Sacramento City Council
November 18, 2025

however, the statutory fee is reduced by the amount of any voluntary participation in a MelloRoos. Satisfaction of the Proposition 1A/SB 50 statutory requirements by a developer is deemed to be “full and complete mitigation.”
Quimby Act
California Government Code Section 66477, Subdivision Map Act, referred to as the Quimby Act, permits local jurisdictions to require the dedication of land and/or the payment of in-lieu fees solely for park and recreation purposes. The required dedication and/or fees are based upon the residential density, parkland cost, and other factors. Land dedication and fees collected pursuant to the Quimby Act may be used for acquisition, improvement, and expansion of park, playground, and recreational facilities or the development of public school grounds.

California Green Building Code
The 2022 California Green Building Standards Code, otherwise known as the CALGreen Code (California Code of Regulations [CCR] Title 24, Part 11) is a portion of the California Building Standards Code (CBSC), which became effective on January 1, 2023. The CBSC is adopted every three years by the Building Standards Commission (BSC).

The purpose of the CALGreen Code is to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact or positive environmental impact and encouraging sustainable construction practices. The CALGreen standards regulate the method of use, properties, performance, types of materials used in construction, alteration repair, improvement and rehabilitation of a structure or improvement to property. The provisions of the code apply to the planning, design, operation, construction, use, and occupancy of every newly constructed building or structure throughout California. Requirements of the current CALGreen Code include, but are not limited to, the following measures:
 Mandatory reduction in indoor water use through compliance with specified flow rates for plumbing fixtures and fittings;
 Mandatory reduction in outdoor water use through compliance with a local water efficient landscaping ordinance or the California Department of Water Resources’ (DWR’s) Model Water Efficient Landscape Ordinance (MWELO);
 65 percent of construction and demolition waste must be diverted from landfills;  Mandatory inspections of energy systems to ensure optimal working efficiency;  Inclusion of electric vehicle (EV) charging stations or designated spaces capable of supporting future charging stations; and
 Low-pollutant-emitting exterior and interior finish materials, such as paints, carpets, vinyl flooring, and particle boards.

The CALGreen standards also include voluntary efficiency measures that are provided at two tiers and implemented at the discretion of local agencies and applicants. According to Section A4.602 of Appendix A4 of the CALGreen Code, CALGreen’s Tier 1 standards call for a 15 percent improvement in energy requirements, stricter water conservation, 65 percent diversion of construction and demolition waste, 10 percent recycled content in building materials, 20 percent permeable paving, 20 percent cement reduction, and cool/solar-reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30 percent improvement in energy requirements, stricter water conservation, 80 percent diversion of construction and demolition waste, 15 percent recycled content in building materials, 30 percent permeable paving, 25 percent cement Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

reduction, and cool/solar-reflective roofs. The City of Sacramento does not require compliance with Tier 1 or Tier 2 CALGreen standards at this time.

California Water Code
The California Water Code requires coordination between land use lead agencies and public water purveyors. The purpose of this coordination is to ensure that prudent water supply planning has been conducted and that planned water supplies are adequate to meet both existing demands and the demands of planned development.

Water Code Sections 10910 to 10915 (inclusive), sometimes referred to as SB 610, require land use lead agencies: 1) to identify the responsible public water purveyor for a proposed development project, and 2) to request from the responsible purveyor, a “Water Supply Assessment.” The purposes of the WSA are (a) to describe the sufficiency of the purveyor’s water supplies to satisfy the water demands of the proposed development project, while still meeting the current and projected water demands of customers, and, (b) in the absence of a currently sufficient supply to describe the purveyor’s plans for acquiring additional water. Water Code Sections 10910 to 10915 delineate the specific information that must be included in the WSA.

According to CEQA Guidelines Section 15155, a “water-demand project” means:

A. A residential development of more than 500 dwelling units.

B. A shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space.

C. A commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.

D. A hotel or motel, or both, having more than 500 rooms.

E. An industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area.

F. A mixed-use project that includes one or more of the projects specified in subdivisions (a)(1)(A), (a)(1)(B), (a)(1)(C), (a)(1)(D), (a)(1)(E), and (a)(1)(G) of this section.

G. A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.

H. For public water systems with fewer than 5,000 service connections, a project that meets the following criteria:

1. A proposed residential, business, commercial, hotel or motel, or industrial development that would account for an increase of 10 percent or more in the number of a public water system's existing service connections; or

2. A mixed-use project that would demand an amount of water equivalent to, or greater than, the amount of water required by residential development that would represent an increase of 10 percent or more in the number of the public water system's existing service connections.

The proposed project would include the development of an industrial park within an approximately 353.5-acre portion of the project site, located immediately south of Bayou Way. Therefore, the project meets criterion E.

Assembly Bill 1327
Assembly Bill (AB) 1327, the Solid Waste Reuse and Recycling Access Act of 1991, requires jurisdictions to adopt ordinances requiring development projects to provide adequate storage area Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

for collection and removal of recyclable materials. The City of Sacramento has adopted such an ordinance (Sacramento City Code Section 13.10.320).

Assembly Bill 1881
AB 1881, the Water Conservation in Landscaping Act of 2006, required the DWR to update the MWELO. Furthermore, AB 1881 required local agencies to adopt the updated model ordinance or an equivalent ordinance by January 1, 2010. If local jurisdictions failed to adopt the updated model ordinance or an equivalent by January 1, 2010, the DWR’s updated model ordinance would automatically be adopted by statute. The City of Sacramento has adopted a WELO (Sacramento City Code Chapter 15.92).

Senate Bill 1016
Enacted in 2007, SB 1016 amended portions of the California Integrated Waste Management Act, allowing the California Integrated Waste Management Board (CIWMB) to use per capita disposal as an indicator in evaluating compliance with the requirements of AB 939. Jurisdictions track and report their per capita disposal rates to CalRecycle.

According to CalRecycle’s jurisdiction disposal records, Sacramento disposed of 694,528.79 tons in 2021.14 The City’s per capita waste disposal rate for residents was 7.3 pounds per day (lbs/day); the per capita disposal rate target for residents according to CalRecycle was 6.9. The per capita waste disposal rate for Sacramento employees in 2021 was 12.4 lbs/day; the CalRecycle per capita disposal rate target was 10.8 lbs/day.

California Integrated Waste Management Act – Assembly Bill 939 AB 939, the California Integrated Waste Management Act of 1989, contains requirements affecting solid waste disposal in California. According to AB 939, all cities and counties are required to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. Solid waste plans are required to explain how each city’s AB 939 plan will be integrated within the respective county plan. The plans must promote (in order of priority) source reduction, recycling and composting, and environmentally safe transformation and land disposal.

Cities and counties that do not meet this mandate are subject to daily fines of $10,000.

Local Regulations
The following are applicable local public services and utility regulations related to the proposed project.

Sacramento Local Agency Formation Commission Policies, Standards and Procedures for LAFCo Manual
The following policies and standards from Sacramento LAFCo’s Policies, Standards and Procedures for LAFCo manual related to public services and utilities are applicable to the proposed project.

14 California Department of Resources Recycling and Recovery. Jurisdiction Diversion/Disposal Rate Detail.

Available at: https://calrecycle.ca.gov/lgcentral/datatools/reports/divdisprtsum/. Accessed June 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

LAFCo General Policies
Policy 6 LAFCo will favorably consider those applications that do not shift the cost for services and infrastructure benefits to other service areas.

Policy 9 Community needs are met most efficiently and
effectively by governmental agencies which:
 are already in existence;
 are capable of coordinating service delivery over
a relatively large area;
 provide more than one type of service to the
territory which they serve.

General Standards – Spheres of Influence
Standard 2 Spheres of Influence are the primary planning tool for LAFCo. To update spheres of influence, agencies must
have an updated Municipal Service Review which meets
the standards as set forth in Government Code Section
56430.

Standard 3 The LAFCo will require that any agency requesting a Sphere of Influence change through LAFCo must have
an updated Municipal Service Review. The LAFCo will
approve a proposal only if the proposed service provider is the most efficient provider of services with an
acceptable cost, as demonstrated in the provider's
Municipal Service Review.

General Standards – Standards for Annexation to and the Detachment from All Agencies
Standard 4 The annexation must be consistent with the applicable Municipal Service Reviews. An annexation or
detachment shall be approved only if the services
element of the Spheres of Influence Plan of the affected agency or agencies demonstrates that adequate
services will be provided within the time frame needed
by the inhabitants of the annexed or detached area.

Proposed annexations for land areas that lie outside of the current and next five-year increments of projected
service delivery in the services element are presumed
not to comply with this standard unless the applicant
clearly establishes that special and unique
circumstances exist which ensure the provision of
quality services during the applicable time frame for the affected area consistent with the other standards.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Standard 5 The annexation must provide the lowest cost and highest quality of urban services for the affected
population, LAFCo will approve an annexation or
detachment only if the commission determines that the
annexing agency possesses the capability to provide the most efficient delivery of applicable urban services for the affected population.

Standard 9 An annexation or attachment shall not be approved merely to facilitate the delivery of one or a few services to the detriment of the delivery of a larger number of
services or services more basic to public health and
welfare.

Standard 11 The LAFCo Commission shall take one of the following three actions on an application for annexation or
detachment:
a. Approve the application if it has found the
change to result in the most efficient delivery of
services for the affected population and complies
with other applicable standards;
b. Approve the application on the condition that the
applicant agree to actions necessary to
maximize -the efficiency of urban services.

These may include, but are not limited to:
(1) Waiver of detachment from an existing
service provider or, in the alternative,
appropriate detachment fees;
(2) Entering into a Joint Powers Agreement
with another service provider.
c. Deny the annexation on the grounds that a more
efficient combination of services for the affected
population may be provided by either existing or
a combination of new and existing service
providers.

In the event of such a denial, LAFCo may present to the applicant, the conducting agency, and affected service
providers, a statement of the reasons for denial, and
recommendations for actions necessary to ensure the
most efficient form of urban services delivery to the
affected population.

Specific Standards by Type of Action – Annexations to Cities Standard 6 The LAFCo opposes extension of services by a city without annexation unless such extension is by contract Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

with another governmental entity or a private utility or as otherwise in compliance with Government Code section
56133.

Specific Standards by Type of Action – Annexations to Districts Standard 3 The LAFCo opposes extension of services by a district without annexation unless such extension is by contract with another governmental entity or a private utility or as otherwise in compliance with Government Code section
56133.

Specific Standards by Type of Action – Reorganization
The LAFCo will evaluate each component organizational change which makes up a reorganization proposal independently. In so doing, the LAFCo will follow the standards presented below.

Standard 1 LAFCo will strive to ensure that each separate territory included in the proposal, as well as affected neighboring residents, tenants, and landowners, receive services of an acceptable quality from the most efficient and
effective service provider after the reorganization is
complete.

Standard 2 The service quality, efficiency, and effectiveness available prior to reorganization shall constitute a
benchmark for determining significant adverse effects
upon an interested party. The LAFCo will approve a
proposal for reorganization which results in significant adverse effects only if effective mitigating measures are included in the proposal.

Specific Standards by Type of Action – Amendments to Spheres of Influence Standard 2 The Sphere of Influence Municipal Service Review must be current before additions to a Sphere of Influence will be approved by LAFCo.

Standard 4 Amendment proposals must be consistent with an updated Sphere of Influence and/or Municipal Service
Review.

Standard 5 An applicant for amendment to a Sphere of Influence must demonstrate a projected need or lack of need for
service.

Standard 9 The LAFCo will deny proposals that would result in significant unmitigable adverse effects upon other
service recipients or other agencies serving the affected area unless the approval is conditioned to avoid such
impacts.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

City of Sacramento 2040 General Plan
The following goals and policies from the City of Sacramento 2040 General Plan related to public services and utilities are applicable to the proposed project.

Public Facilities and Safety Element
Goal PFS-1 Responsive police and fire services that ensure a high level of public safety.

Policy PFS-1.1 Crime and Law Enforcement. The City shall continue to work cooperatively with the community, regional law
enforcement agencies, local government agencies, and
other entities to provide quality police service that
protects the long-term health, safety, and well-being of the community.

Policy PFS-1.9 Equipment, Facilities, and Staffing. The City shall locate and maintain police and fire equipment, facilities, and staffing at locations and levels that allow for
effective service delivery.

Policy PFS-1.12 Cooperative Delivery of Services. The City shall maintain mutual aid relationships with the County of
Sacramento and other local, State, and federal agencies that promote regional cooperation in the delivery of
services and allow for supplemental aid from other
police and fire personnel in the event of emergencies.

Policy PFS-1.14 Timing of Services. The City shall monitor the pace of residential and commercial growth in Sacramento and
make best efforts to match that growth with
commensurate increases in public safety personnel,
equipment, and facilities.

Policy PFS-1.15 Development Fees for Facilities and Services. The City shall require development projects to contribute
fees to ensure the provision of adequate police and fire services.

Policy PFS-1.16 Development Review. The City shall continue to require new development projects to incorporate safety
features and include the Sacramento Police Department
(SPD) and the Sacramento Fire Department (SFD) in
the development review process to ensure that projects
are designed and operated in a manner that minimizes
the potential for criminal activity and fire hazards and maximizes the potential for responsive police and fire
services.

Goal PFS-3 Efficient, high-quality utility infrastructure and services to meet the needs of residents and business throughout the city.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Policy PFS-3.1 Provision of Adequate Utilities. The City shall continue to provide reliable water, wastewater, and
stormwater drainage utility services.

Policy PFS-3.2 Utility Sustainability. The City shall continue to improve the sustainability, resilience, and energy
efficiency of its facilities, infrastructure, and operations consistent with the Climate Action and Adaptation Plan
and the goal of achieving carbon neutrality by 2045.

Policy PFS-3.3 Development Impacts. Through the development review process, including through development impact
fees and offsite improvements constructed by new
development, the City shall ensure that adequate public utilities and services are available to serve new
development.

Policy PFS-3.5 Water Treatment Capacity and Infrastructure. The City shall plan, secure funding for, and procure sufficient water treatment capacity and infrastructure to meet
projected maximum daily water demands. Options to
explore may include the following:
 Expansion or rehabilitation of existing treatment
plant infrastructure;
 Development and management of groundwater
wells; and
 Collaboration on regional water supply solutions.

Policy PFS-3.10 Meet Projected Needs. The City shall foster the orderly and efficient expansion of facilities and infrastructure to adequately meet projected needs, comply with current
and future regulations, and maintain public health,
safety, and welfare. Infrastructure and facility planning should discourage over-sizing of infrastructure that
could induce growth at the edges of the city beyond what is anticipated in the General Plan.

Policy PFS-3.11 Joint-Use Facilities. Wherever feasible, the City shall pursue the development of joint- use water, stormwater
quality, flood control and other utility facilities as
appropriate in conjunction with schools, parks, bike
paths, golf courses, and other suitable uses to achieve economy and efficiency in the provision of services and facilities.

Policy PFS-3.12 Safe and Compatible Utility Design. The City shall ensure that public utility facilities are designed to be safe and compatible with adjacent uses.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Policy PFS-3.13 Impacts to Environmentally Sensitive Lands. The City shall consider the impacts on environmentally
sensitive areas and habitats when locating and
designing municipal utilities.

Policy PFS-3.14 Underground Utilities. The City shall require new development to underground utility lines wherever
feasible and coordinate with electricity and
telecommunications providers to underground existing
overhead lines where feasible.

Goal PFS-4 A reliable supply of high-quality water that meets projected needs within the City’s place of use.

Policy PFS-4.8 New Development. The City shall ensure that water supply capacity is in place prior to granting building
permits for new development.

Goal PFS-5 Sensible waste management that reduces disposal in landfills and supports cost-effective sustainability efforts.

Policy PFS-5.1 Solid Waste Reduction. The City shall reduce the amount of solid waste that is disposed in landfills by
promoting source reduction and recycling throughout
Sacramento and by expanding the range of programs
and information available to local residents and
businesses, consistent with State requirements.

Policy PFS-5.2 Collection and Recycling Services. The City shall provide for continued solid waste collection and
recycling services in Sacramento, including contracting with franchise waste haulers, and ensuring adequate
transfer station facilities capacity and the availability of adequate landfill capacity to meet future needs.

Youth, Parks, Recreation, and Open Space Element
Goal YPRO-1 An integrated system of parks, open space areas, shared-use paths, and recreational facilities that are welcoming, well-maintained, safe, and accessible to all the diverse communities of Sacramento.

Policy YPRO-1.4 Parkland Dedication Requirements. The City shall continue to require that new residential development
projects contribute toward the provision of adequate
parks and recreational facilities to serve the new
residents, either through the dedication of parkland, the construction of public and/or private recreation facilities, or the payment of parkland in-lieu fees, consistent with the Quimby Ordinance. To achieve the level of service
for all parkland in all areas of the city, the City shall seek Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

other funding resources to prioritize park needs in park deficit areas.

Policy YPRO-1.5 Incentivizing Onsite Public Facilities. The City shall continue to provide Park Impact Fee (PIF) credit for
development projects that provide publicly accessible
parks, plazas, and parkways onsite that promote active
or passive recreational opportunities and serve as
neighborhood gathering points.

Policy YPRO-1.9 Timing of Services. The City shall monitor the pace and location of new development through the
development review process and long-range planning
efforts to strive to ensure that development of parks,
recreation programming, and community- serving
facilities and services keeps pace with growth.

Policy YPRO-1.19 Sustainable Design. The City shall design and construct parks, public spaces, and recreational facilities for flexible use, energy/water efficiency, reduced
greenhouse gas emissions and air pollution, adaptability for long-term use, and ease and cost of maintenance.

Sacramento City Code
Sections from the Sacramento City Code related to the adoption of the CBSC, the undergrounding of utilities, and the City’s WELO, are discussed below.

Section 15.04.050 – Adoption of the 2022 California Building Standards Code Buildings constructed within the project site would be subject to the current building standards found in the CBSC, which includes, but is not limited to, the CBC (CCR Title 24, Part 2) and the California Fire Code (CFC) (CCR Title 24, Part 9). The CBC and CFC address roofing materials, automatic sprinkler systems, emergency access, access gates, sprinkler systems, fire alarms within buildings, and construction of access roads to accommodate fire apparatus. The CFC requires that an automatic fire sprinkler and/or fire extinguishing system be installed throughout new one- and two-family dwellings and commercial buildings 3,600 sf and larger.

Section 12.12.260 – Undergrounding
Sacramento City Code Section 12.12.260 requires that in all areas of the City where cables, wires, and other similar facilities of a utility company are placed underground, newly installed cables, wires, and other facilities must be installed underground. In addition, where such utility facilities are installed aboveground, such facilities must be installed underground in the event that new development within the vicinity includes underground utility facilities.

Chapter 15.92 – Water Efficient Landscape Requirements
The City’s WELO is codified in Sacramento City Code Chapter 15.92 and contains requirements for new construction projects with an aggregate landscape area equal to or greater than 500 sf that require a building or landscape permit, Plan Check, Plan Review, or Design Review. As part of compliance with the WELO, new construction projects meeting the aforementioned criteria must submit a landscape documentation package for review and approval to the Chief Building Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Official. The landscape documentation package must include, but not be limited to, the total landscape area in sf, information on the project type, information on the water supply type, and water budget calculations.

City of Sacramento Standard Specifications
Section 26 and 27 of the City of Sacramento Standard Specifications provide supplemental design considerations for sewer and water utility line improvements, respectively. The Standard Specifications set forth requirements with which all construction, trenching, excavation, and improvement work must conform.

City of Sacramento Parks and Recreation Master Plan 2005-2010 The City of Sacramento Parks and Recreation Master Plan 2005-2010 is principally a guiding policy document, strategic in orientation, that charts the growth, direction, priorities, and agenda of the City’s YPCE Department and establishes policies to guide decision-making by City staff and officials. Map 7 of the Parks and Recreation Master Plan 2005-2010 shows growth opportunity areas within the City’s 2030 General Plan planning area.15 In addition, the YPCE Department released a draft update to the Parks and Recreation Master Plan 2005-2010, titled Parks Plan 2040 and anticipated for final adoption in June 2024. The Parks Plan 2040 identifies the community’s needs and priorities for the next 20 years, as they relate to parks and facilities, youth development, and recreation and community enrichment. The Parks Plan 2040 inventories existing physical and programmatic assets and identifies trends, needs, and level of service goals.

The Parks Plan 2040 refines the policies, actions, and tools that YPCE will use to guide the provision of parks, recreation facilities, programs, events, and services.

City of Sacramento Park Impact Fee Nexus Study Update
This Park Impact Fee Nexus Study Update was prepared for the City of Sacramento pursuant to the Mitigation Fee Act set forth by Government Code Section 66000. The purpose of the Park Impact Fee Nexus Study Update was to establish the legal and policy basis to allow the City to impose a fee on new residential and non-residential development within the City. The City originally adopted the Park Impact Fee in August of 1999. The fee was updated in April of 2002, and again in April of 2004. Modifications were also proposed in 2007 and 2011, but were not acted upon, owing to the economic recession occurring at that time. According to the City of Sacramento’s Fees and Charges database, the Park Development Impact Fee is currently assessed at a total rate of $0.22 per sf for new industrial development not in the Central City or a Housing Incentive Zone, which includes a $0.17 per sf rate for Neighborhood/Community fees and a $0.05 per sf rate for Citywide fees.16

4.11.4 IMPACTS AND MITIGATION MEASURES
The section below describes the standards of significance and methodology utilized to analyze and determine the proposed project’s potential project-specific impacts related to public services and utilities. In addition, a discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

15 It should be noted that as part of the City’s 2040 General Plan, Map YPRO-1 shows proposed park locations within the City limits. 16 City of Sacramento. Fees and Charges. Available at: https://www.cityofsacramento.gov/finance/fees-and-charges.

Accessed April 2024.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Standards of Significance
Consistent with Appendix G of the CEQA Guidelines, determination of significant impacts is based on whether the proposed project would result in the following:
 Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
o Fire protection;
o Police protection;
o Schools;
o Parks;
o Other public facilities;
 Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated;
 Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment;  Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects;
 Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years;  Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments;
 Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or  Comply with federal, State, and local management and reduction statutes and regulations related to solid waste.

Impacts related to groundwater and storm drainage facilities are addressed in Chapter 4.8, Hydrology and Water Quality, of this EIR.

Method of Analysis
In order to determine the potential for the project to result in substantial adverse impacts associated with the provision of new or altered government facilities, relevant public services and utilities planning documents were reviewed, including, the City of Sacramento 2040 General Plan, the City of Sacramento Master EIR, and the City of Sacramento 2020 UWMP. In addition, information related to public services was primarily drawn from the Targeted MSR (see Appendix K of this EIR) prepared for the proposed project by Wood Rodgers. Information related to water supply and sewer conveyance was primarily drawn from the Preliminary Water Study (see Appendix L of this EIR) and the Sewer Study (see Appendix M of this EIR), respectively, both of which were also prepared for the proposed project by Wood Rodgers. The method of analysis used in each of the aforementioned assessments is discussed further below.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Targeted Municipal Services Review
The Targeted MSR was prepared to assist the Sacramento Local Agency Formation Commission (LAFCo) in its evaluation of the proposed Sphere of Influence (SOI) Amendment for the respective boundaries of the City of Sacramento and SacSewer. The Targeted MSR complies with the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (Act), pursuant to Government Code Section 56000, et seq., and evaluates existing and future service conditions for the geographic area subject to the requested SOI Amendment. An MSR provides the means to synthesize data regarding a local agency’s operations and public services, ability to provide mandated services, and/or opportunities to provide more efficient services. Government Code Section 56375 permits a LAFCo to take action on recommendations found in an MSR, which can range from initiating studies for changes of organization, updating a SOI, or initiating a change in organization.

An MSR also provides information to help a LAFCo make decisions on a proposed SOI boundary change, including data necessary to determine if an agency has the capability to serve an expanded area and data related to an agency’s financial condition, revenue sources, and projected expenses. In addition, an MSR outlines what infrastructure may be needed to accommodate expansion of public services. Finally, an MSR can recommend changes in an agency or district’s organization, such as consolidation, dissolution, merger, establishment of a subsidiary district, or the creation of a new agency that typically involves a consolidation of agencies.

The Targeted MSR prepared for the proposed project focuses on the service areas currently outside of Sacramento’s incorporated boundary. The Targeted MSR serves as an information base to update the City of Sacramento’s SOI to accommodate the project site, as proposed for development by the project, and to provide a foundation for the public, City of Sacramento, Sacramento County, and Sacramento LAFCo to consider changes to the City’s existing SOI boundary.

To provide Sacramento LAFCo with the information needed to make a determination regarding each of the elements identified above, the Targeted MSR includes the following public service/issue area discussions:
 Growth and Population Projections;
 Disadvantaged Communities;
 Public Facilities and Services;
o Water;
o Wastewater;
o Circulation and Roadways;
o Animal Care;
o Code Enforcement;
o Law Enforcement;
o Fire Protection;
o Solid Waste;
o Storm Drainage and Flood Control;
o Parks and Recreation;
o Libraries;
o Electricity and Natural Gas;
 Financial Ability to Provide Services;
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

 Shared Facilities Opportunities;
 Government Structure and Accountability; and
 Other Matters Related to Effective Service Delivery.

