimated for the proposed UWSP using the methods contained in SMAQMD’s Guide to Air Quality Assessment in Sacramento County (SMAQMD 2021b). The CalEEMod model was used to quantify construction ROG, NOX, PM10, and PM2.5 emissions from off-road equipment, haul trucks associated with demolition and imported soils, on-road worker vehicle emissions, and vendor delivery trips.

PHASE 1 EMISSIONS
The worst-case unmitigated construction emissions for Phase 1 are presented in Table AQ-6. The table also compares estimated emissions to SMAQMD’s NOX, PM10, and PM2.5 construction thresholds. Even though SMAQMD does not have a significance threshold for construction ROG emissions, they were modeled and shown in Table AQ-6 for informational purposes only.

As shown in Table AQ-6, unmitigated NOX emissions are expected to exceed the applicable significance threshold, and thus the impact associated with construction emissions during Phase 1 would be potentially significant. 6 - Air Quality
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Table AQ-6: Unmitigated Maximum Project Construction Emissions – Phase 1 ROG
(lbs/day)
NOX
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
PM10
(tpy)
PM2.5
(tpy)
Phase 1 53 316 41 22 4.2 1.3
SMAQMD Threshold1 N/A 85 80 82 14.6 15
Significant (Yes or No)? Yes No No No No
NOTES:
lbs/day = pounds per day; NOX = nitrogen oxides; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ROG = reactive organic gases; SMAQMD = Sacramento Metropolitan Air Quality Management District; tpy = tons per year.

Project construction emissions estimates were made using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. See Appendix AQ-1 for model outputs and more detailed assumptions.

Values in bold are in excess of the applicable SMAQMD significance threshold. 1 SMAQMD’s non-zero emissions thresholds for PM10 and PM2.5 to assess the project’s unmitigated emissions.

SOURCE: Raney 2024.

Mitigation Measure AQ-1a, as detailed above, includes requirements to be implemented during construction activities, including idling restrictions and engine maintenance requirements, use of low-emissions engines (e.g., Tier 4 Final), and a requirement that all portable equipment over 50 horsepower have either a valid SMAQMD permit or a valid statewide Portable Equipment Registration Program placard and sticker issued by CARB.

Mitigated maximum daily construction emissions for Phase 1 are shown in Table AQ-7, assuming that all construction equipment used for construction activities would use engines that meet USEPA’s Tier 4 Final standards (as required by Mitigation Measure AQ-1a above).

With the implementation of Mitigation Measure AQ-1a, maximum NOX emissions would be reduced by 78 percent due to the use of Tier 4 Final heavy-duty off-road dieselpowered equipment and would be below the threshold for this criteria pollutant precursor; therefore, the impact with respect to construction emissions would be mitigated to less than significant.

SUBSEQUENT PHASES AND OFFSITE IMPROVEMENTS EMISSIONS
Emissions associated with subsequent construction phases for the remainder of the project are shown in Table AQ-8. As shown in Table AQ-8, unmitigated NOX emissions are also expected to exceed the applicable significance thresholds, similar to Phase 1, and thus, the impact associated construction emissions during subsequent phases would be potentially significant.
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Table AQ-7: Mitigated Maximum Project Construction Emissions – Phase 1 ROG
(lb/day)
NOX
(lb/day)
PM10
(lb/day)
PM2.5
(lb/day)
PM10
(tpy)
PM2.5
(tpy)
Phase 1 50 68 38 20 4.1 1.1
SMAQMD Thresholds
1 N/A 85 80 82 14.6 15
Significant (Yes or No)? No No No No No
NOTES:
lb/day = pounds per day; NOX = nitrogen oxides; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ROG = reactive organic gases; SMAQMD = Sacramento Metropolitan Air Quality Management District; tpy = tons per year.

Project construction emissions estimates were made using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. See Appendix AQ-1 for model outputs and more detailed assumptions. 1 SMAQMD’s non-zero emissions thresholds for PM10 and PM2.5 to assess the project’s mitigated emissions.

SOURCE: Raney 2024.

Table AQ-8: Unmitigated Maximum Project Construction Emissions – Subsequent Phases
ROG
(lbs/day)
NOX
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
PM10
(tpy)
PM2.5
(tpy)
Remainder of Project 55 104 47 13 6.0 1.7
SMAQMD Thresholds
1 N/A 85 80 82 14.6 15
Significant (Yes or No)? Yes No No No No
NOTES:
lbs/day = pounds per day; NOX = nitrogen oxides; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ROG = reactive organic gases; SMAQMD = Sacramento Metropolitan Air Quality Management District; tpy = tons per year. 1 SMAQMD’s non-zero emissions thresholds for PM10 and PM2.5 to assess the project’s unmitigated emissions.

Project construction emissions estimates were made using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. See Appendix AQ-1 for model outputs and more detailed assumptions.

Values in bold are in excess of the applicable SMAQMD significance threshold.

SOURCE: Raney 2024.
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Additionally, as depicted on Plate PD-20, the proposed UWSP would include offsite roadway and utility improvements that were not specifically accounted for or included in the construction emissions estimates provided in Tables AQ-6 through AQ-8, above, due to the lack of adequate detail in information about the improvements. However, as noted under the Construction Impacts heading in the Methodology and Assumptions discussion, above, the construction emissions modeling conducted for Phase 1 and subsequent phases use very conservative assumptions, including a doubling of the amount of construction equipment relative to the CalEEMod default equipment amounts for those phases. It is reasonable to conclude that the proposed offsite improvements would result in similar or fewer construction equipment activities compared to those required for Phase 1 and the subsequent phases. Therefore, for the purposes of this analysis, the estimated emissions presented in Tables AQ-6 through AQ-8 are also presumed to represent emissions that would be associated with the proposed offsite improvements, and the proposed offsite improvements would contribute to the potentially significant construction emissions impact. The UWSP would be responsible for funding and implementing the proposed offsite improvements, the timing of which is currently unknown.

Mitigation Measure AQ-1a would be required for construction of the remaining phases and offsite roadway and utility improvements. Although not presented in the Raney technical report, with the implementation of this mitigation measure, the estimated NOX emissions associated with the subsequent phases and offsite improvements would be reduced to a level below the mitigated NOX emissions for Phase 1 and offsite improvements, because estimated subsequent construction phases emissions identified in Table AQ-8 are less than the estimated construction emissions for Phase 1 identified in Table AQ-6.

Because Phase 1 and offsite improvements NOX emissions would be reduced below the significance threshold with implementation of Mitigation Measure AQ-1a, NOX emissions associated with the subsequent phases and offsite improvements would also be reduced below the significance threshold. As a result, with the implementation of Mitigation Measure AQ-1a, the impact with respect to construction emissions would be less than significant.

MITIGATION MEASURES
Implement Mitigation Measure AQ-1a (see above)
IMPACT AQ-3: LONG-TERM OPERATIONAL EMISSIONS OF CRITERIA AIR

POLLUTANTS AND PRECURSORS
Regarding long-term operational activities, development proposed under the proposed UWSP would increase emissions from motor vehicle trips and onsite area and energy sources (e.g., natural gas combustion for space and water heating, landscape maintenance, use of consumer products such as hairsprays, deodorants, and cleaning products).
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CalEEMod was used to estimate operational emissions for the build-out year of 2045 using trip generation rates from the traffic report for the proposed UWSP (Fehr and Peers 2022). Estimated operational emissions are presented in Table AQ-9. Existing conditions consist of roadways and various land uses, which emit ozone precursors ROG and NOX, and PM10 and PM2.5. These emissions were also modeled in CalEEMod using existing land use type inputs and existing roadway conditions inputs.

Table AQ-9: Unmitigated Maximum Project Operation Emissions 1 ROG
(lbs/day)
NOX
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
PM10
(tpy)
PM2.5
(tpy)
Existing Conditions (2045) 21 11 10 3 1.8 0.5
Proposed UWSP (2045)2 631 241 443 125 77.7 21.9
Net change in Emissions3 610 230 432 122 75.8 21.4
SMAQMD Thresholds
4 65 65 80 82 14.6 15
Significant (Yes or No)? Yes Yes Yes Yes Yes Yes
NOTES:
lbs/day = pounds per day; NOX = nitrogen oxides; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ROG = reactive organic gases; SMAQMD = Sacramento Metropolitan Air Quality Management District; tpy = tons per year; UWSP = Upper Westside Specific Plan.
1 Project operational emissions estimates were made using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. See Appendix AQ-1 for model outputs and more detailed assumptions. 2 Emissions have been adjusted using off-model calculations to account for the project not including natural gas hook-ups to single-family residential land uses (ESA 2024). 3 Values in bold are more than the applicable SMAQMD significance threshold. 4 SMAQMD’s non-zero emissions thresholds for PM10 and PM2.5 are used to assess the significance of the Project’s emissions.

SOURCE: Raney 2024, ESA 2024.

Based on the estimates shown in Table AQ-9, the net increase in full build-out operational emissions of ROG, NOX, PM10, and PM2.5 from development under the proposed UWSP would exceed SMAQMD’s significance thresholds. Thus, the operational emissions from development allowed under the proposed UWSP at full build-out would be potentially significant.

SMAQMD’s guidance recommends that project applicants prepare an AQMP for all projects that exceed SMAQMD’s operational significance thresholds. Because the operational emissions of NOX, ROG, and PM2.5, and PM10 from development under the proposed UWSP would be greater than the applicable SMAQMD significance thresholds identified above, an AQMP has been prepared for the proposed UWSP, which can be found in the appendix of the Raney technical report (see Appendix E of Appendix AQ-1).
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The AQMP calculates a reduction target based on the project’s consistency with the current State Implementation Plan, or SIP. For projects included in the current SIP, the SMAQMD recommends a 15 percent reduction of NOX and ROG mobile source emissions. For projects not considered in the SIP, the SMAQMD recommends a 35 percent reduction in NOX and ROG mobile-source emissions relative to unmitigated emissions. SMAQMD has determined that this reduction in NOX and ROG mobilesource emissions would satisfy the “all feasible measures” mitigation requirement for those pollutants under CEQA; however, if the mitigated emissions continue to exceed the applicable thresholds of significance, SMAQMD would consider the impact to be significant and unavoidable. The proposed UWSP was not anticipated by the County in the current General Plan or any other community plan, and the development of the proposed UWSP is not included in the growth assumptions in the SIP. As such, a reduction of 35 percent below unmitigated mobile emissions of the ozone precursors ROG and NOX is considered feasible for a mitigation reduction goal for the proposed UWSP. For PM10 and PM2.5, SMAQMD does not recommend a percent reduction goal for mitigation.

Implementation of Mitigation Measure AQ-1b represents all feasible mitigation that can occur during operation. The maximum operational criteria pollutant emissions, with implementation of this measure, are presented in Table AQ-10.

Table AQ-10: Mitigated Maximum Project Operation Emissions 1 ROG
(lbs/day)
NOX
(lbs/day)
PM10
(lbs/day)
PM2.5
(lbs/day)
PM10
(tpy)
PM2.5
(tpy)
Existing Conditions (2045) 21 11 10 3 1.8 0.5
Mitigated UWSP (2045)2 625 210 424 119 74.4 20.7
Net change in Emissions3 604 200 414 116 72.6 20.2
SMAQMD Thresholds4 65 65 80 82 14.6 15
Significant (Yes or No)? Yes Yes Yes Yes Yes Yes
NOTES:
lbs/day = pounds per day; NOX = nitrogen oxides; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ROG = reactive organic gases; SMAQMD = Sacramento Metropolitan Air Quality Management District; tpy = tons per year; UWSP = Upper Westside Specific Plan.
1 Project operational emissions estimates were made using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. See Appendix AQ-1 for model outputs and more detailed assumptions. 2 Emissions for the mitigated UWSP have been adjusted using off-model calculations to account for the prohibition of natural gas in all residential land uses (ESA 2024). 3 Values in bold are in excess of the applicable SMAQMD significance threshold. 4 SMAQMD’s non-zero emissions thresholds for PM10 and PM2.5 to compare the project’s mitigated emissions.

SOURCE: Raney 2024, ESA 2024.
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Although the mobile sources that would be associated with the proposed UWSP are not specifically delineated from the other proposed UWSP sources in Tables AQ-9 and AQ-9, implementation of Mitigation Measure AQ-1b would achieve the 35 percent reduction in NOX and ROG mobile-source emissions feasibility goal relative to unmitigated emissions (see Appendix AQ-1 model outputs). However, as shown in Table AQ-10, emission levels would still exceed the applicable thresholds of significance relative to all criteria pollutants and precursors evaluated, and therefore, the impact would remain significant and unavoidable.

MITIGATION MEASURES
Implement Mitigation Measure AQ-1b (see above)

HEALTH EFFECTS OF CRITERIA POLLUTANTS
In the decision for the Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502 case regarding the proposed Friant Ranch Project, the California Supreme Court focused on the need for analysis of potential health impacts resulting from the emission of criteria pollutants during operations of proposed projects. In October 2020, SMAQMD released the Guidance to Address the Friant Ranch Ruling for CEQA Projects in the Sac Metro Air District (Friant Ranch Guidance) for the analysis of criteria emissions in areas within the SMAQMD’s jurisdiction (SMAQMD 2020d). The Friant Ranch Guidance represents SMAQMD’s effort to develop a methodology that provides a consistent, reliable, and meaningful analysis in response to the Supreme Court’s direction on correlating health impacts to a project’s emissions.

SMAQMD prepared the Friant Ranch Guidance by conducting regional photochemical modeling. The Friant Ranch Guidance uses the USEPA’s Benefits Mapping and Analysis Program to assess health impacts from ozone and PM2.5. SMAQMD has prepared two tools that are intended for use in analyzing health risks from criteria pollutants. Small projects with criteria pollutant emissions close to or below SMAQMD’s adopted thresholds of significance may use the Minor Project Health Effect Screening Tool, while larger projects with emissions between two and eight times greater than SMAQMD’s adopted thresholds may use the Strategic Area Project Health Screening Tool (SMAQMD 2020b). Because operation of the project would result in emissions that would exceed the SMAQMD’s thresholds of significance, the most appropriate analysis for the project would be to use the Strategic Area Project Health Screening Tool. The Strategic Area Project Health Screening Tool is based on location-specific modeling, in five specific growth area locations. The UWSP area is located closest to the Downtown Sacramento location in the Strategic Area Project Health Screening Tool. Results from the Strategic Area Project Health Effects Screening Tool are shown in Table AQ-11.

As shown in the table, the project could result in 5.2 premature deaths per year due to PM2.5 emissions that it would generate and could result in 0.14 of a premature death per year due to the project’s generation of precursors of ozone (Raney 2024). Such numbers represent a very small increase over the background incidence of premature deaths due to PM2.5 and ozone concentrations (0.012 percent and 0.001 percent, respectively). PM2.5 emissions from the proposed UWSP could result in 2.1 asthma- 6 - Air Quality
Upper Westside Specific Plan 6-45 PLNP2018-00284
related emergency room visits per year, and ozone emissions that would form from the project-generated NOX and ROG emissions could result in 2.9 asthma-related emergency room visits per year. Such numbers represent a small increase over the background level of asthma-related emergency room visits (0.011 percent and

0.033 percent, respectively) (Raney 2024). Additionally, it is noted that the baseline health impacts and the estimated health impacts associated with the project encompass the 5-Air-District Region, which includes over seven counties.

Table AQ-11: Health Effects from Project-Generated Criteria Pollutants Health Endpoint
Age
Range1
Annual Incidences
from Project
Emissions2
(mean)
Background
Health
Incidences3
(percent)
Total Annual
Health
Incidences4
RESPIRATORY PM2.5
Emergency Room Visits, Asthma 0-99 2.1 0.0110 18,419
Hospital Admissions, Asthma 0-64 0.13 0.0072 1,846
Hospital Admissions, All
Respiratory 65-99 0.70 0.0036 19,644
CARDIOVASCULAR PM2.5
Hospital Admissions, All
Cardiovascular (less Myocardial
Infarctions)
65-99 0.37 0.0015 24,037
Acute Myocardial Infarction,
Nonfatal 18-24 0.00019 0.0049 4
Acute Myocardial Infarction,
Nonfatal 25-44 0.016 0.0052 308
Acute Myocardial Infarction,
Nonfatal 45-54 0.036 0.0049 741
Acute Myocardial Infarction,
Nonfatal 55-64 0.062 0.0050 1,239
Acute Myocardial Infarction,
Nonfatal 65-99 0.24 0.0047 5,052
MORTALITY PM2.5
Mortality, All Causes 30-99 5.2 0.012 44,766

RESPIRATORY OZONE
Hospital Admissions, All
Respiratory 65-99 0.20 0.001 19,644
Emergency Room Visits, Asthma 0-17 1.1 0.019 5,859
Emergency Room Visits, Asthma 18-99 1.8 0.014 12,560
6 - Air Quality
Upper Westside Specific Plan 6-46 PLNP2018-00284
Health Endpoint
Age
Range1
Annual Incidences
from Project
Emissions2
(mean)
Background
Health
Incidences3
(percent)
Total Annual
Health
Incidences4

MORTALITY OZONE
Mortality, Non-Accidental 0-99 0.14 0.001 30,386
NOTES:

PM2.5 = particulate matter 2.5 microns or less in diameter 1 Affected age ranges are shown. Other age ranges are available, but the endpoints and age ranges shown here are the ones used by the U.S. Environmental Protection Agency (USEPA) in its health assessments. The age ranges are consistent with the epidemiological study that is the basis of the health function.
2 Health effects are shown in terms of incidences of each health endpoint and how it compares to the base (2035 base year health effect incidences, or “background health incidence”) values. Health effects are shown for the Reduced Sacramento 4-Kilometer Modeling Domain and the 5-Air-District Region. 3 The percent of background health incidence uses the mean incidence. The background health incidence is an estimate of the average number of people that are affected by the health endpoint in a given population over a given period of time. In this case, the background incidence rates cover the 5-Air-District Region (estimated 2035 population of 3,271,451 persons). Health incidence rates and other health data are typically collected by the government as well as the World Health Organization.

The background incidence rates used here are obtained from USEPA’s Benefits Mapping and Analysis Program.
4 The total number of health incidences across the 5-Air-District Region is calculated based on modeling data. The information is presented to assist in providing overall health context.

SOURCE: Raney 2024 (Table 14)
IMPACT AQ-4: EXPOSURE OF SENSITIVE RECEPTORS TO TACS

CONSTRUCTION
DPM represents the primary TAC of concern from construction activities. Construction of Phase 1 development allowed under the proposed UWSP would generate DPM emissions due to operation of internal combustion engines in equipment such as loaders, backhoes, and cranes, as well as diesel-fueled heavy-duty haul trucks. The estimated cancer risk and non-cancer hazard indices that would be associated with proposed UWSP construction activities are presented in Table AQ-12.

As shown in Table AQ-12, TAC emissions associated with the construction of the proposed UWSP would not result in non-cancer, chronic hazard health risks or annual PM2.5 concentrations that exceed the thresholds of significance. However, the potential exists for construction of the proposed UWSP to result in a cancer risk in excess of the threshold of significance. Therefore, a potentially significant impact could occur. 6 - Air Quality
Upper Westside Specific Plan 6-47 PLNP2018-00284
Table AQ-12: Construction-Related Health Risk
Sensitive Receptor
Maximum
Cancer Risk
(in a million)
Chronic Risk
(Hazard Index)
Annual Average
PM2.5 Concentration
(µg/m3)*
Residential Receptor (Maximally
Exposed Individual Receptor) at
Perimeter of Phase 1 Area

7.32 0.003 0.013
On-Site Receptor (Subsequent
Phases) 11.96 0.004 0.021
Total/Maximum 19.28 0.007 0.021
Significance Threshold 10 1.0 0.3
Significant? Yes No No
SOURCE: Raney 2024.

NOTES: µg/m3 = micrograms per cubic meter; PM2.5 = particulate matter 2.5 microns or less in diameter *Annual average PM2.5 concentrations were obtained from Appendix C of Raney 2024. Because the annual average PM2.5 concentrations associated with Phase 1 and subsequent phases would not occur during the same year, the two concentrations are not totaled and are instead shown as maximum emissions.

With implementation of Mitigation Measure AQ-1a (see above), off-road equipment used during construction of the proposed UWSP would be required to meet Tier 4 final engine emission standards. Table AQ-13 provides the mitigated construction-related health risks that would be associated with the proposed UWSP. As shown in the table, use of Tier 4 Final construction equipment for all construction activities would ensure that DPM emissions from construction equipment would not result in increased health risks in excess of the significance thresholds. Consequently, implementation of Mitigation Measure AQ-1a would reduce the construction-related health risk impact to a less-than-significant level.

OPERATION

IMPACT OF TACS ON EXISTING OFF-SITE RECEPTORS
The CARB Air Quality and Land Use Handbook has identified major sources of TACs to include freeways and high-traffic roads, GDFs, distribution centers, and rail yards. Highvolume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic are identified as having the highest associated health risks from DPM. The proposed UWSP has the potential to introduce new GDFs, but the project would be required to comply with CARB’s recommended buffer distances associated with such GDFs. Therefore, this operational HRA focuses on DPM emissions associated with vehicular sources. The existing receptors located south of the site, across I-80, could be exposed to increased DPM emissions associated with increased traffic on I-80 generated by the proposed UWSP, as discussed below. 6 - Air Quality
Upper Westside Specific Plan 6-48 PLNP2018-00284
Table AQ-13: Mitigated Construction-Related Health Risk Sensitive Receptor
Maximum
Cancer Risk
(in a million)
Chronic Risk
(Hazard Index)
Annual Average
PM2.5 Concentration
(µg/m3)*
Residential Receptor (Maximally
Exposed Individual Receptor) at
Perimeter of Phase 1 Area

1.69 0.001 0.003
On-Site Receptor (Subsequent
Phases) 2.76 0.001 0.005
Total/Maximum 4.72 0.002 0.005
Significance Threshold 10 1.0 0.3
Significant? No No No
SOURCE: Raney 2024.

NOTES: µg/m3 = micrograms per cubic meter; PM2.5 = particulate matter 2.5 microns or less in diameter * Annual average PM2.5 concentrations were obtained from Appendix C of Raney 2024. Because the annual average PM2.5 concentrations associated with Phase 1 and subsequent phases would not occur during the same year, the two concentrations are not totaled and are instead shown as maximum emissions.

The existing off-site receptors are located at similar distances from I-80 as the proposed on-site receptors associated with the UWSP, and the prevailing winds would disperse pollutants from I-80 in a similar fashion toward both existing off-site receptors and new on-site receptors. For this reason, the total cancer risk for existing off-site sensitive receptors would generally be the same as the cancer risks associated with the proposed on-site multi-family housing (Table AQ-14). Therefore, the proposed UWSP would result in potential health risks associated with the existing receptors located to the south of the site, across I-80, and a potentially significant impact would occur.

Implementation of Mitigation Measure AQ-1b would be required. Also, Mitigation Measure AQ-4a would require that the specific plan design guidelines and development standards of the proposed UWSP include consideration of recommendations in land use siting found in CARB’s Air Quality and Land Use Handbook: A Community Health Perspective. In addition, installation of MERV 13 filters in the heating, ventilation, and air conditioning (HVAC) systems for the existing sensitive receptors to the south of the project site, across I-80, would reduce the cancer risk for such receptors. However, because installation of such filters in the existing residences would require resident approval, neither Sacramento County nor the project applicant can legally impose such improvements on private properties. Therefore, such a mitigation approach as outlined below in Mitigation Measure AQ-4b would only be effective for residents who select to participate in the program, and it would be speculative to predict what the participation level would be. Therefore, the health risk to existing sensitive receptors would remain 6 - Air Quality
Upper Westside Specific Plan 6-49 PLNP2018-00284
significant and unavoidable with implementation of Mitigation Measures AQ-1b through AQ-4b.

It should be noted, however, that the cancer risks, non-cancer hazard indices, and annual average PM2.5 concentrations presented below represent a worst-case scenario with regard to proposed UWSP traffic. Regulations pertaining to vehicle emissions, such as state and federal vehicle standards, are becoming increasingly more stringent. As such, project traffic, as well as future traffic traveling along I-80, is anticipated to generate fewer TAC emissions than presented here as current and future regulations become effective and vehicle engines become less polluting. Therefore, when considering the effect of future, more stringent regulations, the health risks presented below are conservative.

IMPACT OF TACS ON FUTURE ON-SITE RECEPTORS
The potential health risks associated with project-related traffic along I-80 on proposed multi-family housing near I-80 were evaluated by subtracting the health risks identified in the Raney technical report associated with the cumulative no project scenario from the health risks associated with the cumulative plus project scenario. The operational health risks for proposed UWSP future on-site sensitive receptors are presented below in Table AQ-14.

Table AQ-14: Operational Health Risk
Health Risk at
Maximally Exposed
Individual Receptor
Maximum Cancer
Risk (in a million)
Chronic Risk
(Hazard Index)
Annual Average
PM2.5 Concentration
(µg/m3)
Cumulative No Project: I-80 259.3 0.06 0.10
Cumulative Plus Project
Conditions: I-80 303.7 0.07 0.35
Project Contribution: I-80 44.4 0.01 0.25
Significance Threshold 10 1.0 0.3
Significant? Yes No No
NOTES: µg/m3 = micrograms per cubic meter; I-80 = Interstate 80; PM2.5 = particulate matter 2.5 microns or less in diameter
SOURCE: Based on Raney 2024 (Table 13).

As shown in Table AQ-14, TAC emissions associated with operation of the proposed UWSP would not result in non-cancer hazard health risks or PM2.5 concentrations that exceed the thresholds of significance. However, traffic generated by the proposed UWSP would result in a cancer risk at future proposed residences in excess of the significance threshold. Therefore, a potentially significant impact would occur. 6 - Air Quality
Upper Westside Specific Plan 6-50 PLNP2018-00284
Implementation of Mitigation Measure AQ-1b would be required. Also, Mitigation Measure AQ-4a would require that the specific plan design guidelines and development standards of the proposed UWSP include consideration of recommendations in land use siting found in CARB’s Air Quality and Land Use Handbook: A Community Health Perspective. In addition, Mitigation Measure AQ-4c, as detailed below, would require that a minimum MERV 13 filter be included in the HVAC systems for all sensitive land uses (e.g., residences, schools) within 1,000 feet of I-80. MERV 13 filters are rated to capture at least 85 percent of particles that are 1.3 to 3.0 microns in size and at least 90 percent of particles that are 3.0 to 10.0 microns in size (USEPA 2023). Therefore, the inclusion of MERV 13 filters in sensitive land uses provided by the proposed UWSP would dramatically reduce the exposure of future on-site sensitive receptors to DPM.

The installation of upgraded MERV rating filters has also been shown to reduce indoor PM2.5 exposure by 19 to 28 percent (Zuraimi and Tan 2015). A linear relationship exists between PM10 concentration and the associated cancer risk when all other variables, including exposure time, remain constant. Therefore, in the case of the proposed UWSP, a 19 to 28 percent reduction in PM2.5 concentration would equate to a 19 to 28 percent reduction in cancer risk. After installation of MERV 13 filters, the project’s cancer risk contribution can reasonably be expected to range between 32 and 36 cases per million (a reduction in cancer risk of 19 to 28 percent). However, these values would still exceed the significance threshold of 10 per million. As such, the health risk impact to future proposed sensitive receptors would be significant and unavoidable.

MITIGATION MEASURES
Implement Mitigation Measures AQ-1a and AQ-1b (see above) AQ-4a The specific plan design guidelines and development standards of the proposed UWSP shall include consideration of recommendations in land use siting found in CARB’s Air Quality and Land Use Handbook: A Community Health Perspective. These include the following:
 Prohibit siting new sensitive land uses within 500 feet of urban roads carrying 100,000 vehicles per day.
 Prohibit siting new sensitive land uses within 300 feet of a large gasoline station (defined as a facility with a throughput of 3.6 million gallons per year or greater). A 50-foot separation is recommended for typical gasoline-dispensing facilities.
 Prohibit siting new sensitive land uses within 300 feet of any dry-cleaning operation using perchloroethylene. For operations with two or more machines, provide 500 feet. For operations with three or more machines, consult the local air district. Do not site new sensitive land uses in the same building with dry-cleaning operations that use perchloroethylene.  Obtain facility-specific information where there are questions about siting a sensitive land use close to an industrial facility, including the amount of 6 - Air Quality
Upper Westside Specific Plan 6-51 PLNP2018-00284
pollutant emitted and its toxicity, distance to nearby receptors, and types of emissions controls in place.

AQ-4b Coordinate with existing off-site homeowners adjacent to the proposed UWSP site that are within 1,000 feet of the I-80 right-of-way and offer financial assistance for the use of MERV 13 air filters. Financial assistance will be provided for the purchase of up to two filters per year, or per manufacturer recommendations. The UWSP applicants will establish an online procurement system (or similar) to facilitate the purchase and distribution of the filters to residents electing to participate in the program.

AQ-4c For future proposed sensitive land uses within 1,000 feet of I-80, the project applicant shall implement measures that include, but are not limited to, the following:
 Install, operate, and maintain in good working order a central HVAC system or other air intake system in the building, or in each individual unit, that meets or exceeds a MERV of 13 or higher. The HVAC system shall include the following features: Installation of a high-efficiency filter and/or carbon filter to filter particulates and other chemical matter from entering the building. Either high-efficiency particulate air filters or American Society of Heating, Refrigeration, and Air-Conditioning Engineers–certified 85 percent supply filters shall be used.
 Maintain, repair, and/or replace the HVAC system on an ongoing and asneeded basis or prepare an operation and maintenance manual for the HVAC system and the filter. The manual shall include the operating instructions and the maintenance and replacement schedule. This manual shall be included in the Covenants, Conditions, and Restrictions for residential projects and/or distributed to the building maintenance staff. In addition, the applicant shall prepare a separate homeowners’ manual. The manual shall contain the operating instructions and the maintenance and replacement schedule for the HVAC system and the filters.  Locate individual and common exterior open space and outdoor activity areas proposed as part of individual projects as far away as possible within the project site boundary, facing away from major freeways, and shielded from the air pollution source (i.e., the roadway) by buildings or otherwise buffered to further reduce air pollution for project occupants.  Locate air intakes and design windows to reduce PM exposure (e.g., windows nearest to the roadway do not open).
 Plant trees and/or vegetation between sensitive receptors and pollution source. Trees that are best suited to trapping PM shall be planted, including one or more of the following species: pine (Pinus nigra var. maritima), cypress (Cupressocyparis leylandii), hybrid popular (Populus deltoids x trichocarpa), California pepper tree (Schinus molle), and redwood (Sequoia sempervirens).
6 - Air Quality
Upper Westside Specific Plan 6-52 PLNP2018-00284
IMPACT AQ-5: EXPOSURE TO OBJECTIONABLE ODORS
Construction activities often include diesel-fueled equipment and heavy-duty trucks, which could create odors associated with diesel fumes that may be considered objectionable. Project construction would also be required to comply with all applicable SMAQMD rules and regulations, discussed above. The aforementioned regulations would help to minimize emissions, including emissions leading to odors. Accordingly, substantial objectionable odors would not be expected to occur during construction activities.

Full build-out of the UWSP area would include operations of fast-food and sit-down restaurants, and other uses that could include commercial kitchens. Operations of the commercial kitchens would have the potential to result in emissions of odors related to food preparation and disposal. In particular, preparation of oily food, some baking processes, and cooking using charbroiling grills may create odorous emissions.

However, commercial kitchens and cooking areas are required to comply with state and local regulations associated with cooking equipment and controls, such as grease filtration and removal systems, exhaust hood systems, and blowers to move air into the hood systems, through air cleaning equipment, and then outdoors. Such equipment would ensure that pollutants associated with smoke and exhaust from cooking surfaces would be captured and filtered, allowing only filtered air to be released into the atmosphere. The impact would be less than significant.

SMAQMD also regulates objectionable odors through Rule 402, which prohibits any person or source from emitting air contaminants that cause detriment, nuisance, or annoyance to a considerable number of persons or the public. Rule 402 is enforced based on complaints. If complaints are received, the SMAQMD is required to investigate the complaint, as well as determine and ensure a solution for the source of the complaint, which could include operational modifications. Although not anticipated, if odor complaints are made regarding food preparation or GDF operations after development allowed under the proposed UWSP is approved, the SMAQMD would ensure that such odors are addressed.

MITIGATION MEASURES
None required.

Upper Westside Specific Plan 7-1 PLNP2018-00284
7 BIOLOGICAL RESOURCES

INTRODUCTION
This chapter identifies and analyzes impacts on biological resources based on the proposed UWSP. Policies provided in the proposed UWSP, and existing County and habitat conservation plan (HCP) requirements, are considered in terms of their potential to mitigate or avoid potentially significant impacts.

The Notice of Preparation (NOP) for the EIR was circulated on October 5, 2020. The County received several comment letters related to biological resources.

Comments from the California Department of Fish and Wildlife (CDFW) noted that the EIR should include a complete assessment of the flora and fauna within and adjacent to the project footprint with emphasis on identifying rare, threatened, endangered, and other sensitive species and their associated habitats and provides specific recommendations on what data to include. CDFW further requests that the EIR include analysis of direct, indirect, and cumulative impacts on biological resources; disclose the potential for the project to take state-listed species, especially Swainson’s hawk; include “appropriate and adequate avoidance, minimization, and/or mitigation measures” to avoid, minimize, and mitigate impacts; analyze whether, and to what extent, the project may affect future implementation and the continued viability of the Natomas Basin Habitat Conservation Plan (NBHCP) and Metro Air Park Habitat Conservation Plan (MAP HCP) in the Natomas Basin; and initiate early consultation with staff to discuss adequate avoidance, mitigation, monitoring, and reporting requirements, and permitting needs, including the need for an incidental take permit. CDFW also provided guidance for complying with the California Endangered Species Act (CESA), the Native Plant Protection Act, and the Lake and Streambed Alteration Program.

Comments from the U.S. Fish and Wildlife Service (USFWS) concurred with CDFW’s comment letter, specifically regarding identifying any potential inconsistencies with the NBHCP and MAP HCP and providing special emphasis on the analysis of rare or unique resources covered under the plans. The USFWS also recommends that the USFWS have the opportunity to review and approve the analysis prepared by the project proponent.

The Central Valley Regional Water Quality Control Board (RWQCB) commented on potential permitting requirements to protect water resources depending on potential project impacts, including but not limited to waste discharge of dredged or fill material, disturbance of waters, and use of pesticides.

