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December 2, 2025

due to development of the industrial park are discussed separately in further detail below. Because 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, views of the off-site force main alignment would not be substantially degraded by the proposed project.

Key Viewpoint #1
As shown in Figure 4.1-2, Key Viewpoint #1 represents the view of the project site looking southeast from the southbound lane of I-5. Motorists experience views of low to moderate visual quality with the foreground dominated by human-made elements, such as gravel, pavement, fencing, and utility poles with overhead lines. Midground views are dominated by a paved roadway and an open vista of disced vegetation, and background views consist of distant trees and vegetation, structures outlines, and open sky.

Figure 4.1-6 shows Key Viewpoint #1 one year and 20 years following industrial park buildout, respectively. As shown therein, views of the industrial park looking southeast from the southbound lane of I-5 would change from the existing agricultural vegetation to industrial buildings. While foreground views would remain the same as the existing conditions, midground views would be fundamentally altered by the presence of the proposed industrial park, and existing background views would be eliminated entirely.

It is noted that trees are proposed to be planted along the northern border of the project site. Although the proposed landscaping would partially obscure views of the industrial park from Key Viewpoint #1, the trees would not screen views until after 20 years of growth.

As such, upon initial buildout of the proposed project, development would not be screened from public views. However, the viewer type at Key Viewpoint #1 would be motorists traveling on I-5, which has a speed limit of 65 miles per hour (mph).

Therefore, such views of the project site would be temporary.

Based on the above, the existing visual character and quality of public views of the project site from the southbound lane of I-5 would be considered to be substantially degraded by the industrial park component of the proposed project.

Key Viewpoint #2
As shown in Figure 4.1-3, Key Viewpoint #2 represents the view of the project site from Metro Air Parkway, looking southeast. Metro Air Parkway is an elevated road that crosses above I-5 and leads into the project site. This view is overall similar to Key Viewpoint #1, with foreground views consisting of pavement, road shoulder, guardrail barriers, and grassy vegetation.

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Figure 4.1-6
1-Year and 20-Year Views of Project Site from I-5 Looking Southeast (Key Viewpoint #1) 1-Year
20-Year
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Midground views are dominated by a paved roadway and an open vista of disced vegetation, and background views consist of distant trees and vegetation, structures outlines, and open sky. The overall visual quality of this view is low to moderate quality.

Figure 4.1-7 shows Key Viewpoint #2 one year and 20 years following industrial park buildout, respectively. The proposed hotel and other HC-PUD structures occur in the midground, followed by industrial warehouse buildings, which are located immediately south and west of the HC-PUD structures. Similar to Key Viewpoint #1, although the planned landscaping would help obscure the industrial park from public views, the trees planted would take 20 years of growth to fully cover the buildings. In addition, as shown in Figure 4.1-7, even following 20 years of growth, the trees would not obscure views as efficiently as they would from Key Viewpoint #1.

As a result, the existing visual character and quality of public views of the project site looking southeast from Metro Air Parkway would be considered to be substantially degraded by the industrial park component of the proposed project.

Key Viewpoint #3
As shown in Figure 4.1-4, Key Viewpoint #3 represents two views of the project site looking southwest from the southbound lane of I-5. The foreground of these viewpoints are dominated by pavement, gravel, guardrail barriers, and grassy vegetation. Similar to Key Viewpoint #2, midground views consist of wire fencing, a paved roadway, and an open vista of disced vegetation. Background views consist of distant trees and vegetation, a couple structure outlines, distant hills, and open sky. The overall visual quality of these views is low to moderate quality.

Figure 4.1-8 shows Key Viewpoint #3 one year and 20 years following project buildout, respectively. As discussed above, following buildout of the proposed project, midground and background views of the project site would be fundamentally changed from agricultural land and open space to industrial buildings. The proposed HC-PUD structures would be largely screened by the industrial buildings. Although the proposed landscaping would help partially obscure views of the site, the trees would take 20 years to reach full growth; even then, the buildings would only be partially obscured. Similar to Key Viewpoint #1, discussed above, the viewer type at Key Viewpoint #3 would be motorists traveling on I-5, which has a speed limit of 65 mph.

Therefore, such views of the project site would be temporary.

Based on the above, the existing visual character and quality of public views of the project site looking southwest from the southbound lane of I-5 would be considered to be substantially degraded by the proposed project.

Key Viewpoint #4A
As shown in Figure 4.1-5, Key Viewpoint #4A represents the view of the project site looking northwest from Access Roadway. The foreground of this viewpoint consists of flooded grassy field. Midground views are dominated by a grassy berm as well as a utilities shed and three power line poles. Background views consist of distant trees, the outlines of hills, and open sky. The overall visual quality of this view is low quality.

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Figure 4.1-7
1-Year and 20-Year Views of Project Site from Metro Air Parkway Looking Southeast (Key Viewpoint #2)
1-Year
20-Year
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Figure 4.1-8
1-Year and 20-Year Views of Project Site from I-5 Looking Southwest (Key Viewpoint #3)
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20-Year
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Although the existing visual quality of Key Viewpoint #4A is low quality, the industrial park component of the proposed project would not significantly alter the existing view, as shown in Figure 4.1-5. Figure 4.1-9 shows Key Viewpoint #4A one year and 20 years following industrial park buildout, respectively. As shown therein, buildout of the industrial park would result in minor changes to background views by adding in new trees and buildings. The majority of the proposed buildings would already be obscured by the existing grassy berm in the midground, and the landscaping would further hide the buildings. Furthermore, as discussed in Chapter 4.10, Noise, of this EIR, Mitigation Measure 4.10-2 would require construction of an eight-foot-tall sound wall along a portion of the eastern project boundary. The installation of a sound wall along the eastern boundaries of the project site would further shield public views of the project site from Key Viewpoint #4A and would be visually consistent with the type of boundary shielding associated with industrial uses.

Based on the above, the low quality of this view would not be substantially degraded by the industrial park component of the proposed project.

Nonparticipating Parcels
The nonparticipating parcels portion of the project site consists of approximately 83 acres, and future buildout of such would include approximately 1,404,800 sf of industrial uses. Although specific designs have not yet been prepared for the nonparticipating parcels, due to the position of future development in the southeastern corner of the project site, views of the project site following buildout of the nonparticipating parcels are unlikely to change from what is shown in Figure 4.1-6 through Figure 4.1-8, above. Development within the nonparticipating parcels would either not be visible from the key viewpoints, or would be obscured by the development of the industrial park. In addition, the proposed PUD Guidelines include landscape/screening criteria, such as landscaping species requirements and minimum landscape buffer width standards, which would serve to screen public views towards the project site, thus, limiting the visual intrusion of the proposed structures.

However, Key Viewpoint #4A would be significantly altered beyond what is portrayed in Figure 4.1-9. While the industrial park component of the proposed project would be situated in the background of Key Viewpoint #4A, development of the nonparticipating parcels would convert midground views from the existing grassy berm into industrial buildings. As such, the existing visual character and quality of public views of the project site looking northwest from Access Roadway would be considered to be substantially degraded by the nonparticipating parcels component of the proposed project.

Conclusion
Based on the above, 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. Thus, a significant impact could occur.

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Figure 4.1-9
1-Year and 20-Year Views of Project Site from Access Roadway Looking Northwest (Key Viewpoint #4A)
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20-Year
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Mitigation Measure(s)
Although the proposed project would be required to comply with PUD Guidelines which would help to reduce the severity of the aesthetic impact of the proposed project, feasible mitigation does not exist to reduce the above impact to a less-than-significant level. Due to the substantial degradation of the existing visual character and quality of public views of the project site, the impact associated with construction of both components of the proposed project would remain significant and unavoidable.

4.1-4 Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. The impact would be less than significant.

Existing sources of light in the project area include vehicles traveling on I-5 as well as the residences and Life Storage facility east of the project site. As such, although the project site is currently undeveloped, and, thus, does not generate light and glare, sources of light currently exist in the project vicinity. Because the footprints of the proposed industrial park and nonparticipating parcels are contiguous, the potential for impacts related to new sources of substantial light or glare that could occur from developing either project component would be similar. Thus, the following discussion includes both a project-level and program-level analysis of potential impacts that could occur as a result of developing the proposed industrial park and nonparticipating parcels. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Development of both components of the proposed project would introduce additional sources of light and glare to the project area that would be similar to those emanating from the project vicinity. Sources of light from the proposed project would include headlights from vehicles traveling to and from the site, as well as street lighting. In addition, industrial and commercial uses would introduce new sources of lighting, such as architectural accent lighting, motion-activated security lighting, parking lot lighting, landscape lighting, and interior lighting visible through windows.

The proposed project would be subject to applicable 2040 General Plan policies, which would reduce impacts related to lighting and glare. For example, Policy LUP-4.6 Compatibility with Adjoining Uses would ensure that development of the industrial and commercial uses at the project site would be compatible with (and sensitive to) adjacent residential land uses by requiring all lighting to be shielded from view and directed downward to minimize impacts on adjacent residential uses.

Additionally, the proposed PUD Guidelines include sign standards for signs within the Industrial PUD (M-1-PUD) and HC-PUD zones. For instance, new identification signs installed as part of the proposed project would be a maximum height of 70 feet and would be limited to two signs along I-5. Ground-mounted signs and attached signs would be subject to the requirements set forth in Sacramento City Code Chapter

15.148. The PUD Guidelines also establish that light levels from the proposed structures and signs must be zero foot-candles at the property lines of the project site, Draft EIR
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with LED fixtures facing downward. Furthermore, Section 17.608.040 of the Sacramento City Code would require that exterior lighting for project parking areas be shielded or otherwise designed to avoid spillover lighting on adjacent roadways and land areas. Compliance with such requirements would ensure that new sources of glare associated with the proposed project would not adversely impact airplanes that pass overhead.

With regard to glare associated with the solar panels proposed to be placed on rooftops of the industrial and commercial buildings, when sunlight strikes the glass front of a solar panel at a glancing angle, a portion of the solar radiation is reflected, which can potentially lead to solar glint or glare impacting a person’s vision, including pilots landing aircraft. However, solar panels are designed to absorb, and thus not reflect, close to 100 percent of the solar energy that strikes them, as any reflected light cannot be converted into electricity. In addition, solar panels are typically constructed of dark-colored (usually blue or black) materials and are covered with anti-reflective coatings. Therefore, due to the low reflectivity of the proposed solar panels, as well as the height that the solar panels would be constructed, the panels would not be expected to cause visual impairment for motorists on area roadways because local motorists would pass under the panels’ angle of reflection.

Regarding potential glare effects on the Sacramento International Airport, located one mile northwest of the project site, as discussed above, solar panels are designed to absorb, and thus not reflect, close to 100 percent of the solar energy that strikes them, and are typically covered with anti-reflective coatings. The reflection off a solar photovoltaic (PV) panel from most near normal angles is less than three percent, and has a reflectivity similar to water. In addition, the proposed solar panels would be angled east-west to track the sun, whereas planes taking off and landing at the Sacramento International Airport runways ascend and descend from the north and south. As a result, reflectivity from PV solar panels does not represent a risk to air traffic.9 Therefore, the proposed project would not be expected to cause visual impairment for aircraft pilots ascending or descending from the Sacramento International Airport.

Finally, the proposed off-site force main, including each of the three potential force main segment options, would be installed underground in existing roadway ROW or in other previously disturbed areas. As such, construction of the proposed off-site improvements would not create new sources of light and glare.

Based on the above, the project could introduce additional sources of light and glare from the proposed industrial and commercial uses. Compliance with aforementioned policies and requirements would reduce impacts related to light illumination on the project site. Thus, anticipated lighting from the proposed project would not adversely affect day or nighttime views in the area, and would result in a less-than-significant impact.

Mitigation Measure(s)
None required.
9 Anurag et al. General Design Procedures for Airport-Based Solar Photovoltaic Systems [pg. 10] August 12, 2017.

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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.

Some types of impacts to aesthetic resources are localized and not cumulative in nature. For example, the creation of glare or shadows at one location is not worsened by glare or shadows created at another location. Rather these effects are independent, and the determination as to whether they are adverse is specific to the project and location where they are created. Projects that block a view or affect the visual quality of a site also have localized aesthetic impacts. The impact occurs specific to a site or area and remains independent from another project elsewhere that may block a view or degrade the visual environment of a specific site.

Two types of aesthetic impacts may be additive in nature and thus cumulative, including night sky lighting and overall changes in the visual environment as the result of increasing urbanization of large areas. As development in one area increases and possibly expands over time and meets or connects with development in an adjoining exurban area, the effect of night sky lighting experienced outside of the region may increase in the form of larger and/or more intense nighttime glow in the viewshed.

Similarly, as development in one area changes from rural to urban, and this pattern continues to occur throughout the undeveloped areas of a jurisdiction, the changes in visual character may become additive and cumulatively considerable. The proposed project’s incremental contribution to night sky lighting and changes in visual character are addressed below.

The following discussion of impacts is based on the implementation of the proposed project, including the nonparticipating parcels, in combination with other proposed and pending projects in the region. Other proposed and pending projects in the region under the cumulative context would generally include buildout of the City of Sacramento 2040 General Plan policy area, as well as the sites of the Northlake (Greenbriar) subdivision, the Metro Air Park Project, and the Elkhorn Boulevard Extension Project. For more details regarding the cumulative setting, refer to Chapter 6, Statutorily Required Sections, of this EIR.

4.1-5 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.

Based on the analysis below, the project’s incremental
contribution to the significant cumulative impact is significant and unavoidable.

As discussed previously, the visual resources of the immediate project vicinity are mostly characterized by agricultural lands to the south, west, and north, across I-5.

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site, and the Life Storage facility, Egret Park, and the Westlake single-family residential subdivision are located immediately east of the project site. The Sacramento International Airport, Metro Air Park, and the Amazon SMF-1 Fulfillment Center are located to the north, across I-5 and past intervening agricultural land.

In addition to the existing development in the project vicinity, the Northlake (Greenbriar) subdivision is currently under construction northeast of the project site.

Furthermore, the parcels located immediately north of the project site are planned for industrial development associated with the Metro Air Park, and the parcels northwest and west of the project site are planned for development associated with the Sacramento International Airport.

As discussed under Impact 4.1-3, development of the proposed industrial park and future development of the nonparticipating parcels would substantially degrade the visual character and the quality of public views of the project site. In context with the planned development along the I-5 corridor in the project vicinity, the proposed project would contribute towards significantly altering the visual character of the surroundings.

Therefore, the proposed project’s incremental contribution to such impacts would be significant.

Mitigation Measure(s)
Feasible mitigation does not exist to reduce the above impact to a less-than-significant level. Due to the substantial degradation of the existing visual character and quality of public views of the project site, the impact associated with construction of both components of the proposed project in combination with cumulative development would remain significant and unavoidable.

4.1-6 Creation of new sources of light or glare associated with cumulative development of the proposed project in
combination with future buildout of the City of Sacramento 2040 General Plan. Based on the analysis below, the project’s incremental contribution to the significant cumulative impact is less than cumulatively considerable.

Cumulative effects of lighting are visible over a wide area, due to the potential for lighting from a number of projects to create sky glow. Cumulative development throughout the City of Sacramento 2040 General Plan and Sacramento County General Plan planning areas, particularly conversion of rural or currently vacant sites to urban uses, would increase the sources of light and glare, which would have the potential to contribute to sky glow in the area and result in a significant cumulative impact. Such sources of light would be typical of existing industrial development in the greater project vicinity, such as the Sacramento International Airport and Amazon SMF-1 Fulfillment Center to the north of the project site.

Following approval of the SOI Amendment and Annexation of the project site into the City of Sacramento’s City limits, development on-site would be subject to applicable City regulations. Cumulative development within the City of Sacramento 2040 General Draft EIR
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Plan planning area, including the proposed project, would be subject to existing regulations and guidelines related to light and glare. For example, Policy LUP-4.6 Compatibility with Adjoining Uses would require all lighting at the project site to be shielded from view and directed downward to minimize impacts on adjacent residential uses. In addition, Section 17.608.040 of the City Code would require that exterior lighting for project parking areas be shielded or otherwise designed to avoid spillover lighting on adjacent roadways and land areas.

The MEIR determined that because the City of Sacramento is mostly built-out with a level of ambient light that is typical of and consistent with the urban character of a large city and new development allowed under the 2040 General Plan would be subject to the 2040 General Plan policies, building codes, and (for larger projects) design review, the introduction of substantially greater intensity or dispersal of light would not occur.

In addition, although the project site is not currently within the City of Sacramento’s SOI, the proposed development, as well as other development within the project’s cumulative setting, are located at the westernmost boundary of the City. As such, the light and glare generated by future and existing industrial development in the project vicinity would be consistent with what currently exists as travelers enter the City from the west.

Based upon the above analysis, cumulative development within the City of Sacramento would be subject to all applicable requirements of City of Sacramento 2040 General Plan Policy LUP-4.6 and Section 17.608.040 of the City Code.

Furthermore, cumulative development within Sacramento County in the project vicinity, such as expansion of the Sacramento International Airport, would be subject to compliance with applicable policies of the County’s General Plan, such as Policy LU-33, which is intended to reduce light pollution. Compliance with such would ensure that buildout of the proposed project, in combination with cumulative development of the City’s 2040 General Plan and the County’s General Plan, would not result in a significant cumulative impact related to light and glare and the impact would be less than cumulatively considerable.

Mitigation Measure(s)
None required.

4.2 AGRICULTURAL RESOURCES

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4.2.1 INTRODUCTION
This Agricultural Resources chapter of the EIR summarizes the existing agricultural resources within the boundaries of the Airport South Industrial Project site using the current State Department of Conservation model and data, including identification of any Prime/Unique Farmland or Farmland of Statewide Importance within the project boundaries. 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 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.

The following analysis addresses the conversion of lands to urban uses, as well as any conflicts with existing zoning for agricultural use or right-to-farm ordinances. Furthermore, this chapter outlines the policies and standards set by the Sacramento Local Agency Formation Commission (LAFCo) regarding agricultural resources, and analyzes the proposed project’s consistency with those policies. Documents referenced to prepare this chapter include the City of Sacramento 2040 General Plan,1 the City of Sacramento 2040 Master EIR (MEIR),2 the Sacramento LAFCo Policy, Standards and Procedures Manual,3 the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey,4 Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Sacramento County,5 the California Department of Conservation (DOC) Important Farmland Finder,6 the Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Sacramento County,7 and the CorteseKnox-Hertzberg Local Government Reorganization Act of 2000.8

1 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 2 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023. 3 Sacramento Local Agency Formation Commission. Policy, Standards and Procedures Manual. September 2007. 4 United States Department of Agriculture. National Resources Conservation Service. Web Soil Survey. Accessed January 2022. 5 California Department of Conservation, Farmland Mapping and Monitoring Program: Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Sacramento County, 2010. 6 California Department of Conservation. Farmland Mapping & Monitoring Program. Available at:
https://www.conservation.ca.gov/dlrp/fmmp. Accessed January 2022. 7 California Department of Conservation, Farmland Mapping and Monitoring Program. Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Sacramento County. Updated November 2020. 8 California Legislative Information. Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 [56000- 57550]. Available at:
leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=56064. Accessed January 2022.

4.2 AGRICULTURAL RESOURCES
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4.2.2 EXISTING ENVIRONMENTAL SETTING
The Existing Environmental Setting section describes current farmland and soil productivity classification systems, as well as the extent and quality of the agricultural resources present on the project site.

Farmland Classifications
The NRCS uses two systems to determine a soil’s agricultural productivity: 1) the Soil Capability Classification; and 2) the Storie Index Rating System. The “prime” soil classification of both systems indicates the presence of few to no soil limitations, which if present, would require the application of management techniques (e.g., drainage, leveling, special fertilizing practices) to enhance production. The Farmland Mapping and Monitoring Program (FMMP), part of the Division of Land Resource Protection, California DOC, uses the information from the NRCS to create maps illustrating the types of farmland in the area.

Another farmland classification system employed in the analysis of this chapter is based upon the Sacramento LAFCo definition of “agricultural land” and “prime agricultural land,” as defined below.

Soil Capability Classification
The Soil Capability Classification System takes into consideration soil limitations, the risk of damage when soils are used, and the way in which soils respond to treatment. Capability classes range from Class I soils, which have few limitations for agriculture, to Class VIII soils, which are unsuitable for agriculture. Generally, as the rating of the capability classification system increases, the yields and profits are difficult to obtain. A general description of soil classification, as defined by the NRCS, is provided in Table 4.2-1.

Table 4.2-1
Soil Capability Classification
Class Definition
I Soils have few limitations that restrict their use.

II Soils have moderate limitations that reduce the choice of plants, or that require special conservation practices.

III Soils have severe limitations that reduce the choice of plants, require conservation practices, or both.

IV Soils have very severe limitations that reduce the choice of plants, require very careful management, or both.

V Soils are not likely to erode but have other limitations; impractical to remove and limit their use largely to pasture or range, woodland, or wildlife habitat.

VI Soils have severe limitations that make them generally unsuited to cultivation and limit their use largely to pasture or range, woodland, or wildlife habitat.

VII Soils have very severe limitations that make them unsuited to cultivation and that restrict their use largely to pasture or range, woodland, or wildlife habitat.

VIII Soils and landforms have limitations that preclude their use for commercial plants and restrict their use to recreation, wildlife habitat, or water supply or to aesthetic purposes.

Source: USDA Soil Conservation Service, Soil Survey of Sacramento County, 1993.

Storie Index Rating System
The Storie Index Rating system ranks soil characteristics according to their suitability for agriculture from Grade 1 soils (80 to 100 rating), which do not have limitations or have few Draft EIR
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limitations for agricultural production, to Grade 6 soils (less than 10), which are not suitable for agriculture. Under this system, soils deemed less than prime could function as prime soils when limitations such as poor drainage, slopes, or soil nutrient deficiencies are partially or entirely removed. The six grades, ranges in index rating, and definition of the grades, as defined by the NRCS, are provided in Table 4.2-2, Storie Index Rating System.

Table 4.2-2
Storie Index Rating System
Grade
Index
Rating Definition
1 – Excellent 80 through 100 Soils are well suited to intensive use for growing irrigated crops that are climatically suited to the region.
2 – Good 60 through 79 Soils are good agricultural soils, although they may not be so desirable as Grade 1 because of moderately coarse, coarse, or gravelly surface soil texture; somewhat less permeable subsoil; lower plant available water holding capacity, fair fertility; less well drained conditions, or slight to moderate flood hazards, all acting separately or in combination.
3 – Fair 40 through 59 Soils are only fairly well suited to general agriculture use and are limited in their use because of moderate slopes; moderate soils depths; less permeable subsoil; fine, moderately fine or gravelly surface soil textures; poor drainage; moderate flood hazards; or fair to poor fertility levels, all acting alone or in combination. 4 – Poor 20 through 39 Soils are poorly suited. They are severely limited in their agricultural potential because of shallow soil depths; less permeable subsoil; steeper slope; or more clayey or gravelly surface soil texture than Grade 3 soils, as well as poor drainage; greater flood hazards; hummocky micro-relief; salinity; or poor fertility levels, all acting alone or in combination.
5 – Very Poor 10 through 19 Soils are very poorly suited for agriculture, are seldom cultivated and are more commonly used for range, pasture, or woodland. 6 – Nonagriculture
Less and 10 Soils are not suited for agriculture at all due to very severe to extreme physical limitations, or because of urbanization.

Source: USDA Soil Conservation Service, Soil Survey of San Joaquin County, 1992.

Farmland Mapping and Monitoring Program
The California DOC has a Division called the Land Resource Protection Division. The DOC established the FMMP in 1982 to continue the Important Farmland mapping efforts begun in 1975 by the USDA Soil Conservation Service (USDA-SCS). The intent of the USDA-SCS was to produce agriculture maps based on soil quality and land use across the nation. As part of the nationwide agricultural land use mapping effort, the USDA-SCS developed a series of definitions known as Land Inventory and Monitoring (LIM) criteria. The LIM criteria classified the land’s suitability for agricultural production; suitability included both the physical and chemical characteristics of soils and the actual land use. Important Farmland Maps are derived from the USDA-SCS soil survey maps using the LIM criteria.

Since 1980, the State of California has assisted the USDA-SCS with completing mapping in the State. The FMMP was created within the California DOC to carry on the mapping activity on a continuing basis, and with a greater level of detail. The DOC applied a greater level of detail by modifying the LIM criteria for use in California. The LIM criteria in California utilizes the SCS and Draft EIR
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Storie Index Rating systems, but also considers physical conditions such as dependable water supply for agricultural production, soil temperature range, depth of the groundwater table, flooding potential, rock fragment content and rooting depth.

