significant and unavoidable. Thus, aesthetic impacts associated with the sound wall have not only been adequately addressed, but do not change the overall significance of the impact.
Response to Comment 19-16
As discussed on page 4.1-10 in Chapter 4.1, Aesthetics, of the Draft EIR, all Key Viewpoints, with the exception of Key Viewpoints #4A and #4B, are determined to have low to moderate quality; Key Viewpoints #4A and #4B have low visual quality. Thus, by stating that the overall visual quality of the project site is considered moderate/average quality, the baseline is not only accurate, but provides for a conservative approach by assuming the visual quality of the site is higher than the lowest quality Key Viewpoint. In addition, the conclusion is noted as significant and unavoidable in the Draft EIR.
Response to Comment 19-17
The comment accurately states that the Draft EIR determined that potential impacts to the visual quality of the project site were determined to be significant and unavoidable, and that feasible mitigation does not exist. The comment does not address the adequacy of the Draft EIR.
Response to Comment 19-18
The Draft EIR on page 3-4 specifically calls out the project site’s proximity to the Westlake residential subdivision and Paso Verde K-8 School. Furthermore, the existing environmental setting is included in the analysis of each of the technical chapters of the Draft EIR, including the surrounding residential and school developments when relevant.
Response to Comment 19-19
As discussed on page 7-5 in Chapter 7, Alternatives Analysis, of the Draft EIR, the Mixed-Use Residential Alternative would include the development of Parcels 5 and 8, which are located adjacent to the proposed industrial park, with residential uses. As discussed therein, placing the proposed industrial uses in such close proximity (approximately 300 feet) to the residential units would result in potential impacts due to the incompatible uses. By contrast, the proposed project would include the development of industrial and commercial uses, including future development anticipated within Parcels 5 and 8, that are located further from the nearest incompatible uses (approximately 600 feet) than would be the case under the Mixed-Use Residential Alternative.
Potential impacts related to the proximity of the project site to adjacent uses are addressed throughout the Draft EIR.
Response to Comment 19-20
The comment is incorrect. A discussion of health impacts related to criteria pollutant emissions associated with both the industrial park, the nonparticipating parcels, and off-site improvement area is discussed under Impact 4.3-3 of the Draft EIR.
As discussed therein, SMAQMD released the Guidance to Address the Friant Ranch Ruling for CEQA Projects in the Sac Metro Air District (Guidance) for the analysis of criteria emissions in areas within the District’s jurisdiction.8 The Guidance represents SMAQMD’s effort to develop a methodology that provides a consistent, reliable, and meaningful analysis in response to the 8 Sacramento Metropolitan Air Quality Management District. Guidance to Address the Friant Ranch Ruling for CEQA Projects in the Sac Metro Air District. October 2020.
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Supreme Court’s direction on correlating health impacts to a project’s emissions. The Guidance was prepared by conducting regional photochemical modeling, and relies on the USEPA’s Benefits Mapping and Analysis Program (BenMAP) to assess health impacts from ozone and PM2.5. SMAQMD has prepared two tools that are intended for use in analyzing health risks from criteria pollutants. Small projects with criteria pollutant emissions close to or below SMAQMD’s adopted thresholds of significance may use the Minor Project Health Effect Screening Tool, while larger projects with emissions between two and six times greater than SMAQMD’s adopted thresholds may use the Strategic Area Project Health Screening Tool.
Considering the proposed project would result in overall emissions which exceed the SMAQMD’s thresholds of significance, the Draft EIR determined that the project would qualify for the Strategic Area Project Health Screening Tool. The Strategic Area Project Health Screening Tool is based on location-specific modeling in five specific growth area locations. The proposed project is located closest to the Downtown Sacramento location in the Strategic Area Project Health Screening Tool. Results from the Strategic Area Project Health Screening Tool are included as Appendix C to the Draft EIR and Table 4.3-12 of the Draft EIR presents the health risks associated with operational criteria pollutant emissions resulting from implementation of the proposed project, including future development of the non-participating parcels.