Comments from the Sacramento Local Agency Formation Commission noted that the assessment of biological resources should evaluate the cumulative effects of the proposed UWSP, together with all other constructed and approved projects in the Natomas Basin; include an evaluation of the consistency with, and any impacts on, the existing NBHCP and MAP HCP and other resource planning documents; and provide 7 - Biological Resources
Upper Westside Specific Plan 7-2 PLNP2018-00284
mitigation for any identified adverse effects to special-status species and sensitive habitats.

The City of Sacramento commented that, while the County is not a party to the NBHCP, activities that could affect the success of the conservation strategy established by the NBHCP should be considered in the EIR. Specifically, the City requested that the EIR include the following:
(1) An analysis of the location and quality of proposed mitigation sites (including those within the Natomas Basin), including an analysis of the effect of market competition and price increases resulting from the UWSP project and its effect on the HCP conservation strategy.
(2) Hydrological connectivity to existing preserves in the Natomas Basin. (3) Effects of a reduction in the inventory (supply) of land available for mitigation, while also increasing the demand for mitigation land, driving up the price of mitigation for the existing permit holders.
(4) Appropriate mitigation ratio assuming development of the plan, which would appear to substantially change the assumptions that supported a 0.5:1 ratio for the MAP HCP and the NBHCP, and a 1:1 ratio for Greenbriar. (5) How and where HCP parties with authorized development are to find land for mitigation given the size of the Natomas Joint Vision Area, which overlaps with the Natomas Basin, the County-approved Metro Air Park (MAP) area and Sacramento County airport lands, and the two pending development proposals under consideration by the County (the UWSP and Grandpark).

Below, the Environmental Setting portion of this chapter includes descriptions of existing conditions relevant to biological resources. Farther below, existing regulations, plans, and policies relevant to biological resources associated with implementation of the Project are provided in the Regulatory Setting section. Finally, the impact discussion evaluates potential impacts on biological resources that could result from implementation of the project in the context of existing conditions. The study area discussed herein includes the proposed UWSP (refer to Plate PD-3 in Chapter 2, Project Description) surrounded by a 0.5-mile buffer to account for indirect impacts.

Some of the information and analysis included in this chapter was adapted from the UWSP Draft Supplemental Biological Resources Assessment Report prepared by HELIX Environmental Planning, Inc. (HELIX 2024; Appendix BIO-1), and the Biological Resources Assessment: Upper Westside Specific Plan prepared by Bargas Environmental Consulting (Bargas 2022; Appendix BIO-2).

Additional primary sources of information referenced in this section included the following:
 Historic and current aerial imagery available on Google Earth (2022).  Biological resource databases including the CDFW California Natural Diversity Database (CNDDB) (CDFW 2023a) CDFW Special Animals List (2023b), 7 - Biological Resources
Upper Westside Specific Plan 7-3 PLNP2018-00284
California Native Plant Society (CNPS) Rare Plant Inventory (CNPS 2023), and a USFWS Information for Planning and Consultation Official Species List (USFWS 2023).
 Sacramento County 2030 General Plan (2011).
 Sacramento County General Plan Update, Final Environmental Impact Report (2010)
 Natomas Basin Habitat Conservation Plan – Sacramento and Sutter Counties, California (City of Sacramento et al. 2003).
 The NBHCP Area Biological Effectiveness Monitoring Report 2022 Annual Survey Results (ICF 2023).
 Habitat Conservation Plan for the Metro Air Park in the Natomas Basin (Thomas Reid Associates 2001).

ENVIRONMENTAL SETTING

LAND COVERS
Vegetative communities and other land cover types found within the UWSP area are described below. Land cover types are based on those reported in the Supplemental Biological Resources Assessment Report (HELIX 2024), in which HELIX compiled land cover data for the UWSP area by combining portions of the data from state and commercial sources, including the Central Valley Flood Protection Planning Area Update project and the 2019 i5 Statewide Crop Mapping data. Aquatic resource data were obtained from HELIX and Bargas (Bargas 2022). This information is shown in Plate BR-1, Upper Westside Specific Plan Land Existing Cover, and summarized in Table BR-1, where land cover types developed by HELIX are crosswalked with the land classifications in the NBHCP. Descriptions of land cover types were obtained from the Supplemental Biological Resources Assessment Report (HELIX 2024).

ANNUAL GRASSES AND FORBS
Annual grasses and forbs are found on 17.31 acres of the UWSP area and occur where agricultural fields have remained fallow for an extended period. Annual grasses and forbs consist of annual plant species. Dramatic differences in physiognomy between seasons and years are characteristic of this habitat. Fall rains cause the germination of plant seeds. Plants grow slowly during the cool winter months, remaining low in stature until spring, when temperatures increase and stimulate more rapid growth. Large amounts of standing dead plant material can be found during summer in years of abundant rainfall and light to moderate grazing pressure. Heavy spring grazing favors the growth of summer-annual forbs. Many wildlife species use annual grasslands for foraging. *aUGeQ +
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7 - Biological Resources
Upper Westside Specific Plan 7-5 PLNP2018-00284
Table BR-1: Proportion of Land Cover Classifications Within the UWSP Area and Crosswalk with NBHCP Land Cover Classifications
Land Cover Classification
Corresponding
NBHCP 2003 Land
Cover Classifications Acres Proportion (%)
Annual Grasses and Forbs Grassland 17.31 0.79
Deciduous Orchard 4.38 0.20
Field Crops Non-Rice Crops 334.71 15.22
Fremont Cottonwood Riparian 1.00 0.05
Grain and Hay Alfalfa 792.79 36.05
Partially Irrigated Crops Non-Rice Crops 272.50 12.39
Pasture Pasture 17.91 0.81
Ruderal Ruderal 285.50 12.98
Truck Crops Non-Rice Crops 74.44 3.38
Urban/Developed (General) Urban 258.18 11.74
Valley Oak Tree Groves 34.66 1.58
Vineyard -- 17.23 0.78
Water Canals 45.08a 2.05
SAFCA Wetland Creation 43.62 1.98
Total 2,199 100
NOTES:

NBHCP = Natomas Basin Habitat Conservation Plan; SAFCA = Sacramento Area Flood Control Agency; UWSP = Upper Westside Specific Plan
a Land cover calculation includes all drainage ditches in farmland.

SOURCE: HELIX 2024

DECIDUOUS
Deciduous orchards are found on 4.38 acres of the UWSP area. Deciduous orchards are open, single-species tree-dominated habitats. Spacing between trees is uniform, depending on the desired spread of mature trees. The understory may be composed of low-growing grasses, legumes, and other herbaceous plants, or may be managed to prevent understory growth along tree rows. Orchards are planted on deep fertile soils which once supported productive and diverse natural habitats. Some avian and mammal species have adapted to orchard habitats.
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Upper Westside Specific Plan 7-6 PLNP2018-00284

FIELD CROPS
Field crops are found on 334.71 acres of the UWSP area. Cover type, canopy, plant composition, and other metrics are variable, changing from year to year or even season to season. Vegetation in this habitat includes a variety of sizes, shapes, and growing patterns, and vegetation cover can vary widely from 100 to 0 percent. Some acreages are planted in rotation with other irrigated crops, and sometimes winter wheat or barley may be planted after harvest of a previous crop in the fall, dry farmed (during the wet winter and early spring months), and then harvested in the late spring. Row and field crops are established on fertile soils, which historically supported an abundance of wildlife. Many wildlife species have adapted to croplands. The Natomas Basin Conservancy (TNBC) Alleghany Reserve is located within this land cover type (Plate BR-2).

FREEMONT COTTONWOOD
Fremont cottonwood (Populus fremontii) is a native species that occurs in or around wetlands and riparian areas and is found on 1.00 acre of the UWSP area. Undisturbed areas contain a subcanopy tree layer and an understory shrub layer. Fremont cottonwood and associated riparian areas provide food, water, migration, and dispersal corridors, and escape, nesting, and thermal cover for an abundance of wildlife species.

GRAIN AND HAY
Grain and hay fields (alfalfa fields) are found on 792.79 acres of the UWSP area. Like most agricultural habitat types, cover type, vegetation cover, plant composition, and other metrics are variable and may change from year to year or even season to season.

This land cover is dense monoculture, with nearly 100 percent cover once plants have matured. The habitat’s stature decreases following annual harvest and subsequently reverts to bare ground after plowing or discing. Plowing may occur annually but is usually less often. This land cover can provide a high-quality seasonal resource for a variety of wildlife.

PARTIALLY IRRIGATED CROPS
Irrigated crops are found on 272.50 acres of the UWSP area. Most irrigated field crops are annual species, grown in rows that are usually planted in spring and harvested in summer or fall. Like most agricultural habitat types, cover type, vegetation cover, plant composition, and other metrics are variable, changing from year to year or even season to season. Vegetation in this habitat includes a variety of sizes, shapes, and growing patterns and canopy cover can vary widely from 100 to 0 percent. 'el PaVR 5G
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PASTURE
Pasture land cover is found on 17.91 acres of the UWSP area. As for most agricultural types, cover type, vegetation cover, plant composition, and other metrics are variable and may change from year to year or even season to season. Pasture vegetation is commonly a mix of perennial grasses and legumes that normally provide 100 percent vegetation cover. Height of vegetation varies from a few inches to 2 or more feet on fertile soils, dependent on season and livestock stocking and grazing levels. Pastures are used by a variety of wildlife depending upon the geographic area and adjacent habitats. Ground-nesting bird species can nest in pastures if adequate residual vegetation is present at the onset of the nesting season. Flood irrigation of pastures provides feeding and roosting sites for many wetland-associated birds.1

RUDERAL
Ruderal land cover is present on 285.5 acres of the UWSP area and is present in some offsite improvement areas, such as the Interstate 80/West El Camino Avenue interchange. Ruderal areas have typically been exposed to extensive ongoing anthropogenic disturbance and are characterized largely by non-native, weedy species or early native colonizing species. This land cover type is not paved, retaining a soil substrate. Ruderal land cover can be colonized by burrowing small mammals and thus can be suitable for animals such as burrowing owl and Swainson’s hawk that forage for prey in ruderal habitat. The TNBC Alleghany Reserve is located within this land cover type.

TRUCK CROPS
Truck crops are present on 74.44 acres of the UWSP area. Truck crops include lowgrowing row crops such as tomatoes and melons. This land cover can provide a highquality seasonal resource for a variety of wildlife. The TNBC Alleghany Reserve is located within this land cover type.

URBAN/DEVELOPED (GENERAL)
Urban land cover is found on 258.18 acres of the UWSP area. A variety of vegetation, or lack thereof, occurs in urban/developed areas depending on the land use. Within the UWSP area, areas mapped as urban include residential lots and commercial development. Impervious surfaces, such as pavement, are common in the latter, while the former often includes mowed lawns, gardens, and ornamental trees. Wooded cover in the urban portions of the UWSP area provides shelter and foraging habitat for a wide variety of native and non-native wildlife, especially birds. The TNBC Alleghany Reserve is located within this land cover type.

1 This land cover also includes Sacramento Area Flood Control Agency (SAFCA)-created wetlands that consist of a part of 27.6 acres of wetland creation; however, at the time the NOP for the EIR was circulated (October 5, 2020), these wetlands had not yet been created (Google Earth 2020). No development is proposed by the UWSP in this area.
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Upper Westside Specific Plan 7-9 PLNP2018-00284

VALLEY OAK
Valley oak is found on 34.66 acres of the UWSP area connecting to riparian habitat along the Sacramento River. Valley oak habitat in the study area is dominated by valley oak (Quercus lobata), interspersed with canopy tree species such as California sycamore (Platanus racemosa), or can occur as a grassland dominated by valley oak.

Undisturbed areas typically contain a subcanopy tree layer and an understory shrub layer. In the UWSP area, valley oak understory is dominated by rural residential development, which diminishes the quality of the habitat for plants and wildlife. Valley oak land cover, particularly where it occurs near aquatic drainages, provides food, water, migration and dispersal corridors, and escape, nesting, and thermal cover for an abundance of wildlife species.

VINEYARD
Vineyard land cover is not a recognized land cover type in the NBHCP but is found on

17.23 acres of the UWSP area. Vineyards are monoculture crops planted in rows, usually supported on wood and wire trellises. Vines are normally intertwined within the support structures along the row but land between rows is maintained as open space.

Soil under the vines is usually sprayed with herbicides to prevent the growth of herbaceous plants. Between rows of vines, grasses and other low-growing herbaceous plants may be planted or allowed to grow as a cover crop to control erosion. Vineyards are typically planted on deep fertile soils that once supported productive and diverse natural habitats. Some avian and mammal species have adapted to vineyard habitats, including raptors, which often perch on supporting structures.

WATER (GENERAL)
Water (riverine habitat) is present on 45.08 acres of the UWSP area in the form of irrigation canals and ditches, ponds and detention basins. Irrigation ditches and canals contain duckweed (Lemna minor), green algae, and a variety of emergent vegetation, and the banks of the irrigation canals and ditches were dominated by ruderal vegetation during surveys conducted by Bargas (2022). The TNBC’s Alleghany Reserve is located within this land cover type.

JURISDICTIONAL WATERS AND WETLANDS
Bargas Environmental Consulting conducted an aquatic resources delineation of potential wetlands and other waters of the United States and state on 568.7 acres of the 2,065-acre UWSP area in July 2019 and April 2020. The U.S. Army Corps of Engineers (USACE) issued a Preliminary Jurisdictional Determination on June 19, 2020, for the 568.7-acre surveyed area that determined that 11.22 acres of Other Waters are present within the surveyed area, which are potentially subject to jurisdiction under Section 404 of the Clean Water Act (CWA) (USACE 2023).

Subsequently, HELIX conducted an aquatic resources delineation of potential wetlands and other waters of the United States and state in the UWSP area on March 7, 2023.

Previously mapped jurisdictional features were reviewed in the field. Because the 1,497.3 acres of the UWSP area not previously delineated by Bargas were not 7 - Biological Resources
Upper Westside Specific Plan 7-10 PLNP2018-00284
accessible, this area was assessed following the procedures from Subsections 1 and 3 of the Methods from the Wetlands Delineation Manual (USACE 1987). This method involved applying information already collected from the 568.7-acre aquatic resources delineation completed by Bargas (2020a) to the 1,497.3 acres not previously delineated.

Following this procedure, an additional 33.72 acres of aquatic resources were delineated by HELIX in 2023. A Preliminary Jurisdictional Determination was issued for the 33.72 acres of wetlands on February 23, 2024 (HELIX 2024). Subsequently, approximately 0.14 acre of aquatic resources was added due to a minor change of the UWSP boundary that overlaps the West Drainage Canal (Witter Canal). These aquatic resources are likely to be considered jurisdictional waters by the USACE (HELIX 2024).

Combined with the 11.22 acres of potential waters of the United States previously verified by USACE, a total of 45.08 acres of the UWSP area are subject to USACE and RWQCB jurisdiction under Sections 404 and 401 of the CWA.2

WILDLIFE CORRIDORS
Wildlife movement corridors have been recognized by federal agencies and the state as important habitats worthy of conservation. Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation; they may be continuous habitat or discrete habitat islands that function as steppingstones for wildlife dispersal. Wildlife corridors provide migration channels seasonally (i.e., between winter and summer habitats), and provide non-migrant wildlife the opportunity to move within their home range for food, cover, reproduction, and refuge. The UWSP area is within the Pacific Flyway, one of the four major bird migration routes in North America.

Agricultural canals and ditches in the UWSP area provide potential movement corridors for giant garter snake, western pond turtle, and other amphibians.

SENSITIVE NATURAL COMMUNITIES
According to the Supplemental Biological Resources Assessment Report (HELIX 2024), interconnected canals and ditches that support wetland vegetation are potential waters of the United States and state and could be considered a sensitive natural community.

Both HELIX (2024) and Bargas (2022) concluded that there are no other sensitive natural communities in the UWSP area.

SPECIAL-STATUS SPECIES
The term special-status species refers to plant and wildlife species that are considered sufficiently rare that they require special consideration and/or protection and should be, or currently are, listed as rare, threatened, or endangered by the federal and/or state governments. Such species are legally protected under the federal and/or state Endangered Species Acts or other regulations or are species that are considered

2 A portion of 27.6 acres of SAFCA-created wetlands are currently present in the northeast corner of the UWSP area; however, at the time the NOP for the EIR was circulated (October 5, 2020), these wetlands had not yet been created (Google Earth 2020). No development is proposed by the UWSP in this area.
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sufficiently rare by the regulatory and scientific community to qualify for protection. The term special-status species includes the following:
 Species listed or proposed for listing as threatened or endangered under the federal Endangered Species Act (FESA) (Code of Federal Regulations [CFR] Title 50, Section 17.12 [listed plants] and Section 17.11 [listed animals] and various notices in the Federal Register [FR] [proposed species]).  Species listed or proposed for listing by the State of California as threatened or endangered, or that are candidates for listing, under the CESA (California Code of Regulations Title 14, Section 670.5).
 Plants listed as rare or endangered under the California Native Plant Protection Act (California Fish and Game Code [CFGC] Section 1900 et seq.).  Species designated by CDFW as California Species of Special Concern (SSC). 3  Animals fully protected under the CFGC (Sections 3511 [birds], 4700 [mammals], and 5050 [reptiles and amphibians]).
4  Species that meet the definitions of rare and endangered under CEQA. CEQA Section 15380 provides that a plant or animal species may be treated as “rare or endangered” even if not on one of the official lists (CEQA Guidelines Section 15380).
 Raptors (birds of prey), which are specifically protected by CFGC Section 3503.5, thus prohibiting the take, possession, or killing of raptors, including owls, their nests, and their eggs.
 Plants considered by CDFW and CNPS to be “rare, threatened or endangered in California” (California Rare Plant Rank 1A, 1B, and 2).

A list of special-status plant and wildlife species that may occur within the UWSP area was created by reviewing the resources cited at the beginning of this chapter. The CNDDB (CDFW 2023) and CNPS Rare Plant Inventory (CNPS 2023) were queried based on a search of the Sacramento West, Grays Bend, Taylor Monument, Rio Linda, Davis, Sacramento East, Saxon, Clarksburg, and Florin 7.5-minute U.S. Geological Survey quadrangles. An Official List of Federal Endangered and Threatened Species that Occur in or May Be Affected by the Project was obtained from the USFWS (2023) (refer to Appendix BIO-3, Plant and Wildlife Species Lists for the Project Site and Vicinity, for database reports). The results of these queries, the Biological Resources Assessment Reports for the UWSP area (Bargas 2020; HELIX 2024), and a review of

3 A California SSC is one that has been extirpated from the state; meets the state definition of threatened or endangered but has not been formally listed; is undergoing or has experienced serious population declines or range restrictions that put it at risk of becoming threatened or endangered; and/or has naturally small populations susceptible to high risk from any factor that could lead to declines that would qualify it for threatened or endangered status.
4 The fully protected classification was California’s initial effort in the 1960s to identify and provide additional protection to those animals that were rare or faced possible extinction. The designation can be found in the California Fish and Game Code.
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Upper Westside Specific Plan 7-12 PLNP2018-00284
the resources cited at the beginning of this chapter formed the basis for analyzing the potential for special-status species to occur in the UWSP area.

The following set of criteria has been used to determine the potential for each species to occur within the study area.
 Present: The species has been documented in the study area by a reliable source.
 High potential to occur: The species has not been documented in the study area but is known to recently occur in the vicinity and suitable habitat is present.  Moderate potential to occur: The species has not been documented in the study area or vicinity, but the site is within the known range of the species and suitable habitat for the species is present.
 Low potential to occur: The species has not been documented in the study area or vicinity, but the site is within the known range of the species; however, suitable habitat for the species is of low quality.
 Not expected to occur: The study area is outside the known geographic or elevational range of the species and/or does not support suitable habitat for the species.

Species with a moderate or high potential to occur are considered to meet the threshold of potentially significant impact and are analyzed under the Impacts and Analysis section, below.

Special-status plant species that have a moderate to high potential to occur in the UWSP area include Sanford’s arrowhead (Sagittaria sanfordii), a species covered by the NBHCP.

Special-status and otherwise protected wildlife species that have a moderate to high potential to occur in the UWSP area include northwestern pond turtle (Actinemys marmorata), giant garter snake (Thamnophis gigas), tricolored blackbird (Agelaius tricolor), burrowing owl (Athene cunicularia), Swainson’s hawk (Buteo swainsoni), northern harrier (Circus hudsonius), white-tailed kite (Elanus leucurus), loggerhead shrike (Lanius ludovicianus), song sparrow “Modesto” population (Melospiza melodia); American white pelican (Pelecanus erythrorhynchus), white-faced ibis (Plegadis chihi), purple martin (Progne subis), yellow warbler (Setophaga petechia), yellow-headed blackbird (Xanthocephalus xanthocephalus), pallid bat (Antrozous pallidus), and valley elderberry longhorn beetle (Desmocerus californicus dimorphus) (Table BR-2).

Species that are on the CDFW Watch List (WL) that have a moderate or high potential to occur in the UWSP area include Cooper’s hawk (Accipiter cooperii), osprey (Pandion haliaetus), and white-faced ibis (Plegadis chihi). Watch List species are not considered special-status species; however, they are included in Table BR-2 because they were evaluated in biological resources assessment reports for the UWSP area (Bargas 2020; HELIX 2024) and/or are covered species in regional conservation plans. 7 - Biological Resources
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Table BR-2: Special-Status and NBHCP and MAP HCP Covered Species Evaluated for Potential Occurrence in the UWSP Area
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence PLANTS
Ferris' milk-vetch
Astragalus tener var.
ferrisiae
--/--/1B.1 Annual herb that grows in vernally mesic and subalkaline meadows and seeps, and valley and
foothill grasslands. Blooms from April to May.

Not expected. Vernally moist alkaline flats and
meadows are absent from the UWSP area.

Alkali milk-vetch
Astragalus tener var.
tener
--/--/1B.2 Annual herb that grows in playas and vernal pools of adobe clay, grasslands. Blooms from March to
June.

Not expected. Playas or vernal pools are absent from
the UWSP area.

Heartscale
Atriplex cordulata
var. cordulata
--/--/1B.2 Annual herb that grows in alkaline soils of
chenopod scrub, meadows and seeps, and valley
and foothill grassland (sandy). Blooms from April
to October.

Not expected. Alkaline habitats are absent from the
UWSP area.

Brittlescale
Atriplex depressa
--/--1B.2 Annual herb that grows in alkaline, clay soils of chenopod scrub, meadows and seeps, playas,
valley and foothill grasslands and vernal pools.

Blooms from April to October.

Not expected. Alkaline habitats are absent from the
UWSP area.

Bristly sedge
Carex comosa
--/--/2B.1 Perennial rhizomatous herb that grows in
wetlands of coastal prairies, marshes and
swamps, meadows and seeps, and valley and
foothill grasslands. Blooms from May to
September.

Low. Ditch margins present but provide poor habitat
from the UWSP area.

Pappose tarplant
Centromadia parryi
ssp. parryi
--/--/1B.2 Annual herb that is often found in alkaline
substrates of chaparral, coastal prairies, coastal
salt marshes and swamps, meadows and seeps,
and vernally mesic valley and foothill grasslands.

Blooms from May to November.

Not expected. Alkaline habitats are absent from the
UWSP area.
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Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Palmate-bracted
bird’s-beak
Chloropyron
palmatum
FE/SE/1B.1 Annual herb hemiparasite that grows in alkaline substrates of chenopod scrub and valley and
foothill grasslands. Blooms from May to October.

Not expected. Alkaline habitats are absent from the
UWSP area.

Peruvian dodder
Cuscuta obtusiflora
var. glandulosa
--/--/2B.2 Annual vine parasite that grows in marshes and swamps. Blooms from July to October.

Not expected. Suitable marsh or swamp habitat is
absent from the UWSP area.

Dwarf downingia
Downingia pusilla
--/--/2B.2 Annual herb that grows in mesic valley/foothill grasslands and vernal pools. Blooms from March
to May.

Not expected. Suitable vernal pool habitat and mesic
grasslands are absent from the UWSP area.

Jepson’s coyotethistle
Eryngium jepsonii
--/--/1B.2 Perennial herb that grows in mesic clay soil of valley and foothill grasslands and vernal pools.

Blooms from April to August.

Not expected. Suitable vernal pool habitat and mesic
grasslands are absent from the UWSP area.

San Joaquin
spearscale
Extriplex joaquinana
--/--/1B.2 Annual herb that grows in alkaline substrates of chenopod scrub, meadows and seeps, playas,
and valley and foothill grasslands. Blooms from
April to October.

Not expected. Alkaline habitats are absent from the
UWSP area.

Boggs Lake hedgehyssop
Gratiola
heterosepala
--/SE/1B.2 Annual herb that grows in vernal pools and lake margins. Blooms from April to August.

Not expected. Suitable vernal pool or lake margin
habitat is absent from the UWSP area.

Woolly rose-mallow
Hibiscus lasiocarpos
var. occidentalis
--/--/1B.2 Perennial rhizomatous herb that grows in
marshes/swamps, and often in riprap on the sides
of levees. Blooms from June to September.

Not expected. Suitable marsh or swamp habitats are
absent from the UWSP area.

Alkali-sink goldfields
Lasthenia
chrysantha
--/--/1B.1 Annual herb that grows in vernal pools. Blooms from February to April.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.
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Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Delta tule pea
Lathyrus jepsonii var.
jepsonii
--/--/1B.2 Perennial herb that grows in brackish and
freshwater marshes or swamps. Blooms from May
to July.

Not expected. Suitable marsh and swamp habitat is
absent from the UWSP area.

Legenere
Legenere limosa
--/--/1B.1 Annual herb that grows in vernal pools. Blooms from April to June.

Not expected. Vernal pools are absent from the UWSP
area.

Heckard’s peppergrass
Lepidium latipes var.
heckardii
--/--/1B.2 Annual herb that grows in alkaline flats in valley and foothill grassland. Blooms from March to May.

Not expected. Alkaline habitats are absent from the
UWSP area.

Mason's lilaeopsis
Lilaeopsis masonii
--/SR/1B.1 Perennial rhizomatous herb that grows in intertidal marshes and swamps, and riparian scrub. Blooms
from April to November.

Not expected. Intertidal habitat is absent from the
UWSP area.

Little mousetail
Myosurus minimus
ssp. apus
--/--/3.1 Annual herb found in alkaline vernal pools.

Blooms from March to June.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.

Baker's navarretia
Navarretia
leucocephala ssp.
bakeri
--/--/1B.1 Annual herb that grows in mesic cismontane
woodland, lower montane coniferous forest,
meadows and seeps, valley and foothill
grasslands, and vernal pools. Blooms from April to
July.

Not expected. Vernal pools and mesic grassland in
which this species may occur regionally is absent from
the UWSP area.

Colusa grass
Neostapfia colusana
FT/SE/1B.1 Annual herb that grows in vernal pools. Blooms from May to August.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.

Slender Orcutt grass
Orcuttia tenuis
FT/SE/1B.1 Annual herb that grows in vernal pools. Blooms from May to September.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.

Sacramento Orcutt
grass
Orcuttia viscida
FE/SE/1B.1 Annual herb that grows in vernal pools. Blooms from April to July.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.
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Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Bearded
popcornflower
Plagiobothrys
hystriculus
--/--/1B.1 Annual herb that grows in mesic valley and foothill grasslands, vernal pool margins, and often vernal
swales. Blooms from April to May.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.

California alkali
grass
Puccinellia simplex
--/--/1B.2 Annual herb that grows in vernally mesic alkaline flats and lake margins in chenopod scrub,
meadows and seeps, valley and foothill
grassland, and vernal pools. Blooms from March
to May.

Not expected. Alkaline habitats are absent from the
UWSP area.

Sanford's arrowhead
Sagittaria sanfordii
--/--/1B.2 Aquatic emergent perennial rhizomatous herb that grows in marshes, ponds, and ditches. Blooms
from May to October.

Moderate. There may be suitable habitat in aquatic
ditches in the UWSP area. There are two CNDDB
reported occurrences within a 5-mile radius of the study area.

Keck’s checkerbloom
Sidalcea keckii
FE/--/1B.1 Annual herb that grows in serpentine clay
substrates of cismontane woodland and valley
and foothill grassland. Blooms from April to May
or June.

Not expected. Serpentine substrates are absent from
the UWSP area.

Suisun Marsh aster
Symphyotrichum
lentum
--/--/1B.2 Perennial rhizomatous herb that grows in either brackish or freshwater area of marshes and
swamps. Blooms from March to November.

Not expected. Suitable marsh or swamp habitats are
absent from the UWSP area.

Saline clover
Trifolium
hydrophilum
--/--/1B.2 Annual herb that grows in marshes and swamps, mesic and alkaline valley and foothill grasslands,
and vernal pools. Blooms from April to June.

Not expected. Vernal pools, suitable marshes or
swamps, or alkaline habitats are absent from the UWSP
area.

Crampton's tuctoria
or Solano grass
Tuctoria mucronata
FE/SE/1B.1 Annual herb that grows in mesic valley and foothill grasslands and vernal pools. Blooms from April to
August.

Not expected. Vernal pools or vernal pool grassland
complexes are absent from the UWSP area.
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Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence

WILDLIFE
Invertebrates
Conservancy fairy
shrimp
Branchinecta
conservatio
FE/--/-- Found in vernal pools in the Central Valley ranging from Tehama County in the north to Merced
County in the south. Inhabit small, clear-water,
sandstone depression pools and grassed swale,
earth slump, or basalt-flow depression pools.

Not expected. Suitable vernal pool habitat is absent
from the UWSP area.

Vernal pool fairy
shrimp
Branchinecta lynchi
FT/--/-- Endemic to the grasslands of the Central Valley, central coast mountains, and south coast
mountains, in rain-filled pools. Inhabit small,
clear-water, sandstone depression pools and
grassed swale, earth slump, or basalt-flow
depression pools. Short life cycle requires shorter
hydroperiod than other vernal pool shrimp species.

Low. Vernal pool habitat is absent from the UWSP area,
but this species is capable of inhabiting more ephemeral pools such as tire ruts. Nearest CNDDB occurrence is 3
miles east of the UWSP area.

Midvalley fairy
shrimp
Branchinecta
mesovallensis
--/--/-- Endemic to small portion of the Central Valley.

Inhabit small, clear-water, sandstone depression
pools and grassed swale, earth slump, or
basalt-flow depression pools.

Not expected. Vernal pool habitat is absent from the
UWSP area.

Crotch’s bumble bee
Bombus crotchii
--/SSC/-- Open grasslands and scrub habitat in California with available underground nesting habitat in
fossorial animal burrows.

Not expected. Scrub habitat is not present and annual
grassland is fragmented and composes only a small
minority (17.3 acres or 0.79%) of the UWSP. No CNDDB
occurrence records in the UWSP area since 1998; one
verified record 7 miles south of the UWSP area from
2022 (Bumblebee Watch 2023). No iNaturalist records
within 5 miles of the UWSP (iNaturalist 2024).
7 - Biological Resources
Upper Westside Specific Plan 7-18 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Western bumble bee
Bombus occidentalis
--/SSC/-- Nests, forages, and overwinters in meadows and grasslands with abundant floral resources and
available underground nesting habitat in fossorial
animal burrows. Range is throughout California, but
more common in the Sierra Nevada and Coast
Ranges than in the Central Valley.

Not expected. Grassland habitat is available but is
fragmented and composes only a small minority
(17.3 acres or 0.79%) of the UWSP. No occurrence
records within 5 miles of the UWSP area (CDFW 2024
iNaturalist 2024; Bumble Bee Watch 2024).

Valley elderberry
longhorn beetle
Desmocerus
californicus
dimorphus
FT/--/-- Found in host plant along rivers and streams.

Occurs from southern Shasta County to Fresno
County. Only occurs on host plant, red or blue
elderberry (Sambucus spp.).

Moderate. Numerous CNDDB occurrence records along
the Sacramento and American rivers, but limited habitat present in woodlands within the study area. While no
elderberry shrubs have been specifically observed within the UWSP area, not all potentially suitable habitat within the study area was surveyed for their presence during
prior biological reconnaissance for the project due to
access restrictions (HELIX 2024; Bargas 2022).

Vernal pool tadpole
shrimp
Lepidurus packardi
FE/--/-- Endemic to California’s Great Central Valley, with the majority of the populations found in the
Sacramento Valley. Found in a wide variety of
ephemeral wetland habitats. Inhabits small, clear,
well-vegetated vernal pools to highly turbid pools.

Not expected. Vernal pool habitat is absent from the
UWSP area.

Fish
Sacramento perch
Archoplites
interruptus
--/SSC/-- Species occurs in sloughs, slow-moving rivers, and large lakes in the Central Valley.

Not expected. Suitable aquatic habitat is absent from
the UWSP area.

Green sturgeon –
southern DPS
Acipenser
medirostris pop. 1
FT/--/-- Spawn and rear juveniles in freshwater rivers.

Migrate to saltwater to feed, grow, and mature.

Return to freshwater to spawn.

Not expected. Known to migrate through the
Sacramento River adjacent to the UWSP area; however,
the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the Sacramento River
by pumping plants, making fish passage highly unlikely. 7 - Biological Resources
Upper Westside Specific Plan 7-19 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Delta smelt
Hypomesus
transpacificus
FT/SE/-- Spawn in tidally influenced freshwater, backwater sloughs, and channel edge waters. Rearing and
maturation occurs in low-salinity waters, followed
by a winter upstream migration before spawning.

Not expected. Occurs in the Sacramento River;
however, the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the
Sacramento River by pumping plants, making fish
passage highly unlikely.

Steelhead – central
valley DPS
Oncorhynchus
mykiss irideus pop.
11 FT/--/-- Hatch in gravel-bottomed, fast-flowing freshwater streams. Migrate to the ocean to feed and mature.

Return to freshwater to spawn.

Not expected. Occurs in the Sacramento River;
however, the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the
Sacramento River by pumping plants, making fish
passage highly unlikely.

Chinook salmon –
Central Valley
spring-run ESU
Oncorhynchus
tshawytscha pop. 11
FT/ST/-- Spawn and rear juveniles in freshwater rivers.

Migrate to saltwater to feed, grow, and mature.

Return to freshwater to spawn.

Not expected. Known to migrate through the
Sacramento River adjacent to the UWSP area; however,
the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the Sacramento
River by pumping plants, making fish passage highly
unlikely.

Chinook salmon –
Sacramento River
winter-run ESU
Oncorhynchus
tshawytscha pop. 7
FE/SE/-- Spawn and rear juveniles in freshwater rivers.