Important Farmland Maps for California are compiled using the modified LIM criteria (as described above) and current land use information. Important Farmland Maps for California are updated every two years; it is noted that the City of Sacramento has submitted a request with the California DOC and Sacramento County to update the Important Farmland Maps before the scheduled time in order to correct inaccuracies in the current Maps.9 The minimum mapping unit is 10 acres unless otherwise specified. Units of land smaller than 10 acres are incorporated into surrounding classifications. The Important Farmland Maps identify seven agriculture-related categories: prime farmland, farmland of statewide importance (statewide farmland), unique farmland, farmland of local importance (local farmland), grazing land, urban and built-up land (urban land), and other land. Each is summarized below, based on a Guide to Farmland Mapping and Monitoring Program (2004), prepared by the California DOC.

Prime Farmland: Prime farmland is land with the best combination of physical and chemical features able to sustain the long-term production of agricultural crops. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. The land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.

Statewide Farmland: Farmland of Statewide Importance is land similar to prime farmland, but with minor shortcomings, such as greater slopes or with less ability to hold and store moisture. The land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.

Unique Farmland: Unique farmland is land of lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated, but may include non-irrigated orchards or vineyards, as found in some climatic zones in California. The land must have been cropped at some time during the four years prior to the mapping date.

Local Farmland: Farmland of Local Importance is land of importance to the local agricultural economy, as determined by each county’s Board of Supervisors and a local advisory committee. Sacramento County local farmland includes lands which do not qualify as Prime, Statewide, or Unique designation, but are currently irrigated crops or pasture or non-irrigated crops; lands that would meet the Prime or Statewide designation and have been improved for irrigation, but are now idle; and lands that currently support confined livestock, poultry operations and aquaculture.

Grazing Land: Grazing land is land on which the existing vegetation, whether grown naturally or through management, is suited to the grazing 9 City of Sacramento Community Development Department. Sacramento County Farmland Designation Discrepancies – Request for Amendment. October 31, 2023.

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of livestock. The minimum mapping unit for this category is 40 acres.

Urban Land: Urban and built-up land is occupied with structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. Uses may include residential, industrial, commercial, institutional, public administrative purposes, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes.

Other Land: Other land is land that is not included in any other mapping categories. Common examples include low density rural
developments; brush, timber, wetland, and riparian areas not suitable for livestock grazing; confined livestock, poultry or aquaculture facilities; strip mines, borrow pits; and water bodies smaller than 40 acres. Vacant and nonagricultural land
surrounded on all sides by urban development and greater than 40 acres is mapped as Other Land.

Sacramento LAFCo
Sacramento LAFCo is a State-mandated boundary agency responsible for coordinating logical and timely changes in local government boundaries. As set forth in Section 56001 of the California Government Code, LAFCos are established by the State to ensure the logical formation and determination of local agency boundaries to promote orderly development and balancing that development with sometimes competing state interests of discouraging urban sprawl, preserving open-space and prime agricultural lands, and efficiently extending government services.

The definition of agricultural lands used by all LAFCos is established by Section 56064 of the Government Code. Section 56064 defines “agricultural lands” for LAFCO purposes as land currently used for the purpose of producing an agricultural commodity for commercial purposes, land left fallow under a crop rotational program, or land enrolled in an agricultural subsidy or setaside program. Under the Government Code definition, “prime agricultural land" means an area of land, whether a single parcel or contiguous parcels, that has not been developed for a use other than an agricultural use and that meets any of the following qualifications:
(a) Land that qualifies, if irrigated, for rating as Class I or Class II in the USDA Natural Resources Conservation Service land use capability classification, whether or not land is actually irrigated, provided that irrigation is feasible; (b) Land that qualifies for rating 80 through 100 Storie Index Rating; (c) Land that supports livestock used for the production of food and fiber and that has an annual carrying capacity equivalent to at least one animal unit per acre as defined by the USDA in the National Range and Pasture Handbook, Revision 1, December 2003; (d) Land planted with fruit or nut-bearing trees, vines, bushes, or crops that have a nonbearing period of less than five years and that will return during the commercial bearing period on an annual basis from the production of unprocessed agricultural plant production not less than four hundred dollars ($400) per acre; (e) Land that has returned from the production of unprocessed agricultural plant products an annual gross value of not less than four hundred dollars ($400) per acre for three of the previous five calendar years.

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Existing Farmland
According to the City of Sacramento 2040 General Plan MEIR, the Sacramento policy area, which does not include the project site, contains 41 acres of Prime Farmland, nine acres of Farmland of Statewide Importance, and 3,802 acres of Farmland of Local Importance, as of 2020. The City of Sacramento policy area does not contain Unique Farmland. According to the County’s General Plan EIR, Sacramento County, which includes the project site, contains approximately 110,278 acres of Prime Farmland, 56,140 acres of Farmland of Statewide Importance, 15,187 acres of Unique Farmland, and 39,873 acres of Farmland of Local Importance.

Project Site Characteristics
The following sections provide an overview of the local existing soils and agricultural activity, as well as Williamson Act contracts and important farmland designations associated with the project site.

Soil Classifications
According to the USDA NRCS Web Soil Survey, the project site consists of the following soils, as shown in Figure 4.2-1:
 Capay clay loam, zero to two percent slopes, occasionally flooded (map symbol 113);  Clear Lake clay, hardpan substratum, drained, zero to one percent slopes (115);  Cosumnes silt loam, partially drained, zero to two percent slopes (127);  Jacktone clay, drained, zero to two percent slopes (161);  San Joaquin silt loam, leveled, zero to one percent slopes (213); and  San Joaquin silt loam, zero to three percent slopes (214).

The soils are described below and shown in Table 4.2-3. As shown in Table 4.2-3, four of the onsite soils are Grade 4, indicating that the soils are severely limited in their agricultural potential because of shallow soil depths; less permeable soil; steeper slope; or more clayey or gravelly surface soil texture than Grade 3 soils, as well as poor drainage; greater flood hazards; hummocky micro-relief; salinity; or poor fertility levels all acting alone or in combination.

Table 4.2-3
On-Site Soil Capability Classification and Storie Index Rating Soil Map Symbol and Name Soil Capability Classification Storie Index
Grade
Capay clay loam (113) IIIw, non-irrigated, IIw, irrigated 2 Clear Lake clay (115) IIIs, non-irrigated, IIs, irrigated 5 Cosumnes silt loam (127) IIIw, non-irrigated, IIw, irrigated 4 Jacktone clay (161) IIIs, non-irrigated, IIIs, irrigated 6 San Joaquin silt loam, leveled (213) IIIs, non-irrigated, IIIs, irrigated 4 San Joaquin silt loam (214) IIIs, non-irrigated, IIIs, irrigated 4 Note: Capability subclasses are soil groups within one class. They are designated by adding a small letter, e, w, s, or c, to the class numeral, for example, IIe. The letter e shows that the main hazard is the risk of erosion unless close-growing plant cover is maintained; w shows that water in or on the soil interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage); s shows that the soil is limited mainly because it is shallow, droughty, or stony; and c, used in only some parts of the United States, shows that the chief limitation is climate that is very cold or very dry.

Source: USDA NRCS, Web Soil Survey, 2023.

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Figure 4.2-1
Project Site Soil Map
Project Site
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Soil Descriptions
Capay clay loam, zero to two percent slopes, occasionally flooded (113) is located on the rims of basins. Permeability of the loam is slow. Surface runoff is slow or very slow, and the erosion hazard is slight. The available water capacity is very high. The effective rooting depth is 60 inches or more. The soil is used mainly for irrigated pasture and hay or for dryland crops, such as wheat.

Some areas are used for irrigated crops, including corn, wheat, rice, tomatoes. The land capability unit is IIIw non-irrigated and IIw irrigated, with a Storie Index Grade of 2.

Clear Lake clay, hardpan substratum, drained, zero to one percent slopes (115) is located in basins. Permeability of the clay is slow. Surface runoff is very slow, and the erosion hazard is none to slight. The available water capacity is moderate. The effective rooting depth is 40 to 80 inches. The soil is used mainly for irrigated crops, such as rice, corn, tomatoes, sugar beets, and wheat. The land capability unit is IIIs non-irrigated and IIs irrigated, with a Storie Index Grade of

5. Cosumnes silt loam, partially drained, zero to two percent slopes (127) is located on low flood plains. Permeability of the loam is slow. Surface runoff is slow, and the erosion hazard is slight.

The available water capacity is high. The effective rooting depth is limited by a seasonal high water table in winter and early spring due to seepage. The water table is generally maintained below a depth of 36 inches by pumping, but can be at a depth of 20 to 36 inches for short periods.

The soil is suited for rice crops. The land capability unit is IIIw non-irrigated and IIw irrigated, with a Storie Index Grade of 4.

Jacktone clay, drained, zero to two percent slopes (161) is located in high areas in basins.

Permeability of the clay is slow. Surface runoff is very slow, and the erosion hazard is none to slight. The available water capacity is moderate. The effective rooting depth is 20 to 40 inches.

The soil is used mainly for irrigated crops, such as rice, barley, wheat, and corn. The land capability unit is IIIs both non-irrigated and irrigated, with a Storie Index Grade of 6.

San Joaquin silt loam, leveled, zero to one percent slopes (213) is located on low terraces.

Permeability of this San Joaquin silt loam is very slow. Surface runoff is very slow, and the erosion hazard is none to slight. The available water capacity is low. The effective rooting depth is 23 to 40 inches. The soil is used principally for irrigated crops or for irrigated hay and pasture. Other uses include irrigated crops for rice. The land capability unit is IIIs both non-irrigated and irrigated, with a Storie Index Grade of 4.

San Joaquin silt loam, zero to three percent slopes (214) is located on low terraces. Permeability of the soil is very slow. Surface runoff is slow, and the erosion hazard is slight. The available water capacity is low. The effective rooting depth is 23 to 40 inches. The soil is used principally for irrigated crops or for irrigated hay and pasture. Other uses include irrigated crops for rice. The land capability unit is IIIs both non-irrigated and irrigated, with a Storie Index Grade of 4.

Important Farmland Designation
With the exception of State mandated LAFCo prime farmland definitions as set forth in Government Code Sections 51201 and 56064, farmland designations that do not meet the definition of Important Farmland pursuant to DOC and CEQA requirements, including Farmland of Local Importance and Other Land, are outside the scope of CEQA requirements, and, thus, are not discussed further. On-site California DOC farmland designations are shown in Figure 4.2-2 and on-site LAFCo Prime Farmland designations are shown in Figure 4.2-3.

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Figure 4.2-2
FMMP Designations
Project Site
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Figure 4.2-3
LAFCo Prime Farmland Designation
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As shown in Figure 4.2-2, the California DOC has defined areas of the project site as Important Farmland, including 31.3 acres of Prime Farmland and 12.1 acres of Farmland of Statewide Importance.10 In addition, pursuant the Sacramento LAFCo definition of “prime agricultural land” and the on-site soil capability classifications above, the project site contains an approximate total of 385.3 acres of prime agricultural land, as shown in Figure 4.2-3.

The project site was historically used as hay fields, with intermittent rice fields from 1937 until at least 2020. The project site is not currently used for active agricultural purposes and is not irrigated. The project site is not subject to a Williamson Act contract.

Additionally, as shown in Figure 3-4 of the Project Description chapter of this EIR, the proposed off-site force main alignment, including each of the three potential force main segment options, occurs in existing roadway right-of-way (ROW) or in other previously disturbed areas. Thus, the off-site improvement area does not include Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.

4.2.3 REGULATORY CONTEXT
The following is a description of federal, State, and local environmental laws and policies that are relevant to the review of agricultural resources under CEQA.

Federal Regulations
The proposed project would be required to comply with the federal regulation described below in order to be developed.

Farmland Protection Policy Act
The NRCS, a federal agency within the USDA, is the agency primarily responsible for the implementation of the Farmland Protection Policy Act (FPPA). The purpose of the FPPA is to minimize federal programs’ contribution to the conversion of farmland to nonagricultural uses by ensuring that federal programs are administered in a manner that is compatible with state, local and private programs designed to protect farmland. NRCS provides technical assistance to federal agencies, state, and local governments; tribes or non-profit organizations that desire to develop farmland protection programs and policies.

The FPPA also established the Farmland Protection Program (FPP) and the Land Evaluation and Site Assessment (LESA). The LESA system ranks lands for suitability and inclusion in the FPP.

LESA evaluates several factors, including soil potential for agricultural uses, location, market access, and adjacent land uses. The LESA system has spawned many variations, including the California LESA model, which is used in California’s FMMP.

State Regulations
The proposed project would have to comply with the State regulations described below, where applicable, in order to be developed.
10 California Department of Conservation. Farmland Mapping & Monitoring Program. Available at:
https://www.conservation.ca.gov/dlrp/fmmp. Accessed January 2022.

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California Land Conservation Act – Williamson Act
The California Land Conservation Act, better known as the Williamson Act, has been the State’s premier agricultural land protection program since the act’s enactment in 1965. The California legislature passed the Williamson Act in 1965 to preserve agricultural and open space lands by discouraging premature and unnecessary conversion to urban uses. The Act creates an arrangement whereby private landowners’ contract with counties and cities to voluntarily restrict land to agricultural and open-space uses. The vehicle for these agreements is a rolling term 10- year contract (i.e., unless either party files a “notice of nonrenewal,” the contract is automatically renewed annually for an additional year). In return, restricted parcels are assessed for property tax purposes at a rate consistent with their annual use, rather than potential market value. The project site is not subject to a Williamson Act contract.

Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 - Prime Agricultural Definition
The Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (Act) establishes procedures for local government changes of organization, including city incorporations, annexations to a city or special district, and city and special district consolidations. LAFCos have numerous powers under the Act, but those of primary concern are the power to act on local agency boundary changes and to adopt spheres of influence for local agencies. According to Section 56064 of the Cortese-Knox-Hertzberg Act, prime agricultural land means an area of land, whether a single parcel or contiguous parcels, that has not been developed for a use other than an agricultural use and that meets five specific qualifications discussed further below. The project site is subject to Section 56064 of the Cortese-Knox-Hertzberg Act.

Local Regulations
The following are the local government environmental goals and policies relevant to the CEQA review process.

Sacramento LAFCo
Sacramento LAFCo is a State-mandated boundary commission responsible for coordinating logical and timely changes in local government boundaries. In consideration of proposals, the Commission observes four basic statutory purposes: the discouragement of urban sprawl, the preservation of open space and agricultural land resources, the efficient provision of government services, and the encouragement of orderly growth boundaries based upon local conditions and circumstances. LAFCo’s powers, procedures, and functions are set forth in the Cortese-KnoxHertzberg Local Government Reorganization Act of 2000, (Government Code Section 56000 et seq.). The following statewide LAFCo definitions, as established in Government Code Section 56064, will be used to determine the potential impacts pertaining to compliance with the requirements of the Government Code:

Agricultural lands
"Agricultural lands" means land currently used for the purpose of producing an agricultural commodity for commercial purposes, land left fallow under a crop rotational program, or land enrolled in an agricultural subsidy or setaside program.

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Prime agricultural lands
"Prime agricultural land" means an area of land, whether a single parcel or contiguous parcels, that has not been developed for a use other than an agricultural use and that meets any of the following qualifications:
(a) Land that qualifies, if irrigated, for rating as Class I or Class II in the Soil Conservation Service land use capability classification, whether or not the land is actually irrigated, provided that irrigation is feasible;
(b) Land that qualifies for rating 80 through 100 Storie Index Rating; (c) Land that supports livestock used for the production of food and fiber and that has an annual carrying capacity equivalent to at least one animal unit per acre as defined by the United States Department of Agriculture in the National Range and Pasture Handbook, Revision 1, December 2003;
(d) Land planted with fruit or nut-bearing trees, vines, bushes, or crops that have a nonbearing period of less than five years and that will return during the commercial bearing period on an annual bases from the production of unprocessed agricultural plant production not less than four hundred dollars ($400) per acre;
(e) Land that has returned from the production of unprocessed agricultural plant products an annual gross value of not less than four hundred dollars ($400) per acre for three of the previous five calendar years.

Sacramento LAFCo has adopted specific standards to ensure that fair and consistent decisions are rendered in accordance with State law. The following list of the adopted Sacramento LAFCo policies and standards is not exhaustive, and only lists goals and policies that pertain to the proposed project. The following are applicable policies from the Sacramento LAFCo Policy, Standards and Procedures Manual, Chapter IV, General Standards.

E. Agricultural Land Conservation

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

City of Sacramento 2040 General Plan
The City of Sacramento 2040 General Plan identifies the following goals and policies related to agricultural resources:

Land Use and Placemaking Element
Goal LUP-1 A compact urban footprint and sustainable development pattern with infrastructure that supports efficient delivery of public services while protecting surrounding open space lands
Policy LUP-1.11 Coordinate to Protect Farmland. The City shall continue to work with Sacramento County and other adjacent jurisdictions to implement conservation plans, preserve farmland and protect critical habitat outside the city
Policy LUP-1.12 Development Adjacent to Agriculture. The City shall require open space or other appropriate buffers for new development abutting productive agricultural areas to protect the viability of active agricultural operations outside of the city and ensure compatibility of uses with residents in adjacent areas.

Environmental Resources and Constraints Element
Goal ERC-9 Climate leadership and bold action to achieve carbon neutrality by 2045, aggressively reduce emissions by 2030, and increase climate resilience communitywide.

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Policy ERC-9.12 Regenerative Food System. The City shall encourage regenerative agriculture practices in urban agriculture uses, including carbon-sequestering practices.

Sacramento City Code
The Sacramento City Code does not include sections related to agricultural resources that would apply to the proposed project.

4.2.4 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 agricultural resources. A discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

Standards of Significance
An impact is considered significant under Appendix G of the CEQA Guidelines if the proposed project would result in any of the following:
 Result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use;
 Conflict with existing zoning for agricultural use, or a Williamson Act contract;  Conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production (see Chapter 5, Effects Not Found to be Significant);
 Result in the loss of forest land or conversion of forest land to non-forest use (see Chapter 5, Effects Not Found to be Significant);
 Involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland to non-agricultural uses or conversion of forest land to non-forest uses; or
 Conflict with the requirements of the Cortese-Knox-Hertzberg act (Government Code Section 5600 et. seq.) pertaining to the conversion of agriculture.

As noted above, issues related to whether the proposed project would result in the following are discussed in Chapter 5, Effects Not Found to be Significant, of this EIR:
 Conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production; and
 Result in the loss of forest land or conversion of forest land to non-forest use.

Method of Analysis
Evaluation of potential impacts of the proposed project on agricultural resources were based on the following: the Sacramento 2040 General Plan; the Sacramento 2040 General Plan MEIR; the USDA NRCS Web Soil Survey; the Soil Survey of Sacramento County, the Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Sacramento County; and prime farmland as defined by Government Code Section 56064 and set forth in the Sacramento LAFCo Policies, Standards and Procedures Manual.

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In particular, the FMMP was used to identify and quantify the acreages of on-site Important Farmland. Similarly, the USDA NRCS Web Soil Survey was used to identify and evaluate on-site soils in order to assess the site’s potential to qualify as “prime agricultural land,” per the LAFCo definition. Because the entirety of the project site is proposed to be converted from the current agricultural designation to urban uses, the foregoing information was used to calculate the amount of Important Farmland and/or “prime agricultural land” that would be lost as a result of project buildout.

The standards of significance listed above are used to delineate the significance of any potential impacts.

Project-Specific Impacts and Mitigation Measures
The following discussion of agricultural impacts is based on the implementation of the proposed project unless otherwise noted.

4.2-1 Impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use. Based on the analysis below, even with implementation of mitigation, the impact is significant and unavoidable.

According to the Soil Candidate Listing for Prime Farmland and Farmland of Statewide Importance, Capay clay loam (113), Clear Lake clay (115), and Cosumnes silt loam (127) meet the criteria for Prime Farmland, while San Joaquin silt loam, leveled (213) and San Joaquin silt loam (214) meet the criteria for Farmland of Statewide Importance.

As shown in Figure 4.2-2 above, the California DOC has determined that the project site contains Prime Farmland, Farmland of Statewide Importance, Farmland of Local Importance, and Other Land. Potential impacts to Important Farmland within the industrial park and the nonparticipating parcels are discussed in the following sections.

In addition, as previously discussed, the proposed off-site force main alignment, including each of the three potential force main segment options, occurs in existing roadway ROW or in other previously disturbed areas. Thus, installation of the off-site force main would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses.

It should be noted that potential impacts related to compliance with the agricultural land policies of the California Government Code as implemented by the Sacramento LAFCo are addressed under Impact 4.2-4 below.

Industrial Park
The existing land uses within the industrial park are predominantly agricultural and contain approximately 31.3 acres of Prime Farmland and approximately 12.1 acres of Farmland of Statewide Importance. As shown in Figure 4.2-2, the portions of the site that qualify as Important Farmland are generally located in the northeastern corner of the project site, within the portion of the site planned for development of the industrial park. Based on the California DOC’s definition, Prime Farmland must have been used for irrigated agricultural production at some time during the four years prior to the Draft EIR
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mapping date. The project site has not been irrigated since 2018. As such, in October 2023, the City formally requested that the California DOC modify the map for the project site to reflect this information. However, because the California DOC Farmland Mapping and Monitoring Program has not yet been updated to reflect this request, this EIR has evaluated the 31.3 acres of Prime Farmland and 12.1 acres of Farmland of Statewide Importance at the project site. Buildout of the industrial park with industrial and commercial uses would permanently convert the existing on-site Prime Farmland and Farmland of Statewide Importance to non-agricultural uses, which could result in a significant impact.

Nonparticipating Parcels
The existing land uses within the portions of the nonparticipating parcels that are not currently planned for development include agricultural uses and vacant undeveloped land. While the nonparticipating parcels are not currently proposed for development, the parcels would receive City of Sacramento 2040 General Plan and Prezoning designations as part of the proposed Annexation. As such, the nonparticipating parcels are likely to be subject to future development. However, the land within the nonparticipating parcels is not defined as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Therefore, future development of the nonparticipating parcels would not result in significant impacts relating to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.

Conclusion
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. Therefore, because the proposed project would result in the conversion of Important Farmland to non-agricultural uses, a significant impact would occur.

Mitigation Measure(s)
As discussed in Chapter 4.4, Biological Resources, of this EIR, the easternmost portion of the project site, including the entirety of the nonparticipating parcels, are located within the Natomas Basin Habitat Conservation Plan (HCP) permit area boundaries. As discussed therein, the proposed project would be subject to applicable fees for the conversion of habitat to urban uses within the Natomas Basin HCP policy area. In addition, as discussed in Chapter 4.4, Biological Resources, surplus acreage under the City’s Natomas Basin HCP allocation may be available for use by the remainder of the project site acreage. Thus, pursuant to Mitigation Measure 4.4-5(b), the proposed project would be required to identify appropriate lands to be set aside in permanent conservation easement at a ratio of one acre of habitat located within the Natomas Basin HCP policy area converted to urban land uses to 0.5-acre of habitat preserved.

Therefore, although the proposed project would involve the conversion of farmland to non-agricultural uses, through compliance with Natomas Basin HCP requirements, open space lands would be preserved elsewhere at a 0.5:1 ratio. The following mitigation Draft EIR
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would similarly require the preservation of off-site farmland at a ratio of one Farmland acre converted to urban land uses outside the Natomas Basin HCP policy area to 0.5- acre preserved, which, combined with the biological resources mitigation required by Mitigation Measure 4.4-5(b), would result in an overall preservation at a 1:1 ratio. While the following mitigation measure 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, although implementation of the following mitigation measure would reduce the above potentially significant impact, the impact would remain significant and unavoidable.

Industrial Park

4.2-1 The City shall ensure that, prior to impacting agricultural/open space resources within the project site by the issuance of a grading permit, any and all project-related subdivision maps satisfy the On-Site Open Space and Off-Site Open Space requirements as defined herein. Open space dedications made pursuant to the Natomas Basin Habitat Conservation Plan (HCP) shall be made to the City and/or the Natomas Basin Conservancy and shall be located in the Natomas Basin. The remaining non-Natomas Basin HCP mitigation acreage may be located in unincorporated Sacramento County, Yolo County, and/or Sutter County, and may be held and managed by a qualified third-party entity with the approval of the City. Preservation shall be ensured in perpetuity via conservation easement, fee, or irrevocable offer of dedication to the satisfaction of the City.
a. On-Site Agricultural/Open Space Requirements: The following onsite open space properties are consistent with the mitigation requirements:
 86 acres of detention basins.
 37.9 acres of freeway buffer.
 2.3 acres of canal buffers.
b. Off-site Agricultural/Open Space Requirements: The following OffSite Open Space properties:
 141.51 acres of currently unidentified agricultural/open spaced mitigation property to be located in the unincorporated Sacramento County and/or unincorporated Sutter County.
 50-acre habitat mitigation property APN 225-0020-014.  67.59-acre habitat mitigation property APN 225-0020-015. c. Phasing: The Airport South Industrial Project will develop in phases, as such, the amount of On-Site and Off-Site Open Space to be provided hereunder shall be in proportion to the amount of acreage proposed to Draft EIR
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be impacted by such development by the issuance of a grading permit therefor.
d. With respect to each unidentified open space property listed above, and any proposed substitution of an open space property listed above, the City must determine, in writing, that the proposed agricultural/open space property and/or acreage satisfies the requirements for agricultural/open space to be counted towards the requisite Off-Site Agricultural/Open Space acreage total.
e. Nothing in this Agricultural/Open Space Mitigation is intended to limit or restrict USFWS and CDFW in their consideration of Developer's applications for incidental take and/or other habitat mitigation permits or other entitlements under the federal Endangered Species Act and the California Endangered Species Act.