Preliminary Water Study
The Preliminary Water Study was prepared to analyze the proposed water infrastructure associated with development of the proposed industrial park and commercial uses. The Preliminary Water Study addresses proposed land uses, potable water system hydraulics, and proposed infrastructure-level improvements through an Innovyze InfoWater hydraulic model analysis (version 12.4.13) of the conceptual piping system, which was sized and laid out in accordance with input provided by the City of Sacramento on March 9, 2023.

The proposed project’s domestic and fire demands were identified, calculated, and input into the system model. The regional City system is shown on Exhibit F of the Preliminary Water Study.

The nearest existing City water storage tank is located 4,800 feet south and east of the project site along El Centro Road and has a storage capacity of three million gallons (mg). The Lanfranco Circle point of connection is currently fed by the El Centro Reservoir and has pumping capacity as shown in Exhibit F of the Preliminary Water Study. The potential layout for the proposed project can be seen in Exhibit G of the Preliminary Water Study. The layout was developed in accordance with the City’s comments and focuses on only the public water mains that would serve the project.

For visual purposes, an illustration to show the layout of the public mains versus the private mains is provided in Exhibit J of the Preliminary Water Study.

Land use for the proposed project was assumed based on the Preliminary Site Plan and land use summary (see Figure 3-3 in the Project Description chapter of this EIR), which is provided in Exhibit B and Exhibit C of the Preliminary Water Study. A breakdown of the land use acreages incorporated within the InfoWater model is summarized in Table 4.11-2, which used net acres.17 Table 4.11-2
Preliminary Water Study Land Use Acreages
Land Use Designation Total Net Acreage
Mixed Use1 13.4
Industrial 235.6
Future Industrial 83
Total 332 1 It should be noted that although the Mixed Use land use designation was applied as part of the model, the proposed project would include 13.4 acres of Highway Commercial Planned Use Development (HC-PUD) uses.

Source: Wood Rodgers, 2023.

Node elevations were assumed to be at street elevation and were based on the preliminary earthwork exhibit included in Appendix B of the Preliminary Water Study. The project site was assumed to be designated to allow for industrial and mixed-use development. The assumption was used to calculate water demands for the project site using the demand factors provided in the City of Sacramento 2018 Water Study Design Manual. For fire flow requirements, Wood Rodgers used planning numbers found in the City’s 2018 Water Study Design Manual, pursuant to the City’s direction. Any node that was near an industrial lot was assigned a fire flow of 4,500 17 The term “gross acre” refers to all land within a given boundary. The term “net acre” refers to land measured within a given boundary, minus the acreages of certain features, such as roads, utilities, and open space.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

gallons per minute (gpm). For the mixed-use buildings, a fire flow of 3,500 gpm was assigned to align with the City requirements. A summary of the demands is presented in Table 4.11-3.

Table 4.11-3
Preliminary Water Study Demand Summary
Land Use
Designation
Total Net
Acreage
ADD Unit Water Demand1 Demand (gpm)
AFY/Acre2 GPM/Acre3 ADD1 MDD4 PHD5
Mixed Use6 13.4 2 1.24 17 33 43
Industrial 235.6 0.9 0.56 132 264 343
Future
Industrial 83 0.9 0.56 46 93 120
Total 332 -- -- 195 390 507 1 ADD = Average day demand
2 AFY/Acre = Acre-feet per year per acre
3 GPM/Acre = Gallons per minute per acre
4 MDD = Maximum day with fire flow demand 5 PHD = Peak hour demand 6 It should be noted that although the Mixed Use land use designation was applied as part of the model, the proposed project would include 13.4 acres of HC-PUD uses.

Source: Wood Rodgers, 2023.

For the Preliminary Water Study, the City provided a graphic showing the pressure rating curve at the connection point in Bayou Way, which takes into consideration the full buildout and losses from the Northlake subdivision (formerly Greenbriar). Because the boundary condition takes into consideration all infrastructure for Northlake and other existing uses, the Northlake modeling entities were omitted from the Preliminary Water Study. For the Lanfranco Circle boundary condition, the City provided a graphic showing the pressure rating curve at the connection point.

It should be noted that the model was only capable of representing flow and head (or hydraulic grade line [HGL]), so a conversion was performed to convert the data as required. The boundary conditions at Bayou Road and Lanfranco Circle can be seen in Appendix D of the Preliminary Water Study.

Sewer Study
The sewer equivalent single-family dwelling units (ESD) that make up the sewer demand in the Sewer Study include approximately 81 ESDs of commercial units, 1,870 industrial (warehouse) ESDs, 516 detention basin ESDs, 152 ESDs of roadway/right-of-way (ROW), pump stations and buffer spaces (see Table 4.11-4). All sewer facilities would be permanent. The sewer pump station that would serve the proposed project would be developed in a single phase to meet the ultimate ADWF and peak wet weather flows (PWWF). Based on the land use acreages proposed as part of the project and the aforementioned ESDs, the combined ADWF and PWWF demand is expected to be 0.81 mgd and 2.09 mgd, respectively.

The Sewer Study provides calculations of the ultimate sewer flows that are expected to be generated within the project site (i.e., full buildout of the industrial park and nonparticipating parcels) by using acreage and density information provided in the Preliminary Site Plan (see Figure 3-3 in the Project Description chapter of this EIR) and ADWF in Section 201.1 of the SacSewer Standards and Specifications.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Table 4.11-4
Land Use, Acreages, and Sewer ESDs
Land Use Description Area
(acres)1
Sewer Density (du/ac)2 ESDs
Commercial 13.4 6 80.4
Industrial 311.7 6 1,870.2
Stormwater Detention Basin 86 6 516
Land Buffer 2.3 6 13.8
Pump Station (Sewer and Stormwater) 0.9 6 5.4
Internal Roadways and Caltrans Parcel 22.2 6 133.2
I-5 Corridor 37.9 0 0
Total 474.4 2,619 1 Net acres
2 Dwelling units per acre = du/ac
Source: Wood Rodgers, 2023.

Several assumptions were used in the design approach for the Sewer Study and are provided below:
 Any upstream development will not need to use the sewer infrastructure installed as part of the proposed project. SacSewer’s Expansion Trunk Shed Plans for the Sacramento International Airport, Metro Air Park, and lands south of the airport and west of the project site will convey to existing infrastructure within the Metro Air Park sewer shed;  A significant increase in on-site densities will not occur that could affect the planned onsite facilities;  For the Sewer Study, the location of the trunk and collectors are schematic to more clearly show where sewer is loaded into the demand calculations. The exact horizontal location, rim elevation, and depth of the pipe and manhole infrastructure will be determined during preparation of the Level 2 and Level 3 Sewer Studies;
 Pipe sizes and flow rates were calculated based on the SacSewer Standards and Specifications and adhere to SacSewer “Minimum Sewer Study Requirements” criteria; and
 Areas that are not expected to generate sewer demand are included in the demand calculations. The areas include stormwater detention basins, land buffers, pump stations, a California Department of Transportation (Caltrans) parcel dedication, and on-site roadways.

The following general procedures were used in the development of the Sewer Study:

1. Gross areas and land use information based on the Preliminary Site Plan were used to calculate sewer flows;

2. Sub-shed areas were defined primarily by building sites, then by topographic features;

3. ESDs were calculated for each shed based on the underlying land use and shed area;

4. Each ESD was assumed to have a 310-gallon-per-day (gpd) ADWF;

5. Flows were determined based on the SacSewer Standards and Specifications and on the design criteria and assumptions identified in the Sewer Study; and

6. A permanent pump station will be located on Lot F, as shown in the Preliminary Site Plan;

7. The pump station will be served by a permanent force main discharging to a SacSewer interceptor. The final alignment design and discharge location of the force main will be Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

one of three alignment options, as shown in Figure 3-4 in the Project Description chapter of this EIR.

The SacSewer Standards and Specifications, dated November 30, 2021, were used as the basis for the sewer design. The flows were generated using the information found in Chapter 201 (Capacity Design) of the SacSewer Standards and Specifications. Generally, the minimum allowable ESD densities identified in Chapter 201 were used; however, higher densities were used as established by the proposed land uses (see Table 4.11-4). For further details of the flow criteria, please see Table 3-1 in the Sewer Study.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts related to public services, utilities, and service systems is based on the implementation of the proposed project in comparison with the standards of significance identified above.

4.11-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other
performance objectives for fire protection services. Based on the analysis below, the impact is less than significant.

As discussed in the Project Description chapter of this EIR, the proposed project consists of an industrial park within an approximately 353.5-acre portion of the project site, as well as several nonparticipating parcels, comprised of approximately 83 acres, that would result in first tier entitlements for future industrial uses of approximately 1,404,800 sf. The footprints of both project components are currently served by the SFD and would continue to be served by the SFD following project approval. Thus, the following discussion applies to the potential for both project components to result in impacts related to the provision of services and/or facilities provided by the SFD.18 Given that the proposed off-site force main would be sized to accommodate flows from the project site, installation of the off-site force main would not indirectly induce population growth such that the SFD would require new or expansion of existing facilities, the construction of which would result in potential environmental impacts.

Industrial Park and Nonparticipating Parcels
The relevant CEQA threshold for this discussion is whether new or physically altered fire stations are needed to meet response times or other performance objectives, the construction of which could cause environmental impacts. The nearest SFD fire station to the project site is Station 43, which is located at 4201 El Centro Road, approximately

2.5 miles southeast of the site. Although each of SFD’s 24 fire stations operates within a specific response district encompassing the immediate geographical area around the station, all fire agencies within Sacramento County (i.e., SFD, Sacramento 18 It should be noted that, as discussed in the Project Description chapter of this EIR, the project site encompasses 474.4 acres. In addition to the 353.5-acre industrial park footprint and the 83 acres of nonparticipating parcels, the project site includes 37.9 acres of Caltrans I-5 fee title ROW.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Metropolitan Fire District, Sac Airport Fire, Cosumnes Community Services District Fire Department, and the Folsom Fire Department) share an automatic aid agreement that allows response from the closest fire unit regardless of jurisdiction. According to the Targeted MSR, the SFD seeks to respond to fire incidents and medical emergencies within four minutes, which is generally consistent with General Plan Policies PFS-1.14, -1.15, and -1.16. The foregoing policies generally provide that the SFD shall strive to maintain emergency response times that provide optimal fire protection and emergency medical services.

As the proposed project primarily consists of industrial uses, with a limited number of commercial uses also proposed, the project would not be anticipated to generate a substantial amount of new population within the SFD service area, as the project does not include new residential units and the majority of jobs created by the project would be filled primarily by those already residing within the Sacramento region. As such, the proposed project would not be expected to substantially increase the need for additional SFD fire personnel, equipment, and facilities through population growth.

Nevertheless, due to the industrial nature of the project, the potential exists for workrelated injuries that necessitate emergency medical care to occur during project operation. As discussed further in Chapter 4.10, Transportation, of this EIR, based on assumptions used by the transportation consultant, development of the project could generate a total of approximately 4,000 employees. Given the relatively close proximity of Station 43 to the project site, the SFD is anticipated to be capable of responding to emergency medical and fire incidents at the project site within the department’s four-minute response time goal. In addition, through the automatic aid agreement between fire agencies within Sacramento County, the most efficient fire protection and emergency medical services would be available to the project site. For example, Metro Air Park is scheduled to provide land and facilities for a new fire station near the project site. The 10,000-sf fire station site will be located approximately 1.4 miles north of the project site and operated by the Sacramento Metropolitan Fire District, which would allow for immediate response to fire and emergency medical incidents at the project site.

Furthermore, all structures included as part of the proposed project would be constructed in accordance with the applicable standards set forth by the CBC and CFC. Consistent with the CBC, the design of the proposed buildings would include the installation and use of automatic fire sprinklers. Fire alarm systems would be incorporated pursuant to CFC requirements. Such features would reduce the potential for fires to occur and spread within the proposed structures, thereby reducing the demand for fire protection services associated with the proposed project. Thus, the project would not result in the need for new or physically altered SFD stations to meet response times or other performance objectives, the construction of which could cause environmental impacts.

General Plan Policies PFS-1.14, -1.15, and -1.16 establish the City’s commitment to ensuring the SFD has the necessary levels of facilities, apparatus, equipment, and staffing to provide adequate fire protection and emergency medical services within the department’s service area. The City funds the SFD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

new development. In addition, new development within the City is subject to applicable development impact fees to ensure a fair-share contribution is made to finance the purchase of new or expansion of existing SFD facilities, apparatus, and equipment necessary for the purposes of maintaining adequate service levels. For example, the project site is currently contiguous with the City’s North Natomas Finance Plan Area.

As part of project approval, the proposed project would be subject to the North Natomas Planning Area Development Fees. Pursuant to Sacramento City Code Section 18.24.050, the North Natomas Planning Area Public Facilities Fee is assessed at a rate of $238,272 per net acre for Convenience Commercial uses; $140,361 per net acre for Community Commercial uses; and between $49,752 and $57,527 per net acre for Light Industrial uses. Thus, through payment of the North Natomas Planning Area Development Fees, buildout of the project site with the proposed uses would include a fair-share contribution to the City for the provision of SFD services to the site.

Finally, conservatively estimating that all permanent positions associated with the project would be filled by new residents to the Sacramento region would result in a 0.7 percent increase to the existing City population.19 Although an associated incremental increase in demand for SFD services could result from the foregoing population increase, pursuant to CEQA Guidelines Section 15002(g), a significant effect on the environment is defined as a substantial adverse change in the physical conditions that exist in the area affected by the proposed project. “Environment” means the physical conditions that exist within the area that will be affected by a proposed project, including land, air, water, minerals, flora, fauna, noise, or objects of historic or aesthetic significance (see Public Resources Code Section 21060.5). The courts have affirmed this understanding. In the case City of Hayward v. Board of Trustees of the California State University, the First District Court of Appeal affirmed that the focus of CEQA analysis should be limited to physical environmental impacts related to a project.20 The court held that, “[t]he need for additional fire protection services is not an environmental impact that CEQA requires a Project Proponent to mitigate.” As such, the creation of additional demand for SFD fire protection services as part of the proposed project would not, by itself alone, constitute an impact on the environment, as established by the CEQA Guidelines.

Based on the above, development of the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection services and/or facilities, the construction of which could cause significant environmental impacts, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.
19 Based on 2019 population total for the City of Sacramento presented in the Land Use and Planning/Population and Housing chapter of this EIR. 20 First District Court of Appeal. City of Hayward v. Board of Trustees of the California State University. (November 30, 2015) 242 Cal.App.4th 833.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

4.11-2 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other
performance objectives for police protection services. Based on the analysis below, the impact is less than significant.

The project site is currently provided law enforcement services by the Sacramento County Sheriff’s Office. Following annexation into the City of Sacramento, the footprints of the proposed industrial park and the nonparticipating parcels would be provided police protection services by SPD. Thus, the following discussion applies to the potential for both project components to result in impacts related to the provision of services and/or facilities provided by the SPD. Given that the proposed off-site force main would be sized to accommodate flows from the project site, installation of the offsite force main would not indirectly induce population growth such that the SPD would require new or expansion of existing facilities, the construction of which would result in potential environmental impacts.

Industrial Park and Nonparticipating Parcels
The SPD is headquartered at the City’s Public Safety Center at 5770 Freeport Boulevard and is supported by several substations throughout the City. The nearest police substation to the project site is the Central Command Richards Police Facility, which is located at 300 Richards Boulevard, approximately 5.4 miles to the southeast of the site. According to the Targeted MSR, the SPD does not have an adopted officerto-resident ratio. Unofficially, the SPD maintains an unofficial goal of 2.0 to 2.5 sworn police officers per 1,000 residents and one civilian support staff per two sworn officers.

Additionally, although General Plan Policy PFS-1.14 establishes the City’s commitment to ensuring the SPD achieves and maintains optimal response times for all call priority levels, the Sacramento General Plan does not establish a specific response time standard for emergency calls for the SPD.

Development of the proposed project is estimated to result in a total of approximately 4,000 employees. Conservatively estimating that all permanent positions associated with the project would be filled by new residents to the Sacramento region would result in a 0.7 percent increase to the existing City population.21 While such an increase could incrementally increase demand for police protection services by the SPD, as previously discussed, in the case City of Hayward v. Board of Trustees of the California State University, the First District Court of Appeal affirmed that the focus of CEQA analysis should be limited to physical environmental impacts related to a project.22 As such, as established by the CEQA Guidelines, the incremental increase in demand for SPD police protection services generated by the proposed project would not, by itself alone, constitute an impact on the environment. Furthermore, given the relatively short distance of the Central Command Richards Police Facility to the project site, the SPD 21 Based on 2019 population total for the City of Sacramento presented in the Land Use and Planning/Population and Housing chapter of this EIR. 22 First District Court of Appeal. City of Hayward v. Board of Trustees of the California State University. (November 30, 2015) 242 Cal.App.4th 833.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

would be able to capably respond to service calls from the project site. In addition, General Plan Policies PFS-1.14, -1.15, and -1.16 establish the City’s commitment to ensuring the SPD has the necessary levels of facilities, equipment, and staffing to adequately provide police protection services to the SPD service area. Accordingly, revenues generated through payment of applicable permit application fees by the proposed project, as well as development impact fees established pursuant to Sacramento City Code Section 18.24.050, would ensure the project pays a fair share for police protection services provided by the SPD.

Finally, the development standards established by Sacramento City Code Section

17.220.250 for the Industrial PUD (M-1-PUD) and Industrial (M-1) zoning districts require compliance with the City’s wall, fence, and gate regulations, which are set forth in Sacramento City Code Chapter 17.620. The aforementioned regulations allow for enhanced fencing materials capable of providing additional security for nonresidential structures and requirements for gated entrances. Such features would reduce the demand for police protection services associated with the proposed project. Thus, any increase in demand generated by the project, including new residents indirectly attracted to the City by the project, would not result in the need for new or physically altered SPD facilities to meet response times or other performance objectives, the construction of which could cause environmental impacts.

Based on the above, development of the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection services and/or facilities, the construction of which could cause significant environmental impacts, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-3 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable performance objectives for schools. Based on the analysis below, the impact is less than significant.

The project site is within the boundaries of the NUSD. The following discussion applies to the potential for the proposed industrial park and the nonparticipating parcels to result in impacts related to the provision of school services and/or facilities provided by the NUSD. Given that the proposed off-site force main would be sized to accommodate flows from the project site, installation of the off-site force main would not indirectly induce population growth such that the NUSD would require new or expansion of existing facilities, the construction of which would result in potential environmental impacts.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Industrial Park and Nonparticipating Parcels
As previously discussed, the proposed project primarily consists of industrial uses, with a limited number of commercial uses also proposed. Thus, the project would not be anticipated to generate a substantial amount of new school-aged population within the NUSD boundaries, as the project does not include new residential units and the majority of jobs created by the project would be filled primarily by those already residing within the Sacramento region. Nonetheless, as previously discussed, conservatively estimating that all permanent positions associated with the project would be filled by new residents to the Sacramento region would result in a 0.7 percent increase to the existing City population. While such an increase could incrementally increase demand for school services by the NUSD, the current NUSD enrollment is 16,598 and the current capacity is 18,344 students, including charter schools.23 Therefore, the proposed project would not be expected to substantially increase demand for school services provided by the NUSD, such that the project would necessitate new or expansion of existing facilities, the construction of which would cause environmental impacts.

In addition, pursuant to Government Code Section 65996(b), Proposition 1A/SB 50 prohibits local agencies from using the inadequacy of school facilities as a basis for denying or conditioning approvals of any “legislative or adjudicative act involving the planning, use, or development of real property.” Satisfaction of the Proposition 1A/SB 50 statutory requirements by a developer is deemed to be “full and complete mitigation.” Therefore, according to SB 50, the payment of the necessary school impact fees for the proposed project would be full and satisfactory CEQA mitigation.

Currently, the NUSD development impact fee rate is $4.79 per sf of new residential development, and $0.78 per sf of new commercial/industrial development. The proposed project would be required to pay the NUSD development impact fee, as part of obtaining necessary permits during the project approval process.

Based on the above, through payment of the NUSD development impact fees, the proposed project would not result in the need for new or altered services related to schools, the construction of which would result in substantial environmental impacts, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-4 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable performance objectives for parks or other
government services; or result in an increase in the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical
23 Mellor, Jennifer, Facilities & Strategic Planning Director. Personal Communication [email] with Joseph Baucum, Senior Associate, Raney Planning & Management, Inc. June 29, 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

deterioration of the facility would occur or be accelerated, or include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Based on the analysis below, the impact is less than significant.

The following discussion applies to the potential for the proposed industrial park and the nonparticipating parcels to result in impacts related to the provision of park and other public facilities. In general, park facilities that could be potentially impacted by the proposed project would only be those provided by the City of Sacramento through the YPCE Department, and the only other public facilities beyond those associated with the SFD, SPD, NUSD, and YPCE would be library services and/or facilities provided the SPL. Given that the proposed off-site force main would be sized to accommodate flows from the project site, installation of the off-site force main would not indirectly induce population growth such that the City of Sacramento and/or the SPL would require new or expansion of existing facilities, the construction of which would result in potential environmental impacts.

Industrial Park and Nonparticipating Parcels
As previously discussed, the proposed project primarily consists of industrial uses, with a limited number of commercial uses also proposed. Thus, the project would not be anticipated to generate a substantial amount of new population within the City of Sacramento, as the project does not include new residential units and the majority of jobs created by the project would be filled primarily by those already residing within the region. In addition, as detailed in the City of Sacramento Park Impact Fee Nexus Study Update, non-residential development employees are expected to use park facilities at a lesser rate than residents. For example, within the areas outside of the Central City or a Housing Incentive Zone, workers are not expected to use neighborhood parks (which are typically designed to serve local residents only).

Rather, employees are expected to use community and citywide parks and facilities, but at approximately 20 percent of the usage exhibited by local residents.24 Based on the above, the proposed project is not expected to substantially increase demand for park or library services provided, respectively, by the YPCE Department and the SPL. Similarly, the proposed project would not be anticipated to result in a substantial increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of a recreational facility would occur or be accelerated. Finally, the proposed project does not include parks or recreational facilities, nor would require the construction or expansion of such facilities.

In addition, in accordance with Sacramento City Code Section 18.56.230, the proposed project would be subject to payment of the City’s Park Development Impact Fee prior to issuance of a building permit. Revenues generated through the project’s payment of the Park Development Impact Fee would ensure the project contributes a fair share to the construction or expansion of any new park facilities deemed necessary 24 City of Sacramento. City of Sacramento Park Impact Fee Nexus Study Update. October 12, 2016.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

by the City, which would be required to be constructed in accordance with applicable policies, regulations, and standards to avoid environmental impacts.

Finally, 16 new libraries are planned for construction in the City and County of Sacramento by 2025. Based on plans set forth in the SPL Authority Facility Master Plan, the SPL already expects to provide 1,007,274 sf of library space throughout the SPL’s service area by 2025. Thus, any new residents within the Sacramento region indirectly induced by the proposed project’s permanent employment positions would reasonably be assumed to not result in the need for new or physically altered SPL facilities to meet performance objectives.

Based on the above, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered park or library services and/or facilities, the construction of which could cause significant environmental impacts, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-5 Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water
drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. Based on the analysis below, the impact is less than significant.

The following discussions apply to the potential for development of the proposed industrial park and nonparticipating parcels require the relocation or construction of new utility infrastructure, the construction or relocation of which could cause significant environmental effects. In addition, the analysis includes evaluation of the proposed offsite improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Individual discussions on the water, wastewater treatment, electric power, natural gas, and telecommunications facilities improvements that would be necessary to serve the project site are provided below.

Water Supply Infrastructure
As previously discussed, the City of Sacramento operates and maintains a 30-inch water transmission main in Bayou Way that terminates near the eastern boundary of the project site (see Figure 4.11-2). The transmission main was originally constructed to “wheel” the City’s water through the County of Sacramento to nearby development areas, including the Sacramento International Airport and Metro Air Park, both located north of the project site, across I-5.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

As shown in Figure 4.11-3, from the City’s existing 30-inch water transmission main in Bayou Way at the northeast corner of the project site, a new 12-inch water line would be extended towards the south along the site’s eastern boundary within “A” Drive.

From the “A” Drive/Airport South Industrial Drive intersection, the new 12-inch line would then extend westward into the project site and form a looped water system within Airport South Industrial Drive and the site’s western and northern property lines.

In total, the new on-site water infrastructure would connect to the City’s existing 30- inch transmission main at three points. In addition, the new on-site water distribution system would connect to existing an eight-inch water line at the southeast corner of the project site at Lanfranco Circle, which serves the Westlake subdivision to the east of the site.

It should be noted that as part of the proposed project, ownership and maintenance of 4700 linear feet of the existing 30-inch SCWA transmission main along the northern boundary of Parcel 5 would be transferred to the City of Sacramento. The transfer of the 30-inch water transmission main to the City from SCWA would require reimbursement to the County for the depreciated value of the transmission main.

During plan review, additional discussion between the County, City, Sacramento International Airport, and the project applicant would be required regarding the matter.

If an agreement is not reached and the transfer of ownership of the 30-inch water transmission main does not occur, a revised design of the water system for the proposed project would be required.