Migrate to saltwater to feed, grow, and mature.

Return to freshwater to spawn.

Not expected. Known to migrate through the
Sacramento River adjacent to the UWSP area; however,
the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the Sacramento
River by pumping plants, making fish passage highly
unlikely.

Sacramento splittail
Pogonichthys
macrolepidotus
--/SSC/-- Endemic to the Central Valley. Largely confined to the Delta, Suisun Bay, Suisun Marsh, Napa River,
Petaluma River, and Sacramento-San Joaquin
estuary. Occurs primarily in freshwater estuarine
systems and prefers low salinity, shallow-water
habitats.

Not expected. Known to be present in the Sacramento
River adjacent to the UWSP area; however, the West
Drainage Canal (Witter Canal) and all canals in the
UWSP area are separated from the Sacramento River
by pumping plants, making fish passage highly unlikely. 7 - Biological Resources
Upper Westside Specific Plan 7-20 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Longfin smelt
Spirinchus
thaleichthys
FC/ST/-- Inhabits nearshore waters, estuaries, and lower portions of freshwater streams. Spawn in
freshwater streams with sandy or gravel
substrates, rocks, and aquatic plants.

Not expected. Known to migrate through the
Sacramento River adjacent to the UWSP area; however,
the West Drainage Canal (Witter Canal) and all canals in the UWSP area are separated from the Sacramento
River by pumping plants, making fish passage highly
unlikely.

Reptiles
Northwestern pond
turtle
Actinemys
marmorata
FC/SSC/-- A thoroughly aquatic turtle of ponds, marshes, rivers, streams, and irrigation ditches with aquatic
vegetation. Needs basking sites and suitable
upland habitat for egg-laying (e.g., sandy banks or
grassy open fields). Preys on tadpoles, frog eggs,
snails, aquatic beetles, dragonfly larvae, and fish.

Moderate. Canals in the UWSP area offer suitable
aquatic habitat.

Giant garter snake
Thamnophis gigas
FT/ST/-- Associated with marshes and sloughs. Absent
from larger rivers. Active mid-March through
October. Extremely aquatic; rarely found away
from water during the active season. Retreats to
small-mammal burrows, soil cracks and fissures,
and crevices in riprap.

High. Many recent CNDDB records in the vicinity of the
UWSP area, including along the West Drainage Canal
(Witter Canal) at the northern edge of the UWSP area.

Canals in the UWSP area provide marginally suitable
habitat that is connected to higher quality habitat. Recent trapping surveys in the UWSP area entailing 40,703 total trap days yielded no giant garter snake captures (HELIX 2024). Canals in the UWSP area likely support the
species on a transitory basis based on positive eDNA
samples for the species at one location in the study area and three locations in ditches surrounding the study area over two years (HELIX 2024).
7 - Biological Resources
Upper Westside Specific Plan 7-21 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Amphibians
Western spadefoot
toad
Spea hammondii
--/SSC/-- Breeds in ephemeral pools in open grassland
habitat; remains underground for much of the
year. Requires 2 to 18 weeks of standing water for
larval development.

Not expected. Ephemeral pools are absent from the
UWSP area.

California tiger
salamander
Ambystoma
californiense
FT/ST/-- Breeds in ephemeral pools in open grassland
habitat; remains underground for much of the
year. Requires 2 to 18 weeks of standing water for
larval development.

Not expected. Ephemeral pools are absent from the
UWSP area.

Birds
Cooper’s hawk
Accipiter cooperii
--/WL/-- Nests in riparian areas and oak woodlands, and hunts songbirds at woodland edges. Increasingly
found nesting in neighborhood street trees.

Present year-round.

Present. Open fields and pastures in the UWSP area
provide suitable habitat. The species was observed on
March 7, 2023 (HELIX 2024).

Tricolored blackbird
Agelaius tricolor
BCC/ST/-- Nests colonially in emergent wetland vegetation and blackberry bushes extensive enough to
support a large colony. Forages in agricultural
fields, grasslands, flooded pastures, and edges of
ponds. Present year-round in the Central Valley.

Moderate. Suitable nesting habitat in the UWSP area
includes emergent vegetation along ditches and canals
and blackberry bushes. Agricultural fields in the UWSP
area provide suitable foraging habitat. Numerous
CNDDB occurrences in the UWSP area.

Grasshopper
sparrow
Ammodramus
savannarum
--/SSC/-- Grasslands, prairies, hayfields, and open pastures with scattered shrubs and often with some bare
ground. Builds a domed nest out of grasses on
the ground, often at the base of a clump of grass.

Present in the Central Valley during the breeding
season.

Low. Annual grasslands provide marginally suitable
habitat for nesting and foraging. No CNDDB occurrences
within 5 miles of the UWSP area; however, observations
of the species within 5 miles 92024, 2006) and 2 miles
(2013) of the UWSP area have been documented in
eBird.
7 - Biological Resources
Upper Westside Specific Plan 7-22 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Burrowing owl
Athene cunicularia
--/SSC/-- Open, dry, annual or perennial grasslands,
deserts, and scrublands characterized by
low-growing vegetation. Utilizes rodent burrows,
especially California ground squirrel burrows, or
alternative refuge, such as riprap, culverts, etc.

Present year-round.

Moderate. Suitable habitat is present in the UWSP area
in ruderal or fallowed fields and along the banks of
ditches, canals, and levees, especially where smallmammal burrows are present. One CNDDB occurrence from 1991 east of the UWSP area.

Cackling (=Aleutian
Canada) goose
Branta hutchinsii
leucopareia
FD/WL/-- Lacustrine, fresh emergent wetlands, and moist grasslands, croplands, pastures, and meadows.

Grazes in marshes and stubble fields, roosts in
the water. Present only during winter in the
Central Valley.

Low: This species is not documented in the UWSP area;
however, it may migrate through or forage in the UWSP
area on a transitory basis, during the winter. Suitable foraging habitat is present in agricultural fields in the UWSP area.

Ferruginous hawk
Buteo regalis
--/WL/-- Semiarid grasslands, rocky outcrops, and shallow canyons. Nests on rocky outcrops, hillsides, rock
pinnacles, or in trees. Present only during winter
in the Central Valley.

Low. This species may migrate through the UWSP area
during the winter but is not here during the breeding
season. Fragmented grasslands provide marginally
suitable foraging habitat in the UWSP area.

Swainson’s hawk
Buteo swainsoni
--/ST/-- Breeds in grasslands with scattered trees,
juniper-sage flats, riparian areas, savannas, and
agricultural or ranch areas. Requires adjacent
suitable foraging areas such as grasslands, or
alfalfa or grain fields supporting rodent populations.

Present during breeding season with a minority of
the population overwintering in the Central Valley.

High. Agricultural areas and grassland provide foraging habitat for Swainson’s hawk. This species was observed
nesting and foraging in the study area during surveys in 2019, 2020, and 2021 (Bargas 2022) and there are
numerous CNDDB occurrences in the UWSP area.

Mountain plover
Charadrius
montanus
--/SSC/-- Inhabits open grasslands, open sagebrush areas, and plowed fields with little vegetation. Present
only during winter in the Central Valley.

Low. This species may migrate through the UWSP area
during the winter but is not here during the breeding
season. Fragmented grasslands provide marginally
suitable foraging habitat in the UWSP area.

Western snowy
plover
Charadrius nivosus
nivosus
FT/SSC/-- Found in sparsely vegetated coastal beaches, salt flats and river sandbars. Found year-round on
coastal California.

Not expected. Outside of species’ known range and no
suitable habitat occurs within the UWSP area.
7 - Biological Resources
Upper Westside Specific Plan 7-23 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Northern harrier
Circus hudsonius
--/SSC/-- Found in grasslands, rangelands, and fresh and saltwater emergent wetlands. Nests on the
ground in tall vegetation. Present year-round in
the Central Valley.

Present. Suitable foraging habitat present. Species
observed foraging the UWSP area in 2019 and 2021
(Bargas 2022). Suitable nesting habitat may be present
in emergent vegetation along ditches and canals.

Western yellow-billed
cuckoo
Coccyzus
americanus
occidentalis
FT/CE/-- Found in deciduous riparian habitat with dense foliage. Nests in willows and dense understory.

Present in California only during the breeding
season.

Not expected. Suitably expansive riparian habitat
(generally considered to be a minimum of 300 feet wide) is not present in the UWSP area except for very limited stretches along the Sacramento River. This species is
sensitive to human disturbances and the presence of
traffic noise along Garden Highway and many residences
within the riparian area along the Sacramento River are expected to preclude occupancy by the species. Per the
CNDDB, western yellow-billed cuckoo has not been
documented since the late 1800s in the Sacramento River riparian corridor west of the UWSP area and the species is considered extirpated from this area.

White-tailed kite
Elanus leucurus
--/FP/-- Forages in open plains, grasslands, and prairies; typically nests in trees. Present year-round in the
Central Valley.

High. Suitable nesting trees and suitable foraging
habitat in agricultural fields, pastures, and grasslands are present in the UWSP area. This species was
observed foraging and possibly nesting in the UWSP
area in 2019 (Bargas 2022).

Merlin
Falco columbarius
--/WL/-- Inhabits open grasslands, woodlands, and
wetlands. Roosts in dense trees near bodies of
water. Present only during winter in the Central
Valley.

Low. This species may migrate through the UWSP area
during the winter but does not breed in the Central
Valley. Foraging and roosting habitat is limited.

American peregrine
falcon
Falco peregrinus
anatum
FD/SD/-- Breeds near water with nearby vertical structures such as cliffs, bridges, high-rise buildings, and
former nests of common raven and osprey on
electric transmission towers and boat navigation
markers serving as nesting sites. Preys on birds,
which it takes on the wing.

Low. No potential nesting habitat in the UWSP area.

May forage on or transit through the UWSP area.
7 - Biological Resources
Upper Westside Specific Plan 7-24 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Greater sandhill
crane
Grus canadensis
tabida
--/ST, FP/-- Breeds in open wetland habitats surrounded by shrubs or trees. During the non-breeding season,
this species roosts on shallow lakes or rivers at
night and spends the day foraging in irrigated
croplands, pastures, grasslands, or wetlands.

Present in the Central Valley only during winter.

Low. Suitable wintering habitat is present in the UWSP
area; however, the species is not known to use the
Natomas Basin.

Loggerhead shrike
Lanius ludovicianus
--/SSC/-- Inhabits shrub and grassland habitat and
agricultural fields. Nests in shrubs, trees, and
vines in open and riparian habitats. Present yearround in the Central Valley.

High. No CNDDB occurrences, but the species is
observed regularly throughout the Natomas Basin (City
of Sacramento et al. 2003). Suitable habitat is present in the UWSP area.

California black rail
Laterallus
jamaicensis
coturniculus
--/ST, FP/-- Inhabits wetlands, marshes, and swamps.

Requires stable, shallow water for foraging.

Present year-round in the Central Valley.

Not expected. Outside species’ known range and
suitable habitat is absent from the UWSP area.

Song sparrow
(“Modesto”
population)
Melospiza melodia
pop.1
--/SSC/-- Prefers riparian, fresh, or saline emergent wetland and wet meadow habitats. Requires riparian
thickets of willows, shrubs, vines, tall herbs, and
emergent vegetation for breeding. Present yearround in the Central Valley.

High. Suitable nesting habitat is present within emergent vegetation along ditches and canals in the UWSP area.

Double-crested
cormorant
Phalacrocorax
auritus
--/WL/-- Inhabits fresh, salt, and estuarine waters,
including inland lakes. Roosts beside water in
offshore rocks and steep cliffs. Does not breed in
the Central Valley.

Not expected. Suitable habitat is absent from the
UWSP area.

Osprey
Pandion haliaetus
--/WL/-- Inhabits large trees and snags in open forests and tall human-made structures such as cranes and
light fixtures. Forages in open and clear waters of
rivers, lakes, and estuaries. Present year-round in
the Central Valley.

Present. Suitable foraging habitat along the Sacramento river and suitable nesting habitat in trees and structures in the UWSP area. Species was observed in flight over
the UWSP area on March 7, 2023 (HELIX 2024).
7 - Biological Resources
Upper Westside Specific Plan 7-25 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence American white
pelican
Pelacanus
erythrorhynchos
--/SSC/-- Inhabits lakes, marshes, and salt bays. Breeds inland on isolated islands, while wintering on
shallow protected bays and estuaries. Present
year-round in the Central Valley.

High (foraging only). Species observed foraging and
loafing in the canals of the UWSP area (Bargas 2022).

No suitable breeding habitat in the UWSP area.

White-faced ibis
Plegadis chihi
--/WL/-- Roosts near dense, freshwater vegetation or low shrubs over water. Nesting requires extensive
marshes. Present year-round in the Central
Valley.

Moderate (foraging only). Agricultural fields may
provide suitable foraging habitat, depending on the crop.

No suitable nesting habitat in the UWSP area.

Purple martin
Progne subis
--/SSC/-- Nests in cavities in open areas with low canopy cover over height of the nest, near bodies of water
that support high densities of insects. Cavities
used include bird houses, bridges, buildings, and
woodpecker holes in dead trees. They forage over
cities, parks, open fields, dunes, streams, wet
meadows, and other open areas. Present during
the breeding season in the Central Valley.

Moderate. Most recent CNDDB occurrence is 2.5 miles
from the UWSP area from 2007; however, tree cavities
in large trees or utility poles provide suitable nesting habitat in the UWSP area.

Bank swallow
Riparia riparia
--/ST/-- Generally found near larger bodies of water, such as rivers, lakes, or even the ocean, throughout the
year. They forage in open areas such as
grassland and farmland and tend to avoid dense
forests and mountainous areas. Present during
the breeding season in the Central Valley.

Low. This species is not documented in the UWSP area;
however, it may migrate through or forage in the UWSP
area on a transitory basis, during the winter. Suitable foraging habitat is present in agricultural fields in the UWSP area.

Yellow warbler
Setophaga petechia
--/SSC/-- Found in bushes, swamp edges, streams, and
gardens. Breeds in streamside thickets and
riparian woodlands and gleans insects from
branches of shrubs and small trees. Present
during the breeding season in the Central Valley.

High. While no breeding habitat is present, given the
lack of preferred riparian habitat conditions within the study area, species likely uses the Sacramento River
riparian corridor and utilizes other woodlands and shrubs for foraging in the UWSP area.

Least Bell’s vireo
Vireo bellii pusillus
FE/SE/-- Inhabits grasslands and riparian areas including brushy fields and riverine scrub. Nests in shrubs
and small trees.

Not expected. Outside of species’ known range.
7 - Biological Resources
Upper Westside Specific Plan 7-26 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence Yellow-headed
blackbird
Xanthocephalus
xanthocephalus
--/SSC/-- Inhabit freshwater wetlands and farm fields, nests in reeds over the water. Present during the
breeding season in the Central Valley.

Moderate. Nesting habitat is present in the UWSP area
along ditches and canals with emergent vegetation.

Agricultural fields in the UWSP area may provide
adequate foraging habitat. Observed east of the UWSP
area during recent field surveys (Bargas 2022).

Mammals
Pallid bat
Antrozous pallidus
--
/SSC/WBW
G (High)
A wide variety of habitats is occupied, including
grasslands, shrublands, woodlands, and forests
from sea level up through mixed conifer forests.

The species is most common in open, dry habitats
with rocky areas for roosting. Roosts in buildings,
caves, tree hollows, crevices, mines, and bridges.

Moderate. No CNDDB occurrence records in the UWSP
area; however, potentially suitable roosting habitat in buildings, bridges, and tree cavities is present in the UWSP area.

Silver-haired bat
Lasionycteris
noctivagans
--/--/WBWG
(Medium)
Most common in open, dry habitats with rocky
areas for roosting. Roosts on buildings, under
bridges and overpasses, and hollow trees.

Forages over open meadows, above the canopy
and in riparian zone.

Low. Open, dry, rocky habitat is absent from the UWSP
area, but buildings, bridges and trees are present. No
CNDDB occurrence records in the UWSP area.

Hoary bat
Lasiurus cinereus
--/--/ WBWG
(Medium)
Solitary rooster in tree foliage. Habitats include
woodlands, forests, and riparian habitats with
dense foliage. Winters along the coast and in
Southern California, breeding inland and north of
the winter range. During migration can be found
throughout California.

Low. Very limited suitable roosting habitat in trees at the western edge of the UWSP area, which is planned to
remain agricultural. No CNDDB occurrence records in
the UWSP area.

American badger
Taxidea taxus
--/SSC/-- Most abundant in drier open stages of most
shrub, forest, and herbaceous habitats, with
friable soils. Needs sufficient food, friable soil, and open, uncultivated habitat. Preys on burrowing
rodents.

Not expected. No suitable habitat within the UWSP area
and the only CNDDB occurrence record in Sacramento
County is from 1938.
7 - Biological Resources
Upper Westside Specific Plan 7-27 PLNP2018-00284
Common Name/
Scientific Name
Listing
Status
USFWS/
CDFW/
CRPR Habitat, Ecology, and Life History Potential for Species Occurrence SOURCES: CDFW 2023; CNPS 2023; USFWS 2023
NOTES: CDFW = California Department of Fish and Wildlife; CNDDB = California Natural Diversity Database; CRPR = California Rare Plant Rank; Delta = Sacramento–San Joaquin Delta; DPS = distinct population segment; ESU = evolutionarily significant unit; MAP HCP = Metro Air Park Habitat Conservation Plan; NBHCP = Natomas Basin Habitat Conservation Plan; USFWS = U.S. Fish and Wildlife Service; UWSP = Upper Westside Specific Plan
STATUS CODES:

FEDERAL: (U.S. Fish and Wildlife Service)
FT = Listed as Threatened (likely to become Endangered within the foreseeable future) by the Federal Government.

FE= Listed as Endangered by the Federal Government
FC = Candidate for federal listing
FD= Delisted
STATE:

ST = Listed as Threatened by the State of California
SE= Listed as Endangered by the State of California
CC = California Candidate for Listing
SSC = California Species of Special Concern
FP= California Department of Fish and Wildlife designated “fully protected”
SD = delisted
WL = Watch list
OTHER:

California Native Plant Society (CNPS) California Rare Plant Ranks (CRPR):
1B = Rare, threatened, or endangered throughout range; Most species in this rank are endemic to California.
2B = Rare, threatened, or endangered in California but common in other parts of its range.
3 = Need more information about species to assign it a ranking. .1 = Seriously endangered in California
.2 = Fairly endangered in California
WBWG = Western Bat Working Group:

Low = Stable population
Medium = Need more information about the species, possible threats, and protective actions to implement.

High= Imperiled or at high risk of imperilment.
7 - Biological Resources
Upper Westside Specific Plan 7-28 PLNP2018-00284

CRITICAL HABITAT
USFWS and the National Marine Fisheries Service designate critical habitat for species that they have listed as threatened or endangered. “Critical habitat” is defined in FESA Section 3(5)(A) as those lands (or waters) within a listed species’ current range that contain the physical or biological features that are considered essential to the species’ conservation, as well as areas outside the species’ current range that are determined to be essential to its conservation. Critical habitat may include an area that is not currently used by an endangered or threatened species but that will be needed for species recovery. No critical habitat is designated within the UWSP area and critical habitat is not discussed further in this chapter.

REGULATORY SETTING

FEDERAL

FEDERAL ENDANGERED SPECIES ACT
FESA is the federal government’s set of regulations protecting rare and declining plant and wildlife species. FESA is jointly implemented by USFWS and the National Marine Fisheries Service (marine resources only). FESA protects species using the following status designations: endangered, threatened, proposed, and candidate. A federally endangered species is a species of invertebrate, plant, or wildlife formally listed by the USFWS under FESA as facing extinction throughout all or a significant portion of its range. A federally threatened species is formally listed as likely to become endangered within the foreseeable future throughout all or a significant portion of its range.

A proposed threatened or endangered species has been formally proposed for addition to either the threatened or endangered lists. Candidate species are species with evidence to be proposed as threatened or endangered.

FESA also requires the USFWS to consider whether there are areas of habitat essential to conservation for each listed species. Critical habitat designations protect these areas, including habitat that is currently unoccupied but may be essential to the recovery of a species. An area is designated as critical habitat after the USFWS publishes a proposed federal regulation in the Federal Register and then receives and considers public comments on the proposal. The final boundaries of critical habitat are officially designated when published in the Federal Register.

Section 9 of the FESA prohibits the “take” of federally endangered or threatened wildlife species. Take is defined under FESA (Section 2[19]) to mean “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” Harm is further defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns (50 CFR Section 17.3). Harass is defined as actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns (50 CFR Section 17.3).
7 - Biological Resources
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Section 10(a)(1)(b) of the FESA allows for the take of a threatened or endangered species incidental to development once an HCP has been prepared to the satisfaction of the USFWS, with a Section 10(a) incidental take permit.

For federal projects, Section 7 of the FESA allows for consultation between the affected agency and the USFWS to determine what measures may be necessary to compensate for the incidental take of a listed species. A federal project is any project that is proposed by a federal agent or is at least partially funded or authorized by a federal agency. Additionally, if the listed species or its habitat occurs in a portion of the project subject to federal agency jurisdiction, then consultation under Section 7 is usually permissible and may be required.

MIGRATORY BIRD TREATY ACT
The Migratory Bird Treaty Act of 1918 (MBTA) is a federal law governing the taking, killing, possession, transportation, and importation of various birds, their eggs, parts, and nests. The take of any bird species listed as protected on any treaty lists governed by the MBTA’s regulation of taking migratory birds for educational, scientific, and recreational purposes and requiring harvest level to be limited to prevent over utilization.

The MBTA also prohibits taking, possession, import, export, transport, selling, purchase, barter, or offering for sale purchase or barter, of certain bird species, their eggs, parts, and nests, except as authorized under a valid permit.

CLEAN WATER ACT
Under CWA Section 404, the USACE has primary federal responsibility for administering regulations that concerns waters of the United States. Section 404 of the CWA regulates the discharge of dredged or fill material into waters of the United States.

Fill material is material placed in waters of the United States where the material has the effect of replacing any portion of a water of the United States with dry land or changing the bottom elevation of any portion of a water of the United States. Waters of the United States include navigable waters of the United States; interstate waters; all other waters where the use, degradation, or destruction of the waters could affect interstate or foreign commerce; tributaries to any of these waters, and wetlands adjacent to these waters. Wetlands are defined as those areas that are inundated or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. The USACE requires that a permit be obtained if a project proposes the placement of structures within, over, or under navigable waters and/or discharging dredged or fill material into waters below the ordinary high-water mark.

Under CWA Section 401, applicants for a federal license or permit to conduct activities that may result in the discharge of a pollutant into waters of the United States must apply for water quality certification from the state. Therefore, all projects with a federal component that may affect state water quality (including projects that require federal agency approval, such as a Section 404 permit) must comply with CWA Section 401. As part of the permitting process under Section 404, applicants would be required to apply for water quality certification from the Central Valley RWQCB. 7 - Biological Resources
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STATE

CALIFORNIA ENDANGERED SPECIES ACT
CESA prohibits the take of state-listed threatened and endangered species. Under CESA, CDFW is responsible for maintaining a list of rare, threatened, and endangered species designated under state law (CFGC Sections 2070–2079). CDFW maintains a list of candidate species that have been formally put under review for addition to the state threatened and endangered list. CDFW also maintains a list of species of special concern which are considered as sensitive. The CDFW can authorize take if an incidental take permit is issued by the Secretary of the Interior or Commerce in compliance with FESA, or under CFGC Section 2081 where it is demonstrated that the impacts are minimized and mitigated.

CALIFORNIA FISH AND GAME CODE
Section 1600 of the CFGC provides provisions for protecting riparian systems, including bed, banks, and riparian habitat of lakes, seasonal and perennial streams, and rivers.

This section requires an applicant to notify CDFW and obtain a Lake and Streambed alteration Agreement if their project would divert or obstruct the natural flow of any river, stream, or lake; change the bed, channel, or bank of any river, stream, or lake; use material from any river, stream, or lake; or deposit or dispose of material into any river, stream, or lake.

Section 2050 regards the CESA, establishing the policy of the state to conserve, protect, and enhance threatened or endangered species and their habitats. CESA is administered by CDFW and prohibits the take of any species that the California Fish and Game Commission determines to be a threatened or endangered species. CESA also mandates that “state agencies should not approve projects as proposed which would jeopardize the continued existence of any endangered species or threatened species” if reasonable and prudent alternatives are available that would avoid jeopardy.

CDFW administers CESA and authorizes take through CFGC Section 2081 incidental take permits or through Section 2080.1 for species also listed under FESA.

Section 3511 states that “fully protected” birds, which are those protected prior to the creation of CESA, and parts thereof may not be taken or possessed at any time. Lists of fully protected species were initially developed to provide protection to this that were rare or faced possible extinction and most have since been listed as threatened or endangered under CESA and/or FESA.

CFGC Sections 3503, 3503.5, 3505, and 3513 protect all birds, birds of prey, and all nongame birds, as well as their eggs and nests, for species that are not already listed as fully protected and that occur naturally within the state. Section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by the CFGC or any regulation made pursuant thereto. Section 3503.5 states that it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by the CFGC or any regulation 7 - Biological Resources
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adopted pursuant thereto. Section 3513 states that it is unlawful to take or possess any migratory nongame bird as designated in the Migratory Bird Treaty Act or any part of such migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the MBTA.

PORTER-COLONE WATER QUALITY CONTROL ACT
The Porter-Cologne Water Quality Control Act of 1969 established the State Water Resources Control Board (SWRCB) and the nine RWQCBs. The act authorized the SWRCB and the RWQCBs to provide oversight for water rights and water quality. It uses the National Pollutant Discharge Elimination System to monitor point-source discharges into the waters of the state to prevent water quality degradation. The act also protects wetlands surface waters, and groundwater from both point and nonpoint sources of pollution.

STATE WETLAND DEFINITION AND PROCEDURES
The SWRCB adopted the State Wetland Definition and Procedures for Discharges or Fill Material to Waters of State in 2019 and completed revisions to the set of procedures in 2021. It outlines that an area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water or both; (2) the duration of such saturation is sufficient to cause anerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.

Waters of the state are broadly defined by the Porter-Cologne Water Quality Control Act as “any surface water or groundwater, including saline waters, within the boundaries of the state.” The 2021 procedures expand upon this definition to in to clearly include natural wetlands, wetlands created by modification of a surface water of the state, and artificial wetlands meeting specific criteria. The criteria include wetlands created for agency-approved compensatory mitigation; those identified in a water quality control plan; and those greater than or equal to 1 acre in size unless they are constructed and maintained for wastewater treatment or disposal, sediment setting, stormwater permitting program pollutant or runoff management, surface water treatment, agricultural crop irrigation or stock watering, fire suppression, industrial processing and cooling, active surface mining, log storage, recycled-water management, maximizing groundwater recharge, and rice paddies. Wetland delineation procedures follow those defined by USACE for aquatic resources delineation used to assess the presence or absence of hydrophilic vegetation, hydric soils, and wetland hydrology as required by the SWRCB to delineate waters of the state, with one modification being that “the lack of vegetation does not preclude the determination of such an area that meets the definition of wetland.”
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LOCAL
SACRAMENTO COUNTY 2030 GENERAL PLAN
The following policies from the Agricultural, Conservation, Land Use, and Open Space elements of the Sacramento County 2030 General Plan (County of Sacramento 2011) are applicable to the proposed UWSP. Please note that select policies below have been updated to reflect proposed General Plan Text Amendments requested by the project applicant (see Appendix PD-1). Changes to the text of the policies are shown by either strikethrough where text has been deleted, or double underline where new text has been inserted.

AGRICULTURAL
AG-15 The County shall pursue opportunities to create mitigation banks, environmental mitigation sites, wildlife refuges, or other natural resource preserves wherein substantial agricultural activities that are compatible with protection of high habitat values continue, but incompatible activities and conversion for development are precluded by conservation easements.

AG-17 The establishment of conservation easements combining preservation of agricultural uses, habitat values, and open space on the same property should be encouraged where feasible.

CONSERVATION
CO-25 Support the preservation, restoration, and creation of riparian corridors, wetlands and buffer zones.

CO-26 Protect areas susceptible to erosion, natural water bodies, and natural drainage systems.

CO-58 Ensure no net loss of wetlands, riparian woodlands, and oak woodlands.

CO-59 Ensure mitigation occurs for any loss of or modification to the following types of acreage and habitat function:
 vernal pools,
 wetlands,
 riparian,
 native vegetative habitat, and
 special-status species habitat.

CO-60 Mitigation should be directed to lands identified on the Open Space Vision Diagram and associated component maps (please refer to the Open Space Element), consistent with LU-114.
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CO-61 Mitigation should be consistent with Sacramento County-adopted Habitat Conservation Plans.

CO-62 Permanently protect land required as mitigation.

CO-64 Consistent with overall land use policies, the County shall support and facilitate the creation and biological enhancement of large natural preserves or wildlife refuges by other government entities or by private individuals or organizations.

CO-65 Create a network of preserves linked by wildlife corridors of sufficient size to facilitate the movement of species.

CO-66 Mitigation sites shall have a monitoring and management program including an adaptive management component including an established funding mechanism. The programs shall be consistent with Habitat Conservation Plans that have been adopted or are in draft format.

CO-67 Preserves and conservation areas should have an established funding mechanism, and where needed, an acquisition strategy for its operation and management in perpetuity. This includes existing preserves such as the American River Parkway, Dry Creek Parkway, Cosumnes River Preserve and other plans in progress for riparian areas like Laguna Creek.

CO-68 Preserves shall be planned and managed to the extent feasible so as to avoid conflicts with adjacent agricultural activities (Please also refer to the Agricultural Element).

CO-69 Avoid, to the extent possible, the placement of new major infrastructure through preserves unless located along disturbed areas, such as existing roadways.

CO-70 Community Plans, Specific Plans, Master Plans and development projects shall:
 Include the location, extent, proximity and diversity of existing natural habitats and special-status species in order to determine potential impacts, necessary mitigation and opportunities for preservation and restoration.
 Be reviewed for the potential to identify nondevelopment areas and establish preserves, mitigation banks and restore natural habitats, including those for special-status species, considering effects on vernal pools, groundwater, flooding, and proposed fill or removal of wetland habitat.
 Be reviewed for applicability of protection zones identified in this Element, including the Floodplain Protection Zone, Stream Corridor Ordinance, 7 - Biological Resources
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Cosumnes River Protection Combining Zone and the Laguna Creek Combining Zone.

CO-71 Development design shall help protect natural resources by:
 Minimizing total built development in the floodplain, while designing areas of less frequent use that can support inundation to be permitted in the floodplain.
 Ensuring development adjacent to stream corridors and vernal pools provide, where physically reasonable, a public street paralleling at least one side of the corridor with vertical curbs, gutters, foot path, street lighting, and post and cable barriers to prevent vehicular entry.  Projects adjacent to rivers and streams shall integrate amenities, such as trail connectivity, that will serve as benefits to the community and ecological function.
 Siting of wetlands near residential and commercial areas should consider appropriate measures to minimize potential for mosquito habitation.  Development adjacent to stream corridors and vernal pools shall be designed in such a manner as to prevent unauthorized vehicular entry into protected areas
CO-72 If land within river and stream watersheds in existing agricultural areas is developed for non-agricultural purposes, the County should actively pursue easement dedication for recreation trails within such development as a condition of approval.

CO-75 Maintain viable populations of special-status species through the protection of habitat in preserves and linked with natural wildlife corridors.

CO-78 Plans for urban development and flood control shall incorporate habitat corridors linking habitat sites for special-status species. (Please also refer to the Open Space Element for related policies.)
CO-89 Protect, enhance and maintain riparian habitat in Sacramento County.

CO-91 Discourage introductions of invasive non-native aquatic plants and animals.

CO-120 Development projects adjacent to rivers and streams shall provide unencumbered maintenance access.

CO-121 No grading, clearing, tree cutting, debris disposal or any other despoiling action shall be allowed in rivers and streams except for normal channel maintenance, restoration activities, and road crossings.

CO-134 Maintain and establish a diversity of native vegetative species in Sacramento County.
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CO-137 Mitigate for the loss of native trees for road expansion and development consistent with General Plan policies and/or the County Tree Preservation Ordinance.

CO-138 Protect and preserve non-oak native trees along riparian areas if used by Swainson’s Hawk, as well as landmark and native oak trees measuring a minimum of 6 inches in diameter or 10 inches aggregate for multi-trunk trees at 4.5 feet above ground.

CO-139 Native trees other than oaks, which cannot be protected through development, shall be replaced with in-kind species in accordance with established tree planning specifications, the combined diameter of which shall equal the combined diameter of the trees removed.

CO-145 Removal of non-native tree canopy for development shall be mitigated by creation of new tree canopy equivalent to the acreage of non-native tree canopy removed. New tree canopy acreage shall be calculated using the 15-year shade cover values for tree species.

CO-146 If new tree canopy cannot be created onsite to mitigate for the non-native tree canopy removed for new development, project proponents (including public agencies) shall contribute to the Greenprint funding in an amount proportional to the tree canopy of the specific project.

CO-147 Increase the number of trees planted within residential lots and within new and existing parking lots.

CO-149 Trees planted within new or existing parking lots should utilize pervious cement and structured soils in a radius from the base of the tree necessary to maximize water infiltration sufficient to sustain the tree at full growth.

LAND USE
LU-15 Planning and development of new growth areas should be consistent with Sacramento County-adopted Habitat Conservation Plans and/or other efforts to preserve and protect natural resources.

OPEN SPACE
OS-1 Actively plan to protect, as open space, areas of natural resource value, which may include but are not limited to wetlands preserves, riparian corridors, woodlands, and floodplains associated with riparian drainages.

OS-2 Maintain open space and natural areas that are interconnected and of sufficient size to protect biodiversity, accommodate wildlife movement and sustain ecosystems.

OS-9 Open space easements obtained and offered as mitigation shall be dedicated to the County of Sacramento, an open space agency, or an organization 7 - Biological Resources
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designated by the County to protect and manage the open space. Fee title of land may be dedicated to the County, the open space agency, or organization provided it is acceptable to the appropriate department or agency (Please also refer to Section V of the Conservation Element for related policies).

SACRAMENTO COUNTY TREE ORDINANCE
The Sacramento County Tree Preservation and Protection Ordinance (Chapter 19.12 of the County Code) regulates removal and impacts on certain tree species and establishes a County policy to preserve all trees possible through its development review process.