4.2-2 Impacts related to conflicts with existing zoning for agricultural uses or Williamson Act contracts. Based on the analysis below, the proposed project would result in a lessthan-significant impact.

Potential impacts related to conflicts with existing zoning for agricultural uses or Williamson Act contracts within both the industrial park and the nonparticipating parcels are discussed together, below. In addition, as previously discussed, the proposed offsite force main alignment, including each of the three potential force main segment options, occurs in existing roadway ROW or in other previously disturbed areas. Thus, installation of the off-site force main would not conflict with zoning for agricultural uses of a Williamson Act contract.

Industrial Park and Nonparticipating Parcels
The project site is not subject to any Williamson Act contracts. The project site is currently located within Sacramento County and is not located within the City of Sacramento’s SOI. Sacramento County’s General Plan currently designates the site as Agricultural Cropland and the site is zoned Agricultural 80 (AG-80). As such, development of the proposed project would result in the conversion of agricultural land to non-agricultural uses; impacts related to such are addressed throughout this chapter.

With respect to the project’s potential to conflict with the site’s existing AG-80 zoning designation, in accordance with the Cortese-Knox-Hertzberg Local Government Reorganization Act (see Government Code Section 56375), the City would prezone the project site to M-1, M-1-PUD, and HC-PUD. The proposed project includes a request to be Prezoned to include 317.9 acres of Industrial Planned Unit Development (M-1-PUD) and 13.4 acres of Highway Commercial PUD (HC-PUD) for the industrial park portion of the project site, and 83 acres of Industrial (M-1) for the nonparticipating parcels. Should the proposed project be given approval by the Lead Agencies, the Sacramento LAFCo and the City of Sacramento, the foregoing Prezoning would take effect. Thus, following project approval, the proposed commercial uses would be consistent with the M-1-PUD Draft EIR
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Chapter 4.2 – Agricultural Resources

and HC-PUD zoning designations. Therefore, the proposed project would result in a less-than-significant impact in regard to conflicts with existing agricultural zoning or Williamson Act contracts.

Mitigation Measure(s)
None required.

4.2-3 Impacts related to involving other changes in the existing environment which, due to their location or nature, could result in conversion of farmland to non-agricultural uses or
conversion of forest land to non-forest uses. Based on the analysis below, the proposed project would result in a lessthan-significant impact.

Potential impacts related to other changes in the existing environment that could result in the conversion of farmland to non-agricultural uses as a result of development of both the industrial park and the nonparticipating parcels are discussed together, below. It is noted that neither the project site, nor the surrounding parcels consist of forest land; thus, impacts related to such areas are not discussed in this analysis. In addition, as previously discussed, the proposed off-site force main alignment, including each of the three potential force main segment options, occurs in existing roadway ROW or in other previously disturbed areas. Thus, installation of the off-site force main would not result in the conversion of farmland to non-agricultural uses or conversion of forest land to nonforest uses.

Industrial Park and Nonparticipating Parcels
Existing land uses surrounding the project site 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.

As discussed above, the parcels to the east and north of the project site are either currently developed or are under construction. Although the land west and south of the project site currently consist of undeveloped agricultural land, the parcels adjacent to the project site to the west are planned for future development as part of the Sacramento International Airport Master Plan. In addition, because the parcels south of the project site are not currently subject to agricultural uses and are located next to an existing school, the parcels are unlikely to be used for agricultural uses in the future. Therefore, the surrounding land uses would not be considered as productive agricultural areas and the project would not be required to provide buffers between the project site and the surrounding uses, pursuant to Policy LUP-1.12 of the City of Sacramento 2040 General Plan.

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Based on the above, the proposed project would not involve changes in the existing environment which, due to their location or nature, could result in conversion of farmland to non-agricultural uses, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.2-4 Impacts related to compliance with the requirements of the Cortese-Knox-Hertzberg act (Government Code, Section 56000 et. seq.) pertaining to the conversion of agricultural land.

Based on the analysis below, the proposed project would result in a significant and unavoidable impact.

Potential impacts related to compliance with the policies of Sacramento LAFCo implementing the requirements of the Cortese-Knox-Hertzberg act pertaining to the conversion of agricultural land within both the industrial park and the nonparticipating parcels are discussed together, below. In addition, as previously discussed, the proposed off-site force main alignment, including each of the three potential force main segment options, occurs in existing roadway ROW or in other previously disturbed areas. Thus, installation of the off-site force main would not result in the conversion of farmland to non-agricultural uses.

Industrial Park and Nonparticipating Parcels
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 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.

As noted previously, the Sacramento LAFCo has specific policies related to agricultural land. For example, Sacramento LAFCo Policy IV-E, Agricultural Land Conservation, states that the Sacramento LAFCo will only approve the conversion of prime agricultural land to other uses if it is found that the proposal will lead to the planned, orderly, and efficient development of an area. As such, in compliance with Sacramento LAFCo Policy IV-E(1)(a), the project site is contiguous with lands that have been developed with urban uses. In addition, in compliance with Sacramento LAFCo Policy IV-E(1)(c), because the development of the entire project site would be likely to take place over five years, the proposed development would occur in phases.

Additional 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 development, on-site soils are evaluated in comparison to the Sacramento LAFCo’s definition of prime agricultural land in Table 4.2-4, pursuant to Government Code Section 56064. Should on-site soils meet any one criterion, such land would be considered prime agricultural land by Sacramento LAFCo.

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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 nonirrigated or irrigated, provided that irrigation is feasible. Thus, as shown in Table 4.2-4, soils within the proposed project site meet criteria (a) to qualify as prime agricultural farmland under Section 56064 of the Cortese-Knox-Hertzberg Act. Therefore, the project would result in a significant impact with regards to compliance with LAFCo’s policies related to the conversion of agricultural land to urban uses.

Table 4.2-4
LAFCo “Prime Agricultural Land” Comparison
Criteria
Discussion
Industrial Park Nonparticipating Parcels
(a) Land that qualifies for
rating as Class I or Class
II in the Soil Conservation
Service land use
capability classification.

The majority of on-site
soils are in Class II. The
Class II soils have
moderate limitations
related to water
interference and soil
quality that reduce the
choice of plans, or
require special
conservation practices.

As such, the soils within
the project site meet
criterion (a).

Soils located within the
nonparticipating parcels are in
Class II and Class III. As such,
the soils within the
nonparticipating parcels have
moderate to high limitations
related to water interference and
soil quality that reduce the choice
of plans, or require special
conservation practices.

Therefore, the Class II soils
within the nonparticipating
parcels have the potential to
meet criterion (a).
(b) Land that qualifies for
rating 80 through 100
Storie Index Rating.

The on-site soils have a
Storie Index Rating of
Grade 2 to 4 (20 to 68).

Therefore, the land does
not meet criterion (b).

The conditions of the
nonparticipating parcels do not
differ from the industrial park.

Therefore, the land within the
nonparticipating parcels does not
meet criterion (b).
(c) Land that supports
livestock used for the
production of food and
fiber and that has an
annual carrying capacity
equivalent to at least one
animal unit per acre as
defined by the United
States Department of
Agriculture in the
National Handbook on
Range and Related
Grazing Lands, July
1967, developed
pursuant to Public Law
46, December 1935.

The Airport South
Industrial Project Site has
never been used as land
that supports livestock for
the production of food
and fiber.

Livestock is not
supported for commercial
purposes within the
project site. As such, the
land within the project
site does not meet
criterion (c).

The conditions of the
nonparticipating parcels do not
differ from the industrial park.

Therefore, the land within the
nonparticipating parcels does not
meet criterion (c).
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Table 4.2-4
LAFCo “Prime Agricultural Land” Comparison
Criteria
Discussion
Industrial Park Nonparticipating Parcels
(d) Land planted with fruit or
nut-bearing trees, vines,
bushes, or crops that
have a nonbearing period
of less than five years
and that will return during
the commercial bearing
period on an annual
bases from the
production of
unprocessed agricultural
plant production not less
than four hundred dollars
($400) per acre.

Fruit or nut-bearing trees,
vines, bushes, or crops
are not currently growing
within the project site. As
such, the land within the
industrial park portion of
the project site does not
meet criteria (d).

The conditions of the
nonparticipating parcels do not
differ from the industrial park.

Therefore, the land within the
nonparticipating parcels does not
meet criteria (d).
(e) Land that has returned
from the production of
unprocessed agricultural
plant products an annual
gross value of not less
than four hundred dollars
($400) per acre for three
of the previous five
calendar years.

As discussed in criterion
(d) above, the project site
has not produced
unprocessed agricultural
crops with an annual
gross value of four
hundred dollars ($400) or
more per acre for any
three of the past five
years. Therefore, the
land does not meet
criterion (e).

The conditions of the
nonparticipating parcels do not
differ from the industrial park.

Therefore, the land within the
nonparticipating parcels does not
meet criterion (e).

Notes: The information and data gathered for Table 4.2-4 discussion was provided by various sources, including interviews with property owners and aerial photography.

Mitigation Measure(s)
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. Implementation of mitigation measure 4.2-1 would help reduce the project’s potential impacts related to conversion of important farmland. However, as discussed under Impact 4.2-1, 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-thansignificant level. Therefore, the impact would remain significant and unavoidable.

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.

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Additional detail regarding the cumulative setting is included in Chapter 6, Statutorily Required Sections, of this EIR.

4.2-5 Impacts related to cumulative loss of agricultural land. Based on the analysis below, even with implementation of mitigation, the proposed project would result in a significant and
unavoidable impact.

The City’s 2040 General Plan MEIR determined that the net decrease of Important Farmland for crops from 2018 to 2020 within Sacramento County was 7,053 acres.

Buildout of the 2040 General Plan could result in the further conversion, and therefore loss, of agricultural land to urban uses. Sufficient agricultural land does not exist within the City to be preserved in compensation with the amount of farmland converted to urban uses. Many of the goals and policies listed above encourage the continued productivity and preservation of existing local agricultural lands and operations in areas outside of the City.

Although the project site is not currently within the City’s Sphere of Influence, following the proposed Annexation, the project would be required to comply with all applicable policies. However, the project was not anticipated within the City’s General Plan MEIR analysis. As such, the most relevant cumulative setting for the proposed project is within Sacramento County.

According to the County’s General Plan EIR, the County contains approximately 110,278 acres of Prime Farmland, 56,140 acres of Farmland of Statewide Importance, 15,187 acres of Unique Farmland, and 39,873 acres of Farmland of Local Importance.

The County’s General Plan EIR determined that even with the preservation of farmland at a one-to-one ratio, buildout of the County General Plan would result in a net loss of farmland, and a significant impact would occur.

Thus, 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 aforementioned impact.

Because of the above, even with implementation of mitigation, the project’s incremental contribution to the cumulative impact is cumulatively considerable and significant and unavoidable.

Mitigation Measure(s)
Implementation of the following mitigation measure would help reduce the project’s incremental contribution towards the cumulative impact related to conversion of important farmland. However, the impact would remain significant and unavoidable due to the permanent loss of agricultural land attributable to the project.

4.2-5 Implement Mitigation Measure 4.2-1.

4.3 AIR QUALITY, GREENHOUSE GAS

EMISSIONS, AND ENERGY

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4.3.1 INTRODUCTION
The Air Quality, Greenhouse Gas Emissions, and Energy chapter of the EIR describes the potential impacts of the proposed project on local and regional air quality emissions, potential impacts related to greenhouse gas (GHG) emissions and climate change, and potential impacts related to energy. The chapter includes a discussion of the existing air quality, GHG, and energy setting, the existing regulatory setting, as well as potential air quality, GHG, and energy impacts resulting from implementation of the project. In addition, the chapter includes mitigation measures warranted to reduce or eliminate any identified significant impacts. This chapter is based on the City of Sacramento 2040 General Plan,1 the City of Sacramento 2040 Master EIR (MEIR),2 the Sacramento Metropolitan Air Quality Management District (SMAQMD) CEQA Guide,3 and technical analysis performed by Raney Planning and Management, Inc. (see Appendix C).

As described 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 project site, and the nonparticipating parcels, which are primarily located in the southeastern portion of the overall site. While the entire project site is proposed for annexation into the City of Sacramento, only the industrial park is currently proposed for development. As such, the analysis herein includes a discussion of air quality, GHG, and energy impacts associated with the industrial park, the nonparticipating parcels, or a combination of the two project components, as applicable.

4.3.2 EXISTING ENVIRONMENTAL SETTING
The following information provides an overview of the existing environmental setting in relation to air quality within the proposed project area. Air basin characteristics, ambient air quality standards (AAQS), attainment status and regional air quality plans, local air quality monitoring, odors, sensitive receptors, information related to climate change and GHGs, and energy are discussed.

Air Basin Characteristics
The proposed project site is located in the City of Sacramento, which falls within the Sacramento Valley Air Basin (SVAB) and is within the jurisdictional boundaries of the SMAQMD. The SVAB is in the northern half of California’s Great Valley and is bordered on three sides by mountain ranges.

Air flows into the SVAB through the Carquinez Strait, moves across the Delta and carries pollutants from the heavily populated San Francisco Bay Area into the SVAB. The prevailing winds are moderate in strength and vary from moist clean breezes from the south to dry land flows from the north.

Most precipitation in the SVAB results from air masses moving in from the Pacific Ocean during the winter months. Storms usually move through the area from the west or northwest. During the 1 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 2 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023. 3 Sacramento Metropolitan Air Quality Management District. CEQA Guide. April 2020.

4.3 AIR QUALITY, GREENHOUSE GAS

EMISSIONS, AND ENERGY
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winter rainy season (November through February) over half the total annual precipitation falls while the average winter temperature is a moderate 49 degrees Fahrenheit. During the summer, daytime temperatures can exceed 100 degrees Fahrenheit. Dense fog occurs mostly in midwinter and rarely in the summer. The inland location and surrounding mountains shelter the valley from much of the ocean breeze that keeps the coastal regions moderate in temperature. The only breech in the mountain barrier is the Carquinez Strait, which exposes the midsection of the valley to the coastal air mass.

Ambient Air Quality Standards
Both the U.S. Environmental Protection Agency (USEPA) and the California Air Resources Board (CARB) have established AAQS for common pollutants. The federal standards are divided into primary standards, which are designed to protect the public health, and secondary standards, which are designed to protect the public welfare. AAQS for each contaminant represent safe levels that avoid specific adverse health effects. Pollutants for which air quality standards have been established are called “criteria” pollutants. Table 4.3-1 identifies the major pollutants, characteristics, health effects and typical sources. The federal and California ambient air quality standards (NAAQS and CAAQS, respectively) are summarized in Table 4.3-2. The NAAQS and CAAQS were developed independently with differing purposes and methods. As a result, the federal and State standards differ in some cases. In general, the State of California standards are more stringent than the federal standards, particularly for ozone and particulate matter (PM).

A description of each criteria pollutant and its potential health effects is provided in the following section.

Ozone
Ozone is a reactive gas consisting of three oxygen atoms. In the troposphere, ozone is a product of the photochemical process involving the sun's energy, and is a secondary pollutant formed as a result of a complex chemical reaction between reactive organic gases (ROG) and oxides of nitrogen (NOX) emissions in the presence of sunlight. As such, unlike other pollutants, ozone is not released directly into the atmosphere from any sources. In the stratosphere, ozone exists naturally and shields Earth from harmful incoming ultraviolet radiation. The primary source of ozone precursors is mobile sources, including cars, trucks, buses, construction equipment, and agricultural equipment. Ground-level ozone reaches the highest level during the afternoon and early evening hours. High levels occur most often during the summer months. Ground-level ozone is a strong irritant that could cause constriction of the airways, forcing the respiratory system to work harder in order to provide oxygen. Ozone at the Earth's surface causes numerous adverse health effects and is a major component of smog. High concentrations of ground level ozone can adversely affect the human respiratory system and aggravate cardiovascular disease and many respiratory ailments.

Reactive Organic Gas
ROG refers to several reactive chemical gases composed of hydrocarbon compounds typically found in paints and solvents that contributes to the formation of smog and ozone by involvement in atmospheric chemical reactions. A separate health standard does not exist for ROG. However, some compounds that make up ROG are toxic, such as the carcinogen benzene.

Oxides of Nitrogen
NOX are a family of gaseous nitrogen compounds and are precursors to the formation of ozone and particulate matter.

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Table 4.3-1
Summary of Criteria Pollutants
Pollutant Characteristics Health Effects Major Sources
Ozone A highly reactive gas produced
by the photochemical process
involving a chemical reaction
between the sun’s energy and
other pollutant emissions. Often
called photochemical smog.
 Eye irritation
 Wheezing, chest pain, dry
throat, headache, or nausea
 Aggravated respiratory
disease such as
emphysema, bronchitis, and
asthma
Combustion sources
such as factories,
automobiles, and
evaporation of
solvents and fuels.

Carbon
Monoxide
An odorless, colorless, highly
toxic gas that is formed by the
incomplete combustion of fuels.
 Impairment of oxygen
transport in the bloodstream
 Impaired vision, reduced
alertness, chest pain, and
headaches
 Can be fatal in the case of
very high concentrations
Automobile exhaust,
combustion of fuels,
and combustion of
wood in woodstoves
and fireplaces.

Nitrogen
Dioxide
A reddish-brown gas that
discolors the air and is formed
during combustion of fossil fuels
under high temperature and
pressure.
 Lung irrigation and damage
 Increased risk of acute and
chronic respiratory disease
Automobile and
diesel truck exhaust,
industrial processes,
and fossil-fueled
power plants.

Sulfur
Dioxide
A colorless, irritating gas with a
rotten egg odor formed by
combustion of sulfur-containing
fossil fuels.
 Aggravation of chronic
obstruction lung disease
 Increased risk of acute and
chronic respiratory disease
Diesel vehicle
exhaust, oil-powered
power plants, and
industrial processes.

Particulate
Matter
(PM10 and
PM2.5)
A complex mixture of extremely
small particles and liquid
droplets that can easily pass
through the throat and nose and
enter the lungs.
 Aggravation of chronic
respiratory disease
 Heart and lung disease
 Coughing
 Bronchitis
 Chronic respiratory disease
in children
 Irregular heartbeat
 Nonfatal heart attacks
Combustion sources
such as automobiles,
power generation,
industrial processes,
and wood burning.

Also from unpaved
roads, farming
activities, and fugitive
windblown dust.

Lead A metal found naturally in the
environment as well as in
manufactured products.
 Loss of appetite, weakness,
apathy, and miscarriage
 Lesions of the
neuromuscular system,
circulatory system, brain, and
gastrointestinal tract
Industrial sources and
combustion of leaded
aviation gasoline.

Sources:
 California Air Resources Board. California Ambient Air Quality Standards (CAAQS). Available at:
https://ww2.arb.ca.gov/resources/california-ambient-air-quality-standards. Accessed February 2024.  Sacramento Metropolitan, El Dorado, Feather River, Placer, and Yolo-Solano Air Districts, Spare the Air website. Air Quality Information for the Sacramento Region. Available at: sparetheair.com. Accessed February 2024.
 California Air Resources Board. Glossary of Air Pollution Terms. Available at:
https://ww2.arb.ca.gov/glossary. Accessed February 2024.

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Table 4.3-2
Ambient Air Quality Standards
Pollutant
Averaging
Time CAAQS
NAAQS
Primary Secondary
Ozone 1 Hour 0.09 ppm - Same as primary 8 Hour 0.070 ppm 0.070 ppm Carbon Monoxide 8 Hour 9 ppm 9 ppm - 1 Hour 20 ppm 35 ppm Nitrogen Dioxide Annual Mean 0.030 ppm 53 ppb Same as primary 1 Hour 0.18 ppm 100 ppb -
Sulfur Dioxide
24 Hour 0.04 ppm - -
3 Hour - - 0.5 ppm
1 Hour 0.25 ppm 75 ppb -
Respirable Particulate
Matter (PM10)
Annual Mean 20 ug/m3 - Same as primary
24 Hour 50 ug/m3 150 ug/m3
Fine Particulate Matter
(PM2.5)
Annual Mean 12 ug/m3 12 ug/m3 15 ug/m3
24 Hour - 35 ug/m3 Same as primary
Lead 30 Day Average 1.5 ug/m3 - -
Calendar Quarter - 1.5 ug/m3 Same as primary
Sulfates 24 Hour 25 ug/m3 - -
Hydrogen Sulfide 1 Hour 0.03 ppm - -
Vinyl Chloride 24 Hour 0.010 ppm - -
Visibility Reducing
Particles 8 Hour (see note) - -
ppm = parts per million
ppb = parts per billion
µg/m3 = micrograms per cubic meter
Note: Statewide Visibility Reducing Particle Standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 0.23 per kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.

Source: California Air Resources Board. Ambient Air Quality Standards. May 4, 2016. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf. Accessed February 2024.

The major component of NOX, nitrogen dioxide (NO2), is a reddish-brown gas that discolors the air and is toxic at high concentrations. NOX results primarily from the combustion of fossil fuels under high temperature and pressure. On-road and off-road motor vehicles and fuel combustion are the major sources of NOX. NOX reacts with ROG to form smog, which could result in adverse impacts to human health, damage the environment, and cause poor visibility. Additionally, NOX emissions are a major component of acid rain. Health effects related to NOX include lung irritation and lung damage and can cause increased risk of acute and chronic respiratory disease.

Carbon Monoxide
Carbon monoxide (CO) is a colorless, odorless, poisonous gas produced by incomplete burning of carbon-based fuels such as gasoline, oil, and wood. When CO enters the body, the CO combines with chemicals in the body, which prevents blood from carrying oxygen to cells, tissues, and organs. Symptoms of exposure to CO can include problems with vision, reduced alertness, Draft EIR
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Chapter 4.3 – Air Quality, Greenhouse Gas Emissions, and Energy

and general reduction in mental and physical functions. Exposure to CO can result in chest pain, headaches, reduced mental alertness, and death at high concentrations.

Sulfur Dioxide
Sulfur Dioxide (SO2) is a colorless, irritating gas with a rotten egg odor formed primarily by the combustion of sulfur-containing fossil fuels from mobile sources, such as locomotives, ships, and off-road diesel equipment. SO2 is also emitted from several industrial processes, such as petroleum refining and metal processing. Similar to airborne NOX, suspended sulfur oxide particles contribute to poor visibility. The sulfur oxide particles are also a component of particulate matter, discussed below.

Particulate Matter
Particulate matter, also known as particle pollution or PM, is a complex mixture of extremely small particles and liquid droplets. Particle pollution is made up of a number of components, including acids (such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles. The size of particles is directly linked to their potential for causing health impacts. The USEPA is concerned about particles that are 10 micrometers in diameter or smaller (PM10) because those are the particles that generally pass through the throat and nose and enter the lungs. Once inhaled, the particles could affect the heart and lungs and cause serious health effects. USEPA groups particle pollution into three categories based on their size and where they are deposited:
 "Inhalable coarse particles (PM2.5-10)," which are found near roadways and dusty industries, are between 2.5 and 10 micrometers in diameter. PM2.5-10 is deposited in the thoracic region of the lungs.
 "Fine particles (PM2.5)," which are found in smoke and haze, are 2.5 micrometers in diameter and smaller. PM2.5 particles could be directly emitted from sources such as forest fires, or could form when gases emitted from power plants, industries, and automobiles react in the air. They penetrate deeply into the thoracic and alveolar regions of the lungs.  “Ultrafine particles (UFP),” are very, very small particles (less than 0.1 micrometers in diameter) largely resulting from the combustion of fossil fuels, meat, wood, and other hydrocarbons. While UFP mass is a small portion of PM2.5, their high surface area, deep lung penetration, and transfer into the bloodstream could result in disproportionate health impacts relative to their mass. UFP is not currently regulated separately, but is analyzed as part of PM2.5.

PM10, PM2.5, and UFP include primary pollutants, which are emitted directly to the atmosphere and secondary pollutants, which are formed in the atmosphere by chemical reactions among precursors. Generally speaking, PM2.5 and UFP are emitted by combustion sources like vehicles, power generation, industrial processes, and wood burning, while PM10 sources include the same sources plus roads and farming activities. Fugitive windblown dust and other area sources also represent a source of airborne dust. Long-term PM pollution, especially fine particles, could result in significant health problems including, but not limited to, the following: increased respiratory symptoms, such as irritation of the airways, coughing or difficulty breathing; decreased lung function; aggravated asthma; development of chronic respiratory disease in children; development of chronic bronchitis or obstructive lung disease; irregular heartbeat; heart attacks; and increased blood pressure.

