Agenda packet — Visalia City Council, March 17, 2025 (part 13 of 16)

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project site, a significant increase in vehicle traffic, both personal vehicles and delivery trucks, is expected. This would likely create need for an increase of personnel involved in traffic enforcement, including commercial vehicle regulations.

As discussed in the General Plan, it is anticipated that the VPD’s area of responsibility would increase over time through the annexation of properties (including, among others, the project site) and contemplated development consistent with the General Plan land use vision, and thus the need may arise to construct new or expand police facilities to accommodate additional staffing (sworn and professional staff) in order to maintain and improve any applicable response standards and quality of services currently provided by the VPD to serve its area of responsibility over time.

The industrial uses and compatible commercial uses that would occur over time through implementation of the proposed project are part of the anticipated growth contemplated by the City in its General Plan, as indicated by the project site’s current Industrial and Light Industrial General Plan land use designations. Indirect population growth that occurs as a result of new employment opportunities (such as those that would occur pursuant to the proposed project) is considered planned growth, as discussed in detail in Section 4.2.2, Population and Housing. The General Plan projects for the City’s population to grow from 125,000 people in 2014 to 210,000 people by 2030 and outlines plans for the VPD to expand to meet these growing needs associated with General Plan buildout over that time period within growth areas. The General Plan estimates that a total of 360 officers would be needed to fully staff and serve the City’s anticipated population by 2030. 33 The City
currently has 250 employees with the VPD according to the VPD’s 2020 annual report. 34 It is notable
that the City’s actual population growth has been slower than previously anticipated in the General Plan. According to the United States Census Bureau, the City had a population of 142,384 in 2020. 35 The VPD does not identify specific service standards in terms of officers per thousand residents or incident response time. Police response time was less than 20 minutes for 71 percent of all calls in 2022; the average response time for Priority 1 calls was 7 minutes and 4 seconds.

While the proposed project would result in an increased demand for police protection, the nature of the proposed project’s uses would not result in atypical service demand needs in this regard and is not anticipated to trigger a need to construct new or expand existing police protection facilities to accommodate this relatively minor increase in demand.

Moreover, each project applicant in connection with its individual specific development proposal for the proposed project would be required to pay the required applicable plan review and public safety development impact fees toward police facilities in accordance with the applicable Development Fee Schedule, which would reflect its pro rata fair share contribution to help ensure that the VPD can meet any increased demand for services associated with the proposed project (and other planned 33 City of Visalia. 2014. Visalia General Plan Draft Environmental Impact Report (DEIR), Public Service, Facilities, and Utilities. October. 34 Visalia Police Department (VPD). 2020. Visalia Police Department Annual Report. Accessed September 14, 2022. 35 United States Census Bureau. 2023. Visalia Quick Facts. Website: https://www.census.gov/quickfacts/visaliacitycalifornia. Accessed March 28, 2023.
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growth) and maintain adequate levels of service.
36 For the foregoing reasons, impacts would be less
than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Need for New or Altered Schools
Impact PUB-3: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools? Impact Analysis
Construction
Impacts related to provision of or need for construction of new or expanded school facilities are limited to operational impacts. No construction impacts would occur.

Operation
Upon annexation to the City, the project site would be located in the service areas for Denton Elementary School, Ridgeview Middle School, and Redwood High School of the VUSD.

As described in Section 4, Effects Found not to be Significant, the proposed project would result in some amount of indirect population growth due to the creation of employment opportunities during operation. Because there are no residential units proposed, the proposed project would not result in direct population growth and would not directly increase enrollment numbers in the VUSD. The proposed project is anticipated to generate a total of approximately 4,100 new employees at full buildout. Once operational, given the nature of the proposed project, the project site would likely be staffed by employees local to the City and nearby areas. Nonetheless, it is reasonable to assume that some number of employees could potentially transfer into the area as a result of the proposed project, resulting in a certain degree of indirect population growth.

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could be readily absorbed by the local housing inventory and/or the pending and approved residential projects in the City and the surrounding area. Because the proposed project would not result in substantial unplanned increase in population growth, and further because any such growth would be nominal at most, the proposed project would not increase school enrollment in such a way to trigger the need to construct new or expanded existing school facilities. Moreover, each individual specific development proposal for the proposed project would be required to pay school facility fees in accordance with the applicable Development Fee Schedule, which would reflect its pro rata fair share contribution to help ensure that local schools can meet any increased demand associated with the proposed project (and other planned growth) and maintain adequate levels of service. Pursuant to Government Code Section 65995, payment of adopted development fees is considered “full and complete mitigation” for impacts to school facilities, and local governments are prohibited from assessing additional fees or exactions for school impacts.

For the foregoing reasons, impacts in this regard would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Need for New or Altered Parks and Other Recreational Facilities Impact PUB-4: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental park facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks or other recreational facilities?
Impact Analysis
Construction
Impacts related to provision of and need for construction of new or expanded park facilities are limited to operational impacts. No construction impacts would occur.

Operation
The General Plan establishes the parkland standard of five acres per 1,000 residents.

The City recently approved the East Side Regional Park and Groundwater Recharge Project, which will provide approximately 139 acres of active recreational amenities and 130 acres of passive amenities in the eastern portion of the City. That project would contribute to the City’s park ratio goal. The proposed project would pay into the CIP to fund the East Side Regional Park and Groundwater Recharge Project and other future park projects to offset impacts to park and recreation facilities. As stated above, the Draft EIR for this project was certified by the City Council on November 20, 2023.
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The industrial and compatible commercial uses that would occur over time through implementation of the proposed project are part of the anticipated growth contemplated by the City in its General Plan, as indicated by the project site’s current Industrial and Light Industrial General Plan land use designations. Indirect population growth that occurs as a result of new employment opportunities (such as those that would occur pursuant to the proposed project) is considered planned growth. As noted above, the proposed project is anticipated to generate a total of approximately 4,100 new employees at full buildout and would likely be staffed primarily by local employees once operational.

The closest park to the project site is Lions Park, located approximately 0.40 mile southeast of the project site; this is a neighborhood park that contains amenities such as a playground and basketball court. While it is reasonable to assume that some employees would utilize park facilities during their workday to a certain degree, this use would be limited given the nature of the industrial and related commercial uses and the location of the project site. Project employees and their families would utilize the City’s park and recreational amenities, but the limited amount of demand generated by the proposed project would not trigger the need to construct new or expand existing park facilities.

Based on the foregoing reasons, operational impacts related to need for new or altered park and recreational facilities would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Need for New or Altered Other Public Facilities
Impact PUB-5: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental library facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities, such as libraries?
Impact Analysis
Construction
Impacts related to provision of and need for construction of new or expanded library facilities are limited to operational impacts. No construction impacts would occur.

Operation
The Visalia Branch Library in downtown Visalia serves the project area.

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As noted above, the proposed project is anticipated to generate a total of approximately 4,100 new employees at full buildout and would likely be staffed primarily by local employees once operational.

While it is reasonable to assume that some employees would utilize library facilities during their workday to a certain degree, this use would be limited given the nature of the industrial and related commercial uses and the location of the project site. Project employees and their families would use the library and its services, but the limited amount of demand generated by the proposed project would not trigger the need to construct new or expand existing library facilities.

Based on the foregoing reasons, operational impacts related to need for library facilities would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

3.13.7 - Cumulative Impacts
The geographic scope of the cumulative public service analysis is the service area of each of the public service providers serving the proposed project. Because of differences in the nature of the public service topical areas, they are discussed separately.

Cumulative projects (which consist of past, present and reasonably foreseeable future developments, including those listed in Table 3-1) in conjunction with the proposed project, would result in single- and multi-family residential, warehouse and distribution, commercial, and mixed-use development. All cumulative developments are within City jurisdiction or its UDB, within areas designated and zoned for urban development. While most planned future cumulative projects consist of warehouse and distribution development (and thus relate in only indirect population growth), the planned future residential projects would directly increase population within the City.

Need for New or Altered Fire Protection Facilities
The geographic scope of the cumulative fire protection and emergency medical services analysis is the VFD’s service area, which encompasses 37.49 square miles and 136,246 people. 37 An increase in population due to the relevant cumulative projects would result in an increased demand for fire protection and emergency medical services, which could trigger the need to construct new or expand existing fire protection facilities.

The General Plan projects a population growth of 85,000 new residents by 2030. To help offset this increased demand, the proposed project and other relevant cumulative projects would be required to pay all applicable plan review and development impact fees to the VFD. All cumulative developments would also be required to adhere applicable provisions of the California Fire Code, Part 9 of the CBC, in terms of meeting standards for fire safety such as fire flow requirements for 37 Visalia Fire Department (VFD). 2019. Information Sheet. Website:
https://www.visalia.city/civicax/filebank/blobdload.aspx?BlobID=37488. Accessed December 9, 2022. 2849
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buildings, fire hydrant location and distribution criteria, automated sprinkler systems, fire-resistant building materials, adequate access for emergency vehicles, and adequate emergency evacuation access. In addition, typical safety and security measures would be incorporated into the design and operation of cumulative developments. With adherence to applicable requirements and standards set forth in the CBC and otherwise incorporating typical safety and security measures, this would help to reduce cumulative impacts to fire protection and emergency response services.

Moreover, as part of the related environmental review process that may be necessary as part of the future development of such facilities, payment of applicable plan review and development impact fees would be anticipated to help fund any required expansion of fire protection and emergency medical services. To the extent construction of any new or expanded fire protection and emergency response facilities would be triggered by this increased demand, any impacts would be considered mitigated, to the extent feasible. Based on the foregoing, cumulative impacts with respect to new or altered fire protection facilities would be less than significant.

While the proposed project would generate an increased demand for fire protection and emergency response services, it would be typical for the type of uses proposed (i.e., industrial and compatible commercial); it would be required to adhere applicable provisions of the California Fire Code, Part 9 of the CBC, in terms of meeting standards for fire safety such as fire flow requirements for buildings, fire hydrant location and distribution criteria, automated sprinkler systems, fire-resistant building materials, adequate access for emergency vehicles, and adequate emergency evacuation access. The project would incorporate typical safety and security measures into its design and operation, and it would pay all applicable plan review and development impact fees to ensure its pro rata fair share contribution to support fire protection and emergency medical services.

Based on the foregoing, the proposed project would not have a cumulatively considerable contribution to the already less than significant cumulative impact related to fire protection and emergency medical services.

Need for New or Altered Police Protection Facilities
The geographic scope of the cumulative police protection analysis is the service area of the VPD, consists of the Visalia city limits. An increase in population as a result of the relevant cumulative projects would result in an increased demand for police protection services, which could trigger the need to construct new or expand existing police protection facilities.

Because demand for law enforcement services varies substantially by project (type of services offered, clientele, hours of operation, crime prevention measures, etc.), it is unlikely that there would be substantial overlap in demand that would result in a cumulatively significant impact such that new or expanded police protection facilities are necessary beyond the City’s existing capacity and regular review of service levels for future developments.

To help offset this increased demand, the proposed project and other relevant cumulative projects would be required to pay all applicable plan review and development impact fees to the VPD. In addition, typical safety and security measures would be incorporated into the design and operation of cumulative developments. With adherence to applicable requirements and standards and otherwise incorporating typical safety and security measures, this would help to reduce the need for 2850
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police protection. Moreover, payment of applicable plan review and development impact fees would be anticipated to help fund any required expansion of police protection. To the extent construction of any new or expanded police protection facilities would be triggered by this increased demand, impacts would be considered mitigated, to the extent feasible, as part of the related environmental review process that may be necessary as part of the future development of such facilities. Based on the foregoing, cumulative impacts with respect to new or altered police protection facilities would be less than significant.

While the proposed project would generate an increased demand for police protection, it would be typical for the types of uses proposed (i.e., industrial and compatible commercial) and would not be cumulatively considerable because: it would be required to adhere applicable standards set forth in Municipal Code Chapter 8 Health and Safety, and it would incorporate typical safety and security measures into its design and operation. Based on the foregoing, the proposed project would not have a cumulatively considerable contribution to the already less than significant cumulative impact related to police protection.

Need for New or Altered School Facilities
The geographic scope of the cumulative school facilities analysis is the service area of the VUSD, where over 32,000 students are enrolled. An increase in population as a result of the relevant cumulative projects would result in an increased student demand, which could trigger the need to construct new or expand existing school facilities.

The relevant cumulative developments include residential projects that would directly generate student demand. In addition, there may be some nominal student demand indirectly generated by the nonresidential cumulative developments, including the proposed project (i.e., employees transferring into the area). None of the relevant cumulative developments propose the construction of new educational facilities. To help offset this increased demand, the proposed project and other relevant cumulative projects would be required to pay all applicable plan review and development impact fees to the VUSD, which would be anticipated to help fund any required expansion of school facilities. To the extent construction of any new or expanded school facilities would be triggered by this increased demand, impacts would be considered mitigated, to the extent feasible, as part of the related environmental review process that may be necessary as part of the future development of such facilities. Based on the foregoing, cumulative impacts with respect to new or altered school facilities would be less than significant.

Since the proposed project does not involve any residential uses, it would not directly generate an increased demand for school facilities. To the extent some number of employees may transfer to the area, this type of indirect student demand generation would be expected to be nominal at most.

However, as noted above, payment of applicable development impact fees pursuant to State law would ensure its pro rata fair share contribution to support school facilities.

Based on the foregoing, the proposed project would not have a cumulatively considerable contribution to the already less than significant cumulative impact related to school facilities. 2851
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Need for New or Altered Park and Recreational Facilities The geographic scope of the cumulative park facilities analysis is the city limit. An increase in population the cumulative projects would result in an increased demand for park facilities. To help offset this increase, residential cumulative projects would be required to provide parkland or pay applicable development fees. With payment of applicable park impact fees and/or otherwise satisfying park dedication obligations by cumulative residential projects, there would be a less than significant cumulative impact related to additional increased use and physical deterioration of existing parks and recreational facilities.

Because the proposed project would not include the development of any residences, and therefore, would not increase the population in the area, the proposed project would not contribute to cumulative impacts associated with parks.

Need for New or Altered Library Facilities
The geographic scope of the cumulative libraries analysis is the City. An increase in population as a result of the relevant cumulative projects would result in an increased demand for library services, which could trigger the need to construct new or expand existing library facilities.

The relevant cumulative developments include residential projects that would directly generate demand for library services as well as nonresidential projects that could also indirectly generate demand as well (albeit minor in nature). To the extent construction of any new or expanded library facilities would be triggered by increased demand of new residential development, the related environmental review process and payment of fees would mitigate impacts to the library, to the extent feasible. Based on the foregoing, cumulative impacts with respect to new or altered library facilities would be less than significant.

Since the proposed project does not involve any residential uses, it would not directly generate an increased demand for library facilities. While some employees may periodically use the Visalia Branch Library, given the nature of the proposed uses and the location of the project site, any such increased demand would be nominal.

Based on the foregoing, the proposed project would not have a cumulatively considerable contribution to the already less than significant cumulative impacts associated with library facilities.

Mitigation Measures
No mitigation measures are required.

Level of Cumulative Significance
Less than significant impact.
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3.14 - Transportation

3.14.1 - Introduction
This section describes existing conditions related to transportation on the project site and in the project area as well as the relevant regulatory framework. This section also evaluates the potential impacts related to transportation that could result from implementation of the proposed project.

Information in this section is based, in part, on the project-specific Transportation Impact Analysis (TIA) and the project-specific Vehicle Miles Traveled (VMT) Analysis, included as Appendix I. One public comment was received during the Environmental Impact Report (EIR) scoping period related to transportation:
• San Joaquin Valley Air Pollution Control District, September 28, 2022–Construction and operational emissions may exceed significance thresholds, requiring mitigation measures to reduce VMT.

3.14.2 - Existing Conditions
Roadway Facilities
State
State Route 99
State Route (SR) 99 is a six-lane, north–south divided highway. SR-99 intersects SR-198 approximately 1 mile from the study area. The posted speed limit within the study area is 70 miles per hour (mph).

State Route 198
SR-198 is a four-lane, east–west divided highway connecting to U.S. Highway 101 (US-101) in the west near King City and SR-180 in the east at the Sequoia National Park entrance. SR-198 provides connection for residential, commercial, industrial, and agricultural land uses from the Central Coast to the Central Valley through the counties of Monterey, Fresno, Kings, and Tulare. SR-198 intersects the north–south routes Interstate 5 (I-5) and SR-99. The posted speed limit within the study area is 65 mph.

Local
Arterials
Plaza Drive
Plaza Drive is a classified arterial and a future Class II bike facility running north–south between Avenue 320 and SR-198. Plaza Drive is currently constructed as a four-lane, divided road. The speed limit ranges from 45 to 55 mph. Within the study area, there are limited existing bicycle and pedestrian improvements.

Shirk Street
Shirk Street is a classified arterial and a future Class II bike facility running north–south between Avenue 320 and Avenue 272. The roadway is currently constructed as a two-lane, undivided road.

The speed limit on the segment ranges between 40 to 45 mph. The roadway is classified as a 2853
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greenway and as a future Class II bike facility. There are limited pedestrian improvements and no existing bicycle features.

Akers Street
Akers Street is a classified arterial and a future Class III bike facility running north–south between Avenue 320 and Avenue 272. The roadway is currently constructed as a four-lane, divided road north of Visalia Parkway. South of West Visalia Parkway, the roadway is currently constructed as a twolane, undivided road. The speed limit on the segment ranges from 35 to 50 mph. Bike lanes are present between Porter Avenue and Ferguson Avenue. A sidewalk is present along a significant portion of the street but missing adjacent to undeveloped parcels.

Avenue 320
Avenue 320 is a classified arterial roadway running east–west between Road 38 and Road 108. The roadway is currently constructed as a two-lane, undivided road. There is no posted speed limit within the study area, therefore, the speed limit is 55 mph per County Ordinance. There are no existing bicycle features and limited pedestrian improvements.

Riggin Avenue
Riggin Avenue is a classified arterial roadway and future Class II bike facility running east–west between SR-99 and St. Johns Parkway. The roadway is currently constructed as a four-lane, divided road west of Kelsey Street. Between Demaree Street and Mooney Boulevard, the roadway is constructed as a four-lane, divided road. Between Mooney Boulevard and Dinuba Boulevard, the roadway is constructed as a two-lane, undivided road. Between Dinuba Boulevard and St. Johns Parkway, the roadway is constructed as a two-lane, undivided road. West of Linwood Street, there is no posted speed limit within the study area. Between Linwood Street and St. Johns Parkway, the posted speed limit ranges from 45 to 50 mph. There is no posted speed limit within the study area.

There are limited existing bicycle and pedestrian facilities.

Goshen Avenue
Goshen Avenue is a classified arterial roadway and existing Class I bike facility running east–west between SR-99 and Lovers Lane. The roadway is currently constructed as a four-lane, divided road.

The speed limit ranges from 35 to 55 mph. Within the study area, there are limited existing bicycle and pedestrian improvements. A Class I bike lane is present on the north side of Goshen, between SR-99 and South Giddings Street. There are limited pedestrian improvements on the south side of the road.

Collectors
Kelsey Street
Kelsey Street is a classified collector running north–south between Avenue 320 and Hurley Avenue.

The roadway is currently constructed as a two-lane, undivided road. There is a 2,300-foot section that is undeveloped south of Riggin Avenue to just north of Doe Avenue. There is no posted speed limit within the study area. There are no existing bicycle features and limited pedestrian improvements.
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Shannon Parkway-Riverway Avenue
Shannon Parkway-Riverway Avenue is a classified collector roadway running east–west between Akers Street and Demaree Street. The roadway is currently constructed as a two-lane, undivided road between Demaree Street and Mooney Boulevard, and a four-lane, divided road between Mooney Boulevard and Dinuba Boulevard. The segment between Demaree Street and Dinuba Boulevard has a posted speed of 40 mph. Outside of these limits, the speed limit is 55 mph per County Ordinance. There are no existing bicycle features and limited pedestrian improvements.

Study Area
The study area includes the main roadways and intersections around the project site that would be most impacted by the proposed project’s traffic volumes. The study intersections were selected in adherence with the City’s requirement of all site access drives, major intersections within 1 mile, either signalized or unsignalized, and driveways/intersections where traffic movements could be affected by new driveway traffic movements. Based on this coordination with City staff, the intersections shown in Table 3.14-1 were evaluated.

Table 3.14-1: Study Intersections
# Intersection # Intersection
1 North American Street/West Riggin Avenue
(S)
14 North Shirk Street/West Riggin Avenue (U)
2 North Plaza Drive/Avenue 320 (U) 15 North Shirk Street/ West Sunnyview Avenue and West Ferguson Avenue (U)
3 North Plaza Drive/West Riggin Avenue (S) 16 North Shirk Street/West Doe Avenue (U) 4 North Plaza Drive/West Ferguson Ave (S) 17 North Shirk Street/West Goshen Avenue (S) 5 North Plaza Drive/Future Access Road (U) 18 North Shirk Street/West Hurley Avenue (S) 6 North Plaza Drive/West Goshen Avenue (S) 19 North Roeban Street/West Riggin Avenue (U) 7 North Kelsey Street/Riverway Avenue and
Shannon Parkway (U)
20 North Roeban Street/West Ferguson Avenue
(U)
8 North Kelsey Street/West Riggin Avenue (S) 21 North Akers Street/Avenue 320 (U) 9 North Kelsey Street/West Goshen Avenue (S) 22 North Akers Street/Shannon Parkway (U) 10 Future North Clancy Street/Unnamed North
Road (U)
23 North Akers Street/West Riggin Avenue (S)
11 Future North Clancy Street/West Riggin
Avenue (U)
24 North Akers Street/West Ferguson Avenue (S)
12 North Shirk Street/Avenue 320 (U) 25 North Akers Street/West Goshen Avenue (S) 13 North Shirk Street/Shannon Parkway (U) 26 North Shirk Street/Shannon Parkway (U) Notes:
(S)–Signalized Intersection
(U)–Unsignalized Intersection
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Vehicle Level of Service
Although the California Environmental Quality Act (CEQA) now recognizes VMT as the primary analysis methodology for transportation impacts, intersection Level of Service (LOS) and queueing were also analyzed in this section. This analysis will determine the operational effects of nearby intersections as a result of the proposed project, to be installed by the subject development or to have the relevant contribution of a proportionate fair share be made by the subject applicant. This analysis is in accordance with applicable legal requirements related to nexus. The City is continuing to review traffic LOS as the means by which it plans for roadway improvements in support of its General Plan. LOS analysis is still appropriate and necessary to determine consistency with General Plan policies as they relate to LOS and to determine necessary roadway infrastructure improvements and capacity.

Analysis of intersection deficiencies were based on the concept of LOS, which is a qualitative measure used to describe operational conditions. LOS A (best) represents minimal delay, and F (worst) represents heavy delay and a facility that is operating at or near its functional capacity.

Intersection LOS for this study were determined using methods defined in the Highway Capacity Manual, 6th Edition (HCM 6) within the Synchro 11 analysis software. HCM 6 includes procedures for analyzing side street stop controlled (SSSC), all-way stop controlled (AWSC), and signalized intersections. The SSSC procedure defines LOS as a function of average control delay for the worst minor street movement or major street left turn. Conversely, the AWSC and signalized intersection procedures define LOS as a function of average control delay for the intersection as a whole. Table

3.14-2 relates the operational characteristics associated with each LOS category for signalized and unsignalized intersections.

Table 3.14-2: Signalized and Unsignalized Intersection LOS Criteria Level of
Service Description
Signalized
(Average control
delay per vehicle in
seconds/vehicle)
Unsignalized
(Average control
delay per vehicle in
seconds/vehicle)
A Free Flow or Insignificant Delays: Vehicles are completely unimpeded in their ability to maneuver within the traffic stream. Control delay at signalized intersections is
minimal.
<= 10.0 <= 10.0
B Stable Operation or Minimal Delays: The ability to
maneuver within the traffic stream is only slightly
restricted, and control delay at signalized intersections are not significant.
> 10 and < 20.0 >10 and < 15.0
C Stable Operation or Acceptable Delays: The ability to maneuver and change lanes is somewhat restricted, and
average travel speeds may be about 50 percent of the
free flow speed.
>20 and < 35.0 >15 and < 25.0
D Approaching Unstable or Tolerable Delays: Small
increases in flow may cause substantial increases in delay and decreases in travel speed.
>35 and < 55.0 >25 and < 35.0
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Level of
Service Description
Signalized
(Average control
delay per vehicle in
seconds/vehicle)
Unsignalized
(Average control
delay per vehicle in
seconds/vehicle)
E Unstable Operation or Significant Delays: Significant delays may occur and average travel speeds may be 33
percent or less of the free flow speed.
>55 and < 80.0 >35 and < 50.0
F Forced Flow or Excessive Delays: Congestion, high delays, and extensive queueing occur at critical signalized
intersections with urban street flow at extremely low
speeds.
> 80.0 > 50.0
Source: City of Visalia. Visalia General Plan Circulation Element.

Project deficiencies were determined by comparing conditions with the proposed project to those without the proposed project. Project-related deficiencies at study intersections are created when traffic from the proposed project causes the LOS to fall below the maintaining agency’s LOS threshold or causes deficient intersections to deteriorate further based on applicable thresholds.

The LOS threshold for the City’s intersections analysis is LOS D. A project-induced deficiency occurs if the addition of project traffic would cause an intersection operating at LOS A, B, C, or D, to begin to operate at LOS E or F. For intersections already operating at LOS E or F without project traffic, any addition of project traffic resulting in increased delay of 5.0 seconds or more would also result in a project deficiency.

Peak-Hour Turning Movement Volumes
Intersection turning movement volumes for the signalized study area intersections were collected during the typical 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m. commuter peak periods. For the unsignalized intersections, volumes were collected for a 14-hour period between 6:00 a.m. and 8:00 p.m. Data was collected at 18 of the study intersections in April and May 2022, when local schools were in session. Forty-eight-hour roadway directional volumes were also collected along Riggin Avenue, Kelsey Street, and Shirk Street, adjacent to the project site, for the development of driveway volumes. Vehicular classification was obtained from the intersection data.

Seven additional intersection turning movement volumes were collected in June 2022, after the summer break had commenced. To normalize this supplemental traffic data collected during the summer, 48-hour roadway counts were recollected at the same three locations along Riggin Avenue, Kelsey Street, and Shirk Street for determination of growth factor to be applied to summer volumes collected. Based on the assessment of roadway volumes collected in May and June, it was determined that the traffic volumes collected during the summer at the collected locations were higher for daily and AM and PM peak-hours. Therefore, a growth factor was not applied to the summer counts collected.
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Queueing
Queues that exceed the turn pocket length can create potentially hazardous conditions by blocking or disrupting through-traffic in adjacent travel lanes. However, these potentially hazardous queues are generally associated with left-turn movements. Locations where the right-turn pocket storage is exceeded are generally not considered hazardous because the right-turn movements generally receive “green indications” at the same time as the adjacent through movement. Therefore, any additional vehicles that spill out of the right-turn pocket will likely not hinder nor disrupt the adjacent through traffic, as would be the case in most left-turn pockets.

The effects of vehicle queueing for all exclusive turn-lanes were analyzed by reporting the 95th percentile queues. The 95th percentile queue length represents a condition where 95 percent of the time during the peak-hour, traffic queues are expected to be less than or equal to the queue length estimated by the analysis. This is referred to as the “95th percentile queue,” which is less than the average queueing. The 95th percentile queue length was determined using HCM 6 methodology via Synchro 11 Software.

Study Area
Unacceptable or extended queueing may be defined as spillover from turn pockets into through lanes and/or spillover into adjacent intersections. The City does not have specific thresholds for identifying a project-related queueing deficiency. The TIA assumed spillover when the estimated 95th percentile queue for a turn pocket exceeds available storage by more than one car length, or 25 feet. If a turn pocket is anticipated to exceed available storage under no-project conditions, the proposed project would be expected to cause constrained access for that movement if it increases the deficient queue by more than 25 feet.

Existing Public Transit Service and Facilities
Visalia Transit provides a local fixed route bus system for City residents and visitors, with multiple bus routes operating within the study area.

Study Area
Bus Routes
Route 6 is a local bus service that operates between the Visalia Transit Center and the Visalia Medical Clinic. On weekdays, the bus route operates from 6:00 a.m. to 9:55 p.m. On weekends, service is available from 8:00 a.m. to 6:55 p.m. Within the study area, the route runs along Akers Street between SR-198 and Goshen Avenue, and along Goshen Avenue east of Akers Street. The nearest bus stop to the study area is located at Visalia Medical Clinic.

Route 7 is a local bus service that operates between the Visalia Medical Center and Target Shannon Ranch. On weekdays, the bus route operates from 6:00 a.m. to 9:48 p.m. On weekends, service is available from 8:00 a.m. to 5:48 p.m. Within the study area, the route runs along Akers Street between SR-198 and Riggin Avenue, and along Riggin Avenue east of Akers Street. Bus stops within the study area are located near the intersections of Akers Street/Goshen Avenue and Akers Street/Riggin Avenue.
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Route 15 is a local bus service that operates between the Visalia Transit Center and Goshen Elementary School. On weekdays, the bus route operates from 6:00 a.m. to 10:20 p.m. On weekends, service is available from 7:30 a.m. to 6:35 p.m. Within the study area, the route runs along Shirk Street between SR-198 and Doe Avenue, Doe Avenue between Kelsey Street and Shirk Street, Goshen Avenue west of Kelsey Street, and Kelsey Street between Doe Avenue and Mineral King Avenue. A bus stop is located within the study near the intersection of Shirk Street/Doe Avenue.

Bus stops are also located near the study area at San Joaquin Valley College and along Mineral King Avenue.

Route 17 is a local bus service that operates between the Visalia Medical Clinic and the intersection Kelsey Street/Hillsdale Court. On weekdays, the bus route operates from 6:00 a.m. to 10:30 p.m. On weekends, service is available from 8:00 a.m. to 6:30 p.m. Within the study area, the route runs along Shirk Street north of SR-198, along Riggin Avenue between Shirk Street and Plaza Drive, and along Plaza Drive south of Goshen Avenue. Bus stops within the study area are located near the Kelsey Street/Riggin Avenue intersection and along Riggin Avenue east of Plaza Drive.

Table 3.14-3 provides a summary of the bus services in the study area.

Table 3.14-3: Existing Transit Service
Route Description
Weekdays Weekends
Operating Hours
Headway1
(minutes) Operating Hours
Headway1
(minutes)
6 Transit Center–Medical Clinic 6:00 a.m.–9:55 p.m. 60 8:00 a.m.–6:55 p.m. 60 7 Medical Clinic–Target 6:00 a.m.–9:48 p.m. 60 8:00 a.m.–5:48 p.m. 60 15 Transit Center–Goshen
Elementary School
6:00 a.m.–10:20
p.m.
45 7:30 a.m.–6:35 p.m. 45
17 Medical Clinic–
Kelsey/Hillsdale
6:00 a.m.–10:30
p.m.
30 8:00 a.m.–6:30 p.m. 30
Notes:

Table reflects transit schedule effective September 24, 2020 for Route 6 and Route 7, October 14, 2020 for Route 15, and October 10, 2021 for Route 17. 1 Headways are defined as the time between transit vehicles on the same route. Listed headways are the modes of the headways and rounded to the nearest 5 minutes.

Bicycle Facilities
California Department of Transportation (Caltrans) Highway Design Manual and National Association of City Transportation Officials Urban Bikeway Design Guide define four major types of bicycle facilities:
• Class I: Multiuse Path—These paths provide a completely separate right-of-way and are designated for the exclusive use of bicycles and pedestrians with vehicle cross-flow minimized. 2859
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• Class II: Bicycle Lane—These bicycle lanes provide a restricted right-of-way and are designated for the use of bicycles for one-way travel with a striped lane on a street or highway. These bicycle lanes are generally a minimum of 5 feet wide, and vehicle/pedestrian cross-flow is permitted.
• Class III: Bicycle Route with Sharrows—These bikeways provide right-of-way designated by signs or pavement markings for shared use with motor vehicles. These bikeways include sharrows or “shared-lane markings” to highlight the presence of bicyclists. • Class IV: Buffered Bicycle Lanes—These bicycle lanes consist of a physically separate lane for increased comfort and protection of bicyclists. These bicycle lanes can be physically separated by a barrier, such as planters or on-street parking, grade-separated from the roadway, or a painted buffer area. These can also be called cycle-tracks and can allow for one-way or twoway bicycle travel.

Project Site
Within the study area, there are limited existing bicycle improvements. New bike lanes are proposed along Riggin Avenue as part of the Riggin Avenue Widening and Improvements Capital Improvement Plan (CIP). The proposed project would construct Class II bike lanes adjacent to the project site along Kelsey Street, Clancy Street, and the west side of Shirk Street.

Pedestrian and Bike Facilities
Project Site
Within the study area, there are limited existing pedestrian improvements. Pedestrian access would be provided via new sidewalk constructed adjacent to the project site along the north side of Riggin Avenue, east side of Kelsey Street, both sides of Clancy Street, and west side of Shirk Street.

Pedestrian ramps and signalized crossings would be provided at the intersections of Kelsey Street and Riggin Avenue, Clancy Street and Riggin Avenue, and Shirk Street and Riggin Avenue. The proposed project would dedicate a 25-foot setback (measured from top toe of the bank) along Modoc Ditch to meet storm drain and flood control requirements. This setback would provide space for the planned Class I bikeway along the Modoc Ditch.

Emergency Access and Routes
Study Area
The Tulare County Preparedness Guide provides guidelines regarding disaster preparedness and evacuation planning for Tulare County residents.1 Although there are no specific designated evacuation routes, the recommended evacuation routes during an emergency would likely be main arterial roads into and out of the project vicinity, such as SR-198 in the east–west direction and SR99 in the north–south direction. Although not expressly designated as such, given their nature and location, these roads would likely act as the main evacuation routes into and out of the project vicinity.
1 Tulare County Office of Emergency Services (OES). 2011. Disaster Preparedness Guide. Website:
https://oes.tularecounty.ca.gov/sites/oes/assets/File/Tulare%20County%20Disaster%20Preparedness%20Guide%20(2011)%20- %20English.pdf. Accessed February 28, 2023.
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Project Site
Access to the proposed project would be established through the construction of 19 unsignalized driveways, which meet or exceed the minimum spacing requirements identified by the City’s Design and Improvement Standards. Emergency access would be provided via these 19 points.

3.14.3 - Regulatory Framework
Federal
No federal plans, policies, regulations, or laws related to transportation are applicable to the proposed project.

State
California Department of Transportation Level of Service Goals Caltrans builds, operates, and maintains the State highway system, including the interstate highway system. Caltrans’s mission is to improve mobility Statewide. The department operates under strategic goals to provide a safe transportation system, optimize throughput and ensure reliable travel times, improve the delivery of State highway projects, provide transportation choices, and improve and enhance the State’s investments and resources. Caltrans controls the planning of the State highway system and accessibility to the system. Caltrans establishes LOS goals for highways and works with local and regional agencies to assess impacts and develop funding sources for improvements to the State highway system. Caltrans requires encroachment permits from agencies for new development before any construction work may be undertaken within the State’s right-of-way. For projects that would impact traffic flow and levels of service on State highways, Caltrans reviews measures to mitigate the traffic impacts. SB 743 requires that project VMT be analyzed for CEQA purposes and determination of significant impacts. Caltrans has identified an LOS objective of C/D (i.e., on the “cusp” between levels of service C and D) as the acceptable service level for signalized intersections.