The Sacramento County Tree Ordinance does not apply to the Natomas Basin and would not pertain to the proposed UWSP; however, the Sacramento County General Plan policy protecting native trees does, as described above.

SACRAMENTO COUNTY SWAINSON’S HAWK IMPACT MITIGATION PROGRAM

ORDINANCE
The CDFW requires that mitigation for foraging habitat be provided within the known foraging radius of a nesting Swainson’s hawk. In 1997, in response to the need to mitigate the loss of Swainson’s hawk foraging habitat in Sacramento County, the Board of Supervisors adopted an ordinance that established a Swainson’s Hawk Impact Mitigation Program (Chapter 16.130 of the Sacramento County Code). By adopting the program, the Board of Supervisors found that “the most effective means of mitigation for the loss of suitable Swainson’s hawk foraging habitat is the direct preservation, in perpetuity, of equally suitable foraging habitat on an acre-per-acre basis based on the Project’s determined acreage impact.” As amended by the Board of Supervisors in 2009, the program provides for the following voluntary means for mitigation impacts on Swainson’s hawk foraging habitat:
 For impacts less than 40 acres, project proponents have the option to pay an impact fee or provide title or easement to suitable Swainson’s hawk mitigation lands on a per-acre basis.
 For impacts of 40 acres or greater, project proponents must provide title or easement to approved Swainson’s hawk mitigation lands with 1 acre preserved for each one acre impacted.

The determination of impacts and mitigation land suitability is evaluated by the County’s Community Development Department, Division of Planning and Environmental Review.

HABITAT CONSERVATION PLANS
Two HCPs have been approved for development within the vicinity of the UWSP area:
the Natomas Basin and Metro Air Park HCPs. The NBHCP and the MAP HCP allow for a combined total of 17,500 acres of development in planned development areas in the Natomas Basin and establish an 8,750-acre reserve system to maintain habitat values for covered species.
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While the UWSP area is in the Natomas Basin, the County is not a participant in either the NBHCP or the MAP HCP. Therefore, the applicant (and any future applicants for buildout of the UWSP area) is not eligible for the take coverage granted by USFWS and CDFW under the NBHCP or MAP HCP. The proposed UWSP is also outside of the planned development areas of the NBHCP and MAP HCP and potential impacts resulting from development allowed under the proposed UWSP were not considered in the NBHCP.

Each HCP is described in more detail below.

NATOMAS BASIN HABITAT CONSERVATION PLAN
The NBHCP was finalized in 2003 as an update to the 1997 NBHCP (City of Sacramento et al. 2003). The NBHCP allows 17,500 acres of development to occur within the 53,537-acre Natomas Basin, while implementing a conservation strategy to maintain habitat values for 22 covered species. Of the 17,500 acres of development, 15,517 acres will be developed within the City of Sacramento and Sutter County, which are permittees under the NBHCP, with an additional 1,983 acres to be developed in the Natomas Basin pursuant to the MAP HCP.
5 While MAP is not a permittee under the
NBHCP, the NBHCP considers the impact of MAP development and MAP development is required to comply with the conservation strategy of the NBHCP.

To minimize and mitigate the impacts associated with this development, TNBC, the plan operator (and also a permittee under the NBHCP), will develop an 8,750-acre reserve system in the Natomas Basin based on the conservation strategy of the NBHCP.

The conservation strategy of the NBHCP has four main components that are described in Chapter IV of the NBHCP:
 General conservation strategy. The general conservation strategy is to create a reserve system that provides greater habitat values than the land converted to urban land uses. The reserve system must include one habitat block that is at least 2,500 acres in size and all reserves must be part of habitat blocks that are at least 400 acres in size, and connections between reserves via agricultural irrigation/drainage canals must be maintained. Reserves will include 30- to 70-foot-wide buffers between habitat and adjacent land uses, and site-specific management plans will be developed for each reserve.
 Guidelines for reserve acquisition. Guidelines for the acquisition of reserves provide for a general division of habitat types within TNBC’s system of reserves as follows: 25 percent restored and managed marsh, 50 percent preserved rice land maintained in production, and 25 percent upland habitat. The guidelines for reserve acquisition also require that at the time of acquisition, reserves are at

5 The MAP HCP allows for 2,011 acres of development, 28 acres of which are in the City of Sacramento and thus included in the NBHCP’s acreage of allowable development by the City of Sacramento. 7 - Biological Resources
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least 800 feet from existing urban lands or land designated for urban uses in an adopted general plan.
 Conservation strategy for wetland habitat. The conservation strategy for wetland habitat is to (1) convert rice land into managed marsh wetlands to enhance habitat values for the giant garter snake and other Covered Species, and (2) preserve rice land and manage it to provide greater habitat values than unpreserved rice land. This conservation strategy includes site suitability requirements, marsh design guidelines, management practices for restored marsh and preserved rice land, and water management requirements.  Conservation strategy for upland habitat. The conservation strategy for upland habitat is to avoid development in the Swainson’s Hawk Zone (within the City of Sacramento and Sutter County) and to preserve upland habitat within and outside of the Swainson’s Hawk Zone. This zone encompasses undeveloped land in the Natomas Basin that is within 1 mile of the inside toe of the levee along the Sacramento River from the Natomas Cross Canal south to Interstate 80. The goal of this strategy is to maintain optimum nesting and foraging habitat for Swainson’s hawks nesting in this zone because in the Natomas Basin, most Swainson’s hawk nesting has been along the Sacramento River.

METRO AIR PARK HABITAT CONSERVATION PLAN
Adopted in 2001, prior to the adoption of the 2003 NBHCP, the MAP HCP allows for 2,011 acres of development by the MAP Property Owners Association, while implementing a conservation strategy to maintain habitat values for 14 covered species.

Except for 28 acres in the City of Sacramento, this development is located in unincorporated Sacramento County. Thus, 1,983 acres of development within MAP is additional to the development by the City of Sacramento and Sutter County that is allowed for under the NBHCP. The urban development allowed under the MAP HCP is part of the total 17,500 acres of future planned development in the Natomas Basin reflected in the NBHCP.

The MAP HCP’s conservation strategy has been aligned with the NBHCP’s conservation strategy, and its implementation integrated with that of the NBHCP. The MAP HCP’s conservation strategy was initially based on the 1997 NBHCP, but the MAP HCP has since been revised to incorporate applicable provisions of the 2003 NBHCP, and TNBC is the plan operator for both the MAP HCP and the NBHCP. 7 - Biological Resources
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IMPACTS AND ANALYSIS

SIGNIFICANCE THRESHOLDS
The thresholds used to determine the significance of impacts related to biological resources are based on Appendix G of the CEQA Guidelines. Implementation of the project could have a significant impact on the environment if it would:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, by the CDFW or USFWS; b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS;
c) Have a substantial adverse effect on state or federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or
f) Conflict with the provisions of an adopted HCP, natural community conservation plan, or other approved local, regional, or state HCP.

ISSUES NOT DISCUSSED IN IMPACTS
Substantial adverse effect on any riparian habitat or other sensitive natural community – No riparian habitat or other sensitive natural community is present in the UWSP area. Therefore, no impact would occur, and this issue is not evaluated further in this EIR.

METHODOLOGY AND ASSUMPTIONS
The impact analysis is based on the resources, references, and data collection methods identified in the Introduction to this section. The analysis addresses potential direct and indirect impacts from construction or operation of the proposed UWSP, defined as follows:
 Direct impacts are those that could occur at the same time and place as project implementation, such as the removal of habitat as a result of ground disturbance.  Indirect impacts are those that could occur either at a later time or at a distance from the project areas, but that are reasonably foreseeable, such as the loss of an aquatic species as a result of upstream effects on water quality or quantity. 7 - Biological Resources
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Direct and indirect impacts on biological resources may vary in duration; they may be temporary, short term, or long term.

The analysis considers the potential impacts of the proposed UWSP’s implementation on suitable habitat, special-status species, wetlands, wildlife corridors, conflicts with local policies, and conflicts with a local HCP or natural community conservation plan, using the significance criteria listed above. Mitigation measures are identified as necessary to reduce impacts to less-than-significant levels. Detailed information regarding life history, ecology, and distribution of the special-status plant and wildlife species analyzed below is included in HELIX (2024) (Appendix BIO-1) and Bargas (2022) (Appendix BIO-2).

IMPACT BR-1: PRE-CONSTRUCTION BASELINE BIOLOGICAL RESOURCES REPORT
Because the proposed UWSP is anticipated to be built out in phases by different applicants over an estimated 20 years, different suites of mitigation measures may be required specific to the potential biological resources associated with phases of the build-out. In addition, land cover, land use, and consequently, plant and wildlife habitat may change during the intervening years relative to what is documented in this EIR. To identify whether, when, and where each measure applies, Mitigation Measure BR-1 is provided below, which requires that a pre-construction baseline biological resources report be prepared for each phase of development.

MITIGATION MEASURES
BR-1 Pre-construction Baseline Biological Resources Report Before the construction phase–specific development applications are deemed complete by the County, a qualified biologist shall prepare a Baseline Biological Resources Report documenting current land cover, land use, plant and wildlife habitat, and the locations of potential jurisdictional aquatic resources, native and non-native trees, and any other biological resources needed to reach a conclusion regarding which of the following mitigation measures are required for the specific project phase.

IMPACT BR-2: SPECIAL-STATUS PLANT SPECIES
Sanford’s arrowhead (Sagittaria sanfordii) may be present in aquatic ditches within the UWSP area. Construction within the UWSP area could result in direct temporary or permanent impacts on Sanford’s arrowhead, if present. If clearing and grubbing, ground disturbance, site access, or construction staging were to remove or otherwise damage individuals of these species, this impact would be potentially significant.

To address this impact, Mitigation Measures BR-2a through BR-2c are provided below, which would reduce the potential impact on Sanford’s arrowhead by providing environmental training to construction personnel regarding special-status plant species that could be present in the construction area; designing and implementing a 7 - Biological Resources
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comprehensive, adaptive weed control plan to prevent the introduction and spread of invasive plants during construction; and conducting a rare plant survey and avoiding special-status species where feasible; and, if avoidance is not feasible, implementing salvage and relocation of the plants. Therefore, with the implementation of these mitigation measures, the impact on Sanford’s arrowhead would be less than significant.

MITIGATION MEASURES
BR-2a Worker Environmental Awareness Program
All project personnel involved in ground-disturbing activities will receive a comprehensive Worker Environmental Awareness Program (WEAP) presentation on the first day on a site prior to the initiation of construction provided by a qualified biologist. The WEAP presentation will provide an overview of sensitive biological resources that may be encountered on site.

The conservation status, natural history, and habitat requirements of each protected species will be reviewed and a photograph for each species will be provided for a clearer understanding of what to be watchful for while on a site.

Resource and regulatory permits will be summarized, and specific conservation and species-specific avoidance and minimization measures will be reviewed. Penalties for failure to comply with all project permits will be reviewed. All project personnel involved in ground-disturbing activities shall sign an acknowledgement form indicating they have received the training, understood the training and agreed to abide by all the conditions of the project permits. The biological monitor will maintain a construction notebook with original copies of all training sign-in sheets and will provide trainings to new personnel on their first day on a site.

BR-2b Weed Control Plan
Prior to the issuance of a grading permit, the applicant for each phase of the UWSP area development shall prepare a weed control plan for review and approval by the Environmental Coordinator. Prior to the start of construction activities, the applicant shall implement a comprehensive, adaptive weed control plan for invasive weed management pre-construction, during construction, and for three years post-construction. The weed control plan shall only apply to UWSP properties that are within 100 feet of NBHCP and SAFCA reserve areas (e.g., the Alleghany Reserve and the Cummings Reserve) and the levee for the West Drainage Canal (Witter Canal) toe drain (refer to Plate BR-2), and shall include the following:
 A pre-construction weed inventory (i.e., location, area, and density by species) shall be conducted in the spring (February–April) by surveying all areas subject to ground-disturbing activity, including but not limited to staging areas, access roads, and areas subject to grading.  Weed populations that are rated High for negative ecological impact in the California Invasive Plant Council database shall be mapped and described according to density and area covered.
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 In areas subject to ground disturbance associated with project activities, weed infestations shall be treated prior to construction according to control methods and practices for invasive weed populations, such as described in Weed Control in Natural Areas in the Western United States. The timing of weed control treatment shall be determined for each plant species based on its life history and reproduction with the goal of controlling populations before they start producing seeds.
 Surveying and monitoring shall occur annually for years one to three postconstruction. Post-construction weed cover shall not exceed the combined total area of weed cover documented in the pre-construction weed inventory, except for areas otherwise managed by a third party with a controlling easement, such as areas managed by Reclamation District 1000 along the West Drainage Canal (Witter Canal) toe drain.  An annual report of completed maintenance shall be submitted to the County.
 Weed control treatments shall include all legally permitted herbicide, and manual and mechanical methods. The application of herbicides shall be in compliance with all state and federal laws and regulations under the prescription of a pest control advisor and implemented by a Licensed Qualified Applicator.
 During project pre-construction and construction, vehicles and all equipment shall be washed (including wheels, undercarriages, and bumpers) prior to commencing work in off-road areas.

BR-2c Avoid and Minimize Impacts on Rare Plant Species
Adequate measures shall be taken to avoid inadvertent take of Sanford’s arrowhead (Sagittaria sanfordii) and other special-status plants by implementing the following steps.
 Prior to the start of ground-disturbing activities, including clearing and grubbing, and/or grading, a qualified biologist shall conduct a properly timed special-status plant survey for Sanford’s arrowhead within the species’ suitable habitat within the project work limits. The survey will follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Plan Populations and Sensitive Natural Communities (CDFW 2018), or the most recent guidelines.
 If the survey concludes that Sanford’s arrowhead or other special-status plant species are present within the project work limits, the biologist shall establish an adequate buffer area for each plant population to exclude activities that directly remove or alter the habitat of, or result in indirect adverse impacts on, the special-status plant species. A qualified biologist shall oversee installation of a temporary, plastic mesh-type construction fence (Tensor Polygrid or equivalent) at least 4 feet (1.2 meters) tall around any established buffer areas to prevent encroachment by 7 - Biological Resources
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construction vehicles and personnel. The qualified biologist shall determine the exact location of the fencing. The fencing will be strung tightly on posts set at maximum intervals of 10 feet (3 meters) and will be checked and maintained weekly until all construction is complete. The buffer zone established by the fencing will be marked by a sign stating:
- “This is habitat of [list rare plant(s)] and must not be disturbed. This species is protected by [the Endangered Species Act of 1973, as amended/California Endangered Species Act/California Native Plant Protection Act].”
 As required by the CDFW Guidelines for Assessing the Effects of Proposed Projects on Rare, Threatened, and Endangered Plants and Natural Communities, a qualified botanist shall determine the potential presence and distribution of sensitive natural communities.  If direct impacts on special-status plants cannot be avoided, the project applicant shall prepare a plan for the County’s review minimizing the impacts by one or more of the following methods: (1) salvage and replant plants at the same location following construction; (2) salvage and relocate the plants to a suitable off-site location with long-term assurance of site protection; (3) collect seeds or other propagules for reintroduction at the site or elsewhere; or (4) payment of compensatory mitigation, e.g., to a mitigation bank. As necessary, all necessary approvals from USFWS/CDFW will be obtained for any impacts to special-status plant species protected under FESA or CESA.
 The success criterion for any seeded, planted, and/or relocated plants shall be full replacement at a 1:1 ratio after five years. Monitoring surveys of the seeded, planted, or transplanted individuals shall be conducted annually for a minimum of five years to ensure that the success criterion can be achieved at year five. Monitoring reports shall be submitted to the County. If it appears the success criterion would not be met after five years, contingency measures may be applied. Such measures shall include but are not limited to additional seeding and planting; altering or implementing weed management activities; or introducing or altering other management activities.

IMPACT BR-3: GIANT GARTER SNAKE
Giant garter snake could be present in the irrigation ditches and adjacent uplands within the UWSP area. Construction of individual projects considered under the proposed UWSP would involve removal (filling) of irrigation ditches and adjacent ground disturbance. Removal of ditches would constitute a permanent loss of giant garter snake habitat. Approximately 22 acres of suitable aquatic giant garter snake habitat are present in the UWSP area (HELIX 2024), most of which is expected to be permanently impacted by the proposed UWSP (refer to Plate BR-3). The UWSP area also includes

72.4 acres of suitable upland habitat that is largely undisturbed by anthropogenic actions (i.e., annual grassland, pasture) and 396 acres of anthropogenically disturbed 7 - Biological Resources
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suitable upland habitat (e.g., ruderal, row crops, urban) for giant garter snake (HELIX 2024).6 Grubbing, earthmoving, and operation of heavy equipment in uplands directly adjacent to ditches could result in direct mortality to individual giant garter snake. Noise, vibration, and increased activity levels could indirectly impact giant garter snake by causing individuals to avoid areas they normally use, which could make them more vulnerable to predation or interfere with normal breeding activity. This species, and the amphibian species it preys upon, could also be impacted by turbidity caused by construction-related erosion or in-water work. Such activities could result in impacts to giant garter snake habitat, and this impact would be potentially significant.

Off-site giant garter snake habitat in the Cummings Reserve, which is part of the NBHCP Reserve system, is present immediately north of the proposed UWSP. The Cummings Reserve would be adjacent to agricultural bufferlands and open space within the UWSP area (refer to Figure 2 of HELIX 2024). Therefore, potential project operational impacts on the species and its prey associated with changes in land use, such as increased stormwater runoff and runoff of deleterious materials associated with urban development into off-site giant garter snake habitat, are not expected. Existing ditches and canals in the agricultural and ruderal lands on the west side of the UWSP area also currently provide giant garter snake habitat. The ditches and canals that would be retained within the UWSP agricultural buffer (refer to Plate BR-3) are not expected to be impacted by potential operational impacts because there would not be a change in surrounding land use.

To address this impact, Mitigation Measures BR-2a and BR-3 are provided below, which would reduce the potential impact on giant garter snake by providing environmental training for construction personnel; conducting construction activity during the active period for giant garter snake (May 1 through September 30),7 unless approved by CDFW to work outside of that period; conducting pre-construction surveys; dewatering giant garter snake habitat for at least 15 days prior to excavation or filling;

6 Giant garter snake potential habitat was determined by selecting land cover types with suitable aquatic habitat and mapping areas of upland habitat directly adjacent to aquatic habitat. HELIX used a practical approach by applying two different metrics dependent on the type of habitat that abutted the aquatic zones. For anthropogenically disturbed uplands (e.g., ruderal, row crops, urban), HELIX estimated upland habitat of approximately 218 feet around the aquatic zone. A larger estimate was applied to upland habitat that is largely undisturbed by anthropogenic actions such as annual grasslands and pastures. HELIX mapped up to 1,300 feet in undisturbed uplands habitat adjacent to aquatic features, as giant garter snakes have been observed in aquatic-associated uplands up to hundreds of meters (hundreds of yards) distant from any water body (Wylie et al. 1997; USFWS 2017a). Although giant garter snake is primarily an aquatic species, it utilizes upland terrestrial habitat, particularly during the winter inactive season. Per the Recovery Plan for Giant Garter Snake (USFWS 2017a), over-wintering giant garter snakes use burrows as far as 200 to 250 meters (656 to 820 feet) from the edge of summer aquatic habitat (G. Hansen 1988; Wylie et al. 1997; USFWS 2017a). These data support larger estimates of suitable upland habitat in the relatively natural areas, and when the 1,300-foot metric is applied, geographic locations of giant garter snake occurrence data match the mapped upland habitat.
7 May 1 through September 30 is the active period for the giant garter snake, and direct mortality is lessened because snakes are expected to actively move and avoid danger.

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designating avoided giant garter snake habitat; presence of a biological monitor during initial grading activities; removing temporary fill or construction debris from the site following construction; and compensating for permanent impacts on giant garter snake habitat. As a result, with the implementation of these mitigation measures, the impact on giant garter snake would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-3 Avoid, Minimize, and Compensate for Impacts on Giant Garter Snake Project applicants shall obtain authorization for take of giant garter snake from USFWS and CDFW and implement all measures required therein to avoid, minimize, and compensate for impacts to giant garter snake.

In addition, to avoid and minimize impacts, where construction activities will be conducted within 200 feet of aquatic giant garter snake habitat, project applicants shall:
 Provide construction personnel with environmental awareness training (per BR-2a, “Worker Environmental Awareness Program”);
 Restrict construction activities to the giant garter snake active season;  Conduct pre-construction habitat surveys;
 Dewater aquatic habitat prior to construction;
 Conduct pre-construction surveys for giant garter snake presence;  Minimize vegetation clearing and avoid retained habitat;  Monitor ground-disturbing construction activities; and/or  Remove temporary fill and construction debris.

To compensate for unavoidable permanent loss of aquatic giant garter snake habitat, project applicants shall either: (i) create, restore, or enhance, and preserve and manage suitable aquatic and associated upland habitat to provide giant garter snake habitat at a 1:1 or greater ratio (mitigation acreage to impact acreage), (ii) preserve and manage rice fields as habitat for giant garter snake at a 2:1 or greater ratio, and/or (iii) provide compensatory giant garter snake habitat of equal or greater ecological value as established in separate authorizations or permits by the USFWS and CDFW. Mitigation to compensate for losses of giant garter snake habitat may be fulfilled through a combination of these options, assuming minimum ratios are met.

These mitigation measures are described further below.
 Secure Authorization from the USFWS and CDFW for the Incidental Take of Giant Garter Snake
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Before the commencement of any initial groundbreaking activity within 200 feet of aquatic giant garter snake habitat, project applicants shall secure take authorization from the USFWS and CDFW. The applicant shall fulfill all conditions of the biological opinion and/or incidental take permit(s) issued for the project. Unless CDFW or USFWS require other measures, the avoidance and minimization measure under “Avoid and Minimize Impacts to Giant Garter Snake,” below, shall be implemented; and unless CDFW or USFWS require compensatory mitigation of equal or greater ecological value to giant garter snake, the compensatory mitigation measure “Compensate for Permanent Impacts to Giant Garter Snake Habitat,” below, shall be implemented.
 Avoid and Minimize Impacts on Giant Garter Snake
Unless CDFW or USFWS requires other measures to avoid and minimize impacts to giant garter snake, the following measures shall apply to construction activities within 200 feet of aquatic giant garter snake habitat:
- Restrict Construction Activities to the Giant Garter Snake Active Season. All construction activity involving disturbance within 200 feet of aquatic giant garter snake habitat, such as site preparation and initial grading, is restricted to the period between May 1 and September 30.
- Conduct Pre-construction Habitat Surveys. Pre-construction surveys for giant garter snake shall be completed within 24 hours of the start of initial ground disturbance with 200 feet of aquatic giant garter snake habitat for all development projects by a qualified biologist approved by USFWS and CDFW. 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 and CDFW.  Dewatering Aquatic Habitat prior to Construction. Between April 15 and September 30, all irrigation ditches, canals, or other aquatic habitats shall 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, and prior to ground-disturbing activities within 200 feet of aquatic giant garter snake habitat.  Conduct Pre-construction Surveys for Giant Garter Snake Presence. 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.
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 Minimize Vegetation Clearing and Avoid Retained Habitat. The applicant shall confine clearing to the minimal area necessary to facilitate construction activities and shall flag and designate avoided giant garter snake habitat within or adjacent to the project site as Environmentally Sensitive Areas. Environmentally Sensitive Areas shall be avoided by all construction personnel.
 Monitor Ground-Disturbing Construction Activities. A qualified biological monitor shall be present during initial grading activities within 200 feet of aquatic giant garter snake habitat to ensure that construction activities do not encroach into unauthorized areas. If a live giant garter snake is found during construction activities, the biological monitor shall immediately notify USFWS and CDFW. The biological monitor shall have the authority to stop construction in the vicinity of the snake should the biological monitor have reason to believe “take” of giant garter snake could occur if construction proceeds.

The monitor shall remain in the area for the remainder of the workday to make sure the snake is not harmed or, if it leaves the site, does not return. Escape routes for giant garter snake shall be determined in advance of construction, and snakes shall always be allowed to leave on their own. If the snake does not leave on its own within one working day, the biological monitor shall consult with the USFWS and CDFW to determine any necessary additional measures.

The biological monitor shall also report any giant garter snake mortality within one working day to USFWS. Any project-related activity that results in giant garter snake mortality shall cease until the activity has been modified to the extent practicable to avoid future mortality.
 Remove Temporary Fill and Construction Debris. Because fill or construction debris may be used by giant garter snake as an overwintering site (hibernaculae), upon completion of the current phase of construction activities, any temporary fill and/or construction debris from the site shall be removed. 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 ensure that giant garter snakes are not using it as hibernaculae.
- Compensate for Permanent Impacts to Giant Garter Snake Habitat Prior to the approval of grading permits, improvement plans or building permits, whichever of these approvals occurs first, project applicants shall compensate for permanent loss of giant garter snake aquatic and upland habitat within 200 feet of giant garter snake aquatic habitat. 7 - Biological Resources
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Unless take authorizations from CDFW or USFWS require
compensatory mitigation of equal or greater ecological value to giant garter snake, compensatory mitigation shall be as follows.  Compensatory mitigation shall be provided through creation, preservation, and management of suitable aquatic and associated upland habitat for giant garter snake; and/or preservation and management of rice fields or other suitable aquatic habitat, as habitat for giant garter snake.
 Mitigation sites shall be located outside of the Natomas Basin and in the American Basin Recovery Unit as defined in the Recovery Plan for the Giant Garter Snake (Thamnophis gigas) (USFWS 2017a.

This mitigation may be provided through:
 Purchase of credits from a CDFW- and USFWS-approved conservation bank;
 Payment to an existing in-lieu fee program;
 Creation, restoration, or enhancement, and preservation and management of suitable aquatic and associated upland habitat for giant garter snake; or  Preservation and management of existing giant garter snake habitat through acquisition of fee-title or a conservation easement and funding for long-term management of giant garter snake habitat at a site.

Mitigation through creation, restoration, enhancement, preservation, and management of suitable aquatic and associated upland giant garter snake habitat, or purchase of credits for aquatic and associated upland habitat suitable for giant garter snake (e.g., constructed marsh) shall be at a ratio of at least 1:1 (mitigation aquatic and upland habitat to permanently lost aquatic and upland habitat), and mitigation through preservation and management of rice fields will be at a ratio of at least 2:1.

For mitigation provided through acquisition of fee title or a conservation easement, the following requirements must be satisfied:
 The selection of mitigation site(s) shall be approved by the County in coordination with CDFW and USFWS.
 The form and content of the easement, and the amount of the endowment for long-term management, shall be acceptable to the County, CDFW, and USFWS, and the easement shall prohibit any activity that substantially impairs or diminishes the land’s capacity as suitable giant garter snake habitat and protect any existing water rights necessary to maintain giant garter snake habitat, in accordance with then-current water allocations and in coordination with USFWS.
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 A habitat management plan shall be approved by the County in coordination with CDFW and USFWS. This plan shall describe long-term management and provide the schedule for monitoring and management actions, and an approach to adaptively manage its implementation.  An endowment shall be established to cover the costs of implementing the habitat management plan. The amount and structure of the endowment shall be acceptable to CDFW, USFWS, and the County.

For mitigation that creates, restores, or enhances suitable aquatic and associated upland giant garter snake habitat, a restoration plan shall be developed, approved by the USFWS, CDFW, and the County. The restoration plan shall describe baseline conditions, restoration design and construction, short-term management and monitoring, and success criteria.

IMPACT BR-4: NORTHWESTERN POND TURTLE
Northwestern pond turtle could be present in the irrigation ditches and immediate adjacent uplands within the UWSP area and the West Drainage Canal (Witter Canal).

Construction of individual projects considered under the proposed UWSP would involve removal (filling) of irrigation ditches and adjacent ground disturbance. Removal of ditches would constitute a permanent loss of northwestern pond turtle habitat. Grubbing, earthmoving, and operation of heavy equipment in uplands directly adjacent to ditches and the West Drainage Canal (Witter Canal) (e.g., for construction of the Bike Trail Bridge Crossing) could result in direct mortality to individuals, as well as noise, vibration, and increased activity levels, which could indirectly impact northwestern pond turtle habitat by causing individuals to avoid areas they normally use. This species, and the aquatic species it preys upon, could also be impacted by turbidity caused by construction-related erosion or in-water work. Such activities could result in impacts to northwestern pond turtle habitat, and this impact would be potentially significant.

Off-site northwestern pond turtle habitat in the Cummings Reserve, which is part of the NBHCP Reserve system, is present immediately north of the proposed UWSP.

Cummings Reserve would be adjacent to agricultural bufferlands and open space within the UWSP area (refer to Figure 2 of HELIX 2024). Therefore, potential project operational impacts on the species and its prey associated with changes in land use, such as increased stormwater runoff and runoff of deleterious materials associated with urban development into off-site western pond turtle habitat, are not expected. Existing ditches and canals in the agricultural and ruderal lands on the west side of the UWSP area also currently provide western pond turtle habitat. The ditches and canals that would be retained within the UWSP agricultural buffer (refer to Plate BR-3) are not expected to be impacted by potential operational impacts because there would not be a change in surrounding land use.

To address construction-related impacts, the proposed UWSP would implement Mitigation Measures BR-2a and BR-4, which would reduce the potential impact on western pond turtle because they require providing environmental training for construction personnel; conducting pre-construction surveys; dewatering giant garter 7 - Biological Resources
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snake habitat, which is also northwestern pond turtle habitat, for at least 15 days prior to excavation or filling; having a biological monitor present during grading activities; and protecting northwestern pond turtle encountered on the site during construction and allowing northwestern pond turtle to leave on its own, or coordinating with USFWS and CDFW if it does not leave on its own. Therefore, with implementation of these mitigation measures, the impact on northwestern pond turtle would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-4 Avoid and Minimize Impacts on Northwestern Pond Turtle As recommended in the Natomas Basin Habitat Conservation Plan or NBHCP, 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 requirement described under BR-3. In addition:
 For sites that contain northwestern pond turtle 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 northwestern pond turtle. If construction activities stop on the project site for a period of 14 days or more, a new northwestern pond turtle survey shall be completed no more than 24 hours prior to the re-start of construction activities.
 Clearing shall be confined to the minimal area necessary to facilitate construction activities.
 If dewatering for 15 days has occurred, as described under BR-2, or if wildlife exclusion fencing has been installed to prevent western pond turtle from entering the construction area (including access roads and staging areas), a qualified biological monitor shall be present during initial grading activities within 200 feet of aquatic northwestern pond turtle habitat to ensure that construction activities do not encroach into unauthorized areas.
 If dewatering for 15 days has not occurred, and wildlife exclusion fencing has not been installed, a qualified biological monitor shall be present during all grading activities within 200 feet of aquatic northwestern pond turtle habitat to monitor for and protect the species, if present.  If a live northwestern pond turtle is found during construction activities, the biological monitor shall immediately notify USFWS and CDFW. The biological monitor shall have the authority to stop construction in the vicinity of the turtle. The turtle shall be monitored and given a chance to leave the area on its own. If the turtle does not leave on its own within one working day, the biological monitor shall consult with the USFWS and 7 - Biological Resources
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CDFW to determine any necessary additional measures. The biological monitor shall also report any northwestern pond turtle mortality within one working day to USFWS. Any project-related activity that results in northwestern pond turtle mortality shall cease so that this activity can be modified to the extent practicable to avoid future mortality.  If a live northwestern pond turtle is found during construction activities, the USFWS and CDFW and the project’s biological monitor shall be immediately notified. The biological monitor shall stop construction in the vicinity of the turtle, monitor the turtle, and allow the turtle to leave on its own. The monitor shall remain in the area for the remainder of the workday to make sure the turtle is not harmed or, if it leaves the site, does not return. Escape routes for northwestern pond turtle should be determined in advance of construction, and turtles should always be allowed to leave on their own. If a northwestern pond turtle does not leave on its own within one working day, further coordination with USFWS and CDFW is required.

IMPACT BR-5: SPECIAL-STATUS BIRD SPECIES (OTHER THAN BURROWING OWL AND SWAINSON’S HAWK), BIRDS PROTECTED BY THE MIGRATORY BIRD

TREATY ACT, AND NESTING RAPTORS
Special-status bird species that have the potential to nest and/or forage in the UWSP area include tricolored blackbird, loggerhead shrike, song sparrow (“Modesto” population), purple martin, yellow warbler, yellow-headed blackbird, American white pelican, norther harrier, and white-tailed kite. In addition, active nests and nesting birds protected by the Migratory Bird Treaty Act, or MBTA, and California Fish and Game Code, or CFGC, that have potential to occur in the UWSP area include Cooper’s hawk, osprey, white-faced ibis, and many other species of songbirds, waterbirds, and waterfowl.

Construction-related direct impacts in the UWSP area and offsite improvements areas (described in Chapter 2, Project Description), on special-status birds or nesting birds protected by the MBTA could result from the removal of trees and vegetation, tree trimming, and/or demolition of buildings while an active bird nest is present. In addition, earthmoving, operation of heavy equipment, and increased human presence could result in noise, vibration, and visual disturbance. These conditions could indirectly result in nest failure (disturbance, avoidance, or abandonment that leads to unsuccessful reproduction), or could cause flight behavior that would expose an adult or its young to predators. These activities could cause birds that have established a nest before the start of construction to change their behavior or even abandon an active nest, putting their eggs and nestlings at risk for mortality.

Generally, the failure of a nest due to project activities could be a violation of CFGC Sections 3503–3513, and thus this impact would be potentially significant. Impacts during the non-breeding season generally are not considered significant, primarily because of the birds’ mobility and ability to access other comparable foraging habitat in the region.
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To address this impact, Mitigation Measures BR-2a and BR-5 are provided below, and would reduce the potential impact on nesting birds by requiring the provision of environmental training for construction personnel; limiting construction to the nonnesting season when feasible or, if avoiding the nesting season is not feasible, conducting pre-construction surveys for nesting birds and establishing no-disturbance buffers around any active nests to ensure they are not disturbed by construction; and repeating the pre-construction surveys when work resumes after being suspended for seven days. As a result, with the implementation of these mitigation measures, the impact on nesting birds would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-5 Avoid and Minimize Impacts on Nesting Birds
 Mitigation Measure BR-5 applies to projects that include removal of trees or vegetation, tree trimming, or use of heavy equipment (e.g., earthwork, demolition).
 A qualified wildlife biologist shall conduct pre-construction nesting surveys during the avian nesting breeding season (approximately February 1 to August 31) within 7 days prior to construction. Surveys shall be performed for the project area, vehicle and equipment staging areas, and suitable habitat within 250 feet to locate any active passerine (perching bird) nests and within 500 feet to locate any active raptor (bird of prey) nests.  A pre-construction survey report of findings shall be prepared by the qualified biologist and submitted to the County for review and approval prior to initiation of construction within the no-disturbance zone during the nesting season. The report shall either confirm absence of any active nests or shall confirm that any young within a designated no-disturbance zone have fledged and construction can proceed.
 If no active nests are identified during the survey period, or if construction activities are initiated during the non-breeding season (September 1 to January 31), construction may proceed with no restrictions.  If bird nests are found, an adequate no-disturbance buffer shall be established around the nest location and construction activities shall be restricted within the buffer until the qualified biologist has confirmed that any young birds have fledged and are able to leave the construction area.