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Visibility Reducing Particles
Visibility reducing particles are a mixture of suspended particulate matter consisting of dry solid fragments, solid cores with liquid coatings, and small droplets of liquid. The standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.

Lead
Lead is a relatively soft and chemically resistant metal that is a natural constituent of air, water, and the biosphere. Lead forms compounds with both organic and inorganic substances. As an air pollutant, lead is present in small particles. Sources of lead emissions in California include a variety of industrial activities. Gasoline-powered automobile engines were a major source of airborne lead through the use of leaded fuels. The use of leaded fuel has been mostly phased out, with the result that ambient concentrations of lead have dropped dramatically. However, because lead was emitted in large amounts from vehicles when leaded gasoline was used, lead is present in many soils (especially urban soils) as a result of airborne dispersion and could become re-suspended into the air.

Because lead is slowly excreted by the human body, exposure to small amounts of lead from a variety of sources could accumulate to harmful levels. Effects from inhalation of lead above the level of the AAQS may include impaired blood formation and nerve conduction. Lead can adversely affect the nervous, reproductive, digestive, immune, and blood-forming systems.

Symptoms could include fatigue, anxiety, short-term memory loss, depression, weakness in the extremities, and learning disabilities in children. Lead also causes cancer.

Sulfates
Sulfates are the fully oxidized ionic form of sulfur and are colorless gases. Sulfates occur in combination with metal and/or hydrogen ions. In California, emissions of sulfur compounds occur primarily from the combustion of petroleum-derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. The sulfur is oxidized to SO2 during the combustion process and subsequently converted to sulfate compounds in the atmosphere. The conversion of SO2 to sulfates takes place comparatively rapidly and completely in urban areas of California due to regional meteorological features.

The sulfates standard established by CARB is designed to prevent aggravation of respiratory symptoms. Effects of sulfate exposure at levels above the standard include a decrease in ventilatory function, aggravation of asthmatic symptoms, and an increased risk of cardiopulmonary disease. Sulfates are particularly effective in degrading visibility, and, because they are usually acidic, can harm ecosystems and damage materials and property.

Hydrogen Sulfide
Hydrogen sulfide (H2S) is associated with geothermal activity, oil and gas production, refining, sewage treatment plants, and confined animal feeding operations. Hydrogen sulfide is extremely hazardous in high concentrations, especially in enclosed spaces (800 parts per million [ppm] can cause death).

Vinyl Chloride
Vinyl chloride (C2H3Cl, also known as VCM) is a colorless gas that does not occur naturally, but is formed when other substances such as trichloroethane, trichloroethylene, and tetrachloroethylene are broken down. Vinyl chloride is used to make polyvinyl chloride (PVC) which is used Draft EIR
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to make a variety of plastic products, including pipes, wire and cable coatings, and packaging materials.

Toxic Air Contaminants
In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are also a category of environmental concern. TACs are present in many types of emissions with varying degrees of toxicity. Public exposure to TACs can result from emissions from normal operations, as well as accidental releases. Common stationary sources of TACs include gasoline stations, dry cleaners, and diesel backup generators, which are subject to SMAQMD stationary source permit requirements. The other, often more significant, common source type is on-road motor vehicles, such as cars and trucks, on freeways and roads, and off-road sources such as construction equipment, ships, and trains.

Fossil fueled combustion engines, including those used in cars, trucks, and some pieces of construction equipment, release at least 40 different TACs. In terms of health risks, the most volatile contaminants are diesel particulate matter (DPM), benzene, formaldehyde, 1,3-butadiene, toluene, xylenes, and acetaldehyde. Gasoline vapors contain several TACs, including benzene, toluene, and xylenes. Diesel engines emit a complex mixture of air pollutants, including both gaseous and solid material. The solid material in diesel exhaust, DPM, is composed of carbon particles and numerous organic compounds, including over 40 known cancer-causing organic substances. Examples of such chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene. Diesel exhaust also contains gaseous pollutants, including ROG and NOX. Due to the published evidence of a relationship between diesel exhaust exposure and lung cancer and other adverse health effects, the CARB has identified DPM from diesel-fueled engines as a TAC. Although a variety of TACs are emitted by fossil fueled combustion engines, the cancer risk due to DPM exposure represents a more significant risk than the other TACs discussed above.4
More than 90 percent of DPM is less than one micrometer in diameter, and, thus, DPM is a subset of PM2.5. As a California statewide average, DPM comprises about eight percent of PM2.5 in outdoor air, although DPM levels vary regionally due to the non-uniform distribution of sources throughout the State. Most major sources of diesel emissions, such as ships, trains, and trucks, operate in and around ports, rail yards, and heavily-traveled roadways. Such areas are often located near highly populated areas. Accordingly, elevated DPM levels are mainly an urban problem, with large numbers of people exposed to higher DPM concentrations, resulting in greater health consequences compared to rural areas.

Due to the high levels of diesel activity, high volume freeways, stationary diesel engines, rail yards and facilities attracting heavy and constant diesel vehicle traffic are identified as having the highest associated health risks from DPM. Construction-related activities also have the potential to generate concentrations of DPM from on-road haul trucks and off-road equipment exhaust emissions.

Health risks from TACs are a function of both the concentration of emissions and the duration of exposure, which typically are associated with long-term exposure and the associated risk of contracting cancer. Health effects of exposure to TACs other than cancer include birth defects, neurological damage, and death. Because chronic exposure can result in adverse health effects, TACs are regulated at the regional, State, and federal level. The identification, regulation, and 4 California Air Resources Board. Reducing Toxic Air Pollutants in California’s Communities. February 6, 2002.

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monitoring of TACs is relatively new compared to criteria air pollutants that have established AAQS. TACs are regulated or evaluated on the basis of risk to human health rather than comparison to an AAQS or emission-based threshold.

Attainment Status and Regional Air Quality Plans
The Federal Clean Air Act (FCAA) and the California Clean Air Act (CCAA) require all areas of California to be classified as attainment, nonattainment, or unclassified as to their status with regard to the NAAQS and/or CAAQS. The FCAA and CCAA require that the CARB, based on air quality monitoring data, designate portions of the State where the federal or State AAQS are not met as “nonattainment areas.” Because of the differences between the national and State standards, the designation of nonattainment areas is different under the federal and State legislation. The CCAA requires local air pollution control districts to prepare air quality attainment plans. These plans must provide for district-wide emission reductions of five percent per year averaged over consecutive three-year periods or, provide for adoption of “all feasible measures on an expeditious schedule.”
As presented in Table 4.3-3, under the CCAA, Sacramento County has been designated nonattainment for the State and federal one-hour ozone, State and federal eight-hour ozone, State PM10, and federal PM2.5 standards. The County is designated attainment or unclassified for all other AAQS.

Table 4.3-3
Sacramento County Attainment Status Designations
Pollutant Averaging Time
California
Standards Federal Standards
Ozone 1 Hour Nonattainment Nonattainment
8 Hour Nonattainment Nonattainment
Carbon Monoxide 8 Hour Attainment Attainment
1 Hour Attainment Attainment
Nitrogen Dioxide
Annual Mean Attainment Unclassifiable/
Attainment
1 Hour Attainment Unclassifiable/
Attainment
Sulfur Dioxide 24 Hour Attainment -
1 Hour Attainment Attainment
Respirable Particulate
Matter (PM10)
Annual Mean Nonattainment -
24 Hour Nonattainment Attainment
Fine Particulate Matter
(PM2.5)
Annual Mean Attainment Attainment
24 Hour - Nonattainment
Lead Rolling 3-Month
Average
Attainment Attainment
Sulfates 24 Hour Attainment -
Source: Sacramento Metropolitan Air Quality Management District. Air Quality Pollutants and Standards.

Available at: http://www.airquality.org/air-quality-health/air-quality-pollutants-and-standards. Accessed February 2024.

Due to the nonattainment designations, the SMAQMD, along with the other air districts in the SVAB region, is required to develop plans to attain the federal and State standards for ozone and particulate matter. The air quality plans include emissions inventories to measure the sources of air pollutants, to evaluate how well different control measures have worked, and show how air Draft EIR
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pollution would be reduced. In addition, the plans include the estimated future levels of pollution to ensure that the area would meet air quality goals. Each of the attainment plans currently in effect are discussed in further detail in the Regulatory Context section of this chapter.

Local Air Quality Monitoring
Air quality is monitored by CARB at various locations to determine which air quality standards are being violated, and to direct emission reduction efforts, such as developing attainment plans and rules, incentive programs, etc. The nearest local air quality monitoring station to the project site is the Sacramento – T Street station, located at 1309 T Street in Sacramento, CA, approximately eight miles southeast of the project site. Table 4.3-4 shows historical occurrences of pollutant levels exceeding the State and federal AAQS for the three-year period from 2020 to 2022.

Table 4.3-4
Air Quality Data Summary (2020-2022)
Pollutant Standard
Days Standard Was Exceeded
2020 2021 2022
1-Hour Ozone State 1 0 1
Federal 0 0 0
8-Hour Ozone State 3 1 3
Federal 3 1 3
24-Hour PM2.5 Federal 6 4 0
24-Hour PM10
State 59 12 6
Federal 4 0 0
1-Hour Nitrogen
Dioxide
State 0 0 0
Federal 0 0 0
Source: California Air Resources Board. Aerometric Data Analysis and Management (iADAM) System.

Available at http://www.arb.ca.gov/adam/welcome.html. Accessed February 2024.

Odors
While offensive odors rarely cause physical harm, they can be unpleasant, leading to considerable annoyance and distress among the public and can generate citizen complaints to local governments and air districts. The potential for an odor impact is dependent on a number of variables including the nature of the odor source, distance between a receptor and an odor source, and local meteorological conditions. One of the most important factors influencing the potential for an odor impact to occur is the distance between the odor source and receptors, also referred to as a buffer zone or setback. The greater the distance between an odor source and receptor, the less concentrated the odor emission would be when reaching the receptor.

Meteorological conditions also affect the dispersion of odor emissions, which determines the exposure concentration of odiferous compounds at receptors. The predominant wind direction in an area influences which receptors are exposed to the odiferous compounds generated by a nearby source. Receptors located upwind from a large odor source may not be affected due to the produced odiferous compounds being dispersed away from the receptors. Wind speed also influences the degree to which odor emissions are dispersed away from any area.

Odiferous compounds could be generated from a variety of source types including both construction and operational activities. Examples of common land use types that typically generate significant odor impacts include, but are not limited to, wastewater treatment plants, sanitary landfills, composting/green waste facilities, recycling facilities, petroleum refineries, chemical manufacturing plants, painting/coating operations, rendering plants, and food packaging Draft EIR
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plants. The project site is not located in the vicinity of any such land uses. Although less common, diesel fumes associated with substantial diesel-fueled equipment and heavy-duty trucks, such as from construction activities, freeway traffic, or distribution centers, can be found to be objectionable.

Sensitive Receptors
Some land uses are considered more sensitive to air pollution than others, due to the types of population groups or activities involved. Children, pregnant women, the elderly, and those with existing health problems are especially vulnerable to the effects of air pollution. Accordingly, land uses that are typically considered to be sensitive receptors include residences, schools, day care centers, playgrounds, and medical facilities. The nearest sensitive receptors include the singlefamily residences and Paso Verde K-8 School, located approximately 200 feet east and 200 feet south of the project site, respectively.

Greenhouse Gas Emissions
GHGs are gases that absorb and emit radiation within the thermal infrared range, trapping heat in the Earth’s atmosphere. Some GHGs occur naturally and are emitted into the atmosphere through both natural processes and human activities. Other GHGs are created and emitted solely through human activities. The principal GHGs that enter the atmosphere due to human activities are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated carbons. Other common GHGs include water vapor, ozone, and aerosols. The increase in atmospheric concentrations of GHG due to human activities has resulted in more heat being held within the atmosphere, which is the accepted explanation for global climate change.

The primary GHG emitted by human activities is CO2, with the next largest components being CH4 and N2O. A wide variety of human activities result in the emission of CO2. Some of the largest sources of CO2 include the burning of fossil fuels for transportation and electricity, industrial processes including fertilizer production, agricultural processing, and cement production. The primary sources of CH4 emissions include domestic livestock sources, decomposition of wastes in landfills, releases from natural gas systems, coal mine seepage, and manure management.

The main human activities producing N2O are agricultural soil management, fuel combustion in motor vehicles, nitric acid production, manure management, and stationary fuel combustion.

Emissions of GHG by economic sector indicate that energy-related activities account for the majority of U.S. emissions. Electricity generation is the largest single-source of GHG emissions, and transportation is the second largest source, followed by industrial activities. The agricultural, commercial, and residential sectors account for the remainder of GHG emission sources.5 Emissions of GHG are partially offset by uptake of carbon and sequestration in trees, agricultural soils, landfilled yard trimmings and food scraps, and absorption of CO2 by the Earth’s oceans.

Additional emission reduction measures for GHG could include, but are not limited to, compliance with local, State, or federal plans or strategies for GHG reductions, on-site and off-site mitigation, and project design features. Attainment concentration standards for GHGs have not been established by the federal or State government.
5 U.S. Environmental Protection Agency. Sources of Greenhouse Gas Emissions. Available at:
https://19january2017snapshot.epa.gov/ghgemissions/sources-greenhouse-gas-emissions_.html. Accessed February 2024.

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Global Warming Potential
Global warming potential (GWP) is one type of simplified index (based upon radiative properties) that can be used to estimate the potential future impacts of emissions of various gases. According to the USEPA, the GWP of a gas, or aerosol, to trap heat in the atmosphere is the “cumulative radiative forcing effects of a gas over a specified time horizon resulting from the emission of a unit mass of gas relative to a reference gas.” The reference gas for comparison is CO2. GWP is based on a number of factors, including the heat-absorbing ability of each gas relative to that of CO2, as well as the decay rate of each gas relative to that of CO2. Each gas’s GWP is determined by comparing the radiative forcing associated with emissions of that gas versus the radiative forcing associated with emissions of the same mass of CO2, for which the GWP is set at one. Methane gas, for example, is estimated by the USEPA to have a comparative global warming potential 25 times greater than that of CO2, as shown in Table 4.3-5.

Table 4.3-5
GWPs and Atmospheric Lifetimes of Select GHGs
Gas
Atmospheric Lifetime
(years)
GWP
(100 year time horizon)
Carbon Dioxide (CO2) 50-2001 1
Methane (CH4) 12 25
Nitrous Oxide (N2O) 114 298
HFC-23 270 14,800
HFC-134a 14 1,430
HFC-152a 1.4 124
PFC: Tetrafluoromethane (CF4) 50,000 7,390
PFC: Hexafluoroethane (C2F6) 10,000 12,200
Sulfur Hexafluoride (SF6) 3,200 22,800 1 For a given amount of CO2 emitted, some fraction of the atmospheric increase in concentration is quickly absorbed by the oceans and terrestrial vegetation, some fraction of the atmospheric increase will only slowly decrease over a number of years, and a small portion of the increase will remain for many centuries or more.

Source: USEPA. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019 [Table 1-2]. April 14, 2021.

As shown in the table, at the extreme end of the scale, sulfur hexafluoride is estimated to have a comparative GWP 22,800 times that of CO2. The atmospheric lifetimes of such GHGs are estimated by the USEPA to vary from 50 to 200 years for CO2, to 50,000 years for CF4. Longer atmospheric lifetimes allow GHG to buildup in the atmosphere; therefore, longer lifetimes correlate with the GWP of a gas. The common indicator for GHG is expressed in terms of metric tons of CO2 equivalents (MTCO2e), which is calculated based on the GWP for each pollutant.

Effects of Global Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts related to future air temperatures and precipitation patterns. The Intergovernmental Panel on Climate Change’s (IPCC) Climate Change 2021: The Physical Science Basis report indicated that warming of the climate system is unequivocal, and since the 1950s, many of the observed changes are unprecedented over decades to millennia.6 Signs that global climate change has occurred include:
6 Intergovernmental Panel on Climate Change. Climate Change 2021: The Physical Science Basis Summary for Policymakers. Available at: https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf.

Accessed February 2024.

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 Warming of the atmosphere and ocean;
 Diminished amounts of snow and ice;
 Rising sea levels; and
 Ocean acidification.

Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment (OEHHA) identified various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernable evidence that climate change is occurring in California and is having significant, measurable impacts in the State.

Changes in the State’s climate have been observed, including:
 An increase in annual average air temperature with record warmth;  More frequent extreme heat events;
 More extreme drought;
 A decline in winter chill; and
 An increase in variability of statewide precipitation.

Warming temperatures and changing precipitation patterns have altered California’s physical systems – the ocean, lakes, rivers and snowpack – upon which the State depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade Mountains provide approximately one-third of the State’s annual water supply. Impacts of climate on physical systems have been observed, such as high variability of snow-water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters. Impacts of climate change on biological systems, including humans, wildlife, and vegetation, have also been observed, including climate change impacts on terrestrial, marine, and freshwater ecosystems.

In the Sacramento region, specifically, global climate change hazards include extreme heat and flooding. California’s Fourth Climate Change Assessment predicts that the Sacramento Valley region is expected to see an average daily temperature maximum increase of 10 degrees Fahrenheit by the end of the century. Additionally, Midtown Sacramento is anticipated to experience up to 40 days per year of extreme heat (>103.9 F), as compared to the approximately four days per year that occur now.7 Such extreme heat events pose a public health hazard. In addition to extreme heat, the Sacramento region is anticipated to experience more extreme floods, greater floodplain vulnerability, and higher Delta water levels.8 Although average annual precipitation is not anticipated to substantially change in the next 50 to 75 years, precipitation will likely be delivered in more intense storms and over the course of a shorter wet season.9 7 Governor’s Office of Planning and Research, California Energy Commission, and California Natural Resources Agency. California’s Fourth Climate Change Assessment, Sacramento Valley Region Report [page 18]. August 2018. 8 Ibid. 9 Cal-Adapt. Local Climate Change Snapshot for Sacramento, California, Available at: https://caladapt.org/tools/local-climate-change-snapshot. Accessed February 2024.

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Energy Use in the State
California is one of the highest energy demanding states within the nation. According to the U.S.

Department of Energy, the State consumes approximately 303,300 gigawatt-hours (GWh) of electricity per year.10 Activities such as heating and cooling structures, lighting, the movement of goods, agricultural production, and other facets of daily life consume a variety of energy sources.

However, despite California's high rate of energy use, the State has one of the lowest per capita energy consumption levels in the U.S.

Energy within the State is provided primarily to consumers through a mix of sources including natural gas, hydroelectric, non-hydroelectric renewable sources, nuclear, coal, and petroleum.

California is the nation's top producer of electricity from solar, geothermal, and biomass energy.

In 2021, California was the nation’s top producer of electricity from solar, geothermal, and biomass energy. The state was fourth in the nation in conventional hydroelectric power generation, down from second in 2019, in part because of drought and increased water demand.

Renewable resources, including hydropower and small-scale (less than 1-megawatt), customersited solar photovoltaic (PV) systems, supplied more than half of California's in-state electricity generation, and natural gas-fired power plants provided two-fifths.

Figure 4.3-1 presents the sources that are used to produce energy in the State. As presented therein, energy is mostly generated from natural gas combustion, followed by non-hydroelectric renewables (such as wind and solar) and hydroelectric. Figure 4.3-2 presents energy consumption within California for the most recent year for which data is available (2021). As shown in the figure, transportation-related activity consumes the largest single share of energy within the State. The second largest consumer is the industrial sector.

Figure 4.3-1
California Energy Generation by Source
Source: U.S. Energy Information Administration. California: State Profile and Energy Estimates. Accessible at:
https://www.eia.gov/state/index.php?sid=CA. Accessed February 2024. 10 U.S. Department of Energy. State of California Energy Sector Risk Profile. March 2021.

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Figure 4.3-2
California Energy Consumption By Sector
Source: U.S. Energy Information Administration. California: State Profile and Energy Estimates. Accessible at:
https://www.eia.gov/state/index.php?sid=CA. Accessed February 2024.

Of the total electricity supplied to the State in 2022, Sacramento County consumed approximately 11,410 GWh, which constitutes approximately 3.76 percent of the total energy consumed within the State.11

Energy Consumption at the Project Site
Electricity in the project area is currently provided by the Sacramento Municipal Utility District (SMUD), and natural gas is provided by Pacific Gas and Electric (PG&E). However, the project site (including both the industrial park and nonparticipating parcels) is currently undeveloped except for Bayou Way, which winds through the northern portion of the project site. Structures do not exist on-site; however, a cell tower is located in the northwestern portion of the site. As a result, the project site currently generates a minor demand for energy resources.

4.3.3 REGULATORY CONTEXT
Air quality, GHG emissions, and energy consumption are monitored and regulated through the efforts of various international, federal, State, and local government agencies. Agencies work jointly and individually to improve air quality through legislation, regulations, planning, policymaking, education, and a variety of programs. The agencies responsible for regulating and improving the air quality within the project area and monitoring or reducing GHG emissions and energy consumption are discussed below.
11 California Energy Commission. Electricity Consumption by County. Available at:
http://ecdms.energy.ca.gov/elecbycounty.aspx. Accessed February 2024.

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Federal Regulations Related to Air Quality
The following discussion provides a summary of the federal regulations relevant to air quality, organized by pollutant type.

Criteria Pollutants
The FCAA, passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The USEPA is responsible for implementing most aspects of the FCAA, including setting NAAQS for major air pollutants; setting hazardous air pollutant standards; approving state attainment plans; setting motor vehicle emission standards; issuing stationary source emission standards and permits; and establishing acid rain control measures, stratospheric ozone protection measures, and enforcement provisions. Under the FCAA, NAAQS are established for the following criteria pollutants: ozone, CO, NO2, SO2, PM10, PM2.5, and lead.

The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The NAAQS (other than for ozone, NO2, SO2, PM10, PM2.5, and those based on annual averages or arithmetic mean) are not to be exceeded more than once per year.

NAAQS for ozone, NO2, SO2, PM10, PM2.5 are based on statistical calculations over one- to threeyear periods, depending on the pollutant. The FCAA requires the USEPA to reassess the NAAQS at least every five years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation plan that demonstrates how those areas will attain the standards within mandated time frames.

Hazardous Air Pollutants/Toxic Air Contaminants
The 1977 FCAA amendments required the USEPA to identify national emission standards for hazardous air pollutants to protect public health and welfare. Hazardous air pollutants include certain volatile organic chemicals, pesticides, herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to humans and other mammals. Under the 1990 FCAA Amendments, which expanded the control program for hazardous air pollutants, 189 substances and chemical families were identified as hazardous air pollutants.

Federal Regulations Related to GHG Emissions
The following are the federal regulations relevant to GHG emissions.

Federal Vehicle Standards
In 2010, President Obama issued a memorandum directing the Department of Transportation, Department of Energy, USEPA, and National Highway Traffic Safety Administration (NHTSA) to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the USEPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 through 2025 light-duty vehicles. The proposed standards were projected to achieve emission rates as low as 163 grams of CO2 per mile by model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if the foregoing emissions level was achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017 through 2021 (77 FR 62624–63200), and NHTSA intended to set standards for model years 2022 through 2025 in future rulemaking.

In August 2016, the USEPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase Draft EIR
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two program would have applied to vehicles with model years 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all types of sizes of buses and work trucks. The final standards were expected to lower CO2 emissions by approximately 1.1 billion metric tons (MT), and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program.

In August 2018, the USEPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new, less-stringent standards for model years 2021 through 2026. Compared to maintaining the post-2020 standards that were previously in place, the 2018 proposal would increase U.S. fuel consumption by approximately

0.5 million barrels per day, and would impact the global climate by 3/1000th of 1°C by 2100.

California and other states stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures, and committed to cooperating with other countries to implement global climate change initiatives.

On September 27, 2019, the USEPA and NHTSA published the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program (84 FR 51,310), which became effective November 26, 2019. The Part One Rule revokes California’s authority to set its own GHG emissions standards and set zero-emission-vehicle mandates in California. On March 31, 2020, the USEPA and NHTSA issued the Part Two Rule, which sets CO2 emissions standards and corporate average fuel economy standards for passenger vehicles and light-duty trucks for model years 2021 through 2026. On January 20, 2021, an Executive Order (EO) was issued on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, which includes review of the Part One Rule by April 2021 and review of the Part Two Rule by July 2021. In response to the Part One Rule, in December 2021, the U.S. Department of Transportation withdrew its portions of the "SAFE I” rule. As a result, states are now allowed to issue their own GHG emissions standards and zero-emissions vehicle mandates.12 In addition, the Part Two Rule was adopted to revise the existing national GHG emission standards for passenger cars and light trucks through model year 2026. These standards are the strongest vehicle emissions standards ever established for the light-duty vehicle sector and will result in avoiding more than three billion tons of GHG emissions through 2050.13 Federal Regulations Related to Energy
The following are the federal regulations relevant to energy.