Response to Comment 19-21
The Health Risk Assessment evaluated the project as proposed, which includes many of the project features identified in the comment. For example, the specific loading dock locations were included in the analysis. In fact, the first bullet of the comment is specifically incorporated into Mitigation Measure 4.3-3. As such, components of the warehouse best practices have been included in the project design and mitigation measures. The comment has been noted and referred to the decision-makers for consideration in their deliberations for approval or denial of the project. Please see the Master Response.
Response to Comment 19-22
The Draft EIR includes mitigation measures sufficient to reduce the identified impact from construction emissions to a less-than-significant level. Additional mitigation measures are not warranted; however, the commenter’s suggestion has been forwarded to the decision-makers for their consideration.
Response to Comment 19-23
The comment provides a list of recommended mitigation measures to add to the Draft EIR in order to further reduce the proposed projects air quality and GHG emissions. All recommendations provided in the list have been reviewed, and the following responses have been provided:
With regard to bullet points #1 and #4, the recommendations are State requirements that would inherently be included as part of the proposed project in compliance with California Code of Regulations Title 13, Division 3, Chapter 1, Article 4.5, Section 2025 and the Advanced Clean Cars II Program which requires that all new light- and medium-duty vehicles sold in the State be zero-emission vehicles (ZEVs) by 2035. The Advanced Clean Cars II Program mandates a gradual increase in ZEV sales starting from the 2026 model year. Such requirements were considered in the air quality and GHG modeling prepared for the proposed project.
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Regarding bullet point #2, Mitigation Measure 4.3-2 of the Draft EIR and the AQMP prepared for the proposed project, require that 4.5 percent of the heavy-duty vehicle fleet be zero emission by full buildout of the annexation area. As determined in coordination with the project applicant, given current technology available, requiring 4.5 percent of the fleet to be zero emission is the reasonably feasible maximum amount for the proposed project. In addition, California recently withdrew its request for a waiver and authorization for the addition of the Advanced Clean Fleets (ACF) Regulation to its emissions control program. Thus, the State is no longer requiring that manufacturers only manufacture ZEV trucks starting in the 2036 model year. Without this requirement, the availability of ZEV trucks is currently unknown. As discussed on page 4.3-48 of the Draft EIR, in the event there is a disruption in the manufacturing of zero emission vehicles/trucks or that sufficient vehicles/trucks are not commercially available for the intended application, the “clean fleet requirements” may be adjusted as minimally as possible by the City’s Community Development Department to accommodate the manufacturing disruption or unavailability of commercially available vehicles/trucks. Given the uncertainty surrounding the availability of ZEV trucks, requiring 100 percent of the fleet be ZEV is not considered to be feasible for the proposed project.
Bullet point #5 recommends limiting truck idling to two minutes and bullet point #6 recommends posting signage related to idling restrictions. In addition, bullet point #14 includes recommendations related to queuing and idling of trucks. The proposed project would be required to comply with the State’s Heavy-Duty Truck and Bus Regulation (Title 13, Division 3, Chapter 1, Section 2025) and Heavy-Duty Vehicle Idling Emission Reduction Program which require dieselfueled vehicles with gross vehicle weights greater than 10,000 pounds to idle no more than five minutes at any location, and include requirements related to posting signage notifying drivers of such restrictions. Even without adherence to the idling restrictions included in the State’s HeavyDuty Truck and Bus Regulation and Heavy-Duty Vehicle Idling Emission Reduction Program, the proposed project would not result in significant cancer risk or hazard index impacts associated with DPM emissions from idling vehicles (see Table 4.3-11 of the Draft EIR). In addition, as discussed in Chapter 4.12, Transportation, of the Draft EIR, impacts related to vehicle queuing associated with proposed project were determined to be less than significant. Thus, a nexus for the proposed project to require such recommendations included in bullet point #5 and #14 does not exist.
The recommendations included in bullet points #3, #11, #15, and #16 are already required through the mitigation measures included in the Draft EIR. For example, the AQMP prepared for the proposed project, implementation of which is ensured through Mitigation Measure 4.3-2 of the Draft EIR, requires that all tenants of the on-site industrial uses use zero-emission forklifts and requires that the proposed project implement a Transportation Management Association (TMA), such as Jibe North Natomas, which includes measures to increase use of alternative modes of transportation. In addition, Mitigation Measure 4.3-7(a) includes an option for the proposed project to reduce construction-related GHG emissions through encouraging and providing carpools, shuttle vans, transit passes and/or secure bicycle parking for construction worker commutes.