Required setback distances for the no-disturbance zone shall be established by the qualified biologist and may vary depending on species, line of sight between the nest and the construction activity, and the birds’ sensitivity to disturbance. As necessary, the no-disturbance zone shall be fenced with temporary orange construction fencing if construction is to be initiated on the remainder of the development site.
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 Any birds that begin nesting within the project area and survey buffers amid construction activities shall be assumed to be habituated to construction-related or similar noise and disturbance levels and nodisturbance zones shall not be established around active nests in these cases; however, should birds nesting within the project area and survey buffers amid construction activities begin to show disturbance associated with construction activities, no-disturbance buffers shall be established as determined by the qualified wildlife biologist.
 Any work that must occur within established no-disturbance buffers around active nests shall be monitored by a qualified biologist. If adverse effects in response to project work within the buffer are observed and the biologist determines the activities are likely to compromise the nest’s success, work within the no-disturbance buffer shall halt until the nest occupants have fledged. If the qualified biologist determines that the activities are unlikely to compromise the nest’s success, work can continue.

IMPACT BR-6: BURROWING OWL
Burrowing owl has been documented in several locations in the Natomas Basin, including the higher terrace along the basin’s eastern border, in the tree planter boxes in the Power Balance Pavilion (subsequently Sleep Train Arena) parking lot,8 and along the higher berms of the larger irrigation and drainage canals in the central basin (City of Sacramento et al. 2003). This species was not observed within the 568.7 acres of lands within the UWSP area surveyed by Bargas in 2019, 2020, or 2021 (Refer to “Parcel Access/Bargas ARD Survey Area” shown in Plate BR-3), or by HELIX in 2023 (HELIX 2024).

Construction-related direct impacts on burrowing owl in the UWSP area and offsite improvement areas could result from ground disturbance that destroys occupied burrows or nest sites. In addition, earthmoving, operation of heavy equipment, and increased human presence could result in noise, vibration, and visual disturbance.

These conditions could indirectly result in nest failure (disturbance, avoidance, or abandonment that leads to unsuccessful reproduction) or impacts on non-breeding individuals due to burrow abandonment or could cause flight behavior that would expose an adult or its young to predators. These activities could cause burrowing owls that have established a nest before the start of construction to change their behavior or even abandon an active nest, putting their eggs and nestlings at risk for mortality.

Permanent impacts on individual burrowing owls and/or burrowing owl nesting and foraging habitat would be potentially significant.

8 Subsequent to publication of the NBHCP in 2003 (City of Sacramento et al. 2003), the name of the Power Balance Pavilion was changed to Sleep Train Arena. Ultimately, after the relocation of the Sacramento Kings to the downtown Golden 1 Center, Sleep Train Arena was demolished to make way for proposed future development. However, the arena parking lot remained intact at the time of publication of this EIR.
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To address this impact, Mitigation Measures BR-2a and BR-6 are provided below, and would reduce the potential impact on burrowing owl by requiring the provision of environmental training for construction personnel; conducting focused burrowing owl surveys, and if burrowing owls are detected, avoiding disturbance to individuals and their burrows; conducting take avoidance surveys immediately prior to the start of construction; and, where on-site avoidance is not possible, providing compensatory mitigation for disturbance and/or destruction of burrows. Therefore, with implementation of these mitigation measures, the impact on burrowing owl would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-6 Avoid and Minimize Impacts on Western Burrowing Owl To avoid impacts on potential burrowing owl and their habitat, the following mitigation measures shall be implemented.
 A qualified biologist shall conduct focused burrowing owl surveys in suitable habitat in the area where project activities will occur, plus the surrounding 500 feet, where accessible, in accordance with the number of visits, timing, and survey methods in Appendix D of CDFW’s Staff Report on Burrowing Owl Mitigation (Staff Report), published March 7, 2012.

Surveys shall be repeated if project activities are suspended or delayed more than 14 days.
 Pursuant to the Staff Report, four survey visits shall be conducted during the breeding season (February 1 to August 31), including at least one survey between February 15 and April 15, and at least three surveys at least three weeks apart, between April 15 and July 15, with at least one visit after June 15.
 Non-breeding season surveys shall be conducted during four site visits, spread evenly throughout the non-breeding season.
 If no burrowing owls are detected, no further measures are required. If active burrowing owl burrows are detected, the following avoidance minimization, and mitigation measures shall be implemented prior to initiating project related activities that may impact burrowing owls. - Occupied burrows shall not be disturbed during nesting season (February 1 through August 31) unless a qualified biologist approved by CDFW verifies through non-invasive measures that either (1) the birds have not begun egg-laying and incubation or (2) juveniles from the occupied burrows are foraging independently and are capable of independent survival.
- If nest sites are found, CDFW shall be contacted regarding suitable mitigation measures, which may include on-site avoidance through 7 - Biological Resources
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establishment of a 300-foot buffer from the nest site during the breeding season (February 1 through August 31), or implementation of a relocation effort for the burrowing owl if the birds have not 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 applicant 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. - If relocation of the burrowing owl is approved for the site by CDFW, the applicant shall hire a qualified biologist to prepare a plan for relocating the burrowing owl to a suitable site. The relocation plan must include (1) the location of the nest and burrowing owl proposed for relocation; (2) the location of the proposed relocation site; (3) the number of burrowing owls involved and the time of year when the relocation is proposed to take place; (4) the name and credentials of the biologist who will be retained to supervise the relocation; (5) the proposed method of capture and transport for the burrowing owl to the new site; (6) a description of the site preparations at the relocation site (e.g., enhancement of existing burrows, creation of artificial burrows, onetime or long-term vegetation control); and (7) 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 Staff Report.  Take avoidance surveys may also be conducted. An initial take avoidance survey to determine whether any burrowing owl are using the site for foraging or nesting shall be conducted no less than 14 days prior to initiating ground-disturbing activities, using the methods outlined in Appendix D of the Staff Report. Implementation of avoidance and minimization measures would be triggered by positive owl presence on the site where project activities will occur. The development of avoidance and minimization approaches would be informed by monitoring the burrowing owls. Burrowing owls may re-colonize a site after only a few days. Time lapses between project activities trigger subsequent take avoidance surveys, including but not limited to a final survey conducted within 24 hours prior to ground disturbance.
 Where on-site avoidance is not possible, disturbance and/or destruction of occupied burrows shall be offset through development of suitable habitat on upland reserves. 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 the Staff Report.
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IMPACT BR-7: SWAINSON’S HAWK
The UWSP area provides foraging and nesting habitat for Swainson’s hawk. Swainson’s hawks were observed nesting and foraging in the UWSP area during surveys in 2019, 2020, and 2021 (Bargas 2022).

NESTING
According to TNBC’s 2022 Biological Effectiveness Monitoring Report, in the Natomas Basin, Swainson’s hawks continue to nest primarily in the southern portion and along the far western and northern edges of the basin (ICF 2023), with nest sites occurring predominantly along the Sacramento River and within approximately 1 mile of the river.

Swainson’s hawk breeding season surveys conducted by Bargas Environmental Consulting in 2019 and 2020 documented three Swainson’s hawk territories, of which all or a large proportion was within the UWSP area. In addition, nesting by one of the three pairs was within the UWSP area and resulted in the successful fledging of one chick (Bargas 2019, 2020). The CNDDB includes three documented nesting occurrences of Swainson’s hawk in the UWSP area, two of which correlate with the territories Bargas identified (CDFW 2024). Swainson’s hawks often have one or more alternate nest sites within a breeding territory (TNBC 2022); therefore, these CNDDB records likely overstate nesting territories/pairs.

Potential construction-related disturbance to nesting Swainson’s hawk in the UWSP area and offsite improvements areas could include direct disturbance of active nests during tree removal and indirect disturbance to nests such as noise, vibration, and increased human activity associated with construction activities. These disturbances could cause nest abandonment or interfere with the incubation or feeding of young. In addition, the removal of trees would reduce nesting habitat for Swainson’s hawk. The impact associated with the disturbance of Swainson’s hawk nests would be potentially significant.

To address this impact, Mitigation Measures BR-2a and BR-7a are provided below, and would reduce the potential impact on Swainson’s hawk by requiring the provision of environmental training for construction personnel; conducting focused pre-construction Swainson’s hawk surveys if construction activities would begin during the nesting season; if active nests are found prior to the start of construction, developing an avoidance and minimization plan, which may include establishing a work schedule and no-disturbance buffer during critical nesting periods; and having a biological monitor conduct regular monitoring of the nest during construction activities and halting construction if construction activities are disturbing the nest. With the implementation of Mitigation Measures BR-2a and BR-7a, the impact on Swainson’s hawk nesting habitat would be less than significant.

FORAGING
As stated in the NBHCP, suitable cover types for foraging habitats include, in order of suitability, (1) native grassland; (2) agriculture soon after discing; (3) alfalfa and other hay crops; (4) fallow fields; (5) lightly grazed pasture; (6) combinations of hay, grain, and row crops; (7) rice fields prior to flooding and after draining; and (8) heavily grazed 7 - Biological Resources
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pasture. Unsuitable cover types for foraging habitat include vineyards, mature orchards, cotton, thistle in fallow fields, and any crop where prey are unavailable due to high vegetation height and density, as well as flooded rice fields.

The net loss of annual grasses and forbs, and agricultural land (field crops, grain and hay, partially irrigated crops, pasture, and truck crops) associated with development of the UWSP area would result in permanent loss of 1,197 acres of Swainson’s hawk foraging habitat, 975 acres of which are in the NBHCP Swainson’s Hawk Zone. No loss of Swainson’s hawk foraging habitat is expected in the offsite improvement areas, which are limited to existing roadways and fragments of ruderal land cover adjacent to heavy road traffic, such as at the Interstate 80/West El Camino Avenue interchange.

Conversion of agricultural land to developed/landscaped land in the UWSP area would also potentially result in the loss of nesting territories, displacement of nesting pairs, reduction in reproductive potential, or decreased survival rates, particularly for Swainson’s hawk nesting within 1 mile of the UWSP area, but also for Swainson’s hawk nesting outside of the UWSP area. A telemetry study of Swainson’s hawk nesting in the Natomas Basin found that adult Swainson’s hawk travel distances of up to 6 miles from the nest to forage throughout the breeding season (Fleishman et al. 2016). Plate BR-4 shows suitable Swainson’s hawk foraging habitat within 10 miles of the Natomas Basin.

The impact associated with the loss of foraging habitat would be potentially significant.

To address the impact on Swainson’s hawk foraging habitat, Mitigation Measure BR-7b is provided below, which would provide compensatory mitigation at a 1:1 ratio for project-related loss of Swainson’s hawk foraging habitat. As a result, with the implementation of this mitigation measure, the impact on Swainson’s hawk foraging habitat would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-7a Avoid and Minimize Impacts on Nesting Swainson’s Hawk Project applicants for each construction phase shall avoid, minimize, and compensate for impacts on Swainson’s hawk as described below.  Avoid and Minimize Impacts on Swainson’s Hawk
- Avoid Construction Activities during the Nesting Season. If construction activities will begin during the Swainson’s hawk nesting season (March 20 to September 15), a qualified biologist shall conduct surveys in accordance with the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (Swainson’s Hawk Technical Advisory Committee 2000) or the current CDFW-approved protocol. All potential nest trees within 0.5 mile of the proposed project footprint shall be visually examined for potential Swainson’s hawk nests, if accessible.
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- Document Survey Results. If no active Swainson’s hawk nests are identified on or within 0.5 mile of the proposed project, the project applicant shall submit a letter report documenting the survey methodology and findings to the County and CDFW, and no additional mitigation measures are required. If an active Swainson’s hawk nest is found on or within 0.5 mile of the project footprint, a survey report shall be submitted to the County and CDFW, and an avoidance and minimization plan shall be developed and implemented (see below). - Develop and Implement Avoidance and Minimization Plan. An avoidance and minimization plan shall be developed and implemented in coordination with CDFW prior to the start of construction. The avoidance and minimization plan shall include measures to minimize impacts on active Swainson’s hawk nest(s) depending on the location of the nest relative to the project construction footprint. These measures shall include, but are not limited to:
 Establish Buffer Zone and Work Schedule. A buffer zone and work schedule shall be established to avoid impacting the nest during critical periods. If possible, no work will occur within 200 yards of the nest while it is in active use.
 Conduct Nest Monitoring. A qualified biologist shall conduct regular monitoring of the nest during construction activities, and monitor all work within 200 yards of the nest to ensure that no work occurs within 200 yards of the nest during incubation or within 10 days after hatching (Swainson’s Hawk Technical Advisory Committee 2000).  Halt Construction If Nesting Birds Are Disturbed. In the event that the project biologist determines that the construction activities are disturbing the nest, construction activities shall be halted until CDFW is consulted and recommended measures to avoid
disturbance to active nests are implemented.

BR-7b Compensate for Permanent Impacts on Swainson’s Hawk Foraging Habitat  Compensation for the permanent loss of foraging habitat shall be determined for each development phase. The applicant for each development phase shall retain a Qualified Biologist to verify, map, and quantify (acres) foraging habitat (including annual grasses and forbs, field crops, grain and hay, partially irrigated crops, and truck crops), that would be permanently impacted by the current development phase.

Prior to the approval of either grading permits or building permits, whichever is first, project applicants for each construction phase shall compensate for permanent loss of foraging habitat through the preservation of foraging habitat. This compensatory mitigation shall be at a ratio of at least 1:1 (mitigation habitat to permanently lost habitat).

Mitigation sites shall be located outside, and within 10 miles of, the Natomas Basin.
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This mitigation may be provided through purchase of credits from a CDFW-approved conservation bank, or through protection of habitat, including acquisition of a conservation easement and funding long-term administration, monitoring, and enforcement of the easement.

Mitigation provided through acquisition of a conservation easement must satisfy the following requirements:
- The mitigation site(s) shall be subject to consultation with CDFW and approved by the County.
- The form and content of the easement shall be acceptable to the County and CDFW, prohibit activities that substantially impair or diminish the land’s suitability as Swainson’s hawk foraging habitat, and protect any existing water rights necessary to maintain foraging habitat in agricultural production.
- An endowment in an amount, form, and structure acceptable to the County and CDFW shall be established for administering, monitoring, and enforcing the conservation easement.

IMPACT BR-8: PALLID BAT
Pallid bat, a CDFW species of special concern, has the potential to occur within the UWSP area. The offsite improvement areas are not located in or adjacent to pallid bat habitat. The UWSP area provides potential foraging habitat for this species over agricultural lands, and Fremont cottonwood and valley oak tree groves provide suitable roosting habitat for the species (HELIX 2024). Daytime construction activities in the UWSP area could result in direct impacts to roosting bats if they were to be disturbed, killed, or injured by removal or trimming of a tree in which they were roosting. If roosting bats are present, construction noise could result in indirect impacts due to disturbance, avoidance, or abandonment of roosts. If tree removal in the UWSP area were to occur during periods of winter torpor or maternity roosting, any bats present would likely not survive the disturbance (Tuttle 1991). For these reasons, the impact on the bats would be potentially significant.

To address this impact, Mitigation Measures BR-2a and BR-8 are provided below, and would reduce the potential impact on pallid bat by requiring the provision of environmental training for construction personnel; conducting a pre-construction habitat assessment in the UWSP area; if potential roosting habitat and/or active bat roosts are present, conducting initial building demolition, relocation, and any tree work (trimming or removal) when bats are active; or if seasonal avoidance is infeasible, conducting a preconstruction survey of potential bat roost sites; establishing no-disturbance buffers around active bat roost sites; disturbing buildings and trees with potential bat roosting habitat or active roosts only under fair weather conditions, under the supervision of a qualified biologist; and following a two-step removal process to prevent bats from returning to the roost site prior to complete removal. Therefore, with the implementation of these mitigation measures, the impact on pallid bat would be less than significant. 7 - Biological Resources
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MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-8 Avoid and Minimize Impacts on Pallid Bat
A qualified biologist who is experienced with bat surveying techniques (including auditory sampling methods), behavior, roosting habitat, and identification of local bat species shall be consulted prior to building or bridge demolition, building relocation activities, or tree work to conduct a preconstruction habitat assessment of the project area (focusing on buildings to be demolished or relocated) to characterize potential bat habitat and identify potentially active roost sites. No further action is required should the preconstruction habitat assessment not identify bat habitat or signs of potentially active bat roosts within the project area (e.g., guano, urine staining, dead bats).

The following measures shall be implemented should potential roosting habitat or potentially active bat roosts be identified during the habitat assessment in bridges or buildings to be demolished or relocated, or in trees adjacent to construction activities that could be trimmed or removed within the UWSP area:
 In areas identified as potential roosting habitat during the habitat assessment, initial bridge or building demolition, relocation, and any tree work (trimming or removal) shall occur when bats are active, approximately between the periods of March 1 to April 15 and August 15 to October 15, to the extent feasible. These periods avoid the bat maternity roosting season and period of winter torpor.
9  If seasonal avoidance of potential roosting habitat is infeasible, the qualified biologist shall conduct pre-construction surveys of potential bat roost sites identified during the initial habitat assessment no more than 14 days prior to bridge or building demolition or relocation, or any tree trimming or removal.
 If active bat roosts or evidence of roosting is identified during preconstruction surveys for bridge or building demolition and relocation or tree work, the qualified biologist shall determine, if possible, the type of roost and species. A no-disturbance buffer shall be established around roost sites until the end of the seasonal avoidance windows identified above, or until the qualified biologist determines roost sites are no longer active. The size of the no-disturbance buffer would be determined by the qualified biologist and would depend on the species present, roost type, existing screening around the roost site (such as dense vegetation or a

9 Torpor refers to a state of decreased physiological activity with reduced body temperature and metabolic rate.
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building), as well as the type of construction activity that would occur around the roost site.
 Bridges, buildings, and trees with potential bat roosting habitat or active roosts shall be disturbed only under clear weather conditions when precipitation is not forecast for three days and when daytime temperatures are at least 50 degrees Fahrenheit.
 The demolition or relocation of bridges or buildings containing or suspected to contain potential bat roosting habitat or active bat roosts shall be done under the supervision of the qualified biologist. When appropriate, bridges or buildings shall be partially dismantled to significantly change the roost conditions, causing bats to abandon and not return to the roost, likely in the evening and after bats have emerged from the roost to forage. Under no circumstances shall active maternity roosts be disturbed until the roost disbands at the completion of the maternity roosting season or otherwise becomes inactive, as determined by the qualified biologist.
 Trimming or removal of existing trees with potential bat roosting habitat or active (non-maternity or hibernation) bat roost sites shall follow a two-step removal process, which shall occur during the time of year when bats are active, as discussed above.
- On the first day and under supervision of the qualified biologist, tree branches and limbs not containing cavities or fissures in which bats could roost shall be cut using chainsaws or other handheld equipment. - On the following day and under the supervision of the qualified biologist, the remainder of the tree may be trimmed or removed, using either chainsaws or other equipment (e.g., excavator or backhoe). - All felled trees shall remain on the ground for at least 24 hours prior to chipping, off-site removal, or other processing to allow any bats to escape, or shall be inspected once felled by the qualified biologist to ensure no bats remain within the tree and/or branches.

IMPACT BR-9: VALLEY ELDERBERRY LONGHORN BEETLE
Valley elderberry longhorn beetle is federally listed as threatened. This species is completely dependent on elderberry shrubs for all stages of its life cycle, is generally associated with riparian habitats, and is restricted to the Central Valley. It is threatened by loss and fragmentation of riparian habitat and by predation and displacement by the invasive Argentine ant.

While no elderberry shrubs that could support valley elderberry longhorn beetle were specifically observed in the areas surveyed by Bargas and HELIX, other suitable habitat in riparian and oak woodlands near the Sacramento River not directly accessible during these prior surveys could support elderberry shrubs.
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Construction activities associated with the proposed development in the UWSP area could disturb elderberry shrubs that provide habitat for valley elderberry longhorn beetle. If present during construction, valley elderberry longhorn beetles in the UWSP area may be injured or killed by construction-related activities, including grounddisturbing activities, equipment use, and/or construction of structures and infrastructure.

For this reason, the impact on the valley elderberry longhorn beetle would be potentially significant.

To address this impact, Mitigation Measures BR-2a, BR-9a, and BR-9b are provided below, which would reduce the potential impact on valley elderberry longhorn beetle by implementing measures consistent with the USFWS’s Framework for Assessing Impacts to the Valley Elderberry Longhorn Beetle (Desmocerus californicus dimorphus), dated May 2017. Therefore, with the implementation of these mitigation measures, the impact on valley elderberry longhorn beetle would be less than significant.

MITIGATION MEASURES
BR-2a, Worker Environmental Awareness Program – See Impact BR-2: Special-Status Plant Species.

BR-9a Avoid and Minimize Impacts on Valley Elderberry Longhorn Beetle  A pre-construction survey will be conducted by a qualified biologist prior to construction-related ground disturbance. If such a survey determines that valley elderberry longhorn beetle habitat is present (elderberry shrub within the project footprint), and if exit holes are present in stems greater than 1 inch in diameter, the County shall require the developer to follow the following appropriate measures to avoid and minimize take of individuals:
- If elderberry shrubs are found on or adjacent to the site, a 100-footwide avoidance buffer (measured from the dripline of the plant) will be established around all elderberry shrubs with stems greater than 1 inch in diameter at ground level and will be clearly identified in the field by staking, flagging, or fencing.
- No construction activities involving mechanized equipment will occur within the buffer areas. Human access may be permitted in the buffer, provided that it does not cause disturbance to the shrubs.  Compensatory mitigation for adverse effects may include the transplanting of elderberry shrubs during the dormant season (November 1 to February 15), if feasible, to an area protected in perpetuity as well as required additional elderberry and associated native plantings as approved by the USFWS.
 If off-site compensation includes the dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures, the details of these measures will be included in the mitigation plan and must occur with full endowments for management in perpetuity. 7 - Biological Resources
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The plan will include information on responsible parties for long-term management, holders of conservation easements, long-term management requirements, and other details, as appropriate, for the preservation of long-term viable populations.

BR-9b Transplant Elderberry Shrubs
 If elderberry plants cannot be avoided, or if project activities will result in the death of stems or the entire shrub, they shall be transplanted during the dormant season (November 1 to February 15) to an area protected in perpetuity and approved by the USFWS.
 The elderberry shrub will be cut back 3 to 6 feet from the ground or to 50 percent of its height (whichever is taller) by removing branches and stems above this height. The trunk and all stems measuring 1 inch or greater in diameter at ground level will be replanted. Any leaves remaining on the plant will be removed.
 A hole will be excavated of adequate size to receive the transplant.  The elderberry shrub will be excavated using a Vermeer® spade, backhoe, front-end loader, or other suitable equipment, taking as much of the root ball as possible, and will be replanted immediately. The plant will only be moved by the root ball. The root ball will be secured with wire and wrapped with damp burlap. The burlap will be dampened as necessary to keep the root ball wet. Care will be taken to ensure that the soil is not dislodged from around the roots of the transplant. Soil at the transplant site will be moistened prior to transplant if the soil at the site does not contain adequate moisture.
 Replacement seedling plants will be provided at a ratio of 2 to 1 to 5 to 1 depending on the extent of valley elderberry longhorn beetle utilization of the plants moved or lost. An 1,800-square-foot area will be provided for each transplanted elderberry shrub or every five elderberry seedling plants.

IMPACT BR-10: PROTECTED TREES AND CANOPY
The UWSP area contains trees potentially protected by the Sacramento County 2030 General Plan. Tree surveys were conducted in 2021 on a subset of land in the UWSP area that was accessible or could be viewed at a distance from accessible areas (Bargas 2022). The offsite improvements areas may also include trees potentially protected by the 2030 General Plan. Protected trees in the UWSP area and offsite improvement areas should be protected from removal as well as from ground disturbance.
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NATIVE TREES
Sacramento County has also adopted measures protecting its native and landmark trees. To be considered protected, a tree must have a diameter at breast height (dbh) of at least 6 inches, or if it has multiple trunks of less than 6 inches each, a combined dbh of 10 inches. For the purposes of this analysis, it is assumed that some of the existing native trees within the UWSP area are within vegetation and ground disturbance footprints associated with future construction work; as such, implementation of the proposed UWSP would result in damage to or removal of native trees that are protected by the County, including the native oak trees specifically protected by Sacramento County Code Chapter 19.12. Absent measures to protect protected trees, this impact would be potentially significant.

To address this impact, Mitigation Measures BR-10a and BR-10b are provided below.

As required under these measures, prior to the approval of improvement plans or building permits for individual projects considered under the UWSP, an International Society of Arboriculture (ISA)–Certified Arborist would conduct a tree survey to document the species, size, and condition of all trees within the respective project footprints and any trees to be removed would be individually identified. The measures would also reduce the potential impact on protected trees and canopy by installing tree protection fencing to avoid damage to the trees and their root system; prohibiting placement of vehicles, construction equipment, stockpiles, etc., within the driplines of native trees; avoiding any soil-disturbing activities within the dripline of native trees; and requiring pruning to be done under supervision of an ISA-Certified Arborist. As a result, with implementation of these mitigation measures, the impact on protected trees would be less than significant.

TREE CANOPY
The Urban Forest Management section of the Conservation Element of the Sacramento County General Plan contains an objective to double the county’s tree canopy by 2050.

The General Plan contains supporting policies calling for education and regional cooperation toward the objective; it also requires mitigation for impacts to canopies of non-native trees. Construction of individual projects considered under the proposed UWSP is expected to result in a loss of tree canopy of non-native trees. Absent measures to protect the non-native tree canopy, this impact would be potentially significant.

To address this impact to non-native tree canopies, Mitigation Measure BR-10c is provided below, and includes creation of new tree canopy equivalent to the acreage of non-native tree canopy removed through on-site mitigation or through funding contributed to the Sacramento Tree Foundation’s Greenprint program in an amount proportional to the amount of tree canopy lost. With implementation of this mitigation measure, the impact on non-native tree canopy would be less than significant. 7 - Biological Resources
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MITIGATION MEASURES
BR-10a Native Tree Removal
Before the construction phase–specific development applications are deemed complete, project applicants for each construction phase shall conduct a tree survey by an ISA-Certified Arborist. The tree survey will document the species, size, and condition of all trees within the respective project footprint and any trees to be removed will be individually identified. The removal of native trees shall be compensated for by planting in-kind native trees equivalent to the dbh inches lost, based on the ratios listed below. On-site preservation of native trees that are less than 6 inches (< 6 inches) dbh may also be used to meet this compensation requirement. Native trees include valley oak (Quercus lobata), interior live oak (Q. wislizenii), blue oak (Q. douglasii), or oracle oak (Q. morehus), California sycamore (Platanus racemosa), California black walnut (Juglans californica), Oregon ash (Fraxinus latifolia), western redbud (Cercis occidentalis), gray pine (Pinus sabiniana), California white alder (Alnus rhombifolia), boxelder (Acer negundo), California buckeye (Aesculus californica), narrowleaf willow (Salix exigua), Gooding’s willow (S. gooddingii), red willow (S. laevigata), arroyo willow (S. lasiolepis), shining willow (S. lucida), Pacific willow (S. lasiandra), and dusky willow (S. melanopsis).

Replacement tree planting shall be completed prior to approval of grading or improvement plans, whichever comes first.

Equivalent compensation based on the following ratio is required:
 One preserved native tree < 6 inches dbh on-site = 1 inch dbh  One D-pot seedling (40 cubic inches or larger) = 1 inch dbh  One 15-gallon tree = 1 inch dbh
 One 24-inch box tree = 2 inches dbh
 One 36-inch box tree = 3 inches dbh
Prior to the approval of improvement plans or building permits, whichever occurs first, a replacement tree planting plan shall be prepared by a certified arborist or licensed landscape architect and shall be submitted to the Environmental Coordinator for approval. The replacement tree planting plan(s) shall include the following minimum elements:
 Species, size, and locations of all replacement plantings and < 6-inch dbh trees to be preserved.
 Method of irrigation.
 If planting in soils with a hardpan/duripan or claypan layer, include the Sacramento County Standard Tree Planting Detail L-1, including the 10- foot-deep boring hole to provide for adequate drainage. 7 - Biological Resources
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 Planting, irrigation, and maintenance schedules.
 Identification of the maintenance entity and a written agreement with that entity to provide care and irrigation of the trees for a 3-year establishment period, and to replace any of the replacement trees which do not survive during that period.
 Designation of a 20-foot root zone radius and landscaping to occur within the radius of trees < 6 inches dbh to be preserved on-site.

No replacement tree shall be planted within 15 feet of the driplines of existing native trees or landmark size trees that are retained on-site, or within 15 feet of a building foundation or swimming pool excavation. The minimum spacing for replacement native trees shall be 20 feet on-center. Examples of acceptable planting locations are publicly owned lands, common areas, and landscaped frontages (with adequate spacing). Generally unacceptable locations are utility easements (public utility easements sewer, storm drains), under overhead utility lines, private yards of single-family lots (including front yards), and roadway medians.

Native trees < 6 inches dbh to be retained on-site shall have at least a 20- foot-radius suitable root zone. The suitable root zone shall not have impermeable surfaces, turf/lawn, dense plantings, soil compaction, drainage conditions that create ponding (in the case of oak trees), utility easements, or other overstory tree(s) within 20 feet of the tree to be preserved. Trees to be retained shall be determined to be healthy and structurally sound for future growth, by an ISA-Certified Arborist subject to Environmental Coordinator approval.

If tree replacement plantings are demonstrated to the satisfaction of the Environmental Coordinator to be infeasible for any or all trees removed, then compensation shall be through payment into the County Tree Preservation Fund. Payment shall be made at a rate of $325.00 per dbh inch removed but not otherwise compensated, or at the prevailing rate at the time payment into the fund is made.

BR-10b Native Tree Construction Protection
For the purpose of this mitigation measure, a native tree is defined as anyone of the following species: valley oak (Quercus lobata), interior live oak (Q. wislizenii), blue oak (Q. douglasii), oracle oak (Q. morehus), California sycamore (Platanus racemosa), California black walnut (Juglans californica), Oregon ash (Fraxinus latifolia), western redbud (Cercis occidentalis), gray pine (Pinus sabiniana), California white alder (Alnus rhombifolia), boxelder (Acer negundo), California buckeye (Aesculus californica), narrowleaf willow (Salix exigua), Gooding’s willow (S. gooddingii), red willow (S. laevigata), arroyo willow (S. lasiolepis), shining willow (S. lucida), Pacific willow (S. lasiandra), and dusky willow (S. melanopsis) having a diameter at breast 7 - Biological Resources
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height, or dbh, of at least 6 inches, or if it has multiple trunks of less than 6 inches each, a combined dbh of at least 10 inches.

With the exception of the trees removed and compensated for through Mitigation Measure BR-10a, above, all native trees on the project site, all portions of adjacent off-site native trees that have driplines that extend onto the project site, and all off-site native trees that may be impacted by utility installation and/or improvements associated with this project, shall be preserved and protected as follows:
 A circle with a radius measurement from the trunk of the tree to the tip of its longest limb shall constitute the dripline protection area of the tree.

Limbs must not be cut back to change the dripline. The area beneath the dripline is a critical portion of the root zone and defines the minimum protected area of the tree. Removing limbs that make up the dripline does not change the protected area.
 Chain-link fencing or a similar protective barrier shall be installed 1 foot outside the driplines of the native trees prior to initiating project construction, to avoid damage to the trees and their root system.  No signs, ropes, cables (except cables that may be installed by a certified arborist to provide limb support) or any other items shall be attached to the native trees.
 No vehicles, construction equipment, mobile home/office, supplies, materials or facilities shall be driven, parked, stockpiled, or located within the driplines of the native trees.
 Any soil disturbance (scraping, grading, trenching, and excavation) is to be avoided within the driplines of the native trees. Where this is necessary, an ISA-Certified Arborist will provide specifications for this work, including methods for root pruning, backfill specifications, and irrigation management guidelines.
 All underground utilities and drain or irrigation lines shall be routed outside the driplines of native trees. Trenching within protected tree driplines is not permitted. If utility or irrigation lines must encroach upon the dripline, they should be tunneled or bored under the tree under the supervision of an ISA-Certified Arborist.
 If temporary haul or access roads must pass within the driplines of oak trees, a roadbed of 6 inches of mulch or gravel shall be created to protect the root zone. The roadbed shall be installed from outside of the dripline and while the soil is in a dry condition, if possible. The roadbed material shall be replenished as necessary to maintain a 6-inch depth.  Drainage patterns on the site shall not be modified so that water collects or stands within, or is diverted across, the dripline of oak trees. 7 - Biological Resources
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 No sprinkler or irrigation system shall be installed in such a manner that it sprays water within the driplines of the oak trees.
 Tree pruning that may be required for clearance during construction must be performed by an ISA-Certified Arborist or Tree Worker and in accordance with the American National Standards Institute A300 pruning standards and the ISA “Tree Pruning Guidelines.”
 Landscaping beneath the oak trees may include non-plant materials such as boulders, decorative rock, wood chips, organic mulch, and noncompacted decomposed granite. Landscape materials shall be kept 2 feet away from the base of the trunk. The only plant species that shall be planted within the driplines of the oak trees are those that are tolerant of the natural semi-arid environs of the trees. Limited drip irrigation approximately twice per summer is recommended for the understory plants.
 Any fence/wall that will encroach into the dripline protection area of any protected tree shall be constructed using grade beam wall panels and posts or piers set no closer than 10 feet on center. Posts or piers shall be spaced in such a manner as to maximize the separation between the tree trunks and the posts or piers to reduce impacts on the trees.  For a project constructed during the months of June, July, August, and September, deep-water trees by using a soaker hose (or a garden hose set to a trickle) that slowly applies water to the soil until water has penetrated at least 1 foot in depth. Sprinklers may be used to water deeply by watering until water begins to run off, then waiting at least an hour or two to resume watering (provided that the sprinkler is not wetting the tree’s trunk). Deep-water every two weeks and suspend watering two weeks between rain events of 1 inch or more.