Energy Policy and Conservation Act
The Energy Policy and Conservation Act was originally enacted in 1975 with the intention of ensuring that all vehicles sold in the U.S. meet established fuel economy standards. Following congressional establishment of the original set of fuel economy standards the U.S. Department of Transportation was tasked with establishing additional on-road vehicle standards and making revisions to standards as necessary. Compliance with established standards is based on manufacturer fleet average fuel economy, which originally applied to both passenger cars and light trucks but did not apply to heavy-duty vehicles exceeding 8,500 pounds in gross vehicle 12 National Highway Traffic Safety Administration. In Removing Major Roadblock to State Action on Emissions Standards, U.S. Department of Transportation Advances Biden-Harris Administration’s Climate and Jobs Goals.

Available at: https://www.nhtsa.gov/press-releases/cafe-preemption-final-rule. Accessed February 2024. 13 U.S. Environmental Protection Agency. Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026. Available at: https://www.epa.gov/regulationsemissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-emissions. Accessed February 2024.

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weight. The fuel economy program implemented under the Energy Policy and Conservation Act is known as the Corporate Average Fuel Economy (CAFE) Standards. Updates to the CAFE standards since original implementation have increased fuel economy requirements and begun regulation of medium- and heavy-duty vehicles.

Energy Policy Act of 2005
The Energy Policy Act of 2005 addressed energy production in the U.S. from various sources. In particular, the Energy Policy Act of 2005 included tax credits, loans, and grants for the implementation of energy systems that would reduce GHG emissions related to energy production.

State Regulations Related to Air Quality
The following discussion summarizes applicable State regulations related to air quality, organized by pollutant type. Only the most prominent and applicable California air quality-related legislation is included below; however, an exhaustive list and extensive details of California air quality legislation can be found at the CARB website (http://www.arb.ca.gov/html/lawsregs.htm).

Criteria Air Pollutants
The FCAA delegates the regulation of air pollution control and the enforcement of the NAAQS to the states. In California, the task of air quality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB, which became part of the California Environmental Protection Agency in 1991, is responsible for ensuring implementation of the CCAA of 1988, responding to the FCAA, and regulating emissions from motor vehicles and consumer products.

CARB has established CAAQS, which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are continuously below the CAAQS and do not violate the standards more than once each year.

The CAAQS for ozone, CO, SO2 (one-hour and 24-hour), NO2, PM10, PM2.5, and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded.

The NAAQS and CAAQS are presented in Table 4.3-2.

Hazardous Air Pollutants/Toxic Air Contaminants
The State Air Toxics Program was established in 1983 under Assembly Bill (AB) 1807 (Tanner), and involved definition of a list of TACs. The California TAC list identifies more than 700 pollutants, of which carcinogenic and noncarcinogenic toxicity criteria have been established for a subset of these pollutants pursuant to the California Health and Safety Code. The State list of TACs includes the federally-designated hazardous air pollutants. In 1987, the Legislature enacted the Air Toxics “Hot Spots” Information and Assessment Act of 1987 (AB 2588) to address public concern over the release of TACs into the atmosphere. AB 2588 law requires facilities emitting toxic substances to provide local air pollution control districts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hot spots, notification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over five years. TAC emissions from individual facilities are quantified and prioritized. “High-priority” facilities are required to perform a health risk Draft EIR
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assessment, and, if specific thresholds are exceeded, the facility operator is required to communicate the results to the public in the form of notices and public meetings.

CARB Air Quality and Land Use Handbook
CARB’s Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook) addresses the importance of considering health risk issues when siting sensitive land uses, including residential development, in the vicinity of intensive air pollutant emission sources including freeways or high-traffic roads, distribution centers, ports, petroleum refineries, chrome plating operations, dry cleaners, and gasoline dispensing facilities.14 The CARB Handbook draws upon studies evaluating the health effects of traffic traveling on major interstate highways in metropolitan California centers within Los Angeles (Interstate-405 and Interstate-710), the San Francisco Bay, and San Diego areas. The recommendations identified by CARB, including siting residential uses a minimum distance of 500 feet from freeways or other high-traffic roadways, are consistent with those adopted by the State of California for location of new schools. Specifically, the CARB Handbook recommends, “Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day”.15 Importantly, the Introduction chapter of the CARB Handbook clarifies that the guidelines are strictly advisory, recognizing that: “[l]and use decisions are a local government responsibility. The Air Resources Board Handbook is advisory and these recommendations do not establish regulatory standards of any kind.” CARB recognizes that there may be land use objectives as well as meteorological and other site-specific conditions that need to be considered by a governmental jurisdiction relative to the general recommended setbacks, specifically stating, “[t]hese recommendations are advisory. Land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues”.16
Diesel Particulate Matter
In 2000, CARB approved a comprehensive diesel risk reduction plan to reduce diesel emissions, including DPM, from new and existing diesel-fueled vehicles and engines. The regulation was anticipated to result in an 80 percent decrease in statewide diesel health risk by 2020 compared with the diesel risk in 2000. Additional regulations apply to new trucks and diesel fuel, including the On-Road Heavy Duty Diesel Vehicle (In-Use) Regulation, the On-Road Heavy Duty (New) Vehicle Program, the In-Use Off-Road Diesel Vehicle Regulation, and the New Off-Road Compression-Ignition (Diesel) Engines and Equipment program. The aforementioned regulations and programs have timetables by which manufacturers must comply and existing operators must upgrade their diesel-powered equipment. Several Airborne Toxic Control Measures (ATCMs) exist that reduce diesel emissions, including In-Use Off-Road Diesel-Fueled Fleets (13 CCR 2449 et seq.) and In-Use On-Road Diesel-Fueled Vehicles (13 CCR 2025).

Heavy-Duty Diesel Truck and Bus Regulation
CARB adopted the final Heavy-Duty Truck and Bus Regulation, Title 13, Division 3, Chapter 1, Section 2025, on December 31, 2014, to reduce DPM and NOX emissions from heavy-duty diesel vehicles. The rule requires nearly all diesel trucks and buses to be compliant with the 2010 model year engine requirement by January 1, 2023. CARB also adopted an ATCM to limit idling of diesel14 California Air Resources Board. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. 15 Ibid. 16 Ibid.

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fueled commercial vehicles on December 12, 2013. The rule requires diesel-fueled vehicles with gross vehicle weights greater than 10,000 pounds to idle no more than five minutes at any location (13 CCR 2485).

California Health and Safety Code Section 41700
Section 41700 of the Health and Safety Code states that a person must not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public; or that endanger the comfort, repose, health, or safety of any of those persons or the public; or that cause, or have a natural tendency to cause, injury or damage to business or property. Section 41700 also applies to sources of objectionable odors.

Heavy-Duty Vehicle Idling Emission Reduction Program
On October 20, 2005, CARB approved a regulatory measure to reduce emissions of toxics and criteria pollutants by limiting idling of new and in-use sleeper berth equipped diesel trucks.17 The regulation established new engine and in-use truck requirements and emission performance requirements for technologies used as alternatives to idling the truck’s main engine. For example, the regulation requires 2008 and newer model year heavy-duty diesel engines to be equipped with a non-programmable engine shutdown system that automatically shuts down the engine after five minutes of idling, or optionally meet a stringent NOX emission standard. The regulation also requires operators of both in-state and out-of-state registered sleeper berth equipped trucks to manually shut down their engine when idling more than five minutes at any location within California. Emission producing alternative technologies such as diesel-fueled auxiliary power systems and fuel-fired heaters are also required to meet emission performance requirements that ensure emissions are not exceeding the emissions of a truck engine operating at idle.

In-Use Off-Road Diesel Vehicle Regulation
On July 26, 2007, CARB adopted a regulation to reduce DPM and NOX emissions from in-use (existing), off-road, heavy-duty diesel vehicles in California.18 Such vehicles are used in construction, mining, and industrial operations. The regulation is designed to reduce harmful emissions from vehicles by subjecting fleet owners to retrofit or accelerated replacement/repower requirements, imposing idling limitations on owners, operators, renters, or lessees of off-road diesel vehicles. The idling limits require operators of applicable off-road vehicles (self-propelled diesel-fueled vehicles 25 horsepower and up that were not designed to be driven on-road) to limit idling to less than five minutes. The idling requirements are specified in Title 13 of the CCR.

State Regulations Related to GHG Emissions
The statewide GHG emissions regulatory framework is summarized below. The following text describes EOs, legislation, regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues. The following discussion does not include an exhaustive list of applicable regulations; rather, only the most prominent and applicable California legislation related to GHG emissions and climate change is included below. 17 California Air Resources Board. Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling. October 24, 2013. Available at: https://ww2.arb.ca.gov/our-work/programs/atcm-to-limit-vehicle-idling.

Accessed February 2024. 18 California Air Resources Board. In-Use Off-Road Diesel Vehicle Regulation. December 10, 2014. Available at:
http://www.arb.ca.gov/msprog/ordiesel/ordiesel.htm. Accessed February 2024.

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State Climate Change Targets
California has taken a number of actions to address climate change, including EOs, legislation, and CARB plans and requirements, which are summarized below.

Executive Order S-3-05
EO S-3-05 (June 2005) established California’s GHG emissions reduction targets and laid out responsibilities among the State agencies for implementing the EO and for reporting on progress toward the targets. The EO established the following targets:
 By 2010, reduce GHG emissions to 2000 levels;
 By 2020, reduce GHG emissions to 1990 levels; and
 By 2050, reduce GHG emissions to 80 percent below 1990 levels.

EO S-3-05 also directed the California Environmental Protection Agency (CalEPA) to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team was formed, which subsequently issued reports from 2006 to 2010.

Assembly Bill 32
In furtherance of the goals established in EO S-3-05, the Legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive, multi-year program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the State’s long-range climate objectives. AB 32 also required that the CARB prepare a “scoping plan” for achieving the maximum technologically feasible and cost-effective GHG emission reductions by 2020. The CARB’s Scoping Plan is described in further detail below.

Executive Order B-30-15
EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing GHG emissions to 40 percent below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long-term goal of reducing GHG emissions to 80 percent below 1990 levels by 2050 as set forth in EO S-3-05. To facilitate achieving this goal, EO B-30-15 called for an update to the CARB’s Climate Change Scoping Plan: A Framework for Change (Scoping Plan) to express the 2030 target in terms of million metric tons (MMT) CO2e. The CARB’s Scoping Plan is discussed in further detail below. The EO also called for State agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets.

Senate Bill 32 and Assembly Bill 197
Senate Bill (SB) 32 and AB 197 (enacted in 2016) are companion bills. SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, to provide ongoing oversight over implementation of the State’s climate policies. AB 197 also added two members of the Legislature to the Board as non-voting members; requires CARB to make available and update (at least annually via the CARB’s website) emissions data for GHGs, criteria air pollutants, and TACs from reporting Draft EIR
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facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

CARB’s Climate Change Scoping Plan
One specific requirement of AB 32 is for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost-effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the Scoping Plan at least once every five years.

In 2008, CARB approved the first Scoping Plan. The Scoping Plan included a mix of recommended strategies that combined direct regulations, market-based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG emission limit and initiate the transformations needed to achieve the State’s long-range climate objectives. The key elements of the Scoping Plan include the following:

1. Expanding and strengthening existing energy efficiency programs as well as building and appliance standards;

2. Achieving a statewide renewable energy mix of 33 percent;

3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85 percent of California’s GHG emissions;

4. Establishing targets for transportation-related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets;

5. Adopting and implementing measures pursuant to existing State laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard (LCFS) (17 CCR, Section 95480 et seq.); and

6. Creating targeted fees, including a public goods charge on water use, fees on high GWP gases, and a fee to fund the administrative costs of the State’s long-term commitment to AB 32 implementation.

The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclusive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encouraged local governments to adopt a reduction goal for municipal operations and for community emissions to reduce GHGs by approximately 15 percent from 2008 levels by 2020. Many local governments developed community-scale local GHG reduction plans based on this Scoping Plan recommendation.

In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the State’s GHG emission reduction priorities for the next five years and laid the groundwork to start the transition to the post-2020 goals set forth in EO S-3-05 and EO B-16-2012. The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuation of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050, including energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies. As part of the First Update, CARB recalculated the State’s 1990 emissions level using more recent GWPs identified by the IPCC, from 427 MMT CO2e to 431 MMT CO2e.

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In 2015, as directed by EO B-30-15, CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40 percent below 1990 levels by 2030 to keep California on a trajectory toward meeting or exceeding the long-term goal of reducing GHG emissions to 80 percent below 1990 levels by 2050, as set forth in EO S-3-05. In summer 2016, the Legislature affirmed the importance of addressing climate change through passage of SB 32 (Pavley, Chapter 249, Statutes of 2016).

In December 2017, the Scoping Plan was once again updated. The 2017 Scoping Plan built upon the successful framework established in the initial Scoping Plan and First Update, while identifying new, technologically feasible and cost-effective strategies that would serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the State’s climate change priorities to 2030 and beyond. For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 15 percent reduction goal with a recommendation to aim for a communitywide goal of no more than six MTCO2e per capita by 2030, and no more than two MTCO2e per capita by 2050, which are consistent with the State’s long-term goals. The 2017 Scoping Plan recognized the benefits of local government GHG planning (e.g., through Climate Action Plans [CAPs]) and provided more information regarding tools to support those efforts. The 2017 Scoping Plan also recognized the CEQA streamlining provisions for project-level review where a legally adequate CAP exists.

When discussing project-level GHG emissions reduction actions and thresholds in the context of CEQA, the 2017 Scoping Plan stated that “achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development” for project-level CEQA analysis, but also recognized that such a standard may not be appropriate or feasible for every development project. The 2017 Scoping Plan further provided that “the inability of a project to mitigate its GHG emissions to net zero does not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.”
The most recent update to the Scoping Plan, the 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan Update) was adopted by the CARB in December 2022.19 The 2022 Scoping Plan Update builds upon previous efforts to reduce GHG emissions and is designed to continue to shift the California economy away from dependence on fossil fuels. The 2022 Scoping Plan Update, the most comprehensive and far-reaching Scoping Plan developed to date, identifies a technologically feasible and cost-effective path to achieve carbon neutrality by 2045 while also assessing the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 and laid out in the 2017 Scoping Plan. The 2030 target is an interim but important stepping stone along the critical path to the broader goal of deep decarbonization by 2045. The relatively longer path assessed in the Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts to reduce GHGs and air pollution, while identifying new clean technologies and energy. Given the focus on carbon neutrality, the Scoping Plan also includes discussion for the first time of the Natural and Working Lands (NWL) sectors as both sources of emissions and carbon sinks.

The 2022 Scoping Plan Update lays out a path to achieve targets for carbon neutrality and reduce GHG emissions by 85 percent below 1990 levels by 2045, as directed by AB 1279. The actions 19 California Air Resources Board. 2022 Scoping Plan for Achieving Carbon Neutrality. November 16, 2022. Available at: https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents.

Accessed December 2022.

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and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on NWL to reduce emissions and sequester carbon, and the capture and storage of carbon.

CARB’s Regulations for the Mandatory Reporting of GHG Emissions CARB’s Regulation for the Mandatory Reporting of GHG Emissions (17 CCR 95100–95157) incorporated by reference certain requirements that the USEPA promulgated in its Final Rule on Mandatory Reporting of GHGs (40 Code of Federal Regulations [CFR] Part 98). In general, entities subject to the Mandatory Reporting Regulation that emit more than 10,000 MTCO2e per year are required to report annual GHGs through the California Electronic GHG Reporting Tool.

Certain sectors, such as refineries and cement plants, are required to report regardless of emission levels. Entities that emit more than the 25,000 MTCO2e per year threshold are required to have their GHG emission report verified by a CARB-accredited third party.

Senate Bill 1383
SB 1383 establishes specific targets for the reduction of short-lived climate pollutants (SLCPs) (40 percent below 2013 levels by 2030 for CH4 and hydrofluorocarbons (HFCs), and 50 percent below 2013 levels by 2030 for anthropogenic black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, CARB adopted its SLCP Reduction Strategy in March 2017. The SLCP Reduction Strategy establishes a framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.

Executive Order B-55-18/AB 1279
EO B-55-18 (September 2018) establishes a statewide policy for California to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net-negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the State’s GHG emissions. CARB intends to work with relevant State agencies to ensure that future scoping plan updates identify and recommend measures to achieve the carbon neutrality goal.

On September 16, 2022, AB 1279, also known as the California Climate Crisis Act, codified the carbon neutrality goal established by EO B-55-18.

Mobile Sources
The following regulations relate to the control of GHG emissions from mobile sources. Mobile sources include both on-road vehicles and off-road equipment.

Assembly Bill 1493
AB 1493 (Pavley) (July 2002) was enacted in response to the transportation sector accounting for more than half of California’s CO2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the State board to be vehicles that are primarily used for non-commercial personal transportation in the State. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. When fully phased in, the near-term (2009–2012) standards would result in a reduction of approximately 22 percent of GHG emissions compared to the emissions from the 2002 fleet, and the mid-term (2013–2016) standards would result in a reduction of approximately 30 percent.

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Senate Bill 375
SB 375 (Steinberg) (September 2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 requires CARB to adopt regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035, and to update those targets every eight years. SB 375 requires the State’s 18 regional metropolitan planning organizations to prepare a sustainable communities strategy as part of their Regional Transportation Plans that will achieve the GHG reduction targets set by CARB. If a metropolitan planning organization is unable to devise a sustainable communities strategy to achieve the GHG reduction target, the metropolitan planning organization must prepare an alternative planning strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), a sustainable communities strategy does not (1) regulate the use of land, (2) supersede the land use authority of cities and counties, or (3) require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with the sustainable community strategy. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the State-mandated housing element process.

Advanced Clean Cars Program and Zero-Emissions Vehicle Program The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB has implemented new emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles. By 2025, implementation of the rule is anticipated to reduce emissions of smog-forming pollution from cars by 75 percent compared to the average new car sold in 2015. To reduce GHG emissions, CARB, in conjunction with the USEPA and NHTSA, adopted GHG standards for model year 2017 to 2025 vehicles; the standards were estimated to reduce GHG emissions by 34 percent by 2025. The zero-emissions vehicle program acts as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce increasing numbers of zero-emissions vehicles and plug-in hybrid electric vehicles in the 2018 to 2025 model years.

Executive Order B-16-12
EO B-16-12 (March 2012) required that State entities under the governor’s direction and control support and facilitate the rapid commercialization of zero-emissions vehicles. The order directed CARB, California Energy Commission (CEC), California Public Utilities Commission (CPUC), and other relevant agencies to work with the Plug-In Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve goals by 2015, 2020, and 2025.

On a statewide basis, EO B-16-12 established a target reduction of GHG emissions from the transportation sector equaling 80 percent less than 1990 levels by 2050. EO B-16-12 did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare.

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Assembly Bill 1236
AB 1236 (October 2015) (Chiu) required a city, county, or city and county to approve an application for the installation of electric-vehicle (EV) charging stations, as defined, through the issuance of specified permits unless the city or county makes specified written findings based on substantial evidence in the record that the proposed installation would have a specific, adverse impact upon the public health or safety, and a feasible method to satisfactorily mitigate or avoid the specific, adverse impact does not exist. The bill provided for appeal of that decision to the planning commission, as specified. AB 1236 required EV charging stations to meet specified standards. The bill required a city, county, or city and county with a population of 200,000 or more residents to adopt an ordinance, by September 30, 2016, that created an expedited and streamlined permitting process for EV charging stations. The bill also required a city, county, or city and county with a population of less than 200,000 residents to adopt the ordinance by September 30, 2017.

Water
The following regulations relate to the conservation of water, which reduces GHG emissions related to electricity demands from the treatment and transportation of water.

Executive Order B-29-15
In response to a drought in California, EO B-29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25 percent relative to water use in 2013. The term of the EO extended through February 28, 2016, although many of the directives subsequently became permanent water-efficiency standards and requirements. The EO includes specific directives that set strict limits on water usage in the State. In response to EO B-29-15, the California Department of Water Resources modified and adopted a revised version of the Model Water Efficient Landscape Ordinance (MWELO) that, among other changes, significantly increases the requirements for landscape water use efficiency, and broadens the applicability of the ordinance to include new development projects with smaller landscape areas.

Solid Waste
The following regulations relate to the generation of solid waste and means to reduce GHG emissions from solid waste produced within the State.

Assembly Bill 939 and Assembly Bill 341
In 1989, AB 939, known as the Integrated Waste Management Act (California Public Resources Code [PRC] Sections 40000 et seq.), was passed because of the observed increase in waste stream and the decrease in landfill capacity.

AB 341 (Chapter 476, Statutes of 2011 [Chesbro]) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that the policy goal of the State is that not less than 75 percent of solid waste generated be source-reduced, recycled, or composted by 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery to develop strategies to achieve the State’s policy goal.

Other State Actions
The following State regulations are broadly related to GHG emissions.

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Senate Bill 97
SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research (OPR) to develop guidelines under CEQA for the mitigation of GHG emissions. In 2008, the Governor’s OPR issued a technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those associated with vehicular traffic, energy consumption, water usage, and construction activities. The advisory further recommended that the lead agency determine the significance of the impacts and impose all mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The California Natural Resource Agency (CNRA) adopted the CEQA Guidelines amendments in December 2009, and the amended CEQA Guidelines became effective in March 2010.

Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis, or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR 15064.4[a]). The CEQA Guidelines require a lead agency to consider the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The CEQA Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features or off-site measures. The adopted amendments do not establish a GHG emission threshold, instead allowing a lead agency to develop, adopt, and apply the lead agency’s own thresholds of significance or those developed by other agencies or experts. CNRA acknowledges that a lead agency may consider compliance with regulations or requirements implementing AB 32 in determining the significance of a project’s GHG emissions.

With respect to GHG emissions, the CEQA Guidelines state that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions (14 CCR 15064.4[a]). The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on “qualitative analysis or other performance-based standards” (14 CCR 15064.4[a]).

Section 15064.4(b) states that the lead agency should consider the following when assessing the significance of impacts from GHG emissions on the environment: (1) the extent to which a project may increase or reduce GHG emissions as compared to the existing environmental setting; (2) whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and (3) the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).

Executive Order S-13-08
EO S-13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change, particularly sea-level rise. Therefore, the EO directs State agencies to take specified actions to assess and plan for such impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009, and an update, Safeguarding California: Reducing Climate Risk, followed in July 2014. To assess the State’s vulnerability, the report summarizes key climate change impacts to the State for the following areas: agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water. Issuance of the Safeguarding California: Implementation Action Plans followed in March 2016. In January 2018, the CNRA Draft EIR
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released the Safeguarding California Plan: 2018 Update, which communicates current and needed actions that the State government should take to build climate change resiliency.

State Regulations Related to Energy
The primary State regulatory agencies governing energy consumption are the CEC and the CPUC.

The CEC, created by the Legislature in 1974, has seven major responsibilities: forecasting future energy needs; promoting energy efficiency and conservation by setting the State’s appliance and building energy efficiency standards; supporting energy research that advances energy science and technology through research, development, and demonstration projects; developing renewable energy resources; advancing alternative and renewable transportation fuels and technologies; certifying thermal power plants 50 MW and larger; and planning for and directing State response to energy emergencies.20
The CPUC regulates privately owned electric, natural gas, telecommunications, water, railroad, rail transit, and passenger transportation companies. The CPUC is responsible for ensuring that customers have safe, reliable utility service and infrastructure at reasonable rates, regulating utility services, stimulating innovation, and promoting competitive markets.21 The State has adopted various regulations aimed at reducing energy consumption, increasing energy efficiency, and mandating sourcing requirements for electricity production. The following regulations are applicable to the proposed project.

Building Energy
The following regulations relate to energy efficiency and energy use reductions in the built environment.

Title 24, Part 6
Title 24 of the CCR, which is known as the California Building Standards Code (CBSC), was established in 1978 and serves to enhance and regulate California’s building standards. While not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality.

These energy efficiency standards are reviewed periodically, and revised, if necessary, by the Building Standards Commission and CEC (PRC Section 25402[b][1]). The regulations receive input from members of industry, as well as the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). The regulations are scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, the standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2022 Title 24 standards are the currently applicable building energy efficiency standards and became effective on January 1, 2023. Compliance with the 2022 Title 24 Building Energy 20 California Energy Commission. About the California Energy Commission. Available at:
http://www.energy.ca.gov/about. Accessed February 2024. 21 California Public Utilities Commission. California Public Utilities Commission. Available at:
https://www.cpuc.ca.gov/about-cpuc. Accessed February 2024.

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Efficiency Standards will reduce energy use and associated GHG emissions compared to structures built in compliance with the previous 2019 Title 24 standards.