Senate Bill 743
In November 2017, the Governor's Office of Planning and Research (OPR) released a technical advisory containing recommendations regarding the assessment of VMT, proposed thresholds of significance, and potential mitigation measures for lead agencies to use while implementing the required changes contained in SB 743. Also in November 2017, OPR released the proposed text for Section 15064.3, “Determining the Significance of Transportation Impacts,” which summarized the criteria for analyzing transportation impacts for land use projects and transportation projects and directs lead agencies to “choose the most appropriate methodology to evaluate a project’s VMT, including whether to express the change in absolute terms, per capita, per household or in any other measure.” OPR recommends that for most instances a per service population threshold should be adopted and that a 15 percent reduction below that of existing development would be a reasonable threshold.

For land use projects, SB 743 provides applicants the ability to streamline transportation analysis under CEQA for qualifying urban infill development near major transit stops in metropolitan regions throughout the State. The legislation established a new CEQA exemption for a residential, mixed-use, or employment center project if it is: (1) proposed in a Transit Priority Area (TPA) (i.e., an area within 2861
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0.5 mile of a major transit stop that is existing or planned); (2) consistent with a specific plan for which an EIR was certified, and (3) consistent with the use, intensity, and policies of a Sustainable Communities Strategy (SCS) or Alternative Planning Strategy (APS) that is certified by the California Air Resources Board (ARB) as meeting its greenhouse gas reduction targets. In addition, SB 743 establishes that parking impacts of these projects are not considered significant impacts on the environment.

Accordingly, as of July 1, 2020, under the statute and CEQA Guidelines, localities are required to rely on VMT instead of traffic delay as the primary metric for evaluating transportation impacts in CEQA documents. The existence of automobile delay impacts, or the adequacy of an LOS analysis, is not a basis under CEQA for challenging an EIR (Citizens for Positive Growth & Preservation v. City of Sacramento (2019) 43 CA5th 609, 624).

Regional Regulations
Regional Transportation Plan/Sustainable Communities Strategy The Draft 2022 Regional Transportation Plan/Sustainable Communities Strategy (2022 RTP/SCS) for Tulare County was prepared by TCAG with the assistance of its member jurisdictions. The Regional Transportation Plan (RTP) is a long-range planning document that defines how the region plans to invest in the transportation system over 20+ years based on regional goals, multimodal transportation needs for people and goods, and estimates of available funding.

The SCS is a component of the RTP, required by SB 375, that sets forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, will reduce greenhouse gas (GHG) emissions from passenger vehicles and light trucks to achieve the GHG reduction targets set by the ARB. The future land use and transportation scenario presented in the SCS must accommodate forecast population, employment, and housing sufficient to meet the needs of all economic segments of population, including the State-mandated Regional Housing Needs Assessment (RHNA), while considering State housing goals.2
The plan sets priorities for funding and implementation of transportation-related projects throughout the County. The 2022 RTP/SCS identifies performance measures and indicators for transportation projects and improvements, including transit trips, peak-hour travel speed, cost of deferred street maintenance, and VMT.

Local Regulations
City of Visalia
Visalia General Plan Circulation Element
The Circulation Element of Visalia’s existing General Plan outlines the City’s standards for roadway design, improvements, and levels of service. The Circulation Element also calls for consistency and coordination of local transportation actions with State and County agencies and plans. It also 2 Tulare County Association of Governments (TCAG). 2022. Draft 2022 Regional Transportation Plan/Sustainable Communities Strategy (2022 RTP/SCS). Website: https://tularecog.org/tcag/planning/rtp/rtp-2022/. Accessed February 28, 2023. 2862
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considers other modes of travel and includes policies pertaining to aviation, rail, transit, and nonmotorized transportation (bicycle and pedestrian).

The General Plan sets the following goals and policies that are relevant to transportation in the Circulation Element:

Objective T-O-5 Plan and develop a transportation system for Visalia that contributes to community livability, recognizes and respects community characteristics, and minimizes negative impacts on adjacent land uses.

Policy T-P-22 Require all residential subdivisions to be designed to discourage use of local streets as a bypass to congested arterials, and when feasible, require access to residential development to be from collector streets.

Policy T-P-23 Require that all new developments provide right-of-way, which may be dedicated or purchased, and improvements (including necessary grading, installation of curbs, gutters, sidewalks, parkway/landscape strips, bike and parking lanes) other City street design standards. Design standards will be updated following General Plan adoption.

Policy T-P-24 Require that proposed developments make necessary off-site improvements if the location and traffic generation of a proposed development will result in congestion on major streets or failure to meet LOS D during peak periods or if it creates safety hazards.

Policy T-P-25 Require that where arterial streets are necessary through residential areas, residential development shall be oriented away (side-on or rear-on) from such streets and be properly buffered so that traffic carrying capacity of the street will be preserved and the residential environment will be protected from the adverse characteristics of the arterial street.

Policy T-P-26 Require that future commercial developments or modifications to existing developments be designed with limited points of automobile ingress and egress, including shared access, onto major streets.

Policy T-P-27 Work with Caltrans to modify the State Route 198 Route Concept Report to ensure that the facility is designated as a six-lane freeway from Downtown Visalia east to Lovers Lane.

Policy T-P-28 Promote traffic safety by requiring that ingress and egress to shopping centers be carefully designed, with minimal use of left-turn movements into and out of these centers.

Policy T-P-29 Require, where possible, that arterials and collectors form four-leg, right-angle intersections. Jogged, offset, and skewed intersections at major streets in near proximity shall be avoided, where possible.
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Policy T-P-34 Develop design and development standards to improve transit service in the community, such as wider sidewalks to accommodate bus stops and bus shelters at intersections; bus pads with shelter and shading vegetation; widened rights-ofway for buses; dedicated bus lanes; on-site transit stops for commercial public, institutional and industrial facilities; and bus facilities adjacent to daycare centers, schools, and major residential areas.

Policy T-P-35 Schedule public transportation improvement projects in the Capital Improvements Program.

Policy T-P-39 Develop bikeways consistent with the Visalia Bikeway Plan and the General Plan’s Circulation Element.
• Provide Class I bikeways (right-of-way for bicyclists and pedestrians separated from vehicles) along the St. Johns River, Cameron Creek, Packwood Creek, Mill Creek, Modoc Ditch, the Santa Fe Railroad right-of- way and the San Joaquin Railroad right-of-way.
• Provide Class II bikeways (striped bike lanes) along selected collector and arterial streets.
• Provide Class III bikeways (shared use bike routes) along selected local, collector, and arterial streets.

Policy T-P-41 Integrate the bicycle transportation system into new development and infill redevelopment. Development shall provide short term bicycle parking and longterm bicycle storage facilities, such as bicycle racks, stocks, and rental bicycle lockers. Development also shall provide safe and convenient bicycle and pedestrian access to high activity land uses such as schools, parks, shopping, employment, and entertainment centers.

Policy T-P-44 Increase the safety of those traveling by bicycle by:
• Sweeping and repairing bicycle paths and lanes on a regular basis; • Ensuring that bikeways are signed and delineated according to Caltrans or City standards, and that lighting is provided as needed;
• Providing bicycle paths and lanes on bridges and overpasses; • Ensuring that all new and improved streets have bicycle-safe drainage grates and are free of hazards such as uneven pavement or gravel; • Providing adequate signage and markings warning vehicular traffic of the existence of merging or crossing bicycle traffic where bike lanes and routes make transitions into or across roadways.

Policy T-P-45 Require that collector streets that are identified to function as links for the bicycle transportation system be provided with Class II bikeways (bike lanes) or signed as Class III bike route facilities.
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Policy T-P-48 Require construction of minimum sidewalk widths and pedestrian “clear zones” consistent with the Complete Streets cross-sections in this General Plan and with the City’s Engineering and Street Design Standards for each designated street type.

Policy T-P-50 Provide pedestrian facilities that are accessible to persons with disabilities and ensure that roadway improvement projects address accessibility and use universal design concepts.

Objective OSC-P-23 Where no urban development exists, maintain a minimum riparian habitat development setback from the discernible top of the bank—50 feet for both sides of the Mill, Packwood and Cameron Creek corridors and 25 feet for both sides of Modoc, Persian and Mill Creek Ditches—provided that where riparian trees are located within 100 feet of the discernible top of the banks of the Creek corridors and 50 from the banks for the ditches, the setback shall be wide enough to include five feet outside the drip line of such trees. Restore and enhance the area within the setback with native vegetation. • Where existing development or land committed to development prohibits the 50-foot setback on Mill, Packwood, and Cameron Creek corridors, provide the maximum amount of land available for a development setback. • Where existing development or land committed to development prohibits the 25-foot setback along Modoc, Persian, and Mill Creek Ditches, provide the maximum amount of land available for a development setback.

Visalia Active Transportation Plan
The Active Transportation Plan (ATP) is meant to provide the means to support active transportation, specifically bicycling and walking, as an alternative mode of transportation for work, daily activities, and recreational trips.

The Modoc Ditch Trail is listed in the ATP as a trail with opportunities for key linkages to other trails.

Overall Circulation System Planning
Objective T-0-4 Ensure that new development pays its fair share of the costs of new and improved transportation facilities.

Planned Improvement
Policy T-P-23 Require that all new developments provide right-of-way, which may be dedicated or purchased, and improvements (including necessary grading, installation of curbs, gutters, and sidewalks, parkway/landscape strips, bike and parking lanes) or other City street design standards. Design standards will be updated following General Plan adoption.
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Bicycle Transportation and Trails System
Policy T-P-39 Develop bikeways consistent with the Visalia Bikeway Plan and the General Plan’s Circulation Element.
• Provide Class I bikeways (rights-of-way for bicyclists and pedestrians separated from vehicles) along the St. Johns River, Cameron Creek, Packwood Creek, Mill Creek, Modoc Ditch, the Santa Fe Railroad right-of-way and the San Joaquin Railroad right-of-way.
• Provide Class II bikeways (striped bike lanes) along selected collector and arterial streets.
• Provide Class III bikeways (shared use bike routes) along selected local, collector, and arterial streets.

Development also shall provide safe and convenient bicycle and pedestrian access to high activity land uses such as schools, parks, shopping, employment, and entertainment centers.

Pedestrian Circulation
Policy T-P-48 Require construction of minimum sidewalk widths and pedestrian “clear zones” consistent with the Complete Streets cross-sections in this General Plan and with the City’s Engineering and Street Design Standards for each designated street type.

Policy T-P-50 Provide pedestrian facilities that are accessible to persons with disabilities and ensure that roadway improvement projects address accessibility and use universal design concepts.

Implementation Plan.

Policy 1.9 Require proposed new development to create landscape and lighting districts to fund the maintenance of infrastructure, including active transportation elements, along major roadways.

Policy 2.3 Include facilities that support active transportation in all new development projects.

This should include pedestrian/bicycle connections from contemporary subdivision designs to surrounding arterials and collectors, bicycle parking at shopping, employment, and recreational centers, and bikeways on new collector and arterial roadways.

Policy 2.5 Ensure that on-street parking does not conflict with Class II bike lanes, and restrict parking near intersections and crosswalks to improve visibility and enhance safety for pedestrians and bicyclists.
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Policy 2.6 Identify safety counter measures at areas of high collision activity. Recommend and implement safety improvements.

Policy 8.3 Encourage new large scale commercial, office, and industrial development to provide a variety of support facilities such as secure and convenient bicycle parking and shower/locker facilities.

Engineering Design and Improvement Standards
SD-3 of the City’s Engineering Design and Improvement Standards outlines the Sight Distance Requirements for Arterial and Collector Streets.

3.14.4 - Methodology
Impacts related to transportation resulting from implementation of the proposed project are discussed below. The impact analysis is based on the TIA and the VMT analysis prepared for the proposed project and review of the General Plan and the 2022 RTP/SCS. Additionally, the impact analysis is based on review of the City’s VMT Threshold and Implementation Guidelines and review of the applicable federal, State, and local policies and regulations.

Project VMT
Screening thresholds from the City’s VMT Guidelines related to the proposed land use is broken into the following three steps:

1. TPA Screening: As described in the OPR Technical Advisory, projects located within 0.5 mile from an existing major transit stop or within half of a mile from an existing stop along a highquality transit corridor can be screened out.

2. Low VMT Area Screening: Projects that are consistent with the City’s General Plan and are located within low VMT efficient areas can be screened out. These areas are identified in the City’s guidelines.

3. Low Project Type Screening: Projects that are consistent with the City’s General Plan and generate fewer than 1,000 daily trips could be considered not to lead to a significant impact and can be screened out. For projects that are not consistent with the City’s General Plan, the trip threshold is 500 daily trips.

A land use project must only meet one of the above screening thresholds to be presumed to not result in a significant impact under CEQA pursuant to SB 743. However, the proposed project does not meet any of the screening thresholds. Therefore, a complete VMT analysis is required to further evaluate the proposed project’s potential VMT impacts.

Because the project site would be annexed into the City, the evaluation of VMT was conducted in accordance with the City’s adopted VMT Thresholds and Implementation Guidelines, consistent with other recently approved/annexed projects. These guidelines provide direction to reviewing agency staff, consultants, and project applicants regarding the methodologies and thresholds to be used for VMT analysis within the City. The guidelines also provide basic principles for conducting VMT 2867
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analysis based on OPR Technical Advisory, with revisions made to reflect local characteristics of the City, specifically nonresidential/office/retail land uses.

The County’s thresholds of significance, as adopted by the City, are summarized below:
• Residential–exceeds a level of 16 percent below existing regional average VMT per capita; • Office–exceeds a level of 16 percent below existing regional average VMT per employee; • Retail–any net increase in total VMT;
• Other (consistent with some refinements made to reflect the predominantly rural character of General Plan)–any net increase in VMT per employee; and • Other (not consistent with General Plan)–exceeds a level of 16 percent below existing regional average VMT per employee.

Based on the available land use category options, it was determined that the proposed project would fall under the category of “Other” uses as the VMT related to the proposed project is primarily produced by industrial employees. As discussed in Chapter 2, Project Description, the proposed project involves an industrial use and is consistent with the Industrial and Light Industrial land use designations that currently apply to the project site and should be treated as “consistent with General Plan.”
Therefore, the proposed project would result in a significant CEQA transportation impact if the project VMT per employee exceeds the average VMT per employee for the Traffic Analysis Zone (TAZ) where the project is located.

For consistency with the City, the VMT metric for the proposed project conditions was calculated by using the same Tulare County Association of Governments (TCAG) Travel Demand Model and recommended methodology. TCAG model is a tool used to forecast travel patterns in Tulare County based on estimated future land use and roadway network changes, as well as determination of VMTs.

Trip Generation
Trip generation estimates are based on the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition. A trip is defined as a single or one-directional vehicle movement with either the origin or destination at the project site. In other words, a trip can be either “to” or “from” the site and therefore, a single visitor to a site is counted as two. Trips generated by the proposed project are estimated for the AM and PM commuter peak-hours between 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m. on a typical weekday. Trips generated were based on the average rates for ITE Land Use 130 (Industrial Park) for the warehouse buildings, ITE Land Use 151 (MiniWarehouse) for the mini-storage/RV parking, ITE Land Use 934 (Fast-Food Restaurant with DriveThrough) for the fast-food restaurant, Land Use 945 (Convenience Store with Gas Station) for the convenience market, and ITE Land Use 947 (Self-Service Car Wash) for car wash facility. Consistent with the Highway Capacity Manual (HCM) and the City of Visalia’s Procedures for Traffic Impact 2868
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Analysis (Updated March 2021), a Passenger Car Equivalent (PCE) of 2.0 was applied to the truck volumes to analyze their effects more accurately on roadway capacity and queueing.

Trip reductions were taken into account for internal capture and pass-by trips. With multiuse development, there is potential for interaction among uses within the site. These types of trips are considered internal to the site and are “captured” within the site. Typically, internal capture is derived by methodology and data set forth in the ITE Trip Generation Handbook, 3rd Edition.

However, these percentages exceed the 5 percent maximum reduction that is accepted by Caltrans.

Therefore, the VMT analysis conservatively assumes an internal capture of 5 percent maximum reduction that is accepted by Caltrans. Additionally, commercial uses like ITE Land Uses 934 and 945 generate pass-by trips. These trips represent vehicles already on the road that stop as they pass by the site on their route to another destination. For the purposes of the VMT analysis, pass-by trips enter and exit the project site at the project driveways but are not new/added trips on the external street and roadway network. Pass-By trip reductions are based on information from ITE Trip Generation Manual, 11th Edition, which recommend 50 percent/55 percent for Land Use 934, and 76 percent AM/75 percent PM for the Land Use 945. Since the half of the site east of Clancy Street is composed of mixed uses, internal capture and pass-by trip reductions are applied to the traffic generated by this side of the proposed project only.

Employment Generation
The proposed project is expected to generate 4,177 employees, which is estimated by comparing the ITE trip rate per employee to the expected daily traffic generated.3

3.14.5 - Thresholds of Significance
The lead agency utilizes the criteria in CEQA Guidelines Appendix G Environmental Checklist to determine whether transportation and traffic impacts are significant environmental effects. Would the project:
a) Conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway, bicycle and pedestrian facilities?
b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency access?

3.14.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the proposed project and provides mitigation measures where necessary.
3 For the purpose of conservative analysis, 4,180 employees were utilized in the VMT analysis. 2869
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Affect to Circulation System
Impact TRANS-1: Would the project conflict with a program plan, ordinance or policy of the circulation system, including transit, roadways, bicycle and pedestrian facilities? Impact Analysis
Construction
Bicycle
There are currently limited existing bicycle improvements on Plaza Drive, Riggin Avenue, and Goshen Avenue. A Class I bike lane is present on the north side of Goshen Avenue, between the SR-99 and South Giddings Street. There are no bicycle improvements on Kelsey Street, Shirk Street, Avenue 320, Avenue 316, or other roadways in the existing roadway network. There are no Class II or Class III facilities within the existing roadway network. Because there are no existing Class II or Class III bicycle facilities and limited Class I facilities, road construction of the proposed project would not result in the temporary closure of bicycle facilities during construction. Therefore, construction impacts related to circulation system performance in terms of bicycle facilities would be less than significant.

Pedestrian
There are currently limited pedestrian improvements on Plaza Drive, Kelsey Street, Shirk Street, Avenue 320, Avenue 316, Riggin Avenue and Goshen Avenue, including a sidewalk along the south side of Riggin Avenue. Because the existing pedestrian improvements are limited, construction of the proposed project would not result in significant impacts. Should any sidewalks be temporarily shut down during construction, there are alternative pedestrian facilities in the vicinity, and access to alternative pedestrian facilities would remain available. Therefore, construction impacts related to circulation system performance in terms of pedestrian facilities would be less than significant.

Transit
The nearest existing bus stops to the study area are located at Visalia Medical Clinic, near the intersections of Akers Street/Goshen Avenue and Akers Street/Riggin Avenue, near the intersection of Shirk Street/Doe Avenue, at San Joaquin Valley College, along Mineral King Avenue, near Kelsey Street/Riggin Avenue, and along Riggin Avenue east of Plaza Drive. Construction of the proposed project would not adversely affect or otherwise conflict with existing pedestrian access to these bus stops. Should any sidewalks be temporarily shut down during construction, there are alternative roadway connections to these bus stops, and pedestrian access to these bus stops would remain available throughout construction. Therefore, construction impacts related to circulation system performance in terms of transit facilities would be less than significant.

Operation
Bicycle
According to the TIA, no bicycle-related deficiencies are anticipated due to the proposed project.

Bicycle connectivity would be improved by the bike facilities that are proposed, including new bike lanes along Riggin Avenue and Class II bike lanes along Kelsey Street, Clancy Street, and Shirk Street.

Therefore, operational impacts related to circulation system performance in terms of bicycle facilities would be less than significant.
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Pedestrian
Proposed pedestrian improvements include new sidewalks, pedestrian ramps and signalized crossings. New sidewalk improvements would be located adjacent to the project site along the north side of Riggin Avenue, east side of Kelsey Street, both sides of Clancy Street, and west side of Shirk Street. The proposed project would also construct pedestrian ramps and signalized crossings at the intersections of Kelsey Street and Riggin Avenue, Clancy Street and Riggin Avenue, Shirk Street and Riggin Avenue. The proposed improvements are expected to enhance pedestrian connectivity.

The City‘s ATP requires a 25-foot setback for construction of appropriate storm drainage and flood control. In addition, the ATP relies on that setback for a planned Class I bikeway along the south side of the Modoc Ditch. The proposed project would comply with the City’s ATP by dedicating 28 feet for a pedestrian trail along the south side of Modoc Ditch. This is incorporated as Mitigation Measure (MM) TRANS-1. Per MM TRANS-2, storm drainage and waterways impact fees would be collected to allow the City to construct appropriate trails along waterways.

Therefore, no pedestrian-related deficiencies are anticipated due to the proposed project.

Operational impacts to pedestrian facilities associated with the proposed project would be less than significant.

Transit
Visalia Transit Route 17 provides services along Riggin Avenue. The separate, already-approved Riggin Avenue Widening and Improvements CIP that would be constructed by the City and other third parties involves the installation of an additional bus stop adjacent to the project site at the northwest corner of Shirk Street and Riggin Avenue. The proposed project would enhance connectivity to this future transit stop through its installation of the sidewalk and bicycle facilities discussed above. Therefore, no transit-related deficiencies are anticipated due to the proposed project. Operational impacts related to circulation system performance in terms of transit facilities would be less than significant.

Queueing
Intersection No. 3–Plaza Drive and Riggin Avenue
The LOS analysis shows this intersection is expected to operate at an acceptable LOS during the AM and PM peak periods of all Near-Term and Long-Term scenarios analyzed. Since LOS is acceptable and since the westbound left-turns movements are projected to just exceed 300 turning movements for the Near-Term (2028) Plus Project Buildout scenario (242 AM peak-hour/302 PM peak-hour), dual left-turn pockets are not suggested at this time. It is recommended that the proposed project modify the raised median to extend the existing westbound left-turn pocket by 100 feet, to provide 400-foot left-turn pocket. It is also recommended that the existing northbound right-turn stripe be extended to 300 feet. This is included as MM TRANS-3.

Intersection No. 14–Shirk Street and Riggin Avenue
The proposed project is expected to result in a queueing deficiency for the following conditions:
• Near-Term (2025) Plus Phase 1 (AM and PM peak-hours)–NBL/EBR • Near-Term (2026) Plus Phase 2 (AM and PM peak-hours)–NBL/EBR • Near-Term (2028) Plus Project Buildout (AM and PM peak-hours)–NBL/EBR 2871
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Under Near-Term (2025) Conditions Plus Phase 1, the proposed project is projected to cause a queueing deficiency since one or more queues would extend beyond the turn pockets, and since it would increase the queue length by more than 25 feet. Under the ensuing scenarios, the queueing increases further. This is included as MM TRANS-4.

3.14.7 - LOS Analysis
Level of Service
The General Plan Policy TC-1.16 and the City TIA Guidelines set a minimum acceptable LOS standard of LOS D. According to the TIA, a LOS operational analysis was conducted in accordance with the significance criteria provided in the City’s TIA Guidelines. Project deficiencies were determined based on criteria established in the City’s TIA Guidelines.

Existing (2022) Conditions
The intersection LOS analysis results under Existing (2022) Conditions shows that all intersections are expected to operate at LOS D or better during the commuter peak periods. Construction of the proposed project would not adversely affect or otherwise conflict with the existing LOS conditions.

Near-Term (2025) Conditions
Under Near-Term (2025) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–PM peak-hour). • Intersection No. 19–Roeben Street and Riggin Avenue (LOS F–AM peak-hour and PM peakhour). • Intersection No. 23–Akers Street and Riggin Avenue (LOS E–AM peak-hour/LOS F–PM peakhour).

Near-Term (2025) Conditions Plus Phase 1
Under Near-Term (2025) Conditions Plus Phase 1, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and West Ferguson Avenue (LOS F–PM peak-hour). • Intersection No. 19–Roeben Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS E–AM peak-hour and peak-hour). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Near-Term (2026)
Under Near-Term (2026) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–PM peak-hour). • Intersection No. 19–Roeben Street and Riggin Avenue (LOS F–AM peak-hour and PM peakhour). 2872
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• Intersection No. 23–Akers Street and Riggin Avenue (LOS E–AM peak-hour/LOS F–PM peakhour).

Near-Term (2026) Plus Phase 2
Under Near-Term (2026) Conditions Plus Phase 2, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS E–AM peak-hour/LOS F–PM peakhour). • Intersection No. 19–Roeben Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS E–AM peak-hour/LOS F–PM peakhour). • Intersection No. 24–Akers Street Ferguson Avenue (LOS E–AM peak-hour).

Near-Term (2028) Level of Service
Under Near-Term (2028) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F– PM peak-hour). • Intersection No. 23–Akers Street and Riggin Avenue (LOS E–AM peak-hour/LOS F–PM peakhour). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Near-Term (2028) Plus Project Buildout
Under Near-Term (2028) Conditions Plus Project Buildout, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hours).

Long-Term (2033)
Under Long-Term (2033) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–PM peak-hour) • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hour) • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour) Long-Term (2033) Plus Project Buildout
Under Long-Term (2033) Conditions Plus Project Buildout, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
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• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Long-Term (2038)
Under Long-Term (2038) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–PM peak-hour). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Long-Term (2038) Plus Project Buildout
Under Long-Term (2038) Conditions Plus Project Buildout, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Long-Term (2048)
Under Long-Term (2048) Conditions, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–PM peak-hour). • Intersection No. 20–Roeben Street and Ferguson Avenue (LOS E–PM peak-hour). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

Long-Term (2048) Plus Project Buildout
Under Long-Term (2048) Conditions Plus Project Buildout, all intersections are expected to operate at LOS D or better during the commuter peak periods with the exception of:
• Intersection No. 15–Shirk Street and Ferguson Avenue (LOS F–AM and PM peak-hours). • Intersection No. 20–Roeben Street and Ferguson Avenue (LOS F–AM and PM peak-hours). • Intersection No. 23–Akers Street and Riggin Avenue (LOS F–AM and PM peak-hours). • Intersection No. 24–Akers Street and Ferguson Avenue (LOS E–AM peak-hour).

According to the LOS operational analysis, the proposed project would result in queueing deficiencies at several intersections and would require implementation of the improvements recommended in the TIA. These recommendations are incorporated as the following mitigation measuresto reduce project impacts related to LOS. With implementation of MM TRANS-1 through MM TRANS-8, impacts would be less than signficant.
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Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
MM TRANS-1 Prior to the issuance of building permits, the project shall comply with the City’s Active Transportation Plan (ATP) and dedicate 28 feet for a pedestrian trail along the south side of Modoc Ditch.

MM TRANS-2 Prior to the building permits, the developer shall appropriate Storm Drainage and Waterways impact fees.

MM TRANS-3 Plaza Drive and Riggin Avenue: Prior to the issuance of grading permits the proposed project shall provide site plans that show modification of the raised median to extend the existing westbound left-turn pocket by 100 feet, to provide a 400-foot left-turn pocket. The existing northbound right-turn stripe shall be extended to 300 feet. These improvements shall occur in the year 2026. The project proponent shall be financially responsible for these improvements. “Financially responsible” shall equate to implementing the project as well as paying for the project.

MM TRANS-4 Shirk Street and Riggin Avenue: The proposed project shall provide dual northbound left-turn pockets (300-foot minimum) and a 300-foot minimum southbound left-turn pocket. Since a 300-foot eastbound right-turn pocket would already be installed by the Capital Improvement Plan (CIP) project, additional recommendations are not proposed. These improvements shall occur in the year 2025. The project’s contribution to the Transportation Impact Fees (TIF) will assist in paying for these improvements.

MM TRANS-5 Shirk Street and Ferguson Avenue: Prior to the issuance of final occupancy of any project area, the proposed project shall signalize the intersection, subject to pro rata cost sharing with the adjacent Carlton Acres Specific Plan project. This improvement would allow the intersection to operate at an acceptable Level of Service (LOS) for the deficient scenarios, while reducing the vehicles queues for all intersection turn pockets below the storage capacity. Costs of implementing MM TRANS-5 are expected to be shared by Carlton Acres Specific Plan (CASP) and the proposed project as it provides access to both sites.

MM TRANS-6 Roeben Street and Ferguson Avenue: Prior to final occupancy of any portion of Phase 3, the proposed project shall make a 26.2 percent fair share contribution toward signalizing this intersection. Based on the estimated signalization and interconnect cost of $500,000, the proposed project shall contribute up to $131,000 for these future improvements.

MM TRANS-7 Akers Street and Riggin Avenue: The proposed project shall provide an additional northbound left-turn pocket and through lane and provide an additional eastbound/westbound through lane. Costs of implementing MM TRANS-7 are expected to be shared by Carlton Acres Specific Plan (CASP), the proposed project, and others as it provides access to multiple sites under development. 2875
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MM TRANS-8 Akers Street and Ferguson Avenue: The proposed project shall provide an additional northbound/southbound through lane and right-turn pocket (150-foot minimum) and provide an eastbound right-turn pocket (150-foot minimum). Costs of implementing MM TRANS-8 are expected to be shared by Carlton Acres Specific Plan (CASP) and the proposed project as it provides access to both sites.

MM TRANS-9 Akers Street and Goshen Avenue: The proposed project shall modify the raised median to extend the existing southbound left-turn pocket to 400 feet. It is not recommended to exceed this length further in order to maintain access to the existing driveway north of the intersection. The existing southbound right-turn stripe shall be extended to 400 feet minimum. Costs of implementing MM TRANS-9 are expected to be shared by Carlton Acres Specific Plan (CASP) and the proposed project as it provides access to both sites.

Level of Significance After Mitigation.

Less than significant impact with mitigation incorporated.

Conflict with CEQA Guidelines Section 15064.3, Subdivision (b) Impact TRANS-2: Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Impact Analysis
The VMT analysis identified project-related VMT impacts based on applicable criteria within the City VMT Guidelines and recommended feasible mitigation measures to address any identified VMT impacts. VMT refers to the amount and distance of automobile travel that is, “attributable to a project.” The proposed project will be built in three phases over a period of approximately 4 years.

However, for the purposes of the VMT analysis, only the project's full buildout condition was assessed to fully capture the project's VMT impacts in the region.

As shown in Table 3.14-4 below, It is estimated that Phase 1 of development would generate approximately 7,347 daily PCE trips, with 709 PCE trips (548 inbound/161 outbound) during the AM commuter peak-hour and 709 trips (167 inbound/542 outbound) during the PM commuter peakhour. It is estimated that the proposed project’s Phase 1 and 2 developments (combined) would generate approximately 17,790 daily PCE trips, with 1,183 PCE trips (870 inbound/313 outbound) during the AM commuter peak-hour and 1,162 trips (315 inbound/847 outbound) during the PM commuter peak-hour. It is estimated that buildout of the proposed project (Phase 1, 2 and 3 combined) would generate a total of approximately 21,409 daily PCE trips, with approximately 1,508 PCE trips (1,119 inbound/389 outbound) during the AM commuter peak-hour and approximately 1,495 trips (399 inbound/1,097 outbound) during the PM commuter peak-hour. 2876
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Table 3.14-4: Trip Generation Summary
Phase Daily PCE Trips AM Peak-hour Trips PM Peak-hour Trips 1 7,347 709 709
1 and 2 17,790 1,183 1,162
1, 2, and 3 21,409 1,508 1,495
Notes:

PCE = Passenger Car Equivalent
Source: Kimley-Horn. 2023. Transportation Impact Analysis Shirk & Riggin Industrial Park. October.

In addition, the proposed project is expected to generate 4,177 employees. 4 Based on the City’s SB 743 Guidelines, the proposed project would have a significant impact if it does not meet screening thresholds and if the average VMT/employee would be greater than or equal to the VMT/employee of the TAZ in which the project is located. The proposed project would not meet any of the screening criteria that would allow it to be presumed to have a less than significant impact. Therefore, a VMT analysis was performed.

The proposed project is expected to increase VMT per employee within the TAZ it is located by approximately 0.15 mile, or 1.54 percent of the total miles traveled. Therefore, the proposed project would result in a significant VMT impact, requiring mitigation.

MM TRANS-10a and MM TRANS-10b would be implemented in order to reduce VMT impact.

Combining these two mitigation measures would reduce the proposed project’s VMT per employee by 1.75 percent, exceeding the proposed project’s 1.54 percent impact. Therefore, the proposed project’s VMT impact would be mitigated.

In addition to the proposed mitigation measures, VMT is expected to be further reduced with the construction of the adjacent Carlton Acres development, which contains a high number of residential units. The interaction between the proposed project’s employment opportunities adjacent to the added residential units was not considered by the TCAG travel demand model, but would further reduce VMTs. Additionally, the construction of a bike path along Modoc Ditch is expected to reduce the miles traveled of nearby existing and future developments as it provides an important bicycle and pedestrian connection for the City and County.

Level of Significance Before Mitigation
Potentially significant impact.
4 For the purpose of conservative analysis, 4,180 employees were utilized in the VMT analysis. 2877
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Mitigation Measures
MM TRANS-10a Prior to the issuance of building permits, the site plan shall include the location of up to six secured bicycle storage lockers near each of the buildings entrances and the future transit stop. Up to 10 potential locations shall be included, for a total of up to 60 lockers throughout the site.

Lockers shall be provided for approximately 1.5 percent of the 4,178 site’s daily employees with flexibility to add future lockers based on demand.

MM TRANS-10b Prior to final occupancy of any portion of Phase 1, the developer shall construct a bike path along Modoc Ditch, between Kelsey Street and Shirk Street (approximately 1-mile).

The existing Class I bike path along Modoc ditch runs to the east of the proposed project, between Dinuba Boulevard and the St. John’s River Trail. The Carlton Acres Specific Plan (CASP) project also proposed to construct a portion of the Class I path within the site. Therefore, the bike path shall connect to a new path proposed within the CASP site and future segments to the east and west. This mitigation is subject to contractability and approval by Cal Water.

Level of Significance
Less than significant impact with mitigation incorporated.

Hazards
Impact TRANS-3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Impact Analysis
Construction
Construction of the proposed project would require regular deliveries of equipment and materials to the project site as well as daily trips by construction workers. Given the location of the project site, construction traffic would be expected to access the project site from Riggin Avenue via SR-99. This routing would generally avoid residential streets. For the purposes of the TIA and in accordance with the applicant’s project development goals, construction of the proposed project is anticipated to begin in March 2024 and be completed in March 2028, with operations commencing upon the completion of construction of the proposed project. However, the resulting daily and peak-hour traffic volumes during the construction period are anticipated to be less than during project operation as analyzed in the TIA. It should be noted that while the construction schedule assumes that none of the three project phases may overlap, the potential remains for project phases to be constructed concurrently. Therefore, a conservative analysis considers both scenarios (i.e., sequential and concurrent phasing). In a reasonable worst-case scenario where all three project phases overlap, it is estimated that construction traffic would result in less than 50 percent of the trips generated under Phase I development analyzed in the TIA. 2878
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During construction, the proposed project would require the delivery of heavy construction equipment using area roadways, some of which may require transport by oversize vehicles. Heavy equipment associated with these components would not be hauled to/from the site daily, but rather would be hauled in and out on an as needed basis. Nevertheless, the use of oversize vehicles during construction could create a hazard to the public by limiting motorist views on roadways and by the obstruction of space, which is considered a potentially significant impact. In addition, the project construction activities may result in some temporary lane closures in the area. The proposed project would be required under existing regulations to obtain California Highway Patrol escorts, as well as coordinate the timing of transport, in oversize load permits from Caltrans and Kings County, as appropriate. Therefore, a reasonable worst-case concurrent construction of all phases would not worsen the LOS or impact traffic movement or create roadway hazards to a greater extent than the project as analyzed in the TIA.