Installation of the new water supply infrastructure, including new fire water lines and hydrants, would occur either in existing road ROWs or in areas proposed for disturbance as part of development of the proposed project. All potential physical environmental impacts that could result from development of the proposed project, including the new water distribution infrastructure, have been evaluated throughout the technical chapters of this EIR. In addition, the new water infrastructure would be designed and constructed in accordance with the applicable standards set forth in Section 27 of the City of Sacramento Standard Specifications, ensuring the new water lines are constructed in conformance with proper materials and sizing. All necessary water conveyance infrastructure for the proposed project would be financed by the project applicant. Furthermore, based on the analysis presented under Impact 4.11-6 below, sufficient water supplies exist to serve the proposed project.

Finally, the Sacramento City Council adopted Resolutions 2023-0338 and 2023-0368, respectively, to adjust the Water Development Fee, Sewer Development Fee, and Combined Sewer Development Fee, as well as establish the Drainage Development Fee, to align with the City’s updated Nexus Studies. The aforementioned resolutions provide for an effective date for the new utility development fees of January 22, 2024.

The proposed project would be subject to the utility development fees in effect at the time of building permit application submittal.

Based on the above, development of the proposed project would not require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects, and a less-thansignificant impact would occur.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Figure 4.11-3
Proposed City/County Water System
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Wastewater Infrastructure
As previously discussed, an existing SacSewer trunk line is located within Greg Thatch Circle, to the east of SR 99. From the existing trunk line, flows are conveyed to the 48- inch SacSewer North Natomas interceptor line, which connects with the trunk line to the southeast of the Club Center Drive/Hampton Falls Way intersection and proceeds south of Del Paso Road within East Commerce Way. As detailed in the Project Description chapter of this EIR, sanitary sewer conveyance service within the project site would be provided through a gravity system. As shown in Figure 4.11-4, new eightinch sewer lines would be installed within the project site’s parcels, which would convey flows to a new sewer line in Airport South Industrial Drive ranging in diameter between 12 and 18 inches.

From the sewer line in Airport South Industrial Drive, flows would be directed to a new pump station sited within Lot F. From the new pump station, flows would be conveyed to the existing SacSewer North Natomas interceptor line by way of a force main that would extend from the northeast corner of the site and proceed towards the south within Bayou Way and El Centro Road. At the El Centro Road/Del Paso Road intersection, the off-site force main would connect to the North Natomas interceptor line through one of three optional alignments.

As shown in Figure 3-4 of the Project Description chapter of this EIR, each option would require the force main to proceed east. Option 1 would include installation of the force main within a City highway buffer parallel with the westerly side of I-5. About

0.5-mile south of Del Paso Road, the force main would cross under I-5 within City ROW and then discharge into the North Natomas interceptor line within East Commerce Way. Options 2 and 3 would route the force main either north or south of the I-5 on/off ramps, cross under I-5, and then proceed within Del Paso Road towards East Commerce Way in existing ROW and/or previously disturbed areas.

All potential physical environmental impacts that could result from development of the proposed project, including new on- and off-site sewer infrastructure, have been evaluated throughout the technical chapters of this EIR. In addition, the new sewer infrastructure would be designed and constructed in accordance with the applicable standards set forth in the SacSewer Standards and Specifications, ensuring the new sewer lines and pump station are constructed in conformance with proper materials and sizing. All necessary sewer conveyance infrastructure for the proposed project would be financed by the project applicant. Furthermore, based on the analysis presented under Impact 4.11-7 below, sufficient capacity exists at the SRWTP to serve the proposed project.

Based on the above, development of the proposed project would not require or result in the relocation or construction of new or expanded sewer facilities, the construction or relocation of which could cause significant environmental effects, and a less-thansignificant impact would occur.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Figure 4.11-4
Schematic Sewer System Layout
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Electricity, Natural Gas, and Telecommunications Infrastructure The proposed project would include new connections to existing underground electricity, natural gas, and telecommunications infrastructure located in the project vicinity within I-5 and Power Line Road. Installation of the new electricity, natural gas, and telecommunications infrastructure would occur either in areas that have been previously disturbed or in areas proposed for disturbance as part of development of the proposed project. Consistent with the provisions set forth in Sacramento City Code Section 12.12.260, new electricity, natural gas, and telecommunications infrastructure would be required to be installed underground.

Based on the above, development of proposed project would not require or result in the relocation or construction of new or expanded electricity, natural gas, and telecommunications facilities, the construction or relocation of which could cause significant environmental effects, and a less-than-significant impact would occur.

Conclusion
Based on the above, development of the proposed project would not require or result in the relocation or construction of new or expanded water, wastewater, electricity, natural gas, and telecommunications facilities, the construction or relocation of which could cause significant environmental effects, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-6 Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry, and multiple dry years. Based on the analysis below, the impact is less than significant.

The Targeted MSR evaluated total buildout of the project site in accordance with the proposed land uses. Thus, the following discussion applies to the potential for the City to have sufficient water supplies available to serve the proposed industrial park and the nonparticipating parcels, as well as reasonably foreseeable future development during normal, dry, and multiple dry years. The proposed off-site force main would not generate water demand. As such, the proposed off-site force main would not result in potential impacts related to water supplies.

Industrial Park and Nonparticipating Parcels
The City’s 2020 UWMP includes a water service reliability assessment of the City’s projected supplies and demands during normal, single dry, and five consecutive dry years. Under the various water year types, the total annual water supply sources available are compared to the total annual projected water use for the City’s water service area from 2025 to 2045 in five-year increments.

As previously discussed, Table 4.11-1 above summarizes the supply and demand of each water year type provided in the 2020 UWMP. As shown above, the City is projected to have a surplus of water supplies in all water year types through 2045.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

With respect to the demand anticipated to be generated by the proposed project, the Targeted MSR incorporates results from the modeling conducted as part of the Preliminary Water Study to estimate the project’s water demands, which are summarized in Table 4.11-5.

Table 4.11-5
Proposed Project Water Demand Summary
Land Use Acres
ADD Unit Water Demand
AFY/Acre AFY
Commercial 13.4 2 26.8
Industrial 235.6 0.9 212.04
Nonparticipating 83 0.9 74.7
Total 332 -- 313.54
Source: Wood Rodgers, 2023.

Based on the data presented in Table 4.11-5, the Targeted MSR determined that the total average daily demand for the proposed project would be 313.54 AFY. As shown in Table 4.11-1, the City is anticipated to have a surplus of water supplies in all hydrologic conditions through 2045, and the lowest projected surplus is expected to be 198,436 AFY in 2045 during the fifth consecutive year of drought. Therefore, given the substantial amount of surplus projected for the City’s water supplies in all hydrologic conditions, the City’s existing water supplies would be able to accommodate the demand anticipated to be generated by the City’s existing commitments, as well as the water demand projected for the proposed project.

Based on the above, the City would have sufficient water supplies available to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-7 Result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

Based on the analysis below, the impact is less than
significant.

The Targeted MSR evaluated total buildout of the project site in accordance with the proposed land uses. Thus, the following discussion applies to the potential for the proposed industrial park and the nonparticipating parcels to generate wastewater flows in excess of the SRWTP’s existing capacity. The proposed off-site force main would not generate wastewater flows. Instead, the off-site force main would serve to convey wastewater flows from the project site to the SRWTP. As such, the proposed off-site force main would not result in potential impacts related to wastewater treatment.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Industrial Park and Nonparticipating Parcels
Based on the Preliminary Site Plan (see Figure 3-3 in the Project Description chapter of this EIR), the Sewer Study estimates that the proposed project’s total sewer demand would be 2,619 ESDs (see Table 4.11-4). Based on the ESDs, the Targeted MSR found that the project’s cumulative ADWF and PWWF demand is estimated to be 0.81 mgd and 2.09 mgd, respectively. It should be noted that the proposed on-site sewer pump station would be designed to meet the ultimate PWWF.

According to the Targeted MSR, the SRWTP is permitted to treat ADWF of 181 mgd.

Since the opening of the SRWTP, system improvements have been made to accommodate regional growth and to add capacity to SacSewer’s interceptor system.

In 2014, the SRWTP’s ADWF was approximately 141 mgd. Although future growth in the SacSewer service area will increase demands for wastewater service and use the remaining capacity of the SRWTP, regional water conservation efforts have resulted in a reduction in water use, which has in turn, increased the available capacity at the SRWTP. For instance, SacSewer anticipates per capita water consumption to decline through the continued installation of water meters and water conservation measures.

As such, a substantial amount of additional water conservation is expected throughout SacSewer’s service area, and the wastewater treatment provider expects the existing 181 mgd ADWF capacity to be sufficient through 2050. Accordingly, the Targeted MSR concludes that the SRWTP would maintain sufficient capacity to treat wastewater flows generated by the proposed project, in addition to the provider’s existing commitments.

Based on the above, the proposed project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate wastewater treatment capacity to serve the project’s projected demand in addition to the provider’s existing commitments. Therefore, a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.11-8 Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals, or conflict with federal, State, and local management and
reduction statutes and regulations related to solid waste.

Based on the analysis below, the impact is less than
significant.

Solid waste generated as part of construction and operation of the project site would be disposed of at the Kiefer Landfill. Thus, the following discussion applies to the potential for the proposed industrial park and the nonparticipating parcels to result in impacts related to solid waste disposal. In addition, the analysis includes evaluation of the proposed off-site improvements.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
As previously discussed, solid waste from the City is disposed of at the SRTS, NARS, Sacramento County Kiefer Landfill, as well as other facilities, including the Yolo County Central Landfill, L and D Landfill, the Florin Perkins Public Disposal Site, and the Elder Creek Transfer Station. The Kiefer Landfill is the primary location for the City of Sacramento’s disposal of solid waste. The waste delivered to the landfill is from municipal and industrial sources, with an average of approximately 6,300 tons per day accepted. According to CalRecycle, the Kiefer Landfill is permitted to accept a maximum of 117,400,000 cubic yards of waste.25 The landfill has a remaining capacity of 112,900,000 cubic yards and is anticipated to cease operations by 2064.

Overall, following development of project site, the proposed project would result in a maximum building square footage of 6,707,500 sf. According to the U.S.

Environmental Protection Agency (USEPA) report, Estimating 2003 Building-Related Construction and Demolition Materials Amounts, non-residential construction activities generate an average of 4.34 pounds per square foot (lbs/sf) of waste.26 Therefore, applying such an amount to buildout of the proposed project would produce approximately 29,110,550 lbs (14,555.3 tons) of construction waste (4.34 lbs/sf X 6,707,500 sf).

The construction waste estimate presented above represents a conservative analysis of the maximum potential waste production from construction of the proposed project.

The CALGreen Code requires at least 65 percent diversion of construction waste for projects permitted after January 1, 2017. As such, a minimum of 9,460.9 tons of waste would be diverted away from landfill disposal during construction. Considering the applicable CALGreen Code requirements, buildout of the proposed project would be anticipated to produce up to 5,094.4 tons of waste during construction. In addition, construction waste would be generated as part of installation of the proposed off-site force main. Construction waste generation represents a short-term increase in waste generation. Considering that the Kiefer Landfill has a remaining capacity of 96.1 percent of the total permitted capacity of the landfill, the proposed project’s construction waste would represent only an incremental contribution to the waste received at the landfill, and a less-than-significant impact would occur.

Operational solid waste generation from the proposed project has been estimated based on an average waste generation rate for employees of industrial uses, as published by CalRecycle.27 The total number of employees would produce approximately 35,720 lbs/day (17.86 tons/day) of operational solid waste. The Kiefer Landfill has a permitted throughput of 10,815 tons/day. Considering that the landfill currently accepts 6,300 tons/day, the landfill would be able to accommodate the operational waste generated by the proposed project. In addition, considering that the 25 California Department of Resources Recycling and Recovery. SWIS Facility/Site Activity Details Sacramento County Landfill (Kiefer) (34-AA-0001). Available at:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2070?siteID=2507. Accessed August 2023. 26 U.S. Environmental Protection Agency. Estimating 2003 Building-Related Construction and Demolition Materials Amounts. 2009. 27 California Department of Resources Recycling and Recovery. Estimated Solid Waste Generation Rates. Available at: https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed June 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Kiefer Landfill has a remaining capacity of 96.1 percent, the proposed project’s operational waste would represent only an incremental contribution to the waste received at the landfill.

Based on the above, the proposed project would not generate solid waste in excess of State or local standards or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. In addition, the project would not conflict with applicable federal, State, and local management and reduction statutes and regulations related to solid waste. Thus, a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

Cumulative Impacts and Mitigation Measures
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

The cumulative setting for impacts related to public services and utilities encompasses buildout of the applicable service areas of public service and utility providers discussed in this chapter.

Additional detail regarding the cumulative project setting can be found in Chapter 6, Statutorily Required Sections, of this EIR.

4.11-9 Cumulative impacts to public services. Based on the analysis below, the cumulative impact is less than significant.

The following discussion provides an analysis of potential cumulative impacts related to public services associated with development of the proposed industrial parks, nonparticipating parcels, and development within the City of Sacramento 2040 General Plan policy area. Given that the proposed off-site force main would be sized to accommodate flows from the project site, installation of the off-site force main would not indirectly induce population growth such that new or expansion of existing public facilities would be required, the construction of which would result in potential environmental impacts.

Industrial Park and Nonparticipating Parcels
Potential cumulative impacts related to fire and police protection services, schools, public services and government facilities, and parks and recreation are discussed below.

Fire Protection Services
Cumulative development, in conjunction with the proposed project, would increase the demand for fire protection services provided by the SFD. As discussed above, the SFD Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

seeks to respond to fire incidents and medical emergencies within four minutes, consistent with General Plan Policies PFS-1.14, -1.15, and -1.16.

In addition, the foregoing policies establish the City’s commitment to ensuring the SFD has the necessary levels of facilities, apparatus, equipment, and staffing. The City funds the SFD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. In addition, new development within the City is subject to applicable development impact fees to ensure a fair-share contribution is made to finance the purchase of new or expansion of existing SFD facilities, apparatus, and equipment necessary for the purposes of maintaining adequate service levels. Similar to the proposed project, cumulative development within the City’s General Plan policy area would be subject to applicable taxes and fees, including, but not limited to, property taxes, franchise taxes, business license taxes, and license and permit fees. Additionally, new residents generated by cumulative development would be subject to local sales taxes. Thus, revenues generated through fee payments associated with cumulative development would pay fair shares toward any new SFD facilities deemed necessary by the City, all of which would be required to be designed and constructed in accordance with applicable regulations and standards, and if necessary, undergo CEQA review.

Finally, as discussed above, through the automatic aid agreement between fire agencies within Sacramento County, the most efficient fire protection and emergency medical services are available to properties throughout the County. All structures included as part of buildout of the adopted General Plan would be constructed consistent with the CBC and CFC. Compliance with the CBC and CFC would reduce the potential for fires to occur within the policy area, which would reduce the demand for fire protection services in the City.

Based on the above, cumulative development within the City of Sacramento, in conjunction with the proposed project, would result in a less-than-significant impact related to the need for new or improved fire protection facilities, the construction of which could cause significant environmental impacts.

Law Enforcement Services
Cumulative development, in conjunction with the proposed project, would increase the demand for law enforcement services provided by the SPD. As discussed above, the SPD does not have an adopted officer-to-resident ratio, but unofficially, the SPD maintains an unofficial goal of 2.0 to 2.5 sworn police officers per 1,000 residents and one civilian support staff per two sworn officers. Additionally, the Sacramento General Plan does not establish a specific response time standard for emergency calls for the SPD.

General Plan Policies PFS-1.14, -1.15, and -1.16 establish the City’s commitment to ensuring the SPD has the necessary levels of facilities, equipment, and staffing.

Accordingly, revenues generated through payment of applicable permit application fees, as well as development impact fees established pursuant to Sacramento City Code Section 18.24.050, ensure new development pays a fair share for police protection services provided by the SPD. Cumulative development within the General Plan policy area would be subject to applicable permit application and development Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

impact fees. Additionally, new residents generated by cumulative development would be subject to local sales taxes. Thus, revenues generated through permit application and development impact fee payments associated with cumulative development would pay fair shares toward any new SPD facilities deemed necessary by the City, all of which would be required to be designed and constructed in accordance with applicable regulations and standards, and if necessary, undergo CEQA review.

Based on the above, cumulative development within the City of Sacramento would not result in the need for new or improvements to existing police protection facilities, the construction of which could cause significant environmental impacts, and a less-thansignificant impact would occur.

School Facilities
Cumulative development, in conjunction with the proposed project, would increase the demand for school services provided by the NUSD. However, as discussed above, development as part of cumulative buildout of the General Plan policy area would be subject to NUSD development impact fees, which fund the cost of improving and expanding school facilities and equipment needed to accommodate additional student population induced by new development. Payment of the fees would be deemed to be “full and complete mitigation,” as established by Proposition 1A/SB 50. In addition, Measure L, a $172 million school facilities bond to serve NUSD schools, was approved by voters in November 2018. Funds from Measure L serve to upgrade existing facilities and construct new facilities identified by the NUSD in the 2017 Master Plan Update.

Based on the above, cumulative development within the City of Sacramento would not result in the need for new or improvements to existing school facilities, the construction of which could cause significant environmental impacts, and a less-than-significant impact would occur.

Parks and Other Public Facilities
Cumulative development, in conjunction with the proposed project, would increase the demand for park facilities operated by the City of Sacramento YPCE Department.

However, development facilitated by buildout of the General Plan policy area would be subject to the City’s Park Development Impact Fee, in accordance with Sacramento City Code Section 18.56.230. Revenues generated through projects’ payments of the Park Development Impact Fee would pay the projects’ fair shares toward any new park facilities deemed necessary by the City, all of which would be required to be designed and constructed in accordance with applicable regulations and standards, and if necessary, undergo CEQA review. In addition, based on plans set forth in the SPL Authority Facility Master Plan, the SPL already expects to provide 1,007,274 sf of library space throughout the SPL’s service area by 2025. Thus, the increase in demand for library services generated by cumulative development has already been anticipated.

Based on the above, cumulative development within the City of Sacramento, in conjunction with the proposed project, would result in a less-than-significant impact related to the need for new or improved parks and/or other facilities, the construction of which could cause significant environmental impacts.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Conclusion
Based on the above, the proposed project, in combination with future buildout of the General Plan policy area, would result in a less-than-significant cumulative impact related to public services and recreation.

Mitigation Measure(s)
None required.

4.11-10 Increase in demand for utilities and service systems associated with the proposed project, in combination with future buildout of the Sacramento General Plan. Based on the analysis below, the cumulative impact is less than significant.

The following discussion provides an analysis of potential cumulative impacts related to utilities and service systems associated with development of the proposed industrial parks, nonparticipating parcels, the off-site force main, and development within the City of Sacramento General Plan policy area.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
The following discussions provide an analysis of the proposed project’s contribution to cumulative impacts associated with water supply, wastewater treatment, dry utilities, and solid waste within the City of Sacramento.

Water Supply
Cumulative development, in conjunction with the proposed project, would result in increased demand for water supplies provided by the City. However, as discussed under Impact 4.11-6 and summarized in Table 4.11-5, the City is anticipated to have ample supply to accommodate demand generated by buildout of the City’s General Plan policy area in normal, single dry, and multiple dry years through 2045.

In addition, new water infrastructure required as part of cumulative development within the City would be required to be designed and constructed in compliance with the applicable standards set forth in Section 27 of the City of Sacramento Standard Specifications. Compliance with the foregoing standards would ensure new water lines installed as part of buildout of the City of Sacramento are constructed in conformance with proper materials and sizing.

Based on the above, adequate water supply would be available to serve cumulative development within the City of Sacramento, in conjunction with the proposed project, and a less-than-significant impact would occur.

Wastewater Treatment
Cumulative development, in conjunction with the proposed project, would result in increased demand for wastewater treatment services provided by the SRWTP.

According to the Targeted MSR, the SRWTP is permitted to treat ADWF of 181 mgd.

However, regional water conservation efforts have resulted in a reduction in water use, which has in turn, increased the available capacity at the SRWTP. For instance, Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

continued installation of water meters and water conservation measures have reduced water consumption per capita. As such, a substantial amount of additional water conservation is expected throughout SacSewer’s service area, and the wastewater treatment provider expects the existing 181 mgd ADWF capacity to be sufficient through 2050.

In addition, new sanitary sewer conveyance infrastructure required as part of cumulative development within the City of Sacramento would be required to be designed and constructed in accordance with the applicable standards set forth in the SacSewer Standards and Specifications. Compliance with the foregoing standards would ensure new sewer lines installed as part of buildout of the General Plan are constructed in conformance with proper materials and sizing.

Based on the above, adequate wastewater treatment services would be available to serve cumulative development within the City of Sacramento, in conjunction with the proposed project, and a less-than-significant impact would occur.

Electricity, Natural Gas, and Telecommunications Facilities Environmental effects associated with the construction of new or expanded electricity, propane, and telecommunications facilities would primarily be project-specific, rather than cumulative. As noted under Impact 4.11-5, while the project would include new connections to existing electrical, natural gas, and telecommunications infrastructure located in the project vicinity, substantial extension of existing off-site infrastructure would not be required. Therefore, the proposed project would result in a less-thansignificant cumulative impact related to construction of new or expanded electricity, natural gas, and telecommunications facilities.

Solid Waste
As noted previously, according to CalRecycle, the Kiefer Landfill has a remaining capacity of 112,900,000 cubic yards and is anticipated to cease operations by 2064.

Construction waste generated by development facilitated by buildout of the General Plan policy area would be required to comply with the applicable provisions of the CALGreen Code. The CALGreen Code requires at least 65 percent diversion of construction waste for projects permitted after January 1, 2017. In addition, commercial and residential solid waste collected and processed by the City is sorted at the SRTS, which accepts waste from the southern region of the City, and the NARS, which accepts waste from the north region of the City. Recyclables are separated from the waste to be disposed of at the City’s landfills, which further preserves remaining capacity at the Kiefer Landfill. Considering the remaining capacity at the landfill to serve future development, adequate capacity would be available to serve cumulative development within the City of Sacramento, in conjunction with the proposed project, and a less-than-significant impact would occur.

Conclusion
Based on the above, the proposed project, in conjunction with buildout of the General Plan policy area, would not result in any significant cumulative impacts related to increased demand for utilities and service systems within the City of Sacramento.

Thus, a less-than-significant cumulative impact would occur.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.11 – Public Services, Utilities, and Service Systems

Mitigation Measure(s)
None required.

4.12 TRANSPORTATION

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

4.12.1 INTRODUCTION
The Transportation chapter of the EIR addresses the transportation conditions within the project vicinity, including consideration of proposed project impacts related to pedestrian facilities, bicycle facilities, transit facilities and services, vehicle miles traveled (VMT), and traffic safety issues. The information contained within this chapter is primarily based on a Traffic Impact Analysis,1 Trip Generation and Distribution Memo,2 and VMT Analysis Memo3 prepared for the proposed project by DKS (see Appendix N through Appendix P of this EIR), as well as a VMT Mitigation Memorandum prepared by the City’s Public Works Department (see Appendix Q).4 Additional information was sourced from the City of Sacramento 2040 General Plan,5 and the City of Sacramento 2040 Master EIR (MEIR).6

4.12.2 EXISTING ENVIRONMENTAL SETTING
The section below describes the physical and operational characteristics of the existing transportation system within the project area, including the surrounding roadway network, transit, bicycle, and pedestrian facilities.

Existing Roadways
The following sections provide a summary of the existing roadways within the project area.

Interstate 5
Interstate 5 (I-5) is a north-south freeway facility serving local and interregional traffic within the Sacramento region. I-5 primarily links South Sacramento, the Central Business District in Downtown Sacramento, Natomas, and the Sacramento International Airport. I-5 is also used as a primary route for long-distance traffic, including truck traffic. I-5 is generally about two to four lanes in each direction in the project vicinity.

Power Line Road
Power Line Road is a north-south minor collector, perpendicular to I-5, located along the west side of the project site. To the north, the roadway intersects with Bayou Way and passes over I5. To the south, Power Line Road intersects with Del Paso Road and ends at Garden Highway.

Power Line Road has one lane in each direction with narrow, unpaved shoulders. 1 DKS. Sacramento Airport South Industrial Development Traffic Impact Analysis. June 5, 2023. 2 DKS. Trip Generation and Distribution Memorandum. March 10, 2023. 3 DKS. VMT Analysis Memorandum. March 10, 2023. 4 City of Sacramento Department of Public Works. P21-017 Airport South Industrial - VMT Mitigation Measures.

September 5, 2023. 5 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 6 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023.

4.12 TRANSPORTATION
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Bayou Way
Bayou Way is an east-west local rural road located on the north side of the project site. To the west, the roadway intersects with Power Line Road. To the east, Bayou Way intersects with Metro Air Parkway and continues to the Westlake neighborhood, where the roadway becomes El Centro Road. Bayou Way has one lane in each direction. East of the project site, El Centro Road is separated by a painted median and has painted bike lanes in both directions.

Del Paso Road
Del Paso Road is an east-west minor arterial located approximately 0.5-mile south of the project site. To the west, the roadway intersects with Power Line Road. To the east, Del Paso Road intersects Hovnanian Drive and bisects the suburban Westlake and Sundance Lake neighborhoods. To the east, the roadway is a major arterial and has ramps connected to I-5. The segment of the roadway directly to the south of the project site has one lane in each direction. To the east, the roadway expands to three lanes in each direction with additional left turn lanes and a raised median.