Title 24, Part 11
In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen, and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, industrial, low-rise residential and State-owned buildings and schools and hospitals. The original CALGreen standards have been updated several times. The CALGreen 2022 standards, which are the current standards, improved upon the 2019 CALGreen standards, and went into effect on January 1, 2023. The 2022 CALGreen Code focuses on four key areas in newly constructed homes and businesses:22  Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units.  Establishing electric-ready requirements for single-family homes to position owners to use cleaner electric heating, cooking and EV charging options whenever they choose to adopt those technologies.
 Expanding solar PV system and battery storage standards to make clean energy available onsite and complement the state’s progress toward a 100 percent clean electricity grid.  Strengthening ventilation standards to improve indoor air quality.

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 reduction, and cool/solar-reflective roofs.

Title 20
Title 20 of the CCR requires manufacturers of appliances to meet State and federal standards for energy and water efficiency. The CEC certifies an appliance based on a manufacturer’s demonstration that the appliance meets the standards. New appliances regulated under Title 20 include refrigerators, refrigerator-freezers, and freezers; room air conditioners and room airconditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low-voltage dry-type distribution transformers; power supplies; 22 California Energy Commission. Energy Commission Adopts Updated Building Standards to Improve Efficiency, Reduce Emissions From Homes and Businesses. Available at: https://www.energy.ca.gov/news/2021-08/energycommission-adopts-updated-building-standards-improve-efficiency-reduce-0. Accessed February 2024.

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televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing each type of appliance covered under the regulations, and appliances must meet the standards for energy performance, energy design, water performance, and water design. Title 20 contains three types of standards for appliances: federal and State standards for federally regulated appliances, State standards for federally regulated appliances, and State standards for non-federally regulated appliances.

Senate Bill 1
SB 1 (Murray) (August 2006) established a $3 billion rebate program to support the goal of the State to install rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the PRC, including Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer-funded incentives for PV systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a goal of the State to establish a self-sufficient solar industry. The goals included establishing solar energy systems as a viable mainstream option for homes and businesses within 10 years of adoption, and placing solar energy systems on 50 percent of new homes within 13 years of adoption. SB 1, also termed “Go Solar California,” was previously titled “Million Solar Roofs.” Assembly Bill 1109
Enacted in 2007, AB 1109 required the CEC to adopt minimum energy efficiency standards for general-purpose lighting to reduce electricity consumption by 50 percent for indoor residential lighting and by 25 percent for indoor commercial lighting.

Climate Change Scoping Plan
Expanding and strengthening existing energy efficiency programs as well as building and appliance standards is the key element of the Scoping Plan, as introduced above, related to building energy.

Transportation/Fuel Energy
The following regulations relate to fuel efficiency and energy use reductions in the transportation and motorized vehicle sector.

Assembly Bill 1493
In 2002 California adopted AB 1493, also known as the Pavley I standards, which required new passenger vehicles with model years 2009 to 2016 to meet more stringent fuel efficiency standards. Additional laws have extended these rules to cover vehicles from future model years.

Executive Order S-1-07
EO S-1-07, otherwise known as the LCFS, was adopted in 2009 and requires transportation fuels such as gasoline and diesel sold within the state to be less carbon intensive. These policies reduce emissions from on-road transportation and off-road equipment use in the City of Sacramento.

Executive Order B-16-12
EO B-16-12 (March 2012) required that State entities under the governor’s direction and control support and facilitate the rapid commercialization of zero-emissions vehicles. The order directed CARB, CEC, CPUC, and other relevant agencies to work with the Plug-In Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve Draft EIR
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goals by 2015, 2020, and 2025. On a statewide basis, EO B-16-12 established a target reduction of GHG emissions from the transportation sector equaling 80 percent less than 1990 levels by 2050. EO B-16-12 did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare.

Assembly Bill 1346
AB 1346 (October 2021) prohibits the sale of new non-electric small off-road engines. Small offroad engines, which are used primarily in lawn and garden equipment, emit high levels of air pollutants and, in 2020, California daily criteria pollutant emissions from small off-road engines were higher than emissions from light-duty passenger cars. Thus, by January 1, 2024, regulations shall prohibit engine exhaust and evaporative emissions from new small off-road engines.

Senate Bill 500
SB 500 (September 2021) requires that, beginning January 1, 2030, to the extent allowed by federal law, any autonomous vehicle that is model year 2031 or later, has a gross vehicle weight rating of less than 8,501 pounds, and is equipped with Level 3, 4, or 5 automation (as defined by the International Society of Automotive Engineers) to be a zero-emission vehicle to be operated on California public roads.

Climate Change Scoping Plan
The key elements of the Scoping Plan, as introduced above, related to transportation energy include the following:

1. Establishing targets for transportation-related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets; and

2. Adopting and implementing measures pursuant to existing State laws and policies, including California’s clean car standards, goods movement measures, and the LCFS (17 CCR, Section 95480 et seq.).

Renewable Energy and Energy Procurement
The following regulation relates to the source of electricity provided to consumers within the State, as well as standards related to the generation of electricity within the State.

Renewable Portfolio Standard, Senate Bill 350, and Senate Bill 100 Established in 2002 under SB 1078, accelerated in 2006 under SB 107, and expanded in 2011 under SB 2, California's Renewable Portfolio Standard (RPS) is one of the most ambitious renewable energy standards in the country. The RPS program requires investor-owned utilities, electric service providers, and community choice aggregators to increase procurement from eligible renewable energy resources to 33 percent of total procurement by 2020.

Since the inception of the RPS program, the program has been extended and enhanced multiple times. In 2015, SB 350 extended the State’s RPS program by requiring that publicly owned utilities procure 50 percent of their electricity from renewable energy sources by 2030. The requirements of SB 350 were expanded and intensified in 2018 through the adoption of SB 100, which mandated that all electricity generated within the State by publicly owned utilities be generated through carbon-free sources by 2045. In addition, SB 100 increased the previous renewable energy requirement for the year 2030 by 10 percent; thus, requiring that 60 percent of electricity generated by publicly owned utilities originate from renewable sources by the year 2030.

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Local Regulations
The most prominent local regulations related to air quality, GHG emissions, and energy are established by the SMAQMD and the City of Sacramento General Plan, and are discussed in further detail below.

Sacramento Metropolitan Air Quality Management District The SMAQMD regulates many sources of pollutants in the ambient air as well as GHG emissions, and is responsible for implementing certain programs and regulations for controlling air pollutant and GHG emissions to improve air quality in order to attain federal and State AAQS and reduce GHG emissions in compliance with State goals.

Air Quality Attainment Plan
As a part of the SVAB federal ozone nonattainment area, the SMQAMD works with the other local air districts within the Sacramento area to develop a regional air quality management plan under the FCAA requirement. The regional air quality management plan is called the State Implementation Plan (SIP) which describes and demonstrates how Sacramento County, as well as the Sacramento nonattainment area, would attain the required federal ozone standard by the proposed attainment deadline. In accordance with the requirements of the FCAA, the SMQAMD, along with the other air districts in the region, prepared the Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan (Ozone Attainment Plan) in December 2008.

The CARB determined that the Ozone Attainment Plan met FCAA requirements and approved the Plan on March 26, 2009 as a revision to the SIP. An update to the plan, 2017 Revisions to the Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan (2017 Ozone Attainment Plan), was prepared and adopted by CARB on November 16, 2017. An additional update to the plan was prepared and adopted by CARB on October 15, 2018, and known as the 2018 Updates to the California State Implementation Plan.

The Ozone Attainment Plan, and subsequent updates, demonstrate how existing and new control strategies would provide the necessary future emission reductions to meet the FCAA requirements, including the NAAQS. It should be noted that in addition to strengthening the 8- hour ozone NAAQS, the USEPA also strengthened the secondary 8-hour ozone NAAQS, making the secondary standard identical to the primary standard. The SVAB remains classified as a severe nonattainment area for ozone with an attainment deadline of 2027. On October 26, 2015, the USEPA released a final implementation rule for the revised NAAQS for ozone to address the requirements for reasonable further progress, modeling and attainment demonstrations, and reasonably available control measures (RACM) and reasonably available control technology (RACT). The USEPA published designations for areas in attainment/unclassifiable for the 2015 ozone standards. The USEPA identified the entire Sacramento County as nonattainment for the 2015 ozone standards.23
City of Sacramento 2040 General Plan
The following goals and policies related to air quality are from the City of Sacramento 2040 General Plan:
23 U.S. Environmental Protection Agency. Nonattainment and Unclassifiable Area Designations for the 2015 Ozone Standards. April 30, 2018.

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Environmental Resources and Constraints Element
Goal ERC-4 Collaborative action to address air pollution.

Policy ERC-4.2 Air Quality Awareness. The City shall cooperate with the Sacramento Metropolitan Air Quality Management District (SMAQMD), Sacramento Area Council of Governments
(SACOG), Sacramento Municipal Utility District (SMUD), and other groups to promote public access to air quality monitoring data and awareness about impacts of indoor and outdoor air quality on health and protective strategies.

Policy ERC-4.3 Project Design. The City shall promote the incorporation of new technologies, materials, and design and construction techniques in private development projects that minimize air pollution, noise, excess heat, and other forms of pollution and its impacts.

Policy ERC-4.4 Sensitive Uses. The City shall consult, as appropriate, with the Sacramento Metropolitan Air Quality Management District (SMAQMD) in evaluating exposure of sensitive receptors to toxic air contaminants, and will impose conditions, as
appropriate, on projects to protect public health and safety.

Policy ERC-4.5 Construction Emissions. The City shall ensure that construction and grading activities minimize short-term impacts to air quality by employing appropriate measures and best practices. Refer to Basic Construction Emissions Control Practices (BMPs) recommended by the Sacramento
Metropolitan Air Quality Management District (SMAQMD).

Policy ERC-4.6 Gas-Powered Landscaping Equipment. The City shall encourage alternatives to gas- powered landscaping equipment that would reduce exposure to air and sound pollution caused by the use of these machines.

Policy ERC-4.7 Operational Emissions. The City shall require development projects that exceed Sacramento Metropolitan Air Quality Management District (SMAQMD) reactive organic gas (ROG) and nitrogen oxide (NOX) operational thresholds to incorporate design or operational features that reduce emissions equal to 15 percent from the level that would be produced by an
unmitigated project.

Environmental Justice Element
Goal EJ-1 Clean air, water, and soil with no segment of the community disproportionately burdened by environmental conditions.

Policy EJ-1.4 Impact Assessment. The City shall continue to use the Sacramento Metropolitan Air Quality Management District Draft EIR
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(SMAQMD) modeling tools and guidance documents, as
appropriate, to identify and mitigate air quality impacts from proposed development projects.

Youth, Parks, Recreation, and Open Space
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-1.19 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.

Policy YPRO-1.20 Climate-Resilient Design. The City shall ensure that the design of parks and open spaces balance climate-adaptive design, such as resilient landscaping in place of impervious surfaces, climate-adaptive tree canopy, shade structures, drinking fountains, and cooling amenities, such as water spray areas, that provide respite from higher temperatures to reduce urban heat islands and overexposure to heat.

City of Sacramento Climate Action and Adaptation Plan
On February 27, 2024, the City adopted the 2040 General Plan and Climate Action & Adaptation Plan (CAAP). The CAAP builds off the City’s previously adopted (2012) Climate Action Plan (CAP), the City’s Climate Emergency Declaration of 2019, and incorporates recommendations from the Mayors’ Commission on Climate Change. The CAAP sets new targets for the City which exceed the GHG reduction requirements established by SB 32, and identifies key strategies and actions that form the foundation of Sacramento’s goal of achieving carbon neutrality by 2045, consistent with the goals of the 2022 Scoping Plan. The City’s CAAP serves as a Qualified GHG Reduction Strategy under Section 15183.5 of the CEQA Guidelines, simplifying development review for new projects that are consistent with the CAAP. The Sacramento CAAP includes GHG emission reduction targets, strategies, and implementation measures developed to help the City reach the emission reduction targets. Reduction strategies address GHG emissions associated with the built environment (energy and electrification), mobility, waste, water and wastewater, and carbon sequestration.

4.3.4 IMPACTS AND MITIGATION MEASURES
The standards of significance and methodology used to analyze and determine the proposed project’s potential project-specific impacts related to air quality and GHG emissions are described below. In addition, a discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

Standards of Significance
Based on the recommendations of SMAQMD, and consistent with Appendix G of the CEQA Guidelines, the effects of a project are evaluated to determine if they would result in a significant adverse impact on the environment. For the purposes of this EIR, an impact is considered significant if the proposed project would:

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 Conflict with or obstruct implementation of the applicable air quality plan;  Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors);
 Expose sensitive receptors to substantial pollutant concentrations (including localized CO concentrations and TAC emissions);
 Result in other emissions (such as those leading to odors) affecting a substantial number of people;
 Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources;
 Conflict with or obstruct a state or local plan for renewable energy or energy efficiency;  Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
 Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.

Criteria Pollutant Emissions and TAC Emissions
In order to evaluate criteria air pollutant emissions from development projects, SMAQMD has established significance thresholds for emissions of NOX, ROG, PM10, and PM2.5. The significance thresholds serve as air quality standards in the evaluation of air quality impacts associated with proposed development projects. Thus, if the proposed project’s emissions exceed the SMAQMD thresholds, the project could have a significant effect on regional air quality and attainment of federal and State AAQS. The SMAQMD’s recommended thresholds of significance are listed in Table 4.3-6.

The City of Sacramento, as the CEQA Lead Agency for the proposed project, has formally adopted the SMAQMD’s thresholds of significance. Therefore, if the proposed project’s emissions exceed the pollutant thresholds presented in Table 4.3-6, the project could have a significant effect on air quality, the attainment of federal and State AAQS, and could conflict with or obstruct implementation of the applicable air quality plan.

With regard to other cumulative emissions, such as the cumulative emissions of criteria air pollutants, the SMAQMD directs lead agencies to use the region’s existing attainment plans as a basis for analysis of cumulative emissions. If a project would interfere with an adopted attainment plan, the project would inhibit the future attainment of AAQS, and thus result in a significant incremental contribution to cumulative emissions. As discussed throughout this document, the SMAQMD’s recommended thresholds of significance for ozone precursors and PM10 are based on attainment plans for the region. Thus, SMAQMD concluded that if a project’s ozone precursor and PM10 emissions would be less than the associated thresholds, the project would not be expected to conflict with any relevant attainment plans, and would not result in a cumulatively considerable contribution to a significant cumulative impact. As a result, the operational phase cumulative-level emissions thresholds established by SMAQMD are identical to the project-level operational emissions thresholds; the operational/cumulative thresholds for criteria pollutants are presented in Table 4.3-6.

For TAC emissions, if a project would introduce a new source of TAC or a new sensitive receptor near an existing source of TAC that would not meet the CARB’s minimum recommended setback, a detailed health risk assessment may be required. To assess the potential impacts of TACs, the Draft EIR
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SMAQMD maintains thresholds of significance for the review of local community risk and hazard impacts.

Table 4.3-6
SMAQMD Thresholds of Significance
Pollutant Construction Threshold Operational Threshold
NOX 85 lbs/day 65 lbs/day
ROG -1 65 lbs/day
PM10 80 lbs/day and 14.6 tons/yr
2 80 lbs/day and 14.6 tons/yr3
PM2.5 82 lbs/day and 15 tons/yr2 82 lbs/day and 15 tons/yr3 1 The application of architectural coatings is typically the largest source of ROG emissions during construction activity. SMAQMD addresses construction-related emissions of ROG through the implementation of Rule 442, which regulates ROG emissions from architectural coatings. Therefore, SMAQMD has not adopted a threshold for construction-related ROG emissions. 2 The identified construction thresholds of significance for PM10 and PM2.5 are only applicable when all feasible construction Best Management Practices (BMPs) are applied. The SMAQMD’s construction BMPs are also known as Basic Construction Emission Control Practices. (SMAQMD, Basic Construction Emission Control Practices (Best Management Practices), July 2019) 3 The identified operational thresholds of significance for PM10 and PM2.5 are only applicable when all feasible operational BMPs and Best Available Control Technologies (BACTs) are applied. The implementation of BACTs apply only to stationary source operational emissions. (SMAQMD, Operational Best Management Practices for PM from Land Use Development Projects, October 2020)
Source: SMAQMD Thresholds of Significance Table, April 2020.

The thresholds are designed to assess the impact of new sources of TACs on existing sensitive receptors. Based on the SMAQMD thresholds, the proposed project would result in a significant impact related to TACs if nearby sensitive receptors would experience an increased cancer risk of greater than or equal to 10 in one million people, or experience a chronic or acute hazard index of greater than or equal to 1.0.24 Neither SMAQMD nor the City have established quantitative thresholds of significance for construction-related TAC emissions GHG Emissions
Nearly all development projects in the region have the potential to generate air pollutants that may increase global climate change. SMAQMD has adopted thresholds of significance for GHG emissions during construction and operations of projects. This GHG analysis has been prepared to show compliance with SMAQMD’s GHG thresholds of significance.

For construction-related GHG emissions, the SMAQMD has adopted a threshold of significance of 1,100 MTCO2e/yr. If construction of the proposed project would result in emissions that exceed 1,100 MTCO2e/yr, then construction of the project could be considered to result in a potentially significant impact and mitigation measures would be required.

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 implementation of the Tier 1 measures, then the project is required to implement Tier 2 measures (BMP 3). The Tier 1 and Tier 2 requirements are explained in further detail below. 24 Sacramento Metropolitan Air Quality Management District. Guide to Air Quality Assessment in Sacramento County: Toxic Air Contaminants. April 2020.

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Tier 1
All projects within SMAQMD’s jurisdiction would be required to comply with the Best Management Practices (BMPs) included in Tier 1. The proposed Tier 1 BMPs are as follows:
 BMP 1: No natural gas: Projects shall be designed and constructed without natural gas infrastructure.
 BMP 2: Electric vehicle (EV) ready: Projects shall meet the current CALGreen Tier 2 standards, except all EV Capable spaces shall instead be EV Ready.

If a project would not comply with both of the foregoing BMPs, the project would be required to include features that would achieve an equivalent level of GHG emissions reductions. For instance, a project that includes natural gas infrastructure may include pre-wiring to allow for the future retrofit of all natural gas appliances with all-electric appliances. After implementation of BMPs 1 and 2, if a project’s operational emissions would be at or below 1,100 MTCO2e/yr, the operational emissions would be considered less than significant. Projects that would still result in emissions in excess of 1,100 MTCO2e/yr after implementation of BMPs 1 and 2 are subject to review under Tier 2 of SMAQMD’s thresholds.

Furthermore, projects that are below the Governor’s OPR’s de minimis vehicle miles travelled (VMT) criteria, and/or projects that emit less than 1,100 MTCO2e/yr prior to implementation of BMP 1 and BMP 2 would be considered sufficiently small to screen out of further requirements, and would be assumed to result in a less-than-significant impact related to GHG emissions and climate change. The following types of projects would be considered to be below the OPR’s de minimis VMT criteria:
 Small projects that generate or attract fewer than 110 trips per day;  Residential and office projects in areas with low VMT (currently below threshold VMT) that incorporate similar features (i.e., density, mix of uses, transit accessibility), including affordable housing infill development; or
 Residential, retail, office, or mixed-use projects within 0.5-mile walking distance of an existing major transit stop or existing stop along a high-quality transit corridor, unless the primary use of the site is auto-oriented (e.g., car dealership, car wash, gas station).

It is noted, however, that all projects within the jurisdiction of SMAQMD are required to implement the Tier 1 measures, even if the project qualifies for screening using the OPR’s de minimis VMT criteria.

Tier 2
The second tier of SMAQMD’s thresholds includes the following BMP:
 BMP 3: Residential projects shall achieve a 15 percent reduction in VMT per resident, and office projects should achieve a 15 percent reduction in VMT per worker compared to existing average VMT per capita for the county, or for the city if a more local SB 743 target has been established. VMT reductions can be achieved by many strategies, such as:
o Locate in an area that already has low VMT due to location, transit service, etc.; o Adopt CAPCOA measures;
o Adopt measures noted in Sacramento’s CAAP checklist;
o Join a Transportation Management Association;
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o Incorporate traffic calming measures;
o Incorporate pedestrian facilities and connections to public transportation; and/or o Promote electric bicycle or other micro-mobility options.

Pursuant to the Tier 2 requirement, if a project can successfully achieve a 15 percent reduction in VMT or meet the requirements of an established local SB 743 target, then impacts associated with operational GHG emissions are considered less than significant.

If a project cannot incorporate any of the foregoing BMPs, other reductions or purchasing and retiring of GHG/carbon offsets can be used as an alternative method of compliance. Given that the developer demonstrates that the alternative method(s) of compliance would achieve the same reductions as those required by BMPs 1 through 3, the project can be considered to result in a less-than-significant impact related to operational GHG emissions.

In accordance with CARB and SMAQMD recommendations, the City of Sacramento uses the currently adopted SMAQMD GHG thresholds of significance, as presented above, as well as compliance with the City’s CAAP. 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.

Energy
Quantitative thresholds for the analysis of potential impacts related to energy consumption have not been adopted by any local, regional, or statewide entities. Consequently, potential impacts of the project related to energy will be determined based on whether the project would result in wasteful, inefficient, or unnecessary use of energy. In addition, the potential for the project to conflict with or obstruct a state or local plan for renewable energy generation or energy efficiency will be considered. The analysis of energy consumption will include consideration of energy demand during both project construction and operations.

Method of Analysis
The analysis protocol and guidance provided by the SMAQMD’s CEQA Guide, including screening criteria and pollutant thresholds of significance, was used to analyze the proposed project’s air quality impacts.

Construction Emissions
The proposed project’s short-term construction emissions were estimated using the California Emissions Estimator Model (CalEEMod) version 2020.4.0 software, which is a statewide model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify air quality emissions from land use projects. The model applies inherent default values for various land uses, including trip generation rates based on the Institute of Transportation Engineers (ITE) Manual, vehicle mix, trip length, average speed, etc.

Where project-specific information is available, such information should be applied in the model.

Construction emissions were modeled under two scenarios: the Proposed Project Scenario (i.e., Draft EIR
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development of the industrial park) and the Full Buildout of the Annexation Area Scenario (i.e., development of the industrial park and nonparticipating parcels).

The construction modeling for the Proposed Project Scenario assumes the following based on applicant-provided project-specific data:
 Construction would begin in the year 2023;25
 Construction would occur over an approximately six-year period; and  Approximately 304,000 cubic yards of soil would be imported during grading.

The construction modeling for the Full Buildout of the Annexation Area Scenario assumes the following based on applicant-provided project-specific data:
 Construction would begin in the year 2023;
 Construction would occur over an approximately ten-year period; and  Approximately 304,000 cubic yards of soil would be imported during grading.

In addition, RoadMod was used to model construction of the longest, and, therefore, worst-case off-site sewer force main (Option 2), as described in Chapter 3, Project Description, of this EIR.

RoadMod requires the user to input information related to the area of disturbance and the length of time a project would occur. Construction of the proposed off-site force main was assumed to begin in 2023. The force main was assumed to be approximately 2.32 miles long and 48-inches wide, and was assumed to be constructed over a one-month period.

The results of construction emissions estimations were compared to the standards of significance discussed above in order to determine the associated level of impact. All CalEEMod modeling results are included in Appendix C to this EIR.

Operational Emissions and Operational Energy Use
The proposed project’s operational emissions were estimated using CalEEMod, and were modeled for both the Proposed Project Scenario and Full Buildout of the Annexation Area Scenario. Based on project-specific information provided by the project applicant, the proposed project is anticipated to be fully operational by 2029 for the Proposed Project Scenario and 2033 for the Full Buildout of the Annexation Area Scenario. The modeling performed for the proposed project included compliance with SMAQMD rules and regulations as well as with the California Building Energy Efficiency Standards Code, which is part of the CBSC. The proposed project’s compliance with such would be verified as part of the City’s building approval review process. In addition, DKS provided project-specific trip generation rates and VMT data, which were applied to the project modeling for both scenarios. In addition, the project was assumed to comply with the MWELO under both project scenarios. Finally, the modeling for the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario assumed that diesel forklifts would operate on the project site during project operations.

It should also be noted that emissions associated with heavy-duty trucks travelling to and from the project site were calculated off-model using project-specific trip generation rates provided by 25 It is noted that when the air quality analysis was conducted, project construction was anticipated to commence in 2023. While this is no longer the case, the analysis conducted for this EIR is conservative because construction fleets and electricity generation are becoming more efficient over time due to state regulations; thus, modeling construction at an earlier start date provides a more conservative analysis.

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DKS, trip length data provided by Fehr and Peers for the Metro Air Park Project located just north of the project site, and vehicle emission factors from the CARB’s mobile source emissions inventory (EMFAC2021) model. Consistent with the Travel Behavior Memorandum prepared by Fehr and Peers for the Metro Air Park Project, an average length of 44.80 miles was assumed for heavy truck trips.26 EMFAC2021 was used to calculate all mobile-sourced emissions associated with heavy-duty vehicles.