BR-10c Non-native Tree Canopy
Removal of non-native tree canopy for development shall be mitigated by creation of new tree canopy equivalent to the acreage of non-native tree canopy removed. New tree canopy acreage shall be calculated using the Sacramento County Department of Transportation’s 15-year shade cover values for tree species. Preference is given to on-site mitigation, but if this is infeasible, then funding shall be contributed to the Sacramento Tree Foundation’s Greenprint program in an amount proportional to the tree canopy lost (as determined by the 15-year shade cover calculations for the tree species to be planted through the funding, with the cost to be determined by the Sacramento Tree Foundation).
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IMPACT BR-11: JURISDICTIONAL WETLANDS AND WATERS
Under CWA Section 404, USACE regulates activities that result in the discharge of dredged or fill material into waters of the United States. Waters of the United States include wetlands as well as streams, rivers, lakes, reservoirs, ponds, bays, and oceans (33 CFR 328.3[e]). Wetlands are those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas (33 CFR 328.3[b]). Wetlands, streams, reservoirs, sloughs, and ponds are typically under federal jurisdiction under Section 404 of the CWA and state jurisdiction under the Porter-Cologne Water Quality Control Act. Streams and ponds typically fall under state jurisdiction under Section 1602 of the California Fish and Game Code.

As described in the Environmental Setting discussion, a total of 45.08 acres within the UWSP area are subject to USACE and RWQCB jurisdiction under Sections 404 and 401 of the CWA.

Within the UWSP area, jurisdictional waters and potentially jurisdictional waters would be directly and permanently impacted by filling. Within the offsite improvement areas, work over or adjacent to the West Drainage Canal (Witter Canal) could directly impact potentially jurisdictional waters if the bike trail bridge crossing were to include bridge supports below top of bank or in the channel and if the stormwater discharge and levee bank armoring were to occur below top of bank. Shading of open water due to the new bridge over the West Drainage Canal (Witter Canal) would also be considered a direct impact. Indirect impacts could occur due to construction-related erosion or spills resulting in deleterious materials entering jurisdictional waters. These impacts would be potentially significant.

To address these impacts, Mitigation Measure BR-11 is provided below, and would reduce construction-related impacts by requiring the preparation of a preliminary wetland delineation and, if jurisdictional wetlands and waters are identified, avoidance of such features to the extent practical. If jurisdictional wetlands and waters cannot be avoided, temporary impacts would be restored to pre-project conditions, and permanent impacts would be compensated for through the creation, restoration, enhancement, or preservation of equivalent habitat. Therefore, with the implementation of this mitigation measure, the impact on jurisdictional wetlands and waters would be less than significant.

MITIGATION MEASURES
BR-11 Avoidance of Impacts on Wetlands and Waters
The applicant and its contractors shall minimize impacts on waters of the United States and waters of the state, including wetlands, by implementing the following measures:
 Wetlands identified in the preliminary jurisdictional delineation report shall be avoided through project design, if feasible. All identified avoidance and 7 - Biological Resources
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protection measures shall be included on the plans for proposed demolition, grading, and/or building permits for construction activities within the UWSP area.
 The project shall be designed to avoid, to the extent practical, work within wetlands and/or waters under the jurisdiction of USACE, the Central Valley RWQCB, and/or CDFW. If applicable, permits or approvals shall be sought from the above agencies, as required. Where wetlands or other water features must be disturbed, the minimum area of disturbance necessary for construction shall be identified and the area outside avoided.
 Before the start of construction within 50 feet of any wetlands and drainages, appropriate measures shall be taken to ensure protection of the wetland from construction runoff or direct impact from equipment or materials, such as the installation of a silt fence, and signs indicating the required avoidance shall be installed. No equipment mobilization, grading, clearing, or storage of equipment or machinery, or similar activity, shall occur until a qualified biologist has inspected and approved the fencing installed around these features. The construction contractor for the specific construction activity to be undertaken shall ensure that the temporary fencing is maintained until construction activities are complete.

No construction activities, including equipment movement, storage of materials, or temporary spoils stockpiling, shall be allowed within the fenced areas protecting wetlands.
 Where disturbance to jurisdictional wetlands or waters cannot be avoided, any temporarily affected jurisdictional wetlands or waters shall be restored to pre-construction conditions or better at the end of construction, in accordance with the requirements of USACE, Central Valley RWQCB, and/or CDFW permits. Compensation for permanent impacts on wetlands or waters shall be provided at a 1:1 ratio, or as agreed upon by CDFW, USACE, and the Central Valley RWQCB, as applicable. Compensation for loss of wetlands may be in the form of permanent on-site or off-site creation, restoration, enhancement, or preservation of habitat, or agencyapproved mitigation/conservation credits. To that end, the restoration sites shall, at a minimum, meet the following performance standards by the fifth year after restoration:
 Wetlands restored or constructed as federal wetlands meet the applicable federal criteria for jurisdictional wetlands, and wetlands restored or constructed as state wetlands meet the state criteria for jurisdictional wetlands.
 Channelized habitat restored or constructed on-site to address the conversion of ditch habitat meet criteria as jurisdictional waters of the United States and/or state, as applicable.
 Native vegetation cover shall be at least 70 percent of the baseline native vegetation cover in the impact area.
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 No more cover by invasive species shall be present relative to the preproject baseline in the impact area.  Restoration or compensation shall be detailed in a Wetlands and Waters Mitigation and Monitoring Plan, which shall be developed before the start of construction and in coordination with permit applications and/or conditions from applicable regulatory agencies. Such a mitigation and monitoring plan shall meet USACE requirements for mitigation plans pursuant to 33 CFR 332.4(c) (https://www.sac.usace.army.mil/Portals/ 43/docs/regulatory/Requirements_for_a_Mitigation_Plan.pdf) and comport with the SWRCB’s State Supplemental Dredge or Fill Guidelines, Subpart J, regarding compensatory mitigation plans
(https://www.waterboards.ca.gov/board_decisions/adopted_orders/resoluti ons/2019/040219_10_procedures_clean_v032219_conformed_final.pdf).

At a minimum, the plan shall include:
 Name and contact information for the property owner of the land on which the mitigation will take place.
 Identification of the water source for supplemental irrigation, if needed.  Identification of depth to groundwater.
 Topsoil salvage and storage methods for areas that support specialstatus plants.  Site preparation guidelines to prepare for planting, including coarse and fine grading.
 Plant material procurement, including assessment of the risk of introduction of plant pathogens through the use of nursery-grown container stock vs. collection and propagation of site-specific plant materials, or use of seeds.
 A planting plan outlining species selection, planting locations, and spacing for each vegetation type to be restored.
 Planting methods, including containers, hydroseed or hydromulch, weed barriers, and cages, as needed.
 Soil amendment recommendations, if needed.
 An irrigation plan, with proposed rates (in gallons per minute), schedule (i.e., recurrence interval), and seasonal guidelines for watering.
 A site protection plan to prevent unauthorized access, accidental damage, and vandalism.
 Weeding and other vegetation maintenance tasks and schedule, with specific thresholds for acceptance of invasive species. 7 - Biological Resources
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 Performance standards, as referenced above, by which successful completion of mitigation can be assessed relative to a relevant baseline or reference site, and by which remedial actions will be triggered.
 Success criteria that shall include the minimum performance standards described in 1-4 of this measure, above.
 Monitoring methods and schedule.
 Reporting requirements and schedule.
 Adaptive management and corrective actions to achieve the established success criteria.
 An educational outreach program to inform operations and maintenance departments of local land management and utility agencies of the mitigation purpose of restored areas to prevent accidental damages.

The Wetlands and Waters Mitigation and Monitoring Plan shall be developed before the start of construction and in coordination with permit applications and/or conditions from applicable regulatory oversight agencies. The plan shall be submitted to the County prior to the issuance of any demolition, grading, or building permit that would include construction activities that would have direct impacts on wetlands and/or waters.

IMPACT BR-12: WILDLIFE MOVEMENT AND NURSERY SITES

GIANT GARTER SNAKE
Giant garter snake is well documented in the CNDDB in areas surrounding the UWSP area, including in 2016 at Fisherman’s Lake, immediately north of the UWSP area.

A two-year protocol giant garter snake trapping and eDNA study in 2019 and 2020 resulted in no trapped giant garter snakes in the UWSP area. Giant garter snake eDNA was detected in one location in the central portion of the UWSP area. These results, in combination with the documented presence of giant garter snake in the vicinity of the UWSP area, suggest that while the UWSP area likely does not support a self-sustaining giant garter snake breeding population, individual giant garter snakes likely use the UWSP area as dispersal habitat. Construction of individual projects considered under the proposed UWSP would presumably involve removal (filling) of irrigation ditches and adjacent ground disturbance. Removal of ditches would constitute a permanent loss of giant garter snake dispersal habitat, and this impact would be potentially significant.

To address the potential impact on giant garter snake movement, Mitigation Measure BR-3 is provided above, and would reduce the potential impact on giant garter snake movement corridors in the UWSP area through creation, preservation, and management of marsh, or preservation and management of rice fields, as habitat for giant garter snake; or enhancement or restoration of the connectivity of giant garter snake habitat. As a result, with the implementation of this mitigation measure, the impact on giant garter snake would be less than significant. 7 - Biological Resources
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MIGRATORY BIRDS
The UWSP area is within the Pacific Flyway, and as such supports some migratory bird species. Construction-related direct impacts on migratory birds could result from the removal of vegetation while an active bird nest is present. In addition, earthmoving, operation of heavy equipment, and increased human presence could result in noise, vibration, and visual disturbance. These conditions could indirectly result in nest failure (disturbance, avoidance, or abandonment that leads to unsuccessful reproduction), or could cause flight behavior that would expose a migratory adult to predators. These activities could cause birds that have established a nest before the start of construction to change their behavior or even abandon an active nest, putting their eggs and nestlings at risk for mortality. Without mitigation, this impact on migratory birds is potentially significant.

Previously identified Mitigation Measures BR-2a and BR-5 would reduce the potential impact on nesting birds by requiring the provision of environmental training for construction personnel; limiting construction to the non-nesting season when feasible or, if avoiding the nesting season is not feasible, conducting pre-construction surveys for nesting birds and establishing no-disturbance buffers around any active nests to ensure they are not disturbed by construction; and repeating the pre-construction surveys when work resumes after being suspended for seven days. As a result, with the implementation of these mitigation measures, the impact on migratory birds would be less than significant.

MITIGATION MEASURES
BR-2a Worker Environmental Awareness Program – See Impact BR-2: SpecialStatus Plant Species.

BR-3 Compensate for Permanent Impacts to Giant Garter Snake Habitat – See Impact BR-3: Giant Garter Snake.

BR-5 Avoid and Minimize Impacts on Nesting Birds – See Impact BR-5: SpecialStatus Bird Species (Other Than Burrowing Owl and Swainson’s Hawk), Birds Protected by the Migratory Bird Treaty Act, and Nesting Raptors.

IMPACT BR-13: CONFLICT WITH ANY LOCAL POLICIES OR ORDINANCES

PROTECTING BIOLOGICAL RESOURCES
Sacramento County’s 2030 General Plan policies protect native and landmark trees, and non-native tree canopy as analyzed previously under Impact BR-10. As disclosed previously under Impact BR-10, implementation of Mitigation Measures BR-10a through BR-10c would reduce impacts on protected native and landmark trees and non-native tree canopy to less than significant.

In addition, the County has adopted a Swainson’s Hawk ordinance, described in more detail under the Regulatory Setting. The ordinance established a Swainson’s Hawk Impact Mitigation Program (Chapter 16.130 of the Sacramento County Code), which, as described in the Regulatory Setting section, provides for the voluntary means for 7 - Biological Resources
Upper Westside Specific Plan 7-76 PLNP2018-00284
mitigation of impacts on Swainson’s hawk foraging habitat. The proposed UWSP would permanently impact over 40 acres of Swainson’s hawk foraging habitat, and if not mitigated according to the County’s Swainson’s Hawk Impact Mitigation Program, the impact would be potentially significant.

To address this impact, Mitigation Measures BR-7b and BR-10a through BR-10c are provided above and would reduce potential conflicts with County policies and ordinances protecting biological impacts by complying with the County’s tree preservation ordinance and by complying with the Swainson’s Hawk Impact Mitigation Program, including providing compensatory mitigation at a 1:1 ratio for project-related loss of Swainson’s hawk foraging habitat. Therefore, with the implementation of these mitigation measures, the impact with respect to conflicts with County policies and ordinances protecting biological resources would be less than significant.

MITIGATION MEASURES
BR-7b Compensate for Permanent Impacts on Swainson’s Hawk Foraging Habitat – See Impact BR-7: Swainson’s Hawk.

BR-10a, 10b, and 10c: Comply with Sacramento County Tree Preservation Ordinance – See Impact BR-10: Protected Trees and Canopy.

IMPACT BR-14: CONFLICT WITH NATOMAS BASIN HCP AND METRO AIR

PARK HCP
The NBHCP and MAP HCP are adopted conservation plans with respective plan areas that cover portions of the Natomas Basin. The MAP HCP has been amended to, for all practical purposes, apply the NBHCP’s conservation plan (NBHCP Chapter IV, Conservation Plan). The County of Sacramento is not a party to either the NBHCP or the MAP HCP. As described in the NBHCP, if the County of Sacramento considers new projects within an unincorporated area of the Natomas Basin, the County would review the biological resources impacts of the new projects and ensure that the project demonstrates adequate mitigation to compensate for biological resources impacts in accordance with state and federal law.

The proposed UWSP could affect species covered by these HCPs or the implementation of their conservation plans. The attached Supplemental Biological Resources Assessment (HELIX 2024; Appendix BIO-1) describes in detail the potential effects of the proposed UWSP on the NBHCP and MAP HCP, and an evaluation of the potential conflicts with these HCPs is presented below. This evaluation is focused on potential conflicts with conservation of species covered by the HCPs and potential conflicts with the conservation strategies of their conservation plan.

The NBHCP provides for conservation of 22 wildlife and plant species and the MAP HCP includes 14 covered wildlife and plant species, many of which are the same as those listed under the NBHCP. Mitigation Measures BR-1 and BR-10a through BR-10c, described previously in this chapter, would contribute to protection of species covered under the NBHCP and MAP HCP as shown in Table BR-3.
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Table BR-3: Evaluation of Habitat Conservation Plan Covered Species Common Name/
Scientific Name
NBHCP
Covered
Species?
MAP
HCP
Covered
Species?
Habitat
Mitigation
Measure(s)
Effect on HCP
Covered Species
Northwestern pond turtle
Actinemys marmorata
Yes Yes Suitable habitat is present. BR-1, BR-2a, BR-4
Less than Significant
with Mitigation
Tricolored blackbird
Agelaius tricolor
Yes Yes Suitable habitat is present. BR-1, BR-2a, BR-5
Less than Significant
with Mitigation
California tiger salamander
Ambystoma californiense
Yes No Suitable habitat is absent. NA No impact
Burrowing owl
Athene cunicularia
Yes Yes Suitable habitat is present. BR-1, BR-2a, BR-6
Less than Significant
with Mitigation
Vernal pool fairy shrimp
Branchinecta lynchi
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Midvalley fairy shrimp
Branchinecta mesovallensis
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Cackling (=Aleutian Canada)
goose
Branta hutchinsii leucopareia
Yes Yes
Does not breed in Central Valley and
not documented in the study area.

May occur on transitory basis in
winter.

NA No Impact
Swainson’s hawk
Buteo swainsoni Yes Yes
Suitable habitat identified during
reconnaissance survey.

BR-1, BR-2a,
BR-7a and BR-7b,
BR-10a through
BR-10c
Less than Significant
with Mitigation
Valley elderberry longhorn beetle
Desmocerus californicus
dimorphus
Yes Yes
No elderberry shrubs identified
during reconnaissance survey.

BR-9a and BR-9b
Less than Significant
with Mitigation
American peregrine falcon
Falco peregrinus anatum
No Yes
Species not observed during
reconnaissance survey.

BR-1, BR-2a, BR-5
Less than Significant
with Mitigation
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Common Name/
Scientific Name
NBHCP
Covered
Species?
MAP
HCP
Covered
Species?
Habitat
Mitigation
Measure(s)
Effect on HCP
Covered Species
Boggs Lake hedge-hyssop
Gratiola heterosepala
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Greater sandhill crane
Grus canadensis tabida No Yes
Not known to use the Natomas
Basin, but foraging habitat is
present.

NA No Impact
Delta tule pea
Lathyrus jepsonii var. jepsonii
Yes Yes
Suitable marsh habitat is absent.

NA No Impact
Loggerhead shrike
Lanius ludovicianus
Yes Yes Suitable habitat is present. BR-1, BR-2a, BR-5
Less than Significant
with Mitigation
Legenere
Legenere limosa
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Vernal pool tadpole shrimp
Lepidurus packardi
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Colusa grass
Neostapfia colusana
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Slender Orcutt grass
Orcuttia tenuis
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
Sacramento Orcutt grass
Orcuttia viscida
Yes No
Suitable vernal pool habitat is
absent.

NA No Impact
White-faced Ibis
Plegadis chihi Yes Yes
Suitable extensive marsh habitat for
breeding is absent. Foraging habitat
is present.

BR-1, BR-2a, BR-5
Less than Significant
with Mitigation
Bank swallow
Riparia riparia
Yes Yes
Study area lacks suitable nesting
and foraging habitat.

NA No Impact
Sanford’s arrowhead
Sagittaria sanfordii
Yes Yes
Suitable habitat is not present. BR-1, BR-2a
through BR-2c
Less than Significant
with Mitigation
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Common Name/
Scientific Name
NBHCP
Covered
Species?
MAP
HCP
Covered
Species?
Habitat
Mitigation
Measure(s)
Effect on HCP
Covered Species
Western spadefoot toad
Spea hammondii
Yes No Suitable habitat is not present. N/A No Impact
Giant garter snake
Thamnophis gigas
Yes Yes
Suitable habitat identified during
reconnaissance survey.

BR-1, BR-2a, BR-3
Less than Significant
with Mitigation
NOTES: HCP = habitat conservation plan; MAP HCP = Metro Air Park Habitat Conservation Plan; NA = not applicable; NBHCP = Natomas Basin Habitat Conservation Plan
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The effects of the proposed UWSP, including the effects of implementing Mitigation Measures BR-3 and BR-7, were evaluated to determine whether they would conflict with any of the previously described four main strategies of the NBHCP:

1. General Conservation Strategy

2. Guidelines for Reserve Acquisition

3. Conservation Strategy for Wetland Habitat

4. Conservation Strategy for Upland Habitat
The evaluation of potential conflicts with these four main strategies is summarized below.

GENERAL CONSERVATION STRATEGY
The general conservation strategy consists of:
 Preparation of site-specific management plans (SSMPs) (Section IV.C.1.b).  Buffers within the reserve lands (Section IV.C.1.c).
 Connectivity (Section IV.C.1.d).
 2,500-acre-/400-acre-minimum habitat block size requirements (Section IV.C.1.f).  Foraging habitat (Section IV.C.1.e).
 Basis for 0.5 to 1 mitigation ratio (Section IV.C.1.a).

SITE-SPECIFIC MANAGEMENT PLANS
Development of the proposed UWSP is not anticipated to adversely affect any sitespecific management plans, or SSMPs, for existing or future TNBC reserves within or in the vicinity of the UWSP area. The 30-acre Alleghany Reserve, which is part of the NBHCP reserve system managed by TNBC, is within the UWSP area and would be part of the proposed agricultural buffer (Ag Buffer) planned for the proposed UWSP and thus is not anticipated to be affected by development. The southern portion of the Alleghany Reserve, which borders San Juan Road, may experience temporary impacts during the proposed San Juan Road tie-in to Garden Highway; however, this is not anticipated to adversely affect the SSMP. The offsite improvements would be carried out on an existing section of San Juan Road in a manner that would not be expected to cause impacts on the Alleghany Reserve through compliance with applicable species avoidance and minimization measures BR-1 to BR-9, discussed above. The approximately 56-acre Cummings Reserve, which is also part of the NBHCP reserve system, lies just north of the UWSP Ag Buffer area, and west of the northernmost portion of the UWSP development area, which includes an open space–ag buffer between the Cummings Reserve and very low-density residential development. SSMPs for each existing TNBC reserve are currently designed to maximize benefits to NBHCP Covered Species using the resources within that individual reserve or reserve block and incorporate adaptive management strategies. Thus, changes in land use outside of an existing TNBC reserve are unlikely to necessitate changes to an SSMP.
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BUFFERS WITHIN THE RESERVE LANDS
The proposed UWSP is not expected to affect the buffers within existing reserve lands.

Per the NBHCP, buffers ranging from 30- to 70-foot-wide strips of native or ruderal vegetation along the edge of the reserve are often incorporated into TNBC reserves to minimize the effects of incompatible adjoining land uses. The NBHCP includes a requirement that reserves be initially sited at least 800 feet from existing or planned urban lands at the time of acquisition (City of Sacramento et al. 2003, page IV-16).

Mitigation lands or easements that do not comply with the 800-foot setback requirement may be acquired on a case-by-case basis; for example, the Cummings Reserve and Anne Rudin Reserve were acquired by TNBC on the west side of Fisherman’s Lake despite the less than 800-foot setback from designated urban lands. The proposed UWSP includes a 250-foot open space buffer between planned “very low density residential”10 urban development in the UWSP and the Cummings Reserve. The potential for operational impacts, such as stormwater runoff, from the proposed UWSP on the water quality of the Cummings Reserve would be reduced through compliance of individual projects with the regional Municipal Stormwater Permit, through which site design measures and treatment control measures (e.g., vegetated filter strips, stormwater planters, infiltration basins) would be incorporated into the overall design and would effectively serve as source control measures to protect water quality. The 50-acre Alleghany Reserve is within the UWSP area and would be part of the proposed Ag Buffer planned for the proposed UWSP. An agricultural buffer would separate the eastern edge of the Alleghany Reserve from the western edge of planned low-density residential development.11
The southern portion of the Alleghany Reserve, which borders San Juan Road, may experience temporary impacts during the proposed San Juan Road tie-in to Garden Highway. These offsite improvements would be carried out on an existing section of San Juan Road and in a manner that would not be expected to cause impacts on the Alleghany Reserve through compliance with applicable species avoidance and minimization measures BR-1 to BR-9, discussed above.

Thus, planned urban development within the UWSP area is not adjacent to existing TNBC reserves, and would therefore not alter the effectiveness of buffers within these reserve lands.

CONNECTIVITY
The NBHCP conservation strategy prioritizes maintaining connectivity for giant garter snake between TNBC reserves and anticipates that such connectivity would also afford migration opportunities for other NBHCP-covered species within the Natomas Basin.

The proposed UWSP is not expected to significantly affect the connectivity of aquatic habitat for giant garter snake. Aquatic habitat in the Natomas Basin consists primarily of drainage and flood control channels. Implementation of the proposed UWSP would

10 Very-low-density residential development would provide large single-family lots with densities from

1.0 to 4.0 dwelling units per acre (du/ac) with an anticipated density of 1.0 du/ac. 11 This estimate is based on Figure 2, Proposed Project – Upper Westside Specific Plan (HELIX 2024). 7 - Biological Resources
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result in the loss of approximately 21.9 acres of suitable aquatic giant garter snake habitat; however, the UWSP area is a largely isolated patch of agricultural land surrounded on its eastern, northeastern, and southeastern boundaries by urban development. The UWSP area is hydrologically connected to the Cummings Reserve but given that the existing canals and ditches in the UWSP area are terminal habitat for giant garter snake, the proposed UWSP would not reduce connectivity between reserve land or other giant garter snake habitat. The proposed UWSP also would not affect the delivery of water to existing reserves. Further, off-site mitigation for the proposed UWSP would be sited, to the extent feasible, to enhance connectivity between existing reserves or more conducive giant garter snake habitats within the Natomas Basin.

MINIMUM BLOCK SIZE
The NBHCP stipulates that, by the end of its 50-year life span, the TNBC reserve system will have reached 8,750 acres with one habitat block at least 2,500 acres in size and the balance of reserve lands in habitat blocks of at least 400 acres in size.

The NBHCP is now about 20 years into that 50-year time frame, and it has already successfully completed its largest land acquisition milestone by completing the 2,500- acre block requirement. Regarding establishing habitat blocks of at least 400 acres, the UWSP area is not positioned relative to existing reserves such that its development would preclude connecting existing reserves to create 400-acre blocks, which could be accomplished through land acquisition to the north of the UWSP area, creating linkages that enhance the NBHCP Reserve System. Land within the UWSP Ag Buffer may be suitable as habitat mitigation land and could add to the NBHCP reserve by connecting new reserve land to the Alleghany Reserve (refer to Plate B-3, or the 2024 Base Map published by TNBC, https://natomasbasin.org/maps).

In conclusion, the UWSP would not prevent the development of a reserve system with the minimum block sizes stipulated in the NBHCP.

FORAGING HABITAT AND MITIGATION RATIO
Based on the analysis presented above under Impact BR-7, the proposed UWSP would result in permanent loss of 1,197 acres of Swainson’s hawk foraging habitat within the UWSP area, including 975 acres within the Swainson’s Hawk Zone of the NBHCP.

Consistent with the Sacramento County Swainson’s hawk mitigation ordinance, the proposed UWSP would provide mitigation for impacts on Swainson’s hawk foraging habitat at a 1:1 ratio (Sacramento County Code, Chapter 16.130) as proposed in Mitigation Measure BR-7b.

Based on the analysis presented above under Impact BR-3, the proposed UWSP would result in a permanent loss of 21.9 acres of suitable giant garter snake aquatic habitat,

72.4 acres of suitable undisturbed giant garter snake upland habitat, and 396 acres of suitable disturbed upland habitat for giant garter snake (HELIX 2024). The proposed UWSP would be required to mitigate at a ratio of 1:1 (mitigation aquatic habitat to permanently lost aquatic habitat) and at a ratio of 2:1 for mitigation through preservation and management of rice fields. Mitigation through funding project(s) to enhance or restore habitat connectivity would be for an amount of funding equivalent to mitigation of 7 - Biological Resources
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the impact through the purchase of credits (at a 1:1 ratio) as proposed in Mitigation Measure BR-3.

In addition, this EIR identifies mitigation measures to protect NBHCP and MAP HCP covered species (Table BR-3) that could be potentially impacted by the proposed UWSP, as summarized in the Mitigation Measures discussion, below.

GUIDELINES FOR RESERVE ACQUISITION
As described in the Minimum Block Size discussion, above, the NBHCP has completed its largest land acquisition milestone by completing the 2,500-acre block requirement, and the UWSP area is not positioned relative to existing reserves such that its development would preclude establishing habitat blocks of at least 400 acres adjacent to existing reserves.

The NBHCP aims to create a system of reserves that would support giant garter snake and Swainson’s hawk, and other covered species that overlap significantly in their habitat requirements. Implementation of Mitigation Measure BR-3 and Mitigation Measure BR-7 would require the creation of reserves to compensate for loss of giant garter snake aquatic and upland habitat and Swainson’s hawk foraging habitat, respectively.

In addition, implementation of Mitigation Measure BR-3 and Mitigation Measure BR-7b allow flexibility in the location of future project mitigation sites. For permanent impacts on giant garter snake aquatic habitat, mitigation sites would be required to be located outside of the Natomas Basin and within the American Basin Recovery Unit as defined in the Recovery Plan for the Giant Garter Snake (Thamnophis gigas). For permanent loss of Swainson’s hawk foraging habitat, mitigation sites would be outside, and within 10 miles of, the Natomas Basin. As a result, Swainson’s hawk foraging habitat and giant garter snake habitat mitigation lands would not unnecessarily directly compete with TNBC for habitat mitigation opportunities within the geographic boundaries of the Natomas Basin. Therefore, the proposed UWSP would not conflict with the second main strategy of the NBHCP conservation plan. In addition, mitigation within 10 miles of the Natomas Basin would benefit the American Basin population of giant garter snake and the Central Valley population of Swainson’s hawks, both of which utilize the Natomas Basin.

CONSERVATION STRATEGY FOR WETLAND HABITAT
The NBHCP conservation strategy for wetland habitat is to (1) convert rice land into managed marsh wetlands and (2) preserve rice land and manage it to provide greater habitat values than unpreserved rice land. The UWSP area does not include existing rice land; however, it includes agricultural ditches that provide potential aquatic habitat for giant garter snake. Mitigation Measure BR-3 calls for compensation for grounddisturbing activity within 200 feet of aquatic habitat for giant garter snake. The mitigation would be located in the American Basin Recovery Unit. Because most of the American Basin Recovery Unit is outside the Natomas Basin, implementation of Mitigation Measure BR-3 is not expected to interfere with the ability of TNBC to satisfy its mitigation responsibilities under the NBHCP and MAP HCP. 7 - Biological Resources
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CONSERVATION STRATEGY FOR UPLAND HABITAT
The NBHCP conservation strategy for upland habitat is to avoid development in the Swainson’s Hawk Zone (within the City of Sacramento and Sutter County) and to preserve upland habitat inside the Swainson’s Hawk Zone and elsewhere within the Natomas Basin. The proposed UWSP is anticipated to impact 975 acres of Swainson’s hawk foraging habitat within the Swainson’s Hawk Zone, which would be mitigated offsite. Mitigation Measure BR-7b requires compensatory mitigation for the permanent loss of foraging habitat at a ratio of 1:1 with mitigation sites located outside, and within 10 miles of, the Natomas Basin. The 1:1 mitigation ratio identified in Mitigation Measure BR-7b is greater than the 0.5:1 mitigation ratio identified in the NBHCP Conservation Plan, which calls for 2,187.5 acres of upland habitat managed to support Swainson’s hawk and other upland species12 to address an anticipated 9,188 acres of general foraging habitat for Swainson’s hawk projected to be converted to urban uses. Because Mitigation Measure BR-7b requires that foraging habitat mitigation sites be located outside, and within 10 miles of, the Natomas Basin, implementation of Mitigation Measure BR-7b is not expected to interfere with the ability of TNBC to satisfy its mitigation responsibilities under the NBHCP and MAP HCP. Therefore, while a portion of the proposed UWSP development is within the NBHCP Swainson’s Hawk Zone, implementation of Mitigation Measure BR-7b would minimize any potential conflict with this NBHCP strategy through applying a higher mitigation ratio for conservation of Swainson’s hawk foraging habitat than proposed in the NBHCP, and by targeting this compensatory mitigation outside of Natomas Basin.

SUMMARY
As described above in this chapter, identified mitigation measures to avoid or substantially reduce the adverse effects of the proposed UWSP on biological resources include measures to protect each species covered under the NBHCP and MAP HCP that potentially would be adversely affected by the proposed UWSP (Table BR-3).

With the implementation of these measures, the proposed UWSP would not conflict with the provisions of either the NBHCP or the MAP HCP. Implementation of Mitigation Measures BR-1 through BR-9, as described earlier in this chapter, would avoid and minimize impacts to covered species in the NBHCP and MAP HCP, protected trees and canopy, and jurisdictional wetlands and waters, and have been designed to avoid conflicts with the strategies and provisions of the respective HCPs. Given these considerations, the proposed UWSP would not conflict with the provisions of existing adopted HCPs, and the overall impact would be less than significant.

MITIGATION MEASURES
None required.

12 In addition to these 2,187.5 acres, the NBHCP also identifies that upland edges around managed marsh areas, the 10% of TNBC rice fields that will remain fallow each year, and the fact that TNBC seasonal marshes and rice fields will be drawn down for a substantial portion of the Swainson’s hawk foraging season would provide some additional foraging habitat for the species.

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8 CLIMATE CHANGE

INTRODUCTION
This chapter describes the potential greenhouse gas (GHG) emissions and climate change impacts related to the construction and operation of proposed development in the proposed UWSP. This chapter is based on information presented in the Air Quality and Greenhouse Gas Impact Analysis prepared by Raney Planning and Management, Inc. in 2024, which is included in Appendix AQ-1 to this Draft EIR and was revised to reflect the most recent guidance for evaluating GHG impacts under CEQA developed and adopted by the Sacramento Metropolitan Air Quality Management District (SMAQMD). Additionally, this chapter has been updated to include the most recent developments in the County’s climate action planning process.

Comment letters were submitted in response to the Notice of Preparation that included comments from agencies, groups, and individuals. The proposed UWSP received scoping comments from SMAQMD pertaining to air pollutant emissions, but no comments from SMAQMD or others specifically regarding GHG emissions were received. SMAQMD input regarding air quality is considered in Chapter 6, Air Quality.

ENVIRONMENTAL SETTING
Global warming and climate change are common terms used to describe the increase in the average temperature of the earth’s near-surface air and oceans since the mid-20th century. Increasing GHG concentrations resulting from human activity such as fossil fuel combustion, deforestation, and other activities are a major factor in climate change.

GHGs in the atmosphere naturally trap heat by impeding the exit of solar radiation that has hit the Earth and is reflected back into space—a phenomenon sometimes referred to as the greenhouse effect. Some GHGs occur naturally and are necessary for keeping the Earth’s surface inhabitable. However, increases in the concentrations of these gases in the atmosphere during the last 100 years have trapped solar radiation and decreased the amount that is reflected back into space, intensifying the natural greenhouse effect and resulting in the increase of global average temperature.

Carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) are the principal GHGs. CO2, CH4, and N2O occur naturally and are also generated through human activity. Emissions of CO2 are largely byproducts of fossil fuel combustion (e.g., coal, natural gas), whereas CH4 results from off-gassing,1 natural gas leaks from pipelines and industrial processes, and incomplete combustion associated with agricultural practices, landfills, energy

1 Off-gassing is defined as the release of chemicals under normal conditions of temperature and pressure.
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providers, and other industrial facilities. N2O emissions are also largely attributable to agricultural practices and soil management. Other human-generated GHGs include fluorinated gases such as HFCs, PFCs, and SF6, which have much higher heatabsorption potential than CO2 and are byproducts of certain industrial processes.