Finally, Mitigation Measure 4.3-7(c) of the Draft EIR requires that the proposed provide EV Ready parking spaces at the ratio with which the current CalGreen Tier 2 standards require EV Capable spaces, consistent with SMAQMD BMP-2.
Bullet points #8, #10, #12, #13, #17, #21, and #22 include recommendations related to installing an air monitoring station near the project site; providing electric plugs for electric transport refrigeration units at any refrigerated warehouses on-site; installing solar photovoltaic (PV) Final EIR
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systems; requiring all stand-by emergency generators to be powered by a non-diesel fuel; achieving certification of compliance with LEED green building standards; requiring tenants attend CARB approved courses; and requiring tenants to enroll in the USEPA’s SmartWay program. A nexus for requiring the proposed project to include the recommendations in bullet points #8, #10, #12, #13, #17, #21, and #22 does not exist, given that the measures would either not result in a reduction in any impacts associated with the proposed project (i.e., bullet points #8, #21, and #22), or are intended to reduce impacts related to GHG emissions (i.e., bullet points #10, #12, and #17) or TAC emissions (i.e., #13), both of which were determined to be less than significant with implementation of the mitigation measures prescribed in the Draft EIR. In addition, with regard to bullet point #8, as discussed on page 4.3-9 of the Draft EIR, air quality is currently monitored by CARB at various locations throughout the State. Table 4.3-4 presents the historical occurrences of pollutant levels exceeding the State and federal AAQS at the nearest air quality monitoring station to the project site, the Sacramento – T Street station, located at 1309 T Street in Sacramento, CA. Further, with regard to the solar recommendation included in bullet #12, the proposed project would be required to comply with the provisions of the 2022 CBSC, which require the new non-residential buildings be built solar ready. The proposed project would also be provided electricity by SMUD, which has vowed to reach zero carbon emissions in their power supply by 2030.
9 For further information regarding impacts associated with on-site emergency generators see Response to Comment 23-10. Finally, with respect to the recommendations included in bullet point #21, it should be noted that the project modeling was conducted consistent with the most current EMFAC data for average vehicle fleets. All future tenants would be anticipated to maintain their fleets as a good business practice. All future fleets operating on-site would also be required to comply with all federal, State, and local requirements. Overall, any obligation for the proposed project to include the recommendations of bullet points #8, #10, #12, #13, #17, #21, and #22 would be voluntary by the project applicant, and the project applicant has not indicated such voluntary measures would be implemented. Nonetheless, such recommendations will be forwarded to the decision-makers for their consideration.
Bullet points #7 and #20 include recommendations related to installing air filtration systems and improving landscaping vegetation and the tree canopy for sensitive receptors/residents within the project area. However, because installation of such filters in the existing residences or planting of additional landscaping vegetation/trees within private properties would require resident approval, neither the City of Sacramento, nor the project applicant, can legally impose such improvements on the private properties. Thus, implementation of such recommendations is infeasible. It should also be noted that the proposed project includes adequate mitigation to ensure that impacts related to health risks associated with the proposed project are reduced to a less-than-significant level (see Impact 4.3-3 of the Draft EIR), and implementation of additional mitigation measures to reduce such impacts would not be warranted.
With regard to bullet point #9 related to EV charging stations for trucks, the Sacramento County WattEV Innovative Freight Terminal (SWIFT) is currently being constructed adjacent to the project site’s western boundary. The SWIFT station is proposed to include 90 EV charging stations for medium and heavy-duty vehicles and 18 megawatt stations for pass-through charging on heavyduty vehicles. A reasonable assumption can be made that the ZEV trucks traveling to and from the project site would access the SWIFT station to charge. If additional EV charging stations are required on-site for ZEV trucks, such stations would be installed on an as-needed basis, as 9 Sacramento Municipal Utility District. 2030 Zero Carbon Plan. April 2021.
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tenants using electric trucks within their fleets (consistent with Mitigation Measure 4.3-2 of the Draft EIR and the AQMP prepared for the proposed project) begin occupying the proposed warehouse buildings.