El Centro Road
El Centro Road is a north-south arterial located approximately 0.5-mile east of the project site. El Centro Road is a planned four-lane minor arterial. To the north, the roadway becomes a two-lane facility to Bayou Way. To the south, the roadway intersects with Del Paso Road and runs alongside the suburban neighborhoods of Westlake and Sundance Lake. North of Del Paso Road, the roadway has two southbound lanes, one northbound lane, and a raised median with left turn lanes. To the south of Del Paso Road, the roadway has two lanes in each direction with a raised median.

Metro Air Parkway
Metro Air Parkway is a north-south arterial perpendicular to I-5 that bisects the project site. Metro Air Parkway intersects Bayou Way to the south, passes over I-5, and continues north to intersect with West Elkhorn Boulevard. Within the project area, Metro Air Parkway currently has one lane per direction and is being widened to have two lanes in each direction. In the future, the roadway is anticipated to be widened to three lanes in each direction. Metro Air Parkway is considered a thoroughfare within the County.

Elkhorn Boulevard
Elkhorn Boulevard is an east-west major arterial located north of the project site. To the east, Elkhorn Boulevard connects with State Route (SR) 99. To the west, Elkhorn Boulevard connects with Power Line Road. Elkhorn Boulevard is currently one lane per direction except in front of Northlake, where the roadway has three eastbound lanes and two westbound lanes. Elkhorn Boulevard is anticipated to be widened as a six-lane major arterial/thoroughfare.

Pedestrian, Bicycle and Transit Facilities
The sections below describe the existing pedestrian, bicycle and transit facilities located within the vicinity of the project site.

Pedestrian Facilities
The pedestrian system in the project site vicinity consists of sidewalks along Del Paso Road and El Centro Road as the roadways pass through the Sundance Lake and Westlake neighborhoods, as well as an internal trail system within the neighborhoods. In addition, a sidewalk is located along Bayou Way just east of the project site, associated with the existing self-storage facility.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Pedestrian facilities are not currently located along the project site frontage, as the location is currently undeveloped.

Bicycle Facilities
The City of Sacramento includes the following bicycle system classifications:
 Bicycle paths (Class I) provide a completely separate right-of-way (ROW) and are designated for the exclusive use of bicycles and pedestrians, with vehicle cross-flow minimized.
 Bicycle lanes (Class II) provide a restricted ROW and are designated for the use of bicycles for one-way travel with a striped lane on a street or highway. Bicycle lanes are generally a minimum of five feet wide. Vehicle parking and vehicle/pedestrian cross-flow are permitted.
 Bicycle routes (Class III) provide a ROW designated by signs or pavement markings for shared use with motor vehicles. These include “sharrows” or shared-lane markings to highlight the presence of bicyclists.
 Bikeways (Class IV) are cycle tracks or “separated” bikeways that provide a ROW designated exclusively for bicycle travel within a roadway and are protected from other vehicle traffic by physical barriers, including, but not limited to grade separation, flexible posts, inflexible vertical barriers such as raised curbs, or parked cars.

The bicycle system in the site vicinity consists of infrastructure around the Westlake and Sundance Lake neighborhoods. The bicycle system consists of a Class I bike path and Class II bike lanes to the south and east of the project site. Figure 4.12-1 illustrates the existing bicycle system in the project vicinity.

Transit System
The project area is served by the local Sacramento Regional Transit (SacRT) bus service (Routes 13 and 142) as well as North Natomas Jibe (Lines 171 and 174), as illustrated in Figure 4.12-2.

SacRT Bus Route 13 operates along Del Paso Road, south of the project site, and SacRT Bus Route 142, which is a peak-only line, operates along I-5 and stops north of the project site. North Natomas Jibe Line 171 passes along the project site on Callison Drive, and North Natomas Jibe Line 174 operates on Del Paso Road southeast of the project site. However, Jibe Line 174 does not include any stops in the vicinity of the site.

Jibe routes have traditionally ran from Natomas to Downtown during the morning peak hour and from Downtown to Natomas during the afternoon peak hour. However, it should be noted that, due to continued low ridership caused by the COVID19 pandemic, the North Natomas Jibe has suspended all service.

It should also be noted that while the project site is not currently served by SacRT Light Rail Transit (LRT), as outlined in the Sacramento Area Council of Governments (SACOG) Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS), a future SacRT LRT Green Line station is planned within 0.5-mile of the project boundary at Elkhorn Blvd and Power Line Road.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Figure 4.12-1
Existing Bicycle Network
Project Site
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12
– Transportation

Figure 4.12-2
Existing Transit Network
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Vehicle Miles Traveled
VMT is a measure of the total amount of vehicle travel occurring on a given roadway system. VMT is a metric that accounts for the number of vehicle trips generated and the length or distance of those trips. For analysis purposes, VMT refers to automobile VMT, specifically passenger vehicles and light trucks; heavy truck traffic is typically excluded. VMT does not directly measure traffic operations; instead, VMT is a measure of transportation network use and efficiency, especially when expressed as a function of population (i.e., VMT per capita).

As a result of Senate Bill (SB) 743, passed in 2013, local jurisdictions may not rely on vehicle level of service (LOS) and similar measures related to delay as the basis for determining the significance of transportation impacts under CEQA. Thus, consistent with the CEQA Guidelines, VMT is the primary metric used to identify transportation impacts to roadway systems within this chapter. The City of Sacramento currently uses VMT procedures and standards consistent with technical guidance published by the Governor’s Office of Planning and Research (OPR). The City of Sacramento has an average VMT per employee of 17.33.

4.12.3 REGULATORY CONTEXT
Existing transportation policies, laws, and regulations that would apply to the proposed project are summarized below and provide a context for the impact discussion related to the project’s consistency with the applicable regulatory conditions. Federal plans, policies, regulations, or laws related to transportation and circulation are not directly applicable to the proposed project. Rather, the analysis presented herein focuses on State and local regulations, which govern the regulatory environment related to transportation and circulation at the project level.

State Regulations
The following are the regulations pertinent to the proposed project at the State level, organized chronologically.

Senate Bill 743
In 2013, SB 743 was passed to amend Sections 65088.1 and 65088.4 of the Government Code, amend Sections 21181, 21183, 21186, 21187, 21189.1, and 21189.3 of the Public Resources Code (PRC), to add Section 21155.4 to the PRC, to add Chapter 2.7 (commencing with Section 21099) to Division 13 of the PRC, to add and repeal Section 21168.6.6 of the PRC, and to repeal and add Section 21185 of the PRC, relating to environmental quality. In response to SB 743, OPR has updated the CEQA Guidelines to include new transportation-related evaluation metrics. In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package along with an updated Technical Advisory related to Evaluating Transportation Impacts in CEQA. Full compliance with the Guidelines became effective July 2020.

As a result of SB 743, and Section 15064.3 of the CEQA Guidelines, as discussed in further detail below, local jurisdictions may no longer rely on vehicle LOS and similar measures related to delay as the basis for determining the significance of transportation impacts under CEQA, and instead a VMT metric should be evaluated.

Technical Advisory on Evaluating Transportation Impacts in CEQA In December of 2018, the OPR published the Technical Advisory on Evaluation Transportation Impacts in CEQA (Technical Advisory), which is a guidance document to provide advice and recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. The Technical Advisory is intended to be a resource for the public to use at their discretion, and the OPR does not enforce any part of the recommendations contained therein.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

The Technical Advisory includes recommendations regarding methodology, screening thresholds, and recommended thresholds per land use type.

Vehicle Miles Traveled-Focused Transportation Impact Study Guide In May of 2020, the California Department of Transportation (Caltrans) adopted the Vehicle Miles Traveled-Focused Transportation Impact Study Guide (TISG) to provide direction to lead agencies regarding compliance with SB 743. The TISG replaces the Caltrans’ 2002 Guide for the Preparation of Traffic Impact Studies and is for use with local land use projects, not for transportation projects on the State Highway System. The objectives of the TISG are to provide:7 a) Guidance in determining when a lead agency for a land use project or plan should analyze possible impacts to the State Highway System, including its users. b) An update to the Guide for the Preparation of Traffic Impact Studies (Caltrans, 2002) that is consistent with SB 743 and the CEQA Guidelines adopted on December 28, 2018. c) Guidance for Caltrans land use review that supports state land use goals, state planning priorities, and GHG emission reduction goals.
d) Statewide consistency in identifying land use projects’ possible transportation impacts, to the State Highway System, and to identify potential non-capacity increasing mitigation measures.
e) Recommendations for early coordination during the planning phase of a land use project to reduce the time, cost, and/or frequency of preparing a Transportation Impact Study or other indicated analysis.

Caltrans has jurisdiction over State highways. Therefore, Caltrans controls all construction, modification, and maintenance of State highways, and any improvements to such roadways require Caltrans approval.

Traffic Safety Bulletin 20-02-R1: Interim Local Development Intergovernmental Review Safety Review Practitioners Guidance In December 2020, Caltrans released Traffic Safety Bulletin 20-02-R1: Interim Local Development Intergovernmental Review Safety Review Practitioners Guidance (Traffic Safety Guidance). The purpose of the Caltrans Traffic Safety Guidance is to provide instructions to Caltrans personnel, lead agencies, developers, and consultants conducting safety reviews for proposed land use projects and plans affecting the State Highway System. The Guidance establishes the safety impact review expectations for Caltrans and lead agencies to comply with CEQA, and is intended to be used by lead agencies, developers, and consultants as a model for analyzing the safety impacts of proposed land use projects and plans on local roadways. The Guidance prioritizes vulnerable users and communities; enhances safety for pedestrians, bicycle, transit and vehicular modes; and applies both reactive and systemic perspectives.

Local Regulations
The following are the local environmental laws and policies relevant to transportation.

Metropolitan Transportation Plan/Sustainable Communities Strategy The SACOG MTP/SCS is a federally mandated, long-range planning document for identifying and programming roadway improvements throughout the region, including the City of Sacramento. 7 California Department of Transportation. Vehicle Miles Traveled-Focused Transportation Impact Study Guide. May 20, 2020.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

The MTP/SCS is required to be a 20-year multimodal transportation plan that is financially feasible, achieves health standards for clean air, and addresses statewide climate goals.

Sacramento County Transportation Analysis Guidelines
The Sacramento County Transportation Analysis Guidelines were published in September 2020.

The Guidelines are intended to provide a clear and consistent technical approach to conducting transportation analyses for Sacramento County land development and transportation projects in compliance with SB 743. They establish analysis techniques for transportation studies based on the current state-of-the-practice in transportation planning and engineering. For example, the Guidelines set forth a number of thresholds for use in analyses within the County, including VMT thresholds per region. The significance thresholds for Sacramento County and recommended VMT metric used to measure VMT are described by land use type.

City of Sacramento 2040 General Plan
The following goals and policies from the City of Sacramento 2040 General Plan related to transportation are applicable to the proposed project.

Land Use and Placemaking Element
Goal LU-4 Walkable, transit-oriented centers and corridors that concentrate new jobs, housing, and entertainment opportunities to support frequent, reliable transit service and foster connected, accessible neighborhoods.

Policy LUP-4.10 Multi-Modal Access. The City shall require that new development provide bicycle, pedestrian, and transit access where appropriate to reduce the need for onsite parking and to improve the pedestrian experience within corridors and centers with street trees and landscaping.

Mobility Element
Goal M-1 An equitable, sustainable multimodal system that provides a range of viable and healthy travel choices for users of all ages, backgrounds, and abilities.

Policy M-1.2 User Prioritization. The City shall prioritize mobility, comfort, health, safety, and convenience for those walking, followed by those bicycling and riding transit, ahead of design and operations for those driving.

Policy M-1.5 Street Design Standards. The City shall maintain street design and operations standards that prioritize comfort and travel time for walking, bicycling, and transit, while managing vehicle speeds and traffic volumes, updating them as best practices evolve.

Policy M-1.11 Increase Bicycling and Walking. The City shall strive to increase bicycling and walking citywide so that it can meet its equity, reduced vehicle miles traveled, and sustainability goals.

Policy M-1.13 Walkability. The City shall design streets to prioritize walking by including design elements such as the following:

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

 Grid networks that provide high levels of
connectivity;
 Closely spaced intersections;
 Frequent and low-stress crossings;
 Wide, unobstructed walkable sidewalks;
 Separation from vehicle traffic;
 Street trees that provide shading; and
 Minimal curb cuts.

Policy M-1.15 Improve Walking Connectivity. The City shall require new subdivisions, new multi- unit dwelling developments, and new developments along commercial corridors to include well-lit, tree-shaded walkways where feasible, that provide direct links to the public realm or adjacent public destinations such as transit stops and stations, schools, parks, and shopping centers.

Policy M-1.16 Barrier Removal. The City shall remove barriers to walking, where feasible, and work with utility companies to remove barriers to allow people of all abilities to move with comfort and convenience throughout the city, including through the
following:
 Provision of curb ramps, crosswalks, and
overpasses;
 Relocation of infrastructure or street furniture that impedes travel pathways;
 Reducing or consolidating driveways and curb cuts;
 Providing long and short-term bicycle and scooter
parking to minimize sidewalk obstructions; and
 Creation of additional walking entrances to important destinations like schools, parks, and commercial
areas.

Policy M-1.17 Improve Bicycling Connectivity. The City shall plan and seek funding for a continuous, low-stress bikeway network consisting of bicycling-friendly facilities that connect neighborhoods with destinations and activity centers throughout the city.

Policy M-1.18 Bicycling Safety. When designing projects, the City shall prioritize designs that strengthen the protection of people bicycling such as improvements that increase visibility of bicyclists, increase bikeway widths, raise bikeways, design safer intersection crossings and turns, and separate bikeways from traffic wherever feasible.

Policy M-1.19 Walking Safety. When designing projects, the City shall prioritize designs that encourage walking and improve walking safety best practice designs and considerations for efficiencies in walking.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Policy M-1.23 Transit Priority. Where appropriate, the City shall support transit by incorporating features such as bus bulbs, traffic signal priority, queue jumps, and other solutions into priority corridors to improve transit speed, reliability, and operating efficiency while reducing passenger delay.

Policy M-1.36 Electric Vehicles (EVs) in New Development. The City shall support minimum levels of EV infrastructure readiness and installation in new development and incentivize additional levels of EV charging, and EV car share, beyond City Code minimums.

Policy M-1.40 Contributions from New Development. The City shall require new development to construct or pay a proportionate share of the cost of improvements based on mobility-related impacts of the new development.

Goal M-2 Reduced reliance on single-occupant vehicles.

Policy M-2.1 Transportation Demand Management (TDM). The City should promote the greater use of Transportation Demand Management strategies by employers and residents to reduce dependence on single-occupancy vehicles with the target that 17 percent of all trips are made by transit and active
transportation modes by 2030 and 23 percent of all trips are made by transit and active transportation modes by 2045.

Policy M-2.3 Vehicle Miles Traveled (VMT) as Metric. Consistent with state law, the City shall evaluate transportation California
Environmental Quality Act (CEQA) impacts using vehicle miles traveled or other metrics as determined by the City, and shall not rely on automobile delay, as described by level of service or similar measures of vehicular delay as a measure of
environmental significance. Local Transportation Analyses (LTA) shall continue to be required when necessary to aid in conditioning project entitlements for needed operational improvements.

Goal M-3 Streets designed and maintained as places that contribute to quality of life.

Policy M-3.2 Street Design. The City shall ensure street design and potential redesign opportunities for existing streets minimize driver speed as appropriate within residential neighborhoods and incorporate street trees wherever possible without compromising
connectivity for emergency access or people bicycling, walking, and using mobility devices.

City of Sacramento Traffic Impact Study Guidelines
The City of Sacramento Traffic Impact Study Guidelines, prepared in December 2022, is a living policy document updated and maintained by the City of Sacramento’s Public Works Department.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

The Traffic Impact Study Guidelines provide basic details regarding methodologies and criteria to assist in the preparation of traffic studies. The Traffic Impact Study Guidelines provide guidance on how to conduct traffic analyses, including what types of software are appropriate to use for each type of analysis, recommendations on assumptions to use for the analysis, how to determine if the project would negatively affect the surrounding transportation network, and how to address the negative effects based on the type of analysis conducted.

4.12.4 IMPACTS AND MITIGATION MEASURES
This section describes the standards of significance and methodology utilized to analyze and determine the proposed project’s potential impacts related to transportation and circulation.

Standards of Significance
Consistent with Appendix G of the CEQA Guidelines, the proposed project would be considered to result in a significant adverse impact on the environment in relation to transportation if the project would result in any of the following:
 Conflict with a program, plan, ordinance, or policy, addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities;  Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b);  Substantially increase hazards to vehicle safety due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or  Result in inadequate emergency access.

VMT Standards of Significance
The proposed project includes industrial, highway, and commercial land uses. Based on the current practice of the City of Sacramento, transportation impacts are considered significant if the proposed project would result in a VMT per capita or office VMT per employee above 85 percent of the regional average, consistent with technical guidance published by OPR. The OPR guidance does not specify a particular significance threshold for industrial employment and recommends that local jurisdictions determine this threshold based on local conditions. Some jurisdictions in the Sacramento region (including Sacramento County and the City of Rancho Cordova) have determined that the significance threshold for industrial employment is 100 percent of the regional average. The City of Sacramento Transportation Impact Analysis Guidelines do not specify a significance threshold for industrial land uses. Consistent with a May 21, 2021 memo provided to the City of Sacramento for the Florin Perkins Distribution Center, the significance threshold for industrial employment was determined to be 100 percent of the regional average.

New retail development (such as the proposed Highway Commercial Planned Unit Development [HC-PUD] uses) often redistributes trips rather than creating new travel demand. The OPR guidance recommends that lead agencies analyze the net change in VMT to indicate the transportation impact of retail projects. The potential for VMT impacts, according to the approach, hinges on whether the project can be considered local-serving or regional. By adding retail opportunities within existing neighborhoods, local-serving retail projects can shorten trips and reduce overall VMT. In contrast, regional destination retail projects would draw customers from larger trade areas, potentially substituting for shorter trips and increasing VMT. The OPR guidance suggests that any retail projects, including stores larger than 50,000 square feet (sf), might be considered regional serving retail.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Caltrans Facilities
The proposed project is defined to have a significant impact on Caltrans facilities if:
 Project traffic causes off-ramp traffic to queue back beyond the freeway gore point (i.e., the triangled section separating the exit lane from the main portion of the freeway).

Pedestrian Facilities
The proposed project is defined to have a significant impact on pedestrian facilities if implementation of the proposed project would:
 Adversely affect existing or planned pedestrian facilities;  Fail to adequately provide access for pedestrians; and/or  Result in unsafe conditions for pedestrians, including unsafe bicycle/pedestrian or pedestrian/motor vehicle conflicts.

Bicycle Facilities
The proposed project is defined to have a significant impact on bicycle facilities if implementation of the proposed project would:
 Adversely affect existing or planned bicycle facilities;  Fail to adequately provide access by bicycle; and/or
 Result in unsafe conditions for bicycles, including unsafe bicycle/pedestrian or bicycle/motor vehicle conflicts.

Transit Facilities
The proposed project is defined to have a significant impact on transit facilities if implementation of the proposed project would:
 Adversely affect public transit operations;
 Eliminate existing or planned transit service;
 Remove an existing bus stop;
 Cause a substantial rerouting of existing or planned bus service; and/or  Fail to provide access to transit adequately.

Construction-Related Traffic Impacts
The proposed project is defined to have a significant construction-related traffic if implementation of the proposed project would:
 Degrade an intersection or roadway to an unacceptable level;  Cause inconveniences to motorists due to prolonged road closures; and/or  Result in an increased frequency of potential conflicts between vehicles, pedestrians, and bicyclists.

Method of Analysis
The information contained within this chapter is primarily based on a Traffic Impact Analysis, Trip Generation and Distribution Memo, and VMT Analysis Memo prepared for the proposed project by DKS, as well as a VMT Mitigation Memorandum prepared by the City’s Public Works Department.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

It should be noted that, pursuant to CEQA Guidelines Section 15064.3, impact significance in this chapter is based upon VMT, whereas the results of the Traffic Impact Analysis related to LOS will be used by the City, separate from the analysis in this EIR, to address consistency with Sacramento 2040 General Plan goals and policies related to transportation, including adopted LOS policies. Where applicable, this chapter incorporates the analysis in the Traffic Impact Analysis to address potential safety impacts related to transportation.

Further discussion of the methodology used in the aforementioned documents related to the analysis presented herein is included below. However, the methodology related to LOS, including the study intersections and segments, trip distribution, and LOS analysis scenarios are not discussed further herein; rather, such methodology can be found in the Traffic Impact Analysis included as Appendix N to this EIR.

Project Trip Generation
Regional trip generation and distribution for the proposed project were estimated using a combination of data from the SACOG SACSIM 19 travel demand model and data from the ITE Trip Generation Manual 11th Edition.

For parcels one through five, eight through 11, and the Caltrans parcel, the parcels were assumed to be developed in a manner comparable to the Metro Airpark Project (located on the north side of I-5). As the SACOG SACSIM 19 travel demand model uses “employees” as the land use variable, the building size was converted to the number of employees. To calculate the square footage to employee conversion, the project applicant provided information from comparable facilities throughout the United States, including the adjacent Metro Airpark. Such information was reviewed by City staff, and an employment density of 0.572 employees per 1,000 sf was assigned (one employee per 1,748 sf). Overall, the proposed project was determined to generate a total of 3,781 employees. Of the total employee trips, 96 percent are anticipated to be vehicle trips, three percent are anticipated to be pedestrian trips, and one percent is anticipated to be bicycle trips.

The vehicle trips include 71 percent single occupancy vehicles (SOV), and 14 percent high occupancy vehicles.

The total vehicle trip generation rates of the SACOG SACSIM 19 travel demand model (trips per 1,000 sf) were compared to ITE trip generation rates for similar land uses. The SACOG SACSIM 19 travel demand model estimates were determined to be similar to the ITE warehouse rates (the model is higher for daily and AM peak hours and lower for PM peak hours), but lower than light industrial and manufacturing uses. Overall, DKS determined that the model projections are consistent with the warehousing and fulfillment center uses that predominate the Metro Airpark, and further adjustments to the SACOG SACSIM 19 travel demand model for industrial total trip generation purposes were not recommended.

The heavy vehicle trip generation estimates of the travel demand model were compared to the ITE trip generation percentages for similar land uses, as well as data from Metro Airpark. Based on the ITE data, the heavy vehicle trip generation rates were increased and applied with a postprocessor methodology to adjust the model estimates to reflect anticipated heavy vehicle travel volumes.

Table 4.12-1 below presents the project trip generation expected for the Industrial PUD (M-1- PUD) uses associated with the proposed project. As shown in Table 4.12-1, approximately 2,559 Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

trips per day (20 percent of the daily trips) are anticipated to be generated by heavy duty truck traffic.

Similar to the M-1-PUD uses, the building sizes of the HC-PUD uses were converted to employees for the SACOG SACSIM 19 travel demand model. Consistent with other retail and service uses in the travel demand model, 500 sf per employee was assumed. Overall, the proposed project is anticipated to generate 33 employees for the land use west of Metro Air Parkway (i.e., parcels 6A through 6C) and 164 employees for the land use east of Metro Air Parkway (i.e., parcels 7A through 7C). Approximately 97 percent of employee trips associated with the HC-PUD uses are anticipated to be vehicle trips, three percent of trips are anticipated to be pedestrian trips, and less than one percent are anticipated to be bicycle trips. It should also be noted that the HC-PUD uses are not anticipated to generate a large number of heavy-duty truck trips, and, as a result, such trips are inherently included in daily trip generation associated with parcels 6A through 7C.

Table 4.12-1
Project Trip Generation – Industrial Planned Unit Development Uses Daily
AM Peak Hour PM Peak Hour
Enter Exit Total Enter Exit Total
Heavy Duty
Trucks 2,559 89 31 119 28 72 100
Total
Industrial 12,794 886 305 1,191 281 723 1,004
Percent
Heavy Duty
Trucks
20% 10% 10% 10% 10% 10% 10%
Source: DKS, 2023.

The recommended trip generation for HC-PUD uses is based upon representative uses from the ITE Trip Generation Manual, 11th Edition. Table 4.12-2 below presents the project trip generation expected for the HC-PUD uses associated with the proposed project.

Vehicle Miles Traveled Assessment
VMT associated with the proposed project was estimated using the latest SACOG SACSIM-19 activity-based travel demand model. Based on the latest SACOG model scripts, SACSIM-19 also reflects the entire trip length, which is consistent with OPR guidance, including the portion of the trip that occurs outside the SACOG region. External-internal and internal-external VMT are calculated using a script file provided by SACOG and included in their model for VMT postprocessing. The post-processor determines the added VMT that occurs outside the SACOG region (i.e., for trips that either start or end outside of the region).