Furthermore, MM TRANS-11, would require standard construction traffic control measures be implemented as is consistent with applicable Caltrans and City policies. Measures would require the preparation and implementation of a Construction Traffic Control Plan that would reduce the potential for construction vehicle conflicts with other roadway users. Therefore, construction impacts related to roadway safety hazards would be less than significant with mitigation incorporated.

Operation
A sight distance analysis for each project driveway was conducted to determine whether outbound vehicles would have adequate sight distance to observe conflicting traffic along the intersecting public roadways. Intersection sight distance for the project driveways were evaluated following methodology outlined by the City of Visalia Design and Improvement Standard SD-3, which is based on guidance outlined by the American Association of State Highway and Transportation Officials, A Policy on Geometric Design of Highway and Street, 7th Edition. The proposed project would be required to satisfy the required sight lines and clear zone requirements for all project driveways, to ensure roadway hazards are minimized.

Additionally, a collision analysis was conducted as part of the TIA. The collision analysis determined any historic trends that may indicate existing safety hazards present in the study area. Collision data was obtained from the Statewide Integrated Traffic Record System (SWITRS) between January 1, 2018 to December 31, 2020. Over the 3-year period, there was a total of 74 documented collisions, mostly occurring along Goshen Avenue. The most common collision type was a broadside collision.

On the proposed project’s frontage, along Riggin Avenue and Shirk Road, a total of 11 collisions occurred during the same time period. The most common collision type was a hit object collision.

The study intersections with the most collisions over the 3-year period are the following:
• Intersection No. 6–Plaza Drive and Goshen Avenue
- 10 collisions (most common collision was rear end)
• Intersection No. 12–Shirk Street and Avenue 320
- 12 collisions (all collisions were broadside)
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• Intersection No. 25–Akers Street and Goshen Avenue
- 11 collisions (most common collision was rear end).

Considering the generally low traffic volumes at Shirk Street and Avenue 320, the 12 collisions indicate a much higher accident frequency than the rest of study area and a potential safety concern. The County has installed large “STOP” signs and advance “STOP AHEAD” signs on each intersection approach. A street light has also been approved for the intersection, which is currently awaiting approval from the Southern California Edison (SCE). No further intersections are required.

Access to the project site would be provided via 19 new driveways and would contain an internal network of drive aisles. The entrances and roadways providing access to the proposed project would be required to obtain City encroachment permits, comply with applicable provisions of the City’s Fire Code and other applicable laws and regulations and would implement improvement measures and would thus operate at acceptable service levels. Furthermore, proposed roadway improvements would further increase roadway safety by being designed according to applicable City, Caltrans, and industry standards. Therefore, impacts associated with roadway design safety hazards would be less than significant.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
MM TRANS-11 Prior to the issuance of construction permits, the project developer shall prepare and submit a Construction Traffic Control Plan to the City of Visalia for approval and implement the approved Construction Traffic Control Plan during construction. The Construction Traffic Control Plan shall be prepared in accordance with both the California Department of Transportation Manual on Uniform Traffic Control Devices and Work Area Traffic Control Handbook and shall include, but not be limited to, the following issues:
a. Timing of deliveries of heavy equipment and building materials; b. Directing construction traffic with a flag person;
c. Placing temporary signing, lighting, and traffic control devices if required, including, but not limited to, appropriate signage along access routes to indicate the presence of heavy vehicles and construction traffic; d. Ensuring access for emergency vehicles to the project site; e. Temporarily closing travel lanes or delaying traffic during materials delivery, transmission line stringing activities, or any other utility connections; f. Maintaining access to adjacent property; and,
g. Specifying both construction-related vehicle travel and oversize load haul routes, minimizing construction traffic during the AM and PM peak-hour, distributing construction traffic flow across alternative routes to access the project sites, and avoiding residential neighborhoods to the maximum extent feasible.
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Level of Significance After Mitigation
Less than significant impact with mitigation incorporated.

Emergency Access
Impact TRANS-4: Would the project result in inadequate emergency access? Impact Analysis
Construction
As discussed above, project construction activities could result in potential vehicular access issues due to potential temporary road detours and/or closures to accommodate the proposed project, which could impede emergency access. MM TRANS-11 would require the preparation and implementation of a Construction Traffic Control Plan that would reduce the potential for construction vehicle conflicts with other roadway users. The Construction Traffic Control Plan would so include measures to ensure that construction would not interfere with emergency response or evacuation plans. With implementation of MM TRANS-11, less than significant impacts are anticipated. Therefore, no significant impacts to vehicular and emergency access would occur during construction activities.

Operation
Several factors determine whether a project has sufficient access for emergency vehicles, including:
• Location of closest fire stations.
• Number of access points (both public and emergency access only). • Width, height, and turning radius of access points.
• Width, height, and turning radius of internal roadways.

Each of these factors is discussed in further detail below.

Fire Station 55 is the nearest Visalia Fire Department (VFD) station, located approximately 0.39 mile south of the project site at 6921 West Ferguson Avenue. Primary fire protection access to the project site would occur from existing roadways that would not be changed as part of the proposed project.

Vehicular access for the proposed project consists of 19 driveways, 18 of which would be unsignalized, that would intersect the public streets, detailed below:
• Phase 1
- Kelsey Street: five full-access driveways
- Clancy Street: four full-access driveways
• Phase 2
- Riggin Avenue: one limited-access driveway
- Riggin Avenue: one right-in/right-out driveway
- Clancy Street: four full-access driveways
- Shirk Street: one right-in/right-out driveway
• Phase 3
- Riggin Avenue: one limited-access driveway
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- Shirk Street: one right-in/right-out driveway
- Shirk Street: one limited-access driveway
An internal network of drive aisles would connect the overall project. Proposed off-site roadway improvements would be constructed by the proposed project along Riggin Avenue, Kelsey Street, Clancy Street and Shirk Street, and City encroachment permits would be obtained prior to the start of construction.

The provision of these access points would satisfy the applicable California Fire Code’s emergency access requirements. Moreover, the width of these access points and internal roadways would adhere to all other applicable local and State requirements and standards to ensure that access roadways can accommodate fire apparatus vehicles and adequate turning radius, including Section 503, Fire Apparatus Access Roads, of the California Fire Code,
5 as well as Chapter 8.20 of the Visalia Municipal
Code.
6 For the foregoing reasons, impacts related to adequate emergency access would be less than significant with mitigation implemented.

Mitigation Measures
Implementation of MM TRANS-11.

Level of Significance After Mitigation
Less than significant impact with mitigation incorporated.

3.14.8 - Cumulative Impacts
The geographic scope of the cumulative transportation analysis is the roadway network and the transit, pedestrian, and bicycle facilities in the vicinity of the project site. Cumulative projects analyzed here are developments identified by City to be in the planning process or approved, but not constructed (Exhibit 3-1). Transportation impacts tend to be localized, depending on trip generation and as detailed by traffic distribution. Therefore, the transportation network in the vicinity of the project site would be most affected by project activities. This analysis evaluates whether the impacts of the proposed project, together with the impacts of cumulative development, would result in a cumulatively significant impact related to transportation. This analysis then considers whether incremental contribution to cumulative impacts associated with the implementation of the proposed project would be significant. Both conditions must apply for a proposed project’s cumulative effects to rise to a level of significance.

Transit, Bicycle, and Pedestrian Circulation and Facilities With respect to transit facilities, should construction or operation of the cumulative projects temporarily or permanently conflict with existing transit connections, each project sponsor for the relevant cumulative project(s) would be required to coordinate with the City and the transit providers to provide alternative transit access.
5 International Code Council, Digital Codes. 2020. 2019 California Fire Code, Title 24, Part 9 with Jan 2020 Errata. Website:
https://codes.iccsafe.org/content/CFC2019P2. Accessed May 2, 2023. 6 City of Visalia. 2019. Visalia Municipal Code Chapter 8.20, California Fire Code. Website:
https://codelibrary.amlegal.com/codes/visalia/latest/visalia_ca/0-0-0-25779. Accessed May 2, 2023. 2882
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With respect to pedestrian and bicycle facilities, Cumulative Projects 1, 2, 4, 6, and 7 share a street with the proposed project. Since the project area contains many agricultural uses that did not require frontage improvement, there are limited existing pedestrian and bicycle facilities. The proposed project would dedicate a 28-foot setback for a pedestrian trail along the south side of Modoc Ditch. This is incorporated as MM TRANS-1 Neither the proposed project nor the cumulative projects would remove existing bicycle or pedestrian infrastructure or make a cumulatively considerable contribution to this less than significant cumulative impact. Moreover, as part of the proposed project’s frontage improvements, the proposed project would construct new bike lanes along Riggin Avenue and Class II bike lanes along Kelsey Street, Clancy Street, and Shirk Street, which would improve pedestrian and bicycle infrastructure. Therefore, cumulative impacts related to the circulation system in terms of transit, bicycle, and pedestrian facilities would be less than significant.

Level of Service
As discussed in Impact TRANS-1, all intersections in the study area operate at an acceptable LOS under existing conditions. Under Near-Term (2025) Conditions and later, even without the proposed project, three of the intersections studied are expected to operate below acceptable levels of service. The proposed project would result in a net increase of 21,409 daily trips, including 1,508 trips during the morning peak-hour and 1,495 trips during the afternoon peak-hour. The proposed project would contribute trips already operating below acceptable LOS standards. However, with implementation of MM TRANS-3 through MM TRANS-9, impacts would be less than significant.

Cumulative Projects listed in Table 3-1 would also generate new vehicle trips that may trigger or contribute to unacceptable intersection, roadway, and freeway operations. All projects would be required to mitigate their fair share of impacts. Therefore, the proposed project, in conjunction with other projects, would result in a cumulatively less than significant impact with mitigation incorporated.

Vehicle Miles Traveled
Transportation impact analysis is inherently cumulative because it is important to analyze a project’s impact within the context of existing and future traffic conditions to which all projects contribute and, where appropriate, provide mitigation measures to reduce a project’s contribution to any cumulative significant impacts identified to the degree feasible. Cumulative impacts associated with transportation are analyzed throughout this section. Cumulative projects would be required to comply with applicable State and local laws and regulations. If found to result in significant VMT impacts, the cumulative projects would be required to implement feasible Transportation Demand Management (TDM) measures that would reduce VMT and encourage alternative modes of transportation, such as transit, bicycle use, and walking. The provision of transit, bicycle, and pedestrian facilities would depend on the nature of the cumulative project at issue and its location.

Cumulative projects would also be required to include facilities and provide TDM measures based on future transportation studies prepared for that project. Because the proposed project’s VMT impacts are less than signficant with mitigation incorporated, the proposed project’s contribution would not be cumulatively considerable.
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Roadway Safety and Emergency Access
Trucks used during the construction of cumulative projects, including those listed in Table 3-1, Chapter 3, Environmental Impact Analysis, would be required to utilize truck routes designated by the City and therefore would not conflict with the automobile traffic and bicycle and pedestrian activity along public streets. In addition, the relevant local engineering and planning departments would review project plans prior to construction permits in order to determine whether any construction traffic control plans would be required and would require the implementation of same, as necessary.

If any cumulative projects, including those listed in Table 3-1, would redesign City streets in such a way that would significantly impact roadway safety, they would be required to mitigate such impacts as feasible. Roadways constructed as part of the cumulative projects would be constructed to meet applicable City and California Fire Code design standards. Cumulative project driveways and access points would be constructed in compliance with applicable provisions of the California Fire Code and other applicable regulations related to roadway safety and emergency access. As such, cumulative roadway safety and emergency access impacts would be less than significant. Further, as described more fully above, the proposed project, in conjunction with other cumulative projects, would not make a cumulatively considerable contribution to this less than significant cumulative impact associated with roadway safety or emergency access with the implementation of MM TRANS-12.

As described in Impact TRANS-3, the proposed project would be required to implement MM TRANS11 (Construction Traffic Control Plan) and MM TRANS-11 (fund additional safety roadway feature).

The proposed project’s contribution to the less than significant cumulative impact would not be cumulatively considerable with implementation of MM TRANS-8 and MM TRANS-9. As such, the proposed project, in conjunction with other cumulative projects, would have a less than significant cumulative impact with respect to roadway safety and hazards, and the proposed project’s contribution would not be cumulatively considerable.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
Implementation of MM TRANS-1 though TRANS-11.

Level of Cumulative Significance After Mitigation
Less than significant cumulative impact with mitigation incorporated. 2884
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3.15 - Utilities and Service Systems

3.15.1 - Introduction
This section describes the existing conditions related to utilities and service systems (water, wastewater, stormwater, solid waste, electric power, natural gas, and telecommunications facilities) in the City and project area as well as the relevant regulatory framework. This section also evaluates the possible impacts related to such utilities and service systems that could result from implementation of the project. Information in this section is based, in part, on information provided in the Water Supply Assessment (WSA) (Appendix J), 2020 Urban Water Management Plan (2020 UWMP), the California Department of Resources Recycling and Recovery (CalRecycle), and the Visalia General Plan (General Plan).

No public comments were received during the Environmental Impact Report (EIR) scoping period regarding utilities and service systems. During tribal outreach, North Fork Mono Tribe expressed concerns about cumulative water use by recent and proposed development in the area.

3.15.2 - Environmental Setting
Project Site
The project site lies within the Modoc Ditch Drainage Basin, which is the northwesternmost drainage basin in the Sphere of Influence (SOI), encompassing 8,242 acres including areas of the City as well unincorporated areas of the County and areas included in the City’s Urban Growth Boundary (UGB).1 Modoc Ditch is an open channel irrigation canal that provides irrigation service to approximately 6,500 acres with a capacity of approximately 154 to 674 cubic feet per second (cfs).2 The Modoc Ditch Drainage Basin can generally be characterized as encompassing predominantly agricultural and industrial land uses, stretching as far east as Bridge Street and as far north as Patterson Tract.

The project site abuts Modoc Ditch on its northern border and contains a retention basin diverting from Modoc Ditch on-site. The site topography is generally flat and drains to the north or northwest toward Modoc Ditch.3
Water
The California Water Service (Cal Water) Visalia District, provides water supplies for the City of Visalia (City). The proposed project involves the annexation of the project site into the City; upon annexation, the site will be added to the Cal Water Visalia District service area. Cal Water Visalia District is part of a regional group of agencies and providers as follows:
• Mid-Kaweah Groundwater Sustainability Agency (MKGSA)
• Kaweah Delta Water Conservation District (KDWCD)
• Kaweah River Basin Regional Water Management Group
1 Boyle Engineering Company. 1994. City of Visalia Storm Water Master Plan and Management Program. 2 Ibid. 3
Ninyo & Moore. 2022. Phase I Environmental Site Assessment Northeast Corner of West Riggin and Kelsey Street. July 20. 2885
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Cal Water is an urban water supplier that provides the main source of water supply for the City and surrounding communities. The Visalia District is an urban retail water supplier, as defined by the California Water Code Section 10608.12. The Visalia District does not provide water wholesale. The sole source of water supply for the customers of the Visalia District is groundwater. The Visalia District of Cal Water pumps from the Kaweah basin, which has been designated by the California Department of Water Resources (DWR) as critically over drafted.

The Cal Water Visalia District is in Tulare County and serves the City and segments of unincorporated Tulare County including the communities of Goshen, Mullen, and Tulco.4 The Visalia District service area lies approximately 42 miles southeast of the City of Fresno and 75 miles north of the City of Bakersfield. The Cal Water system includes 75 operational groundwater wells, about one-third of which have auxiliary power for backup. There are 519 miles of main pipeline in the system, ranging in size from two inches in diameter to 12 inches in diameter.5 The Visalia District had 45,550 municipal connections and supplied 30,152 acre-feet of water in 2020. As future developments within the Urban Development Boundary (UDB) are approved, they will be annexed into the City and be served by Cal Water, Visalia District‘s supply.

Water Supply
Groundwater is the primary source of drinking water within the Planning Area, meaning that the City’s water comes from large, underground aquifers, rather than rivers, lakes, or reservoirs. The San Joaquin Groundwater Basin encompasses all of the Central Valley counties between Sacramento County and Kern County and also includes portions of Sacramento County and El Dorado County at the north end and a portion of Kern County at the south end.

Visalia is within the Kaweah Groundwater Subbasin. The total surface area of the Kaweah Subbasin is 446,000 acres or 696 square miles. Major rivers and streams in the subbasin include the Kaweah and St. Johns Rivers, with the former being the primary source of recharge in the area. Groundwater flow is generally southwestward. In 1999, small groundwater depressions occurred to the north and south of Visalia and at the northwest corner of the subbasin, and a groundwater mound was present in the central western subbasin. Based on current and historical groundwater elevation maps, horizontal groundwater barriers do not appear to exist in the subbasin.

Cal Water’s 75 active supply wells in the Visalia District extract groundwater from the Kaweah Groundwater Subbasin and distribute it over approximately 519 miles of pipeline. The Cal Water system includes two elevated 300,000-gallon storage tanks, an ion exchange treatment plant, four granular activated carbon filter plants and one nitrate blending facility. These facilities are in place to provide Cal Water’s customers with safe drinking water of a quality and quantity to meet State and federal drinking water standards such as the federal Safe Drinking Water Act and the California Safe Drinking Water Act.

The Visalia District extracts water from the Kaweah and Tule Subbasins using a total of 59 wells, and also extracts water from wells in adjacent public water systems. The Visalia District has four surface 4 California Water Service (Cal Water). 2021. 2020 Urban Water Management Plan. June. 5 City of Visalia. 2014. General Plan EIR Section 3.9 Public Services, Facilities and Utilities. 2886
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storage structures that can be used to pump groundwater to storage during non-peak-hours and subsequently aid demand during peak demand periods.

The water supplies needed to serve the City’s water service area, including the existing water demands and planned future uses on the project site, are described in the 2020 UWMP.6 Therefore, the descriptions provided below for the City’s water supplies have been taken from the 2020 UWMP.

Table 3.15-1 lists the amount of groundwater pumped by Cal Water over the past 5 years. The available groundwater supply has been sufficient to meet all of the District’s demands in the past five years and all prior years. It is also important to note that the majority of groundwater pumping in the Kaweah Subbasin is for agricultural use. From a regional and basin-wide standpoint, the Visalia District is only a small fraction of total groundwater pumping. Based on the Kaweah Subbasin water budget information presented in the Mid-Kaweah Groundwater Sustainability Plan (GSP), average annual groundwater pumping from 1981 through 2017 totaled approximately 754,415 acre-feet per year (AFY), including approximately 685,375 AFY for irrigated agriculture and 69,040 AFY for Municipal and Industrial (M&I) use. These data show that M&I pumping accounted for approximately 9 percent of total pumping in the Kaweah Subbasin, and Visalia District pumping in the Visalia and Tulco public water systems accounts for only a portion of the total M&I pumping.

Table 3.15-1: Groundwater Volume Pumped
Location/Basin Name
2016
(AFY)
2017
(AFY)
2018
(AFY)
2019
(AFY)
2020
(AFY)
Kaweah Subbasin 25,802 27,856 29,218 28,900 30,131
Tule Subbasin 41 26 25 19 21
Total 25.843 27,882 29,243 28,919 30,152
Notes:

AFY = acre-feet per year
Source: California Water Service (Cal Water). 2021. 2020 Urban Water Management Plan. June.

Water Demand and Use
Historical and Existing Water Demand
The Visalia District’s water demand per capita has been steadily decreasing since the early 2000s due to a combination of Cal Water implementing conservation pricing, the City becoming fully metered, strict appliance efficiency standards and plumbing codes, and conservation programs.7

Water use in 2020 was 30,152 AFY. Residential customers account for most of the Visalia District’s service connections and 69 percent of its water uses. Nonresidential water uses account for 28 percent of total demand, while distribution system losses account for 3 percent. 6 California Water Service (Cal Water). 2021. 2020 Urban Water Management Plan. June. 7 Ibid.
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Future Water Use
Although water demand per capita has been decreasing, the Visalia District’s water demand is anticipated to continue to increase as approved projects are constructed and new developments are approved and constructed in accordance with the General Plan within the City’s water service area.

Projected population and services are based on population and employment forecasts for Tulare County generated by the California Department of Transportation’s (Caltrans) long-term socioeconomic forecast model. Over the 25-year planning period (2020-2045), the Visalia District’s water demand is expected to increase at an average rate of 1.8 percent annually. For comparison’s sake, between 2000 and 2020, demand increased at an average rate of 2.4 percent annually. Visalia District per capita water use in 2020 was 30 percent below its 2004 peak.8 The 2020-2045 water
demand projections include consideration for reduced future water use as a result of effects of appliance standards and plumbing codes, demand management measures, and increases in the real cost of water service and household income.
9 Table 3.15-2 shows the Visalia District’s projected
water use through 2045 based on future normal hydrologic years.10 These forecasts incorporate the effects of several State codes and regulations which are discussed in section 3.15.3 below.

Table 3.15-2: Use for Potable and Nonpotable Water–Projected Use Types
Projected Water Use (AFY)
2025 2030 2035 2040 2045
Single-family 20,815 22,593 24,604 26,513 28,705
Multi-family 1,583 1,686 1,815 1,945 2,070
Commercial 5,634 6,009 6,448 6,891 7,364
Institutional/Government 2,854 3,152 3,483 3,819 4,164
Industrial 308 308 308 308 308
Other Potable 223 223 223 223 223
Landscape1 0 0 0 0 0
Losses2 1,102 1,304 1,429 1,559 1,695
Total 32,520 35,276 38,310 41,258 44,529
Notes:

AFY = acre-feet per year 1 District’s billing system does not track this use type separate from other use types. 2 Real and apparent losses.

The future conservation savings of 811 acre-feet in 2025, 1,421 acre-feet in 2030, 1,900 acre-feet in 2035, 2,605 acre-feet in 2040, and 3,156 acre-feet in 2045, are included in these projections Table 3.15-3 shows the City’s projected supply and demand totals for a single normal year. 8 California Water Service (Cal Water). 2021. 202 Urban Water Management Plan. June. 9 Ibid. 10 Ibid.
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Table 3.15-3: Normal Year Supply and Demand Comparison
2025 2030 2035 2040 2045
Supply totals 32,520 35,276 38,310 41,258 44,529
Demand totals 32,520 35,276 38,310 41,258 44,529
Difference 0 0 0 0 0
Notes:
* Volumes are in units of acre-foot.
** Neither the Kaweah nor Tule Subbasins are adjudicated, and this projected supply volumes do not comprise a determination of water rights or maximum allowable pumping.

Single and Multiple Dry Year Water Demand
Table 3.15-4 shows the projected supply and demand totals for the single dry year, and Table 3.15-5 shows the projected supply and demand totals for multiple dry year periods extending 5 years. As shown in these tables, the Visalia District will have sufficient supplies to meet demands during both single dry year and multiple dry year conditions.

Table 3.15-4: Single Dry Year Supply and Demand Comparison 2025 2030 2035 2040 2045
Supply totals 33,152 35,962 39,057 42,063 45,400
Demand totals 33,152 35,962 39,057 42,063 45,400
Difference 0 0 0 0 0
Notes:
* Volumes are in units of acre-foot.
** Neither the Kaweah nor Tule Subbasins are adjudicated, and this projected supply volumes do not comprise a determination of water rights or maximum allowable pumping.

Table 3.15-5: Multiple Dry Years Supply and Demand Comparison 2025 2030 2035 2040 2045
First Year Supply totals 33,543 36,387 39,520 42,562 45,939 Demand totals 33,543 36,387 39,520 42,562 45,939
Difference 0 0 0 0 0
Second Year Supply totals 33,543 36,387 39,520 42,562 45,939 Demand totals 33,543 36,387 39,520 42,562 45,939
Difference 0 0 0 0 0
Third Year Supply totals 33,543 36,387 39,520 42,562 45,939 Demand totals 33,543 36,387 39,520 42,562 45,939
Difference 0 0 0 0 0
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2025 2030 2035 2040 2045
Fourth Year Supply totals 33,543 36,387 39,520 42,562 45,939 Demand totals 33,543 36,387 39,520 42,562 45,939
Difference 0 0 0 0 0
Fifth Year Supply totals 33,543 36,387 39,520 42,562 45,939 Demand totals 33,543 36,387 39,520 42,562 45,939
Difference 0 0 0 0 0
Notes:
* Volumes are in units of acre-feet.
** Neither the Kaweah or Tule Subbasins are adjudicated, and this projected supply volumes do not comprise a determination of water rights or maximum allowable pumping.

Water Distribution
In general, the water distribution system is a looped system with deep wells spaced throughout a distribution pipeline grid system. The deep well and pipeline grid has expanded with the growth of the City. Because of the area’s flat topography, the entire system is in one pressure zone, with wells spaced throughout the system. Modeling analysis done for the WSA and Facilities Master Plan indicate that the grid system pipe sizes and well spacing have kept normal operating pressures in the system above 40 pounds per square inch (psi) and fire flow pressure residuals at fire hydrants above 20 psi.

Recycled Water and Nonpotable Irrigation Water Supply
In 2018, through its Water Conservation Plant Upgrade Project, the City of Visalia began producing Title 22 Recycled Water for delivery to the Tulare Irrigation District (TID) in exchange for surface water used to recharge the City’s groundwater. The City provides 11,000 acre-feet of treated water to TID annually in exchange for 5,500 acre-feet of surface water for groundwater recharge to be stored in recharge basins east of Visalia. These basins have greater potential to recharge the underlying aquifers and should help lessen the overdraft situation in the long term. 11,12 In addition to
recharge, treated water may also be used to irrigate the areas noted above, reducing the amount of pumped groundwater.

Currently, no wastewater is recycled for potable reuse within the Visalia District service area and will likely only be considered if conditions related to Visalia District supply change significantly in the future.

Wastewater
City of Visalia
The City owns and operates a Water Conservation Plant (WCP), located west of State Route (SR) 99 and south of SR-198. The City’s wastewater collection system consists of gravity sewers, pump 11 Mid-Kaweah Groundwater Sustainability Agency. 2019. Groundwater Sustainability Plan. December. Website:
https://www.midkaweah.org/_files/ugd/55be79_0dd4bb3a882641efa526ccc63e4c07a0.pdf. Accessed May 3, 2023. 12 City of Visalia. 2014. General Plan EIR Section 3.9 Public Services, Facilities and Utilities. 2890
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stations, and force mains. The collected wastewater is discharged to trunk sewers and interceptors and conveyed to the City’s WCP. In 2017, the City completed an upgrade project at the WCP which included replacement of the secondary and tertiary treatment processes with a membrane bioreactor system and ultraviolet (UV) light disinfection system, among other upgrades. The WCP has a capacity to treat 22 million gallons per day (GPD).
13 As of 2010, the plant operates at an average
daily flow of 13 GPD.

The City’s sewer collection system facilities consist of gravity sewer pipelines ranging in size from 6- inch to 42-inch, as well as 13 sewage lift stations and associated force mains. All of the pipelines within the city limits convey wastewater to the WCP.

Stormwater
Generation and Collection
City of Visalia
The City’s Public Works Department manages the City’s storm drainage system. The City contains seven major drainage basins, including:14
• St. John’s Basin
• Modoc Ditch Basin
• Mill Creek Basin
• Evans Ditch Basin
• Packwood Creek Basin
• Cameron Creek Basin
• Persian/Watson Basin
Stormwater drains through natural rivers and watercourses, irrigation ditches, storage reservoirs, and discharge locations.15 The planned system takes street and lot drainage into a storm drain pipeline system that is directed generally by gravity and augmented with lift pumps toward the main drain system. The system relies on detention basins and several retention basins to slow and divert stormwater for larger storms. This allows the creeks and ditches to convey stormwater both during and after a storm and permits the existing creek and ditch system to handle larger storms than would otherwise be the case. The creeks and ditches used for stormwater also convey irrigation flows, a shared use system that is managed based on formal agreements between the City and irrigation agencies and companies.16
Stormwater runoff from the City is transported to the WCP located west of SR-99 and south of SR198 before being discharged into Mill Creek and/or stored in basins owned by the City.17 The State of California requires small communities to implement development standards to protect water quality under the "General Permit for Waste Discharge Requirements for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (MS4s) Order No. 2013-0001-DWQ." These 13 California Water Service (Cal Water). 2021. 202 0Urban Water Management Plan. June. 14 Boyle Engineering Company. 1994. City of Visalia Storm Water Master Plan and Management Program. 15 City of Visalia. 2014. Visalia General Plan – Parks, Schools, Community Facilities, and Utilities Element. October 14. 16 Ibid. 17 Ibid. 2891
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requirements are an extension of similar requirements imposed on larger communities (e.g., the cities of Visalia and Tulare, and parts of the County of San Joaquin.) The development standards, also known as post-construction stormwater requirements, will become part of every regulated community's development process.

Solid Waste
Solid waste disposal is provided by the Tulare County Resource Management Agency, which operates the Visalia Disposal Site, northwest of Visalia; the Woodville Disposal Site, southeast of Tulare; and the Teapot Dome Disposal Site, southwest of Porterville.18 The Visalia Landfill is approximately 1.5 miles north of the project site. The facility serves the cities of Visalia, Farmersville, Dinuba, Exeter, Tulare, Woodlake, Fresno, and unincorporated areas of northern Tulare County and southern Fresno County. As of this writing, these landfills have a combined maximum capacity of 40,071,173 cubic yards and a remaining capacity of 22,340,353 cubic yards (see Table 3.15-6). The City generated approximately 138,821.08 tons of solid waste in 2021, the most recent year with data available.19 The City provides refuse collection for residential and commercial customers and contracts with Sunset Waste Systems to provide recycling service.20 The City’s solid waste is taken to one of three disposal sites operated discussed above. The City provides split containers for residential trash and recycling, and green waste containers for residential green waste and compostable materials. The City also actively encourages commercial recycling and provides refuse, green waste and recycling bins or boxes to the commercial accounts it services.

Table 3.15-6: Disposal Site Capacity
Disposal Site
Max Permitted
Throughput
(tons/day)
Maximum Permitted
Capacity (cubic yards)
Remaining Capacity
(cubic yards)
Projected Closure
date
Teapot Dome 800 8,320,307 431,707 02/2024
Visalia 2,000 18,630,666 14,815,501 01/2024
Woodville 1,078 13,120,200 7,093,145 01/2043
Sources:

California Department of Resources Recycling and Recover (CalRecycle). 2023. Solid Waste Information System (SWIS)– Teapot Dome Disposal Site. Website: https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/3834. Accessed May 3, 2023.

California Department of Resources Recycling and Recover (CalRecycle). 2023. Solid Waste Information System (SWIS)– Visalia Disposal Site. Website: https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/822?siteID=3839.

Accessed May 3, 2023.
18 City of Visalia. 2014. Visalia General Plan Draft Environmental Impact Report – Public Services, Facilities, and Utilities. October 14. 19 California Department of Resources Recycling and Recovery (CalRecycle). 2022. Disposal Rate Calculator: Jurisdiction Review Reports. Website: https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/DisposalRateCalculator. Accessed December 7, 2022. 20 City of Visalia. 2014. Visalia General Plan – Parks, Schools, Community Facilities, and Utilities Element. October 14. 2892
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Energy
Electricity
Southern California Edison (SCE) provides natural gas and electricity services to the City. SCE provides natural gas and electricity to approximately 15 million people throughout a 50,000-square-mile service area in central, coastal, and Southern California. SCE produces or buys its energy from a mix of conventional and renewable generating sources, which travel through our electric transmission and distribution systems to reach customers. SCE charges connection and user fees for all new development and sliding use-based rates for electrical and natural gas service.

The California Energy Commission reports electricity consumption by County on a yearly basis. The total electricity consumption, including residential and nonresidential, attributable to Tulare County from 2011 to 2021 is provided in Table 3.15-7.

Table 3.15-7: Electricity Consumption in Tulare County 2011–2021 Year Millions of kWh (GWh)
2011 3746.71
2012 4163.27
2013 4316.70
2014 4492.36
2015 4477.12
2016 4363.20
2017 4243.88
2018 4438.02
2019 4249.14
2020 4642.81
2021 4878.46
Notes:

GWh = gigawatt-hours
kWh = kilowatt-hour
Source: California Energy Commission. 2023. Electricity Consumption by County. Website:
https://ecdms.energy.ca.gov/elecbycounty.aspx. Accessed June 7, 2023.

Natural Gas
Natural gas service is primarily provided by the Southern California Gas Company (SoCalGas). The California Energy Commission reports gas consumption by County on a yearly basis. The total natural gas consumption, including residential and nonresidential, attributable to Tulare County from 2011 to 2021 is provided in Table 3.15-8.
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Table 3.15-8: Natural Gas Consumption in Tulare County 2011–2021 Year Millions of Therms
2011 159.47
2012 157.72
2013 157.84
2014 151.22
2015 149.48
2016 151.40
2017 150.41
2018 157.28
2019 155.13
2020 159.46
2021 167.90
Source: California Energy Commission. 2023. Gas Consumption by County. Website:
http://www.ecdms.energy.ca.gov/gasbycounty.aspx. Accessed June 7, 2023.

Telecommunications
Three major communication companies provide communications services in the City: AT&T, Sprint, and Verizon. Comcast is the primary provider of internet and cable television.21

3.15.3 - Regulatory Framework
Federal
Safe Drinking Water Act
The Safe Drinking Water Act authorizes the United States Environmental Protection Agency (EPA) to establish national standards for drinking water, called the National Primary Drinking Water Regulations, to protect against both naturally occurring and man-made contaminants. These standards set enforceable maximum contaminant levels in drinking water and require all water providers in the United States to treat water to remove contaminants, except for private wells serving fewer than 25 people. In California, the State Department of Health Services conducts most enforcement activities.

Clean Water Act
The Water Pollution Control Act of 1972, more commonly known as the Clean Water Act (CWA), regulates the discharge of pollutants into watersheds throughout the nation. Under the CWA, the EPA implements pollution control programs and sets wastewater standards. 21 City of Visalia. 2014. Visalia General Plan–Parks, Schools, Community Facilities, and Utilities Element. October 14. 2894
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The National Pollutant Discharge Elimination System (NPDES) permit program was established within the CWA to regulate M&I discharges to surface waters of the United States. Federal NPDES permit regulations have been established for broad categories of discharges, including point-source municipal waste discharges and nonpoint-source stormwater runoff. NPDES permits generally identify effluent and receiving water limits on allowable concentrations and/or mass emissions of pollutants contained in the discharge; prohibitions on discharges not specifically allowed under the permit; and provisions that describe required actions by the discharger, including industrial pretreatment, pollution prevention, self-monitoring, and other activities. Wastewater discharge is regulated under the NPDES permit program for direct discharges into receiving waters and by the National Pretreatment Program for indirect discharges to a sewage treatment plant.

Resource Conservation and Recovery Act (Amended 1986)
The Resource Conservation and Recovery Act (RCRA) is a federal act regulating the potential health and environmental problems associated with solid waste hazards and non-hazardous wastes.

Specific regulations addressing solid waste issues are contained in Title 40, Code of Federal Regulations.

Energy Policy and Conservation Act
Water use standards for residential and commercial clothes washers and dishwashers are established by the United States Department of Energy through its authority under the federal Energy Policy and Conservation Act. Water use efficiency is summarized by the water factor for the appliance which measures the gallons of water used per cycle per cubic foot of capacity. A typical top-loading residential clothes washer manufactured in the 1990s had a water factor of around 12.

In 2018, the water factor standard for top-loading residential clothes washers was reduced to 6.5.

The maximum water factor for Energy Star compliant top- and front-loading washers is 3.7 and 4.3, respectively. An Energy Star compliant washer uses about two-thirds less water per cycle than washers manufactured in the 1990s.