CO2 is the typical reference gas for climate change, as it is the GHG emitted in the highest volume. While some other GHGs have a higher potential for causing climate change, they are emitted in much lower levels and are not as significant a factor. In emissions inventories, GHG emissions are typically reported as metric tons of CO2 equivalents (MTCO2e). CO2e emissions are calculated as the product of the mass emitted of a given GHG and its specific global warming potential (GWP).

POTENTIAL EFFECTS OF HUMAN ACTIVITY ON GHG EMISSIONS
Fossil fuel combustion, especially for the generation of electricity and powering of motor vehicles, has led to substantial increases in CO2 emissions and thus substantial increases in atmospheric concentrations of CO2. There is international scientific consensus that human-caused increases in GHGs have contributed to and will continue to contribute to global warming. Potential global warming impacts in California may include a loss in Sierra Nevada snowpack, sea level rise, more extreme heat days per year, an increase in high ground-level ozone days, larger and more intense forest fires, and increased drought conditions. Secondary effects will likely include displacement due to sea level rise, impacts on agriculture, changes in disease vectors, and changes in habitat and biodiversity for various plants and animals. In California, it is expected that global warming will cause detrimental effects to some of the state’s largest industries, including agriculture, winemaking, tourism, skiing, commercial and recreational fishing, forestry, and the adequacy of electrical power generation (CARB 2017).

GREENHOUSE GAS EMISSIONS ESTIMATES

GLOBAL EMISSIONS
Worldwide GHG emissions generated in 2020 were approximately 54 billion MTCO2e (Ritchie, et al. 2024). This includes both ongoing emissions from industrial and agricultural sources but excludes emissions from land use changes.

U.S. EMISSIONS
In 2022, the last emissions year reported at the federal level, the United States emitted about 6.3 billion MT CO2e. Of the major economic sectors—residential, commercial, industrial, electric power, agricultural, and transportation—transportation accounts for the highest fraction of GHG emissions (approximately 29 percent), followed by electric power (approximately 25 percent) and industry (approximately 23 percent). The remaining 23 percent of U.S. GHG emissions were contributed by, in order of magnitude, the agriculture, commercial, and residential sectors (USEPA 2024). 8 - Climate Change
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STATE OF CALIFORNIA EMISSIONS
California produced approximately 381 million MTCO2e in 2021. Combustion of fossil fuel in the transportation sector was the single largest source of California GHG emissions in 2021, accounting for 39 percent of total GHG emissions in the state. This sector was followed by the industrial sector (22 percent), the electric power sector (including both in-state and out-of-state sources) (16 percent), residential and commercial sectors (14 percent), and agriculture sector (8 percent) (CARB 2024).

EXISTING CONDITIONS

SACRAMENTO COUNTY EMISSIONS
Sacramento County produced approximately 4.03 million MTCO2e in 2021, according to the most recent community-wide emissions inventory year. The transportation sector represented the largest source of GHG emissions, accounting for 43 percent of annual CO2e emissions. Electricity and natural gas used to operate, heat, and cool commercial, industrial, and residential buildings accounted for another 36 percent of annual CO2e emissions. The other CO2e emissions sectors included in the inventory were solid waste (4 percent), off-road vehicles (2.5 percent), agriculture (6 percent), high-GWP gases (8 percent), and wastewater (<1 percent) (Sacramento County 2023). Table CC-1 presents the 2021 GHG inventory for Sacramento County.

Table CC-1: Sacramento County GHG Emissions
Sector
2021 GHG Emissions
(MTCO2e) Percent
Residential Energy 878,308 22%
Commercial / Industrial Energy 555,596 14%
On-Road Vehicles 1,740,212 43%
Off-Road Vehicles 107,174 2.5%
Solid Waste 156,422 4%
Agriculture 234,536 6%
High-GWP Gases 329,734 8%
Wastewater 24,928 0.5%
Total 4,026,910 100%
NOTES: GHG = greenhouse gas; MTCO2e = metric tons of carbon dioxide equivalent; GWP = global warming potential.

SOURCE: Sacramento County 2023
8 - Climate Change
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EXISTING (BASELINE) CONDITIONS
The UWSP area is located in unincorporated Sacramento County adjacent to the existing city of Sacramento communities of North and South Natomas. The proposed UWSP is bounded by Fisherman’s Lake Slough to the north, the West Drainage Canal (Witter Canal) to the east, I-80 to the south, and Garden Highway to the west. The 2,066-acre site is outside of the County’s Urban Policy Area and Urban Services Boundary in the Natomas community and Natomas Vision Area, and is predominantly agricultural land with existing commercial uses, including a truck stop, restaurants, gas stations, and hotels located west of the I-80 off/on-ramp.

Surrounding existing land uses include the Sacramento River to the south and west; agricultural land to the west; I-80, multi-family residences, and a business park to the east; and single-family residences to the east, west, north, and south.

The Sacramento County General Plan designates the site as Agricultural Cropland, Agricultural Residential, Commercial/Office, and Recreation and the site is zoned Agricultural, Agricultural Residential, General Commercial, and Highway Travel Commercial.

The existing land uses in the UWSP area are agriculture, agricultural residential, commercial, and recreation. The area is currently being actively farmed, but the site is not an existing substantial material source of GHG emissions.

REGULATORY SETTING
In recent years federal, state, regional, and local governments have been active in studying and regulating GHG emissions. The actions that are considered particularly important in establishing targets for GHG emissions, and that have been used by Sacramento County in establishing thresholds of cumulative significance, are listed below.

FEDERAL
MASSACHUSETTS V. ENVIRONMENTAL PROTECTION AGENCY
In Massachusetts v. Environmental Protection Agency et al. (2007) 549 U.S. 497, California and other states, cities, and environmental organizations sued to require the U.S Environmental Protection Agency (USEPA) to regulate GHGs as pollutants under the Clean Air Act. The U.S. Supreme Court ruled that GHGs fit within the Clean Air Act’s definition of a pollutant and that USEPA has the authority to regulate GHGs. On December 7, 2009, the USEPA Administrator signed two findings regarding GHGs under Section 202(a) of the federal Clean Air Act:
 Endangerment Finding: The current and projected atmospheric concentrations of six key GHGs—CO2, methane, nitrous oxide, hydrofluorocarbons, 8 - Climate Change
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perfluorocarbons, and sulfur hexafluoride—threaten the public health and welfare of current and future generations.
 Cause or Contribute Finding: The combined emissions of these GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution that threatens public health and welfare.

FEDERAL VEHICLE STANDARDS
In response to the U.S. Supreme Court ruling discussed above, the George W. Bush Administration issued Executive Order 13432 in 2007 directing USEPA, the U.S.

Department of Transportation, and the U.S. Department of Energy to establish by 2008 regulations for reducing GHG emissions from motor vehicles, non-road vehicles, and non-road engines. In 2009, the National Highway Traffic Safety Administration (NHTSA) issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in 2010, USEPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016.

In 2010, the Obama Administration issued a memorandum directing the U.S.

Department of Transportation, U.S. Department of Energy, USEPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG emissions reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, USEPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model year 2017–2025 light-duty vehicles (USEPA 2010). The proposed standards were designed to achieve 163 grams per mile of CO2 in model year 2025, on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017–2021, and NHTSA intended to set standards for model years 2022– 2025 in a future rulemaking. However, on January 12, 2017, USEPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks (USEPA 2017).

In addition to the regulations applicable to cars and light-duty trucks described above, in 2011 USEPA and NHTSA announced fuel economy and GHG standards for mediumduty and heavy-duty trucks for model years 2014–2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories:
combination tractors, heavy-duty pickup trucks and vans, and recreational vehicles.

According to USEPA, this regulatory program was designed to reduce GHG emissions and fuel consumption for the affected vehicles by 6–23 percent over the 2010 baselines.

In August 2016, USEPA and NHTSA announced the adoption of the Phase 2 program related to the fuel economy and GHG standards for medium-duty and heavy-duty trucks. The Phase 2 program applies to model years 2018–2027 for certain trailers, and model years 2021–2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (USEPA 2016). 8 - Climate Change
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STATE
CALIFORNIA ENVIRONMENTAL QUALITY ACT AND SENATE BILL 97 Under CEQA, lead agencies are required to disclose the reasonably foreseeable adverse environmental effects of projects they are considering for approval. GHG emissions have the potential to adversely affect the environment because they contribute to global climate change. In turn, global climate change has the potential to raise sea levels, alter rainfall and snowfall, and affect habitat.

Senate Bill (SB) 97, signed in August 2007, acknowledges that climate change is a prominent environmental issue requiring analysis under CEQA. This bill directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the California Natural Resource Agency (CNRA) guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, no later than July 1, 2009. The CNRA was required to certify or adopt those guidelines by January 1, 2010.

On December 30, 2009, the CNRA adopted amendments to the State CEQA Guidelines, as required by SB 97. The State CEQA Guidelines amendments provide guidance to public agencies regarding the analysis and mitigation of the effects of GHG emissions in draft CEQA documents. The amendments became effective March 18, 2010.

The State CEQA Guidelines are embodied in the California Code of Regulations (CCR), Public Resources Code, Division 13, starting with Section 21000. Section 15064.4 of the State CEQA Guidelines specifically addresses the significance of GHG emissions, requiring a lead agency to make a “good-faith effort” to “describe, calculate or estimate” GHG emissions in CEQA environmental documents. Section 15064.4 further states that the analysis of GHG impacts should include consideration of (1) the extent to which the project may increase or reduce GHG emissions, (2) whether the project GHG emissions would exceed a threshold of significance that the lead agency determines applies to the project, and (3) the extent to which the project would comply with “regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions (see, e.g., Section 15183.5(b)).” The CEQA Guidelines also state that a project’s incremental contribution to a cumulative effect might not be cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program (including plans or regulations for the reduction of greenhouse gas emissions) that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area in which the project is located (State CEQA Guidelines Sections 15064(h)(3 and 15064.4(b)).

The CEQA Guidelines do not require or recommend a specific analytical methodology or provide quantitative criteria for determining the significance of GHG emissions, nor do they set a numerical threshold of significance for GHG emissions. Section 15064.7(c) clarifies that “when adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” 8 - Climate Change
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When GHG emissions are found to be significant, State CEQA Guidelines Section 15126.4(c) includes the following direction on measures to mitigate GHG emissions:

Consistent with Section 15126.4(a), lead agencies shall consider feasible means, supported by substantial evidence and subject to monitoring or reporting, of mitigating the significant effects of greenhouse gas emissions. Measures to mitigate the significant effects of greenhouse gas emissions may include, among others:
(1) Measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision; (2) Reductions in emissions resulting from a project through implementation of project features, project design, or other measures;
(3) Off-site measures, including offsets that are not otherwise required, to mitigate a project’s emissions;
(4) Measures that sequester greenhouse gases; and
(5) In the case of the adoption of a plan, such as a general plan, long range development plan, or plans for the reduction of greenhouse gas emissions, mitigation may include the identification of specific measures that may be implemented on a project-by project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions.

MANDATORY REPORTING REQUIREMENTS
Pursuant to CCR Title 17, Sections 95100–95158, operations of large industrial stationary combustion and process emissions sources that emit 10,000 MTCO2e or more per calendar year are required to report and verify their GHG emissions to the California Air Resource Board (CARB). Entities that emit more than the 25,000 MTCO2e per year threshold are required to have their GHG emission report verified by a CARBaccredited third party. Certain sectors are required to report regardless of emission levels, such as refineries and cement plants.

STATE OF CALIFORNIA EXECUTIVE ORDERS
EXECUTIVE ORDER S-3-05
In 2005, in recognition of California’s vulnerability to the effects of climate change, Governor Arnold Schwarzenegger issued Executive Order S-3-05, which set forth a series of target dates by which statewide emissions of GHGs would be progressively reduced, as follows:
 By 2010, reduce GHG emissions to 2000 levels;
 By 2020, reduce GHG emissions to 1990 levels; and
 By 2050, reduce GHG emissions to 80 percent below 1990 levels. 8 - Climate Change
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EXECUTIVE ORDER S-1-07
Executive Order S-1-07, which was signed by Governor Schwarzenegger in 2007, proclaims that the transportation sector is the main source of GHG emissions in California, generating more than 40 percent of statewide emissions. It established a low carbon fuel standard with a goal to reduce the carbon intensity of transportation fuels sold in California by at least 10 percent by 2020.

In September 2018, CARB extended the low carbon fuel standard program to 2030, making significant changes to the design and implementation of the Program including a doubling of the carbon intensity reduction to 20 percent by 2030.

EXECUTIVE ORDER S-13-08
Governor Schwarzenegger signed EO S-13-08 on November 14, 2008. The order called on State agencies to develop California’s first strategy to identify and prepare for expected climate impacts. As a result, the 2009 California Climate Adaptation Strategy report was developed to summarize the best-known science on climate change impacts in the State to assess vulnerability and outline possible solutions that can be implemented within and across State agencies to promote resiliency. The State’s fourth major assessment on climate change explores local and statewide vulnerabilities to climate change, highlighting opportunities for taking concrete actions to build climatechange resiliency.

EXECUTIVE ORDER B-16-12
In March 2012, Governor Jerry Brown issued an executive order establishing a goal of

1.5 million zero emission vehicles (ZEVs) on California roads by 2025. In addition to the ZEV goal, EO B-16-12 stipulated that by 2015 all major cities in California will have adequate infrastructure and be ‘zero-emission vehicle ready’; that by 2020 the State will have established adequate infrastructure to support 1 million ZEVs; that by 2050, virtually all personal transportation in the State will be based on ZEVs, and that GHG emissions from the transportation sector will be reduced by 80 percent below 1990 levels.

EXECUTIVE ORDER B-30-15
Governor Brown signed EO-B-30-15 on April 29, 2015, directed the following:
 Established a new interim statewide reduction target to reduce GHG emissions to 40 percent below 1990 levels by 2030.
 Ordered all State agencies with jurisdiction over sources of GHG emissions to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 reduction targets.
 Directed CARB to update the Climate Change Scoping Plan to express the 2030 target in terms of MMTCO2e.

EXECUTIVE ORDER B-55-18
On September 10, 2018, Governor Brown signed EO B-55-18, committing California to total, economy-wide carbon neutrality by 2045. EO B-55-18 directs CARB to work with 8 - Climate Change
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relevant State agencies to develop a framework to implement and accounting that tracks progress toward this goal.

STATE OF CALIFORNIA POLICY AND LEGISLATION

CALIFORNIA ENVIRONMENTAL QUALITY ACT AND CLIMATE CHANGE Under CEQA lead agencies are required to disclose the reasonably foreseeable adverse environmental effects of projects they are considering for approval. GHG emissions have the potential to adversely affect the environment because they contribute to global climate change. In turn, global climate change has the potential to raise sea levels, alter rainfall and snowfall, and affect habitat.

SENATE BILL 97
Senate Bill (SB) 97, signed in August 2007, acknowledges that climate change is a prominent environmental issue requiring analysis under CEQA. This bill directed the OPR to prepare, develop, and transmit to the California Natural Resources Agency guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, no later than July 1, 2009. The California Natural Resources Agency was required to certify or adopt those guidelines by January 1, 2010.

On December 30, 2009, the Natural Resources Agency adopted amendments to the State CEQA Guidelines, as required by SB 97. These State CEQA Guidelines amendments provide guidance to public agencies regarding the analysis and mitigation of the effects of GHG emissions in draft CEQA documents. The amendments became effective March 18, 2010.

STATE CEQA GUIDELINES
The State CEQA Guidelines are embodied in the CCR, Public Resources Code, Division 13, starting with Section 21000. The CEQA Guidelines were amended in 2018 by the Natural Resources Agency. State CEQA Guidelines section 15064.4 specifically addresses the significance of GHG emissions, requiring a lead agency to make a “goodfaith effort” to “describe, calculate or estimate” GHG emissions in CEQA environmental documents. Section 15064.4 states that the GHG analysis should focus on the “reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change” which may be cumulatively considerable even if emissions are small relative to statewide, national, or global emission levels, and that the analysis should consider “a timeframe that is appropriate for the project” using “evolving scientific knowledge and state regulatory schemes.” Section 15064.4 further states that the analysis of GHG impacts should include consideration of (1) the extent to which the project may increase or reduce GHG emissions, (2) whether the project emissions would exceed a locally applicable threshold of significance, and (3) the extent to which the project would comply with “regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.” The CEQA Guidelines also state that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program (including plans or 8 - Climate Change
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regulations for the reduction of greenhouse gas emissions) that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area in which the project is located (State CEQA Guidelines section 15064(b)(3)). In addition, the recent revisions to the CEQA Guidelines state that significance determinations can be made based on statewide targets: “In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is not cumulatively considerable.” The State CEQA Guidelines do not, however, set a numerical threshold of significance for GHG emissions.

The CEQA Guidelines also include the following direction on measures to mitigate GHG emissions, when such emissions are found to be significant:

Consistent with Section 15126.4(a), lead agencies shall consider feasible means, supported by substantial evidence and subject to monitoring or reporting, of mitigating the significant effects of greenhouse gas emissions. Measures to mitigate the significant effects of greenhouse gas emissions may include, among others:
(1) Measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision; (2) Reductions in emissions resulting from a project through implementation of project features, project design, or other measures;
(3) Off-site measures, including offsets that are not otherwise required, to mitigate a project’s emissions;
(4) Measures that sequester greenhouse gases; and
(5) In the case of the adoption of a plan, such as a general plan, long range development plan, or plans for the reduction of greenhouse gas emissions, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions. (State CEQA Guidelines section 15126.4(a).)
SENATE BILL 350
SB 350 (Clean Energy and Pollution Reduction Act of 2015) was signed into law on October 7, 2015, establishing new goals for clean energy, clean air, and GHG reduction goals for 2030 and beyond. SB 350 requires the following:
 Increase California’s renewable electricity procurement goal under the Renewable Portfolio Standard (RPS) from 33 percent by 2020 to 50 percent by 2030,
 Double the energy efficiency of existing buildings by 2030; and 8 - Climate Change
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 Facilitate the growth of renewable energy markets within the western U.S. by reorganizing the California Independent System Operator.

SENATE BILL 100
On September 10, 2018, Governor Brown signed SB 100, establishing that 100 percent of all electricity in California must be obtained from renewable and zero-carbon energy resources by December 31, 2045. SB 100 also creates new standards for the RPS goals established by SB 350 in 2015. Specifically, the bill increases required energy from renewable sources for both investor-owned utilities and publicly-owned utilities from 50 percent to 60 percent by 2030. Incrementally, these energy providers must also have a renewable energy supply of 33 percent by 2020, 44 percent by 2024, and 52 percent by 2027. The updated RPS goals are considered achievable, since many California energy providers are already meeting or exceeding the RPS goals established by SB 350.

SENATE BILL 1020
SB 1020, signed on September 16, 2022, revises SB 100 to require that renewable energy resources and zero-carbon resources supply 90 percent of all retail sales of electricity to end-use customers by December 31, 2035; 95 percent of all retail sales to end users by December 31, 2040; 100 percent of all retail sales to end users by December 31, 2045; and 100 percent of electricity procured to serve all state agencies by December 31, 2035.

ASSEMBLY BILL 1493
In 2002, Governor Gray Davis signed Assembly Bill (AB) 1493. AB 1493 requires that CARB develop and adopt, by January 1, 2005, regulations that achieve “the maximum feasible reduction of greenhouse gases emitted by passenger vehicles and light-duty trucks and other vehicles determined by CARB to be vehicles whose primary use is noncommercial personal transportation in the State.”
To meet the requirements of AB 1493, in 2004 CARB approved amendments to the California Code of Regulations, adding GHG emissions standards to California’s existing standards for motor vehicle emissions. All mobile sources are required to comply with these regulations as they are phased in from 2009 through 2016.

Because the Pavley standards (named for the bill’s author, State Senator Fran Pavley) would impose stricter standards than those under the Clean Air Act (CAA), California applied to the USEPA for a waiver under the CAA. In 2008, the USEPA denied the application. In 2009, however, the USEPA granted the waiver. The waiver has been extended consistently since 2009; however, in 2019, the USEPA and NHTSA revoked California’s waiver and prohibit future State emissions standards enacted under the CAA. The status of the federal government’s revocation of the waiver is uncertain and because the outcome of pending litigation is speculative, this analysis uses the best available information at this time, as set forth in CARB’s Emission Factor Database (EMFAC).
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ASSEMBLY BILL 32 AND THE GLOBAL WARMING SOLUTIONS ACT OF 2006 In 2006, the California Legislature passed AB 32 (California Health and Safety Code Section 38500 et seq.), also known as the Global Warming Solutions Act. AB 32 required CARB to design and implement feasible and cost-effective emissions limits, regulations, and other measures, such that statewide GHG emissions are reduced to 1990 levels by 2020 (representing a 25 percent reduction in emissions). The legislature anticipated that AB 32 GHG reduction goals will be met, in part, through local government actions. CARB identified a GHG reduction target of 15 percent from current levels for local governments (municipal and community-wide) and noted that successful implementation of the plan relies on local governments’ land use planning and urban growth decisions because local governments have the primary authority to plan, zone, approve, and permit land development to accommodate population growth and the changing needs of their jurisdictions.

SENATE BILL 32 AND ASSEMBLY BILL 197
Signed into law on September 8, 2016, SB 32 (Amendments to California Global Warming Solutions Act of 2006: Emission Limit) amended Health and Safety Code Division 25.5 and codifies the 2030 target in Executive Order B-30-15 (40 percent below 1990 levels by 2030). The 2030 target is intended to ensure that California remains on track to achieve the goal set forth by Executive Order B-30-15 to reduce statewide GHG emissions by 2050 to 80 percent below 1990 levels. SB 32 stated the intent of the legislature to continue to reduce GHGs for the protection of all areas of the state and especially the state’s most disadvantaged communities, which are disproportionately affected by the deleterious effects of climate change on public health. The law amended Health and Safety Code Division 25.5 and established a new climate pollution reduction target of 40 percent below 1990 levels by 2030, while AB 197 includes provisions to ensure that the benefits of state climate policies include disadvantaged communities.

ASSEMBLY BILL 1279
The California Climate Crisis Act, otherwise known as AB 1279, was enacted on September 16, 2022. AB 1279 establishes the policy of the State of California to achieve net zero GHG emissions as soon as possible but no later than 2045, and to achieve and maintain net negative GHG emissions thereafter. Additionally, AB 1279 mandates that by 2045, statewide anthropogenic GHG emissions are to be reduced at least 85 percent below 1990 levels. AB 1279 also requires CARB to ensure that the Scoping Plan identifies and recommends measures to achieve carbon neutrality, and to identify and implement policies and strategies for CO2 removal solutions and carbon capture, utilization, and storage technologies. It also requires CARB to submit an annual report on progress in achieving the Scoping Plan’s goals.

THE CALIFORNIA CLIMATE CHANGE SCOPING PLAN
Pursuant to AB 32, CARB adopted the Climate Change Scoping Plan (Scoping Plan) in December 2008 (CARB 2008) (re-approved by CARB on August 24, 2011). The Scoping Plan must be updated at least every 5 years. The First Update to the Climate Change Scoping Plan described progress made to meet near-term emissions goals of AB 32, defined California’s climate change priorities and activities for the next few years 8 - Climate Change
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and described the issues facing the State of California as it establishes a framework for achieving air quality and climate goals beyond the year 2020. On December 14, 2017, CARB approved the final version of California’s 2017 Climate Change Scoping Plan, which outlines the proposed framework of action for achieving the 2030 target of reducing GHG emissions by 40 percent relative to 1990 levels (CARB 2017). The 2017 Scoping Plan acknowledged the importance of local government actions in GHG planning and provided information to support those efforts.

The 2022 Climate Change Scoping Plan for Carbon Neutrality (2022 Scoping Plan) was adopted on December 15, 2022. It assesses progress toward achieving the SB 32 target of 40 percent below 1990 levels by 2030 and lays out the path to achieve carbon neutrality and reduce GHG emissions by 85 percent below 1990 levels by 2045, as directed by AB 1279 (CARB 2022). Among other things, the plan’s actions and outcomes are intended to achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon.

SENATE BILL 375
Signed into law on October 1, 2008, SB 375 supplements GHG reductions from new vehicle technology and fuel standards with reductions from more efficient land use patterns and improved transportation. Under the law, CARB approved GHG reduction targets in February 2011 for California’s 18 federally designated regional planning bodies, known as Metropolitan Planning Organizations. CARB may update the targets every four years and must update them every eight years. Metropolitan Planning Organizations in turn must demonstrate how their plans, policies and transportation investments meet the targets set by CARB through Sustainable Communities Strategy.

SENATE BILL 743
In 2013, Governor Brown signed SB 743, which added Public Resources Code Section 21099 to CEQA, to change the way that transportation impacts are analyzed in transit priority areas under CEQA to better align local environmental review with statewide objectives to reduce GHG emissions, encourage infill mixed-use development in designated priority development areas, reduce regional sprawl development, and reduce vehicle miles traveled (VMT) in California.

As required under SB 743, OPR developed potential metrics to measure transportation impacts that may include, but are not limited to, VMT, VMT per capita, automobile trip generation rates, or automobile trips generated. The new VMT metric is intended to replace the use of automobile delay and level of service (LOS) as the metric to analyze transportation impacts under CEQA. In its 2018 Technical Advisory on Evaluating Transportation Impacts in CEQA, OPR recommends different thresholds of significance for projects depending on land use types. For example, residential and office space projects must demonstrate a VMT level that is 15 percent less than that of existing development to determine whether the mobile-source GHG emissions associated with the project are consistent with statewide GHG reduction targets. With respect to retail 8 - Climate Change
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land uses, any net increase of VMT may be sufficient to indicate a significant transportation impact (OPR 2018).

ADVANCED CLEAN CARS PROGRAM
In January 2012, pursuant to Recommended Measures T-1 and T-4 of the Scoping Plan, CARB approved the Advanced Clean Cars Program, an emissions-control program for model year 2017 through 2025. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero-emission vehicles. By 2025, when the rules will be fully implemented, the new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smog-forming emissions. The program also requires car manufacturers to offer for sale an increasing number of ZEVs each year, including battery electric, fuel cell, and plug-in hybrid electric vehicles.

ADVANCED CLEAN CARS II
In 2022, CARB approved the Advanced Clean Cars II Program for model years 2026– 2035, which requires that all new passenger cars, trucks, and SUVs sold in California be zero emissions by 2035 (CARB 2023a). The regulation amends the ZEV Regulation to require an increasing number of ZEVs, and relies on advanced vehicle technologies, including battery-electric, hydrogen fuel cell electric, and plug-in hybrid electric-vehicles, to meet air quality and climate change emissions standards, in support of Executive Order N-79-20 (CARB 2023a). This program also amended the Low-Emission Vehicle Regulations to include increasingly stringent standards for gasoline cars and heavier passenger trucks to continue to reduce smog-forming emissions.

ADVANCED CLEAN TRUCKS
On June 25, 2020, the air board adopted the Advanced Clean Trucks rule, which requires truck manufacturers to transition from diesel vehicles to electric zero-emissions vehicles beginning in 2024, with the goal of reaching 100 percent zero-emissions vehicles by 2045 (CARB 2020). The goal of the legislation is to help California meet its climate targets of a 40 percent reduction in GHG emissions and a 50 percent reduction in petroleum use by 2030, and an 80 percent reduction in GHG emissions by 2050.

Truck manufacturers will be required to sell zero-emissions vehicles as an increasing percentage of their annual sales from 2024 through 2035. Companies with large distribution fleets (50 or more trucks) will be required to report information about their existing fleet operations in an effort to identify future strategies for increasing zeroemissions fleets statewide (CARB 2021).

ADVANCED CLEAN FLEETS
On September 29, 2023, the Office of Administrative Law approved CARB’s Advanced Clean Fleets rule, which became state law on October 1, 2023. This regulation is part of CARB's broader strategy to accelerate the transition to zero-emissions medium- and heavy-duty vehicles. It complements the Advanced Clean Trucks regulation, focusing on reducing emissions and promoting zero-emissions vehicle adoption. The Advanced Clean Fleets regulation covers various fleet types, including drayage operations, government-owned fleets, and high-priority fleets, mandating ZEV adoption in phases.

Key provisions include manufacturer sales mandates, requirements for drayage fleets to 8 - Climate Change
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transition to ZEVs, and specific ZEV targets for high-priority and government fleets. The Advanced Clean Fleets regulation requires that manufacturers may sell only zeroemissions medium- and heavy-duty vehicles in California starting in 2036 and that highpriority fleets must purchase only ZEVs beginning 2024 and, starting January 1, 2025, must remove internal combustion engine vehicles at the end of their useful life, or that high-priority fleets must achieve 100 percent ZEVs by 2042 (CARB 2023b). The regulation is expected to significantly reduce emissions, benefit public health, and contribute to achieving climate goals.

SUSTAINABLE FREIGHT ACTION PLAN
Executive Order B-32-15 directed the State to establish targets to improve freight efficiency, transition to zero emission technologies, and increase the competitiveness of California’s freight transport system. The targets are not mandates, but rather aspirational measures of progress towards sustainability for the State to meet and try to exceed. The targets include:
 System Efficiency Target: Improve freight system efficiency by 25 percent by increasing the value of goods and services produced from the freight sector, relative to the amount of carbon that it produces by 2030.  Transition to Zero Emission Technology Target: Deploy over 100,000 freight vehicles and equipment capable of zero emission operation and maximize near-zero emission freight vehicles and equipment powered by renewable energy by 2030.  Increased Competitiveness and Economic Growth Targets: Establish a target or targets for increased State competitiveness and future economic growth within the freight and goods movement industry based on a suite of commonsense economic competitiveness and growth metrics and models developed by a working group comprised of economists, experts, and industry. These targets and tools will support flexibility, efficiency, investment, and best business practices through State policies and programs that create a positive environment for growing freight volumes and jobs, while working with industry to mitigate potential negative economic impacts. The targets and tools will also help evaluate the strategies proposed under the Action Plan to ensure consideration of the impacts of actions on economic growth and competitiveness throughout the development and implementation process.

CALIFORNIA TRANSPORTATION PLAN 2040
The California Transportation Plan 2040 provides a long-range policy framework to meet future mobility needs and reduce GHG emissions. The plan defines goals, performance-based policies, and strategies to achieve maximum feasible emission reductions in order to attain a statewide reduction in GHG emissions.

The California Transportation Plan 2040 recognizes that the Governor is committed to reduce by one-half current petroleum use in cars and trucks; increase from one-third to one-half the electricity derived from renewable sources; double the efficiency savings of existing buildings and make heating fuels cleaner; reduce the release of methane, black 8 - Climate Change
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carbon, and other short-lived climate pollutants; and manage farm and rangelands, forests, and wetlands to store more carbon.

Transportation GHG reduction strategies within the plan include demand management (including telecommuting/working at home, increased carpoolers, and increase car sharing), mode shift (including transit service improvements, high-speed rail, bus rapid transit, expanded bike and pedestrian facilities, carpool land occupancy requirements, and increased high occupancy vehicle lanes), travel cost (implement expanded pricing policies), and operational efficiency (incident/emergency management, Caltrans’ Master Plan, intelligent transportation system/transportation systems management [TSM]strategies and programs, and eco-driving).

RENEWABLE ELECTRICITY STANDARDS
SB 1078 (Chapter 516, Statutes of 2002) requires retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. SB 107 (Chapter 464, Statutes of 2006) changed the target date to 2010. In November 2008, Governor Schwarzenegger signed Executive Order S-14-08, which expanded the state’s Renewable Portfolio Standard to 33 percent renewable power by 2020. In September 2009, Governor Schwarzenegger continued California’s commitment to the Renewable Portfolio Standard by signing Executive Order S-21-09, which directed the CARB under its AB 32 authority to enact regulations to help the state meet its Renewable Portfolio Standard goal of 33 percent renewable energy by 2020.

The 33 percent by 2020 RPS goal was codified in April 2011 with SB X1-2. This Renewable Portfolio Standard preempted the CARB 33 percent Renewable Electricity Standard and applies to all electricity retailers in the state, including publicly owned utilities, investor-owned utilities, electricity service providers, and community choice aggregators. SB 350 was signed in October 2015, and requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from eligible renewable energy resources by 2030. Most recently, SB 100, signed by Governor Brown on September 10, 2018, increases the standard requirement to 60 percent eligible renewables by 2030 and 100 percent by 2045.

CALIFORNIA INTEGRATED WASTE MANAGEMENT ACT AND CALIFORNIA ASSEMBLY BILL 341 The legislature passed the California Integrated Waste Management Act of 1989 (AB 939) in 1990, requiring all cities and counties to divert 50 percent of all solid waste from landfill facilities by January 1, 2000. In order of priority, waste reduction efforts must promote source reduction, recycling and composting, and environmentally safe transformation and land disposal. AB 341 (Public Resources Code Division 30, Part 3, Chapter 12.8), which became law in 2011, established a new statewide goal of 75 percent diversion by 2020, and changed the way that the state measures progress toward the 75 percent goal, focusing on source reduction, recycling, and composting.

AB 341 also requires all businesses and public entities that generate 4 cubic yards or more of waste per week to have a recycling program in place. The objective of the law is to reduce GHG emissions by diverting commercial solid waste into recycling programs and expand the opportunity for additional recycling services and recycling 8 - Climate Change
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manufacturing facilities in California. Although AB 341 established a statewide recycling goal of 75 percent, the 50 percent disposal reduction mandate still applies for cities and counties under AB 939.

TITLE 24 – CALIFORNIA ENERGY EFFICIENCY STANDARDS
Energy consumption for new residential and nonresidential buildings is regulated by CCR Title 24, Part 6, California Energy Efficiency Standards (California Energy Code), which was established in 1978 in response to a legislative mandate to reduce energy consumption in the State. Although not originally intended to reduce GHG emissions, increased energy efficiency and reduced consumption of electricity, natural gas, and other fuels would result in fewer GHG emissions from residential and nonresidential buildings subject to the standard. The standards are updated periodically (typically every three years) to allow for the consideration and inclusion of new energy efficiency technologies and methods (CEC 2015). The current standards became effective on January 1, 2023.

TITLE 24 – CALIFORNIA GREEN BUILDING STANDARDS CODE
Part 11 of CCR Title 24 California Building Standards Code is referred to as the California Green Building Standards (CALGreen) Code, which established new sustainable building standards for all buildings in California. The code covers five categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and indoor environmental quality. These standards include a mandatory set of minimum guidelines, as well as more rigorous voluntary measures, for new construction projects to achieve specific green building performance levels. This code went into effect as part of local jurisdictions’ building codes on January 1, 2011, and was most recently updated as the 2022 California Green Building Standards Code, which became effective January 1, 2023 (CBSC 2023). As discussed below, CALGreen includes several residential and nonresidential electric vehicle charging requirements and recommendations.