Interregional VMT is then added to the internal-internal VMT to determine the total VMT. Pursuant to OPR guidelines, only automobile trips are considered as a part of this analysis. Heavy-duty truck and delivery vehicle VMT, as well as alternative mode VMT (transit vehicles), are not reflected.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Table 4.12-2
Project Trip Generation – Highway Commercial Planned Unit Development Uses ITE Land Use
ITE Land
Use Code
Project
Size (sf)
Daily
Trips
AM Peak-Hour PM Peak-Hour
Total In Out Total In Out
Gross Trips
6A - Restaurant 934 3,900 1,823 174 89 85 129 67 62 6B - Restaurant 934 3,900 1,823 174 89 85 129 67 62 6C - Fueling
Station / Carwash 945 8,100 8,655 686 343 343 589 295 294 7A - Hotel 310 73,400 975 56 31 25 72 37 35
7B - Restaurant 934 3,900 1,823 174 89 85 129 67 62
7C - Restaurant 934 5,000 2,337 223 114 109 165 86 79
Gross Trips Generated 17,436 1,487 755 732 1,213 619 594 Internal Capture Trips
6A/6B/6C 15,900 -729 -70 -35 -35 -52 -26 -26 7A/7B/7C 82,300 -195 -11 -6 -5 -14 -7 -7 Total Internal Capture Reduction -924 -81 -41 -40 -66 -33 -33 Driveway Trips 16,512 1,406 714 392 1,147 586 561
Additional Project Trip Reductions
Pass-By Trip Reduction -10,115 -848 -427 -420 -708 -360 -349 Total Trip Reductions -11,039 -929 -468 -460 -774 -393 -382 Net New External Project Trips 6,397 558 287 272 439 226 212 Source: DKS, 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Ramp Queuing
A freeway off-ramp queuing analysis was conducted to determine queuing conditions at the offramps as a result of traffic from the project. Queue length analysis was estimated using SimTraffic

11. SimTraffic reports the 95th percentile queue length in feet, which can be compared against the available storage length. The focus of the queuing analysis is to specifically determine if adequate storage capacity is available at the off-ramps. Several analysis scenarios were considered as part of the queuing analysis, including the following:
 Baseline: Represents average traffic conditions at the year of construction. The baseline scenario includes reasonably foreseeable developments in the short term near the project site, including developments in Metro Air Park and Northlake (Greenbriar).  Baseline with Project: Includes the baseline analysis plus project conditions.  Cumulative: Includes all planned developments and mobility changes for the forecasting year of 2040. The cumulative scenario is based on the City of Sacramento’s Draft 2040 General Plan for consistency and is consistent with the regional MTP/SCS.  Cumulative with Project: Includes the cumulative analysis plus project conditions.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts related to transportation is based on implementation of the proposed project in comparison to the existing conditions and the standards of significance presented above.

4.12-1 Conflict with a program, plan, ordinance, or policy addressing the circulation system during construction activities. Based on the analysis below, the impact is less than significant.

The proposed project would include the development of an industrial park within a 353.5-acre portion of the project site. The project site also includes several nonparticipating parcels, comprised of approximately 83 acres. Given that development of both the industrial park and nonparticipating parcels would result in the construction of similar land uses on contiguous parcels, the following discussion applies to the potential for both project components to conflict with a program, plan, ordinance, or policy addressing the circulation system during construction activities. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Areas
Construction activities associated with the proposed project would include use of construction equipment, including vehicles removing or delivering fill material, bulldozers, and other heavy machinery, as well as building materials delivery, and construction worker commutes. The transport of heavy construction equipment to the site, haul truck trips, and construction worker commutes could affect the local roadway network.

Construction workers typically arrive before the morning peak hour and leave before the evening peak hours of the traditional commute time periods. Deliveries of building material (lumber, concrete, asphalt, etc.) would also normally occur outside of the traditional commute time periods. In addition, any truck traffic to the site would follow Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

designated truck routes established by Caltrans, and project construction would likely stage any large vehicles (i.e., earth-moving equipment, cranes, etc.) on the site prior to beginning site work and remove such vehicles at project completion. In addition, Sacramento City Code Section 12.20.030 requires that a construction traffic control plan be prepared and approved prior to the beginning of project construction, to the satisfaction of the City Traffic Engineer and subject to review by all affected agencies.

All work performed during construction must conform to the conditions and requirements of the approved plan. The plan would ensure that safe and efficient movement of traffic through the construction work zone(s) is maintained. At a minimum, the plan is required to include the following:
 Time and day of street closures;
 Proper advance warning and posted signage regarding street closures;  The provision of a driveway access plan to ensure safe vehicular, pedestrian, and bicycle movements;
 Safe and efficient access routes for emergency vehicles;  Provisions for pedestrian safety;
 Use of manual traffic control when necessary;
 The number of anticipated truck trips and time of day of arrival and departure of trucks; and
 Provision of a truck circulation pattern and staging area with a limitation on the number of trucks that can be waiting and any limitations on the size and type of trucks appropriate for the surrounding transportation network.

In addition, the plan must be available at the site for inspection by the City representative during all work. Therefore, with the implementation of the traffic control plan, local roadways and freeway facilities would continue to operate at acceptable operating conditions during project construction.

Based on the above, the proposed project would not conflict with a program, plan, ordinance, or policy addressing the circulation system during construction activities, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.12-2 Conflict with a program, plan, ordinance or policy addressing the circulation system during operations. Based on the
analysis below, and with the implementation of mitigation, the impact is less than significant.

Given that development of both the industrial park and nonparticipating parcels would result in the development of similar land uses on contiguous parcels, the following discussion applies to the potential for both project components to conflict with a program, plan, ordinance, or policy addressing the circulation system during operations. Because the proposed off-site force main would be installed underground within existing roadway ROW or other previously disturbed areas, operation of the Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

force main would not conflict with existing or planned pedestrian, bicycle, or transit facilities and services within the project area.

Industrial Park and Nonparticipating Parcels
As discussed throughout this chapter, LOS is no longer the applicable metric when evaluating transportation impacts of a project. The evaluation of VMT is discussed in Impact 4.12-3 of this chapter. Therefore, the following discussion focuses on whether the proposed project would result in impacts to existing or planned pedestrian, bicycle, or transit facilities and services within the project area.

Pedestrian and Bicycle Facilities
As discussed above, the pedestrian system in the project site vicinity consists of sidewalks along Del Paso Road and El Centro Road as the roadways pass through the Sundance Lake and Westlake neighborhoods, as well as an internal trail system within the neighborhoods. In addition, a sidewalk is located along Bayou Way just east of the project site, associated with the existing self-storage facility. The bicycle system in the site vicinity consists of a Class I bike path and Class II bike lanes to the south and east of the project site, around the Westlake and Sundance Lake neighborhoods.

Bicycle and pedestrian facilities are not currently located along the project site frontage, as the location is currently undeveloped. As such, the proposed project would not adversely affect existing pedestrian or bicycle facilities. However, the existing site plan does not illustrate where planned pedestrian or bicycle facilities would be on-site.

Additionally, the site plan does not currently show the planned Class IV cycle track on the east side of the site, which is in the City’s master bicycle network. Because such facilities are not shown on the current site plan, operations of the proposed project could be considered to conflict with a program, plan, ordinance, or policy addressing pedestrian and bicycle facilities, and a potentially significant impact could occur.

Transit Facilities and Services
Public transit in the project vicinity includes a SacRT bus north of the project site. The proposed project would not include features that would conflict with existing or planned transit services. Therefore, operations of the proposed project would not conflict with a program, plan, ordinance, or policy addressing transit facilities, and a less-thansignificant impact would occur.

Conclusion
Based on the above, the proposed project would not result in impacts to transit facilities. However, the proposed project could conflict with a program, plan, ordinance, or policy addressing the circulation system, including pedestrian and bicycle facilities during operations. Therefore, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level.

4.12-2 The following requirements shall be noted on project improvement plans, subject to review and approval by the City of Sacramento Community Development Department:

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

 The project should construct pedestrian and bicycle facilities along its frontage to City Standards.
 Class IV separated bicycle facilities shall be accommodated within the proposed cross section to provide separation between cyclists and heavy truck traffic.
 The bicycle network shall be connected to the existing and planned City and County bikeway system, including, but not limited to, Bayou Way at the northeast corner of the site, the Class I bikeway at the southeast corner of the site, and Metro Air Parkway north of I-5.
 The off-street Class IV cycle track shown on the eastern side of the site in the City Bikeway Master Plan shall be accommodated in the proposed plans.

4.12-3 Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Given that development of both the industrial park and nonparticipating parcels would result in the development of similar land uses on contiguous parcels, the following discussion applies to the potential for both project components to conflict with, or be inconsistent with, CEQA Guidelines Section 15064.3, subdivision(b). Because the proposed off-site force main, including each of the three potential force main segment options, would be installed underground and would not involve generation of vehicle trips during operation, VMT associated with operation of the force main would be negligible. Thus, the proposed off-site force main would not conflict CEQA Guidelines Section 15064.3, subdivision(b).

It should be noted that the SACOG 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) includes 2040 projections for VMT per capita across the Sacramento region in Figure 3.11 of the MTP/SCS. However, the project site is not identified as a VMT-generating location in Figure 3.11, as the MTP/SCS does not identify the project site as land to be developed in the MTP/SCS planning period. Thus, this EIR includes a quantitative analysis of anticipated VMT associated with the proposed project.

Industrial Park and Nonparticipating Parcels
The following discussion includes an analysis of VMT associated with the M-1-PUD and HC-PUD uses proposed on-site, as well as the anticipated industrial development on the nonparticipating parcels.

Industrial Planned Unit Development Uses
As previously discussed, the OPR guidance does not specify a particular significance threshold for industrial land uses, and recommends that local jurisdictions determine a threshold based on local conditions. The threshold for industrial uses is less restrictive compared to other employment types due to the development of industrial uses improving overall VMT efficiency of all future development in aggregate.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Industrial uses generally have more zoning restrictions, and are generally less densely developed than other employment types making them less desirable within urban areas. By keeping industrial uses outside of urban centers, the land that such uses would occupy can instead be used for higher density land development that can see a greater benefit from being located in VMT efficient areas. As such, industrial uses often inherently have higher VMT per employee than other employment types because such uses are located further from housing and services, which are necessary to achieve lower overall VMT levels. As noted above, heavy-duty truck and delivery vehicle VMT, as well as alternative mode VMT (transit vehicles), are not considered herein.

The City of Sacramento Transportation Impact Analysis Guidelines do not specify a significance threshold for industrial land uses. As such, a regional baseline (2016) average VMT per employee metric was used to establish the threshold, which was determined to be 100 percent of the regional average. As discussed above, the regional average VMT per employee was determined to be 17.33. Based on the SACOG SACSIM 19 travel demand model, the on-site M-1-PUD uses are anticipated to generate 22.21 VMT per employee, which is 128 percent of the regional average; above the significance threshold established for the proposed project.

Highway Commercial Planned Unit Development Uses
With regard to the HC-PUD uses, because new retail development often redistributes trips rather than creating new travel demand, the OPR guidance recommends that lead agencies analyze the net change in VMT to indicate the transportation impact of retail projects.

The potential for VMT impacts, according to this approach, hinges on whether the project can be considered local-serving or regional. By adding retail opportunities within existing neighborhoods, local-serving retail projects can shorten trips and reduce overall VMT. In contrast, regional destination retail projects would draw customers from larger trade areas, potentially substituting for shorter trips and increasing VMT. The OPR guidance suggests that any retail projects, including stores larger than 50,000 sf, might be considered regional serving retail. The proposed project does not include any retail uses in excess of 50,000 sf. Therefore, the HC-PUD uses are considered to be local-serving retail, and consistent with OPR guidance, would result in a less-than-significant impact related to VMT.

Conclusion
Based on the above, while the HC-PUD uses would meet the OPR screening criteria associated with local-serving retail uses, the M-1-PUD uses would result in VMT in excess of the applicable threshold of significance. Therefore, the project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), and a significant impact could occur.

Mitigation Measure(s)
In order to reduce VMT associated with the on-site M-1-PUD uses to 100 percent of the regional average, the proposed project would be required to achieve a 22 percent reduction in VMT. Consistent with SB 743, OPR’s Technical Advisory, and the California Air Pollution Control Officers Association (CAPCOA), the proposed project Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

is required to reduce VMT through the CAPCOA Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. With implementation of such measures, as required by Mitigation Measure

4.12-3, the proposed project would achieve a 22 percent reduction in VMT. Therefore, implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level.

4.12-3 Prior to the certificate of occupancy for each on-site industrial building, the owner/operator of each building shall be required to prepare and implement a VMT Reduction Plan that includes a sufficient selection of CAPCOA Trip Reduction Programs (T-6 through T-13) to reduce VMT by at least 22 percent, consistent with the VMT Mitigation Memorandum prepared by the City’s Public Works Department for the proposed project (see Appendix Q to the EIR). CAPCOA Trip Reduction Programs T-6 through T-13 include measures such as implementing a commute trip reduction program and/or marketing, providing a rideshare program, implementing a subsidized or discounted transit program, providing end-of-trip bicycle facilities, providing employersponsored vanpool, pricing workplace housing, and implementing employee parking cash-out. The VMT Reduction Plan shall be submitted to the City’s Department of Public Works and Community Development Department for review and approval.

4.12-4 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) or result in
inadequate emergency access. Based on the analysis below, the impact is less than significant.

The following discussion applies to the potential for both project components to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) or result in inadequate emergency access. Because the proposed off-site force main would be installed underground within existing roadway ROW or other previously disturbed areas, operation of the force main would not substantially increase hazards or result in inadequate emergency access.

Industrial Park and Nonparticipating Parcels
A discussion of potential hazards related to vehicle queuing and emergency access/vehicle circulation is provided below.

Vehicle Queuing
As traffic volumes increase vehicle queues typically will also increase at most intersections. A summary of the freeway ramp termini intersection queueing analyses for the Baseline and Baseline with Project conditions are presented in Table 4.12-3 and Table 4.12-4, respectively.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Table 4.12-3
Queuing at Freeway Ramp Termini During Peak Hours —
Baseline Conditions
Intersection /
Analysis
Scenario Movement
A.M. Peak Hour P.M. Peak Hour
Available
Storage
(ft)
95th %
Queue
(ft)
Available
Storage
(ft)
95th %
Queue
(ft)

1. Airport Blvd and
I-5 northbound
ramps
WBL 1,350 20 1,350 20

2. Airport Blvd and
I-5 southbound
ramps
EBL/EBR 1,375 60 1,375 60

3. Metro Air
Parkway and I-5
northbound ramps
WBL/WBT 1,575 35 1,575 25
WBR 160 145 160 105
NBL 160 60 160 20

4. Metro Air
Parkway and I-5
southbound ramps
EBL/EBR 1,600 115 1,600 50
SBR 130 90 130 90

9. Del Paso Road
and I-5 northbound
ramps
NBL 1,270 295 1,270 295
NBR 1,270 320 1,270 380

10. Del Paso Road
and I-5
southbound ramps
SBL 1,100 105 1,100 125
SBR 250 120 250 80

13. West Elkhorn
Boulevard and SR
99 northbound
ramps
NBL 1,525 145 1,525 85

14. West Elkhorn
Boulevard and SR
99 southbound
ramps
SBL 400 85 400 165
SBR 1,480 115 1,480 85
NOTES: EB = eastbound; EBL = eastbound left; EBR = eastbound right; ft = feet; NB = northbound; NBL = northbound left; NBR = northbound right; SB = southbound; SBL = southbound left; SBR = southbound right; WB = westbound; WBL = westbound left; WBR = westbound right Black bolded results indicate an operational deficiency. Red bolded results indicate an operational deficiency either caused by or exacerbated by the project. Values rounded up to the nearest multiple of five.

Source: DKS, 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Table 4.12-4
Queuing at Freeway Ramp Termini During Peak Hours —
Baseline Plus Project Conditions
Intersection /
Analysis
Scenario Movement
A.M. Peak Hour P.M. Peak Hour
Available
Storage
(ft)
95th %
Queue
(ft)
Available
Storage
(ft)
95th %
Queue
(ft)

1. Airport Blvd and
I-5 northbound
ramps
WBL 1,350 20 1,350 20

2. Airport Blvd and
I-5 southbound
ramps
EBL/EBR 1,375 75 1,375 60

3. Metro Air
Parkway and I-5
northbound ramps
WBL 350 270 350 175
WBT/WBR 1,575 180 1,575 180
NBL 100 150 100 145
NBT 875 220 875 245
SBT 700 330 700 305
SBR 650 100 650 95

4. Metro Air
Parkway and I-5
southbound ramps
EBL 1,600 135 1,600 115
EBR 170 95 170 45
NBL 300 200 300 220
NBT 470 205 470 240
SBT 840 405 840 260
SBR 130 255 130 185

9. Del Paso Road
and I-5 northbound
ramps
NBL 1,270 480 1,270 355
NBR 1,270 345 1,270 465

10. Del Paso Road
and I-5 southbound
ramps
SBL 1,100 100 1,100 135
SBR 250 140 250 90

13. West Elkhorn
Boulevard and SR
99 northbound
ramps
NBL 1,525 130 1,525 115

14. West Elkhorn
Boulevard and SR
99 southbound
ramps
SBL 400 80 400 75
SBR 1,480 150 1,480 55
NOTES: EB = eastbound; EBL = eastbound left; EBR = eastbound right; ft = feet; NB = northbound; NBL = northbound left; NBR = northbound right; SB = southbound; SBL = southbound left; SBR = southbound right; WB = westbound; WBL = westbound left; WBR = westbound right Black bolded results indicate an operational deficiency. Red bolded results indicate an operational deficiency either caused by or exacerbated by the project. Values rounded up to the nearest multiple of five.

Source: DKS, 2023.

As noted in the tables, red bolded text indicates an operational deficiency either caused by or exacerbated by the project. However, as shown in Table 4.12-4, while operational deficiencies exist at the Metro Air Parkway and I-5 northbound ramps at the northbound left lane and the Metro Air Parkway and I-5 southbound ramps at the southbound left lane during both the AM and PM peak hour under Baseline with Project Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

conditions, such deficiencies would not be caused by or exacerbated by the proposed project. Therefore, a less-than-significant impact would occur related to vehicle queuing associated with the proposed project.

Site Access and Circulation
Several factors determine whether a project has sufficient access for emergency vehicles, including the following:

1. Number of access points (both public and emergency access only);

2. Width of access points; and

3. Width of internal roadways.

Access to the project site would be provided from the north by Metro Air Parkway, which would connect to the proposed Airport South Industrial Drive. The proposed project would include abandonment of the existing South Bayou Way within the project limits, and replacement with a new internal roadway system. Concurrent with abandonment, an access easement would be dedicated over the eastern segment of South Bayou Way (from a proposed cul-de-sac to the new round-a-bout) to serve future industrial Parcels 9-11, and the Caltrans Remnant.

In order to guide truck traffic directly to I-5 and limit traffic impacts to Bayou Way east of the project site, the project would be served by a new internal roadway system including Airport South Industrial Drive, a modified two-lane Local Industrial roadway with a 75-foot-wide ROW, that would bisect the property west to east by connecting Power Line Road to a future street (labeled “A” Drive in Figure 3-3 in the Project Description chapter of this EIR) that would run north along the site’s eastern border and connect to a proposed round-a-bout where Bayou Way meets the project site. It is anticipated that the round-a-bout will have signage and be configured to prohibit offsite truck traffic from the project site, east and south along Bayou Way/El Centro Road to Del Paso Road. Metro Air Parkway, a modified four-lane Local Industrial roadway with a 97-foot-wide ROW, would be extended south from the existing I-5 interchange to the proposed Airport South Industrial Drive, providing a direct connection for trucks.

The proposed project would be required to comply with all building, fire, and safety codes and specific development plans would be subject to review and approval by the City’s Public Works Department and the City’s Fire Department. Required review by the aforementioned departments would ensure that the proposed circulation system for the project site would provide adequate emergency access. The proposed project would not alter the circulation network of the other local roadways or otherwise prevent emergency vehicle access or evacuation.

Conclusion
Based on the above, the proposed project would not substantially increase hazards due to a geometric design feature or incompatible uses, or result in inadequate emergency access, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Cumulative Impacts and Mitigation Measures
For further detail related to the cumulative setting of the proposed project, refer to Chapter 6, Statutorily Required Sections, of this EIR.

It should be noted that increased traffic volumes on local roadway facilities under cumulative conditions would not substantially alter performance related to bicycle facilities, pedestrian facilities, transit facilities and services, and emergency vehicle access. Rather, impacts to such facilities under cumulative plus project conditions would be similar to those discussed above. In addition, construction activities associated with the project would be complete prior to the cumulative analysis year. Therefore, such topics are not discussed further in the cumulative analysis presented herein.

Similarly, the VMT impact analysis presented under Impact 4.12-3 would also apply to cumulative plus project conditions. The VMT significance threshold compares project-generated VMT per unit of development to that of existing local development. The VMT comparison is useful because the comparison provides information regarding how the project aligns with long-term environmental goals related to VMT established based on existing development levels. Use of VMT significance thresholds based on existing development levels is recommended in the OPR’s Technical Advisory. The Technical Advisory indicates that VMT efficiency metrics, such as VMT per service population or VMT per unit of development, may not be appropriate for CEQA cumulative analysis because they employ a denominator. Instead, the Technical Advisory recommends that an impact finding from an efficiency-based project-specific VMT analysis (i.e., existing plus project conditions) would imply an identical impact finding for a cumulative VMT analysis.8 An example provided by OPR explains that a project that falls below an efficiencybased threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Therefore, an analysis of VMT is not presented in this cumulative discussion as the conclusion would remain identical to that presented under Impact 4.12-3.

However, with regard to vehicle queueing, Cumulative and Cumulative with Project conditions could differ from Baseline and Baseline with Project conditions due to the increase in traffic on project area roadways associated with cumulative development. Therefore, an analysis of impacts associated with vehicle queuing under Cumulative and Cumulative with Project conditions is discussed below.

4.12-5 Substantially increase cumulative hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). Based on the analysis below, the impact is less than cumulatively
considerable.

The following discussion applies to the potential for both project components to substantially increase cumulative hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

As previously discussed, operation of the force main would not substantially increase hazards or result in inadequate emergency access.
8 Governor’s Office of Planning and Research. Technical Advisory on Evaluating Transportation Impacts in CEQA [pg. 6]. December 2018.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Industrial Park and Nonparticipating Parcels
A summary of the freeway ramp termini intersection queueing analyses for the Baseline and Cumulative and Cumulative with Project conditions are presented in Table 4.12-5 and Table 4.12-6, respectively.

Table 4.12-5
Queuing at Freeway Ramp Termini During Peak Hours —
Cumulative Conditions
Intersection /
Analysis
Scenario Movement
A.M. Peak Hour P.M. Peak Hour
Available
Storage
(ft)
95th %
Queue
(ft)
Available
Storage
(ft)
95th %
Queue
(ft)

1. Airport Blvd and
I-5 Northbound
ramps
WBL 1,350 20 1,350 20

2. Airport Blvd and
I-5 southbound
ramps
EBL/EBR 1,375 75 1,375 65

3. Metro Air
Parkway and I-5
Northbound ramps
WBL 350 85 350 40
WBT/WBR 1,575 280 1,575 250
NBL 100 260 100 200
NBT 875 95 875 70
SBT 700 390 700 700
SBR 650 130 650 485

4. Metro Air
Parkway and I-5
southbound ramps
EBL 1,600 95 1,600 85
EBR 170 60 170 65
NBL 300 40 300 40
NBT 470 15 470 20
SBT 840 50 840 275
SBR 130 70 130 335

9. Del Paso Road
and I-5
Northbound ramps
NBL 1,270 1905 1,270 1200
NBR 1,270 1845 1,270 1270

10. Del Paso
Road and I-5
southbound ramps
SBL 1,100 150 1,100 295
SBR 250 185 250 250

13. West Elkhorn
Boulevard and SR
99 Northbound
ramps
NBL 1,525 330 1,525 1455
NBR 420 145 420 325

14. West Elkhorn
Boulevard and SR
99 southbound
ramps
SBL 1,480 115 1,480 90
SBR 400 130 400 175
NOTES: EB = eastbound; EBL = eastbound left; EBR = eastbound right; ft = feet; NB = Northbound; NBL = Northbound left; NBR = Northbound right; SB = southbound; SBL = southbound left; SBR = southbound right; WB = westbound; WBL = westbound left; WBR = westbound right Black bolded results indicate an operational deficiency. Red bolded results indicate an operational deficiency either caused by or exacerbated by the project. Values rounded up to the nearest multiple of five.