State
California Porter-Cologne Water Quality Control Act
Under the Porter-Cologne Water Quality Control Act (Porter-Cologne), which was passed in California in 1969, the California State Water Resources Control Board (State Water Board) has the ultimate authority over State water rights and water quality policy. Porter-Cologne also establishes nine Regional Water Quality Control Boards (RWQCBs) to oversee water quality on a day to-day basis at the local and regional level. The RWQCBs engage in a number of water quality functions in their respective regions, and regulate all pollutant or nuisance discharges that may affect either surface water or groundwater.

California Urban Water Management Planning Act
The Urban Water Management Planning Act (California Water Code §§ 10610–10656) requires that all urban water suppliers with at least 3,000 customers prepare UWMPs and update them every 5 years. The act requires that UWMPs include a description of water management tools and options used by that entity that will maximize resources and minimize the need to import water from other regions. Specifically, UWMPs must:
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• Provide current and projected population, climate, and other demographic factors affecting the supplier’s water management planning.
• Identify and quantify, to the extent practicable, the existing and planned sources of water available to the supplier.
• Describe the reliability of the water supply and vulnerability to seasonal or climatic shortage. • Describe plans to supplement or replace that source with alternative sources or water demand management measures.
• Describe the opportunities for exchanges or transfers of water on a short-term or long-term basis (associated with systems that use surface water). • Quantify past and current water use.
• Provide a description of the supplier’s water demand management measures, including schedule of implementation, program to measure effectiveness of measures, and anticipated water demand reductions associated with the measures.
• Assess the water supply reliability.

California Health and Safety Code
Section 64562 of the California Health and Safety Code establishes water supply requirements for service connections to public water systems. Before additional service connections can be permitted, enough water must be available to the public water system from its water sources and distribution reservoirs to adequately, dependably, and safely meet the total requirements of all water users under maximum-demand conditions.

California Senate Bills 610 and 221
Senate Bill (SB) 610 and SB 221 (Water Code § 10910(c)(2)) amended State law, effective January 1, 2002, to improve the link between information on water supply availability and certain land use decisions made by cities and counties. SB 610 and SB 221 seek to promote more collaborative planning between local water suppliers and cities and counties by requiring that detailed information regarding water availability be provided to decision-makers prior to approval of specified large development projects. SB 610 requires that detailed information be included in a WSA, which is then included in the administrative record that serves as the evidentiary basis for an approval action by a city or county. SB 221 requires that the detailed information be included in a verification of water supply. Under SB 610, WSAs must be furnished to local governments for inclusion in any environmental documentation for certain projects (as defined in Water Code § 10912(a)) subject to the California Environmental Quality Act (CEQA).

California Water Conservation Act
The California Water Conservation Act (SB X7-7) was enacted in November 2009 and requires each urban water supplier to select one of four water conservation targets contained in California Water Code Section 10608.20 with the Statewide goal of achieving a 20 percent reduction in urban per capita water use by 2020. Under SBX7-7, urban retail water suppliers are required to develop water use targets and submit a water management plan to the DWR by July 2011. The plan must include 2896
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the baseline daily per capita water use, water use target, interim water use target, and compliance daily per capita water use.

California Model Water Efficient Landscape Ordinance
The California Model Water Efficient Landscape Ordinance (MWELO) was adopted by the California Office of Administrative Law in September 2009, and requires local agencies to implement water efficiency measures as part of its review of landscaping plans. Local agencies can either adopt the MWELO or incorporate provisions of the ordinance into its own code requirements for landscaping.

The County has not adopted a local ordinance.

Assembly Bill 1881
Assembly Bill (AB) 1881 expanded previous legislation related to landscape water use efficiency. AB 1881, the Water Conservation in Landscaping Act of 2006, enacted landscape efficiency recommendations of the California Urban Water Conservation Council (CUWCC) for improving the efficiency of water use in new and existing urban irrigated landscapes in California. AB 1881 required the DWR to update the existing Model Local Water Efficient Landscape Ordinance and local agencies to adopt the updated model ordinance or an equivalent. The law also requires the CEC to adopt performance standards and labeling requirements for landscape irrigation equipment, including irrigation controllers, moisture sensors, emission devices, and valves to reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy or water.

Assembly Bill 2882
AB 2882 was passed in 2008 and encourages public water agencies throughout California to adopt conservation rate structures that reward consumers who conserve water. AB 2882 clarifies the allocation-based rate structures and establishes standards that protect consumers by ensuring a lower base rate for those who conserve water.

California Integrated Waste Management Act
To minimize the amount of solid waste that must be disposed of by transformation and land disposal, the State Legislature passed Assembly Bill 939, the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990. The legislation required each local jurisdiction in the State to set diversion requirements of 25 percent in 1995 and 50 percent in 2000; established a comprehensive Statewide system of permitting, inspections, enforcement, and maintenance for solid waste facilities; and authorized local jurisdictions to impose fees based on the types or amounts of solid waste generated. In 2007, amendments to the California Integrated Waste Management Act introduced a new per capita disposal and goal measurement system that moves the emphasis from an estimated diversion measurement number to using an actual disposal measurement number as a per capita disposal rate factor. As such, the new disposal-based indicator (pounds per person per year) uses only two factors: a jurisdiction’s population (or in some cases employment) and its disposal as reported by disposal facilities.

The California Solid Waste Reuse and Recycling Access Act Subsequent to the California Integrated Waste Management Act, additional legislation was passed to assist local jurisdictions in accomplishing the goals of AB 939. The California Solid Waste Reuse and Recycling Access Act of 1991 directs the California Integrated Waste Management Board to draft a 2897
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model ordinance relating to adequate areas for collecting and loading recyclable materials in development projects. The model ordinance is used by the County as the basis for imposing recycling conditions on new development projects and on existing projects that add 30 percent or more to their existing floor area. Beginning in 1994, the model ordinance requires that any new development project for which an application is submitted include adequate, accessible, and convenient areas for collecting and loading recyclable materials.

Senate Bill 1383
SB 1383 was approved in September 2016 and went into effect on January 1, 2022. In an effort to reduce organic waste from landfills, it requires that all food waste and any organic items associated with food and drink items shall be segregated and placed into separate trash receptacles.

Assembly Bill 341
A general Statewide recycling goal of 75 percent to be achieved by 2020 was established by AB 341 in 2011. The previous recycling goal of 50 percent was met in 2005. It is recognized by CalRecycle that the State did not reach the 75 percent recycling goal by 2020.

Assembly Bill 32
Mandatory Commercial Recycling was one of the measures adopted in the AB 32 Scoping Plan by the California Air Resources Board (ARB) pursuant to the California Global Warming Solutions Act (Chapter 488, Statutes of 2006). The Mandatory Commercial Recycling Measure focuses on increased commercial waste diversion as a method to reduce GHG emissions. It is designed to achieve a reduction in GHG emissions of 5 million metric tons of carbon dioxide (CO2) equivalents. To achieve the measure’s objective, an additional 2 to 3 million tons of materials annually will need to be recycled from the commercial sector by the year 2020 and beyond.

The Solid Waste Disposal Measurement System Act
The Solid Waste Disposal Measurement System Act of 2008, SB 1016, amended the California Integrated Waste Management Act procedures for measuring and reporting diversion requirements.

Starting in 2009, jurisdictions are required to calculate the 50 percent diversion requirement in a per capita disposal rate equivalent. CalRecycle will determine the per capita disposal rate equivalent for each jurisdiction.

CalRecycle delegates local permitting, enforcement, and inspection responsibilities to Local Enforcement Agencies. The Visalia Municipal Code contains regulations related to solid waste and recycling in Title 8, Chapters 28 and 29.

Sustainable Groundwater Management Act
The 1992 Groundwater Management Act, AB 3030, established provisions by which local water agencies could develop and implement Groundwater Management Plans (GMP). GMPs are generally designed to prevent local and regional aquifer over drafting, which reduces available groundwater resources and which, under certain conditions, can lead to degradation of water quality and to land subsidence. The City has been, and continues to be, involved in both regional and local groundwater management efforts.
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On August 29, 2014, the California Legislature passed comprehensive groundwater legislation contained in SB 1168, SB 1319, and AB 1739, which are collectively referred to as the Sustainable Groundwater Management Act (SGMA). This legislation was signed by former Governor Brown on September 16, 2014, and it became effective on January 1, 2015. The legislative intent of SGMA is to provide sustainable management of groundwater basins, enhance local management of groundwater, establish minimum standards for sustainable groundwater management, and provide local groundwater agencies with the authority and the technical and financial assistance necessary to sustainably manage groundwater.

The Kaweah Subbasin is designated by DWR as a high priority basin that is critically over drafted. 22 As
such, the Kaweah Subbasin is subject to the requirements of SGMA, which include the formation of one or more GSAs and the development and implementation of one or more GSPs. The Greater Kaweah GSA submitted its Initial Draft GSP on September 16, 2019. The Greater Kaweah GSA Board of Directors took action to approve the Kaweah Sub basin Coordination Agreement and adopt the Greater Kaweah GSA GSP on January 22, 2020.23
The Tule Subbasin is also designated by DWR as a high priority basin that is critically over drafted. 24 As such, the Tule Subbasin is subject to the requirements of SGMA, which include the formation of one or more GSAs and the development and implementation of one or more GSPs. The Tule Subbasin is divided into six GSAs, five of which have published draft GSPs. 25 Central Valley Regional Water Quality Control Board
The primary responsibility for the protection of water quality in California rests with the California State Water Resources Water Board (State Water Board) and nine RWQCBs. The State Water Board sets Statewide policy for the implementation of State and federal laws and regulations. The RWQCBs adopt and implement Water Quality Control Plans (Basin Plans) that recognize regional differences in natural water quality, actual and potential beneficial uses, and water quality problems associated with human activities.

California Department of Water Resources
The DWR is a department within the California Resources Agency. The DWR is responsible for the State’s management and regulation of water usage.

California Water Code Section 13260
California Water Code Section 13260 requires any person who discharges waste, other than into a community sewer system, or proposes to discharge waste that could affect the quality of waters of the State, to submit a report of waste discharge to the applicable RWQCB. Any actions of the proposed project that would be applicable under California Water Code Section 13260 would be reported to the RWQCB.
22 California Water Service (Cal Water). 2021. 202 Urban Water Management Plan. June. 23 Greater Kaweah Groundwater Sustainability Agency. 2022. Groundwater Sustainability Plan. Website:
https://greaterkaweahgsa.org/resources/gsp/. Accessed December 7, 2022. 24 California Water Service (Cal Water). 2021. 202 Urban Water Management Plan. June. 25 Tule Subbasin Sustainable Groundwater Management Act. n.d. Which GSA do you belong to? Website :https://www.tulesgma.com/.

Accessed June 20, 2023.
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Assembly Bill 715
Enacted in 2007, AB 715 requires that any toilet or urinal sold or installed in California on or after January 1, 2014, cannot have a flush rating exceeding 1.28 and 0.5 gallons per flush, respectively. On April 8, 2015, in response to the Governor’s Emergency Drought Response Executive Order (EO B-29- 15), the California Energy Commission approved new standards for urinals requiring that they not consume more than 0.125 gallon per flush, 75 percent less than the standard set by AB 715.

CALGreen
New construction and renovations in California are subject to the California Green Building Standards Code (CALGreen) requirements which include prescriptive indoor provisions for maximum water consumption of plumbing fixtures and fittings in new and renovated properties. CALGreen also allows for an optional performance path to compliance, which requires an overall aggregate 20 percent reduction in indoor water use from a calculated baseline using a set of worksheets provided with the CALGreen guidelines.

For construction and demolition waste, the CALGreen Code (California Building Code 2022, Part 11, Title 24, California Code of Regulations) requires the recycling of 65 percent of construction waste.

The CALGreen Code is incorporated into the City's Development Code, and this recycling requirement is subject to enforcement by the City. The recycling of 65 percent of waste construction material, which comprises by far the largest portion of the overall project solid waste generation, would result in a greater than 50 percent recycling rate for solid waste generated by the construction and operation of the facility as a whole.

Senate Bill 407
Enacted in 2009, SB 407 mandates that all buildings in California come up to current State plumbing fixture standards. This law also requires, effective January 1, 2017, that a seller or transferor of single-family residential property show to the purchaser or transferee, in writing, the specified requirements for replacing plumbing fixtures and whether the real property includes noncompliant plumbing. Similar disclosure requirements went into effect for multi-family and commercial transactions January 1, 2019. SB 837, passed in 2011, reinforces the disclosure requirement by amending the statutorily required transfer disclosure statement to include disclosure about whether the property follows SB 407 requirements.

Local
City of Visalia Water Conservation Ordinance
The City’s Water Conservation Ordinance was adopted in 1989 and can be found in Chapter 13.20 of the Municipal Code. The Ordinance sets regulations to minimize outdoor water use and reduce unnecessary consumption of potable water. It defines and places restrictions on wasteful uses of water and establishes water conservation alert stages to be enacted during periods of water shortage.

Cal Water Urban Water Management Plan–Visalia District
The most recent UWMP was prepared by Cal Water in 2015 and updated in 2021. in compliance with the Urban Water Management Planning Act. The UWMP describes the Visalia District service area, 2900
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system demand and usage, available water resources, reliability of the water supply, and contingency planning for water shortage. It also contains a conservation section in compliance with SB X7-7 describing water usage reduction targets and implementation measures. The UWMP identifies five core programs for water conservation in the Visalia District that involve promotion of high-efficiency fixtures in residential settings, promotion of high-efficiency irrigation systems, and public information and education.

City of Visalia 2020 Urban Water Management Plan
The City prepared the 2020 UWMP to meet the requirements of the California Urban Water Management Planning Act. The 2020 UWMP evaluates sources of the water supply for the City’s projected population and future water demand until 2045, which is the planning horizon. The UWMPs are intended to help facilitate implementation of SB 610 and SB 221.

City of Visalia
General Plan
Public Services Park and Facilities Element
Objectives
PSCU-O-14 Provide for long-range community water needs by adopting best management practices for water use, conservation, groundwater recharge and wastewater and stormwater management.

PSCU-O-15 Preserve groundwater resources.

PSCU-O-16 Ensure that adequate wastewater collection, treatment, recycling and disposal facilities are provided in a timely fashion to serve existing and future needs.

PSCU-O-17 Manage solid waste such that City needs are met, opportunities for waste reduction and recycling are maximized, and high-quality service is provided.

Policies
PSCU-P-44 Continue to improve and expand the City’s Water Conservation Program, consistent with the Urban Water Management Plan as appropriate, including an active public outreach component and an online presence. The program should provide information and links to additional resources on water efficient plumbing fixtures and planting and irrigation methods, and the development of safe and effective gray water systems. It should also maintain an up-to-date list of incentive programs.

PSCU-P-45 Continue the City’s active role in regional and local water management planning, building on partnerships with Kaweah Delta Water Conservation District and participation in the Integrated Regional Water Management Planning (IRWM) in implementing the Urban Water Management Plan and the Groundwater Management Plan. Continue to develop and implement projects that address groundwater overdraft mitigation, and support additional groundwater recharge, using funds generated from the Water Resources Management and Groundwater Overdraft Mitigation Fee Ordinance and other sources.
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PSCU-P-50 Require that industrial development projects submit plans for water recycling and conservation and demonstrate how water use will meet requirements of the National Pollution Discharge Elimination System during the plan review process.

PSCU-P-51 Ensure that City building plan inspectors are adequately prepared to implement the requirements of the California Green Building Code (CalGreen), including mandatory low-water-use plumbing and water meters.

PSCU-P-52 Continue development of a conveyance system to allow for the reuse of treated wastewater for groundwater recharge, irrigation for farmland, ornamental landscaping, and golf courses, and expand the use of recycled water with a “purple pipe” delivery system, to the greatest extent feasible.

PSCU-P-55 Periodically review and update development impact fees, wastewater connection charges, groundwater mitigation fees, and monthly service charges to ensure that adequate funds are collected to operate and maintain existing facilities and to construct new facilities.

PSCU-P-58 Coordinate urban growth management planning with public and private utilities.

Develop and carry- out an infrastructure and public services assessment during annexation reviews to determine infrastructure needs, feasibility, timing, and financing.

PSCU-P-59 Implement public facility master plans through various funding mechanisms including assessment districts, user fees, development impact fees, reimbursement agreements and/or other mechanisms which provide for equitable distribution of development costs.

PSCU-P-60 Require new developments to incorporate flood water detention basins into project designs where consistent with the Stormwater Master Plan and the Groundwater Recharge Plan.

Stormwater drainage basins can provide groundwater recharge, and may be combined with recreational uses. Additional policies for drainage basins designed for recreational use are provided in the Parks and Open Space section, which follows.

PSCU-P-61 Control urban and stormwater runoff, and point and nonpoint discharge of pollutants. As part of the City’s Stormwater Management Program, adopt and implement a Stormwater Management Ordinance to minimize stormwater runoff rates and volumes, control water pollution, and maximize groundwater recharge.

New development will be required to include Low Impact Development features that reduce impermeable surface areas and increase infiltration. Such features may include, but are not limited to:
• Canopy trees or shrubs to absorb rainwater;
• Grading that lengthens flow paths over permeable surfaces and increases runoff travel time to reduce the peak-hour flow rate;
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• Partially removing curbs and gutters from parking areas where appropriate to allow stormwater sheet flow into vegetated areas;
• Use of permeable paving in parking lots and other areas characterized by significant impervious surfaces;
• On-site stormwater detention, use of bioswales and bioretention basins to facilitate infiltration; and
• Integrated or subsurface water retention facilities to capture rainwater for use in landscape irrigation and other nonpotable uses.

3.15.4 - Methodology
Water
A WSA was completed for the proposed project and is provided in Appendix J. 26 The purpose of the WSA was to perform the evaluation required by California Water Code Sections 10910 through 10915, as established by SB 610. The WSA evaluates the adequacy of the total project water supplies of the City (as the water purveyor to the proposed project), including existing water supplies and future planned water supplies, to meet the City’s existing and projected future water demands, including those future water demands associated with the proposed project, under all hydrological conditions (Normal Years, Single Dry Years, and Multiple Dry Years).

Wastewater
Wastewater production was calculated and compared with the City’s treatment capacity to determine whether wastewater treatment requirements would be exceeded. The City’s wastewater discharge permitting requirements were also reviewed.

Stormwater
Stormwater production was calculated and compared with the City’s stormwater facility treatment capacity to determine whether stormwater collection requirements would be exceeded.

Solid Waste
Solid waste production was calculated and compared with the applicable landfill capacity to determine whether landfill daily permitted capacity and total storage capacity would be exceeded.

The City’s and RecycleSmart’s solid waste regulations and policies were also reviewed.

Electricity and Natural Gas
Electricity and natural gas usage were calculated and compared to existing capacity to determine whether existing sources would meet project demands. Section 3.6, Energy, and Section 3.8, Greenhouse Gas Emissions, also address electricity and natural gas demands.

Telecommunications
The telecommunications providers in the City were identified. 26 4Creeks Inc. 2022. Water Supply Technical Memorandum Shirk and Riggin Industrial Park. December. 2903
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3.15.5 - Thresholds of Significance
The lead agency utilizes the criteria in CEQA Guidelines Appendix G Environmental Checklist to determine whether impacts to utilities and service systems are significant environmental effects.

Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? e) Comply with federal, State, and local statutes and regulations related to solid waste?

3.15.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the project and provides mitigation measures where appropriate.

Water or Wastewater Treatment Facilities
Impact UTIL-1: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Impact Analysis
The proposed project would involve both flex industrial and light industrial uses as described in Chapter 2, Project Description. Flex industrial uses would consist of small incubator space available for small manufacturing, storage, limited warehouse space, while the light industrial uses would consist of warehouse, distribution, storage, and light manufacturing.

Construction
Water Supply
As discussed in Section 3.10, Hydrology and Water Quality, project construction would occur in 2024.

The UWMP expects a demand of 31,951 acre-feet in 2024. With the project construction, the Visalia District is expected to have a total demand of 32,253.6 acre-feet, which represents an increase of 302.4 acre-feet.
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The UWMP states that 2013 was the driest year since 1991 and during 2013 there was an available water supply of 45,400 AFY. Therefore, even if 2024 is a dry year, there would be at least 13,449 acre-feet available. This would be able to supply the one-time increase in 302.4 AFY. Therefore, construction impacts related to the need for new water supply infrastructure facilities due to water demand would be less than significant.

As shown in Table 3.10-4, water demand during construction (2024 through 2028) is anticipated to be a total of 1,210 acre-feet of water. The implementation of the proposed project would result in the construction of new water line connections extending from an existing water line located within Kelsey Street. Service laterals would be extended from an existing water line located within Kelsey Street. As shown in Exhibit 2-13, the proposed project would be served by a series of new 8-inch and 12-inch water lines throughout the project site. Based on the data presented from the WSA, there is sufficient water available to support the proposed project, and there are no additional impacts associated with the construction or expansion of water infrastructure that would result in potentially significant impacts. No additional mitigation would be required to address potential impacts related to construction or expansion of water supply infrastructure facilities. Therefore, construction impacts related to planned construction, expansion, and relocation of water infrastructure facilities would be less than significant.

Wastewater Treatment
Construction of the proposed project would result in the generation of wastewater associated with water used for dust control, mixing concrete, washing equipment and vehicles, and other activities as well as wastewater generated from construction workers. The WCP would treat wastewater generated by construction of the proposed project consistent with applicable standards established by the Central Valley RWQCB. The WCP would have sufficient capacity to serve the proposed project during construction and a new or expanded wastewater treatment facility would not be required.

Therefore, construction impacts related to the need for new wastewater infrastructure facilities as a result of wastewater generation would be less than significant.

No new or expanded wastewater treatment facilities would be required as a result of construction of the proposed project. The proposed project would include connections to the existing City sanitary sewer system operated by the Public Works Department via the existing wastewater line extended from an existing sewer line located within Riggin Avenue and Kelsey Street. Service laterals would be extended from an existing sewer line located within Riggin Avenue and Kelsey Street. As shown in Exhibit 2-14, the proposed project would be served by a series of new 8-inch and 12-inch sewer lines throughout the project site. Beyond the foregoing, there are no additional impacts associated with the construction or expansion of wastewater infrastructure that would result in potentially significant impacts, and no additional mitigation would be required to address potential construction impacts related to the need for expansion of wastewater infrastructure. Therefore, impacts related to the planned construction, expansion, and relocation of wastewater infrastructure facilities would be less than significant.

Stormwater
The construction of the proposed project itself would not result in the need for increased stormwater infrastructure improvements beyond those proposed on-site to serve the proposed 2905
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project. Specifically, the proposed project is anticipated to construct various storm drainage improvements including the proposed project’s on-site stormwater detention basins and stormwater pipelines connecting to the existing stormwater pipes on Riggin Avenue and Shirk Street. There are no additional impacts associated with the construction of new or expanded stormwater facilities that would result in potentially significant impacts, and no additional mitigation would be required to address potential impacts related to construction or expansion of these facilities. Therefore, construction impacts related to planned construction, expansion, and relocation of stormwater facilities would be less than significant.

Electricity
Construction of the proposed project would consume electricity for construction work areas, field services (office trailers), and electric-driven equipment such as pumps and other tools. As on-site construction activities would be restricted between permitted construction hours (6:00 a.m. and 7:00 p.m. on weekdays or between the hours of 9:00 a.m. and 7:00 p.m. on weekends and federal holidays),27 it is anticipated that the use of construction lighting would be relatively limited. As discussed in Section 3.6, Energy, construction equipment is estimated to consume a total of approximately 886,679 gallons of diesel fuel over the entire construction duration, and the proposed project is estimated to use a combined approximately 924,696 gallons of gasoline and diesel for vehicle travel during construction. A typical 720-square-foot office trailer would consume approximately 6,548 kilowatt hours (kWh) each year during the construction. As discussed more fully in Section 3.6, Energy, due to the temporary nature of construction and the financial incentives for developers and contractors to use energy-consuming equipment in an efficient manner, construction demand and consumption of electricity would not be significant. Therefore, construction impacts related to the need for new electrical supply infrastructure facilities because of electricity demand would be less than significant.

Construction of the proposed project would include new connections from existing electrical lines.

However, due to the relatively short duration of construction activities, there are no additional impacts associated with the construction or expansion of electrical connections that would result in potentially significant impacts, and no additional mitigation would be required to address potential impacts related to the need for relocation or construction of expanded electrical facilities. Therefore, construction impacts related to planned construction, expansion, and relocation of electrical infrastructure facilities would be less than significant.

Natural Gas
The proposed project would not consume natural gas for construction purposes. Therefore, there would be no construction impact related to a need for new or expanded natural gas supply infrastructure facilities as a result of natural gas demand.

There are no additional impacts associated with the expansion of existing natural gas infrastructure, and no additional mitigation would be required to address potential impacts related to the need for construction of expanded natural gas facilities. Therefore, construction impacts related to planned 27 City of Visalia. 2023. Municipal Code Chapter 8.36.050 Exterior noise standards—Mobile noise sources prohibition against use.

Website: https://codelibrary.amlegal.com/codes/visalia/latest/visalia_ca/0-0-0-26473. Accessed June 11, 2023. 2906
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construction, expansion, and relocation of electrical infrastructure facilities would be less than significant.

Telecommunications
During construction, construction crew would use their personal devices (phone and internet).

Construction office field services (office trailers) would require new telecommunications hookups or equipment, which would be provided by existing communication and internet providers in the area.

Implementation of the proposed project would not result in a substantial demand for service. There are no additional impacts associated with extension and expansion of existing telecommunications infrastructure, and no additional mitigation measures would be required to address potential impacts related to construction of these facilities. Therefore, construction impacts related to planned construction, expansion, and relocation of telecommunications infrastructure facilities would be less than significant.

Operation
For the purposes of this analysis, buildout is assumed to be 2028.

Water
The proposed project is currently an almond farm. An analysis from the Pacific Institute of DWR found that almond farms require 4.49 acre-feet annually per acre. The site is currently developed with over 280 acres in agricultural production as an almond orchard that is conservatively estimated to use 1,257 AFY.

However, while the overall project’s operational water usage of approximately 124.1 AFY at buildout in 2028 would be significantly less under the proposed uses, water projection estimates in the UWMP and WSA are based on annexation of the site into the Cal Water service area, and projected availability is based on planned land uses in the City. The proposed project would convert irrigated agricultural land into other uses with reduced water demand. The UWMP states, “Irrigated agriculture typically uses more water on a per acre basis than urban uses; thus, some future growth will likely result in a net decrease in water use within the subbasins.” Therefore, the proposed project would use significantly less water than the existing use on-site.

The UWMP and WSA did not reflect the current agricultural use of the site due to the aforementioned reason. Because the existing orchard is not currently connected to the Cal Water service area, the proposed project would increase demand for potable water from the Cal Water Visalia District water system, which is reliant on groundwater to serve its customers. Nevertheless, based on analysis in the UWMP and WSA, and as summarized below, the water system would maintain sufficient supply in normal year, single dry year, and multiple dry years.

The information herein is based, in part, on the WSA that was prepared for the project (Appendix J).

As discussed in Section 3.10–Hydrology and Water Quality, accounting for the planned expanded 2045 population, the UWMP states that the District would require 44,529 acre-feet in a normal year, 45,400 acre-feet in a single dry year, and 45,939 acre-feet each year for multiple dry years. 2907
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This includes the expected demand from the planned Industrial and Light Industrial use of the site in the General Plan. Factoring in the proposed project’s estimated water demand of 124.1 AFY, the total District demand would increase by 12.3 AFY due to the project’s floor area ratio (FAR) being higher than the baseline FAR assumed in the UWMP. This would require the Visalia District to supply 45,541.3 acre-feet in an average year, 45,412.3 acre-feet in a single dry year, and 45,951.3 acre-feet every year over multiple dry years. These demands are higher than the supply given by the UWMP by 12.3 acre-feet, however the UWMP states "It should be noted that the Kaweah and Tule Subbasins are not adjudicated, and the projected groundwater supply volumes are not intended to and do not determine, limit or represent Cal Water’s water rights or maximum pumping volumes." Since Cal Water has stated that the maximum pumping capacity is 100,829 AFY and the capacity is adequate to meet a projected 2030 demand of 57,364 AFY, it can be reasonably be expected that there would be sufficient water supplies available during normal, dry, and multiple dry years. The UWMP states "Cal Water expects that, under all hydrologic conditions, its groundwater supply for the Visalia District will fully meet future demands."
Cal Water can expect to meet the increased demand because M&I pumping accounted for 9 percent of the total pumping in the Kaweah Subbasin, and 3 percent of the total pumping in the Tule Subbasin. From this, the UWMP is able to conclude that "It is therefore likely that management of agricultural groundwater use, rather than M&I use, will be a much larger determining factor in maintaining groundwater sustainability in both the Kaweah and Tule Subbasins in the future." The proposed project would be adequately served by the existing water system and would not require the relocation or construction of new or expanded water facilities. Impacts would be less than significant.

The proposed project is consistent with land use and zoning growth projections from the General Plan and is located within the UGB, thus making it planned growth. In its future projections, the UWMP anticipates increases in supply, demand, and service area under planned growth. Therefore, the proposed project is considered planned growth and would not create the need for unplanned connection or increases in service demands to Cal Water. Impacts would be less than significant.

Wastewater
The UWMP provided estimates of the volume of wastewater collected by the WCP from the Visalia District customers in year 2020. According to the UWMP, the WCP received approximately 14,635 acre-feet of wastewater that was collected from the City service area in year 2020. This estimate was calculated by annualizing 90 percent of January water use from the Visalia Water District service area for that year. This equates to approximately 13.1 million GPD of wastewater generation. Based on the City’s existing capacity to process up to 22.0 million GPD, there is additional capacity to handle approximately 8.9 million GPD of additional wastewater.

As discussed above, the proposed project’s operational water demand is estimated to be approximately 124.1 AFY at full buildout. To determine the proposed project’s wastewater generation, it is assumed that 90 percent of the water used by the proposed project would be treated at the WCP (utilizing the same calculation as shown in the UWMP to determine year 2020 2908
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wastewater flows in the City). This would equate to approximately 111.7 AFY or 99,719 GPD of wastewater.

The City’s existing WCP has capacity to process up to 22.0 MGD of wastewater. According to the City’s UWMP, the WCP processed approximately 13.1 MGD in year 2020, leaving approximately 8.9 MGD of additional capacity. The proposed project would conservatively add approximately 99,719 gallons of wastewater per day, or approximately 1.1 percent of the existing available capacity.

Based on the WCP’s existing capacity of 22.0 MGD, the WCP can adequately serve the proposed project in addition to other growth/development in the City. The proposed project would also be required to pay all applicable fees associated with the City’s sewer system outlined in Municipal Code Section 13.08.710. The proposed project would be adequately served by the existing wastewater system and would not require the relocation or construction of new or expanded water facilities. Impacts would be less than significant.

Stormwater
Compared to existing conditions, the proposed project would result in a substantial increase of impervious surfaces, with a commensurate increase in stormwater runoff. As a result, the proposed project would result in the need for new or expanded storm drainage facilities.

As described in Chapter 2, Project Description, the proposed project includes construction of an onsite storm drainage system consisting of inlets, underground piping, and retention basins.

Approximately 31.3 acres of retention basins would be installed. Runoff would drain to drainage system located throughout the project site. The system would be designed to meet the City’s drainage requirements and all applicable standards and requirements would include accommodating a 100-year storm event, retaining runoff and releasing it at a rate no greater than the predevelopment condition of the project site.

The proposed project’s on-site stormwater retention basin would be sized to accommodate the stormwater discharge for the proposed project prior to the start of operations. Therefore, pursuant to the proposed project’s compliance with all other applicable laws and regulations, the proposed project would not require the relocation or construction of new or expanded stormwater drainage facilities. Impacts would be less than significant.

Electric Power
SCE would provide electricity to the project site for lighting, appliances, and other associated operational uses. The proposed project would be required to comply with the State’s applicable Title 24 energy efficiency standards (including designing structures to be solar-ready). These standards contain advanced energy efficiency standards and would ensure that the proposed project would not require significant or unplanned new electrical sources. Therefore, operational impacts related to the need for new electrical infrastructure facilities as a result of electricity demand would be less than significant.

The proposed project would include new connections from existing electrical lines, which have the capacity to serve project operations. The proposed project is required to obtain will and can serve letters from SCE prior to connecting to SCE’s existing system. As such, the proposed project would 2909
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not require the relocation or expansion of electrical infrastructure to serve the increased demand, because it would be served by SCE with adequate electrical supplies. Therefore, operational impacts related to adequacy and capacity of electrical infrastructure facilities would be less than significant.

Natural Gas
Implementation of the proposed project would include new connections from existing natural gas lines. The proposed project could utilize natural gas for heating, which would be provided by SoCalGas. As discussed in Section 3.6, Energy, the proposed project would be required to be designed and constructed consistent with the State’s current Title 24 energy efficiency standards.

These standards would ensure that the proposed project would not require significant or unplanned new natural gas sources. Therefore, operational impacts related to the need for new natural gas supply would be less than significant.

Telecommunications
At operation, the proposed project would increase demand for internet and telephone services provided by local telecommunications providers. The proposed project is located in an area where existing telecommunications providers already offer internet and telephone services and have sufficient capacity to meet project operational demands. The building tenants/operators would coordinate with telecommunication providers in order to provide service, which have the capacity to serve project operations. Therefore, operational impacts related to the need for new or expanded telecommunications infrastructure facilities as a result of telecommunications demand would be less than significant.

Level of Significance
Less than significant impact.

Mitigation Measures
None required.

Water Supplies
Impact UTIL-2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
As discussed in Impact UTIL-1, the proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.28 Therefore, the impact would be less than significant.

Level of Significance
Less than significant impact.
28 4Creeks Inc. 2022. Water Supply Technical Memorandum Shirk and Riggin Industrial Park. September. 2910
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Mitigation Measures
None required.

Wastewater Treatment Capacity
Impact UTIL-3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? As discussed in Impact UTIL-1, the City has adequate wastewater capacity to serve the projected project in addition to the City’s existing commitments. Impacts would be less than significant.

Level of Significance
Less than significant impact.

Mitigation Measures
None required.

Attainment of Solid Waste Reduction Goals
Impact UTIL-4: Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Construction
During construction, the proposed project would generate solid waste from demolition and removal of existing structures on the project site. The EPA estimates 4.34 pounds per square foot for a nonresidential construction project (defined as lodging, office, commercial, health care, educations, religious, public safety, and manufacturing facilities).29 Common construction waste may include metals, masonry, plastic pipe, rocks, dirt, cardboard, or green waste related to land development.

The proposed project would not generate any acutely hazardous material, and any other hazardous waste, such as fuels greases and solvents, generated or used during construction would be disposed of at an approved facility. Waste should be diverted from disposal in landfills (particularly Class III landfills) and maximize source reduction, reuse, and recycling of construction and demolition debris.

The proposed industrial and flex industrial buildings would cover approximately 3,720,149 square feet; therefore, the proposed project is expected to generate approximately 16,145,447 pounds or 8,073 tons of solid waste during the four years of construction.30 Assuming construction would occur only on the weekdays, there would be approximately 980 construction days. Spread over the 980- working day demolition and construction schedule, this equates to approximately 8.3 tons per day.