For new hotels, motels, and multi-family dwellings with 20 or more units, the 2022 CALGreen Code mandates that 10 percent of parking spaces must be EV Capable,2 25 percent must be EV Ready,3 and 5 percent must have electric vehicle supply equipment (EVSE)4(40 percent total). Residential electric vehicle voluntary measures include Tier 1 and Tier 2 measures. Tier 1 requires 35 percent of parking spaces to be EV Ready and 10 percent must have EVSE (45 percent total). Tier 2 requires

2 A vehicle space with electrical panel space and load capacity to support a branch circuit and necessary raceways, both underground and/or surface mounted, to support EV charging. 3 A vehicle space which is provided with a branch circuit; any necessary raceways, both underground and/or surface mounted; to accommodate EV charging, terminating in a receptacle or charger. 4 The conductors, including the undergrounded, grounded and equipment grounding conductors and the electric vehicle connectors, attachment plugs, and all other fittings, devices, power outlets or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle.
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40 percent of parking spaces to be EV Ready and 15 percent must have EVSE (55 percent total).

For new hotels, motels, and multi-family dwellings with less than 20 units, the 2022 CALGreen Code mandates that 10 percent of parking spaces must be EV Capable and 25 percent must be EV Ready. Tier 1 requires 35 percent of parking spaces to be EV Ready. Tier 2 requires 40 percent of parking spaces must be EV Ready.

For new non-residential development, 15 percent of the total number of parking spaces are required to be EV capable spaces and 5 percent are required to have EVSE (20 percent total). There are also Tier 1 and Tier 2 nonresidential electric vehicle charging voluntary measures. For Tier 1, 20 percent of the total number of parking spaces are required to be EV capable spaces and 10 percent are required to have EVSE (30 percent total). For Tier 2, 30 percent of the total number of parking spaces are required to be EV capable spaces and 15 percent are required to have EVSE (45 percent total).

LOCAL

SACRAMENTO COUNTY GENERAL PLAN
The following goals and policies from the Air Quality, Circulation, Energy, and Land Use elements of the Sacramento County 2030 General Plan are applicable to the proposed UWSP.

AIR QUALITY
AQ-1 New development shall be designed to promote pedestrian/bicycle access and circulation to encourage community residents to use alternative modes of transportation to conserve air quality and minimize direct and indirect emission of air contaminants.

AQ-2 Support Regional Transit’s efforts to secure adequate funding so that transit is a viable transportation alternative. Development shall pay its fair share of the cost of transit facilities required to serve the project.

AQ-4 Developments which meet or exceed thresholds of significance for ozone precursor pollutants, and/or Greenhouse Gases (GHG) as adopted by the Sacramento Metropolitan Air Quality Management District (SMAQMD), shall be deemed to have a significant environmental impact. An Air Quality Mitigation Plan and/or a Greenhouse Gas Reduction Plan shall be submitted to the County of Sacramento prior to project approval, subject to review and recommendation as to technical adequacy by the Sacramento Metropolitan Air Quality Management District.

AQ-5 Reduce emissions associated with vehicle miles travelled and evaporation by reducing the surface area dedicated to parking facilities; reduce vehicle emissions associated with “hunting” for on-street parking by implementing innovative parking solutions including shared parking, elimination of minimum 8 - Climate Change
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parking requirements, creation of maximum parking requirements, and utilize performance pricing for publicly owned parking spaces both on- and offstreet, as well as creating parking benefit districts.

AQ-6 Provide incentives for the use of transportation alternatives, including a program for the provision of financial incentives for builders that construct ownership housing within a quarter mile of existing and proposed light rail stations.

AQ-8 Promote mixed-use development and provide for increased development intensity along existing and proposed transit corridors to reduce the length and frequency of vehicle trips.

AQ-10 Encourage vehicle trip reduction and improved air quality by requiring development projects that exceed the SMAQMD’s significance thresholds for operational emissions to provide on-going, cost-effective mechanisms for transportation services that help reduce the demand for existing roadway infrastructure.

AQ-11 Encourage contractors operating in the county to procure and to operate lowemission vehicles, and to seek low emission fleet status for their off-road equipment.

AQ-13 Use California State Air Resources Board (CARB) and SMAQMD guidelines for Sacramento County facilities and operations to comply with mandated measures to reduce emissions from fuel consumption, energy consumption, surface coating operations, and solvent usage.

AQ-16 Prohibit the idling of on-and off-road engines when the vehicle is not moving or when the off-road equipment is not performing work for a period of time greater than five minutes in any one-hour period.

AQ-17 Promote optimal air quality benefits through energy conservation measures in new development.

AQ-19 Require all feasible reductions in emissions for the operation of construction vehicles and equipment on major land development and roadway construction projects.

AQ-20 Promote Cool Community strategies to cool the urban heat island, reduce energy use and ozone formation, and maximize air quality benefits by encouraging four main strategies including, but not limited to: plant trees, selective use of vegetation for landscaping, install cool roofing, and install cool pavements.

AQ-22 Reduce greenhouse gas emissions from County operations as well as private development.
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CIRCULATION
CI-40 Whenever possible, the applicant/developer of new and infill development projects shall be conditioned to fund, implement, operate and/or participate in TSM programs to manage travel demand associated with the project.

CI-41 Consider TSM programs that increase the average occupancy of vehicles and divert automobile commute trips to transit, walking, and bicycling.

CI-43 The County shall promote transit-supportive programs in new development, including employer-based trip-reduction programs (employer incentives to use transit or non-motorized modes), “guaranteed ride home” for commute trips, and car-share or bike-share programs.

CI-67 When feasible, incorporate lighter colored (higher albedo) materials and surfaces, such as lighter-colored pavements, and encourage the creation of tree canopy to reduce the built environment’s absorption of heat to reduce the urban “heat island” effect.

ENERGY
EN-5 Reduce travel distances and reliance on the automobile and facilitate increased use of public transit through appropriate land use plans and regulations.

LAND USE
LU-27 Provide safe, interesting and convenient environments for pedestrians and bicyclists, including inviting and adequately lit streetscapes, networks of trails, paths and parks and open spaces located near residences, to encourage regular exercise and reduce vehicular emissions.

LU-37 Provide and support development of pedestrian and bicycle connections between transit stations and nearby residential, commercial, employment or civic uses by eliminating physical barriers and providing linking facilities, such as pedestrian overcrossings, trails, wide sidewalks and safe street crossings.

LU-40 Employ appropriate traffic calming measures in areas where pedestrian travel is desirable but made unsafe by a high volume or excessive speed of automobile traffic. Preference shall be given to measures that slow traffic and improve pedestrian safety while creating the least amount of conflict with emergency responders.

LU-42 Master planning efforts for new growth areas shall provide for separated sidewalks along all arterials and thoroughfares to make walking a safer and more attractive transportation option.

LU-115 It is the goal of the County to reduce greenhouse gas emissions to 1990 levels by the year 2020. This shall be achieved through a mix of State and local action.
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SACRAMENTO AREA COUNCIL OF GOVERNMENTS
The Sacramento Area Council of Governments (SACOG) is the metropolitan planning organization for the Sacramento region, including the UWSP area. One of the main responsibilities of SACOG is to maintain and develop comprehensive transportation planning for the region through transportation planning documents intended to improve future transportation networks and options for residents. SB 375, described above, requires metropolitan planning organizations to develop a Sustainable Communities Strategy (SCS) as part of their planning activities, which identifies policies and strategies to reduce GHG emissions from passenger vehicles to targets sets by the CARB.

In 2019, SACOG adopted the 2020 Metropolitan Transportation Plan (MTP)/SCS, which became the long-range transportation plan for the region. The MTP/SCS is a comprehensive blueprint that prioritizes sustainability and integrated planning. The focus is developing a well- connected transportation network, emphasizing public transit, active transportation, and reduced reliance on private vehicles, all while fostering transit-friendly, walkable communities. This plan aims to reduce GHG emissions, improve air quality, and enhance overall quality of life by aligning land-use and transportation strategies, engaging the public, and complying with relevant regulations to create a more sustainable and livable region.

SACRAMENTO COUNTY CLIMATE ACTION PLAN
The Sacramento County Board of Supervisors adopted the Climate Action Plan – Strategy and Framework Document (Phase 1 CAP) on November 9, 2011. The Phase 1 CAP provides a framework and overall policy strategy for reducing GHG emissions and managing the County’s resources in order to comply with AB 32 (Sacramento County 2011b). The Phase 1 CAP includes a GHG inventory for the unincorporated areas of Sacramento County for 2005, a GHG emission reduction target, and goals and implementation measures developed to help the County reach these goals. Reduction strategies address GHG emissions associated with transportation and land use, energy, water, waste management and recycling, and agriculture and open space. The County’s primary goals related to transportation and energy use include the following:
 Increase the average fuel efficiency of County-owned vehicles powered by gasoline and diesel and encourage increased fuel efficiency in community vehicles;
 Increase the use of alternative and lower carbon fuels in the County-owned vehicle fleet and facilitate their use in the community;  Reduce total vehicle miles traveled per capita in the community and region;  Improve energy efficiency of existing and new buildings in the unincorporated county;
 Improve energy efficiency of operating County-owned infrastructure (roads, water, waste, buildings, etc.); and
 Decrease use of fossil fuels by transitioning to renewable energy sources. 8 - Climate Change
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On September 11, 2012, the Phase 2A CAP (Government Operations) was adopted by the County. Neither the Phase 1 CAP nor the Phase 2A CAP are “qualified” GHG reduction plans pursuant to CEQA Guidelines section 15183.5(b), through which subsequent projects may receive CEQA streamlining benefits.

In 2016, the County began preparing the communitywide CAP (Phase 2B CAP), but in late 2018, it was placed on hold pending in-depth review of CAP-related litigation in other jurisdictions. General Plan Policy LU-115 and associated Implementation Measures F through J of the General Plan Land Use Element identifies the County’s commitment to a Communitywide CAP. This commitment was made in part due to the County’s General Plan Update process and potential expansion of the Urban Policy Area to accommodate new growth areas. General Plan Policies LU-119 and LU-120 were developed with SACOG to be consistent with smart growth policies in the SACOG Blueprint, which are intended to reduce VMT and GHG emissions. In addition to reducing GHG emissions in Sacramento County, the CAP is intended to serve as a climate change resiliency plan to ensure that the County is prepared for the physical effects of climate change. The County released an updated GHG inventory for 2021 in 2023 (see Table CC-1 above) and a Climate Change Vulnerability Assessment in 2017, which identified extreme heat and increased flooding as the most likely adverse impacts to Sacramento County.

The Phase 2B CAP was re-initiated in early 2020. In March of 2021, the draft Phase 2B CAP was released by the County for public review. On September 7, 2021, a Final Draft CAP and Addendum to the 2030 General Plan EIR was released for public review. The County revised the CAP a second time and released the Revised Final Draft CAP and Revised Addendum to the 2030 General Plan EIR on February 17, 2022. These documents were presented at a Board of Supervisors workshop on March 23, 2022.

The County received more than 85 comment letters on the Revised Final Draft CAP leading up to the Board workshop on March 23, 2022. Based on input from the Board of Supervisors during the September 27, 2022, hearing on the CAP, County staff are reviewing the numerous comments received and preparing responses to those comments.

As a result, another revision to the CAP is expected prior to adoption of the CAP.

Based on the inventory and GHG reductions identified in the draft Phase 2B CAP, the County has set a goal of achieving a 4.0 MTCO2e per capita for 2030, resulting in an emissions limit of 3,674,904 MTCO2e (Sacramento County 2022). As allowed under CEQA Guidelines Section 15183(b), lead agencies may choose to analyze and mitigate significant GHG emissions in a plan for the reduction of GHG emissions or similar document. The CAP remains in draft form and has not been formally adopted by the County. As such, the CAP is not yet qualified for use in CEQA reviews.

SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT SMAQMD is the primary agency responsible for addressing air quality concerns in all of Sacramento County—its role is discussed further in Chapter 6, Air Quality. SMAQMD also recommends methods for analyzing project-generated GHGs in CEQA analyses and offers multiple potential GHG reduction measures for land use development projects.

SMAQMD developed thresholds of significance to provide a uniform scale to measure 8 - Climate Change
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the significance of GHG emissions from land use and stationary source projects in compliance with CEQA (SMAQMD 2021). SMAQMD’s goals in developing GHG thresholds include ease of implementation; use of standard analysis tools; and emissions mitigation consistent with the statewide GHG targets mandated by AB 32 of 2006.

According to the SMAQMD’s Guide to Air Quality Assessment in Sacramento County (CEQA GUIDE), GHG emissions generated during project construction that exceed 1,100 MTCO2e per year represent a cumulatively considerable contribution to a significant cumulative environmental impact (SMAQMD, 2021).

SMAQMD has published CEQA guidance for the evaluation of operational GHG emissions to provide lead agencies with a pathway to demonstrate that a project would not result in a cumulatively considerable contribution to global climate change. This guidance identifies operational measures that should be applied to a project to demonstrate consistency with statewide targets. The measures target GHG emissions sources from new development for which state policies and regulations do not achieve adequate reductions, requiring local supportive measures. These measures are known as Tier 1 and Tier 2 Best Management Practices (BMPs).

The Tier 1 BMPs are:
 BMP 1: Projects shall be designed and constructed without natural gas infrastructure.
 BMP 2: Projects shall meet the current CALGreen Tier 2 standards, except all EV capable spaces shall instead be EV ready.

EV capable means that the parking space is installed with a raceway and electrical panel capable of supporting an EV charging station. In addition to the raceway and panel, EV ready spaces have dedicated branch circuits, circuit breakers, and other electrical components to support future installation of charging stations, but do not include installation of the charger itself.

If Tier 1 BMPs are not fully implemented, then emissions, including natural gas emissions, should be estimated; on-site measures should be implemented to the maximum extent feasible; the project should have the capacity to be all-electric in the future; and BMP 2 requirements should be met.

If emissions exceed 1,100 MTCO2e per year after applying Tier 1 BMPs, then the project must implement SMAQMD’s Tier 2 BMP:
 BMP 3: Projects shall commit to reduce applicable project residential and office VMT by 15 percent compared to existing average residential and worker VMT per capita, respectively, and there shall be no increase in retail VMT.

In areas with above-average existing VMT, BMP 3 requires a commitment to provide electrical capacity for future 100 percent electric vehicles. 8 - Climate Change
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If the project would achieve BMP 3, then the operational emissions would not be cumulatively considerable, the impact would be less than significant, and no further analysis is needed.

IMPACTS AND ANALYSIS

SIGNIFICANCE CRITERIA
For purposes of this EIR and consistent with the criteria presented in Appendix G of the CEQA Guidelines, impacts on climate change may be considered significant if implementation of the proposed UWSP would:
 Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
 Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing emissions of GHGs.

CEQA Guidelines Section 15064.4 gives lead agencies the discretion to determine whether to assess GHG emissions quantitatively or qualitatively. The CEQA Guidelines do not establish a bright-line quantitative threshold of significance; rather, lead agencies are granted discretion to establish significance thresholds for their respective jurisdictions, including looking to thresholds developed by other public agencies, or suggested by other experts, such as the California Air Pollution Control Officers Association, so long as any threshold chosen is supported by substantial evidence (refer to CEQA Guidelines Section 15064.7(c)).

Sacramento County adopted SMAQMD’s thresholds of significance (summarized under the heading, “Sacramento Metropolitan Air Quality Management District,” above) on December 16, 2020, by Resolution #2020-0855. The SMAQMD GHG thresholds require that the project meet both Tier 1 and Tier 2 BMPs and implement additional BMPs to meet the VMT target established by SB 743 (summarized under the heading, “Senate Bill 743,” in the State of California Policy and Legislation discussion, above) for the impact to be identified as less than significant.

ISSUES NOT DISCUSSED IN IMPACTS
All potential issues related to climate change identified in the significance criteria above are evaluated below.

METHODOLOGY AND ASSUMPTIONS

EMISSION ESTIMATES
Project-related GHG emissions were evaluated in two categories: short-term emissions due to construction and long-term ongoing emissions due to operations. 8 - Climate Change
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The proposed UWSP would be built out over several phases across approximately 20 years in response to market-based demand for housing. Phase 1 is anticipated to be constructed over approximately seven years, but the construction schedule for the remaining phases would be based on market demand and is subject to economic fluctuations related to the housing market. Therefore, the timing of the subsequent phases is unknown. Nevertheless, in order to disclose the total Project GHG construction emissions, emissions associated with Phase 1 and the subsequent phases were estimated.

Additionally, the proposed UWSP would include offsite roadway and utility improvements that were not specifically quantified or included in the construction emissions estimates due to the lack of adequate detail in information about the improvements. However, as noted under the Construction Impacts heading in the Methodology and Assumptions discussion in Chapter 6, Air Quality, the construction emissions modeling conducted for Phase 1 and subsequent phases use very conservative assumptions, including a doubling of the amount of construction equipment relative to the California Emissions Estimator Model (CalEEMod) default equipment amounts for those phases. It is reasonable to conclude that the proposed offsite improvements would result in similar or less construction equipment activities as would be required for Phase 1 and the subsequent phases. Therefore, for the purposes of this analysis, the estimated emissions for Phase 1 and the subsequent phases are also presumed to represent emissions that would be associated with the proposed offsite improvements.

Operational emissions associated with the proposed UWSP were estimated for the year 2045 by determining the net change in emissions between existing conditions and the proposed UWSP scenario.

GHG emissions associated with construction and operation of the proposed UWSP were estimated using the CalEEMod, version 2020.4.0. CalEEMod is an approved emissions inventory software program that allows the user to estimate criteria pollutant and GHG emissions from land use development projects. Project-specific information was used for modeling, when possible (e.g., construction phases and regulations).

Where project-specific data are unavailable, CalEEMod default factors were used.

Additional details on GHG emissions modeling are presented in Appendix AQ-1.

EVALUATION OF EMISSIONS
As described in the Regulatory Setting above, the County’s 2012 CAP was adopted prior to the passing of SB 32 or AB 1279 and does not present a 2030 community GHG target based on the SB 32 statewide emissions reduction goal for 2030, nor does it address the state’s emissions reduction targets for 2045 pursuant to AB 1279.

Therefore, the County’s 2012 CAP is not used to determine the project’s GHG emissions impacts.

In the absence of a CEQA-qualified CAP for post-2020 projects, SMAQMD has developed and adopted thresholds of significance for GHG emissions during construction and operation of projects. The recommended SMAQMD significance 8 - Climate Change
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threshold for project construction is 1,100 MTCO2e per year. Should subsequent individual projects developed under the proposed UWSP's result in construction emissions that exceed 1,100 MTCO2e in any calendar year, there would be a potentially significant impact and mitigation measures would be required (SMAQMD 2021).

Regarding operational emissions, the SMAQMD identifies two quantitative bright-line thresholds of significance: 10,000 MTCO2e per year for stationary sources and 1,100 MTCO2e per year for land use projects (SMAQMD 2021). Land use projects which exceed 1,100 MTCO2e per year must implement SMAQMD Tier 1 BMPs. If a project’s GHG emissions are below 1,100 MTCO2e per year after implementation of the Tier 1 BMPs, the project’s contribution to the global climate change impact would be considered less than significant. Projects that do not implement the Tier 1 BMPs must conduct additional calculations to determine excess emissions and provide measures either on-site or off-site to provide equivalent mitigation. If a project’s GHG emissions are above 1,100 MTCO2e per year after implementation of the Tier 1 BMPs, then the project must implement the Tier 2 BMP. The Tier 1 and Tier 2 BMPs are listed below.

Tier 1 BMPs:
 BMP 1: Projects shall be designed and constructed without natural gas infrastructure.
 BMP 2: Projects shall meet the current CALGreen Tier 2 standards, except all EV capable spaces shall instead be EV ready.

Tier 2 BMP:
 BMP 3: Projects shall commit to reduce applicable project residential and office VMT by 15 percent compared to existing average residential and worker VMT per capita, respectively, and there shall be no increase in retail VMT.

For purposes of evaluating a project’s consistency with the 2045 statewide carbon neutrality target pursuant to AB 1279, a project would need to eliminate natural gas completely (BMP 1) or require all pre-wiring necessary so that the buildings are ready for a future retrofit to all-electric. Additionally, for a project located in an area with relatively high vehicle miles traveled per capita (resident and/or worker) the project would need to provide sufficient electrical capacity that 100 percent of project vehicles have the potential to be zero emission vehicles. Qualitatively, the project would be required to show that it is not otherwise impeding the 2045 statewide carbon neutrality goal. As such, the proposed UWSP was also evaluated for consistency with the 2022 Scoping Plan goal to achieve carbon neutrality and reduce GHG emissions by 85 percent below 1990 levels by 2045.

IMPACT CC-1: GHG EMISSIONS

CONSTRUCTION
Based on the methods described above, the unmitigated maximum annual GHG emissions for the proposed UWSP were estimated to be approximately 5,239 MTCO2e 8 - Climate Change
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per year during Phase 1 and 6,558 MTCO2e per year during the subsequent phases, as shown in Table CC-2. These maximum annual emissions would exceed the SMAQMD GHG significance threshold of 1,100 MTCO2e per year for construction emissions, and the impact would be potentially significant. However, as these annual construction emissions represent construction for all subsequent projects under the proposed UWSP in any given year, it is possible that individual subsequent projects could independently exceed the 1,100 MTCO2e per year threshold.

Table CC-2: Maximum Unmitigated Construction GHG emissions (MTCO2e per Year)
Construction
Project
Construction
GHG Emissions
SMAQMD
Annual GHG
Threshold
Exceeds
Threshold
(yes or no)?
Phase 1 Maximum Emissions 5,239 1,100 Yes
Subsequent Phases Maximum Emissions 6,558 1,100 Yes
SOURCE: Appendix AQ-1, Appendix A, CalEEMod Air Quality and Greenhouse Gas Modeling Results.

Mitigation Measure CC-1a, as detailed below, requires that each applicant of a subsequent project must demonstrate that their construction-related GHG emissions would be reduced to below 1,100 MTCO2e per year, and implement all feasible mitigation measures to reduce GHG emissions from construction to below 1,100 MTCO2e per year. Mitigation Measure CC-1a stipulates the requirements and a clear, quantitative performance standard (1,100 MTCO2e per year) for construction of subsequent development projects under the proposed UWSP and therefore does not defer mitigation (CEQA Guidelines, § 15370). Mitigation Measure CC-1a requires each project applicant(s) to meet this standard by committing to feasible project-specific emission reduction strategies and to purchase and retire GHG offset credits from a CARB-accredited carbon registry.

Mitigation measures may specify performance standards for mitigating a significant impact when it is impractical or infeasible to specify the specific details of mitigation during the EIR review process, provided the lead agency commits to implement the mitigation, adopts the specified performance standard, and identifies the types of actions that may achieve compliance with the performance standard (See Guidelines, § 15126.4, subd. (a)(1)(B). The County has the discretion to modify these mitigation measures with equally or more effective measures as technology improves in the future, as long as the measures do not change the project’s impacts (See Guidelines, § 15162, subd. (a)(3)).

As described in the Emissions Estimates discussion in the Methodology and Assumptions section, above, the estimated emissions for Phase 1 and the subsequent phases shown in Table CC-2 also represent emissions that would be associated with the proposed offsite improvements. The proposed UWSP would be responsible for 8 - Climate Change
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funding and implementing the proposed offsite improvements – the timing of which would be dependent upon traffic volume and utility use “triggers.” These offsite improvement activities would also be required to implement Mitigation Measure CC-1.

IMPACT DETERMINATION
As described above, construction of the proposed UWSP and subsequent development projects would exceed the SMAQMD GHG significance threshold of 1,100 MTCO2e per year. However, with implementation of Mitigation Measure CC-1a, this impact would be reduced to less than significant.

OPERATION
Operation of development allowed under the proposed UWSP would result in the longterm generation of GHG emissions from a variety of on-site emissions sources including natural gas combustion for space and water heating, indirect emissions from electricity consumption, landscape maintenance, and mobile on-road vehicle travel. Long-term emissions from energy-related sources would be minimized due to Title 24 compliance, compliance with the County’s Green Building standards, and implementation of the State’s RPS.

As discussed in the Methodology and Assumptions discussion above, SMAQMD has identified BMPs to reduce a project’s GHG emissions sources that are not adequately addressed by state measures, requiring project-level action that must be applied to a project to demonstrate consistency with the State’s 2030 GHG target pursuant to SB 32, the State’s 2050 carbon neutrality goal, and the CARB 2017 Scoping Plan. The proposed UWSP’s consistency with these Tier 1 and Tier 2 BMPs is described below.

For the comprehensive analysis regarding the project’s consistency with the 2022 Scoping Plan, see the Impact: Conflicts with an Applicable Plan, Policy, or Regulation discussion below.

BMP 1 (TIER 1)
The single-family residential components of the proposed UWSP would not include natural gas infrastructure and would therefore be consistent with BMP 1. However, this analysis assumes the high-density residential uses and non-residential components of the proposed UWSP would include natural gas infrastructure. Therefore, SMAQMD BMP 1 (projects shall be designed and constructed without natural gas infrastructure) would not be implemented by the proposed UWSP. Pursuant to SMAQMD guidance, additional GHG emissions from not implementing Tier 1 BMPs, including natural gas emissions, shall be estimated, and on-site or off-site measures providing equivalent reduction in GHG emissions should be implemented. Table CC-3 presents the unmitigated annual operational GHG emissions estimated for existing conditions, the proposed UWSP, and the net change.

GHG emissions from natural gas use in the non-residential components of the proposed UWSP were estimated to be approximately 5,996 MTCO2e per year at full buildout (see Appendix AQ-1). The proposed UWSP therefore must reduce GHG emissions by 5,996 MTCO2e per year to fully comply with BMP 1. Mitigation Measure CC-1b would 8 - Climate Change
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ensure that the proposed UWSP would achieve an equivalent reduction of GHG emissions and comply with BMP 1. As required by Mitigation Measure CC-1b, the applicant would be required to reduce GHG emissions associated with each phase of the proposed UWSP at a rate of 1.42 MTCO2e per year per thousand square feet of non-residential development (5,996 MTCO2e per year divided by the modeled total of 4,214 thousand square feet of non-residential development = 1.42 MTCO2e per year per thousand square foot of nonresidential development). Mitigation Measure CC-1b stipulates requirements and a clear, quantitative performance standard for operation of future nonresidential development projects under the proposed UWSP and therefore does not defer mitigation (CEQA Guidelines, § 15370). Mitigation Measure CC-1b requires the project applicant to meet this standard through project features and projectspecific emission reduction strategies, along with GHG offset credits purchased through a CARB-accredited carbon registry if necessary.

Table CC-3: Unmitigated Operational GHG emissions (MTCO2e per Year) Source Existing Conditions Proposed UWSP Net Change
Area 0.35 161.62 161.27
Energy 700.21 8,937.851 8,237.64
Mobile 1,395.13 54,632.27 53,237.14
Waste 245.26 6,392.06 6,146.80
Water 27.91 649.98 622.07
Total 2,368.85 70,773.78 68,404.93
NOTES:
1 Proposed UWSP CO2e energy emissions have been adjusted using off-model calculations to account for the project not including natural gas hook-ups for single-family residential land uses. Emissions also factor in the extra electricity that would be required for heating, etc., by converting single-family residential natural gas usage (BTU) to electricity usage (kWh) to estimate CO2e using the CO2e/kWh emission factor.

SOURCE: Appendix AQ-1, Table 16, ESA 2024.

BMP 2 (TIER 1)
Per the requirement of SMAQMD BMP 2, projects shall meet the current CALGreen Tier 2 voluntary standards, except all EV capable spaces (i.e., capable of supporting future EVSE) shall instead be EV ready (i.e., EVSE installed). The proposed UWSP would require the following: garages for single-family units provide appropriately sized electric outlets to allow convenient recharging of electric vehicles; all multi-family attached projects have electric outlets to allow for overnight EV recharging for a minimum of 50 percent of the parking spaces; and all development include EV charging infrastructure consistent with CALGreen Tier 2 standards in effect at the time. The proposed UWSP does not specifically commit to having all EV spaces being EV ready (i.e., EVSE installed). Therefore, the proposed UWSP would not be consistent with SMAQMD BMP 2. With implementation of Mitigation Measure CC-1c, all EV capable 8 - Climate Change
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parking spaces provided at the ratio required by CALGreen Tier 2 would be required to be equipped as EV Ready spaces to ensure compliance with SMAQMD BMP 2.

With implementation of Tier 1 BMPs or equivalent reductions through mitigation measures CC-1b and CC-1c, the annual operational emissions would be reduced by 5,996 MTCO2e per year, but the residual emissions would still exceed the screening significance threshold of 1,100 MTCO2e per year. Therefore, the proposed UWSP would be required to comply with BMP 3.

BMP 3 (TIER 2)
BMP 3 requires reducing project-generated residential VMT per resident and office VMT per worker by 15 percent compared to the existing average countywide VMT per capita, and no increase in retail VMT. In areas with above average existing VMT, BMP 3 requires a project to provide sufficient electrical capacity that 100% of project vehicles have the potential to be zero emission vehicles.

A Transportation Impact Analysis was conducted for the proposed UWSP, following OPR's guidelines and Sacramento County's Transportation Analysis Guidelines (Fehr and Peers 2022). The analysis used SACOG’s SACSIM19 travel demand model and adapted for trip length variations within and beyond the region. While SACSIM19 projected 15.4 percent of home-based household trips within the UWSP area, adjustments were made to the analysis to align it with expected internal resident trips.

Table CC-4 shows the results of the modeled work tour VMT per employee and household VMT per capita associated with the proposed UWSP. Work tour VMT includes all automobile trips that are part of home-work tours or work-based tours.5 As shown below, the VMT per resident and per employee associated with the proposed UWSP’s residential and office land uses would not exceed the applicable thresholds of significance.

Table CC-4: Residential VMT per Capita and Office VMT per Employee Measure
Work Tour VMT per
Employee (Office)
Household VMT per
Capita (Residential)
Regional Average 18.48 17.44
Proposed UWSP 15.31 14.34
Threshold of Significance
(15 percent below regional average)

15.70 14.83
Exceeds Threshold? NO NO
SOURCE: Appendix AQ-1, Table 18

5 Tours refer to the travel pattern of individuals associated with activities on a typical weekday as simulated by the SACSIM19 model.
8 - Climate Change
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The retail components associated with the proposed UWSP were assessed using SACSIM19. This analysis shows that the proposed UWSP’s regional retail uses would reduce VMT by shortening travel distances for residents traveling to regional retail destinations. Table CC-5 shows that the proposed UWSP without the regional retail component generates more VMT than the project with the regional retail added.

Consequently, the proposed UWSP would result in no increase in retail VMT and the proposed UWSP would be consistent with BMP 3.

Table CC-5: Effect of Project’s Regional Retail on VMT – Baseline Conditions Measure
Base Year SACSIM
Model Plus Project
Base Year SACSIM Model Plus
Project Without Regional Retail
Total Regional VMT 42,992,142 43,014,069
SOURCE: Appendix AQ-1, Table 19

IMPACT DETERMINATION
As described above, operation of the proposed UWSP would not comply with BMP 1 or BMP 2. However, with implementation of Mitigation Measure CC-1b and Mitigation Measure CC-1c, this impact would be reduced to less than significant.

MITIGATION MEASURES
CC-1a Prior to the initiation of construction for each subsequent development project, the applicant for each project shall demonstrate that constructionrelated GHG emissions for all construction activities in each year of construction would be reduced to less than 1,100 MTCO2e per year. The project applicant shall submit proof to the County’s Department of Planning and Environmental Review that construction emissions are reduced to less than 1,100 MTCO2e per year.

The project applicant(s) shall reduce construction-related GHG emissions through implementation of the following options for reducing GHG construction emissions:
 Modify the construction schedule to reduce the intensity of construction to lower emissions;
 Minimize the overlap of construction phases of development;  Use zero-emission off-road equipment for all off-road equipment used during construction, if commercially available. Available technologies currently include battery-electric and hydrogen fuel cell technologies.

Portable equipment shall be powered by grid electricity if available.

Electric equipment shall include, but is not limited to, concrete/industrial saws, sweepers/scrubbers, aerial lifts, welders, air compressors, fixed cranes, forklifts, and cement and mortar mixers, pressure washers, and pumps. To qualify for an exception, the Applicant shall provide the County 8 - Climate Change
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with evidence supporting its conclusion that electric equipment is not commercially available and shall use the next cleanest piece of off-road equipment in terms of GHG emissions.
 All portable engines, such as generators, shall be electric. If grid electricity is not available, propane or natural gas generators shall be used.  Use of renewable diesel for construction fuel rather than diesel, provided that renewable diesel fuel reduces tailpipe GHG emissions compared to non-renewable diesel fuel;
 Improve fuel efficiency from construction equipment by:
− 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 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
− 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 on-road 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 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);
 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. 8 - Climate Change
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 Any other best technology available in the future may be included, provided that the Project applicant submits documentation to the County demonstrating that (1) the technology would result in comparable GHG emissions reductions and (2) it would not increase other air pollutant emissions or exacerbate other impacts, such as noise. This may include new alternative fuels or engine technology for certain off-road equipment (such as electric or hydrogen fuel cell equipment) that is not available as of 2024.
 For purposes of this mitigation measure, zero-emission off-road equipment shall ordinarily be considered “commercially available” if the vehicle is capable of serving the intended purpose and is included in the California Air Resources Board’s Advanced Clean Equipment (ACE) List, https://ww2.arb.ca.gov/our-work/programs/msei/off-road-advanceclean-equipment, included in California Air Resources Board’s Clean Off-Road Equipment Voucher Incentive Project (CORE) catalog, https://californiacore.org/equipmentcatalog/, or listed as available in the US on the Global Commercial Vehicle Drive to Zero Off-Road Zero-Emission Technology Inventory (ZETI) inventory,
https://globaldrivetozero.org/tools/zeti-offroad/. The County shall be responsible for the final determination of commercial availability, based on all the facts and circumstances at the time the determination is made. For the County to make a determination that such vehicles are commercially unavailable, the operator must submit documentation from a minimum of three (3) zero-emission off-road equipment dealers identified on the ACE or CORE websites demonstrating the inability to obtain the required zeroemission off-road equipment needed within 6 months.