Source: DKS, 2023.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

Table 4.12-6
Queuing at Freeway Ramp Termini During Peak Hours —
Cumulative with Project Conditions
Intersection /
Analysis
Scenario Movement
A.M. Peak Hour P.M. Peak Hour
Available
Storage
(ft)
95th %
Queue
(ft)
Available
Storage
(ft)
95th %
Queue
(ft)

1. Airport Blvd and I-5
Northbound ramps WBL 1,350 20 1,350 20

2. Airport Blvd and I-5
southbound ramps EBL/EBR 1,375 75 1,375 70

3. Metro Air Parkway
and I-5 Northbound
ramps
WBL 350 245 350 185
WBT/WBR 1,575 190 1,575 255
NBL 100 175 100 220
NBT 875 135 875 145
SBT 700 240 700 705
SBR 650 35 650 460

4. Metro Air Parkway
and I-5 southbound
ramps
EBL 1,600 145 1,600 120
EBR 170 115 170 100
NBL 300 80 300 105
NBT 470 165 470 140
SBT 840 275 840 465
SBR 130 45 130 360

9. Del Paso Road and
I-5 Northbound ramps
NBL 1,270 2795 1,270 2110
NBR 1,270 2960 1,270 2200

10. Del Paso Road
and I-5 southbound
ramps
SBL 1,100 165 1,100 365
SBR 250 210 250 305

13. West Elkhorn
Boulevard and SR 99
Northbound ramps
NBL 1,525 330 1,525 1,465
420 155 420 330

14. West Elkhorn
Boulevard and SR 99
southbound ramps
SBL 1,480 125 1,480 80
SBR 400 135 400 180
NOTES: EB = eastbound; EBL = eastbound left; EBR = eastbound right; ft = feet; NB = Northbound; NBL = Northbound left; NBR = Northbound right; SB = southbound; SBL = southbound left; SBR = southbound right; WB = westbound; WBL = westbound left; WBR = westbound right Black bolded results indicate an operational deficiency. Red bolded results indicate an operational deficiency either caused by or exacerbated by the project. Values rounded up to the nearest multiple of five.

Source: DKS, 2023.

As traffic volumes increase, vehicle queues typically will also increase at most intersections. However, as shown in the tables, queueing across multiple intersections was identified under both the Cumulative and Cumulative with Project conditions related to the ramp metering to the on-ramps to Caltrans facilities.

According to DKS, ramp meters on such intersections may ultimately operate differently than was assumed for the analysis presented herein, which would result in less queueing along Metro Air Parkway southbound and Del Paso Road approaching Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.12 – Transportation

the interchange in both directions. Nonetheless, the project would contribute to queueing caused by such ramp meters.

With regard to queuing on the Caltrans off-ramps, according to DKS, two locations are expected to exceed the available queue storage in the Cumulative condition: Del Paso Road and the I-5 Northbound Ramps, and Del Paso Road and the I-5 southbound ramps. At Del Paso Road and the I-5 Ramps, the project would contribute traffic volumes sufficient to increase the already deficient 95th percentile queues by several car lengths. However, based on Caltrans guidance related to freeway queuing, the proposed project would not result in a significant impact related to traffic safety, as the queues already spill back onto the mainline under the Cumulative condition, without the addition of project traffic.

Therefore, the project’s incremental contribution to significant cumulative impacts related to traffic safety would be less than cumulatively considerable under Cumulative with Project conditions.

Mitigation Measure(s)
None required.

4.13 TRIBAL CULTURAL RESOURCES

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

4.13.1 INTRODUCTION
The Tribal Cultural Resources chapter of the EIR addresses known and unknown tribal cultural resources in the vicinity of the project area. Pursuant to Public Resources Code (PRC) Section 21074, tribal cultural resources are defined as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either included or determined to be eligible for inclusion in the California Register of Historical Resources or included in a local register of historical resources as defined in subdivision (k) of PRC Section 5020.1. A Tribal cultural landscape is defined as a geographic area (including both cultural and natural resources and the wildlife therein), associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values.

As discussed further in Chapter 3, Project Description, of this EIR, the project site is divided into two portions: the industrial park, which consists of the majority of the western portion and the northeast corner of the overall site, and the nonparticipating parcels, primarily located in the southeastern portion of the overall site. While the proposed project would require approval of a Sphere of Influence (SOI) Amendment and Annexation of the entire project site into the City of Sacramento City limits, only the industrial park is currently proposed for development. In addition, the proposed project would include construction of an off-site force main to convey wastewater generated from the proposed uses to the 48-inch Sacramento Area Sewer District (SacSewer) North Natomas interceptor line in East Commerce Way.

This chapter summarizes the existing setting with respect to tribal cultural resources, identifies thresholds of significance, evaluates potential project impacts to such resources, and sets forth mitigation measures. Information presented in this chapter is primarily drawn from a Sacred Lands File (SLF) search conducted by the California Native American Heritage Commission (NAHC), project notification letters sent by the City to Native American individuals and organizations pursuant to Assembly Bill (AB) 52 and Senate Bill (SB) 18, follow-up Native American consultation, and a Cultural Resources Study prepared by Tom Origer & Associates,1 as well as the City of Sacramento 2040 General Plan2 and the City of Sacramento 2040 Master EIR (MEIR).3

4.13.2 EXISTING ENVIRONMENTAL SETTING
A detailed overview of the project area’s cultural history is included in Chapter 4.5, Cultural Resources of this EIR. The sections below provide an ethnographic overview of tribal history within the project area, as well as an overview of the tribal outreach conducted for the project site by Tom Origer & Associates during preparation of the site-specific Cultural Resources Study, formal AB 52 and SB 18 tribal consultation conducted by the City, and any known tribal cultural resources on-site.

1 Tom Origer & Associates. Cultural Resources Study for the Airport South Industrial Park Project. March 7, 2022. 2 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 3 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023.

4.13 TRIBAL CULTURAL RESOURCES
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

Ethnographic Overview of the Project Area
Linguists and ethnographers tracing the evolution of languages have found that most of the indigenous languages of the California region belong to one of five widespread North American language groups (the Hokan and Penutian phyla, and the Uto-Aztecan, Algic, and Athabaskan language families). The distribution and internal diversity of four of the groups suggest that original centers of dispersal were outside, or peripheral to, the core territory of California, which are the Central Valley, the Sierra Nevada, the Coast Range from Cape Mendocino to Point Conception, and the Southern California coast and islands. Only languages of the Hokan phylum can be traced back to populations inhabiting parts of California’s core region during the Archaic period, and hints of connections exist between certain branches of Hokan, such as between the Salinan and Seri, which suggest that at least some of the Hokan languages could have been brought into California by later immigrants, primarily from the Southwest and northwestern Mexico.

Around 2500 BC, ancestors to Miwok and Costanoans occupied the lower Sacramento Valley, which coincides with the occurrence of the Windmiller Pattern in the same area. Utian-speaking populations remained in the lower Sacramento Valley until the arrival of Europeans and spread in all directions. When Europeans arrived in California, Penutian-speakers made up the majority of the state.

At the time of Euro-American settlement, the project area was situated in a region controlled by the Nisenan. The Nisenan territory encompassed a region bounded on the west by the Sacramento River, between the American and Consumnes rivers to the south, the crest of the Sierra Nevada to the east, and to the north the boundary was not clearly established to ethnographers but lies a few miles south of the Feather River. The Nisenan were huntergatherers who lived in rich environments that allowed for dense populations with complex social structures. The Nisenan settled in permanent villages, often with clusters of small settlements located near and around the larger village. The Valley Nisenan built villages on low, natural rises along streams and rivers or on gentle slopes with a southern exposure. Very few villages were located within the valley plain as that area was reserved for hunting, gathering, and fishing. The Hill Nisenan built villages on ridges and large flats along major waterways and were often smaller than the Valley Nisenan villages. Primary village sites were occupied throughout the year and other sites were visited to procure resources that were especially abundant or available only during certain seasons. Sites were often situated near fresh water sources and in ecotones where plant life and animal life were diverse and abundant.

Local Native Americans that inhabited the area appear to have had an economy based largely on hunting, with limited exchange, and social structures based on the extended family unit. Later, milling technology and an inferred acorn economy were introduced. The diversification of economy appears to be coeval with the development of sedentism and population growth and expansion. Sociopolitical complexity and status distinctions based on wealth are also observable in the archaeological record, as evidenced by an increased range and distribution of trade goods (e.g., shell beads, obsidian tool stone), which are possible indicators of both status and increasingly complex exchange systems. Archaeological site indicators expected to be found in the region include but are not limited to: obsidian and chert flakes and chipped stone tools; grinding and mashing implements such as slabs and hand-stones, and mortars and pestles; and locally darkened midden soils containing some of the previously listed items plus fragments of bone, shellfish, and fire-affected stones.

In 1833, a great epidemic swept through the Sacramento Valley. The epidemic has been attributed to malaria, and is estimated to have killed seventy-five percent of the native population, leaving only a shadow of the original population to face the intruding miners and settlers. The Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

Nisenan of the mountain areas felt less of the impact of European settlement in California than the Valley Nisenan, who were subjected to some missionization. The Mountain Nisenan, remote from the early impacts of settlers, were overwhelmed by the gold rush. Native ways of life were almost totally abandoned, and today only a few families in Placer, Nevada, Yuba, and El Dorado counties identify themselves as Nisenan and can speak the language.4 Many descendants of Valley Nisenan throughout the larger Sacramento region belong to the United Auburn Indian Community, Shingle Springs, Ione Band, Colfax-Todds Valley, and Wilton Rancheria Tribes. The tribes actively participate in the identification, evaluation, preservation, and restoration of Tribal Cultural Resources.

Tribal Outreach
The following discussion includes a description of the tribal outreach activities that were conducted for the project site by Tom Origer & Associates, during preparation of the site-specific Cultural Resources Study. The Lead Agencies also conducted formal AB 52 and SB 18 consultation for the proposed project, which is discussed in later sections of this Chapter.

Tom Origer & Associates contacted the NAHC requesting a search of the SLF for traditional cultural resources within or near the project site on January 21, 2022. The results of the search returned by the NAHC on February 7, 2022 were negative for Native American cultural resources in the project vicinity. The NAHC provided contact information for tribal members or organizations affiliated with the region, and recommended that the tribes be contacted for more information on the potential for Native American cultural resources within or near the project site. Tom Origer & Associates contacted each of the tribes included on the list provided by the NAHC.

At the time the Cultural Resources Study was prepared, responses had not been received by any of the tribes contacted by Tom Origer & Associates. However, on March 9, 2022, the Yocha Dehe Wintun Nation responded by email, and deferred all correspondence regarding the proposed project to the United Auburn Indian Community of the Auburn Rancheria (UAIC) and Wilton Rancheria. Neither the UAIC, nor the Wilton Rancheria responded to the tribal outreach activities conducted by Tom Origer & Associates; however, as detailed below, the UAIC provided a response to the City’s official notification.

Tribal Consultation
In compliance with AB 52 (PRC Section 21080.3.1) and PRC Section 21082.3, the Lead Agencies must consult with tribes traditionally and culturally affiliated with the project area that have requested formal notification and responded with a request for consultation. The parties must consult in good faith. Consultation is deemed concluded when the parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource when one is present or when a party concludes that mutual agreement cannot be reached. Mitigation measures agreed on during the consultation process must be recommended for inclusion in the environmental document.

Pursuant to AB 52, project notification letters were sent by the Lead Agencies on January 27, 2022 to tribes who requested notification of proposed projects within this geographic area.

Specifically, AB 52 notification letters were sent to the UAIC, Wilton Rancheria, Shingle Springs Band of Miwok Indians, and Buena Vista Rancheria. Similarly, SB 18 notification letters were sent by the City on January 27, 2022 to a list of tribes that were identified by the NAHC as being culturally or traditionally affiliated with the project area, including the Buena Vista Rancheria of 4 City of Sacramento. Sacramento 2035 General Plan Background Report. August 2014.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

Me-Wuk Indians, Ione Band of Miwok Indians, Shingle Springs Band of Miwok Indians, Tsi Akim Maidu, UAIC, Wilton Rancheria, and Colfax-Todds Valley Consolidated Tribe.

The City received one response to both the AB 52 and SB 18 notification letters from the UAIC, with a request to consult on the proposed project due to the cultural sensitivity of the area. The City subsequently initiated consultation with the UAIC. Consultation included the provision of the Cultural Resources Study to the UAIC for review. The UAIC provided tribe-specific mitigation, which is included in the analysis below, to be implemented as part of the proposed project. The UAIC did not provide any comments on the Cultural Resources Study, and further requests for consultation were not received. As such, consultation with the UAIC has since been closed.

The UAIC is a federally recognized tribe comprised of both Miwok and Maidu (Nisenan) Tribal members who are traditionally and culturally affiliated with the project area. The tribe has a deep spiritual, cultural, and physical ties to their ancestral land and are contemporary stewards of their culture and landscapes. The Tribal community represents a continuity and endurance of their ancestors by maintaining their connection to their history and culture. The tribe’s goal is to ensure the preservation and continuance of their cultural heritage for current and future generations.

Known Tribal Cultural Resources
As described in detail above, the City of Sacramento and the surrounding area are known to have been occupied by Native American groups for thousands of years prior to settlement by nonNative peoples. As such, archaeological materials, including human burials, have been found throughout the City, some in deeply buried contexts. Generalized areas of high sensitivity for cultural resources are located within close proximity to the Sacramento and American rivers and moderate sensitivity was identified near other watercourses. However, the City designates a wide swath of land along the American River as Parks, which limits development and impacts on sensitive cultural resources. High-sensitivity areas may be found in other areas related to the ancient flows of the rivers, with differing meanders than found today. Recent discoveries during infill construction in downtown Sacramento have shown that the downtown area is highly sensitive for archaeological and pre-contact indigenous resources. For example, Native American burials and artifacts were found in 2005 during construction of the new City Hall.

Based on a search of the NAHC SLF, as described in further detail in the Method of Analysis section below, recorded Native American sacred sites or traditional cultural properties are not known to exist within the project site. In addition, during the course of the field surveys conducted by Tom Origer & Associates as part of the Cultural Resources Study, archaeological resources associated with Native American tribes were not discovered on the project site. However, according to the Cultural Resources Study, the project site is located within District P-34-005225, which was recorded in 2018 as a Tribal Cultural Landscape of the Nisenan and the Plains Miwok.

The Landscape consists of natural waterways, riparian forests, and wetlands that supported the lifeways of the local inhabitants. Because the proposed off-site force main alignment occurs along existing roadway right-of-way (ROW) and other previously disturbed areas, known tribal cultural resources do not occur along the force main alignment.

4.13.3 REGULATORY CONTEXT
Federal, State, and local governments have developed laws and regulations designed to protect significant tribal cultural resources that may be affected by actions that they undertake or regulate.

The following section contains a summary of basic federal and State laws governing preservation of tribal cultural resources of national, regional, State, and local significance.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

Federal Regulations
The following are the federal environmental laws and policies relevant to tribal cultural resources.

Section 106 of the National Historical Preservation Act of 1966 Federal regulations for cultural resources are governed primarily by Section 106 of the National Historical Preservation Act (NHPA) of 1966. Section 106 of NHPA requires Federal agencies to take into account the effects of their undertakings on historic properties and affords the Advisory Council on Historic Preservation a reasonable opportunity to comment on such undertakings. The Council’s implementing regulations, “Protection of Historic Properties,” are found in 36 Code of Federal Regulations (CFR) Part 800. The goal of the Section 106 review process is to offer a measure of protection to sites, which are determined eligible for listing on the National Register of Historic Places (NRHP). The criteria for determining NRHP eligibility are found in 36 CFR Part

60. Amendments to the Act (1986 and 1992) and subsequent revisions to the implementing regulations have, among other things, strengthened the provisions for Native American consultation and participation in the Section 106 review process. While federal agencies must follow federal regulations, most projects by private developers and landowners do not require this level of compliance. Federal regulations only come into play in the private sector if a project requires a federal permit or uses federal funding.

State Regulations
The following are the State environmental laws and policies relevant to tribal cultural resources.

Assembly Bill 52
AB 52 adds tribal cultural resources to the categories of cultural resources in CEQA, which had formerly been limited to historic, archaeological, and paleontological resources. “Tribal cultural resources” are defined as either:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of Historical Resources.
(B) Included in a local register of historical resources as defined in subdivision (k) of Section 5020.1.
(2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1. In applying the criteria set forth in subdivision (c) of Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe.

Under AB 52, a project that may cause a substantial adverse change in the significance of a Tribal Cultural Resource is defined as a project that may have a significant effect on the environment.

Where a project may have a significant impact on a tribal cultural resource, the lead agency’s environmental document must discuss the impact and whether feasible alternatives or mitigation measures could avoid or substantially lessen the impact. AB 52 (PRC 21080.3.1) requires lead agencies to provide notice to tribes that are traditionally and culturally affiliated with the geographic area of a proposed project if they have requested notice of projects proposed within that area. If the tribe(s) requests consultation within 30 days upon receipt of the notice, the lead agency must consult with the tribe(s). Consultation may include discussing the type of Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

environmental review necessary, the significance of tribal cultural resources, the significance of the project’s impacts on the tribal cultural resources, and alternatives and mitigation measures recommended by the tribe(s).

Senate Bill 18
SB 18, signed into law in September 2004, requires local (city and county) governments to consult with California Native American tribes, when amending or adopting a general plan or specific plan, or designating land as open space, in order to aid in the protection of traditional tribal cultural places (“cultural places”). The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places. The consultation and notice requirements apply to adoption and amendment of both general plans (defined in Government Code Section 65300 et seq.) and specific plans (defined in Government Code Section 65450 et seq.). The proposed project includes a General Plan Amendment, and, thus, is subject to SB 18 consultation requirements.

Public Resources Code Section 5024.1(c)
According to PRC Section 5024.1(c), a resource may be listed as an historical resource in the California Register if the resource meets any of the following NRHP criteria:
(1) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
(2) Is associated with the lives of persons important in our past. (3) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.
(4) Has yielded, or may be likely to yield, information important in prehistory or history.

Local Regulations
The following are the local environmental laws and policies relevant to tribal cultural resources.

City of Sacramento General Plan
Goals and policies from the City’s 2040 General Plan related to tribal cultural resources are presented below.

Goal HCR-1 Historic and cultural resources that enrich our sense of place and our understanding of the City’s prehistory and history.

Policy HCR-1.13 Indigenous Cultures. The City shall seek ways to recognize the peoples who first lived in, traveled, and traded in what is now the Sacramento area, by working
with tribal representatives to preserve their identity, culture, and artifacts. Methods for recognizing tribal history and imagery may include, but are not limited to, the following:
 Public art that provides a Native American
perspective including works by Native artists;
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

 Naming of parks and places that reflects local
Native American heritage and/or restores tribal
names;
 Parks and recreation programming that increases
awareness of tribal heritage and culture (including
through interpretive displays) and allows
opportunities for craft sharing;
 Incorporation of traditional native plants into
landscape design palettes.

Policy HCR-1.15 Treatment of Native American Human Remains. The City shall treat Native American human remains with
sensitivity and dignity and ensure compliance with the
associated provisions of California Health and Safety Code and the California Public Resources Code. The City shall collaborate with the most likely descendants identified by the Native American Heritage Commission.

Policy HCR-1.17 Evaluation of Archeological Resources. The City shall work in good faith with interested communities to evaluate proposed development sites for the presence of subsurface historic, archaeological, and tribal cultural resources that may be present at the site. These efforts may include the following:
 Consideration of existing reports and studies,
 Consultation with Native American tribes as
required by State law,
 Appropriate site-specific investigative actions, and
 Onsite monitoring during excavation if appropriate.

4.13.4 IMPACTS AND MITIGATION MEASURES
The following section describes the standards of significance and methodology used to analyze and determine the proposed project’s potential impacts related to tribal cultural resources. In addition, a discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

Standards of Significance
Consistent with Appendix G of the CEQA Guidelines, an impact related to tribal cultural resources is considered significant if the proposed project would:
 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
o Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k); or o A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

(c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Method of Analysis
The impact analysis contained in this chapter is primarily based on a SLF search conducted by the NAHC, project notification and offer to consult letters sent by the City to Native American individuals and organizations, and follow-up Native American consultation pursuant to AB 52 and SB 18, as well as a Cultural Resources Study prepared by Tom Origer & Associates. The methods of analysis are described in further detail below.

Native American Tribal Consultation
As discussed above, Tom Origer & Associates contacted the NAHC to request a search of the SLF to determine whether known tribal cultural resources are located within or near the project area. The SLF is populated by members of the Native American community who have knowledge about the locations of tribal resources. In requesting a search of the SLF, Tom Origer & Associates solicited information from the Native American community regarding tribal cultural resources; however, the responsibility to formally consult with the Native American community lies exclusively with the federal and local agencies under applicable State and federal law.

Per the NAHC’s suggestion, Tom Origer & Associates contacted each of the following Native American tribes or individuals with the potential to have knowledge of cultural resources in the project area:
 Buena Vista Rancheria of Me-Wuk Indians;
 Chicken Ranch Rancheria of Me-Wuk Indians;
 Confederated Villages of Lisjan;
 Guidiville Indian Rancheria, Ione Band of Miwok Indians;  Nashville Enterprise Miwok-Maidu-Nishinam Tribe;
 Tule River Indian Tribe;
 UAIC;
 Wilton Rancheria;
 Cachil Dehe Band of Wintun Indians of the Colusa Indian Community;  Colfax-Todds Valley Consolidated Tribe;
 North Valley Yokuts Tribe;
 Shingle Springs Band of Miwok Indians;
 Tsi Akim Maidu;
 Yocha Dehe Wintun Nation; and
 Muwekma Ohlone Indian Tribe of the San Francisco Bay Area.

In addition to the outreach conducted by Tom Origer & Associates, and in compliance with AB 52 (PRC Section 21080.3.1) and SB 18, project notification letters were distributed by the Lead Agencieson January 27, 2022 to the appropriate tribes in the project area. Specifically, pursuant to AB 52, project notification letters were sent by the City to the UAIC, Wilton Rancheria, Shingle Springs Band of Miwok Indians, and Buena Vista Rancheria. SB 18 notification letters were sent by the City to the Buena Vista Rancheria of Me-Wuk Indians, Ione Band of Miwok Indians, Shingle Springs Band of Miwok Indians, Tsi Akim Maidu, UAIC, Wilton Rancheria, and Colfax-Todds Valley Consolidated Tribe.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

Tom Origer & Associates did not receive responses from any tribes other than the Yocha Dehe Wintun Nation, who deferred all correspondence regarding the proposed project to the UAIC and Wilton Rancheria. Neither the UAIC, nor the Wilton Rancheria responded to the tribal outreach activities conducted by Tom Origer & Associates. However, the City received one response to both the AB 52 and SB 18 notification letters from the UAIC requesting formal consultation. The UAIC requested a copy of the Cultural Resources Study prepared for the proposed project, which was provided to the tribe.

UAIC Background Search
The UAIC conducted background search for the identification of tribal cultural resources for the proposed project, which included a review of pertinent literature, historic maps, and a records search using UAIC’s Tribal Historic Information System (THRIS). UAIC’s THRIS database is composed of UAIC’s areas of oral history, ethnographic history, and places of cultural and religious significance, including UAIC Sacred Lands that are submitted to the NAHC. The THRIS resources shown in this region also include previously recorded indigenous resources identified through the CHRIS as well as historic resources and survey data.

Field Survey Methods
A mixed-strategy field survey was conducted at the project site by Tom Origer & Associates on February 9 and 10, 2022. An additional site visit was conducted on February 16, 2022. Field conditions during the field survey and site visit were warm, clear, and dry. Most of the project site was examined by walking in zig-zags within 15-meter corridors and hoes were used as needed to expose the ground surface. Ground visibility ranged from excellent to poor, with vegetation and imported gravel being the primary hindrances. The area between Interstate 5 (I-5) and Bayou Way had been subject to several cultural resources studies and also recently developed with I-5 off/on ramps and connector roads, so the area was surveyed in a cursory manner.

In addition to a surface survey, attempts were made to observe subsurface soils. The banks of ditches and canals within and adjacent to the project site were examined, when possible. Three hand-dug borings were excavated using a 4-inch diameter barrel auger. One auger boring went to a depth of 100 centimeters and the other two went to a depth of 150 centimeters. The locations were chosen to avoid portions of the project site that were inundated during prehistoric times and to be within a geological formation that dates to the Holocene Epoch.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts is based on implementation of the proposed project in comparison with the standards of significance identified above.

4.13-1 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

The 474.4-acre project site is undeveloped and consists entirely of agricultural land.

The proposed project would include the development of an industrial park within a 353.5-acre portion of the project site. The project site also includes several nonparticipating parcels, comprised of approximately 83 acres. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous, the potential for impacts to tribal cultural resources to occur from development of either project Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

component would be similar. Thus, the following discussion applies to the potential for both project components to impact historical resources. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
As noted previously, a records search of the NAHC SLF did not indicate the presence of tribal cultural resources within the project site. In addition, archaeological resources associated with Native American tribes were not discovered on the project site during field surveys conducted by Tom Origer & Associates. Furthermore, while the project site is located within District P-34-005225, which was recorded in 2018 as a Tribal Cultural Landscape of the Nisenan and the Plains Miwok, the Cultural Resources Study concluded that important elements of the Tribal Cultural Landscape, including waterways, tule habitats, fisheries, and wildlife, are not present within the project site.

Considering the results of the literature search and the prehistory and history of the area, the project site was determined by Tom Origer & Associates to range in low to high potential for buried archaeological site indicators, with the level of potential dependent on the specific location within the overall project site. However, auger borings were excavated in the locations that had the highest potential for buried resources, and archaeological site indicators were not found in the auger borings or in exposed banks. Therefore, the potential for buried archaeological site indicators to occur on-site was reduced to a low to moderate potential. In addition, while the UAIC requested to review the Cultural Resources Study as part of consultation, the tribe did not provide any comments on the Cultural Resources Study. In addition, aside from the request to include tribe-specific mitigation within this chapter, as presented below, the UAIC did not have any additional comments or concerns regarding the proposed project and further requests for consultation were not received.