The County’s three landfills are permitted to receive between 800 and 2,000 tons of waste per day.31 One of the landfills has an expected closure date in 2024, which is before the close of the 29 United States Environmental Protection Agency (EPA). 2003. Estimating 2003 Building-Related Construction and Demolition Materials Amounts. Website: https://www.epa.gov/sites/production/files/2017- 09/documents/estimating2003buildingrelatedcanddmaterialsamounts.pdf. Accessed: June 20, 2023. 30 Calculation: 3,720,149 square feet * 4.34 pounds per square foot = 16,145,447 pounds; 16,145,447 pounds/2,000 = 8,073 tons. 31 California Department of Resources Recycling and Recover (CalRecycle). 2022. Solid Waste Information System (SWIS). Website:
https://www2.calrecycle.ca.gov/SolidWaste/Site/Search. Accessed December 7, 2022. 2911
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construction periods; however, the City is undertaking measures to expand the landfills and extend their lifespans.32 Construction/demolition debris generated by the proposed project represents a nominal percent (approximately 1 percent) of the quantity of solid waste that the landfill currently accepts on a daily basis. Mitigation Measure (MM) UTIL-1 would require that a recycling coordinator be identified to ensure the separation and proper disposal of recyclable materials and solid waste during construction. MM UTIL-1 also requires having recycling areas and receptacles on-site during construction to encourage recycling of materials to the extent feasible. In addition, compliance with applicable local and State laws and regulations would ensure that all construction waste would be conveyed to the appropriate solid waste facility and would be disposed of properly. Therefore, construction impacts related to landfill capacity would be less than significant.

Operation
Using 8.93 pounds per employee per day solid waste generation rate33 (the most recent source provided by CalRecyle), the proposed project’s approximately 4,177 employees would generate an estimated 37,300 pounds of solid waste per day (18.65 tons),34 and 13,614,500 pounds per year (6,807 tons), assuming operation 365 days per year. As of this writing, these landfills have a combined maximum capacity of 40,071,173 cubic yards and a remaining capacity of 22,340,353 cubic yards. The three landfills have expected closure dates ranging between 2024 and 2043; however, the City is undertaking measures to expand the landfills and extend their lifespans. 35 As a
result, the proposed project’s estimated 18.65 tons of solid waste per day and 6,807 tons per year represent less than 1 percent of daily permitted capacity and overall landfill capacity. Pursuant to AB 939, cities are required to redirect at least 50 percent of municipal waste; as of 2009, the City reduced its annual waste tonnage collected by 25 percent, however no other data is provided by the City on its progress of achieving diversion rates in adherence to AB 939. 36 Implementation of MM
UTIL-1 (e) would require each development project to provide a recycling storage area for recyclable materials during operations. Therefore, the proposed project would be served by a landfill that contains sufficient capacity, and operational impacts related to landfill capacity and solid waste reduction goals consistency would be less than significant.

Level of Significance Before Mitigation
Potentially significant impact.

Mitigation Measures
MM UTIL 1 The provisions listed below shall apply to the project during construction activities in connection with project development.
a. An on-site Recycling Coordinator shall be designated by the project proponent/contractor to facilitate recycling.
b. The Recycling Coordinator shall facilitate recycling of all construction waste through coordination with contractors, local waste haulers, and/or other facilities that recycle construction/demolition wastes.
32 City of Visalia. 2014. Visalia General Plan Draft Environmental Impact Report – Public Services, Facilities, and Utilities. October 14. 33 California Department of Resources Recycling and Recovery (CalRecycle). 2019. Estimated Solid Waste Generation Rates. Website:
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed: December 9, 2022. 34 Calculation: 8.93 pounds/employee/day * 4,100 = 36,613 pounds/day; 36,613 pound/day/2,000 = 18.3 tons/day. 35 City of Visalia. 2014. Visalia General Plan Draft Environmental Impact Report – Public Services, Facilities, and Utilities. October 14. 36 Ibid. 2912
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c. The on-site Recycling Coordinator shall also be responsible for ensuring wastes requiring special disposal are handled according to State and County regulations that are in effect at the time of disposal.
d. Contact information of the coordinator shall be provided to the City of Visalia prior to issuance of building permits.
e. The project proponent/operator shall provide a storage area for recyclable materials within the fenced project area that is clearly identified for recycling.

This area shall be maintained on the site during construction and operations. A site plan showing the recycling storage area shall be submitted prior to the issuance of any grading or building permit for the site.

Level of Significance After Mitigation
Less than significant impact with mitigation incorporated.

Solid Waste Regulations
Impact UTIL-5: Would the project comply with federal, State, and local statutes and regulations related to solid waste?
Construction
During construction, the proposed project would be required to comply with Municipal Code Chapter 8.29 related to construction and demolition materials management. Compliance with this regulation would ensure compliance with AB 939 by ensuring construction waste is transferred to facilities that can adequately recycle solid waste. Thus, with compliance with the Visalia Municipal Code and AB 939, the proposed project would be required to comply with applicable solid waste regulations and statutes. Therefore, impacts related to solid waste regulations consistency are less than significant.

Operation
During operation, the proposed project would be required to comply with applicable State and local laws and regulations related to solid waste such as AB 939, SB 1383 related to organic waste, AB 341 and AB 32 related to recycling, and Municipal Code Chapter 8.28 related to solid waste collection and disposal. Adherence to AB 939, SB 1383, AB 341, AB 32, and the Municipal Code would ensure sufficient solid waste collection and transportation is available and would ensure that disposal sites contain sufficient capacity through permit review and inspections and recycling programs are implemented to divert waste. As such, operation of the proposed project would not impede the ability of the City to meet waste diversion requirements or cause the City to violate State and local statutes and regulations related to solid waste. Therefore, with compliance with applicable State and City laws and regulations requiring recycling and waste diversion from landfills, operational impacts related to solid waste regulations consistency would be less than significant.

Level of Significance
Less than significant impact.

Mitigation Measures
None required.
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3.15.7 - Cumulative Impacts
Water
The geographic scope of the cumulative potable water analysis is the service area of Cal Water Visalia District, which provides potable water to residents and businesses within the City service area. The WSA evaluates the adequacy of the City’s total project water supplies, including existing water supplies and future planned water supplies, to meet the City’s existing and projected future water demands, including those future water demands associated with the proposed project, under all hydrological conditions (Normal Years, Single Dry Years, and Multiple Dry Years).

Cumulative projects, including those listed in Chapter 3, Environmental Impact Analysis, Table 3-1, Cumulative Projects, are located within the areas of the City. As discussed under Impact UTIL-2, a WSA was completed for the proposed project that evaluated projected water demand associated with the proposed project, in addition to existing and other planned future users within the Visalia District service area. Water demand within the City’s water service area is not expected to exceed the City’s supplies at buildout under normal hydrologic conditions based on the City’s existing supplies coupled with the implementation of its additional future planned projects. Furthermore, some of the cumulative projects would convert the existing agricultural use to other uses which have a significantly smaller water demand.

Developers of the other cumulative projects would be required to pay their proportionate share of required funding to the City for completion of water infrastructure improvements (which includes recycled water infrastructure) as included in the City’s Capital Improvement Program (CIP). In addition, cumulative projects, such as those listed in Table 3-1, would be required to comply with provisions of the applicable laws and regulations in the Municipal Code and CALGreen related to water conservation. Therefore, cumulative impacts would be less than significant. As discussed above, the proposed project would also be required to comply with City/County ordinances and General Plan policies, as well as other laws and regulations that address water supply. The proposed project would also be required to pay applicable impact fees to help facilitate the completion of necessary water infrastructure. For these reasons, the proposed project would not have a cumulatively considerable contribution toward this less than significant cumulative impact related to water supply and treatment.

Wastewater
The geographic scope of the cumulative wastewater analysis is the service area of the City, which provides wastewater collection and treatment services for the City and its service area.

The City has estimated wastewater generated from its existing and future development in the service area and forecasted the needed facility upgrades. The forecast included treatment facility upgrades needed to accommodate existing needs and the planned growth in the service area and to maintain compliance with applicable regulatory standards for wastewater treatment and discharge.

The City has recently upgraded its WCP. The WCP has a capacity to treat 22 million GPD and currently treats approximately 13 million GPD.
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The cumulative projects, including those listed in Chapter 3, Environmental Impact Analysis, Table 3- 1, located in the City are within the service area and would generate volumes of wastewater conveyed to and treated at the WCP. Cumulative projects not located in the City or its service area would convey wastewater to the applicable wastewater treatment plant and are not included in this cumulative analysis. The City has anticipated planned growth and determined that capacity would exist to service the demand for wastewater treatment facilities given the existing capacity coupled with the upgrades discussed in Impact UTL-3. Projects within the service area would be required to pay applicable fees in effect at the time building permits are issued. Therefore, the proposed project’s contribution to this less than significant impact related to wastewater generation and treatment would not be cumulatively considerable.

Storm Drainage
The geographic scope of the cumulative analysis of storm drainage is projects within the City, consisting of areas that drain to the storm drainage system and to the Kaweah River’s Delta system.

The cumulative projects within the City would undergo its own CEQA review, which would evaluate and be required to mitigate any potential significant impacts with storm drainage pursuant to applicable laws and regulations. In addition, consistent with measures in the Municipal Code and other applicable standards and requirements, all development in the City would be required to incorporate a stormwater control plan and stormwater collection systems into the development that would in turn reduce the volume and velocity of stormwater runoff that cumulative projects would generate to adhere to applicable performance standards. Therefore, cumulative impacts in this regard would be less than significant.

As discussed above, the proposed project would have a less than significant impact on storm drainage. Therefore, the proposed project’s contribution to this less than significant impact related to storm drainage would not be cumulatively considerable. (See also Section 3.10, Hydrology and Water Quality).

Solid Waste
The geographical area for considering cumulative impacts associated with solid waste is the geographic area covered by the Tulare County Solid Waste Division.

Cumulative projects, including those listed in Chapter 3, Environmental Impact Analysis, Table 3-1 consist predominantly of industrial and residential uses. However, as with the surrounding areas, new cumulative development (residential and nonresidential) would increase demand on solid waste facilities to receive, process, and store solid waste. Existing solid waste facilities provide sufficient capacity to serve all development anticipated in the City, as well as existing, planned, and probable future land uses in the City for the foreseeable future.

As of this writing, these landfills have a combined maximum capacity of 40,071,173 cubic yards and a remaining capacity of 22,340,353 cubic yards. Additionally, other cumulative projects within the cumulative geographic context, would be required to comply with applicable federal, State, and local laws, regulations and policies to address and mitigate, as necessary, any potentially significant 2915
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impacts related to solid waste. For these reasons, cumulative impacts to solid waste would be less than significant.

The proposed project’s contribution to this less than significant cumulative impact would not be cumulatively considerable. The anticipated waste volume of development associated with the proposed project represents less than 1 percent of the landfill’s permitted daily capacity.

Furthermore, implementation of MM UTIL-1 would require that a recycling coordinator be identified to ensure the separation and proper disposal of recyclable materials and solid waste during construction. MM UTIL-1 also requires having recycling areas and receptacles on-site during construction to encourage recycling of materials to the extent feasible. Therefore, the proposed project, in conjunction with other cumulative projects, would result in a less than significant cumulative impact related to solid waste generation and landfill capacity.

Energy
Cumulative analysis with respect to Energy is addressed in Section 3.6, Energy.

Telecommunications
Cumulative projects would increase demand for internet and telephone services provided by local telecommunications providers. These cumulative projects would coordinate with telecommunication providers to provide service, and would be required to ensure there is sufficient capacity to serve each project, through analysis and adequate mitigation, as necessary. For these reasons, cumulative impacts with respect to telecommunications would be less than significant.

The proposed project would also coordinate with telecommunication providers to provide service, which has capacity to serve project operations, and the proposed project’s contribution to the less than significant cumulative impact would not be cumulatively considerable. Therefore, the proposed project, in conjunction with other cumulative projects, would result in a less than significant cumulative impact related to telecommunications.

Mitigation Measures
Implement MM UTIL-1.

Level of Cumulative Significance
Less than significant impact with mitigation incorporated. 2916
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3.16 - Wildfire

3.16.1 - Introduction
This section describes the existing wildfire conditions on the project site and vicinity as well as the regulatory framework related to the potential environmental effects associated with wildfire. The section also explains the methodologies used in evaluating these potential impacts, the criteria used to evaluate the significance of potential impacts, and an analysis of potential impacts related to wildfire that could result from implementation of the proposed project. The analysis in this section is based, in part, on review of the project plans, the City’s General Plan and General Plan Environmental Impact Report, information from the California Department of Forestry and Fire Protection (CAL FIRE), and CAL FIRE Tulare County Fire Hazards Severity Zone (FHSZ) Maps, the Biological Resources Assessment provided in Appendix C, and the Phase I Environmental Site Assessment provided in Appendix F of this Draft EIR.

No public comments were received during the Notice of Preparation (NOP) scoping period related to wildfire.

Wildfire Hazard Area Designations
CAL FIRE is responsible for mapping fire hazards within State Responsibility Areas (SRAs) based on fuel loading, slope, fire weather, and other relevant factors present, including areas where winds have been identified as a major cause of wildfire spread.

These zones, referred to as FHSZ classify a wildland zone as Moderate, High, or Very High fire hazard based on the average hazard across the area included in the zone. There are also “Fire Protection Responsibility Areas” (non-SRA), delineated as either a Federal Responsibility Area (FRA) or a Local Responsibility Area (LRA).

3.16.2 - Environmental Setting
Project Site
Pursuant to the CAL FIRE’s Fire Hazard Severity Zone Map, the project site is not located in or near an SRA and also does not contain lands classified as a Very High Fire Hazard Severity Zone (VHFHSZ). 1 According to the CAL FIRE FHSZ Maps for the LRA, the project site is classified as LRA Unzoned, which means that the project site is outside of areas identified by CAL FIRE as having substantial or very high risk. The Unit Strategic Fire Plan for the CAL FIRE Tulare Unit designates the project site as being located within an Agriculture area by the County.2
The closest mapped FHSZ is an SRA Moderate Zone located approximately 15 miles east of the project site, at the outer city limits of the City of Exeter. There is a FRA Moderate Zone located 1 California Department of Fire and Forest Protection (CAL FIRE). 2023. FHSZ Viewer. Website: https://egis.fire.ca.gov/FHSZ/. Accessed February 15, 2023. 2 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. Unit Strategic Fire Plan CAL FIRE/Tulare Unit. May. 2917
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approximately 23 miles to the southwest of the project site just outside of the City of Lemoore city limits.3 The nearest VHFHSZ is located over 25 miles east of the project site.

In addition, the City of Visalia General Plan (General Plan) does not designate the project site as a fire hazard area. According to General Plan Figure 8-4, Fire Hazards and Public Safety Services, there is an area of moderate fire susceptibility located along North Plaza Drive between West Ferguson Avenue and Goshen Avenue, which is located approximately 3,700 feet southwest of the project site.4
Wildfire-conducive Conditions
Grassland or other vegetation in California is easily ignited, particularly in dry seasons. Wildfire is a serious hazard in high dry fuel load areas, particularly near areas of natural vegetation and steep slopes since fires tend to burn more rapidly on steeper terrain. Wildfire is also a serious hazard in areas of high wind, given that fires will travel faster and farther geographically when winds are higher. Furthermore, wildfire is more likely in areas where electric power lines are located above ground where they may encounter vegetation or building materials.

Project Site
The vast majority of the project site (approximately 284 acres) consists of an active almond orchard, with the remaining portions of the project site consisting of some non-native planted ornamental trees, access roads and small amounts of vegetation. All orchard areas are actively managed, with sparce herbaceous understory plant cover that consists of managed ruderal non-native grasses and forbs, and tree cover. Barren areas on the project site consist of access roads, which are currently dirt with small amounts of managed, non-native invasive grasses and forbs on edges. In addition, there are streetlights and above ground power and telecommunication lines in various locations adjacent to the project site. The project site is gently sloping toward the east but does not contain significant slopes. Additionally, the project site is surrounded by agricultural and industrial areas and is not located adjacent to wildlands or grasslands or in a wildland urban interface (WUI) area.

Emergency and Evacuation Routes/Access
Project Site
Based on its location, the most likely evacuation routes from the project site would be SR-198 (in the east–west direction), and SR-99 and SR-63 (in the north–south direction). These routes are approximately 2 miles, 2.15 miles, and 3.66 miles away from the project site, respectively.

Post-fire Slope Instability and Drainage Pattern Changes Slope instability from wildfire scarring of the landscape can result in slope instability in the form of more intensive flooding and landslides. These post-fire slope soils and altered drainage patterns can more easily creep away downslope sides of foundations and reduce lateral support. 3 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. Unit Strategic Fire Plan CAL FIRE/Tulare Unit. May. 4 City of Visalia. 2014. Visalia General Plan Chapter 8: Safety and Noise, Figure 8-4: Fire Hazards and Public Safety Services. October. 2918
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Project Site
The project site has not been impacted from previous wildfire damage or post-fire drainage pattern changes.5 As described previously, the project site contains relatively level elevation and does not contain steep slopes. The prevailing wind pattern is from the northwest.

Water Supply and Infrastructure
Water supplies and water infrastructure is needed to address firefighting capacity within the project site. Potential loss of water pressure during a fire may decrease available water supplies, and the potential loss of power may eliminate the supply of water to the project site. Therefore, the following discussion addresses water supplies, infrastructure, and power to evaluate potential wildfire risk impacts.

Project Site
Water for the proposed project would be provided by the City’s water supply (provided by Cal Water). The proposed project would require connection to City-owned utility and infrastructure. The applicant would be required to comply with all applicable standards, including public and private fire hydrants, to ensure the provision of adequate water pressure and durations as specified by the City’s Hydrant Ordinance. According to the Hydrant Ordinance, light industrial developments require a minimum flow of 2,000 gallons per minute at 20 psi residual pressure at any required fire hydrant.6 During the development review process for the proposed project, City staff and the Visalia Fire Department would review water flow and distribution requirements as well as infrastructure to confirm adequate water pressure for firefighting.

3.16.3 - Regulatory Framework
Federal
United States Department of Interior, Office of Wildland Fire This federal agency develops, reviews and updates federal policy related to wildland fire management to ensure consistent and effective program implementation across the Department of the Interior and its many partners. To that end, this federal agency adopted the 1995 Federal Wildland Fire Management Policy (January 2001), which sets forth the following that are relevant to this analysis:

1. Safety—Firefighter and public safety is the first priority. All Fire Management Plans and activities must reflect this commitment.

2. Fire Management and Ecosystem Sustainability—The full range of fire management activities will be used to help achieve ecosystem sustainability, including its interrelated ecological, economic, and social components.

3. Response to Wildland Fire—Fire, as a critical natural process, will be integrated into land and resource management plans and activities on a landscape scale, and across agency boundaries. Response to wildland fire is based on ecological, social, and legal consequences 5 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. History of Wildfires. Website:
https://projects.capradio.org/california-fire-history/#9.77/36.3423/-119.3612. Accessed November 9, 2022. 6 City of Visalia. 2001. Municipal Code Section 16.36.120 Water mains, fire hydrants and fire department access. Website:
https://www.visalia.city/civicax/filebank/blobdload.aspx?blobid=4255. Accessed November 22, 2022. 2919
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of the fire. The circumstances under which a fire occurs, and the likely consequences on firefighter and public safety and welfare, natural and cultural resources, and values to be protected dictate the appropriate management response to the fire.

4. Use of Wildland Fire—Wildland fire will be used to protect, maintain, and enhance resources and, as nearly as possible, be allowed to function in its natural ecological role.

Use of fire will be based on approved Fire Management Plans and will follow specific prescriptions contained in operational plans.

5. Rehabilitation and Restoration—Rehabilitation and restoration efforts will be undertaken to protect and sustain ecosystems, public health, and safety, and to help communities protect infrastructure.

6. Protection Priorities—The protection of human life is the single, overriding priority. Setting priorities among protecting human communities and community infrastructure, other property and improvements, and natural and cultural resources will be based on the values to be protected, human health and safety, and the costs of protection. Once people have been committed to an incident, these human resources become the highest value to be protected.

7. Wildland Urban Interface—The operational roles of federal agencies as partners in the WUI are wildland firefighting, hazardous fuels reduction, cooperative prevention and education, and technical assistance. Structural fire suppression is the responsibility of tribal, State, or local governments. Federal agencies may assist with exterior structural protection activities under formal Fire Protection Agreements that specify the mutual responsibilities of the partners, including funding. (Some federal agencies have full structural protection authority for their facilities on lands they administer and may also enter into formal agreements to assist State and local governments with full structural protection.)

8. Planning—Every area with burnable vegetation must have an approved Fire Management Plan. Fire Management Plans are strategic plans that define a program to manage wildland and prescribed fires based on the area’s approved land management plan. Fire Management Plans must provide for firefighter and public safety; include fire management strategies, tactics, and alternatives; address values to be protected and public health issues; and be consistent with resource management objectives, activities of the area, and environmental laws and regulations.

9. Science—Fire Management Plans and programs will be based on a foundation of sound science. Research will support ongoing efforts to increase our scientific knowledge of biological, physical, and sociological factors. Information needed to support fire management will be developed through an integrated interagency fire science program.

Scientific results must be made available to managers in a timely manner and must be used in the development of land management plans, Fire Management Plans, and implementation plans.

10. Preparedness—Agencies will ensure their capability to provide safe, cost-effective fire management programs in support of land and resource management plans through appropriate planning, staffing, training, equipment, and management oversight.

11. Suppression—Fires are suppressed at minimum cost, considering firefighter and public safety, benefits, and values to be protected, consistent with resource objectives. 2920
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12. Prevention—Agencies will work together and with their partners and other affected groups and individuals to prevent unauthorized ignition of wildland fires.

13. Standardization—Agencies will use compatible planning processes, funding mechanisms, training and qualification requirements, operational procedures, values to be protected methodologies, and public education programs for all fire management activities.

14. Interagency Cooperation and Coordination—Fire management planning, preparedness, prevention, suppression, fire use, restoration and rehabilitation, monitoring, research, and education will be conducted on an interagency basis with the involvement of cooperators and partners.

15. Communication and Education—Agencies will enhance knowledge and understanding of wildland fire management policies and practices through internal and external communication and education programs. These programs will be continuously improved through the timely and effective exchange of information among all affected agencies and organizations.

16. Agency Administrator and Employee Roles—Agency administrators will ensure that their employees are trained, certified, and made available to participate in the wildland fire program locally, regionally, and nationally as the situation demands. Employees with operational, administrative, or other skills will support the wildland fire program as necessary. Agency administrators are responsible and will be held accountable for making employees available.

17. Evaluation—Agencies will develop and implement a systematic method of evaluation to determine effectiveness of projects through implementation of the 2001 Federal Fire Policy.

The evaluation will assure accountability, facilitate resolution of areas of conflict, and identify resource shortages and agency priorities.

State
California Emergency Response Plan
California has developed an emergency response plan to coordinate emergency services provided by federal, State, and local governments and private agencies. Responding to hazardous materials incidents is one part of this plan. The plan is administered by the California Governor’s Office of Emergency Services, which coordinates the responses of other agencies. When Tulare County experiences an emergency, an Emergency Operations Center may be opened. In the event an Emergency Operations Center is opened, emergency response team members coordinate efforts and work with local fire and police agencies, emergency medical providers, the California Highway Patrol, CAL FIRE, California Department of Fish and Wildlife (CDFW), and Caltrans.

California Department of Forestry and Fire Protection Threat Potential Mapping CAL FIRE has mapped fire threat potential throughout California. CAL FIRE maps fire threat based on the availability of fuel and the likelihood of an area burning (based on topography, fire history, and climate). The threat levels include no fire threat, Moderate, High, and Very High fire threat. While FHSZs do not predict when or where a wildfire will occur, they do identify areas where wildfire hazards could be more severe and, therefore, are of greater concern. According to the CAL FIRE FHSZ 2921
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Maps for the LRA, the project site is classified as LRA Unzoned. Given this designation, the project site is outside of areas identified by CAL FIRE as having substantial or very high risk. The land immediately east, west, and south of the project site consists of agricultural uses with a mix of row crops and orchards, while the land to the south and west is used for industrial warehouses and residential uses. The land surrounding the project site is categorized as LRA Unzoned. The nearest VHFHSZ is located over 25 miles east of the project site. In addition, the Unit Strategic Fire Plan for the CAL FIRE Tulare Unit designates the project site as being located within an Agriculture area by the County.
7 California Building Code
Chapter 7 of the 2022 California Building Standards Code (CBC) details the materials, systems, and/or assemblies used in the exterior design and construction of new buildings located within a WUI Fire Area. A WUI Area is defined in Section 702A as a geographical area identified by the State as a FHSZ in accordance with the Public Resources Code Sections 4201–4204 and Government Code Sections 51175–51189, or other areas designated by the enforcing agency to be at a significant risk from wildfires. The CBC details the materials, systems, and assemblies used for structural fire resistance and fire-resistance-rated construction separation of adjacent spaces to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings. The City adopted the CBC in Chapter 15 of the City of Visalia Municipal Code (Municipal Code).

California Public Resources Code
California Public Resources Code Sections 4201-4204 and Government Code Sections 51175-51189 directs CAL FIRE to map FHSZ within SRAs and LRAs. Areas of significant fire hazards are identified based on fuels, terrain, weather, and other relevant factors. The FHSZs define the type of mitigation strategies to be applied to reduce risks associated with wildland fires. SRAs and were originally mapped by CAL FIRE in 1985 and LRAs in 1996. Within SRAs, the Director of CAL FIRE has designated areas as Moderate, High, and VHFHS. Outside of SRAs, but within LRAs, the Director of CAL FIRE was charged with recommending the locations of VHFHSZs. California Public Resources Code Sections 4291–4299 et seq. requires that brush, flammable vegetation, or combustible growth within 100 feet of buildings be maintained. Vegetation that is more than 30 feet from the building, less than 18 inches high, and is important for soil stability may be maintained, as may single specimens of trees or other vegetation that is maintained to manage fuels and would not form a means of rapid fire transmission from other nearby vegetation to a structure. California Public Resources Code Sections 4291–4299 et seq. applies to both high fire threat districts, as determined by the California Public Utilities Commission (CPUC) pursuant to its rulemaking authority, and SRAs. Additionally, the Public Resources Code outlines infraction fees, certification, and compliance procedures applicable with State and local building standards, including those described in Government Code Section 51189(b).

The California Public Resources Code includes fire safety regulations that restrict the use of equipment that may produce a spark, flame, or fire; require the use of spark arrestors8 on construction equipment that use an internal combustion engine; specify requirements for the safe 7 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. Unit Strategic Fire Plan CAL FIRE/Tulare Unit. May. 8 A spark arrestor is any device that prevents the emission of flammable debris from a combustion source (i.e., fireplaces, internal combustion engines, and wood burning stoves).
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use of gasoline-powered tools in fire hazard areas; and specify fire suppression equipment that must be provided on-site for various types of work in fire-prone areas.

These regulations include the following:
• Earthmoving and portable equipment with internal combustion engines will be equipped with a spark arrestor to reduce the potential for igniting a wildland fire (Public Resources Code [PRC] § 4442).
• Appropriate fire suppression equipment will be maintained during the highest fire danger period—from April 1 to December 1 (PRC § 4428).
• On days when a burning permit is required, flammable materials will be removed to a distance of 10 feet from any equipment that could produce a spark, fire, or flame, and the construction contractor will maintain the appropriate fire suppression equipment (PRC § 4427). • On days when a burning permit is required, portable tools powered by gasoline-fueled internal combustion engines will not be used within 25 feet of any flammable materials (PRC § 4431).

Regional
CAL FIRE Tulare Unit Strategic Fire Plan
The CAL FIRE Tulare Unit Strategic Fire Plan (Fire Plan), updated in May 2022, is the most current document that assesses the wildland fire situation throughout the SRA within CAL FIRE jurisdiction.

The Fire Plan was created to assist the CAL FIRE Tulare Unit with pre-suppression projects which exist within each Battalion. The CAL FIRE Tulare Unit plans, identifies, and evaluates priority landscape, fire hazards, and wildfire risk. Additionally, it identifies opportunities for reducing structural ignitability, and identifies potential fuel reduction projects and techniques for minimizing those risks.

The Fire Plan gives an overview of CAL FIRE Tulare Unit Battalions and ranks these areas in terms of priority needs as well as identifies the areas of SRA. According to the Fire Plan, 19.3 percent of Tulare County areas are within an SRA. Tulare County is broken up into four different fuel management areas, including Badger, Kaweah, Tule, and Fountain Springs. The project site is located adjacent to Kaweah Battalion 4112, but is not within an SRA and is not directly within the jurisdiction of a fuel management area.9 The CAL FIRE Tulare Unit has mutual aid agreements with the Visalia Fire Department.

Multi-Jurisdictional Local Hazard Mitigation Plan
The Multi-Jurisdictional Local Hazard Mitigation Plan (MJLHMP), updated in 2017, assesses the natural, technological, and human-caused risks to County communities, and reduces the potential impact of the hazards by creating mitigation strategies. The MJLHMP complies with The Federal Disaster Mitigation Act of 2000 (DMA 2000), Federal Register 44 Code of Federal Regulations Parts 201 and 206. This law, as of November 1, 2004, requires local governments to develop and submit hazard mitigation plans as a condition of receiving Federal Emergency Management Agency (FEMA) Hazard Mitigation Grant Program (HMGP) and other mitigation project grants. The County; the Cities 9 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. Unit Strategic Fire Plan CAL FIRE/Tulare Unit. May. 2923
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of Dinuba, Exeter, Farmersville, Lindsay, Porterville, Tulare, Visalia, and Woodlake; the Tule River Tribe; and Tulare County Office of Education staffs coordinated to prepare the MJLHMP.

Local
City of Visalia Municipal Code
Visalia Fire Code
Chapter 8.20 of the Municipal Code details the Visalia Fire Code, which is an adoption of the 2019 California Fire Code with some amendments. The purpose of the Visalia Fire Code is to regulate the safeguarding of life, property, and public welfare to a reasonable degree from the hazards of fire, hazardous materials release, and/or explosion due to handling of dangerous and hazardous materials, conditions hazardous to life or property in the occupancy and use of buildings and premises, the operation, installation, construction, and location of attendant equipment, the installation and maintenance of adequate means of egress, and providing for the issuance of permits and collection of fees.

Visalia Hydrant Ordinance
Chapter 16.36.120 of the Municipal Code outlines the following requirements for water mains, fire hydrants, and fire department access:

The subdivider shall install water mains, fire hydrants and provide fire department access when required. The costs associated with such installations shall be at the expense of the subdivider. Fire hydrants, water mains and fire department access shall be installed in accordance with the following:

A. The water system, including water mains and fire hydrants, shall be installed and in operation prior to the commencement of building construction on any site within the subdivision unless otherwise authorized by the fire marshal, fire chief and/or their designee.

B. Fire hydrants shall be of a type approved by the fire marshal, fire chief and/or their designee.

C. The minimum water main line size to serve any fire hydrant shall be 6 inches in diameter.

D. A gate valve shall be installed between the tee in the main and the fire hydrant.

E. Minimum water flow shall comply with the following requirements:

1. Single-family developments shall require a minimum flow of 1,000 gallons per minute at 20 psi residual pressure at any required fire hydrant. 2 Multi-family, one or two story, zero lot line clearance, condominiums, and mobile home parks, light commercial and light industrial developments shall require a minimum flow of 2,000 gallons per minute at 20 psi residual pressure at any required fire hydrant.

3. Multi-family, three stories or higher, heavy commercial and heavy industrial development shall require a minimum flow of 2,500 gallons per minute at 20 psi residual pressure at any required fire hydrant.

F. Water systems, other than California Water Service Company mains, supplying fire hydrants shall comply with the current adopted Fire Code.
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1. A backup pump shall be provided with an alternative source of power and the backup pump shall be capable of supplying the required fire flow.

2. The alternative source of power must be different from the primary course of power and must be installed with the capacity of delivering the minimum flow requirements specified above and comply with the flow duration established in the Uniform Fire Code.

3. The alternative source of power shall automatically turn on in the event of failure of the primary source of power.

G. Fire hydrant spacing shall comply with the following requirements:
1 Single-family residential developments shall be provided with fire hydrants every 600 lineal feet of residential frontage. In isolated developments, no less than two fire hydrants shall be provided not more than 600 lineal feet apart from one another.

2. Multi-family, zero lot line clearance, mobile home park or condominium developments shall be provided with fire hydrants every 400 feet of residential frontage. In isolated developments, no less than two fire hydrants shall be provided not more than 400 lineal feet apart from one another.

3. Multi-family or condominium developments with 100 percent coverage fire sprinkler systems shall be provided with fire hydrants every 600 lineal feet of multi-family or condominium frontage. In isolated developments, no less than two fire hydrants shall be provided not more than 600 lineal feet apart from one another. 4 Commercial and industrial shall be provided with fire hydrants every 300 hundred feet of commercial or industrial frontage. In isolated developments, no less than two fire hydrants shall be provided not more than 300 lineal feet apart from one another.

5. Commercial or industrial developments with 100 percent coverage fire sprinkler systems shall be provided with fire hydrants every five hundred lineal feet of commercial or industrial frontage. In isolated developments, no less than two fire hydrants shall be provided not more than 5000 lineal feet apart from one another.

6. When any portion of a building is in excess of 150 feet from a water supply on a public street, there shall be provided, when required by the fire marshal, fire chief and/or their designee, on-site fire hydrants and water mains capable of supplying the required fire flow, or suitable fire appliances of a type approved by the fire marshal, fire chief and/or their designee.

7. Any building provided with a fire sprinkler system shall provide a fire hydrant within 50 feet of the fire department connection.

8. The exact location of fire hydrants within or adjacent to subdivisions and the final decision as to the number of fire hydrants shall be at the discretion of the fire marshal, fire chief, and/or their designee.

H. Fire department access shall comply with current adopted Fire Code.

I. Every building constructed shall be accessible to fire department apparatus by way of access roadways with an all weather driving surface of not less than 20 feet of unobstructed width, capable of supporting the imposed loads of fire apparatus and having a minimum of 13 feet 6 inches in vertical clearance. Dead-end access roadways longer than 150 feet shall have a turnaround area designed and constructed in accordance to City standards. When deemed 2925
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necessary by the fire marshal, fire chief and/or their designee, access road will be declared fire lanes and will comply with the requirements established in the Uniform Fire Code. Fire department access shall be provided prior to the commencement of building construction on any site within the subdivision unless otherwise authorized by the fire marshal, fire chief and/or their designee.

J. Nothing in the above regulations shall prevent the fire marshal, fire chief, and/or their designee from making special requirements as based on the appropriate level of fire protection for a particular system.

K. The fire chief may adopt, amend and enforce regulations necessary to implement this section, in accordance with the procedures outlined in the City's policy permitting adoption, amendment or repeal of regulations. (Ord. 2017-01 (part), 2017: Ord. 2013-07, 2013).

City of Visalia Emergency Operations Plan
The City’s Emergency Operations Plan (EOP) was adopted in 2011. The City’s EOP is designed to establish a framework for implementation of the California Standardized Emergency Management System for the City, which is located within the Governor's Office of Emergency Service’s Mutual Aid Region V. The City’s EOP is used in conjunction with the Tulare County’s EOP, which incorporates the County’s updated 2011 Evacuation Plan, establishes responsibilities, threat levels, and triggers for evacuation, evacuation areas, and evacuation routes to be used in case of catastrophic emergencies, including wildfire. The EOP also addresses the planned response to extraordinary emergency situations associated with natural disasters, technological incidents, and national security emergencies in or affecting the City of Visalia.

This plan accomplishes the following:
• Establishes the emergency management organization required to mitigate any significant emergency or disaster affecting the City of Visalia.
• Identifies the policies, responsibilities and procedures required to protect the health and safety of the City of Visalia community, public and private property and the environmental effects of natural and technological emergencies and disasters. • Establishes the operational concepts and procedures associated with Initial Response Operations (field response) to emergencies, the Extended Response Operations (City Emergency Operations Center [EOC] activities) and the recovery process.