Bullet point #18 recommends that the project provide meal options on-site or shuttles to and from nearby meal destinations. The proposed project would include approximately 98,200 sf of retail/highway commercial uses, including three 3,900 sf restaurant buildings and one 5,000 sf restaurant building. Thus, meal options are provided on-site as part of project design, and the recommendations included in bullet point #18 are inherently included as part of the proposed project.
The recommendations included in bullet point #19 consist of posting enforceable signs at every truck exit driveway to provide directional information to the truck route. The intent of the proposed project is for all heavy-duty trucks traveling to and from the site to access the site directly from I5 and to access I-5 directly from the site. Trucks would not be allowed access to Bayou Way or Power Line Road. In addition, the proposed project would be required to comply with all requirements included in Section 10.24.010, Truck Routes, of the City’s Municipal Code, which includes requirements related to signage. [Note to City: Please confirm if the proposed truck route will be an officially designated truck route by the City.] Based on the above, the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR are adequate, and implementation of the recommended mitigation measures is not warranted. Nonetheless, the comment has been noted for the record and will be forwarded to the decision-makers as part of their consideration of the proposed project.
Response to Comment 19-24
Contrary to the commenter’s claim, as stated on page 3-4 in Chapter 3, Project Description, of the Draft EIR, it is acknowledged that the project site borders the West Drainage Canal.
Regardless, any recreational uses southeast of the site are located outside the project site boundaries and, thus, would not be directly impacted by the proposed project. Although the West Drainage Canal is not specifically mentioned, potential impacts related to parks and recreational facilities are addressed in Impact 4.11-4 on page 4.11-36 of the Draft EIR. Furthermore, impacts to riparian vegetation, including riparian habitat in the southeastern portion of the site, are addressed under Impact 4.4-11 in Chapter 4.4, Biological Resources, of the Draft EIR.
Response to Comment 19-25
While the general baseline for the project as a whole is established in Chapter 3, Project Description, of the Draft EIR, the more specific and applicable baseline for each environmental topic is established in the Existing Setting section of the relevant technical chapter.
Response to Comment 19-26
As discussed on page 4.3-35 of the Draft EIR, SMAQMD has adopted thresholds of significance for GHG emissions during construction and operations of projects. For construction-related GHG emissions, the SMAQMD has adopted a threshold of significance of 1,100 MTCO2e/yr. For evaluating operational GHG emissions, SMAQMD has prepared a two-tiered framework of analysis for new projects. All development projects are required to implement Tier 1 measures (BMP 1 and 2). If operations of the proposed project would exceed 1,100 MTCO2e/yr after Final EIR
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implementation of the Tier 1 measures, then the project is required to implement Tier 2 measures (BMP 3).
In accordance with CARB and SMAQMD recommendations, the City of Sacramento uses the currently adopted SMAQMD GHG thresholds of significance, as well as compliance with the City’s CAAP to analyze GHG emissions. Therefore, if the proposed project would result in construction GHG emissions in excess of 1,100 MTCO2e/yr, and would not comply with the measures included in the CAAP, construction of the proposed project would be considered to result in a cumulatively considerable contribution to global climate change. In addition, if the proposed project would not achieve the SMAQMD’s Tier 1 GHG requirements (BMPs 1 and 2) and, if applicable, Tier 2 GHG requirements (BMP 3), and would not comply with the measures included in the CAAP, operations of the project would be considered to result in a cumulatively considerable contribution to global climate change. Consistent with the City of Sacramento approach to analyzing GHG emissions, the GHG analysis included in Impact 4.3-7 of the Draft EIR is based on such guidance provided by CARB and SMAQMD.
Response to Comment 19-27
The modeling results used for the GHG analysis in the Draft EIR are included as Appendix C to the Draft EIR. Furthermore, the methodology used in the modeling is clearly established in the Method of Analysis section of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR.
Response to Comment 19-28
A detailed analysis of potential impacts related to all significant impacts identified for the proposed project is presented for each of the alternatives addressed in Chapter 7, Alternatives Analysis, of the Draft EIR. As such, while more general terms are used to summarize the impacts of each alternative, the Draft EIR does present a detailed analysis to compare and assess the various alternatives.