While known tribal cultural resources are not located within the project site, the possibility exists that buried tribal cultural resources associated with local tribes could occur within the project site. In addition, the proposed off-site force main alignment occurs along existing roadway ROW and other previously disturbed areas. Thus, tribal cultural resources are not anticipated to occur within the force main alignment.

However, due to the off-site force main’s location underground, the possibility of construction of the proposed off-site improvements encountering unknown tribal cultural resources cannot be entirely ruled out. Therefore, ground-disturbing activities associated with the proposed project could cause a substantial change in the significance of a Tribal Cultural Resource as defined in PRC Section 21074, and a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

4.13-1(a) Conduct Cultural Resources Sensitivity and Awareness Training Prior to Ground-Disturbing Activities
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

The City shall require the applicant/contractor to provide a tribal cultural resources sensitivity and awareness training program (Worker Environmental Awareness Program [WEAP]) for all personnel involved in project construction, including field consultants and construction workers. The WEAP will be developed in coordination with culturally affiliated Native American tribes. The WEAP shall be conducted before any project-related construction activities begin at the project site. The WEAP will include relevant information regarding sensitive tribal cultural resources, including applicable regulations, protocols for avoidance, and consequences of violating State laws and regulations.

The WEAP will also describe appropriate avoidance and impact minimization measures for tribal cultural resources that could be located at the project site and will outline what to do and who to contact if any potential tribal cultural resources are encountered. The WEAP will emphasize the requirement for confidentiality and culturally appropriate treatment of any discovery of significance to Native Americans and will discuss appropriate behaviors and responsive actions, consistent with Native American tribal values.

4.13-1(b) In the Event that Tribal Cultural Resources are Discovered During Construction, Implement Procedures to Evaluate Tribal Cultural Resources and Implement Avoidance and Minimization Measures to Avoid Significant Impact.

If tribal cultural resources (such as structural features, unusual amounts of bone or shell, artifacts, or human remains) are encountered at the project site during construction, work shall be suspended within 100 feet of the find (based on the apparent distribution of cultural materials), and the construction contractor shall immediately notify the project’s City representative. Avoidance and preservation in place is the preferred manner of mitigating impacts to tribal cultural resources. This will be accomplished, if feasible, by several alternative means, including:
 Planning construction to avoid tribal cultural resources, archaeological sites and/or other cultural resources;
incorporating cultural resources within parks, green-space or other open space; covering archaeological resources; deeding a cultural resource to a permanent conservation easement; or other preservation and protection methods agreeable to
consulting parties and regulatory authorities with jurisdiction over the activity.
 Recommendations for avoidance of tribal cultural resources will be reviewed by the City representative, interested culturally affiliated Native American tribes and other appropriate agencies, in light of factors such as costs, logistics, feasibility, design, technology and social, cultural and environmental considerations, and the extent to which avoidance is consistent with project objectives. Avoidance and design alternatives may Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

include realignment within the project site to avoid tribal cultural resources, modification of the design to eliminate or reduce impacts to tribal cultural resources or modification or realignment to avoid highly significant features within a cultural resource or tribal cultural resource.
 Native American representatives from interested culturally affiliated Native American tribes will be notified to review and comment on these analyses and shall have the opportunity to meet with the City representative and its representatives who have technical expertise to identify and recommend feasible avoidance and design alternatives, so that appropriate and feasible avoidance and design alternatives can be identified.  If the discovered tribal cultural resource can be avoided, the construction contractor(s), will install protective fencing outside the site boundary, including a 100-foot buffer area, before construction restarts. The boundary of a tribal cultural resource will be determined in consultation with interested culturally affiliated Native American tribes and tribes will be notified to monitor the installation of fencing. Use of temporary and permanent forms of protective fencing will be determined in consultation with Native American representatives from
interested culturally affiliated Native American tribes.  The construction contractor(s) will maintain the protective fencing throughout construction to avoid the site during all remaining phases of construction. The area will be demarcated as an “Environmentally Sensitive Area”.

If a tribal cultural resource cannot be avoided, the following performance standard shall be met prior to continuance of construction and associated activities that may result in damage to or destruction of tribal cultural resources:
 Each resource will be evaluated for California Register of Historical Resources- (CRHR) eligibility through application of established eligibility criteria (California Code of Regulations 15064.636), in consultation with consulting Native American tribes, as applicable.

If a tribal cultural resource is determined to be eligible for listing in the CRHR, the City will avoid damaging effects to the resource in accordance with California PRC Section 21084.3, if feasible. The City shall coordinate the investigation of the find with a qualified archaeologist (meeting the Secretary of the Interior’s Professional Qualifications Standards for Archeology) approved by the City and with interested culturally affiliated Native American tribes that respond to the City’s notification. As part of the site investigation and resource assessment, the City and the archaeologist shall consult with interested culturally affiliated Native American tribes to assess the significance of the find, make recommendations for further evaluation and treatment Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

as necessary and provide proper management recommendations should potential impacts to the resources be determined by the City to be significant. A written report detailing the site assessment, coordination activities, and management recommendations shall be provided to the City representative by the qualified archaeologist.

These recommendations will be documented in the project record. For any recommendations made by interested culturally affiliated Native American tribes that are not implemented, a justification for why the recommendation was not followed will be provided in the project record.

Native American representatives from interested culturally affiliated Native American tribes and the City representative will also consult to develop measures for long-term management of any discovered tribal cultural resources. Consultation will be limited to actions consistent with the jurisdiction of the City and taking into account ownership of the subject property. To the extent that the City has jurisdiction, routine operation and maintenance within tribal cultural resources retaining tribal cultural integrity shall be consistent with the avoidance and minimization standards identified in this mitigation measure.

If the City determines that the project may cause a significant impact to a tribal cultural resource, and measures are not otherwise identified in the consultation process, the following are examples of mitigation capable of avoiding or substantially lessening potential significant impacts to a tribal cultural resource or alternatives that would avoid significant impacts to the resource. These measures may be considered to avoid or minimize significant adverse impacts and constitute the standard by which an impact conclusion of less-than significant may be reached:
 Avoid and preserve resources in place, including, but not limited to, planning construction to avoid the resources and protect the cultural and natural context, or planning greenspace, parks, or other open space, to incorporate the resources with culturally appropriate protection and management criteria.
 Treat the resource with culturally appropriate dignity taking into account the Tribal cultural values and meaning of the resource, including, but not limited to, the following:
o Protect the cultural character and integrity of the
resource.
o Protect the traditional use of the resource.
o Protect the confidentiality of the resource.
o Establish permanent conservation easements or other
interests in real property, with culturally appropriate management criteria for the purposes of preserving or
using the resources or places.
o Protect the resource.

4.13-1(c) Implement Procedures in the Event of the Inadvertent Discovery of Native American Human Remains.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

If an inadvertent discovery of human remains is made at any time during project-related construction activities or project planning, the City will implement the procedures listed above. The following performance standards shall be met prior to implementing or continuing actions such as construction, which may result in damage to or destruction of human remains. In accordance with the California Health and Safety Code (HSC), if human remains are encountered during ground-disturbing activities, the City shall immediately halt potentially damaging excavation in the area of the remains and notify the Sacramento County Coroner and a professional archaeologist to determine the nature of the remains. The Coroner is required to examine all discoveries of human remains within 48 hours of receiving notice of a discovery on private or State lands (HSC Section 7050.5[b]).

If the human remains are of historic age and are determined to be not of Native American origin, the City will follow the provisions of the HSC Section 7000 (et seq.) regarding the disinterment and removal of nonNative American human remains.

If the Coroner determines that the remains are those of a Native American, he or she must contact the Native American Heritage Commission (NAHC) by phone within 24 hours of making that determination (HSC Section 7050[c]). After the Coroner’s findings have been made, the archaeologist and the NAHC-designated Most Likely Descendant (MLD), in consultation with the landowner, shall determine the ultimate treatment and disposition of the remains. The responsibilities of the City for acting upon notification of a discovery of Native American human remains are identified in California PRC Section 5097.9 et seq.

Cumulative Impacts and Mitigation Measures
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. For further detail related to the cumulative setting of the proposed project, see Chapter 5, Statutorily Required Sections, of this EIR.

4.13-2 Cause a cumulative loss of tribal cultural resources. Based on the analysis below, the cumulative impact is less than
significant.

Generally, while some tribal cultural resources may have regional significance, the resources themselves are site-specific, and impacts to them are project-specific. For example, impacts to a subsurface tribal cultural resource at one project site would not generally be made worse by impacts to a tribal cultural resource at another site due to development of another project. Rather, the resources and the effects upon them are Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.13 – Tribal Cultural Resources

generally independent. A possible exception to the aforementioned general conditions would be where a tribal cultural resource represents the last known example of its kind or is part of larger resource site. For such a resource, cumulative impacts, and the contribution of a project to them, may be considered cumulatively significant.

As described throughout this chapter, the project site does not contain known resources that would be eligible for inclusion on the NRHP or considered significant pursuant to CEQA. Furthermore, implementation of the project-specific mitigation measures set forth in this EIR (Mitigation Measures 4.13-1[a] through 4.13-1[c]) would ensure that any impacts to previously unknown, subsurface resources that are discovered on the project site during construction activities are reduced to less than significant.

Similar to the proposed project, future development projects within the City would be required to consult with tribes culturally and traditionally affiliated with the project area to implement project-specific mitigation to ensure any potential impacts to identified tribal cultural resources are reduced to a less-than-significant level, where possible.

Therefore, given that tribal cultural resource impacts are generally site-specific and each future project within the City would be required to mitigate such impacts, any potential impacts associated with cumulative buildout of the City would not combine to result in a significant cumulative impact.

Based on the above, the potential for impacts related to a cumulative loss of tribal cultural resources, to which implementation of the proposed project might contribute, is less than significant.

Mitigation Measure(s)
None required.

5. EFFECTS NOT FOUND TO BE

SIGNIFICANT

Draft EIR
Airport South Industrial Project
May 2024
Chapter 5 – Effects Not Found to be Significant

5.1 INTRODUCTION
Section 15128 of the CEQA Guidelines requires that an EIR briefly describe why various environmental effects were determined not to be significant and therefore were not discussed in detail in the EIR. The Effects Not Found to be Significant chapter of this EIR summarizes environmental issues that were determined not to be significant with implementation of the proposed project. The reasons for the conclusion of non-significance are provided for each issue area, as applicable, below.

5.2 FORESTRY RESOURCES
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:
 Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code [PRC] Section 12220[g]), timberland (as defined by PRC Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104[g]); or
 Result in the loss of forest land or conversion of forest land to non-forest use.

The project site is not considered forest land (as defined in PRC Section 12220[g]), timberland (as defined by PRC Section 4526), and is not zoned Timberland Production (as defined by Government Code Section 51104[g]). In addition, installation of the proposed off-site force main, including each of the three potential force main segment options, would occur either in existing roadway ROW or in other previously disturbed areas. As such, the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland, or result in the loss of forest land or conversion of forest land to non-forest use.

Therefore, the project would result in no impact.

5.3 GEOLOGY AND SOILS
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:
 Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

As stated in Chapter 3, Project Description, of the EIR, one of the project objectives for the proposed project is to amend the Sphere of Influence of the Sacramento Area Sewer District (SacSewer) to provide wastewater services to the project site. Therefore, the proposed project would not use septic tanks or alternative wastewater disposal systems, and no impact would occur related to having soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

5. EFFECTS NOT FOUND TO BE SIGNIFICANT
Draft EIR
Airport South Industrial Project
May 2024
Chapter 5 – Effects Not Found to be Significant

5.4 HAZARDS AND HAZARDOUS MATERIALS
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:
 Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; and
 Expose people or structures, either directly or indirectly, to the risk of loss, injury or death involving wildland fires.

As discussed in Chapter 4.12, Transportation, of this EIR, the proposed project would comply with Sacramento 2040 General Plan policies and design standards, and, as a result, would not impair any emergency response or evacuation plans. As discussed in further detail below, the proposed project is not located within a Very High Fire Hazard Severity Zone or a High Fire Hazard Severity Zone as assessed by the California Department of Forestry and Fire Protection (CAL FIRE) Fire and Resource Assessment Program. As such, no impact would occur with respect to wildfires.

5.5 MINERAL RESOURCES
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:
 Result in the loss of availability of a known mineral resource that would be of value to the region and residents of the state; or
 Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

According the California Geological Survey Information Warehouse: Mineral Land Classification, Portland Cement, Concrete-Grade Aggregate and Clay Resources are found in the greater Sacramento region. The Sacramento County General Plan EIR evaluated potential impacts related to mineral resources that could occur through buildout of the County’s General Plan planning area and concluded that because the County could not rule out the possibility of future development precluding or inhibiting the extraction of known, available, high-quality mineral resources in the Jackson Highway Corridor growth area, the impact would be significant and unavoidable. However, the County’s General Plan EIR notes that only a relatively small portion of the County overlies known, high-quality mineral resources that are available for extraction.

Additionally, the majority of the County’s mineral resources are located in the northwest portion of the Jackson Highway Corridor growth area, generally between the intersection of Elder Creek Road and Elk Grove Florin Road and the south side of Mather Airport. The project site is not located within the aforementioned area. Furthermore, the City of Sacramento Master EIR (MEIR) states that should a project lead to the loss of the availability of known mineral resources of State, regional, or local importance, adherence to SMARA and the City Code would promote compatibility with surrounding land uses for both future and existing mineral production activities and prevent development that would limit these activities. Because the proposed project would be required to comply with the foregoing requirements, and due to the project site’s location outside of the Jackson Highway Corridor growth area, a less-than-significant impact would occur.

5.6 POPULATION AND HOUSING
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:

Draft EIR
Airport South Industrial Project
May 2024
Chapter 5 – Effects Not Found to be Significant

 Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

The project site is currently not developed with residential development. In addition, installation of the proposed off-site force main, including each of the three potential force main segment options, would occur either in existing roadway ROW or in other previously disturbed areas. Thus, the proposed project would not result in the displacement of existing housing or residents, and no impact would occur.

5.7 WILDFIRE
Consistent with Appendix G of the CEQA Guidelines, the proposed project was determined to have no impact with regard to the following issue areas:
 Substantially impair an adopted emergency response plan or emergency evacuation plan;  Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
 Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or  Expose people or structures to significant risks, including downslope or downstream flooding, or landslides, as a result of the runoff, post-fire slope instability, or drainage changes.

The project site is not located in a Very High Fire Hazard Severity Zone or a High Fire Hazard Severity Zone as assessed by the CAL FIRE Fire and Resource Assessment Program.

Additionally, the project site is not located in a State Responsibility Area. As such, there would be no impact with respect to wildfires.

In addition, as discussed in Chapter 4.12, Transportation, of this EIR, the proposed project would comply with Sacramento 2040 General Plan policies and design standards, and as a result would not impair any emergency response or evacuation plans. Similarly, the project site is located on flat land, and therefore, would not exacerbate fire risks or expose people or structures to risks due to a slope. Finally, the project site is surrounded by existing and planned development which would serve as a fire break to decrease fire risks.

6. STATUTORILY REQUIRED SECTIONS

Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

6.1 INTRODUCTION
The Statutorily Required Sections chapter of the Draft EIR includes discussions regarding those topics that are required to be included in an EIR, pursuant to CEQA Guidelines, Section 15126.2.

The chapter includes a discussion of the proposed project’s potential to result in growth-inducing impacts; the cumulative setting analyzed in this EIR; significant irreversible environmental changes; and significant and unavoidable impacts caused by the proposed project.

6.2 GROWTH-INDUCING IMPACTS
State CEQA Guidelines section 15126.2(e) requires an EIR to evaluate the potential growthinducing impacts of a proposed project. Specifically, an EIR must discuss the ways in which a proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Growth can be induced in a number of ways, including the elimination of obstacles to growth, or by encouraging and/or facilitating other activities that could induce growth. Examples of projects likely to have growthinducing impacts include extensions or expansions of infrastructure systems beyond what is needed to serve project-specific demand, and development of new residential subdivisions or office complexes in areas that are currently only sparsely developed or are undeveloped.

The CEQA Guidelines are clear that while an analysis of growth-inducing effects is required, it should not be assumed that induced growth is necessarily significant or adverse. This analysis examines the following potential growth-inducing impacts related to implementation of the proposed project and assesses whether these effects are significant and adverse (see CEQA Guidelines, Section 15126.2[e]):

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

2. Eliminate obstacles to population growth.

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

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

Foster Population and Economic Growth, or the Construction of Housing
As discussed in further detail in Chapter 3, Project Description, of this EIR, while the proposed project would require approval of a Sphere of Influence (SOI) Amendment and Annexation of the entire project site into the City of Sacramento limits, only the industrial park is currently proposed for development. Although the nonparticipating parcels portion of the project site is planned for future industrial development, such development is not currently proposed. It is noted that because the project site is not currently located within the City of Sacramento SOI and requires approval of a General Plan Amendment (GPA) and Prezoning, buildout of the project site, as well as any associated population or economic growth, has not been anticipated or analyzed in the City of Sacramento 2040 General Plan Master EIR (MEIR). However, the 2040 MEIR does mention probable future projects within Sacramento County, including the Airport South Industrial Project.

6. STATUTORILY REQUIRED SECTIONS
Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

As discussed further under Impact 4.9-4 in the Land Use and Planning/Population and Housing chapter of this EIR, the proposed project would include the development of the industrial park portion of the project with industrial and retail/highway commercial uses, including hotel/hospitality uses. Because of the industrial and commercial nature of the proposed project, buildout would not directly result in an increase in population or construction of housing.

While construction of the proposed project would result in a limited increase in construction employment opportunities, construction would be temporary, and jobs would likely be filled by the local employee base. Therefore, an increase in permanent population and a demand for housing in the vicinity of the project site as a result of the construction-related employment opportunities associated with the proposed project would not occur.

The proposed project would also provide long-term employment opportunities associated with operation of the proposed industrial and commercial facilities. Although development of the proposed project could generate a total of approximately 4,000 employees, new employees would likely be drawn from current residents in the area. According to the City’s population projections, as presented in Table 4.9-4, City of Sacramento Population Growth Projections, in Chapter 4.9, Land Use and Planning/Population and Housing, of this EIR, the population of the City of Sacramento is anticipated to increase from 2020 to 2030 by 111,515. Conservatively estimating that all permanent positions associated with the project would be filled by new residents to the Sacramento region and assuming that the proposed project would be fully built out and operating at full capacity by 2030, the project’s contribution to the overall population increase by 2030 would be approximately 0.77 percent. Thus, the increase in jobs would be relatively small compared to the City’s existing and anticipated population levels. As such, the proposed project would not result in a substantial increase in permanent population and a demand for housing in the vicinity of the project site.

Surrounding existing land uses include a Life Storage facility and the Westlake single-family residential subdivision to the east; the West Drainage Canal, vacant agricultural land, open space land, and the Paso Verde K-8 School to the south; undeveloped agricultural land to the west; the Sacramento International Airport to the northwest, across I-5; and the Metro Air Park, Amazon SMF-1 Fulfillment Center, and the under-construction Northlake (Greenbriar) subdivision to the north, across I-5. It should also be noted that the approved Sacramento International Airport Master Plan is located to the northwest of the project site, and the proposed SWIFT Project is located adjacent to the project site’s western boundary. As such, the project site is surrounded to the north, west, and east by existing, planned, or proposed development. Therefore, development of the proposed project would not result in additional development in the vicinity of the project site beyond what has been anticipated.

The proposed project has the potential to foster economic growth due to the commercial nature and employment opportunities of the proposed project. However, it is reasonable to assume that the magnitude of economic growth would not be substantial such that new business growth would result elsewhere in the region which could necessitate additional housing to support the employment base. Thus, while the project would foster economic growth, a less-than-significant impact related to population and economic growth would occur.

Eliminate Obstacles to Population Growth
The elimination of either physical or regulatory obstacles to growth is considered to be a growthinducing effect. A physical obstacle to growth typically involves the lack of public service Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

infrastructure. The extension of public service infrastructure, including roadways, water mains, and sewer lines, into areas that are not currently provided with these services, would be expected to support new development. Similarly, the elimination or change to a regulatory obstacle, including existing growth and development policies, could result in new growth.

As discussed in Chapter 4.11, Public Services, Utilities, and Service Systems, of this EIR, the City of Sacramento operates and maintains a 30-inch water transmission main in Bayou Way that terminates near the eastern boundary of the project site. The proposed project would include the installation of new 12-inch water lines which would connect to the existing 30-inch water transmission main to serve the project site. However, water infrastructure would not be extended beyond the project site to serve other areas, and the proposed project does not include residential uses. Thus, the proposed water system is not anticipated to result in elimination of obstacles to population growth. Additionally, although the proposed project would include installation of an offsite force main, which would extend from the northeastern corner of the project site to the existing 48-inch Sacramento Area Sewer District (SacSewer) North Natomas interceptor line in East Commerce Way, the force main would sized to accommodate wastewater flows from only the project site, and as discussed, the project does not include residential uses. Thus, the proposed off-site force main would not directly or indirectly induce population growth.

As detailed in the Project Description chapter of this EIR, sanitary sewer conveyance service within the project site would be provided through a gravity system, which would include the extension of new sewer lines from the project site to existing off-site trunk lines, and would require the installation of a new pump station. However, the gravity system would be sized to accommodate the proposed project’s wastewater generation only. Therefore, the proposed gravity system would not serve to eliminate obstacles to population growth in the project vicinity.

Based on the above, all utility infrastructure improvements involved in the proposed project would exclusively serve the proposed project. Additionally, as noted above, the proposed project would include a SOI Amendment and Annexation, as well as a GPA and Prezoning. As part of approval of the SOI Amendment, the City of Sacramento SOI would be amended to include the project site, which would facilitate Annexation of the project site into the City; development of the industrial park portion of the project, as well as future development of the nonparticipating parcels, has not been anticipated by the MEIR. However, the foregoing entitlements would only apply to the project site and would not allow for further expansion of the City boundaries or additional development beyond what is proposed. Therefore, the project would not be anticipated to eliminate any obstacles to population growth.

Affect Service Levels, Facility Capacity, or Infrastructure Demand Increases in population that would occur as a result of a proposed project, including the proposed industrial park and future development of the nonparticipating parcels within the Annexation Area, may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental impacts. As discussed in Chapter 4.11, Public Services, Utilities, and Service Systems, of this EIR, increased demands for fire and police protection services attributable to the proposed project would not necessitate the construction of new or expanded facilities that could cause significant environmental impacts. In addition, wastewater generated by the proposed project could be accommodated by wastewater treatment facilities and infrastructure proposed as part of the project, including the proposed off-site force main alignment, and existing water supply infrastructure exists to accommodate the domestic water demand associated with the proposed project.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

The landfill that would serve the proposed project has adequate capacity to manage the solid waste generated as result of the project. Furthermore, mitigation measures set forth in Chapter

4.8, Hydrology and Water Quality, of this EIR would ensure that the proposed project would not create or contribute runoff water that would exceed the capacity of the proposed and existing stormwater drainage systems. Therefore, the proposed project would not increase population such that service levels, facility capacity, or infrastructure demand would require construction of new facilities that could cause significant environmental impacts.

Encourage or Facilitate other Activities That Could Significantly Affect the Environment
This EIR provides a comprehensive assessment of the potential for environmental impacts associated with implementation of the proposed project. Please refer to Chapters 4.1 through

4.13 of this EIR, which comprehensively address the potential for impacts from development on the project site.

6.3 CUMULATIVE IMPACTS
CEQA Guidelines, Section 15130 requires that an EIR discuss the cumulative and long-term effects of the proposed project that would adversely affect the environment. “Cumulative impacts” are defined as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts” (CEQA Guidelines, Section 15355). “[I]ndividual effects may be changes resulting from a single project or a number of separate projects” (CEQA Guidelines, Section 15355, subd. [a]). “The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time” (CEQA Guidelines, Section 15355, subd. [b]).

The need for cumulative impact assessment reflects the fact that, although a project may cause an “individually limited” or “individually minor” impact that, by itself, is not significant, the increment may be “cumulatively considerable,” and, thus, significant, when viewed together with environmental changes anticipated from past, present, and probable future projects (CEQA Guidelines, Section 15064[h][1] and Section 15355[b]). Accordingly, particular impacts may be less than significant on a project-specific basis but significant on a cumulative basis if their small incremental contribution, viewed against the larger backdrop, is cumulatively considerable.

However, it should be noted that CEQA Guidelines, Section 15064, Subdivision (h)(4) states, “[…]the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.” Therefore, even where cumulative impacts are significant, any level of incremental contribution is not necessarily deemed cumulatively considerable.

Section 15130(b) of CEQA Guidelines indicates that the level of detail of the cumulative analysis need not be as great as for the project impact analyses, but that analysis should reflect the severity of the impacts and their likelihood of occurrence, and that the analysis should be focused, practical, and reasonable. To be adequate, a discussion of cumulative effects must include the following elements:
(1) Either (a) a list of past, present and probable future projects, including, if necessary, those outside the agency’s control, or (b) a summary of projections contained in an adopted general plan or related planning document, or in a prior certified EIR, which Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

described or evaluated regional or area-wide conditions contributing to the cumulative impact, provided that such documents are referenced and made available for public inspection at a specified location;
(2) A summary of the individual projects’ environmental effects, with specific reference to additional information and stating where such information is available; and (3) A reasonable analysis of all of the relevant projects’ cumulative impacts, with an examination of reasonable, feasible options for mitigating or avoiding the project’s contribution to such effects (Section 15130[b]).