City of Visalia General Plan
Chapter 8: Safety and Noise
Policies and Objectives
S-O-5 Provide a comprehensive program of safety services including police, fire and medical response in all parts of the Visalia Planning Area.

S-O-6 Provide comprehensive emergency response and evacuation routes for Visalia area residents.
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S-P-21 Develop a community wildfire mitigation plan that identifies and prioritizes areas for hazard fuel reduction treatments, and recommend the types of methods of treatments.

S-P-22 Manage vegetation in areas within and adjacent to public rights-of-way and in close proximity to critical facilities in order to reduce the risk of tree failure and property damage and avoid creation of wind acceleration corridors within vegetated areas.

S-P-25 Implement a fuel reduction program, such as the collection and disposal of dead fuel, within publicly-owned open spaces and around critical facilities located within a high and very high wildfire zones.

S-P-27 Implement a fuel modification program, which also includes residential maintenance requirements and enforcement, plan submittal and approval process, guidelines for planting, and a listing of undesirable plant species. Require builders and developers to submit their plans, complete with proposed fuel modification zones, to the Fire Department for review and approval prior to beginning construction.

S-P-28 Assist in solving the incendiary problem by improving law enforcement and investigation equipment, adapting equipment available in other fields; and purchasing new equipment where needed. Implement “no burn” programs, particularly in areas outside of immediate response zones of fire stations.

S-P-29 Ensure availability of adequate water supplies to meet public health and safety needs, and for resource protection, by maintaining the following order of priority for water use:
• Potable water supply, fire protection, and domestic use • Resource protection and preservation
• Industrial, irrigation and commercial uses
• Water-oriented recreation
• Air conditioning
S-P-30 Integrate the Tulare County Hazard Mitigation Plan, in particular the hazard analysis and mitigation strategy sections, into the development review process, the Emergency Operations Plan, and Capital Improvement Program, as appropriate.

3.16.4 - Methodology
Wildfire impacts are considered on the basis of: (1) off-site wildland fires that could result due to the proposed project, and (2) on-site generated combustion that could affect surrounding areas. The proposed project’s potential impacts associated with wildfires have been evaluated using a variety of resources, including CAL FIRE maps showing FHSZs, Fire and Resource Assessment Program (FRAP) and fire history, vegetation data from the Biological Resources Assessment and Phase I Environmental Site Assessment,
10 project location maps, and a review of the project site’s 10 Ninyo & Moore. 2022. Phase I Environmental Site Assessment Northeast Corner of West Riggin Avenue and Kelsey Street. July 20. 2927
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characteristics. Using the aforementioned resources and professional judgment, impacts were analyzed according to California Environmental Quality Act (CEQA) significance criteria described below.

3.16.5 - Thresholds of Significance
The Lead Agency derives its significance criteria based on the questions in the CEQA Guidelines Appendix G Environmental Checklist. Accordingly, wildfire impacts from implementation of the proposed project would be considered significant:

If located in or near SRAs or lands classified as VHFHSZ, the proposed project would:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan. b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

3.16.6 - Project Impacts and Mitigation Measures
This section discusses potential impacts associated with the development of the proposed project and provides feasible mitigation measures if required.

Emergency Response/Evacuation Plan Consistency
Impact WILD-1: If located in or near an SRA or lands classified as a VHFHSZ, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
Impact Analysis
As noted in the Hazards and Hazardous Materials section under Impact HAZ-7, the project site is not located in or near an SRA or lands classified as a VHFHSZ, pursuant to the CAL FIRE’s Fire Hazard Severity Zone Map.11 According to the CAL FIRE FHSZ Maps for the LRA, the project site is classified as LRA Unzoned, which means that the project site is outside of areas identified by CAL FIRE as having substantial or very high risk. The Unit Strategic Fire Plan for the CAL FIRE Tulare Unit designates the project site as being located within an Agriculture area by the County.12 Additionally, as discussed above, there is no history of wildfires on or near the project site.

Accordingly, the project site is not considered a high wildfire prone area. Therefore, because the 11 Ibid. 12 California Department of Forestry and Fire Prevention (CAL FIRE). 2022. Unit Strategic Fire Plan CAL FIRE/Tulare Unit. May. 2928
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project site is not located in or near an SRA or lands classified as a VHFHSZ, there would be a less than significant wildfire impact.

During construction, construction equipment and vehicles would access and leave the project site, which in turn could potentially impede evacuation or Emergency Vehicle Access (EVA). The City General Plan designates SR-198, SR-99, and SR-63 as evacuation routes consistent with the Tulare County Evacuation Plan.13 The foregoing State Routes are located 2 miles, 2.15 miles, and 3.66 miles from the project site, respectively. In addition to these evacuation routes that would likely be used in the event of a wildfire emergency, there are other main arterial roads that are in the vicinity and readily accessible, which could reasonably be assumed to serve as emergency evacuation routes in the project vicinity.

The proposed project’s primary access roads (Kelsey Street, Clancy Street, Shirk Street, and Riggin Avenue) allow adequate egress/ingress to the project site in the event of an emergency. These streets would connect to an internal road network within the project site, providing ample access for emergency vehicles in case of an emergency. Given the multiple evacuation routes available to the proposed project as well as other community members, coupled with several alternate main arterial roads that provide access to these identified evacuation routes, the proposed project’s construction would not substantially impair these evacuation routes.

Furthermore, the proposed project would be designed in accordance with the applicable City standards and the Tulare County MJLHMP to accommodate emergency evaluation by providing safe and ready access for emergency equipment and provide alternate routes for evacuation. As such, the proposed project would not substantially impair any adopted emergency response plan or emergency evacuation plan.

In conclusion, because the project site is not located in or near an SRA or lands classified as a VHFHSZ, the proposed project would have a less than significant impact in this regard. Moreover, the project site is not considered a high wildfire prone area, and the proposed project would not introduce environmental or public safety hazards that would increase the risk of ignition and or impede evacuation such that any existing environmental hazards would be exacerbated. Impacts would be less than significant.

During operation, the proposed project would be readily and adequately served by police and fire services (see Section 3.13, Public Services). Given the industrial nature of the proposed project, it would not create a permanent residential increase in population unaccounted for in the General Plan that could lead to overwhelming calls for emergency services. Additionally, the proposed project is not expected to trigger the need for significant additional law enforcement, fire protection, or emergency services. As noted above, given the availability of multiple evacuation routes available to the proposed project as well as other community members, coupled with several alternate main arterial roads that provide access to these identified evacuation routes, the proposed project’s operation would not substantially impair these evacuation routes and would not substantially impair any adopted emergency response plan or emergency evacuation plan. Furthermore, the proposed 13 City of Visalia. 2014. Visalia General Plan Chapter 8: Safety and Noise. 2929
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project would be designed to be consistent with all applicable Fire Code requirements and standards. Therefore, no mitigation is required and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Expose Project Occupants to Pollutant Concentrations from Wildfire Impact WILD-2: If located in or near an SRA or lands classified as a VHFHSZ, would the project due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Impact Analysis
A significant impact would occur if the project site were located in or near an SRA or lands classified as a VHFHSZ, and also contained specific conditions that would exacerbate wildfire risks, including exposure to wildfire related pollutants or uncontrolled spread of a wildfire. As noted above, the project site is not located in or near an SRA or lands classified as a VHFHSZ. Therefore, because this is the case, there would be a less than significant wildfire impact.

Slope and wind speed and can influence the spread of fires. Upslope topography eventually increases the spread rate of the fire in all fuel beds over flat conditions. As described previously, the project site has an elevation of approximately 303 feet above mean sea level (AMSL). The project site is predominantly flat with a gentle slope to the northwest.

The nearest air monitoring station that measures meteorological data is the Visalia Municipal Airport Station, located approximately 2.87 miles southwest of the project site. According to the California Air Resources Board (ARB), this station has an average wind speed of 6.9 mph and an annual maximum of 12 mph.14 While these wind speeds could potentially spread wildfires, the project site and vicinity are not in or near a WUI zone, and are bordered by urban development on two sides, with similar development planned in the area in the immediate future.15 Annual prevailing winds in the City of Visalia are from the northwest; therefore, the prevailing winds would blow fire embers away from the project site and would not exacerbate fire risk.16 As such, the project site and its surroundings do not embody conditions that would exacerbate wildfire in this regard.
14 California Air Resources Board (ARB). 2022. Tulare County – All Networks Annual Resultant Wind Summary Data 2022. Website:
https://www.arb.ca.gov/aqmis2/display.php?param=WINSPD_mph&year=2022&mon=8&day=18&hours=all&county_name=54- Tulare&basin=--AIR+BASIN--&latitude=--PART+OF+STATE--
&report=ASRPT&order=state%2Cbasin%2Ccounty_name%2Cname&network%5B%5D=ALL&submit=Retrieve+Data&ptype=met.

Accessed August 18, 2022. 15 California Department of Forestry and Fire Prevention (CAL FIRE). 2019. Wildland Urban Interface (WUI). December. 16 Western Regional Climate Center. 2022. Prevailing Wind Direction. Website:
https://wrcc.dri.edu/Climate/comp_table_show.php?stype=wind_dir_avg. Accessed November 22, 2022. 2930
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As noted in Impact WILD-1, the project site is not in a wildfire prone area. Additionally, the proposed project would not exacerbate exposure to pollutant concentrations due to wildfires.

The project site is designated as LRA Unzoned, which are considered areas with low fire frequency.

The potential for wildfire on the project site is not considered high. In addition, the project site has not previously experienced wildfire. The reduction in fuel load and relatively flat slope, as well as agricultural irrigation, further reduces the potential for wildfire to spread on-site. The proposed project would be adequately served by fire hydrant water pressure in accordance with applicable water distribution design criteria.

Given that the project site does not experience consistent high winds, is not located in or near an area of steep terrain or an area experiencing historical wildfire, and would be adequately served by water supplies, the project site would not be prone to greater wildfire risk.

During construction and operation, the proposed project would comply with applicable existing California Fire Code (Municipal Code 8.20) standards and requirements related to the maintenance of mechanical equipment, handling and storage of flammable materials, and cleanup of spills of flammable materials, as well as the installation of sprinkler systems and fire/smoke detection devices. The proposed project is not anticipated to expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire due to slope, prevailing winds, and other factors during construction.

In conclusion, because the project site is not located in or near an SRA or a VHFHSZ, it does not meet the threshold for a potentially significant impact. Moreover, the relatively flat terrain, lack of prevailing winds or other factors, the proposed project would not exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. Therefore, no mitigation is required and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Infrastructure That Exacerbates Fire Risk
Impact WILD-3: If located in or near SRAs or lands classified as VHFHSZ would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Impact Analysis
See Impacts WILD-1 and WILD-2. The project site is not located in or near an SRA or lands classified as a VHFHSZ. Therefore, there would be a less than significant wildfire impact. 2931
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Development of the proposed project would include road improvements and internal roadways to allow for vehicular travel. However, the proposed project would not require the installation of firebreaks, because it is in a generally urbanized area surrounded by existing urban development with little natural vegetation and is not considered a high wildfire prone area, as discussed at length above.

The proposed project would be required to implement applicable provisions of the Fire Code, including, among others, adhering to the minimum fire flows, the minimum spacing for and numbers of fire hydrants, sprinkler systems, smoke detection devices, and fire department access requirements.

Fire hydrants must be of a type approved by the Fire Marshal or Fire Chief. Therefore, the project site would have adequate water supplies for firefighting purposes and would have adequate access to fire hydrants, as well as adequate emergency access. New utilities such as electrical power and natural gas lines would be installed below ground, helping to reduce potential ignition and related fire risk above ground, as well as reducing the possibility of a power outage during a fire since underground power lines are less likely to be damaged by falling branches or flying debris.

In conclusion, due, in part to its location and the incorporation of project design features such as road improvements, availability of adequate water supply for firefighting purposes, undergrounding of new utility lines, and adherence to applicable laws and regulations relating to fire protection, the proposed project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Therefore, no mitigation is required, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

Flooding and Landslide Hazards Due to Post-fire Slope Instability/Drainage Changes Impact WILD-4: If located in or near an SRA or lands classified as a VHFHSZ, would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
Impact Analysis
See Impacts WILD-1 through WILD-3.

The project site is not located on or near steep slopes susceptible to landslides or downstream flooding. As discussed previously, the project site has also not been affected by previous wildfires that could have resulted in drainage changes or loss of vegetation. Additionally, the project site is not located in or near fire-prone areas, such as unmanaged open space or a designated fire hazard zone.

In addition, the proposed project would be required to implement a SWPPP pursuant to applicable laws and regulations, which would include erosion and sediment control BMPs during construction, thereby reducing the potential of erosion and siltation during construction and would control potential flooding events that could occur during construction. Also, the proposed project would 2932
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install an on-site storm drainage system consisting of inlets, underground piping, and detention basins that would be required to adhere to all applicable standards and requirements pursuant to applicable laws and regulations. Runoff would drain to the proposed project’s drainage system located throughout the project site. The system would be designed to meet all applicable standards and requirements including accommodating a 100-year storm event and would be required to detain runoff and release it at a rate no greater than the pre-development condition of the project site.

In conclusion, the project site is not considered a high wildfire prone area; it would be required to implement all applicable standards and requirements related to wildfires and fire protection.

Therefore, the proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. No mitigation is required, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Significance
Less than significant impact.

3.16.7 - Cumulative Impacts
The geographic scope of the cumulative wildfire analysis is the City of Visalia and the western portion of Tulare County because based on the overall topography and existing development (including natural and man-made fire breaks), a fire event beyond this geographic scope is unlikely to affect the proposed project, and any fires starting in the project site and vicinity would not likely significantly affect lands beyond this geographic scope. The cumulative setting includes the built development and the wildland areas within the foregoing geographic scope. The cumulative projects relevant to this analysis include those listed in Chapter 3, Project Description, Table 3-1, Cumulative Projects. The City contains mostly urban and suburban uses with relatively little open space or foothill areas that would be susceptible to wildfire hazards. The western portion of Tulare County, which lies west of Sequoia National Park, contains the cities of Visalia, Tulare, Farmersville, Exeter, Woodlake, Lindsay, Porterville, and Dinuba as well as many “Urban Development” areas as identified by the Tulare County General Plan.
17 The western portion of Tulare County is predominantly within an LRA, with areas to the east of the cities of Woodlake, Exeter, Lindsay and Porterville identified as areas of “Moderate” and “High) FHSZ within a SRA.18 According to CAL FIRE, there are no VHFHSZs within City boundaries or its Sphere of Influence (SOI). With respect to the western portion of Tulare County, which is predominantly within an LRA, there are no areas identified as VHFHSZ. 19 In addition,
there are no SRA within the City or the western portion of Tulare County, and none of the cumulative projects are located in or near an SRA or lands classified as a VHFHSZ.

Because none of the cumulative projects are located in or near an SRA or lands classified as a VHFHSZ cumulative impacts would be less than significant. 17 Tulare County. 2021. Tulare County General Plan 2030 Update. August. 18 California Department of Forestry and Fire Protection (CAL FIRE). 2023. FHSZ Viewer. Website: https://egis.fire.ca.gov/FHSZ/.

Accessed February 23, 2023. 19 Ibid.
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Moreover, a combination of federal, State, and local laws and regulations help to limit or minimize the potential for exposure to wildfires by reducing the amount of development in WUI areas, ensuring new projects are developed according to the CBC and Fire Code and related standards and requirements, and incorporating mandates for fire-resistant construction into land use planning.

There are several plans at the County and City level that further help to implement various requirements, recommendations and guidelines to further reduce risks associated with wildfires.

The Cumulative Development listed in Table 3-1 (See Chapter 3: Environmental Impact Analysis) consists predominantly of residential, commercial, and industrial developments, which would result in an additional number of persons and structures with the geographic scope. Planned uses proposed by the cumulative projects would increase the need for emergency services to a certain degree, and all development would be required to comply with applicable emergency access requirements and other Fire Code related mandates (e.g., relating to fire hydrants, fire flow, etc.), which would be imposed as enforceable standard conditions of approval. Given the location of the relevant cumulative developments, it is anticipated that the identified evacuation routes of SR-198 (east–west), SR-99 (north–south), and SR-63 (north–south) would be available and would not be substantially impaired. The cumulative developments would also need to comply with applicable laws and regulations relating to erosion and sediment control, thereby helping to further reduce significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

There would be cumulative project construction (including the installation and/or maintenance of associated infrastructure such as roads, fuel breaks, emergency water sources, power lines or other utilities. However, adherence to applicable laws and regulations would help to ensure that cumulative development would not result in permanent road closures, nor impede established emergency access routes or interfere with emergency response requirements. Accordingly, cumulative projects would not exacerbate wildfire risk.

The proposed project’s contribution would not be cumulatively considerable. Moreover, the project site is not in a high fire-prone area, is relatively flat and not prone to flooding, does not have a history of prior wildfires, and would be required to adhere to all applicable laws and regulations relating to emergency access, use of fire-resistant materials, availability of adequate fire hydrants and fire flow supply/pressure, and sediment and erosion control. The proposed project is therefore not expected to exacerbate wildfire hazards or substantially impair emergency/evacuation response.

No mitigation is required and cumulative impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Level of Cumulative Significance
Less than significant impact.
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CHAPTER 4: EFFECTS FOUND NOT TO BE SIGNIFICANT

4.1 - Introduction
This chapter is based, in part, on the Notice of Preparation (NOP) of an Environmental Impact Report (EIR), dated August 30, 2022, and contained in Appendix A of this Draft EIR. The NOP was prepared to identify the potentially significant effects of the proposed project and was circulated for public review between August 30, 2022, and September 28, 2022. During the NOP scoping period, certain impacts were anticipated to be less than significant given the nature of the various project components and the project site. In addition, in preparing this Draft EIR, certain other impacts have been determined to be less than significant in accordance with applicable provisions of the California Environmental Quality Act (CEQA) as detailed more fully herein and based on substantial evidence in the record.

This chapter provides a brief description of effects found not to be significant or less than significant, based on the NOP and NOP public comments received, as well as more detailed analysis conducted as part of the EIR preparation process. No NOP public comments were received during the NOP scoping period related to Mineral Resources, Population and Housing, and Parks and Recreation.

Further information and analysis is set forth below as to the basis for concluding that the foregoing environmental topic areas would not result in any significant impacts. In addition to these topic areas, there are certain impacts in other environmental topic areas that were found to be less than significant, which are addressed in the various EIR topical sections (Sections 3.1 through 3.16), providing further comprehensive discussion to support the conclusion of less than significant, in order to better inform decision-makers and the general public.

4.2 - Environmental Effects Found Not To Be Significant

4.2.1 - Mineral Resources
Loss of Mineral Resources of Statewide or Local Importance There are no mineral resource recovery sites on the project site or in the vicinity; in fact, there are none within the entire City of Visalia Planning Area.
1 Therefore, implementation of the proposed
project would not result in the loss of a locally important mineral resource recovery site delineated by an applicable land use plan. A Mineral Resource Zones (MRZ) and Resources Sectors map prepared by the California Geological Survey indicates that the project site is located outside of known mineral deposits of significance. Furthermore, given available information, the project site does not contain any known mineral resources. In addition, the project site is currently zoned for agricultural purposes, which does not include any mineral resource-related operations. As such, no known mineral resources would be impacted by the proposed project, and there would be no impact.
1 California Geological Survey. 2022. CGS Information Warehouse: Mineral Land Classification. Website:
https://maps.conservation.ca.gov/cgs/informationwarehouse/mlc/. Accessed August 19, 2022. 2935
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4.2.2 - Population and Housing
Growth Inducement
The proposed project’s potential growth-inducing impacts are discussed in Chapter 5, Other CEQA Considerations. As detailed more fully therein, growth-inducing impacts consider whether a project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. For example, direct population growth would result if the proposed project were to include residential units. Because the proposed project is industrial in nature and would not develop single-family or multi-family residential uses, no direct population growth would be expected to occur as a result of the proposed project. In terms of the removal of any direct barriers to growth, this would not occur due to the proposed project because it does not propose removing any existing obstacles that currently prevent growth within the City.

For example, the proposed project would not require expansion of existing water, wastewater, and/or other public facilities and services beyond what was already planned for in the General Plan.

Furthermore, the utility infrastructure installed as part of the proposed project would be sized and located expressly to serve the proposed project and would not, therefore, induce growth in the project vicinity.

Given the nature of the proposed project, it would likely be staffed primarily by local employees once operational. As of July 2022, the City had an unemployment rate of 4.2 percent, indicating a presence of approximately 6,005 unemployed workers.2 Approximately 22.5 percent of the City’s workforce works in industry sectors that the proposed project would occupy, including wholesale trade, manufacturing, retail trade, and transportation and warehousing. 3 Therefore, it is reasonable
to conclude there are at least 1,352 workers eligible to work in wholesale trade, manufacturing, retail trade, and transportation and warehousing sectors in the City.4 Thus, the proposed project would likely be able to hire from the City’s existing labor force. Furthermore, according to the U.S.

Census Bureau 2011–2015 5-Year American Community Survey (ACS) Commuting Flows, there are a total of 140,091 workers who both live in Tulare County and commute to work within the County. 5 It
is reasonable to assume that workers who currently reside in the Tulare County near the City of Visalia would continue to commute to work and thus also would be available to serve as employees for the proposed project. Nonetheless, a certain number of additional employees could potentially transfer into the area as a result of the proposed project, resulting in a certain amount of population growth. However, the General Plan projected that the population would grow from 125,000 people in 2014 to 210,000 people by 2030, which corresponds to an average annual growth rate of 2.6 percent. Employment in the City was projected to increase by 39 percent between 2010 and 2030, with a total of 25,520 new jobs projected during this time frame.6 The population growth caused by increased employment would be within the planned growth anticipated in the General Plan. 2 State of California.2022. Monthly Labor Force Data for Cities and Census Designated Placed (CDP) July 2022. August 19. 3 United States Census. “OnTheMap” Tool. Website: https://onthemap.ces.census.gov/. Accessed August 26,2022. 4 6005 * .225 = 1,352 5 United States Census. 2011–2015 5-Year ACS Commuting Flows. Website: https://www2.census.gov/programssurveys/demo/tables/metro-micro/2015/commuting-flows-2015/table1.xlsx. Accessed November 17, 2022. 6 City of Visalia. 2014. Visalia General Plan Chapter 2: Land Use. October. 2936
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Additionally, the industrial uses on the project site were anticipated by the City in the General Plan, and thus the City generally assumed this number of employees needed for such a project. It is reasonable to conclude that any increase in potential housing demand could be readily absorbed by the local housing inventory and/or the pending and approved residential projects in the City and the surrounding area. As of this writing, the current housing vacancy rate in the City is approximately 3.9 percent, and the County current vacancy rate is approximately 5.7 percent. 7 Thus, the proposed
project would not result in a significant, unplanned change to the population of the City or alter the location, distribution, density, intensity, or growth rate of the anticipated population planned for the City. Therefore, direct and indirect impacts would be less than significant.

Further, implementation of the proposed project would not make a cumulatively considerable contribution to this already less than significant cumulative impact because the City is not experiencing unplanned growth and the project site has already been planned for industrial development; thus, the proposed project would be consistent with the City’s long-range planning and land use vision for the project site and vicinity and would improve the overall jobs/housing projections by providing job opportunities within the City. Therefore, project implementation would not result in potentially significant cumulative impacts to population and housing.

Displacement of Persons or Housing
The project site does not currently have any residential structures on the premises and consists entirely of agricultural land used as an almond grove. Because there are no residential structures located on the project site, no people would be directly or indirectly displaced by the proposed project. Furthermore, because the proposed project would not result in the displacement of any persons or housing, it would not contribute to any potential cumulative impact in this regard. There would be no impact.

4.2.3 - Parks and Recreation
Physical Deterioration of Park and Recreational Facilities As of 2014, the City has maintained approximately 640 acres of park and recreational lands within its jurisdiction. The City would need to provide a minimum of 429 additional acres of park land to reach a total of 1,048 acres by 2030 to meet its park standard for neighborhood and community parks of

5.0 acres per 1,000 residents at General Plan buildout. 8 According to the City of Visalia General Plan,
as of October 2014, the City has provided parks at a rate of 5.1 acres for every 1,000 residents and continues to implement a successful strategy preserving and providing parks.9 The City currently has approximately 4.74 acres of park per 1,000 residents. The City recently approved the East Side Regional Park and Groundwater Recharge Project, which will provide approximately 139 acres of active recreational amenities and 130 acres of passive amenities in the eastern portion of the City.

That project would contribute to the City’s park ratio goal. The proposed project would pay into capital improvement program to fund the East Side Regional Park and Groundwater Recharge Project and other future parks projects to offset impacts to park and recreation facilities. 7 California Department of Finance. 2022. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022. 8 City of Visalia. 2014. General Plan–Parks, Schools, Community Facilities, and Utilities. October 14. 9 Ibid. 2937
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Furthermore, the nearest public park to the project site is Lion’s Park, located approximately 0.38 miles southeast of the project site. As discussed above, the proposed project is anticipated to generate a total of approximately 4,100 new employees at full buildout, and it is thus reasonable to assume that some of these employees would utilize, at least to some degree, the City’s available park and recreational facilities during the workday. However, given the nonresidential, industrial nature and location of the proposed project, it is likely that any such use would be limited and thus would not result in substantial physical deterioration of park and recreational facilities occurring or being accelerated. Moreover, as discussed in detail above, because the proposed project would not be expected to result in a significant increase to the population of the City (given the primarily local nature of the anticipated workforce), the quantity of existing visitors and total facility usage would not likely increase significantly as a result of the proposed project. As such, the proposed project would not result in substantial physical deterioration of existing park and recreational facilities, and therefore impacts in this regard would be less than significant.

New or Expanded Recreational Facilities
Because the proposed project is not located within or adjacent to any designated natural or open space areas and would not likely significantly increase the City’s residential population (given the primarily local nature of the anticipated workforce), coupled with the limited likely employee usage of such facilities, the proposed project would not trigger the need to construct new or expanded park and recreational facilities to ensure that the applicable ratio of parks to residents would be maintained. Accordingly, there would be less than significant impact in this regard. 2938
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CHAPTER 5: OTHER CEQA CONSIDERATIONS
California Environmental Quality Act (CEQA) Guidelines Section 15126 requires that all aspects of a project be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. As part of this analysis, the Draft Environmental Impact Report (Draft EIR) must identify (1) significant environmental effects of the proposed project; (2) significant environmental effects which could not be avoided if the proposed project were implemented; (3) significant irreversible environmental changes which would be involved in the proposed project should it be implemented; (4) growth-inducing impact of the proposed project; (5) mitigation measures proposed to minimize the significant effects; and (6) alternatives to the proposed project.

This chapter provides a discussion of other CEQA-mandated topics, including significant unavoidable impacts, growth inducement, and significant irreversible environmental changes, if any, which would be involved in the proposed project should it be implemented. Chapter 3, Environmental Impact Analysis, describes the significant environmental effects of the proposed project and provides mitigation measures proposed to minimize significant effects to the extent feasible. Chapter 6, Alternatives to the Proposed Project discusses a reasonable range of potential alternatives to the proposed project.

5.1 - Significant Unavoidable Impacts
CEQA Guidelines Section 15126.2(a)(c) requires an EIR to identify and focus on the significant environmental effects of the proposed project, including effects that could not be avoided if the proposed project were implemented. This includes those significant impacts that can be mitigated but not reduced to a level of insignificance.

As required under CEQA, the proposed project was analyzed for potentially significant impacts related to each of the environmental topic areas discussed in Sections 3.1 through 3.16. The results of the analysis indicate that the proposed project would result in the following significant and unavoidable impacts:
• Project-Level Conversion of Prime Farmland: Although the proposed project is consistent with the project site’s General Plan designation and conversion of the project site to industrial use has long been envisioned as part of buildout under the General Plan, the proposed project would result in the loss of agricultural land and conversion of Prime Farmland to urban uses.

There are no feasible mitigation measures available to reduce this impact. Accordingly, despite the fact that this conversion was previously evaluated and disclosed as part of the General Plan EIR, this Draft EIR has evaluated and hereby discloses that the proposed project would result in significant and unavoidable impacts related to the conversion of Important Farmland identified by Farmland Mapping and Monitoring Program (FMMP) mapping to nonagricultural use.
• Cumulative Conversion of Prime Farmland: Much of the City’s Urban Development Boundary (UDB) consists of Important Farmland that would be converted to nonagricultural uses with 2939
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implementation of future development already envisioned by the General Plan Land Use Element. Development within Tier II and III of the UDB that would convert Prime Farmland is subject to the 1:1 ratio of agricultural land preservation elsewhere outside of the City’s UDB.

Although cumulative projects occurring in Tier II and III of the UDB would be required to preserve agricultural land elsewhere, loss of Prime Farmland would still occur and the cumulative impact remains significant. The development of the proposed project would further contribute to this already significant cumulative impact, due to the loss of approximately 284 acres of Prime Farmland, which has been identified as an individual significant and unavoidable impact due to lack of feasible mitigation. Moreover, the proposed project’s contribution to this significant cumulative effect to agricultural resources would be considered cumulatively considerable.
• Project-Level Impact Related to Implementation of the Applicable Air Quality Plan: The proposed project is consistent with the project site’s General Plan designation which means the proposed industrial use was accounted for in the Air Quality Plan (AQP) land use projections. However, the proposed project could create a localized violation of State or federal air quality standards, significantly contribute to cumulative nonattainment pollutant violations, and could expose sensitive receptors to substantial pollutant concentrations. The proposed project would be required to implement Mitigation Measure (MM) AIR-2a through MM AIR-2g. However, because MM AIR-2a through MM AIR-2f would not reduce construction or operational impacts below the applicable thresholds and full implementation of MM AIR-2g cannot be guaranteed due to potential technical and/or financial feasibility, the proposed project’s potentially significant impact is conservatively identified as significant and unavoidable. Therefore, the proposed project is inconsistent with Criterion 1 of the AQP even after the incorporation of feasible mitigation. The impact would be significant and unavoidable.
• Project-Level Impact Related to Cumulatively Considerable Net Increase of Nitrogen Oxide (NOX) During Construction, and ROG, NOX, and PM10 During Operation: For purposes of a conservative analysis, this Draft EIR evaluated the potential impacts assuming that none of the three anticipated project phases overlapped (sequential), and also considered the potential impacts if the project phases did, in fact, overlap (concurrent). In the sequential phasing scenario, after the incorporation of MM AIR-2a and MM AIR-2b, construction of the proposed project would not exceed the applicable San Joaquin Valley Air Pollution Control District (Valley Air District) daily emission screening levels for an Ambient Air Quality Analysis (AAQA), pursuant to District Rule 2201. However, if the three phases of construction occur concurrently, emissions of CO and NOX would exceed the applicable Valley Air District’s significance thresholds even after implementation of feasible mitigation. As such, this impact would remain significant and unavoidable after implementation of identified mitigation.

During operation, unmitigated emissions would exceed applicable Valley Air District thresholds of significance for CO, ROG, and NOX. Therefore, MMs AIR-2c through MM AIR-2g would be required to mitigate operational emissions to below Valley Air District thresholds.

However, the full implementation of MMs AIR-2c through MM AIR-2f would not reduce emissions below the applicable thresholds and MM AIR-2g cannot be guaranteed during project operation; therefore, the reasonable worst-case operational emissions would exceed 2940
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the applicable Valley Air District significance thresholds for CO, ROG, NOX, and PM10 and this impact would remain significant and unavoidable.
• Cumulative Significant Air Quality Impact: Because the proposed project would exceed certain identified construction and operational significance thresholds, its emissions would also be cumulatively considerable.
• Project-Level Impact Related to Mobile Source Operational Noise: Without development of the proposed project, nearly every roadway segment is estimated to experience noise increases from a minimum 0.9 dBA Leq to a maximum 8.6 dBA Leq by 2028, compared to existing traffic noise levels. The addition of the proposed project’s traffic would increase noise levels up to an additional 3.7 dBA Leq upon full buildout. The proposed project would contribute to increasing traffic volumes–and therefore traffic-related noise levels–in its primary trip distribution area, which is generally bounded by the project site/Riggin Avenue to the north, State Route (SR) 99 to the west, Akers Street to the east, and SR-198 to the south.

There are no feasible mitigation measures available to reduce this impact to less than significant. The proposed project’s off-site mobile source operational noise impact from traffic generation would be considered significant and unavoidable. • Cumulative Noise Impact: The proposed project would exceed the identified operational significance threshold, its impact would also be cumulatively considerable.

5.2 - Growth-inducing Impacts
CEQA requires a discussion of the ways in which a project could foster economic or population growth, or the construction of additional housing, in the surrounding environment or may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Therefore, to assess the potential for growth-inducing impacts, a project’s characteristics that may encourage and facilitate activities that individually or cumulatively could affect the environment must be evaluated (CEQA Guidelines § 15126(d) and 15126.2(e)).

Pursuant to the CEQA Guidelines, there would be a significant growth-inducing impact if the proposed project would:
• Induce substantial population growth in an area (for example, by proposing new homes or commercial or industrial businesses beyond the land use density/intensity envisioned in the general plan);
• Substantially alter the planned location, distribution, density, or growth rate of the population of an area; or
• Remove obstacles to population growth such as, for example, extensions of roads or expansions of other infrastructure not assumed in the general plan or adopted capital improvements project list, or otherwise upsize infrastructure (i.e., exceeds the needs of the project and could accommodate future developments) to serve unplanned growth.

The City recognizes that certain forms of growth are beneficial, both economically and socially. The proposed project would include the construction of flex industrial and light industrial uses and 2941
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related improvements as well as other compatible non-industrial uses, such as self storage and RV parking, a gas station, convenience store, a car wash, and two drive-through restaurants. The proposed project would be expected to employ a total of approximately 4,100 employees at full buildout. As described in Chapter 4, Effects Found not to be Significant, direct population growth would result if the proposed project were to include residential units. Because the proposed project is industrial in nature and would not develop single-family or multi-family residential uses, no direct population growth would be expected to occur.

In terms of the removal of any direct barriers to growth, this would not occur as a result of the proposed project because it would not remove any existing obstacles that currently prevent growth within the City. For example, the proposed project would not require expansion of existing water, wastewater and public facilities and services beyond what was already planned for in the City General Plan. Instead, the proposed project only involves the connection to various City-operated existing utility and infrastructure systems for water, wastewater, and stormwater facilities, as well as connection to existing non-City provided infrastructure such as natural gas (to be provided by Southern California Gas Company [SoCalGas]) and electrical services (to be provided by Southern California Edison [SCE]). The utility infrastructure installed as part of the proposed project would be sized and located expressly to serve only the proposed project and would not, therefore, induce growth in the project vicinity. The proposed project does not involve any extensions of roads or other infrastructure not assumed in the General Plan or adopted capital improvements project list, which would exceed the needs of the proposed project and thus accommodate future developments.

Therefore, because the proposed project does not involve housing, nor would it remove any direct barriers to growth, the proposed project would not directly increase population.