The estimated emissions from CalEEMod and EMFAC2021 were added together to represent total project emissions, and were compared to the standards of significance discussed above in order to determine the associated level of impact. All CalEEMod results and EMFAC2021 calculations are included in Appendix C to this EIR.

Operational Health Risk Assessment
In order to assess the health risk impacts of DPM emissions from heavy-duty trucks travelling to and from the project site on nearby sensitive receptors, first, the number of estimated dieselfueled vehicles associated with the proposed project was determined using truck volumes provided by DKS. Next, the rate of DPM emissions for heavy-duty trucks travelling at the speed limit of the local roadway segments was obtained through the CARB’s EMission FACtors (EMFAC2021 v1.0.2) database.27 EMFAC provides the rate of PM2.5 emissions, in grams per mile, for each vehicle category. By applying the foregoing data, the total grams of DPM that would be emitted by diesel-fueled vehicles traveling along the roadway segments closest to the project site was calculated. It should be noted that DPM is considered a subset of PM2.5 emissions. Thus, the estimated concentration of PM2.5 was used as a conservative proxy to represent emissions of DPM.

DPM concentrations resulting from project implementation were estimated using the American Meteorological Society/Environmental Protection Agency (AMS/EPA) Regulatory Model (AERMOD). The associated cancer risk and non-cancer hazard index were calculated using the CARB’s Hotspot Analysis Reporting Program Version 2 (HARP 2) Risk Assessment Standalone Tool (RAST), which calculates the cancer and non-cancer health impacts using the risk assessment guidelines of the 2015 OEHHA Guidance Manual for Preparation of Health Risk Assessments.28 The modeling was performed in accordance with the USEPA’s User’s Guide for the AERMOD29 and the 2015 OEHHA Guidance Manual.

Although pollutant concentrations at all nearby receptors were estimated, for the purpose of determining potential health risks, only the highest estimated pollutant concentrations were used in calculating cancer risk and hazard indices. The receptor experiencing the highest estimated pollutant concentrations was considered to be the maximally exposed receptor, and would experience the highest potential health risks. Health risks to all other receptors would be lower than the health risks to the maximally exposed receptor, because all other receptors would be exposed to lower concentrations of heavy-duty truck-related pollutants as compared to the maximally exposed receptor.
26 Fehr & Peers. Metro Air Park Travel Behavior Data. February 18, 2022. 27 California Air Resources Board. EMFAC Emissions Inventory. Available at https://arb.ca.gov/emfac/emissionsinventory/84f774a613b49d07f7fe9d750d9d00c86d945fb5. Accessed February 2024. 28 Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots Program Risk Assessment Guidelines, Guidance Manual for Preparation of Health Risk Assessments [pg. 8-18]. February 2015. 29 U.S. Environmental Protection Agency. User’s Guide for the AMS/EPA Regulatory Model (AERMOD). December 2016.

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Additionally, considering that both schools and residences exist in proximity to the area of disturbance, the estimation of health risks conservatively assumed that nearby receptors would be continuously exposed to pollutants from heavy-duty trucks at the maximum estimated concentrations. This assumption would represent a scenario whereby a resident living nearby also attends one of the nearby schools and is therefore exposed to pollutants both at home and at school. In practice, concentrations of pollutants at nearby schools would be much less than the concentration of pollutants at the maximally exposed receptor location. Due to the difference in pollutant concentrations at the maximally exposed receptor location and nearby schools, a single receptor would not be anticipated to be continuously exposed to the maximum level of pollutant concentrations both at home and at school. Nevertheless, by using the maximum estimated concentrations and assuming continuous exposure to pollutants, the estimated health risks presented below are considered a worst-case estimate of potential health risks, and actual health risks to receptors in the project area would be lower than the levels presented within this analysis.

It should be noted that due to the distance from the nearest proposed Highway Commercial Planned Unit Development (HC-PUD) zone to the Paso Verde K-8 School (approximately 3,500 feet), health risk impacts associated with operation of the potential fueling station were not evaluated as part of this EIR, as potential impacts are not anticipated to occur.

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.

4.3-1 Conflict with or obstruct implementation of the applicable air quality plan during project construction. Based on the
analysis below and with implementation of mitigation, the impact is less than significant.

During construction of the project, various types of equipment and vehicles would temporarily operate on the project site and in off-site improvement areas.

Construction-related emissions would be generated from construction equipment, vegetation clearing and earth movement activities, construction workers’ commute, and construction material hauling for the entire construction period. The aforementioned activities would involve the use of diesel- and gasoline-powered equipment that would generate emissions of criteria pollutants. Project construction activities also represent sources of fugitive dust, which includes PM emissions. As construction of the proposed project would generate emissions of criteria air pollutants, including ROG, NOX, and PM10, intermittently within the site and in the vicinity of the site, until all construction has been completed, construction is a potential concern, as the proposed project is located in a nonattainment area for ozone and PM.

It should be noted that construction activity related to implementation of the proposed project is required to comply with all SMAQMD rules and regulations. The applicable rules and regulations would include, but would not be limited to, the following:
 Rule 403 related to Fugitive Dust;
 Rule 404 Related to Particulate Matter;
 Rule 407 related to open burning;
 Rule 442 related to Architectural Coatings;
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 Rule 453 related to Cutback and Emulsified Asphalt Paving Materials; and  Rule 460 related to Adhesives and Sealants.

In addition, the control of fugitive dust during construction is required by SMAQMD Rule 403, and enforced by SMAQMD staff. The City would enforce compliance with Rule 403 though implementation of Mitigation Measure 4.3-1(a), below.

Using CalEEMod, the maximum construction-related emissions were estimated for development of both the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario. Table 4.3-7 below presents the estimated constructionrelated emissions of ROG, NOX, PM10, and PM2.5 associated with the proposed project in comparison with the SMAQMD thresholds of significance as described above for both project scenarios.

Table 4.3-7
Maximum Unmitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 89.34 lbs/day 85 lbs/day YES
ROG 63.65 lbs/day - NO
PM10 67.97 lbs/day and

4.58 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.17 lbs/day and

1.31 tons/yr
82 lbs/day and 15
tons/yr* NO
Full Buildout of the Annexation Area
NOX 100.2 lbs/day 85 lbs/day YES
ROG 51.28 lbs/day - NO
PM10 75.17 lbs/day and

5.49 tons/yr
80 lbs/day and 14.6
tons/yr* NO
PM2.5 19.5 lbs/day and

1.56 tons/yr
82 lbs/day and 15
tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.

Source: CalEEMod, June 2023.

Industrial Park and Off-Site Improvement Area (Proposed Project Scenario)
As shown in Table 4.3-7, construction activities associated with the Proposed Project Scenario would result in emissions of ROG, PM10, and PM2.5 below the applicable SMAQMD thresholds of significance. However, emissions of NOX would be above the applicable SMAQMD threshold of significance. Therefore, construction activities associated with development of the proposed project could substantially contribute to the SVAB’s non-attainment status for ozone. Accordingly, construction of the proposed project could violate an air quality standard or contribute to an existing or projected air quality violation, and a significant impact could occur associated with construction.

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Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area (Full Buildout of the Annexation Area Scenario)
As shown in Table 4.3-7, construction activities associated with the Full Buildout of the Annexation Area Scenario would result in emissions of ROG, PM10, and PM2.5 below the applicable SMAQMD thresholds of significance. However, emissions of NOX would be above the applicable SMAQMD threshold of significance. Therefore, construction activities associated with full buildout of the annexation area could substantially contribute to the SVAB’s non-attainment status for ozone. Accordingly, construction of the proposed project, including future development of the non-participating parcels, could violate an air quality standard or contribute to an existing or projected air quality violation, and a significant impact could occur associated with construction.

Conclusion
Because the proposed project would result in construction-related NOX emissions in excess of SMAQMD’s thresholds of significance, the proposed project would be considered to conflict with or obstruct the implementation of applicable air quality plans during construction. Therefore, the impact would be considered significant.

Mitigation Measure(s)
Implementation of Mitigation Measure 4.3-1(a) would ensure compliance with SMAQMD Rule 403. In addition, implementation of Mitigation Measure 4.3-1(b) would require the use of a combination of engine Tier 3 or Tier 4 off-road construction equipment, or hybrid, electric, or alternatively fueled equipment (or any combination of the above), during construction of the proposed project, including the industrial park, nonparticipating parcels, and off-site force main, to reduce the project’s constructionrelated NOX emissions to below to applicable SMAQMD threshold of significance. For example, the emissions presented in Table 4.3-8 assume the use of all Tier 4 final equipment. As shown in the table, use of all Tier 4 final equipment would reduce NOX emissions to below the applicable threshold of significance construction of the project components. Therefore, implementation of Mitigation Measures 4.3-1(a) and 4.3-1(b) would reduce the above potential construction-related impact to a less-than-significant level.

4.3-1(a) The following SMAQMD’s Basic Construction Emissions Control Practices (BMPs) for dust control shall be included through a notation on all project grading plans prior to the issuance of grading permits, to the satisfaction of the City of Sacramento Community Development Department.  Water all exposed surfaces two times daily. Exposed surfaces include, but are not limited to soil piles, graded areas, unpaved parking areas, staging areas, and access roads;
 Cover or maintain at least two feet of free board space on haul trucks transporting soil, sand, or other loose material on the site.

Any haul trucks that would be traveling along freeways or major roadways should be covered;
 Use wet power vacuum street sweepers to remove any visible trackout mud or dirt onto adjacent public roads at least once a day.

Use of dry power sweeping is prohibited;
 Limit vehicle speeds on unpaved roads to 15 miles per hour (mph); Draft EIR
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 All roadways, driveways, sidewalks, parking lots to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used;
 Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes [CCR Title 13, Sections 2449(d)(3) and 2485]. Provide clear signage that posts this requirement for workers at the entrances to the site;  Provide current certificate(s) of compliance for CARB’s In-Use OffRoad Diesel-Fueled Fleets Regulation [CCR Title 13, Sections 2449 and 2449.1]. For more information contact CARB at 877-593- 6677, [email protected], or www.arb.ca.gov/doors/compliance_ cert1.html.; and
 Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determine to be running in proper condition before it is operated.

Table 4.3-8
Maximum Mitigated Construction-Related Emissions
Pollutant Project Emissions
Construction
Threshold
Exceeds
Threshold?
Proposed Project
NOX 65.13 lbs/day 85 lbs/day NO
ROG 61.5 lbs/day - NO
PM10 66.74 lbs/day and

4.5 tons/yr 80 lbs/day and 14.6 tons/yr* NO
PM2.5 17.41 lbs/day and

1.24 tons/yr 82 lbs/day and 15 tons/yr* NO
Full Buildout of the Annexation Area
NOX 75.98 lbs/day 85 lbs/day NO
ROG 49.13 lbs/day - NO
PM10 73.95 lbs/day and

5.42 tons/yr 80 lbs/day and 14.6 tons/yr* NO
PM2.5 11.21 lbs/day and

1.49 tons/yr 82 lbs/day and 15 tons/yr* NO
* The above thresholds for PM only apply when all feasible BACT/BMPs are applied. If all feasible BACT/BMPs are not applied, then the applicable threshold of significance for PM is 0.

Source: CalEEMod, February 2024.

4.3-1(b) Prior to approval of any Improvement Plans, the project applicant shall provide proof of compliance with the following to the satisfaction of the City of Sacramento Community Development Department:

The project applicant shall show on the plans via notation that the contractor shall ensure that the heavy-duty off-road vehicles (50 horsepower or more) to be used in the construction of all project components (i.e., construction of the industrial park,
nonparticipating parcels, and off-site force main), including owned, Draft EIR
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leased, and subcontractor vehicles, shall be a combination of engine Tier 3 or Tier 4 off-road construction equipment, or hybrid, electric, or alternatively fueled equipment (or any combination of the above), sufficient to achieve a fleet-wide average reduction in construction-related NOX emissions to below the applicable SMAQMD thresholds of significance (85 lbs/day). For instance, the emissions presented in Table 4.3-8 of the Draft EIR were achieved by requiring all equipment used during construction to be engine Tier 4.

In addition, all off-road equipment operating at the construction site must be maintained in proper working condition according to manufacturer’s specifications. Idling shall be limited to five minutes or less in accordance with the In-Use Off-Road Diesel Vehicle Regulation as required by CARB. Clear signage regarding idling restrictions shall be placed at the entrances to the construction site.

Portable equipment over 50 horsepower must have either a valid SMAQMD Permit to Operate (PTO) or a valid statewide Portable Equipment Registration Program (PERP) placard and sticker issued by CARB.

Conformance with the foregoing requirements shall be included as notes and be confirmed through review and approval of grading plans by the City of Sacramento Community Development
Department.

4.3-2 Conflict with or obstruct implementation of the applicable air quality plan during project operation. Based on the analysis below, and with the implementation of mitigation, the impact is significant and unavoidable.

Operational emissions of ROG, NOX, and PM would be generated by the proposed project from both mobile and stationary sources. Day-to-day activities such as the future vehicle trips to and from the project site would make up the majority of the mobile emissions. Emissions would also occur from area sources and consumer products (e.g., deodorants, cleaning products, spray paint, etc.).

As discussed above, due to the nonattainment designations of the area, the SMAQMD has developed plans to attain the State and federal standards for ozone and particulate matter. The current applicable air quality plan for the proposed project area is the Sacramento Regional 2009 NAAQS 8-Hour Ozone Attainment and Reasonable Further Progress Plan (Ozone Attainment Plan), updated July 24, 2017. The Ozone Attainment Plan demonstrates how existing and new control strategies would provide the necessary future emission reductions to meet the CAA requirements, including the federal AAQS. Adopted SMAQMD rules and regulations, as well as the thresholds of significance, have been developed with the intent to ensure continued attainment of AAQS, or to work towards attainment of AAQS for which the area is currently designated nonattainment, consistent with the applicable air quality plan. Thus, if a Draft EIR
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project’s operational emissions exceed the SMAQMD’s mass emission thresholds, a project would be considered to conflict with or obstruct implementation of the SMAQMD’s air quality planning efforts.

Emissions of ROG, NOX, and PM10 would be generated during operations of the proposed project from both mobile and stationary sources. Emissions related to operation of the proposed project would include sources such as architectural coatings, landscape maintenance equipment exhaust, and consumer products (e.g., deodorants, detergents, cleaning products, spray paint, insecticides, floor finishes, polishes, etc.). However, the most significant source of emissions related to the proposed project would be from mobile sources. As discussed in the Method of Analysis section above, to capture the potential emissions related to mobile sources from the proposed project, project-specific trip generation rates and VMT estimates were provided by DKS. In addition, emissions associated with heavy-duty trucks travelling to and from the project site were calculated off-model. The estimated emissions from CalEEMod and EMFAC2021 were added together to represent total project emissions.

The project is required to comply with all SMAQMD rules and regulations related to operations. The modeling was adjusted to reflect the project’s inherent site or design features and compliance with applicable regulations. It should be noted that the project would not involve installation or operation of any pieces of equipment that would require implementation of SMAQMD’s BACT measures; therefore, the project would be subject to SMAQMD’s mass emissions thresholds for PM10 and PM2.5. As discussed above, the maximum operational emissions were estimated for development of both the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario.

The maximum unmitigated operational emissions for both project scenarios are presented in Table 4.3-9, below. It should be noted that the proposed off-site force main would not result in operational emissions, and thus, is not included in the analysis below.

Industrial Park (Proposed Project Scenario)
As shown in Table 4.3-9, operation of the proposed project under the Proposed Project Scenario would result in emissions of PM10 and PM2.5 below the applicable SMAQMD thresholds of significance. However, emissions of ROG and NOX would exceed SMAQMD thresholds of significance. Therefore, operation of the proposed project could substantially contribute to the SVAB’s non-attainment status for ozone.

Accordingly, operational emissions associated with the proposed project could violate an air quality standard or contribute to an existing or projected air quality violation, and a potentially significant impact could occur associated with project operations.

Industrial Park and Nonparticipating Parcels (Full Buildout of the Annexation Area Scenario)
As shown in Table 4.3-9, operation of the proposed project under the Full Buildout of the Annexation Area Scenario would also result in emissions of PM10 and PM2.5 below the applicable SMAQMD thresholds of significance. However, emissions of ROG and NOX would further exceed the applicable SMAQMD thresholds of significance.

Therefore, operation of the proposed project, including future development within the Draft EIR
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non-participating parcels, could substantially contribute to the SVAB’s non-attainment status for ozone. Accordingly, operational emissions associated with full buildout of the annexation area could violate an air quality standard or contribute to an existing or projected air quality violation, and a potentially significant impact could occur associated with project operations.

Table 4.3-9
Maximum Unmitigated Project Operational Emissions
Pollutant Project Emissions
Operational
Threshold
Exceeds
Threshold?
Proposed Project
NOX 628.33 lbs/day 65 lbs/day YES
ROG 172.37 lbs/day 65 lbs/day YES
PM10 32.99 lbs/day and

5.36 tons/yr 80 lbs/day and 14.6 tons/yr NO
PM2.5 17.91 lbs/day and

2.74 tons/yr 82 lbs/day and 15 tons/yr NO
Full Buildout of the Annexation Area
NOX 738.56 lbs/day 65 lbs/day YES
ROG 214.49 lbs/day 65 lbs/day YES
PM10 45.84 lbs/day and

7.68 tons/yr 80 lbs/day and 14.6 tons/yr NO
PM2.5 19.52 lbs/day and

3.07 tons/yr 82 lbs/day and 15 tons/yr NO
Source: CalEEMod, June 2023.

Conclusion
As shown in Table 4.3-9, the 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 SMAQMD thresholds for PM2.5 and PM10. However, ROG and NOX emissions would be above the applicable SMAQMD thresholds of significance under both project scenarios. Based on the emissions presented in Table 4.3-9, operation of the proposed project could create a conflict with or obstruct implementation of the applicable air quality plan, and a significant impact could result.

Mitigation Measure(s)
For land development projects that are anticipated to exceed the SMAQMD’s operational emissions thresholds of significance for criteria pollutants, such as the proposed project, SMAQMD requires that the project proponent develop an Air Quality Mitigation Plan (AQMP) describing what features the project will incorporate to reduce operational criteria pollutant emissions from baseline conditions. SMAQMD guidance provides that the creation and implementation of an AQMP represents all feasible mitigation, provided that the AQMP demonstrates a 15 percent reduction of ozone precursors below baseline emissions for projects considered in the SIP and 35 percent for projects not considered in the SIP. As the proposed project was not anticipated by the City in its current General Plan or other community plan, development of the project is not included in the growth assumptions of the SIP. As such, a reduction of 35 percent below baseline emissions of ozone precursors is required for the proposed project.

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should be based on mobile emissions only. Mitigation Measure 4.3-2 requires preparation and implementation of a project-specific AQMP. The AQMP (see Appendix D of this EIR) was prepared using assumptions associated with full buildout of the annexation area, to represent a worst-case scenario. As shown in Table 4.3-10, the proposed project would meet the 35 percent reduction target with implementation of Mitigation Measure 4.3-2, which represents all feasible mitigation. However, even with a 35 percent reduction, emission levels would still exceed the applicable threshold of significance and, therefore, the impact would remain significant and unavoidable.

Table 4.3-10
AQMP Operational Criteria Pollutant Emissions Reduction Summary (tons/yr)
Scenario ROG NOX PM10
Maximum Mobile Emissions Baseline1 10.18 85.88 22.51
TARGET (35% Reduction) 3.56 30.06 All Feasible
Total Tons Reduced 8.56 38.03 16.26
Difference 5.00 +7.97 N/A
Meets Target YES YES YES 1 According to SMAQMD, a project’s ozone precursor emissions reductions targets should be based on mobile emissions only; however, reductions of ozone precursors from non-mobile emission reduction measures (e.g., natural gas or energy reductions) may still be accounted for and applied towards the emission reduction targets.

Source: CalEEMod, June 2023 (see Appendix D).

4.3-2 Prior to the approval of project improvement plans for both the industrial park and nonparticipating parcels, the project applicant shall comply with the provisions of the Air Quality Management Plan prepared for the proposed project (see Appendix D), and incorporate all requirements into the Airport South Industrial Project conditions of approval. The measures included in the AQMP include the following:

1. Natural gas use shall be prohibited in all land uses, with the exception of the restaurant kitchen.

2. The project shall implement a Transportation Management Association (TMA), such as Jibe North Natomas (for more information, visit https://jibe.org/). The TMA must comply with the following criteria, and is subject to approval by the City of Sacramento and SMAQMD:
a. The TMA must be legally constituted as a non-profit
organization, Property/Business Improvement District
(PBID), or a government entity with a non-revocable funding mechanism, such as a community finance district, dedicated to TMA operations and services; and
b. The TMA must provide a minimum level of TDM services to employees and residents within the area covered by the
AQMP sufficient to achieve the emission reductions claimed by the measure. Services must be enumerated and funded
to the satisfaction of the lead agency and SMAQMD.

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3. The project applicant shall require all tenants of the on-site industrial uses to use zero-emission forklifts.

4. The project applicant shall require that 4.5 percent of the heavyduty vehicle fleet be zero emission by full buildout of the annexation area. It should be noted that in the event there is a disruption in the manufacturing of zero emission vehicles/trucks or that sufficient vehicles/trucks are not commercially available for the intended application, the “clean fleet requirements” may be adjusted as minimally as possible by the City’s Community Development Department to accommodate the manufacturing disruption or unavailability of commercially available vehicles/trucks.

5. The project shall provide complete sidewalks separated from roadway throughout the project site and pedestrian crossing at intersections on-site to ensure employees and visitors can walk between land uses/businesses. The project shall also connect the pedestrian network on-site to the adjacent properties off-site (including South Bayou Way, Power Line Road and potential future connections) as indicated on the preliminary site plan when those portions of the site develop.

6. Provide EV Ready parking spaces at the ratio with which the current CalGreen Tier 2 standards require EV Capable spaces.

4.3-3 Expose sensitive receptors to substantial pollutant concentrations. Based on the analysis below, and with the implementation of mitigation, the impact is less than
significant.

As noted previously, the nearest sensitive receptors include the single-family residences and Paso Verde K-8 School, located approximately 200 feet east and south of the project site. The major pollutant concentrations of concern are localized CO emissions, TAC emissions, and criteria pollutant emissions, which are addressed in further detail below.

Localized CO Emissions
The following includes a discussion of impacts related to localized CO emissions associated with both the industrial park and the nonparticipating parcels.

Industrial Park and Nonparticipating Parcels
Localized concentrations of CO are related to the levels of traffic and congestion along streets and at intersections. Per the SMAQMD Guide, emissions of CO are generally of less concern than other criteria pollutants, as operational activities are not likely to generate substantial quantities of CO, and the SVAB has been in attainment for CO for multiple years.30 Consequently, the proposed project is not anticipated to result in significant impacts to air quality related to localized CO emissions. 30 Sacramento Metropolitan Air Quality Management District. Guide to Air Quality Assessment, Chapter 4:

Operational Criteria Air Pollutant and Precursor Emissions. June 2020.

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TAC Emissions
Another category of environmental concern is TACs. The CARB’s Air Quality and Land Use Handbook: A Community Health Perspective (Handbook) provides recommended setback distances for sensitive land uses from major sources of TACs, including, but not limited to, freeways and high traffic roads, gasoline dispensing facilities, chrome plating operations, distribution centers, and rail yards. The CARB has identified DPM from diesel-fueled engines as a TAC; thus, high volume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic are identified as having the highest associated health risks from DPM. Health risks associated with TACs are a function of both the concentration of emissions and the duration of exposure, where the higher the concentration and/or the longer the period of time that a sensitive receptor is exposed to pollutant concentrations would correlate to a higher health risk.

The proposed project would involve components that would result in emissions of TACs. In particular, implementation of the proposed project would result in emissions of DPM during project construction and from the on-site use of heavy-duty diesel trucks to transport goods during project operations. Each source of TACs is discussed in further depth in the sections below.

Construction Emissions
The following includes a discussion of impacts regarding construction-related TAC emissions associated with both the industrial park and the nonparticipating parcels.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Short-term, construction-related activities could result in the generation of TACs, specifically DPM, from on-road haul trucks and off-road equipment exhaust emissions. However, construction is temporary and occurs over a relatively short duration in comparison to the operational lifetime of the proposed project. Health risks are typically associated with exposure to high concentrations of TACs over extended periods of time (e.g., 30 years or greater). As discussed above, construction of the proposed project is anticipated to occur over an approximately six-year period.

All construction equipment and operation thereof would be regulated per the CARB’s In-Use Off-Road Diesel Vehicle Regulation, which is intended to help reduce emissions associated with off-road diesel vehicles and equipment, including DPM. Project construction would also be required to comply with all applicable SMAQMD rules and regulations, particularly associated with permitting of air pollutant sources. In addition, construction equipment would operate intermittently throughout the day and only on portions of the sites at a time.