For some projects, the only feasible mitigation measures will involve the adoption of ordinances or regulations, rather than the imposition of conditions on a project-by-project basis (Section 15130[c]). Section 15130(a)(3) states that an EIR may determine that a project’s contribution to a significant cumulative impact will be rendered less than cumulatively considerable, and thus not significant, if a project is required to implement or fund the project’s fair share of a mitigation measure or measures designed to alleviate the cumulative impact.

A discussion of cumulative impacts is provided within each of the technical chapters of this EIR pursuant to CEQA Guidelines Section 15130.

Cumulative Setting
The lead agency should define the relevant geographic area of inquiry for each impact category (id., Section 15130, subd. [b][3]), and should then identify the universe of “past, present, and probable future projects producing related or cumulative impacts” relevant to the various categories, either through the preparation of a “list” of such projects or through the use of “a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area wide conditions contributing to the cumulative impact” (id., subd. [b][1]).

As discussed above, two approaches exist for identifying cumulative projects and their associated impacts. The “list” approach identifies individual projects known to be occurring or proposed in the surrounding area in order to identify potential cumulative impacts. The “projection” approach uses a summary of projections in adopted General Plans or related planning documents to identify potential cumulative impacts. This EIR uses the projection approach for the cumulative analysis, which is based upon a summary of projections contained in the City of Sacramento 2040 General Plan and the Sacramento County General Plan. The reason for using these two adopted plans as the cumulative setting is that although the project site is currently part of Sacramento County, following project approval, the project site would be annexed into the City of Sacramento’s Sphere of Influence. Planned and future development within the City’s 2040 General Plan policy area or areas within Sacramento County in the project vicinity include the Sacramento County WattEV Innovative Freight Terminal Project, the Northlake (Greenbriar) Project, the Metro Air Park Project, the Elkhorn Boulevard Extension Project, the Upper West Side Specific Plan, the Sacramento International Airport Master Plan, and the Grandpark Specific Plan.

Limited situations exist where the geographic setting differs for certain CEQA topics. Examples include air quality, for which the cumulative geographic setting is the Sacramento Valley Air Basin (SVAB). Global climate change is, by nature, a cumulative impact. Emissions of GHG contribute, on a cumulative basis, to the significant adverse environmental impacts of global climate change (e.g., sea level rise, impacts to water supply and water quality, public health impacts, impacts to Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

ecosystems, impacts to agriculture, and other environmental impacts). A single project could not generate enough GHG emissions to contribute noticeably to a change in the global average temperature. However, the combination of GHG emissions from a project in combination with other past, present, and future projects could contribute substantially to the world-wide phenomenon of global climate change and the associated environmental impacts. Although the geographical context for global climate change is the Earth, for analysis purposes under CEQA, and due to the regulatory context pertaining to GHG emissions and global climate change applicable to the proposed project, the geographical context for global climate change in this EIR is limited to the State of California.

In addition, as discussed in Chapter 4.8, Hydrology and Water Quality, of this EIR, the cumulative analysis is defined by watershed boundaries. The project site is located within the Natomas Basin.

Overall, the total watershed area being analyzed within this EIR includes approximately 50,000 acres.

6.4 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
Per CEQA Guidelines Section 15126.2(d), this EIR is required to include consideration of significant irreversible environmental changes that would be caused by the proposed project, should the project be implemented. An impact would be determined to be a significant and irreversible change in the environment if:
 Buildout of the project area could involve a large commitment of nonrenewable resources;  The primary and secondary impacts of development could generally commit future generations to similar uses (e.g., a highway provides access to a previously remote area);  Development of the proposed project could involve uses in which irreversible damage could result from any potential environmental accidents associated with the project; or  The phasing and eventual development of the project could result in an unjustified consumption of resources (e.g., the wasteful use of energy).

The proposed project would likely result in, or contribute to, the following significant irreversible environmental changes:
 Irreversible consumption of construction materials, such as lumber, associated with the proposed project;
 Irreversible consumption of goods and services, such as fire and police services, associated with project buildout;
 Irreversible consumption of energy and natural resources, such as water, electricity, and natural gas, associated with project buildout;
 Irreversible conversion of agricultural land to non-agricultural use; and  Irreversible conversion of biological habitat to urban use.

6.5 SIGNIFICANT AND UNAVOIDABLE IMPACTS
According to CEQA Guidelines, an EIR must include a description of those impacts identified as significant and unavoidable should the proposed action be implemented (CEQA Guidelines Section 15126.2[c]). Such impacts would be considered unavoidable when the determination is made that either mitigation is not feasible or only partial mitigation is feasible such that the impact is not reduced to a level that is less-than-significant. This section identifies significant impacts that could not be eliminated or reduced to a less-than-significant level by mitigations imposed by the Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

City of Sacramento and the Sacramento Local Agency Formation Commission (LAFCo). The final determination of the significance of impacts and the feasibility of mitigation measures would be made by the City and the Sacramento LAFCo as part of their certification actions. The significant and unavoidable impacts of the proposed project are summarized below.

In a non-urbanized area, 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) or, in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality. (Impact 4.1-3) Implementation of the proposed project would result in a significant impact related to the change of the existing public viewsheds of the site from predominantly undeveloped, disced fields with scattered trees and bushes to industrial and commercial development. Although the inclusion of landscaping trees would partially obscure views of the industrial park portion of the project site, the existing visual character and quality of public views of the site would be substantially degraded by development of both components of the proposed project. Feasible mitigation does not exist to reduce such impacts to a less-than-significant level. Therefore, a significant and unavoidable impact would occur.

Long-term changes in visual character associated with cumulative development of the proposed project in combination with future buildout of the City of Sacramento 2040 General Plan and the Sacramento County General Plan (Impact 4.1-5)
Development of the proposed project, in combination with existing and planned development in the project vicinity, including the Northlake (Greenbriar) subdivision currently under construction northeast of the project site, the industrial development associated with the Metro Air Park north of the site, and the development associated with the Sacramento International Airport northwest and west of the site, the proposed project would contribute towards significantly altering the visual character of the surroundings. Therefore, the impact would be significant and unavoidable.

Impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use. (Impact 4.2-1)
While the nonparticipating parcels do not contain land that is defined as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and, thus, would not result in negative impacts to such resources upon future development, construction activities on the rest of the project site would result in conversion of approximately 31.3 acres of Prime Farmland and approximately 12.1 acres of Farmland of Statewide Importance in the northeast corner of the project site. While implementation of Mitigation Measure 4.2-1 would preserve an equivalent acreage of Farmland elsewhere, the proposed project would result in the conversion of agricultural land to urban uses, and would not create new agricultural land; as such, the proposed project would lead to an overall loss of Farmland. Therefore, the impact would remain significant and unavoidable.

Impacts related to compliance with the policies of Sacramento LAFCo pertaining to the conversion of agricultural land. (Impact 4.2-4) The proposed project site is currently located within Sacramento County and has a Sacramento County General Plan land use designation of Agricultural Cropland and is zoned AG-80. The Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

proposed project would include a request for annexation of the 474.4-acre project site to the City of Sacramento, which ultimately requires the approval of Sacramento LAFCo. Sacramento LAFCo policies related to agricultural land include those related to the conversion of areas containing prime soils or productive agricultural operations to uses that are not conducive to agricultural production. Because the project site is proposed to be annexed into the City of Sacramento and the industrial park portion of the site is proposed for commercial and industrial development, onsite soils are evaluated in comparison to the Sacramento LAFCo’s definition of prime agricultural land. The project site contains an approximate total of 385.3 acres of soils that qualify for rating as Class II when irrigated in the Soil Conservation Service land use capability classification.

Criteria (a) of the Sacramento LAFCo’s definition of prime agricultural land applies to soils that qualify as Class I or Class II, regardless of whether the soil is non-irrigated or irrigated, provided that irrigation is feasible. Thus, soils within the proposed project site meet criteria (a) to qualify as prime agricultural farmland under Section 56064 of the Cortese-Knox-Hertzberg Act. Potential mitigation for impacts related to the conversion of prime agricultural land to non-agricultural uses could include purchasing agricultural conservation easements outside the project area. However, as discussed above, such mitigation would not create new agricultural land; rather, the mitigation would simply preserve existing agricultural land elsewhere. Feasible mitigation measures do not exist to reduce the above impact to a less-than-significant level. Therefore, the impact would remain significant and unavoidable.

Impacts related to cumulative loss of agricultural land. (Impact 4.2- 5)
Development of the proposed project, as well as other development within the County’s General Plan policy area, such as the proposed Upper Westside Specific Plan, the Sacramento International Airport Master Plan, the Grandpark Specific Plan, and Metro Air Park, would contribute to the cumulative loss of agricultural land. Therefore, even with implementation of mitigation, the project’s incremental contribution to the cumulative impact is cumulatively considerable and significant and unavoidable.

Conflict with or obstruct implementation of the applicable air quality plan during project operation. (Impact 4.3-2)
Emissions resulting from operation of the proposed project under both the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario would be below the applicable Sacramento Metropolitan Air Quality Management District (SMAQMD) thresholds for Particulate Matter (PM10 and PM2.5). However, reactive organic gases (ROG) and oxides of nitrogen (NOX) emissions would be above the applicable SMAQMD thresholds of significance under both project scenarios. Therefore, operation of the proposed project could create a conflict with or obstruct implementation of the applicable air quality plan. Although Mitigation Measure 4.3-2 requires preparation and implementation of a project-specific Air Quality Mitigation Plan (AQMP) which would result in a 35 percent reduction in emissions, emission levels would still exceed the applicable threshold of significance and, therefore, the impact would remain significant and unavoidable.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 6 – Statutorily Required Sections

Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). (Impact 4.3-6)
The proposed project is within a nonattainment area for ozone and PM10. By nature, air pollution is largely a cumulative impact. The population growth and vehicle usage within the nonattainment area from the proposed project, in combination with other past, present, and reasonably foreseeable projects within Sacramento and surrounding areas, contributes to the region’s adverse air quality impacts on a cumulative basis, and could either delay attainment of AAQS or require the adoption of additional controls on existing and future air pollution sources to offset emission increases. Thus, the project’s emissions of criteria air pollutants would contribute to cumulative regional air quality effects. The proposed project’s unmitigated cumulative contribution to regional emissions is equivalent to the project’s unmitigated operational emissions. As such, although the proposed project’s unmitigated operational emissions of PM10 and PM2.5 would be below the SMAQMD’s applicable thresholds of significance, because the proposed project would result in operational emissions of ROG and NOX, which exceed all applicable SMAQMD thresholds of significance, the proposed project could be considered to result in a cumulatively considerable net increase of a criteria pollutant for which the project region is non-attainment.

7. ALTERNATIVES ANALYSIS

Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

7.1 INTRODUCTION
The Alternatives Analysis chapter of the EIR includes consideration and discussion of a range of reasonable alternatives to the proposed project, as required per CEQA Guidelines Section 15126.6. Generally, the chapter includes discussions of the following: the purpose of an alternatives analysis; alternatives considered but dismissed; a reasonable range of project alternatives and their associated impacts in comparison to the proposed project’s impacts; and the environmentally superior alternative.

7.2 PURPOSE OF ALTERNATIVES
The primary intent of the alternatives evaluation in an EIR, as stated in Section 15126.6(a) of the CEQA Guidelines, is to “[…] describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” In the context of CEQA Guidelines Section 21061.1, “feasible” is defined as:
[...]capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors.

Section 15126.6(f) of CEQA Guidelines states, “The range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice.” Section 15126.6(f) of CEQA Guidelines further states:

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

In addition, an EIR is not required to analyze alternatives when the effects of the alternative “cannot be reasonably ascertained and whose implementation is remote and speculative.” The CEQA Guidelines provide the following guidance for discussing alternatives to a proposed project:
 An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives (CEQA Guidelines Section 15126.6[a]).
 Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code [PRC] Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if

7. ALTERNATIVES ANALYSIS
Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

these alternatives would impede to some degree the attainment of the project objectives, or would be more costly (CEQA Guidelines Section 15126.6[b]).  The EIR should briefly describe the rationale for selecting the alternatives to be discussed.

The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination […] Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts (CEQA Guidelines Section 15126.6[c]).  The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison (CEQA Guidelines Section 15126.6[d]).  If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed (CEQA Guidelines Section 15126.6[d]).
 The specific alternative of “no project” shall also be evaluated along with its impact. The purpose of describing and analyzing a no project alternative is to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. The no project alternative analysis is not the baseline for determining whether the proposed project’s environmental impacts may be significant, unless it is identical to the existing environmental setting analysis which does establish that baseline (CEQA Guidelines Section 15126.6[e][1]).
 If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (CEQA Guidelines Section 15126.6[e][2]).

Project Objectives
Based on the above, reasonable alternatives to the project must be capable of feasibly attaining most of the basic objectives of the project. The proposed project is being pursued with the following objectives:

1. Utilize a targeted municipal service review to amend the City’s Sphere of Influence, followed by Annexation of the project site into the City of Sacramento, to construct a highquality industrial park with elevated aesthetics to be capable of serving warehouse, distribution, research, and other light industrial uses, as well as retail and commercial uses.

2. Utilize a targeted municipal service review to amend the Sphere of Influence of the Sacramento Area Sewer District (SacSewer) to provide wastewater services to the project site.

3. Create substantial, permanent employment opportunities for residents of the City of Sacramento and surrounding areas, including the North Natomas area and the Northlake project site.

4. Provide light industrial and warehousing opportunities closer to the City of Sacramento developed areas, thereby lowering local and regional vehicle miles traveled (VMT) and traffic congestion.

5. Provide needed retail, commercial, and hotel uses along the I-5 corridor in close proximity to Sacramento International Airport.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

6. Attract new businesses and jobs to the City, thereby improving the jobs/housing balance both in the City and the region.

7. Construct an industrial park that incorporates energy efficiency and low water use principles in order to promote the City’s environmental goals.

8. Utilize alternative energy sources, including solar panels, where feasible.

9. Locate the project as near as possible to existing developed areas and utility infrastructure with anticipated capacity.

10. Create an internal roadway network for the project site that will allow for efficient access to the site and limit impacts to offsite roadways by directing truck traffic directly to Interstate

5. 11. Phase project construction to be responsive to market demands.

12. Minimize environmental impacts to surrounding areas, including residential communities and other sensitive land uses.

Impacts Identified in the EIR
In addition to attaining the majority of project objectives, reasonable alternatives to the project must be capable of reducing the magnitude of, or avoiding, identified significant environmental impacts of the proposed project. The significant and unavoidable impacts identified in the EIR are presented below.
 Aesthetics. The EIR determined that the proposed project would result in significant and unavoidable impacts related to substantially degrading the existing visual character or quality of public views of the site and its surroundings. Although the inclusion of landscaping trees would partially obscure views of the industrial park portion of the project site, the existing visual character and quality of public views of the site would be substantially degraded by development of both components of the proposed project. In addition, the EIR determined that the proposed project would result in significant and unavoidable impacts related to long-term changes in visual character associated with cumulative development of the proposed project in combination with future buildout of the City of Sacramento 2040 General Plan and the Sacramento County General Plan.  Agricultural Resources. The EIR determined that the proposed project would result in significant and unavoidable impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use, even with implementation of mitigation measures. While the Nonparticipating Parcels do not contain such land, construction activities on the rest of the project site would result in conversion of approximately 31.3 acres of Prime Farmland and approximately 12.1 acres of Farmland of Statewide Importance. Similarly, because the project site is proposed to be annexed into the City of Sacramento and the industrial park portion of the site is proposed for commercial and industrial development, on-site soils are evaluated in comparison to the Sacramento Local Agency Formation Commission’s (LAFCo) definition of prime agricultural land. The EIR identified significant and unavoidable impacts related to compliance with the policies of the Sacramento LAFCo pertaining to the conversion of agricultural land even with implementation of mitigation measures.  Air Quality, GHG Emissions, and Energy. The EIR determined that the proposed project would result in significant and unavoidable impacts related to conflicting with or obstructing implementation of the applicable air quality plan during project operation under both the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario because Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

the reactive organic gases (ROG) and oxides of nitrogen (NOX) emissions would be above the applicable Sacramento Metropolitan Air Quality Management District (SMAQMD) thresholds of significance. Additionally, the EIR determined that the amount of ROG and NOX emissions generated by the proposed project would result in a cumulatively considerable net increase of a criteria pollutant for which the project region is in nonattainment under an applicable federal or State ambient air quality standard (AAQS).

7.3 SELECTION OF ALTERNATIVES
The requirement that an EIR evaluate alternatives to the proposed project or alternatives to the location of the proposed project is a broad one; the primary intent of the alternatives analysis is to disclose other ways that the objectives of the project could be attained, while reducing the magnitude of, or avoiding, one or more of the significant environmental impacts of the proposed project. Alternatives that are included and evaluated in the EIR must be feasible alternatives.

However, the CEQA Guidelines require the EIR to “set forth only those alternatives necessary to permit a reasoned choice.” As stated in Section 15126.6(a), an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. The CEQA Guidelines provide a definition for “a range of reasonable alternatives” and thus limit the number and type of alternatives that may need to be evaluated in a given EIR. According to the CEQA Guidelines Section 15126.6(f):

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

First and foremost, alternatives in an EIR must be feasible. In the context of CEQA Guidelines Section 21061.1, “feasible” is defined as:
[...] capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors.

Finally, an EIR is not required to analyze alternatives when the effects of the alternative “cannot be reasonably ascertained and whose implementation is remote and speculative.” Alternatives Considered But Dismissed From Further Analysis Consistent with CEQA, primary consideration was given to alternatives that could reduce significant project impacts, while still meeting most of the basic project objectives.

As stated in Guidelines Section 15126.6(c), among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are:
(i) failure to meet most of the basic project objectives, (ii) infeasibility, or
(iii) inability to avoid significant environmental impacts.

Regarding item (ii), infeasibility, among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent). The aforementioned factors do not establish a fixed limit on the scope of reasonable alternatives.

An off-site alternative and mixed use residential alternative were considered but dismissed from detailed analysis in this EIR. The reasons for dismissal, within the context of the three aboveoutlined permissible reasons, are provided below.

Off-Site Alternative
The possibility of an off-site location was considered as an alternative to the proposed project.

The County’s Geographic Information System (GIS) database was consulted to provide information regarding vacant properties in the area of sufficient size to accommodate the proposed project. In considering sites potentially available for future development, the objectives of the proposed project were used to assess the suitability of available sites.

Various potential sites were reviewed. The location that comes closest to feasibility is located northwest of the intersection of Fruitridge Road and South Watt Avenue in the southeast portion of the City, and is already designated Industrial Mixed-Use by the Sacramento 2040 General Plan.

Use of this land for an off-site alternative would not require the City to annex the land or expand its Sphere of Influence. Other sites were not identified, and thus, the Fruitridge and South Watt Avenue site was reviewed.

In order to include a comparable amount of acreage to the proposed project, the off-site alternative would require the demolition of several commercial businesses, including, but not limited to, a building materials store, furniture store, and 7-Eleven convenience store. In addition, approximately 117 acres of the 354 acres required of the alternative would consist of land already set aside for L and D Landfill. Given that buildout of the off-site alternative at this location would require the project applicant to either redesign the proposed project to build around existing commercial businesses or reduce the amount of land designated for residential development while simultaneously demolishing existing businesses, the Off-Site Alternative would be in direct conflict with the project objectives concerning improvement of the job and housing balance in the City and the region. Finally, the project applicant does not own the identified alternative site.

Overall, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible. As a result, the Off-Site Alternative is dismissed from detailed evaluation.

Mixed-Use Residential Alternative
Given that the proposed project already contains plans for industrial development and commercial development, the proposed project is already considered a mixed-use project. However, the Mixed-Use Residential Alternative would include buildout of the project site as proposed for the majority of the parcels, while designating Parcels 5 and 8 for a residential neighborhood. The Mixed-Use Residential Alternative would result in the development of 704,320 fewer square feet (sf) of industrial buildings than the proposed project, and would develop approximately 109.7 acres of agricultural land as residential.

However, the development of portions of the project site with residential uses would prevent the proposed project from developing employment uses, as specified in the project objectives, and could result in conflicts related to the incompatibility between residential and industrial land uses.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

Buildout of the Mixed-Use Residential Alternative would require the modification of the proposed entitlement actions, such as the addition of residential designations to the requested GPA and Prezoning. Additionally, the proximity of the new residential development on-site, such as on Parcel 8, may result in significant impacts (e.g., noise conflicts, exposure to toxic air contaminants, etc.) with the planned industrial uses of the proposed project.

Overall, a Mixed-Use Residential Alternative that could accomplish the project objectives is not considered feasible. As a result, the Mixed-Use Residential Alternative is dismissed from detailed evaluation.
100 Percent Electric Fleet Alternative
The 100 Percent Electric Fleet Alternative would consist of buildout of the project site as proposed, including the future industrial warehouse buildout, and would require all active warehouses to develop the entire truck fleet with electric vehicles (EVs) at full buildout.

Because the 100 Percent Electric Fleet Alternative would include development of the project site with the proposed uses, all of the project objectives would be met. In addition, because the 100 Percent Electric Fleet Alternative would include the operation of EVs over gas-powered vehicles, the project objectives concerning energy efficiency, utilizing alternative energy sources, and minimizing impacts would be improved. In the case of an electric fleet, impacts associated with air quality and GHG emissions would be most significantly reduced by this Alternative.

However, requiring the proposed project to maintain a completely electric fleet would render the project infeasible. EVs are an emerging technology and are not yet produced on a scale that would allow future tenants of the proposed industrial park to maintain a completely electric fleet.

As such, requiring a fully electric fleet of any future tenants would limit the pool of potential tenants to such a degree that extensive vacancies could occur, or that the project site would be unable to develop the parcels consistent with the project objectives. As such, the 100 Percent Electric Fleet Alternative was dismissed from detailed evaluation.

Alternatives Considered in this EIR
The following alternatives are considered and evaluated in this section:
 No Project (No Build) Alternative;
 20 Percent Electric Fleet Alternative; and
 Reduced Footprint Alternative.

Each of the project alternatives is described in detail below, with a corresponding analysis of each alternative’s impacts in comparison to the proposed project. As discussed above, reasonable alternatives to the project must be capable of avoiding or substantially lessening a new significant impact or substantial increase in severity of a significant impact, as identified by this EIR.

Therefore, this chapter focuses on the resource areas and specific impacts listed above that have been identified in this EIR for the proposed project as requiring new or modified mitigation to reduce significant impacts to less than significant, or have been found to remain significant and unavoidable. While an effort has been made to include quantitative data for certain analytical topics, where possible, qualitative comparisons of the various alternatives to the project are primarily provided. Such an approach to the analysis is appropriate as evidenced by CEQA Guidelines Section 15126.6(d), which states that the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis

The analysis evaluates impacts that would occur with the alternatives relative to the significant impacts identified for the proposed project. When comparing the potential impacts resulting from implementation of the foregoing alternatives, the following terminology is used:
 “Fewer” = Less than Proposed Project;
 “Similar” = Similar to Proposed Project;
 “Greater” = Greater than Proposed Project; and
 "None” = No impact.

When the term “fewer” is used, the reader should not necessarily equate this to elimination of significant impacts identified for the proposed project. For example, in many cases, an alternative would reduce the relative intensity of a significant impact identified for the proposed project, but the impact would still be expected to remain significant under the alternative, thereby requiring mitigation. In other cases, the use of the term “fewer” may mean the actual elimination of an impact identified for the proposed project altogether. Similarly, use of the term “greater” does not necessarily imply that an alternative would require additional mitigation beyond what has been required for the proposed project. To the extent possible, this analysis will distinguish between the two implications of the comparative words “fewer” and “greater.” See Table 7-1 at the end of this chapter for a comparison of the environmental impacts resulting from the considered alternatives and the proposed project.

No Project (No Build) Alternative
CEQA requires the evaluation of the comparative impacts of the “No Project” alternative (CEQA Guidelines Section 15126.6[e]). Analysis of the no project alternative shall:
“[…] discuss […] existing conditions […] as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.” (Id., subd. [e][2]) “If the project is other than a land use or regulatory plan, for example a development project on identifiable property, the ‘no project’ alternative is the circumstance under which the project does not proceed. Here the discussion would compare the environmental effects of the property remaining in the property’s existing state versus environmental effects that would occur if the project were approved. If disapproval of the project under consideration would result in predictable actions by others, such as the proposal of some other project, this ‘no project’ consequence should be discussed. In certain instances, the no project alternative means ‘no build,’ wherein the existing environmental setting is maintained.

However, where failure to proceed with the project would not result in preservation of existing environmental conditions, the analysis should identify the practical result of the project's non-approval and not create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment.” (Id., subd. [e][3][B]).

The Lead Agencies have decided to evaluate a No Project (No Build) Alternative, which assumes that the current conditions of the project site would remain, and the site would not be developed.

As described in this EIR, the project site consists of undeveloped agricultural land currently located within the Natomas area of unincorporated Sacramento County (County). In addition, a portion of Bayou Way is located within the project site and is generally laid out in an east-to-west direction. The No Project (No Build) Alternative would not meet any of the project objectives.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 7 – Alternatives Analysis