Indirect population growth occurs when a project creates substantial employment opportunities or provides new, upsized infrastructure that could lead to additional unplanned growth. As noted, the proposed project is anticipated to create approximately 4,100 new employees at full buildout. Given the nature of the proposed project, it would likely be staffed primarily by local employees. In 2022, the City had an unemployment of 4.2 percent, indicating a presence of approximately 6,005 unemployed workers.1 Approximately 22.5 percent of the City’s workforce works in industry sectors that the proposed project would occupy, including employment opportunities with potential tenants/operators involving wholesale trade, manufacturing, retail trade, and transportation and warehousing consistent with the proposed flex industrial, light industrial and other commercial uses.
2 Therefore, it is reasonable to conclude there are at least 1,352 workers eligible to in the City who could fill a portion of the jobs that are expected to result from the proposed project. 3 Furthermore, Tulare County currently has an unemployment rate of 9.7 percent, or 20,800 people of the working population.4 There are a total of 140,091 workers who both live in Tulare County and 1 State of California. 2022. Monthly Labor Force Data for Cities and Census Designated Places (CDP) July 2022. August 19. 2 United States Census. “OnTheMap” Tool. Website: https://onthemap.ces.census.gov/. Accessed August 26, 2022. 3 6005 * .225 = 1,352 4 Employment Development Department – Labor Market Information Division. 2023. Visalia Porterville MSA (Tulare County). May 19.

Website: https://labormarketinfo.edd.ca.gov/file/lfmonth/visa$pds.pdf. Accessed May 25, 2023. 2942
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commute to work within the County.5 It is reasonable to assume that a number of unemployed county residents living near the City of Visalia could accept a job working at one of the proposed project businesses, and would commute to the City to work.

Nonetheless, additional employees could potentially transfer into the area as a result of the proposed project, resulting in population growth. However, the General Plan contemplated a certain amount of population growth, projecting that its population would grow from 125,000 people in 2014 to 210,000 people by 2030, which corresponds to an average annual growth rate of 2.6 percent. Employment in the City was projected to increase by 39 percent between 2010 and 2030, with a total of 25,520 new jobs projected during this time frame.6 Therefore, any population growth caused by increased employment opportunities provided by the proposed project would be within the planned growth anticipated in the General Plan. To the extent people transfer into the City and vicinity to fill the positions provided by the proposed project, it is reasonable to conclude that any such increase in potential housing demand could be readily absorbed by the local housing inventory and/or the pending and approved residential projects in the City and the surrounding area. As of this writing, the current housing vacancy rate in the City is 3.9 percent, and the County vacancy rate is

5.7 percent.7 Thus, the proposed project would not result in a significant, unplanned change to the population of the City or alter the location, distribution, density, or growth rate of the anticipated population planned for the City.

As noted above, existing infrastructure and services would be extended to make the necessary connections to serve the proposed project, but would not involve any upsizing of infrastructure that was not already planned for in the General Plan and relevant City master infrastructure plans and thus would not encourage additional unplanned growth. For these reasons, implementation of the proposed project would not induce substantial indirect population growth within the City.

Based on the foregoing reasons, the proposed project would not result in direct or indirect growth. It would not negatively alter the existing jobs/housing balance, be inconsistent with the General Plan or relevant City master infrastructure plans, or remove a barrier to growth through the extension of infrastructure or utilities to an unserved area or upsize infrastructure to serve unplanned growth.

Therefore, growth-inducing impacts would be less than significant.

5.3 - Significant Irreversible Environmental Changes
The environmental effects of the proposed project are summarized in the Executive Summary and are analyzed in detail in Section 3, Environmental Impact Analysis, of this Draft EIR.

As mandated by CEQA Guidelines Section 15126.2(c), the Draft EIR must address significant irreversible environmental changes (if any) that would result from implementation of the proposed project. Primary impacts and, particularly, secondary impacts (such as a highway improvement that 5 United States Census. 2011–2015 5-Year ACS Commuting Flows. Website: https://www2.census.gov/programssurveys/demo/tables/metro-micro/2015/commuting-flows-2015/table1.xlsx. Accessed November 17, 2022. 6 City of Visalia. 2014. Visalia General Plan Chapter 2: Land Use. October. 7 California Department of Finance. 2022. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022. 2943
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provides access to a previously inaccessible area) generally commit future generations to similar uses. Specifically, such an irreversible environmental change would occur if:
• The proposed project would involve a large commitment of nonrenewable resources, which makes removal or nonuse thereafter unlikely.
• Irreversible damage could result from environmental accidents associated with the proposed project.
• Any irretrievable commitments of resources are not justified (e.g., the proposed project results in the wasteful use of energy). (Refer to Section 3.6, Energy, which addresses this topic in accordance with CEQA Guidelines Appendix F.)
The proposed project involves construction and operation of light industrial, flex industrial, as well as compatible commercial uses, consisting of self storage/RV parking, a gas station, convenience store, a car wash, and two drive-through restaurants, which, at buildout, would total approximately 3.7 million square feet.

Stringent construction and demolition debris recycling practices consistent with applicable laws and regulations, which would be imposed on the proposed project, would be expected to facilitate the recovery and reuse of building materials such as concrete, lumber, and steel and would limit disposal of these materials, some of which are nonrenewable.

Construction of the proposed project would include the consumption of resources that are not replenishable, or that may renew so slowly to be considered nonrenewable. These resources would include the following: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt, such as sand, gravel, and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics; and water. Fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment. However, anticipated consumption of these common building materials and energy would be typical and consistent with other similar developments in the region and commitments of resources would not be unique or unusual to the proposed project. Given its nature and scope, development of the proposed project would not be expected to involve an unusual commitment of nonrenewable resources, nor would it be expected to consume resources in a wasteful manner.

At operation, day-to-day activities would involve the typical use of nonrenewable resources such as petroleum and natural gas during operations. However, the new buildings and related infrastructure would be required to adhere to the latest adopted edition of the California Building Standards Code (CBC), which are viewed as some of the most stringent in the nation; this would include a number of standards that would reduce energy demand, water consumption, wastewater generation, and solid waste generation that would collectively reduce the demand for resources. This would result in the emission and generation of less pollution and effluent and would lessen the severity of corresponding environmental effects. Although the proposed project would result in an irretrievable commitment of nonrenewable resources, the commitment of these resources would not be significantly inefficient, unnecessary, or wasteful.
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Furthermore, given its nature and scope, the proposed project does not have the potential to cause significant environmental accidents through releases into the environment, as it would not involve large quantities of hazardous materials, as discussed in Section 3.9, Hazards and Hazardous Materials. The project site is designated as Local Responsibility Area (LRA) Un-zoned, which identifies areas with low fire frequency. The potential for wildfire on the project site is not considered high. In addition, the project site has not previously experienced wildfire and is not located in or near an area of steep terrain or historical wildfire burn, nor does it experience consistent high winds; therefore, the project site would not be prone to wildfire risk (see Section

3.17, Wildfire). During operation, the proposed project would be readily and adequately served by police and fire protection services. The proposed project does not contain any uses or features that would exacerbate wildfire risks or place occupants at a greater risk to wildfire pollutants or uncontrolled wildfire. The proposed project would also be required to comply with applicable provisions of the California Fire Code with regard to access and building materials. Public Resources Code 4291 further requires the proposed project to maintain, at all times, a minimum of 30 feet of defensible space in every direction from structures adjacent to forest, brush, grass, or lands covered with flammable material. In addition, new construction would be required to comply with applicable requirements as set forth in Chapter 7A of the most current adopted CBC, which would further reduce risk due to wildland fire. As such, the design of the proposed project would be required to incorporate fire safety features and comply with the applicable fire safety provisions of the CBC, thereby further reducing the risk of loss, injury, or death involving wildland fires.

Thus, implementation of the proposed project’s light industrial, flex industrial and other compatible commercial uses would not have the potential to result in significant environmental accidents and would not result in significant irreversible environmental changes. 2945

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CHAPTER 6: ALTERNATIVES TO THE PROPOSED PROJECT

6.1 - Introduction
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this Draft Environmental Impact Report (Draft EIR) contains a comparative impact assessment of alternatives to the proposed project. The purpose of this section is to provide decision-makers, other interested organizations, and the public with a reasonable number of potentially feasible project alternatives that could attain most of the basic project objectives, while avoiding or reducing any of the project’s significant adverse environmental effects. Important considerations for this alternatives analysis are noted below pursuant to CEQA Guidelines Section 15126.6. • An EIR need not consider every conceivable alternative to a project; • An EIR should identify alternatives that were considered by the lead agency, but rejected as infeasible during the scoping process;
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives; - Infeasibility; or
- Inability to avoid significant environmental effects.

6.1.1 - Significant Unavoidable Impacts
The proposed project would result in the following significant unavoidable impacts:
• Project-level conversion of Prime Farmland: Although the proposed project is consistent with the project site’s General Plan designation and conversion of the project site to industrial use has long been envisioned as part of buildout under the General Plan, the proposed project would result in the loss of agricultural land and conversion of Prime Farmland to urban uses.

There are no feasible mitigation measures available to reduce this impact. Accordingly, despite the fact that this conversion was previously evaluated and disclosed as part of the General Plan EIR, this Draft EIR has evaluated and hereby discloses that the proposed project would result in significant and unavoidable impacts related to the conversion of Important Farmland identified by Farmland Mapping and Monitoring Program (FMMP) mapping to nonagricultural use.
• Cumulative conversion of Prime Farmland: Much of the City’s Urban Development Boundary (UDB) consists of Important Farmland that would be converted to nonagricultural uses with implementation of future development already envisioned by the General Plan Land Use Element. Development within Tier II and III of the UDB that would convert Prime Farmland is subject to the 1:1 ratio of agricultural land preservation elsewhere outside of the City’s UDB.

Although cumulative projects occurring in Tier II and III of the UDB would be required to preserve agricultural land elsewhere, loss of Prime Farmland would still occur and the cumulative impact remains significant. The development of the proposed project would further contribute to this already significant cumulative impact, due to the loss of 2947
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approximately 284 acres of Prime Farmland, which has been identified as an individual significant and unavoidable impact due to lack of feasible mitigation. Moreover, the proposed project’s contribution to this significant cumulative effect to agricultural resources would be considered cumulatively considerable.
• Project-level impact related to implementation of the applicable Air Quality Plan: The proposed project is consistent with the project site’s General Plan designation which means the proposed industrial use was accounted for in the Air Quality Plan (AQP) land use projections. However, the proposed project could create a localized violation of State or federal air quality standards, significantly contribute to cumulative nonattainment pollutant violations, and could expose sensitive receptors to substantial pollutant concentrations. The proposed project would be required to implement Mitigation Measure (MM) AIR-2a through MM AIR-2g. However, because MM AIR-2a through MM AIR-2f would not reduce construction or operational impacts below the applicable thresholds and full implementation of MM AIR-2g cannot be guaranteed due to potential technical and/or financial feasibility, the proposed project’s potentially significant impact is conservatively identified as significant and unavoidable. Therefore, the proposed project is inconsistent with Criterion 1 of the AQP even after the incorporation of feasible mitigation. The impact would be significant and unavoidable.
• Project-level impact related to cumulatively considerable net increase of nitrogen oxide (NOX) during construction, and reactive organic gas (ROG), NOX, and particulate matter 10 micrometers or less in diameter (PM10) during operation: For purposes of a conservative analysis, this Draft EIR evaluated the potential impacts assuming that none of the three anticipated project phases overlapped (sequential), and also considered the potential impacts if the project phases did, in fact, overlap (concurrent). In the sequential phasing scenario, after the incorporation of MM AIR-2a and MM AIR-2b, construction of the proposed project would not exceed the applicable San Joaquin Valley Air Pollution Control District (Valley Air District) daily emission screening levels for an Ambient Air Quality Analysis (AAQA), pursuant to District Rule 2201. However, if the three phases of construction occur concurrently, emissions of carbon monoxide (CO) and NOX would exceed the applicable Valley Air District’s significance thresholds even after implementation of feasible mitigation. As such, this impact would remain significant and unavoidable after implementation of identified mitigation.

During operation, unmitigated emissions would exceed applicable Valley Air District thresholds of significance for CO, ROG, and NOX. Therefore, MM AIR-2c through MM AIR-2g would be required to mitigate operational emissions to below Valley Air District thresholds.

However, the full implementation of MM AIR-2c through MM AIR-2f would not reduce emissions below the applicable thresholds and MM AIR-2g cannot be guaranteed during project operation; therefore, the reasonable worst-case operational emissions would exceed the applicable Valley Air District’s significance thresholds for CO, ROG, NOX, and PM10 and this impact would remain significant and unavoidable.
• Cumulative significant air quality impact: Because the proposed project would exceed certain identified construction and operational significance thresholds, its emissions would also be cumulatively considerable.
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• Project-level impact related to mobile source operational noise: Without development of the proposed project, nearly every roadway segment is estimated to experience noise increases from a minimum 0.9 A-weighted decibel (dBA) equivalent sound level (Leq) to a maximum 8.6 dBA Leq by 2028, compared to existing traffic noise levels. The addition of the proposed project’s traffic would increase noise levels up to an additional 3.7 dBA Leq upon full buildout.

The proposed project would contribute to increasing traffic volumes—and therefore trafficrelated noise levels—in its primary trip distribution area, which is generally bounded by the project site/Riggin Avenue to the north, State Route (SR) 99 to the west, Akers Street to the east, and SR-198 to the south. There are no feasible mitigation measures available to reduce this impact to less than significant. The proposed project’s off-site mobile source operational noise impact from traffic generation would be considered significant and unavoidable. • Cumulative noise impact: The proposed project would exceed the identified operational significance threshold, its impact would also be cumulatively considerable.

Potential significant impacts were identified with respect to biological resources, cultural resources, geology and soils, noise, and transportation; however, mitigation measures were identified that would reduce the impacts to less than significant.

6.1.2 - Alternatives to the Proposed Project
Following is an analysis of a reasonable range of potentially feasible alternatives to the proposed project for evaluation of their comparative merits, pursuant to CEQA Guidelines Section 15126.6.

The three alternatives to the proposed project analyzed in this section are as follows:
• No Project Alternative: Under this alternative, development of the project site would not occur, and the project site would remain in its current existing condition. • Reduced Footprint Alternative: Under this alternative, the proposed project would be developed in such a way as to reduce some construction and operational air quality impacts, operational noise impacts, and protect some of the on-site Prime Farmland by reducing the overall footprint of the developed areas. The eastern half of the project site, approximately 142 acres, would be preserved and would remain in agricultural production, and half of the total warehouse and industrial park land uses would be developed. The proposed associated commercial uses would be relocated to the western half of the site. The stormwater basins would be sized accordingly. It is assumed that culvert crossings over Modoc Ditch would be required, similar to the proposed project.
• Alternative Location: Under this alternative, the proposed project would be constructed in the approximately 284-acre parcels west of Plaza Drive and Riggin Avenue (APNs 077-840-001, 077-840-002, and 077-840-003). These parcels are selected as they are few of the remaining parcels within Tier I of the UDB that is designated as Industrial therefore generally suitable for the proposed development. The proposed project would require a General Plan Amendment to re-designate a portion of the site as Light Industrial for the proposed associated flex industrial/commercial uses conditionally allowed under Light Industrial. This site would be approximately 650 feet from the nearest sensitive receptors located to the southwest. 2949
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The boundaries of Alternative 2 and Alternative 3 are shown in Exhibit 6-1. The three alternatives to the proposed project are analyzed below. These analyses compare the proposed project and each individual project alternative. In several cases, the description of the impact may be the same under each alternative when compared with the CEQA Thresholds of Significance (i.e., both the project and the alternative would result in a less than significant impact). The actual degree of impact may be slightly different between the proposed project and each alternative, and this relative difference will factor into this analysis in terms of a conclusion of greater or lesser impacts.

CEQA Guidelines Section 15126.6(f)(2) sets forth considerations to be used in evaluating an alternative location. The section states that the “key question” is whether any of the significant effects of the project would be avoided or substantially lessened by relocating the project.

The CEQA Guidelines identify the following factors that may be taken into account when addressing the feasibility of an alternative location:
1) Site suitability
2) Economic viability
3) Availability of infrastructure
4) General Plan consistency
5) Other plans or regulatory limitations
6) Jurisdictional boundaries
7) Whether the project applicant can reasonably acquire, control, or otherwise have access to the alternative site.

6.2 - Alternative Eliminated from Further Consideration An EIR must describe a reasonable range of alternatives to the proposed project, or to its location, which would feasibly attain most of the project's basic objectives while reducing or avoiding any of its significant effects. An EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are potentially feasible and, therefore, merit in-depth consideration, and which are clearly infeasible. “The discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly” (CEQA Guidelines § 15126.6(b)). Alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered (CEQA Guidelines § 15126.6(f)(3)). CEQA Guidelines Section 15126.6(a) states that an EIR need not evaluate every conceivable alternative to a project. The discussion of alternatives is subject to a rule of reason and the scope of alternatives to be analyzed must be evaluated on the facts of each case.

Following is the identification of one alternative initially considered by the lead agency, but rejected as infeasible, along with a brief explanation of the reasons for its exclusion. As noted below, this 2950
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alternative was eliminated from detailed consideration in the Draft EIR since it fails to meet most of the project objectives and is infeasible.

Self Storage/Lighter Use Alternative: Under this alternative, the proposed project would be developed as self storage or other uses allowed or allowed with a conditional use permit under the land use designations that would involve fewer use of heavy heavy-duty trucks that use diesel as the fuel source, such as office, selected types of eateries, and gas station. Operation may increase passenger trips but decrease heavy heavy-duty truck trips. However, due to the sheer size of the project site, it would not be economically viable to have these types of uses to fill the entire site. It would not be consistent with applicable goals and policies as set forth in the General Plan, including the land use vision set forth therein that contemplates light industrial and industrial uses. It also would not maximize development of the currently underutilized site and would not create as many employment opportunities for the region. For these reasons, this alternative to develop the site as other uses is considered but rejected.

6.3 - Project Objectives
The fundamental purpose and goal of the proposed project is to accomplish the orderly development of the project site as proposed, consistent with the General Plan’s industrial land use designation, which would provide economic benefits to the City, among others. As stated in Chapter 2, Project Description, the objectives of the proposed project are to:

1. Ensure that development of the project site is accomplished in an economically viable manner consistent with applicable goals and policies as set forth in the City’s General Plan, including the land use vision set forth therein that contemplates light industrial and industrial uses, taking into account necessary site plan considerations including efficient access and loading.

2. Maximize development of the existing underutilized project site and generate increased revenue and economic development for the City in order to support the City’s ongoing City operations.

3. Develop of a mixed-use industrial park, with light manufacturing, warehouse, distribution, and/or flex industrial uses, in the City that is designed to meet market demand and contemporary industry standards including building size and clear height requirements, modern façades, articulated concrete panels, a natural color palette, and expansive glass entry features.

4. Create employment-generating businesses in the City to reduce the need for members of the local workforce to commute outside the area for employment and to improve the jobs-tohousing balance.

5. Maximize placement of industrial uses in close proximity to the State Highway system (SR-99) and other major transportation corridors to avoid or shorten truck-trip lengths, as feasible, on other roadways and to avoid locating industrial buildings in close proximity to residential uses or other sensitive receptors.
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6. Develop innovative industrial uses providing a range of building sizes with cross dock and rear load capability that have ready access to available infrastructure, including major transportation corridors and utilities to be used as part of the Central Valley supply chain and goods movement network.

6.4 - Alternative 1—No Project Alternative
CEQA Guidelines Section 15126.6(e) requires EIRs to evaluate a “No Project Alternative,” which is defined as the “circumstance under which the project does not proceed.” Under the No Project Alternative, the 3,720,149 square feet of light industrial and flex industrial development, infrastructure improvements, roadway frontage improvements would not be constructed on the project site and in its vicinity. In this scenario, the project site’s existing agricultural uses would remain; road improvements would not occur; trees and crops would not be removed or impacted; and grading would not take place. This alternative would not require annexation or conditional use permit.

6.4.1 - Impact Analysis
Aesthetics, Light, and Glare
The proposed project’s impacts related to aesthetics would be less than significant (See Section 3.1, Aesthetics, Light, and Glare). Under the No Project Alternative, the existing orchards, tree cover, retention basin, and pump station would not be converted and could remain on-site. The infrastructure improvements to utilities and roadway frontage improvements would not occur. There would be no change in visual character, views, nighttime lighting, daytime glare, or shadow, as there would be no change to the existing on-site buildings, parking area, streets, utility lines, topography, or vegetation/landscaping, or conflict with zoning. Thus, there would be no aesthetics impacts under this alternative.

Because there would be no impacts under the No Project Alternative, this alternative would have a lesser impact as compared to the proposed project.

Agriculture and Forest Resources
The proposed project’s impacts related to agriculture would be significant and unavoidable, and there would be no impact related to forestry resources (See Section 3.2, Agricultural Resources and Forestry Resources). The No Project Alternative would not convert any Prime Farmland as identified by the FMMP to nonagricultural use, nor would it conflict with zoning or a Williamson Act Contract.

This alternative would have no impacts to existing conditions with respect to agriculture or forestry resources.

The No Project Alternative would avoid the significant and unavoidable impact on agricultural resources that would result from the proposed project and would therefore have reduced impacts as compared to the proposed project. However, this alternative would not meet any of the proposed project’s objectives, fulfill the underlying purpose of the proposed project, or meet the General Plan’s development vision.
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Air Quality
Under the proposed project, air quality impacts would be significant and unavoidable because construction and operational emissions would exceed applicable thresholds even after compliance with all applicable rules, regulations, and implementation of feasible mitigation.

Under the No Project Alternative, the project site would not be developed with 3,720,149 square feet of light industrial and flex industrial uses, and existing site conditions would remain the same.

There would be no ground disturbance within the project site and within the areas proposed for the off-site improvements, and no construction or operation of the facilities would occur. Therefore, no impacts to air quality would occur under this alternative during construction, and the significant and unavoidable impacts in this regard would be avoided. Similarly, the significant and unavoidable air quality impacts related to operations would not occur. Therefore, this alternative would result in reduced impacts as compared to the proposed project.

However, this alternative would not meet any of the project objectives related to air quality because it would not reduce commutes for regional residents by proving local employment opportunities or maximize the placement of industrial sites in proximity to major transportation corridors to avoid or shorten truck-trip lengths.

Biological Resources
The proposed project’s impacts related to biological resources would be less than significant with mitigation incorporated (see Section 3.4, Biological Resources). Under the No Project Alternative, there would be no change related to wildlife or habitat on-site, and the No Project Alternative would not have any potential impacts to special-status wildlife species or jurisdictional wetlands. Thus, there would be no biological resources impacted under this alternative. Therefore, this alternative would result in reduced impacts as compared to the proposed project.

Cultural Resources and Tribal Cultural Resources
The proposed project’s impacts related to cultural resources would be less than significant with mitigation incorporated (see Section 3.5, Cultural Resources and Tribal Cultural Resources). Under the No Project Alternative, there would be no change in historic, archaeological, or tribal resources, as there would be no change to the existing on-site structures and no ground disturbance. Thus, there would be no cultural or tribal resources impacts under this alternative, and there would be reduced impacts as compared to the proposed project.

This alternative would not meet the project objectives in terms of employment opportunities and infrastructure and services.

Energy
The proposed project’s impacts related to energy use and conservation would be less than significant (see Section 3.6, Energy). Under the No Project Alternative, there would be no change related to energy consumption, as there would be no change to the existing land uses or daily vehicle trips. Thus, there would be no impact related to energy use under this alternative, and the level of impacts would be reduced as compared to the proposed project. 2953
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The No Project Alternative would not result in the construction of industrial and flex industrial buildings or infrastructure improvements, and would therefore have no impact related to energy consumption. However, this alternative would not meet the project objectives related to energy because it would not provide local jobs to reduce the commute for regional residents, which would reduce energy impacts resulting from the use of car fuels, nor would it maximize the placement of industrial sites in proximity to major transportation corridors to reduce truck fuel usage.

Geology and Soils
The proposed project’s impacts related to geology and soils would be less than significant with mitigation incorporated (see Section 3.7, Geology and Soils). Under the No Project Alternative, there would be no impact related to potential exposure of persons and property to seismic- and soilrelated hazards, nor would there be any potential paleontological impacts. The No Project Alternative would not construct warehouses in a seismically active area and on soil that is expansive, unstable, and susceptible to liquefaction and other seismic-related ground failure. Therefore, there would be no impact with regard to geology and soils and paleontological resources under the No Project Alternative.

Therefore this alternative would have reduced impacts compared to the proposed project.

Greenhouse Gas Emissions
The proposed project’s impacts related to greenhouse gas (GHG) emissions would be less than significant with mitigation incorporated (see Section 3.8, Greenhouse Gas Emissions). Under the No Project Alternative, there would be no change related to GHG emission generation, as there would be no change to the existing land uses or daily vehicle trips. Thus, there would be no impact related to GHG emissions under this alternative. The No Project Alternative would have no impact related to GHG emissions, as it would not create emissions from construction or operation of the warehouses.

Therefore, it would have reduced impacts compared to the proposed project. However, it would not meet any of the project objectives related to GHG emissions, because this alternative would not reduce commutes for regional residents by proving local employment opportunities or place industrial sites in proximity to major transportation corridors to avoid or shorten truck-trip lengths.

Hazards and Hazardous Material
The proposed project’s impacts related to hazards and hazardous materials would be less than significant with mitigation incorporated (see Section 3.9, Hazards and Hazardous Materials). Under the No Project Alternative, there would be no demolition of the existing on-site buildings, and no potential exposure to lead-based paint or asbestos-containing materials (ACM) would occur from demolition activities.

The No Project Alternative would have no impact related to hazards and hazardous materials.

Therefore, it would have a lesser level of hazards and hazardous materials impact compared to the proposed project.
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Hydrology and Water Quality
The proposed project’s impacts related to hydrology and water quality would be less than significant (see Section 3.10, Hydrology and Water Quality). Under the No Project Alternative, there would be no change related to hydrology, stormwater runoff and drainage, water quality, groundwater recharge and depletion, or flooding, as there would be no change to the existing on-site buildings, hardscape, or landscaping resulting in changes in impervious vs. pervious surfaces on-site. The stormwater detention basin would eventually be constructed by the City as part of their Stormwater Master Plan. Thus, there would be no hydrology and water quality impacts or improvements under this alternative.

The No Project Alternative would have no impacts related to hydrology and water quality; thus, the impacts would be reduced as compared to the proposed project. However, the No Project Alternative would not meet the project objectives in terms of infrastructure improvements.

Land Use and Planning
The proposed project’s impacts related to land use and planning would be less than significant, and the proposed project would meet many of the project objectives, including applying the goals and policies of the General Plan (see Section 3.11, Land Use and Planning). Under the No Project Alternative, the project site would not be developed with 3,720,149 square feet of warehouse development, and the improvements to utilities, roadway frontage, and infrastructure would not occur.

This alternative would not be consistent with the project objective to apply the goals and policies of the General Plan, which focuses on developing employment opportunities and expanding the City’s industrial base. The No Project Alternative would not be consistent with the General Plan’s land use vision or with the goals and policies outlined in the General Plan. Therefore, impacts under this alternative would be less than significant, which is similar to the proposed project. This alternative would not reduce impacts as compared to the proposed project and may result in somewhat increased impacts due to the land use inconsistency, although the impacts under this alternative would still be considered less than significant.

In addition, this alternative would not meet any of the project objectives related to employment opportunities, land use, and industrial uses.

Noise
The proposed project would result in a significant and unavoidable impact related to mobile source operational noise, less than significant impact with mitigation for temporary increase in ambient noise levels during construction, and less than significant impacts for noise land use compatibility, groundborne vibration, and airport noise (see Section 3.12, Noise). Under the No Project Alternative, there would be no change in groundborne vibration and noise sources (including from traffic-related noise), as there would be no changes to the existing land uses or daily vehicle trips. Noise and vibration levels in the project vicinity would remain the same as under existing conditions. Thus, there would be no noise impacts under this alternative. 2955
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Compared to the project, the No Project Alternative would have reduced noise impacts and would avoid the proposed project’s significant and unavoidable noise impact.

Public Services
The proposed project’s impacts to public services would be less than significant (see Section 3.13, Public Services). Under the No Project Alternative, there would be no change related to fire, police, school, or library services, as there would be no change to the existing land uses on the project site.

There would be no impact.

The No Project Alternative would have a lower level of public services impacts compared to the proposed project. However, the No Project Alternative would not meet the project objectives related to public services, such as providing buildings that meet contemporary industry standards, providing industrial uses with ready access to available infrastructure, or applying the land use vision that is contemplated for this site. Furthermore, the infrastructure improvements associated with the proposed project would not be implemented.

Under the No Project Alternative, transportation and traffic conditions would remain the same as the existing conditions because no development would occur on the project site. However, the proposed improvements to roadways and circulation, including new bike and pedestrian facilities, would not be implemented under this alternative. Under the No Project Alternative, there would be no impact, no mitigation would be required, and impacts would be reduced compared to the proposed project.

While the project site conditions would remain the same as existing conditions under the No Project Alternative, this alternative would not meet any of the project objectives related to transportation because this alternative would not reduce the need for members of the local workforce to commute outside the area for employment, place industrial sites in proximity to major transportation corridors to avoid or shorten truck-trip lengths, or place innovative industrial facilities in proximity to the Central Valley supply chain and goods movement network.

Utilities and Service Systems
The proposed project’s impacts to utility and service systems would be less than significant with mitigation incorporated (see Section 3.15, Utilities and Service Systems). Under the No Project Alternative, the infrastructure improvements to utilities and roadway frontage improvements would not occur. There would be no change related to water supply and wastewater utilities and 2956
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stormwater and solid waste collection service systems, as there would be no change to the existing on-site buildings and agricultural operations and associated utilities demand and infrastructure facilities. However, as discussed in Section 3.15, Utilities, the proposed project would use significantly less water than the existing almond farm on-site. As such, water demand would be greater under the No Project Alternative than under the proposed project. The Pacific Institute of California Department of Water Resources found that almond farms require 4.49 acre-feet per year (AFY) per acre, which is among the most water-intensive crops. Therefore, the No Project Alternative would demand more water than the proposed project. Furthermore, other project benefits related to utilities would not be implemented under this alternative, such as installation of stormwater retention basins, payment of impact fees for new water services, and reduced water use implementations from the policies outlined in the Visalia General Plan. However, because the existing water use on the project site is not considered a significant impact, no mitigation measures would be required, and this impact is considered less than significant. Thus, impacts related to utility and service systems would be less than significant under this alternative, which is less than the proposed project. The No Project Alternative would lessen impacts related to utilities and service systems.

Additionally, this alternative would not meet the project objectives related to utilities and service systems because it would not provide buildings that meet contemporary industry standards and ready access to available infrastructure, including utilities.

Wildfire
The proposed project would have less than significant impacts related to wildfire (See Section 3.16, Wildfire). The project site is not located in a “Fire Hazard Severity Zone,” nor is it located in an State Responsibility Area (SRA) or a “Very High Fire Hazard Severity Zone” in a local, State, or federal responsibility area. Under the No Project Alternative, there would be no change to the project site with regard to wildfire susceptibility. Thus, there would be no impact related to wildfire under this alternative.

The No Project Alternative would not exacerbate existing wildfire conditions and would have a lower level of wildfire risk, as the existing agricultural operations would remain on-site and would not add additional facilities and associated employees, potentially exposing additional persons to wildfire risk. However, the No Project Alternative would not add enhancements to reduce roadway safety hazards or improve emergency access, which would incrementally reduce impacts associated with wildfires. As such, under this alternative, there would be no impact, which is less than the proposed project.

6.4.2 - Conclusion
Under the proposed project, the implementation of mitigation measures would be required to reduce the potentially significant impacts associated with biological resources; cultural resources and tribal cultural resources; geology and soils; GHG emissions; hazards and hazardous materials; transportation; and utilities and service systems to less than significant levels. Agriculture and forest resource impacts related to the conversion of farmland would be significant and unavoidable. Air quality impacts related to criteria pollutants would be significant and unavoidable. Noise impacts 2957
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related to mobile source and operational noise would be significant and unavoidable. None of the mitigation measures required for biological resources; cultural resources and tribal cultural resources; geology and soils; GHG emissions; hazards and hazardous materials; transportation; and utilities and service systems would be implemented under this alternative; thus, these impacts would be lesser than the proposed project.

The No Project Alternative would further reduce the proposed project’s less than significant impacts related to aesthetics, light, and glare; energy; hydrology and water quality; public services; and wildfire.

The No Project Alternative would have similar impacts as compared to the proposed project’s less than significant impacts on land use and planning. This alternative would not result in any increased impacts.

The No Project Alternative would avoid the majority of the project’s impacts by leaving the site in its existing condition, thus avoiding impacts caused by the demolition of on-site buildings, construction of industrial and flex industrial buildings, infrastructure and off-site improvements, and impacts caused by the operation of the proposed project. Additionally, this alternative would avoid all of the proposed project’s significant and unavoidable impacts related to agriculture and forest resources, air quality, and noise. However, the No Project Alternative would not offer any of the benefits of the proposed project and would not advance any of the overall project objectives.

6.5 - Alternative 2—Reduced Footprint Alternative
Under this alternative, the alternative project would be developed in such a way as to reduce some construction and operational air quality impacts, operational noise impacts, and protect some of the on-site Prime Farmland by reducing the overall footprint of the developed areas. The eastern half of the project site, approximately 142 acres, would be preserved and would remain in agricultural production, and half of the total warehouse and industrial park land uses would be developed. The proposed associated commercial uses would be relocated to the western half of the site. The stormwater basins would be sized accordingly. It is assumed that culvert crossings over Modoc Ditch would be required, similar to the proposed project.

6.5.1 - Impact Analysis
Aesthetics, Light, and Glare
The proposed project’s impacts related to aesthetics would be less than significant (See Section 3.1, Aesthetics, Light, and Glare). Under Alternative 2, the square footage of the industrial park would be reduced, and approximately 142 acres would be preserved, which would result in reduced impacts to aesthetics, light, and glare as compared to the proposed project. Construction-related impacts including light and glare from construction equipment, construction machinery, and nighttime security lighting would be reduced because of the smaller development footprint. Additionally, the change in lighting and glare sources and changes to the existing character would not occur on 142 acres of the project site, resulting in incrementally reduced impacts. However, under Alternative 2, there would still be changes to the existing character of the project site, as well as the addition of 2958
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new light and glare sources, resulting in less than significant impacts. Therefore, impacts under this alternative would be similar to the proposed project.

Agriculture and Forest Resources
The proposed project’s impacts related to agriculture would be significant and unavoidable, and there would be no impact related to forestry resources. Most of the project site is designated as Prime Farmland and is subject to a Williamson Act Contract. The proposed project would result in the conversion of 284 acres of farmland to urban uses (See Section 3.2, Agricultural Resources and Forestry Resources). Under this alternative, 142 acres on the eastern half of the project site would be preserved and would remain in agricultural production, resulting in a 50 percent reduction in the number of acres that would be converted from farmland to urban uses. This alternative would preserve approximately half of the agricultural lands as compared to the proposed project. However, a partial Nonrenewal of the Williamson Act Contract was approved by the Tulare County Board of Supervisors on May 3, 2022 (Resolution No. 2022-0677). Cancellation of the Williamson Act Contract was approved by the Board of Supervisors on November 29, 2022 (Resolution No. 2022-1005).

Accordingly, the Williamson Act Contract will be issued a Certificate of Cancellation upon payment of cancellation fees. Under Alternative 2, half of the farmland on the project site would be preserved, but the Williamson Act Contract would still expire because of the County-approved cancellation.

The General Plan EIR planned for the conversion of approximately 14,265 acres of farmland to be converted into urban uses, including the project site. This conversion was evaluated and disclosed as part of the General Plan EIR. By reducing the amount of farmland to be converted, the impacts that were evaluated in the General Plan would be slightly reduced. However, even with the preservation of 142 acres on the project site, the overall loss of farmland in the General Plan area would still be significant and unavoidable with no available mitigation measures. Under this alternative, the project would result in a loss of 142 acres of farmland. While the total loss of acres in the General Plan area would be lower, the Draft EIR would still need to conservatively conclude that the project impacts are significant and unavoidable due to the loss of Prime Farmland on the project site. The preservation of 142 acres would not be substantial enough to change the conclusions of the General Plan EIR or of the Draft EIR prepared for the proposed project. Therefore, similar to the proposed project, impacts would remain significant and unavoidable under this alternative.