Response to Comment 19-29
The Draft EIR adequately explains why some alternatives are dismissed from further analysis, pursuant to Guidelines Section 15126.6(c), beginning on page 7-4 in in Chapter 7, Alternatives Analysis, of the Draft EIR. Furthermore, the Draft EIR is not required to identify and analyze every conceivably feasible alternative to the proposed project, merely a reasonable range of alternatives; the analysis presented in Chapter 7, Alternatives Analysis, of the Draft EIR is adequately thorough pursuant to the CEQA Guidelines.
Response to Comment 19-30
A list of the commenters who submitted comments on the NOP for the Draft EIR, as well as a summary of the contents of those comments, is included beginning on page 1-7 in Chapter 1, Introduction, of the Draft EIR. As stated therein, the issues raised by the comments are addressed in the relevant sections of the Draft EIR. Furthermore, a copy of each comment letter is available for public review, included as Appendix B of the Draft EIR.
Response to Comment 19-31
The comment makes an unsubstantiated claim and does not provide sufficient detail for a response. Please see the Master Response.
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Response to Comment 19-32
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 and congestion 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 Chapter 4.12, Transportation, of the Draft EIR. Therefore, impacts related to congestion are not required to be addressed in the Draft EIR.
Response to Comment 19-33
Contrary to the claim of the commenter, as discussed under Impact 4.3-6 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, cumulative air quality impacts of the proposed project were determined to be cumulatively considerable and significant and unavoidable. In addition, vehicular emissions and industrial activities are included in the modeling conducted (see the Method of Analysis section).
Response to Comment 19-34
It is noted that the existing background noise measurements in the project vicinity are presented in Table 4.10-2 in Chapter 4.10, Noise, of the Draft EIR. The noise analysis presented throughout Chapter 4.10, Noise, is based primarily on the Environmental Noise Assessment prepared for the proposed project by Saxelby Acoustics, LLC., which was included as Appendix J to the Draft EIR.
The Environmental Noise Assessment was prepared in compliance with all applicable regulations and industry standards, and presents data supporting the conclusions presented in Chapter 4.10, Noise, of the Draft EIR.
Response to Comment 19-35
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
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Letter 20
20-1
20-2
20-3
20-4
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Letter 20 Cont.
20-4
Cont.
20-5
20-6
20-7
20-8
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Letter 20 Cont.
20-9
20-10
20-11
20-12
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LETTER 20: JERRY SPENCER, SACRAMENTO COUNTY FARM BUREAU Response to Comment 20-1
The comment provides background information regarding the goals of the Sacramento County Farm Bureau. The comment does not address the adequacy of the Draft EIR.
Response to Comment 20-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-4
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-5
The comment provides background information regarding the benefits of agricultural land. The comment does not address the adequacy of the Draft EIR.
Response to Comment 20-6
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-7
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
It is noted that impacts related to GHG emissions are addressed in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy; impacts related to biological habitat are addressed in Chapter 4.4, Biological Resources; impacts related to flooding are addressed in Chapter 4.8, Hydrology and Water Quality; and impacts related to wildfire are addressed in Chapter 5, Effects Not Found to be Significant, of the Draft EIR.
Response to Comment 20-8
The comment does not address the adequacy of the Draft EIR. Alternatives to the proposed project, including off-site alternatives, are addressed in Chapter 7, Alternatives Analysis, of the Draft EIR. As discussed, off-site alternatives that could accomplish the project objectives or accommodate a similar type and intensity of development as the proposed project are not considered feasible for the reasons detailed therein. Please see the Master Response.
Response to Comment 20-9
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-10
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 20-11
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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Response to Comment 20-12
The comment is a conclusion statement and does not address the adequacy of the Draft EIR.
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Letter 21
21-1
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LETTER 21: BARBARA LEARY, SIERRA CLUB SACRAMENTO
Response to Comment 21-1
Please see Responses to Comments 13-1 through 13-96.
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Letter 22
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22-2
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Letter 22 Cont.
22-4
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22-5
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Letter 22 Cont.
22-6
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22-7
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22-8
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22-9
Letter 22 Cont.
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22-9
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22-10
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22-10
Cont.
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Letter 22 Cont.