Because construction equipment on-site would not operate for long periods of time and would be used at varying locations within the sites, associated emissions of DPM would not occur at the same location (or be evenly spread throughout the entire project site) for long periods of time. Due to the temporary nature of construction and the relatively short duration of Draft EIR
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potential exposure to associated emissions, the potential for any one sensitive receptor in the area to be exposed to concentrations of pollutants for a substantially extended period of time would be low. Therefore, construction associated with the proposed project would not be expected to expose any sensitive receptors to substantial pollutant concentrations.

In addition, it should be noted that due to the temporary nature of construction activities, construction of the proposed project would not result in any worse impacts than what would occur during operations associated with DPM emissions generated by heavy duty truck traffic, as discussed in further detail below. In addition, as discussed above, Mitigation Measure

4.3-1(b) would require the use of cleaner engine construction equipment, such as Tier 4 final equipment, during project construction, which would further help to reduce DPM emissions during construction.

Heavy Duty Truck Circulation
The following discussion includes both a project-level analysis regarding the industrial park and program-level analysis regarding the nonparticipating parcels associated with potential impacts that could occur due to DPM emissions generated by heavy duty truck traffic associated with on-site industrial uses.

Industrial Park
The proposed project would include the development of approximately 5,204,500 sf of industrial uses within project site. While specific tenants of the proposed warehouses have not been identified at this time, industrial uses are anticipated to involve the use of heavy-duty diesel trucks associated with the movement of goods to and from the sites. The operation of heavy-duty diesel-powered trucks would result in an increase in emissions of DPM within the project sites and on the surrounding roadways. It should be noted that the HC-PUD uses are not anticipated to involve substantial use of heavy-duty trucks. Thus, DPM emissions associated with the HC-PUD uses are not evaluated below.

To assess the increase in DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site, the anticipated truck route was mapped, and idling points were placed at the nearest loading dock to the sensitive receptors associated with each of the five proposed warehouse buildings.

DPM is considered a subset of PM2.5 emissions. Thus, the estimated concentration of PM2.5 was used as a proxy to represent emissions of DPM.

Emissions rates for the heavy-duty diesel-powered trucks were obtained through the CARB’s EMFAC2021 database. Once the emissions of DPM were determined, the concentration of DPM at nearby receptors was then estimated using the AMS/EPA AERMOD. Finally, the associated cancer risk and non-cancer hazard index were calculated using the CARB’s HARP 2 RAST, which calculates the cancer and non-cancer health impacts using the risk assessment guidelines of the 2015 OEHHA Guidance Manual for Draft EIR
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Preparation of Health Risk Assessments.31 The modeling was performed in accordance with the USEPA’s User’s Guide for the AMS/EPA Regulatory Model – AERMOD32 and the 2015 OEHHA Guidance Manual. The exposure period in HARP 2 RAST was set to a 30-year exposure period.

Table 4.3-11 presents the result of the health risk assessment prepared for the proposed project.

Table 4.3-11
Maximum Cancer Risk and Hazard Index
Associated with Heavy-Duty Diesel Trucks
Cancer Risk
(per million
persons)
Acute Hazard
Index
Chronic
Hazard Index
At Maximally
Exposed Receptor 9.53 0.00 0.00
Thresholds of
Significance 10 1.0 1.0
Exceed
Thresholds? NO NO NO
Sources: EMFAC, AERMOD, and HARP 2 RAST, May 2023 (see Appendix C).

In addition, Figure 4.3-3 provides a visual representation of the emissions concentration dispersion within the project area due to heavy-duty truck traffic associated with the proposed industrial warehouses. Figure 4.3-3 also presents the maximally exposed sensitive receptor, represented by a white X, which is located just east of the project site. As discussed above, land uses that are typically considered to be sensitive receptors include residences, schools, day care centers, playgrounds, and medical facilities.

The proposed project does not include the development of any such uses.

The nearest sensitive receptors include the single-family residences and Paso Verde K-8 School, located approximately 200 feet east and 200 feet south of the project site, respectively.

As shown in Table 4.3-11, operation of heavy-duty diesel-powered trucks on roadways and within the project site would result in cancer risk and hazard index at the maximally exposed receptor below the applicable SMAQMD thresholds of significance.

Consequently, operation of the proposed project would not expose sensitive receptors to excess concentrations of pollutants, and the proposed project would result in a less-than-significant impact related to DPM.
31 Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots Program Risk Assessment Guidelines, Guidance Manual for Preparation of Health Risk Assessments [pg. 8-18]. February 2015. 32 U.S. Environmental Protection Agency. User’s Guide for the AMS/EPA Regulatory Model (AERMOD). December 2016.

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Figure 4.3-3
AERMOD Results
Source: AERMOD, May 2023 (see Appendix C).

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Nonparticipating Parcels
The project site also includes six nonparticipating parcels, comprised of approximately 83 acres, that would result in an additional approximately 1,404,800 sf future industrial uses within the site. As discussed above, the CARB Handbook provides recommended setback distances for sensitive land uses from major sources of TACs, including distribution centers.

DPM is a highly dispersive gas, and concentrations of DPM decline rapidly with distance.33 Based on the CARB’s Handbook, an 80 percent drop-off in pollutant concentrations occurs at approximately 1,000 feet from a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week). Therefore, the CARB Handbook’s recommended setback distance for sensitive land uses from distribution centers is 1,000 feet.

The majority of the nonparticipating parcels are located more than 1,000 feet from the nearest sensitive receptor, and, therefore, are not anticipated to expose sensitive receptors to excess concentrations of DPM if distribution centers are developed on such parcels in the future. However, Parcel 8, which is a 64.3-acre nonparticipating parcel owned by Cayocca, is located adjacent to the existing neighborhood to the east of the project site. Given that site-specific development plans or designs have not been proposed for Parcel 8, the location of the loading docks are not currently known. As a result, health risks associated with Parcel 8 would be speculative, and, thus, such risks associated with Parcel 8 have not been modeled in this analysis.

Nonetheless, because the potential exists for a future distribution center to be developed on Parcel 8 within 1,000 feet of the existing sensitive receptors, future development of Parcel 8 could expose sensitive receptors to excess concentrations of pollutants, and the proposed project could result in a significant impact related to DPM.

Criteria Pollutants
The following includes a discussion of health impacts related to criteria pollutant emissions associated with both the industrial park, the nonparticipating parcels, and off-site improvement area.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Recent rulings from the California Supreme Court (including the Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502 case regarding the proposed Friant Ranch Project) have underscored the need for analysis of potential health impacts resulting from the emission of criteria pollutants during operations of proposed projects. Although analysis of project-level health risks related to the emission of CO and TACs has long 33 California Air Resources Board. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005.

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been practiced under CEQA, the analysis of health impacts due to individual projects resulting from emissions of criteria pollutants is a relatively new field. 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.34 The Guidance represents SMAQMD’s effort to develop a methodology that provides a consistent, reliable, and meaningful analysis in response to the Supreme Court’s direction on correlating health impacts to a project’s emissions.

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 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 this EIR. Table 4.3-12 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.

However, it should be noted that the maximum amount of emissions that can be input into the Strategic Area Project Health Screening Tool for all criteria pollutants is 656 lbs/day. As shown in Table 4.3-9, operation of the proposed project under the Full Buildout of the Annexation Area Scenario would result in 738.56 lbs/day of NOX emissions. Therefore, the proposed project’s actual unmitigated health impacts associated with criteria pollutant emissions would be slightly higher than what is presented in Table 4.3-12. However, as noted above, with implementation of Mitigation Measure 4.3-2 the proposed project’s operational emissions, and subsequently the proposed projects health impacts associated with criteria pollutant emissions, would be reduced as compared to what is presented in Table 4.3-12.

As shown in the table, according to the Strategic Area Project Health Screening Tool, the proposed project could result in 5.6 premature deaths per year due to the project’s PM2.5 emissions and 0.32 premature deaths per year due to the project’s ozone emissions. Such numbers represent a very small increase over the background incidence of premature deaths due to PM2.5 and ozone concentrations (0.01 percent and 0.001 percent, respectively). In addition, according to the Strategic Area Project Health Screening Tool, PM2.5 emissions from the proposed project could result in 2.5 asthma-related emergency room visits, and ozone emissions from the proposed project could result in 5.5 asthma-related emergency room visits. Such numbers represent a minute increase over the background level of asthma-related emergency room visits (0.01 percent and 0.03 percent, respectively). 34 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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Table 4.3-12
Health Effects from Proposed Project
Health Endpoint
Age
Range1
Incidences Across the
5-Air-District Region
Resulting from Project
Emissions (per year)2
Percent of
Background Health
Incidences Across the
5-Air-District Region3
Total Number of
Health Incidences
Across the 5-AirDistrict Region (per
year)4 (Mean) (%)
Respiratory PM2.5
Emergency Room Visits, Asthma 0-99 2.3 0.012 18,419
Hospital Admissions, Asthma 0-64 0.15 0.0079 1,846
Hospital Admissions, All Respiratory 65-99 0.77 0.0039 19,644 Cardiovascular PM2.5
Hospital Admissions, All Cardiovascular
(less Myocardial Infarctions) 65-99 0.40 0.0017 24,037
Acute Myocardial Infarction, Nonfatal 18-24 0.00020 0.0054 4 Acute Myocardial Infarction, Nonfatal 25-44 0.018 0.0057 308 Acute Myocardial Infarction, Nonfatal 45-54 0.040 0.0054 741 Acute Myocardial Infarction, Nonfatal 55-64 0.068 0.0055 1,239 Acute Myocardial Infarction, Nonfatal 65-99 0.26 0.0051 5,052 Mortality PM2.5
Mortality, All Cause 30-99 5.6 0.013 44,766
Respiratory Ozone
Hospital Admissions, All Respiratory 65-99 0.39 0.002 19,644 Emergency Room Visits, Asthma 0-17 2.1 0.036 5,859 Emergency Room Visits, Asthma 18-99 3.4 0.027 12,560 Mortality Ozone
Mortality, Non-Accidental 0-99 0.26 0.00084 30,386
1 Affected age ranges are shown. Other age ranges are available, but the endpoints and age ranges shown here are the ones used by the USEPA in their health assessments. The age ranges are consistent with the epidemiological study that is the basis of the health function. 2 Health effects are shown in terms of incidences of each health endpoint and how it compares to the base (2035 base year health effect incidences, or “background health incidence”) values. Health effects are shown for the 5-Air-District Region. 3 The percent of background health incidence uses the mean incidence. The background health incidence is an estimate of the average number of people that are affected by the health endpoint in a given population over a given period of time. In this case, the background incidence rates cover the 5-Air-District Region (estimated 2035 population of 3,271,451 persons). Health incidence rates and other health data are typically collected by the government as well as the World Health Organization. The background incidence rates used here are obtained from BenMAP. 4 The total number of health incidences across the 5-Air-District Region is calculated based on the modeling data. The information is presented to assist in providing overall health context.

Source: SMAQMD, Minor Project Health Effects Screening Tool. September 2020 (see Appendix C).

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In addition, the results of the Minor Project Health Effects Screening Tool have been presented for informational purposes only.

Conclusion
Based on the above analysis, the operations of the proposed project would not be anticipated to result in the production of substantial concentrations of localized CO or criteria pollutants. In addition, the proposed project would not be anticipated to result in the production of substantial concentrations of TACs, including DPM.

However, Parcel 8, the 64.3-acre nonparticipating parcel owned by Cayocca, is located adjacent to the existing neighborhood to the east of the project site. Therefore, the potential exists for a future distribution center to be developed on Parcel 8 within 1,000 feet of the existing sensitive receptors.

As a result, future development of Parcel 8 could expose sensitive receptors to excess concentrations of DPM. Therefore, the proposed project could result in the exposure of sensitive receptors to substantial pollutant concentrations, and a significant impact could result.

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

4.3-3 If Parcel 8 (the 64.3-acre nonparticipating parcel owned by Cayocca) is proposed to be developed with a distribution center (i.e., an industrial warehouse that accommodates more than 100 heavy-duty trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week) within 1,000 feet of a sensitive receptor, prior to the issuance of any building permit, a Health Risk Assessment (HRA) shall be conducted to calculate the cancer risk associated with on-site truck diesel particulate matter (DPM) emissions.

The HRA shall be prepared in accordance with SMAQMD guidelines, as well as the guidelines identified in the California Office of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments. If health risks associated with Parcel 8 are determined to exceed the applicable SMAQMD thresholds, a qualified air quality consultant shall identify measures sufficient to reduce the project’s health risks to below the SMAQMD’s thresholds of significance. Reduction measures may include, but are not limited to, relocation of loading docks to further than 1,000 feet from sensitive receptors, electrification of the heavy-duty truck fleet, and/or other options as they become available. Conformance with the foregoing requirement shall be confirmed through review and approval of the HRA by the City of Sacramento Community Development Department.

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4.3-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. Based on the analysis below, the impact is less than significant.

The following discussion applies to the potential for both project components to result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Emissions of pollutants have the potential to adversely affect sensitive receptors within the project area. Pollutants of principal concern include emissions leading to odors, emissions that have the potential to cause dust, or emissions considered to constitute air pollutants. Air pollutants have been discussed in Impacts 4.3-1 through 4.3-3 above. Therefore, the following discussion focuses on emissions of odors and dust.

Odors
Odors are generally regarded as an annoyance rather than a health hazard. Due to the subjective nature of odor impacts, the number of variables that can influence the potential for an odor impact, and the variety of odor sources, quantitative methodologies to determine the presence of a significant odor impact are difficult.

Certain land uses such as wastewater treatment and conveyance facilities, landfills, confined animal facilities, composting operations, food manufacturing plants, refineries, and chemical plants have the potential to generate considerable odors.

Operations of the proposed project would involve activities typical to commercial and industrial/warehouse developments, and, consequently, would not be anticipated to result in the creation of substantial odors.

Diesel fumes from construction equipment could be found to be objectionable; however, as addressed above, operation of construction equipment would be regulated by SMAQMD rules and regulations, restricted to the hours of 7:00 AM to 6:00 PM Monday through Saturday, and between 9:00 AM and 6:00 PM on Sundays, pursuant to Section 8.68.080 of the Sacramento City Code, and would occur intermittently throughout the course of a day. Furthermore, considering the large development area, construction equipment would operate at various locations throughout the project site intermittently, and the distances from the nearest sensitive receptors would allow for dispersal of diesel odors. For the aforementioned reasons, the project would not result in any noticeable objectionable odors associated with construction.

In addition, SMAQMD Rule 402, Nuisance, prohibits the emission of nuisance air contaminant discharges, including odors, and provides enforcement of odor control.

Rule 402 is complaint-based, where if public complaints are sufficient to cause the odor source to be considered a public nuisance, then SMAQMD is required to investigate the identified source, as well as determine and ensure a solution for the source of the complaint, which could include operational modifications to correct the nuisance condition. Thus, although not anticipated, if odor or air quality complaints are made upon development of the proposed project, SMAQMD would be required Draft EIR
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(per SMAQMD Rule 402) to ensure that such complaints are addressed and mitigated, as necessary.

Dust
With regard to dust, the proposed project is required to comply with all applicable SMAQMD rules and regulations for construction, including, but not limited to, Rule 403 (Fugitive Dust) and Rule 404 (Particulate Matter). Furthermore, all projects are required to implement the SMAQMD’s BMPs. Compliance with SMAQMD rules and regulations and BMPs would help to ensure that dust is minimized during project construction. Following project construction, vehicles operating within the project site would be limited to paved areas of the site, which would not have the potential to create substantial dust emissions. Thus, project operations would not include sources of dust that could adversely affect a substantial number of people.

Conclusion
For the aforementioned reasons, project construction and operations would not result in substantial emissions, such as those leading to odors or dust, which could adversely affect a substantial number of people, and a less-than-significant impact would result.

Mitigation Measure(s)
None required.

4.3-5 Result in the inefficient or wasteful use of energy, or conflict with a State or local plan for renewable energy or energy efficiency. Based on the analysis below, the impact is less than significant.

The following discussion applies to the potential for both project components to result in the inefficient or wasteful use of energy, or conflict with a State or local plan for renewable energy or energy efficiency. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
The proposed project would include the development of industrial, retail/highway commercial, and hotel/hospitality uses within the 353.5-acre project site. Energy use associated with operation of the proposed project would be typical of such uses, requiring electricity for interior and exterior building lighting, HVAC systems, electronic equipment, machinery, refrigeration, appliances, security systems, and more.

Maintenance activities during operations, such as landscape maintenance, would involve the use of electric or gas-powered equipment. In addition to on-site energy use, the proposed project would result in transportation energy use associated with vehicle trips generated by employees and visitors travelling to and from the project site. Energy use associated with construction of the proposed project, as well as building energy use and transportation energy use are discussed separately below.

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Construction Energy Use
Construction of the proposed project would involve increased energy demand and consumption related to use of oil in the form of gasoline and diesel fuel for construction worker vehicle trips, hauling and materials delivery truck trips, and operation of offroad construction equipment. In addition, diesel-fueled portable generators may be necessary to provide additional electricity demands for temporary lighting, welding, and for supplying energy to areas of the site where energy supply cannot be met through a hookup to the existing electricity grid.

Typically, at construction sites, electricity from the existing grid is used to power portable and temporary lights or office trailers. Because grid electricity would be used primarily for steady sources such as lighting, not sudden, intermittent sources such as welding or other hand-held tools, the increase in electricity usage at the site during construction would not be expected to cause any substantial peaks in demand.

Construction of the proposed project, which would result in temporary increases in electricity demand, would not cause a permanent or substantial increase in demand that would exceed SMUD’s demand projections or exceed the ability of SMUD’s existing infrastructure to handle such an increase. Therefore, project construction would not result in any significant impacts on local or regional electricity supplies, the need for additional capacity, or on peak or base period electricity demands. In addition, standards or regulations specific to construction-related electricity usage do not currently exist.

Even during the most intense period of construction, due to the different types of construction activities (e.g., site preparation, grading, building construction), only portions of the project site would be disturbed at a time, with operation of construction equipment occurring at different locations on the project site, rather than a single location. In addition, as discussed above, construction is temporary and occurs over a relatively short duration. Furthermore, all construction equipment and operation thereof would be regulated pursuant to the CARB In-Use Off-Road Diesel Vehicle Regulation. The In-Use Off-Road Diesel Vehicle Regulation is intended to reduce emissions from in-use, off-road, heavy-duty diesel vehicles in California by imposing a five-minute limit on idling, requiring all vehicles to be reported to CARB, restricting the addition of older vehicles into fleets, and requiring fleets to reduce emissions by retiring, replacing, or repowering older engines, or installing exhaust retrofits.

Furthermore, as a means of reducing emissions, construction vehicles are required to become cleaner through the use of renewable energy resources. Engine tiers are used to describe the emissions intensity and efficiency of an engine. Construction equipment with Tier 0 or Tier 1 engines are the least efficient, and Tier 4 is the most efficient. In November 2021, the CARB began developing standards for Tier 5 engines.

As of 2015, vehicles with Tier 0 and Tier 1 engines are prohibited from being added to equipment fleets. Fleets with a total horsepower over 2,501, excluding non-profit training centers, may not add any Tier 2 engines and, starting January 1, 2024, all newly added engines must be Tier 4 final or higher.35 The In-Use Off-Road Diesel Vehicle Regulation would, therefore, help to improve fuel efficiency for equipment used in construction of the proposed project.
35 California Air Resources Board. In-Use Off Road Diesel-Fueled Fleets Regulation Overview, Revised October 2016. 2016.

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The CARB enforces off-road equipment regulations through their reporting system, Diesel Off-road Online Reporting System (DOORS). Each construction fleet is required to update their DOORS account within 30 days of buying or selling a vehicle, and DOORS automatically calculates the fleet average index for each fleet. The fleet average index is an indicator of a fleet’s overall emission rate, and is based on each vehicle’s engine horsepower and model year, and whether it is equipped with a Verified Diesel Emission Control Strategy (VDECS). If a fleet cannot, or does not want to, meet the fleet average target in a given year, the fleet may instead choose to comply with the BACT requirements. A fleet may meet the BACT requirements each year by turning over or installing VDECS on a certain percentage of its total fleet horsepower. ‘Turnover’ means retiring a vehicle, designating a vehicle as permanent low-use (a vehicle used less than 200 hours per year), repowering a vehicle with a higher tier engine, or rebuilding the engine to a more stringent emission standard. By each compliance date (annually on January 1st), the fleet must either show that its fleet average index was less than or equal to the calculated fleet average target rate, or that the fleet has met the BACT requirements.36 The project would be required to comply with such regulations, which would ensure that construction equipment meets all State efficiency requirements.

Technological innovations and more stringent standards are being researched, such as multi-function equipment, hybrid equipment, or other design changes, which could help to further reduce demand on oil and limit emissions associated with construction.

Over time, as technology progresses and more stringent emissions standards are put in place, construction equipment engines become increasingly efficient. Project construction would also be required to comply with all applicable SMAQMD rules and regulations, which are indirectly related to energy efficiency, which would help to further reduce energy use associated with the proposed project.

Based on the above, the temporary increase in energy use occurring during construction of the proposed project would not result in a significant increase in peak or base demands or require additional capacity from local or regional energy supplies.

In addition, the proposed project would be required to comply with all applicable regulations related to energy conservation and fuel efficiency, which would help to reduce the temporary increase in demand.

Building Energy Demand
The proposed project is required to comply with all applicable standards and regulations regarding energy conservation and fuel efficiency, including the CBSC and CARB standards, which would ensure that the future uses would be designed to be energy efficient to the maximum extent practicable. Adherence to the most recent CALGreen Code and the Building Energy Efficiency Standards would ensure that the proposed development on-site would consume energy efficiently through the incorporation of such features as efficient water heating systems, high performance attics and walls, and high efficacy lighting. In addition, State regulations promote the generation of renewable energy and encourage energy efficiency through requirements placed on utility providers and strict development standards. For instance, the RPS requires utilities, including the SMUD, to procure an increasing 36 California Air Resources Board. Frequently Asked Questions, Regulation for In-Use Off-Road Diesel-Fueled Fleets (Off-Road Regulation). August 2014.

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proportion of electricity from renewable sources. Ultimately the RPS requirements mandate that all electricity produced within the State be renewably sourced by the year 2045.

Based on the air quality modeling prepared for the proposed project, the proposed project (including full buildout of the non-participating parcels) is anticipated to result in increased electricity consumption of approximately 93.85 GWh annually during operations. It is noted that, compared to the electricity consumption for all of Sacramento County, the proposed project’s contribution would represent a 0.84 percent increase in electricity demand. Although the project would increase electricity demand in the project area, given the relatively small increase as compared to energy usage in the region, the increased demand is not anticipated to conflict with SMUD’s ability to meet the RPS requirements, or exceed SMUD’s capacity such that the proposed project’s energy demands would not be met.

With regard to landscaping and maintenance equipment, AB 1346 would require that all small off-road engines purchased after January 1, 2024 are all-electric. Given that SMUD has vowed to reach zero carbon emissions in their power supply by 2030,37 the use of electric maintenance equipment would be considered more energy efficient than diesel- or gas-powered maintenance equipment.

Transportation Energy Demand
The average fuel economy for the U.S. passenger vehicle fleet was 25 miles per gallon (mpg) in 2021, the most recent year such data is available.38 An average of 25 mpg and an annual VMT of approximately 16,828,96739 for the project would result in the consumption of approximately 15,838 barrels of gasoline a year. California is estimated to consume approximately 605 million barrels of petroleum per year.40 Based on the annual consumption within the State, vehicle trips generated by the proposed project would result in a 0.0026 percent increase in the State’s current consumption of gasoline.

The calculation above is likely an overestimate, as the estimate does not account for the increasing ownership of electric vehicles. California leads the nation in registered alternatively-fueled and hybrid vehicles. In fact, under SB 500, the State has required that, starting in the year 2030, all cars sold shall be zero-emission/electric vehicles. In addition, State-specific regulations encourage fuel efficiency and reduction of dependence on oil. Improvements in vehicle efficiency and fuel economy standards help to reduce consumption of gasoline and reduce the State’s dependence on petroleum products. The 2022 CBSC requires new developments to include the necessary electrical infrastructure for EV charging stations. A total of 3,670 vehicle parking stalls would be provided on-site. Based on the 2022 CBSC, for non-residential projects that include more than 201 parking spaces, 20 percent of the parking spaces 37 Sacramento Municipal Utility District. 2030 Zero Carbon Plan. April 2021. 38 U.S. Energy Information Administration. Total Energy, Table 1.8 Motor Vehicle Mileage, Fuel Consumption, and Fuel Economy. Accessible at: https://www.eia.gov/totalenergy/data/browser/?tbl=T01.08#/?f=A&start=200001.

Accessed February 2024. 39 The annual VMT estimate presented herein is based on data provided by DKS for the proposed project. 40 U.S. Energy Information Administration. California: State Profile and Energy Estimates. Accessible at:
https://www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_use_pa.html&sid=US&sid=CA.

Accessed February 2024.

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