Furthermore, the preservation of an additional 142 acres of farmland would prevent the project from fully meeting several project objectives, including ensuring that development of the project site is consistent with applicable goals and policies as set forth in the City’s General Plan, including the land use vision set forth therein that contemplates light industrial and industrial uses; and maximizing development of the existing underutilized project site.

Air Quality
Under the proposed project, air quality impacts related to consistency with the applicable AQP and criteria pollutant emissions would be significant and unavoidable because construction and operational emissions and health risks would exceed applicable thresholds even after compliance with all applicable rules, regulations, and implementation of feasible mitigation. Whereas impacts related to odors would be less than significant.
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Under Alternative 2, the square footage of the industrial park would be reduced, and approximately 142 acres would be preserved, which would result in reduced construction and operational air quality impacts as compared to the proposed project. Reducing the size of development by 50 percent would reduce construction criteria pollutant emissions, such as CO and NOX, below the applicable thresholds, because 50 percent less development would result in fewer days of construction, fewer hours of operation of heavy equipment, less grading and hauling of soils, and fewer construction worker vehicles trips. In addition, Alternative 2 would reduce operational criteria pollutant emissions because 50 percent less development would result in fewer mobile emissions from trucks and passenger vehicles. However, despite the reduction of at least half of the proposed warehouse and industrial park uses and proportional heavy heavy-duty trucks trips during this alternative, operational criteria pollutant emissions would still exceed thresholds for CO, ROG, and NOX because the vast majority of operational emissions would still be from the use of heavy heavyduty trucks as part of warehouse and industrial park land uses. MM AIR-2c through MM Air-2f would reduce operational emissions. No additional mitigation measures would be feasible beyond what was proposed in the EIR, because the applicant would not have ownership over any of the heavy heavy-duty truck fleets. Therefore, although Alternative 2 would reduce some operational air quality criteria pollutants, air quality impacts related to operational emissions of criteria pollutants would remain significant and unavoidable. By reducing the project footprint and preserving the eastern half of the site, the project’s distance from the nearest sensitive receptors is significantly increased to over 2,700 feet. Health risk impacts during construction would be reduced to less than significant levels because diesel particulate matter (DPM) emissions would no longer be significantly concentrated in close proximity to sensitive receptors. This alternative would result in the same impacts related to odors because the type of land uses and development considered would be the same as analyzed in the EIR.

This alternative would meet the project objectives of developing innovative industrial uses as part of the Central Valley supply chain and goods movement network. However, because the project site would not be built out to its full potential, it would only partially meet the project objectives related to air quality, such as creating employment-generating businesses to reduce the need for members of the local workforce to commute outside the area for employment, and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to avoid or shorten truck-trip lengths.

Biological Resources
Under the proposed project, impacts to biological resources would be less than significant with mitigation incorporated. Under Alternative 2, approximately 142 acres would be preserved, which would protect some of the project site’s farmland and reduce potential impacts to biological resources, including Swainson’s hawk, special-status wildlife such as San Joaquin kit fox, active bird’s nests, and roosting bats, because fewer habitats could be disturbed. Overall, Alternative 2 would have marginally reduced impacts to biological resources as compared to the proposed project, although mitigation to prevent impacts to birds, kit fox, and bats would still be required under this alternative. Additionally, under this alternative, culvert crossings over Modoc Ditch and mitigation related to the jurisdictional delineation would still be required. Therefore, with implementation of MM BIO-1a through MM BIO-1f, and MM BIO-3 impacts to special-status species and to wetlands 2960
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and jurisdictional features under this alternative would be less than significant with mitigation incorporated, which is similar to the proposed project.

Cultural Resources and Tribal Cultural Resources
Under the proposed project, impacts to cultural resources and tribal cultural resources would be less than significant with mitigation incorporated. Under Alternative 2, the overall footprint of the developed areas would be reduced, and approximately 142 acres would be preserved. Because of the reduced square footage of development, there would be less ground disturbance and potentially fewer impacts on cultural resources and tribal cultural resources. However, because ground will be disturbed under this alternative, the possibility of inadvertent discovery remains similar to the proposed project and the mitigation measures to prevent impacts to cultural resources and tribal cultural resources from ground disturbance would still be required under this alternative. Therefore, with implementation of MM CUL-1, MM CUL-2, MM CUL-3, and MM CUL-4, impacts to historic resources, archaeological resources, human remains, and to tribal cultural resources under this alternative would be less than significant with mitigation, which is similar to the proposed project.

Energy
Under the proposed project, impacts related to energy would be less than significant. Under Alternative 2, the overall footprint of the developed areas would be reduced. Under Alternative 2, there would be a smaller change related to energy consumption during construction because the overall amount of construction activity, including building square footage, would be smaller. In addition, during operation less energy would be needed for lighting and energy due to smaller overall building space and fewer vehicle fuel consumption due to less demand for employees and truck deliveries. As a result, impacts would remain less than significant, similar to the proposed project.

This alternative would meet the project objectives of developing innovative industrial uses as part of the Central Valley supply chain and goods movement network. However, because the project site would not be built out to its full potential, it would only partially meet the project objectives related to energy, such as creating employment-generating businesses to reduce the need for members of the local workforce to commute outside the area for employment, and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to reduce fuel usage from truck trips.

Geology and Soils
The proposed project’s impacts related to geology and soils would be less than significant with mitigation incorporated (see Section 3.7, Geology and Soils). Development under Alternative 2 could cause potential substantial adverse impacts associated with seismic ground shaking because of the project’s location in a highly seismic region within the influence of multiple faults, similar to the proposed project. Because geological impacts such as seismic hazards are due to the project’s location, this alternative would still require the same mitigation measures as the proposed project to reduce geological impacts to less than significant. Implementaiton of MM GEO-1 and MM GEO-2 would reduce impacts related to earthquakes, seismic ground shaking, soil erosion and topsoil loss, unstable geologic location, and expansive soil. Furthermore, similar to the proposed project, 2961
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structures would be designed in accordance with the current California Building Standards Code (CBC) and Visalia Building Code (Chapter 15.08) to reduce hazards posed by seismic ground shaking and the proximity to known active faults. Additionally, this alternative would have a reduced impact on paleontological resources because the development footprint is smaller than the proposed project; however, because this alternative would still result in ground disturbance, mitigation would still be required during construction. Implementation of MM GEO-3 would reduce impacts to paleontological resources. Therefore, this alternative would be less than significant with mitigation incorporated. With the implementation of mitigation, this alternative would have a similar level of impacts as the proposed project.

Greenhouse Gas Emissions
Under the proposed project, impacts related to GHG emissions would be less than significant with mitigation incorporated. Mitigation measures to reduce GHG emissions impacts would require rooftop solar panels or a solar-ready rooftop design, as well as roofing material with light coloring, electric vehicle (EV) charging infrastructure, and limiting warehouse uses to dry storage. Under Alternative 2, the overall footprint of the developed areas would be reduced. Because of the reduced size of the facility and a smaller construction footprint and fewer operational vehicle trips, GHG emissions generation would be reduced as compared to the proposed project. However, under this alternative, mitigation measures such as rooftop solar and EV charging infrastructure would still be required in order to ensure the project would not conflict with applicable policies and plans with goals of reducing GHG emissions. Implementation of MM AIR-2d, MM GHG-2a, and MM GHG-2b would reduce impacts related to conflict with a plan, policy, or regulation that reduces GHG emissions. Therefore, similar to the proposed project, impacts related to GHG emissions would be less than significant with mitigation incorporated.

Additionally, because of the reduced development, this alternative would only partially meet the project objectives related to GHG emissions, such as reducing the need for members of the local workforce to commute outside the area for employment and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to reduce emissions from trucks.

Hazards and Hazardous Material
The proposed project’s impacts related to hazards and hazardous materials would be less than significant with mitigation incorporated (see Section 3.9, Hazards and Hazardous Materials). Under this alternative, the overall square footage of buildings would be reduced, and a portion of the site would be preserved for agricultural uses. The reduced development footprint would likely reduce the total amount of hazardous materials present on-site during both construction and operation; however, the hazardous materials on-site would require the same level of compliance with applicable regulations as the proposed project. Therefore, although impacts associated with hazards and the handling of hazardous materials may slightly decrease, the level of impacts would be less than significant, which would not be substantially lower than the proposed project such that there would be no impacts. However, similar to the proposed project, an unknown, abandoned, or unrecorded well may occur on-site and may be discovered during construction of this alternative, 2962
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which would require adherence to MM HAZ-1. Therefore, similar to the proposed project, impacts would be less than significant with mitigation incorporated under this alternative.

Hydrology and Water Quality
The proposed project’s impacts related to hydrology and water quality would be less than significant (see Section 3.10, Hydrology and Water Quality). Under this alternative, the overall square footage of development would be reduced, and ground disturbance would be reduced. Because of the reduced impervious hardscape due to preservation of existing agricultural lands, impacts related to hydrology, stormwater runoff and drainage, water quality, groundwater recharge and depletion, or flooding would be reduced. However, the level of impacts would not be reduced significantly such that there would be no impacts. Thus, hydrology and water quality impacts or improvements under this alternative would be less than significant, which is similar to the proposed project.

Land Use and Planning
The proposed project’s impacts related to land use and planning would be less than significant, and the proposed project would meet many of the project objectives, including of applying the goals and policies of the General Plan (see Section 3.11, Land Use and Planning). Under this alternative, the total square footage of development would be reduced, and 142 acres of agricultural land would be preserved.

This alternative would be only partially consistent with the project objective of applying the goals and policies of the General Plan, which focuses on developing employment opportunities and expanding the City’s industrial base. This alternative would not fully implement the General Plan’s land use vision, which planned the project site for industrial and light industrial uses. Therefore, this alternative would result in the same or slightly increased land use and planning impacts as compared to the proposed project. Impacts under this alternative would still be considered less than significant, which is similar to the proposed project.

In addition, this alternative would only partially meet the project objectives related to employment opportunities, land use, and industrial uses.

Noise
Under the proposed project, mitigation would be required to reduce impacts from noise-generating equipment associated with the drive-through carwash during operation of the proposed project, as well as noise impacts from potential conflicts between noise-generating operations and noisesensitive receptors. However, impacts related to off-site mobile source operational noise impact from traffic generation would be significant and unavoidable.

Under Alternative 2, there would be a change in noise sources from traffic-related noise as a result of the reduced project footprint, and a fewer number of employees would result in fewer daily vehicle trips and fewer truck trips when compared to the proposed project. Operational noise levels from traffic generation in the project vicinity would be somewhat reduced as compared to the proposed project. However, this alternative would still have the potential to result in impacts due to the drive-through carwash and conflicts between noise generators and noise-sensitive receptors and 2963
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would therefore require implementation of the same mitigation measures as the proposed project. implementation of MM NOI-1 and NOI-2 would reduce impacts related to substantial noise increase in excess of standards. Additionally, the significant and unavoidable off-site mobile source operational noise impact from traffic generation would be reduced under this alternative. Therefore, impacts would be less than significant with mitigation incorporated, and Alternative 2 would result in lesser noise impacts as compared to the proposed project.

Under Alternative 2, on-site construction activities would be located at the same distances from surrounding sensitive land uses (i.e., residences), meaning that construction-related noise impacts from on-site activities would be similar to the proposed project and also less than significant.

However, due to the reduction in land uses, Alternative 2 would require a shorter construction schedule. So, in this sense, the impact may be considered reduced compared to the proposed project.

Off-site construction noise impacts from sources such as haul trucks would be similar to the proposed project and also less than significant because haul trucks and other construction vehicles would likely utilize the same roadways as they would for the proposed project. But, as explained, Alternative 2 would require a shorter construction schedule and involve reduced construction requirements. As a result, Alternative 2 may require a shorter construction schedule. Overall, this alternative would result in lesser impacts as compared to the proposed project.

This alternative would not meet the project objectives related to placement of industrial uses to avoid locating industrial buildings in close proximity to residential uses and other sensitive receptors.

Public Services
The proposed project’s impacts to public services would be less than significant (see Section 3.13, Public Services). Because of the reduced square footage, the demand for public services would be reduced under this alternative. However, development under this alternative would still generate a demand for public services, which would be considered a less than significant impact. Therefore, impacts under this alternative would be similar to the proposed project.

This alternative would only partially meet the project objectives related to public services, such as providing buildings that meet contemporary industry standards, providing industrial uses with ready access to available infrastructure, and applying the land use vision that is contemplated for this site.

Transportation and Traffic
The proposed project’s transportation impacts would be less than significant with mitigation incorporated. Mitigation would include the preparation and implementation of a construction traffic control plan that would reduce the potential for construction vehicle conflicts with other roadway users, funding the addition of two flashing beacons/solar panels to be mounted on existing stop signs at the intersection, installing new STOP pavement markings and limit lines for the northbound and southbound approaches, and funding the addition of an advance intersection warning sign for the eastbound and westbound approaches, and additional improvements to intersections, drive approaches, and sidewalks, as well as installation of end-of-trip bicycle facilities and expansion of bicycle network. Implementation of MM TRANS-1 through MM TRANS-9, MM TRANS-10a, MM 2964
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TRANS-10b, and MM TRANS-11 would reduce impacts related to circulation system, Vehicle Miles Traveled (VMT), hazards, and emergency access.

Although the building footprint would be reduced, the proposed infrastructure improvements would still be required under this alternative. As such, this alternative would still generate potential conflicts between construction vehicles and other roadway users, and would require similar mitigation measures as the proposed project to reduce potential roadway safety hazards. Therefore, impacts would be less than significant with mitigation under this alternative. This alternative would result in similar impacts related to transportation as compared to the proposed project.

This alternative would only partially meet the project objectives related to transportation, such as creating local employment opportunities to reduce the commute for regional residents and placing industrial facilities close to major transportation corridors.

Utilities and Service Systems
The proposed project’s impacts to utility and service systems would be less than significant with mitigation incorporated (see Section 3.15, Utilities and Service Systems). Under this alternative, the overall development would be reduced, but the infrastructure improvements to utilities would still be developed to serve the project. Because of the reduced square footage, the demand for wastewater and solid waste collection service systems would be reduced under this alternative.

However, under this alternative, approximately 142 acres of farmland would remain in agricultural production. As discussed in Section 3.15, Utilities and Service Systems, the proposed project would use significantly less water than the existing almond farm. As such, because half of the existing almond farm would remain in production, water demand would be greater under this alternative than under the proposed project. However, water demand under this alternative would be reduced as compared to the existing conditions. Similar to the proposed project, development under this alternative would be adequately served by the existing water system and would not require the relocation or construction of new or expanded water facilities. Similar to the proposed project, development under this alternative would be required to adhere to MM UTIL-1, which would require that debris and waste generated shall be recycled to the extent feasible, allowing the development to be served by a landfill that contains sufficient capacity. Therefore, impacts under this alternative would be less than significant with mitigation incorporated, which is similar to the proposed project.

This alternative would only partially meet the project objectives related to utilities, such as providing buildings that meet contemporary industry standards, providing industrial uses with ready access to available infrastructure, and applying the land use vision that is contemplated for this site.

Wildfire
The proposed project would have no impacts related to wildfire (See Section 3.16, Wildfire). The project site is not located in a “Fire Hazard Severity Zone” nor is it located in an SRA or a “Very High Fire Hazard Severity Zone” in a local, State, or federal responsibility area. Under this alternative, there would be no change to the project site with regard to wildfire susceptibility. Thus, there would be no impact related to wildfire under this alternative, which is similar to the proposed project. 2965
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6.5.2 - Conclusion
Based on the above, this project alternative would result in lesser impacts related to noise. There are no greater impacts under this alternative. Alternative 2 would have similar impacts as compared to the proposed project regarding aesthetics, light, and glare; agricultural and forestry resources; air quality; biological resources; cultural resources and tribal cultural resources; energy; geology and soils; GHG emissions; hazards and hazardous materials; hydrology and water quality; land use and planning; public services; transportation; utilities and service systems; and wildfire. While these impacts would be marginally reduced under this alternative due to the reduced footprint of development and preservation of agriculture, it would not eliminate the significant and unavoidable impacts or reduce the need for mitigation, with the exception of noise impacts.

This alternative would meet the project objectives of developing a mixed-use industrial park, placing industrial uses near the State Highway system, and developing innovative industrial uses as part of the Central Valley supply chain and goods movement network, and applying the goals and policies of the General Plan, which focuses on developing light industrial and industrial uses. However, because the project site would not be built out to its full potential, it would only partially meet the project objectives of maximizing development of the site to generate increased revenue and economic development, and creating employment-generating businesses to reduce commuting and improve the jobs-to-housing balance.

Therefore, Alternative 2 would be environmentally inferior to the proposed project.

6.6 - Alternative 3—Alternative Location
Under this alternative, the alternative project would be constructed in the approximately 284-acre parcels west of Plaza Drive and Riggin Avenue. These parcels are selected as they are few of the remaining parcels within Tier I of the UDB that is designated as Industrial therefore generally suitable for the proposed development. The proposed project would require a General Plan Amendment to re-designate a portion of the site as Light Industrial for the proposed associated flex industrial/commercial uses conditionally allowed under Light Industrial. This site would be approximately 650 feet from the nearest sensitive receptors located southwest.

6.6.1 - Impact Analysis
Aesthetics, Light, and Glare
The proposed project’s impacts related to aesthetics would be less than significant (See Section 3.1, Aesthetics, Light, and Glare). Under the Alternative Location alternative, the project site would be located on a parcel west of the proposed project site (See Exhibit 6-1). Construction-related impacts including light and glare from construction equipment, construction machinery, and nighttime security lighting would be similar to the proposed project. Additionally, the change in lighting and glare sources and changes to the existing character of the alternative site would result in similar impacts. However, under this alternative, the nearest sensitive receptors would be located farther from the site, which would potentially reduce the light and glare impacts to the nearest sensitive receptors. However, the overall level of impacts would remain less than significant. Therefore, impacts under this alternative would be similar to the proposed project. 2966
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Agriculture and Forest Resources
The proposed project’s impacts related to agriculture would be significant and unavoidable, and there would be no impact related to forestry resources. Most of the project site is designated as Prime Farmland and is subject to a Williamson Act Contract. The proposed project would result in the conversion of 284 acres of farmland to urban uses (See Section 3.2, Agricultural Resources and Forestry Resources).

Under this alternative, the project site would be located on a site currently designated Industrial. A majority the alternative site is designated Prime Farmland, while the northern portion of the alternative site is designated Farmland of Statewide Importance.1 A partial Nonrenewal of the project site’s Williamson Act Contract was approved by the Tulare County Board of Supervisors on May 3, 2022 (Resolution No. 2022-0677). Cancellation of the Williamson Act Contract was approved by the Board of Supervisors on November 29, 2022 (Resolution No. 2022-1005). Accordingly, the Williamson Act Contract will be issued a Certificate of Cancellation upon payment of cancellation fees. Therefore, under this alternative, the Prime Farmland and Farmland of Statewide Importance would be converted to nonagricultural uses; however, the Williamson Act Contract would still expire regardless of the alternative development because of the County-approved cancellation.

Similar to the project site, the alternate site is located within Tier 1 of the City’s UDB. 2 Therefore,
similar to the proposed project, the mitigation program required in LU-P-34 is not applicable to the alternative site. This alternative would result in the loss of Prime Farmland, which was evaluated and disclosed as part of the General Plan EIR. Therefore, this alternative would not reduce the significant and unavoidable impacts associated with the proposed project. Impacts under this alternative would conservatively be considered significant and unavoidable, similar to the proposed project.

This alternative would meet the project objectives related to the conversion of agriculture, including ensuring that the development of the project site is consistent with applicable goals and policies as set forth in the City’s General Plan.

Under Alternative 3, the proposed project would be constructed in the parcels west of Plaza Drive and Riggin Avenue, but the square footage would be the same as the proposed project, and the construction and operations of this alternative would be the same as the proposed project.

Accordingly, there would be significant and unavoidable air quality impacts from construction and operational activities associated with generation of criteria pollutants, such as CO, ROG, NOX, and PM10 in Alternative 3. Since this alternative would be of the same size and scale and within close 1 California Department of Conservation. 2022. California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/dlrp/ciff/. Accessed June 13, 2023. 2 City of Visalia. 2014. Visalia General Plan Figure 6-4: Farmland. 2967
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proximity of the proposed project, impacts related to emissions of criteria pollutants would be significant and unavoidable, which is the same as the proposed project. Similar to the proposed project, under this alternative the same odor impacts would occur because the type of development-warehouse, industrial, and commercial uses would not generate significant odors.

This alternative would meet the project objectives of developing innovative industrial uses as part of the Central Valley supply chain and goods movement network. Because the project would be of similar size and scale under Alternative 3, it would achieve the project objectives related to air quality, such as creating employment-generating businesses to reduce the need for members of the local workforce to commute outside the area for employment, and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to avoid or shorten truck-trip lengths.

Biological Resources
Under the proposed project, impacts to biological resources would be less than significant with mitigation incorporated. With development of a similar project on an alternate site under Alternative 3, biological impacts could occur from development of a site previously used for agricultural purposes. The alternate location would potentially have similar biological resources as the proposed project (e.g., a project site used in an agricultural capacity), such as Swainson’s hawk, special-status wildlife such as San Joaquin kit fox, active bird’s nests, and roosting bats, which would require the same mitigation as the proposed project.

However, the Modoc Ditch runs through the center of the Alternative 3 site and would likely require multiple crossings or may require filling the Ditch in order to link the northern and southern parcels.

In contrast, the Ditch is located on the border of the current project site and would not require linking parcels between the Ditch. Therefore, mitigation measures to reduce potential impacts to the Ditch would be less practicable under this alternative as compared to the potential project impacts on the current project site.

With implementation of MM BIO1a through MM BIO-1f and MM BIO-3 impacts to special-status species and to wetlands and jurisdictional features would be reduced. Therefore, although impacts associated with biological resources would likely be less than significant with mitigation incorporated, this alternative would have greater impacts than the proposed project.

Cultural Resources and Tribal Cultural Resources
Under the proposed project, impacts to cultural resources and tribal cultural resources would be less than significant with mitigation incorporated. Under Alternative 3, there would be similar amounts of ground disturbance in a location near the proposed project site. The alternate site has not been evaluated for cultural resources and tribal cultural resources. Because ground will be disturbed under this alternative, the mitigation measures to prevent impacts to cultural resources and tribal cultural resources from ground disturbance would likely still be required under this alternative.

Additionally, a pedestrian survey or records search result could potentially indicate a greater sensitivity for cultural and tribal cultural resources. Therefore, with implementation of MM CUL-1, MM CUL-2, MM CUL-3, and MM CUL-4, impacts to historic resources, archaeological resources, 2968
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human remains, and to tribal cultural resources under this alternative would likely be less than significant with mitigation, which is similar to the proposed project.

Energy
Under the proposed project, impacts related to energy would be less than significant. Under Alternative 3, the overall footprint of the developed areas would be the same as the proposed project. With development of a similar project on an alternate site, energy impacts would occur from construction activities that utilize electricity and fuel and operational activities that utilize electricity, natural gas, and fuel. Since Alternative 3 would be of similar size and scale as the proposed project, impacts would be less than significant, which is the same as the proposed project.

Additionally, because Alternative 3 would be of a similar size, location, and scale and the proposed project, this alternative would meet the project objectives related to energy, such as reducing the need for members of the local workforce to commute outside the area for employment and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to reduce energy use from trucks.

The alternate site would be approximately 3,000 feet (0.57 mile) west of the proposed project site, which is in a similar geological setting as the proposed project site. Furthermore, development under this alternative would be of a similar size and scale as the propsed project. Furthermore, similar to the proposed project, structures would be designed in accordance with the current CBC and Visalia Building Code (Chapter 15.08) to reduce hazards posed by seismic ground shaking and the proximity to known active faults. Additionally, this alternative would have a similar potential to result in the discovery of previously unknown paleontological resources, so mitigation would still be required during construction. Therefore, the same mitigation measures that would be required for the proposed project, MM GEO-1, MM GEO-2, and MM GEO-3 would also be required under this alternative, and impacts related to earthquakes, seismic ground shaking, soil erosion and topsoil loss, unstable geologic location, expansive soil, and paleontological resources under this alternative would be less than significant with mitigation incorporated, which is similar to the proposed project.

Greenhouse Gas Emissions
Under the proposed project, impacts related to greenhouse gas emissions would be less than significant with mitigation incorporated. Mitigation measures to reduce greenhouse gas emissions impacts would require requiring rooftop solar panels or a solar-ready rooftop design, as well as roofing material with light coloring, EV charging infrastructure, and limiting warehouse uses to dry storage. Under Alternative 3, the project would be of a similar size and scale and would result in the same type of construction activities such as grading, hauling of soils, and building construction and 2969
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operational activities such as heavy heavy-duty trucks trips. Since this alternative would be of similar size and scale to the proposed project and is approximately the same distance to urbanized areas of Visalia, impacts would be similar to the proposed project. Furthermore, the mitigation measures that would be implemented under the proposed project for solar-ready rooftop and EV charging would need to be implemented under this alternative. Implementation of MM AIR-2d, MM GHG-2a, and MM GHG-2b would reduce impacts related to conflict with a plan, policy, or regulation that reduces GHG emissions. Therefore, similar to the proposed project, impacts would be less than significant with mitigation incorporated.

Additionally, because Alternative 3 would be of a similar size, location, and scale and the proposed project, this alternative would meet the project objectives related to greenhouse gas emissions, such as reducing the need for members of the local workforce to commute outside the area for employment, and maximizing the placement of industrial uses in close proximity to the State Highway system and other major transportation corridors to reduce emissions from trucks.

Hazards and Hazardous Material
The proposed project’s impacts related to hazards and hazardous materials would be less than significant with mitigation incorporated (see Section 3.9, Hazards and Hazardous Materials). Under this alternative, the overall square footage of development would be similar to the proposed project, and the hazardous materials on-site would require the same level of compliance with applicable regulations as the proposed project. Therefore, impacts associated with hazards and the handling of hazardous materials would be the same as the proposed project. In addition, similar to the proposed project, an unknown, abandoned, or unrecorded well may occur on-site and may be discovered during construction of this alternative, which would require adherence to MM HAZ-1. The level of impacts would be less than significant with mitigation incorporated, which would be the same as the proposed project. Therefore, similar to the proposed project, impacts would be less than significant with mitigation incorporated under this alternative.

Hydrology and Water Quality
The proposed project’s impacts related to hydrology and water quality would be less than significant (see Section 3.10, Hydrology and Water Quality). Under this alternative, the addition of new impervious surfaces would be the same as the proposed project, and associated improvements such as stormwater drainage would be similar to the proposed project. Impacts related to hydrology, stormwater runoff and drainage, water quality, groundwater recharge and depletion, or flooding would be similar to the proposed project. Thus, hydrology and water quality impacts or improvements under this alternative would be less than significant, which is similar to the proposed project.

Land Use and Planning
The proposed project’s impacts related to land use and planning would be less than significant, and the proposed project would meet many of the project objectives, including of applying the goals and policies of the General Plan (see Section 3.11, Land Use and Planning). 2970
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This alternative would not fully meet the project objectives related to land use and planning.

Although this alternative would be consistent with the project objective of applying the goals and policies of the General Plan, which focuses on developing employment opportunities and expanding the City’s industrial base, this alternative would not fully implement the General Plan’s land use vision because it would not implement the site of the proposed project for industrial and light industrial uses. Instead, it would develop on an alternate site that would require a General Plan Amendment to re-designate a portion of the site as Light Industrial for the proposed associated commercial uses conditionally allowed under Light Industrial. “General Plan consistency” is an important factor. CEQA case law is clear that EIRs for proposed private projects consistent with governing General Plan designations generally need not address alternative sites, given that such existing General Plan designations embody policy decisions already made by governing city councils and boards of supervisors. “[T]he keystone of regional planning is consistency—between the general plan, its internal elements, subordinate ordinances, and all derivative land use decisions.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 572.) “Case-by-case reconsideration of regional land use policies, in the context of a project-specific EIR, is the very antithesis of that goal.” (Id. at p. 573.) “[A]n EIR is not ordinarily an occasion for the reconsideration or overhaul of fundamental land use policy.” (Ibid.)
Therefore, this alternative would result in slightly increased land use and planning impacts as compared to the proposed project. However, with a General Plan Amendment, impacts under this alternative would still be considered less than significant, which is similar to the proposed project.

Under Alternative 3, on-site construction activities would be located farther from surrounding sensitive land uses (i.e., residences), meaning that construction-related noise impacts from on-site activities would be slightly less than the proposed project and similarly less than significant. Off-site construction noise impacts from sources such as haul trucks would be similar to the proposed project and less than significant because haul trucks and other vehicles would likely utilize the same roadways as they would for the proposed project.

However, because Alternative 3 would result in a similar number of new vehicle trips as the proposed project, it would have similar impacts on roadside noise levels in the vicinity of the project site, and mobile source operational impacts would therefore remain significant and unavoidable.

Overall, the level of impacts would be similar to the proposed project.

This alternative would meet the project objectives related to placement of industrial uses to avoid locating industrial buildings in close proximity to residential uses and other sensitive receptors, which would have the benefit of limiting noise impacts to residences and other noise-sensitive receptors.
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Public Services
The proposed project’s impacts to public services would be less than significant (see Section 3.13, Public Services). Because of the similar scale and size of development under this alternative, as well as the close proximity to the proposed project site, the demand for public services would be similar to the proposed project under this alternative. Development under this alternative would generate a similar demand for public services, which would be considered a less than significant impact.

Therefore, impacts under this alternative would be similar to the proposed project.

This alternative would not fully meet the project objectives related to public services. Although it would meet the project objectives of providing buildings that meet contemporary industry standards and providing industrial uses with ready access to available infrastructure, this alternative would not meet the project objective of applying the land use vision that is contemplated for the proposed project site.

With development of a similar project on an alternate site, transportation impacts would occur from construction (vehicles and equipment, which would require a Traffic Control Plan) and operation (vehicles associated with the residential and commercial development). Since Alternative 3 would be of similar size and scale to the proposed project, impacts are determined to be similar to the proposed project. Additionally, similar to the proposed project, the alternate site would be adjacent to Riggin Avenue, which would likely result in similar impacts as the proposed project regarding construction traffic and roadway safety, and mitigation would need to be implemented.

Implementation of MM TRANS-1 through MM TRANS-9, MM TRANS-10a, MM TRANS-10b, and MM TRANS-11 would reduce impacts related to circulation system, VMT, hazards, and emergency access.

Although the specific mitigation measures would be modified due to the alternate location, this alternative would not substantially reduce transportation impacts and would not eliminate the need for mitigation measures to reduce potential impacts related to construction vehicles and safety.

Therefore, impacts would be less than significant with mitigation incorporated, which is similar to the proposed project.

This alternative would meet the project objectives related to transportation, such as creating local employment opportunities to reduce the commute for regional residents and placing industrial facilities close to major transportation corridors.
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Draft EIR Alternatives to the Proposed Project
6-27
Utilities and Service Systems
The proposed project’s impacts to utility and service systems would be less than significant with mitigation incorporated (see Section 3.15, Utilities and Service Systems). Under this alternative, the location of the project would change, but the infrastructure improvements to utilities would still be developed to serve the alternate project site, which is currently undeveloped. Because the project would be of similar scale and size, the demand for wastewater and solid waste collection service systems would be similar under this alternative. Furthermore, development under this alternative would demand the same amount of water as the proposed project and would therefore be adequately served by the existing water system, and would not require the relocation or construction of new or expanded water facilities. Similar to the proposed project, development under this alternative would be required to adhere to MM UTIL-1, which would require that debris and waste generated shall be recycled to the extent feasible, allowing the development to be served by a landfill that contains sufficient capacity. Therefore, impacts under this alternative would be less than significant with mitigation incorporated, which is similar to the proposed project.

This alternative would only partially meet the project objectives related to utilities and service systems. Although it would meet the project objectives of providing buildings that meet contemporary industry standards, providing industrial uses with ready access to available infrastructure, it would not meet the project objective of building out the land use vision that is contemplated for the proposed project site.

6.6.2 - Conclusion
Based on the above, this project alternative would not increase or decrease any impacts, but it would meet most of the project objectives. Alternative 3 would have similar impacts as compared to the proposed project regarding aesthetics, light, and glare; agricultural resources and forest resources; air quality; cultural resources and tribal cultural resources; energy; geology and soils; GHG emissions; hazards and hazardous materials; hydrology and water quality; land use and planning; noise; public services; transportation; utilities; and wildfire.

This alternative would result in marginal increases or decreases to several impacts, as well as a substantial reduction in noise impacts due to conflicts between noise generators and noise-sensitive receptors, but it would not reduce the overall level of impacts for any of the topical areas analyzed under Alternative 3 above. Biological resources impacts would be slightly greater due to the location relative to the Modoc Ditch.

Overall, this alternative would meet most of the project objectives. These include developing a mixed-use industrial park, placing industrial uses near the State Highway system, and developing 2973
City of Visalia—Shirk and Riggin Industrial Project
Alternatives to the Proposed Project Draft EIR
6-28
innovative industrial uses as part of the Central Valley supply chain and goods movement network, maximizing development of the site to generate increased revenue and economic development, and creating employment-generating businesses to reduce commuting and improve the jobs-to-housing balance, and applying the goals and policies of the General Plan, which focuses on developing light industrial and industrial uses. However, this alternative would not meet the project objective of building out the land use vision that is contemplated for the proposed project site.

Furthermore, the alternative site that was analyzed under Alternative 3 is not currently under the ownership of the Applicant, and the project applicant cannot reasonably acquire, control, or otherwise have access to the alternative site that was selected (CEQA Guidelines § 15126.6(f)(2)).

Additionally, this property would require a General Plan Amendment and is therefore less consistent with the General Plan than the proposed project site.

Therefore, this alternative is environmentally inferior to the proposed project.

6.7 - Environmentally Superior Alternative
CEQA Guidelines Section 15126(e)(2) requires identification of an environmentally superior alternative. If the No Project Alternative is environmentally superior, CEQA requires selection of the “environmentally superior alternative other than the No Project Alternative” from among the project and the alternatives evaluated. The qualitative environmental effects of each alternative in relation to the proposed project are summarized in Table 6-1 below. As shown in Table 6-1, the No Project Alternative is the environmentally superior alternative, as future development within the planning area under the current General Plan and Zoning would result in fewer and less severe impacts.

Table 6-1: Summary of Alternatives
Environmental Topic Area No Project Reduced Footprint Alternate Location Aesthetics, Light, and Glare Lesser Similar Similar
Agricultural Resources and Forestry Resources Lesser Similar Similar Air Quality Lesser Similar Similar
Biological Resources Lesser Similar Greater
Cultural Resources and Tribal Cultural Resources Lesser Similar Similar Energy Lesser Similar Similar
Geology and Soils Lesser Similar Similar
Greenhouse Gas Emissions Lesser Similar Similar
Hazards and Hazardous Materials Lesser Similar Similar
Hydrology and Water Quality Lesser Similar Similar
Land Use and Planning Similar Similar Similar
Noise Lesser Lesser Similar
Public Services Lesser Similar Similar
Transportation Lesser Similar Similar
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Draft EIR Alternatives to the Proposed Project
6-29
Environmental Topic Area No Project Reduced Footprint Alternate Location Utilities and Service Systems Lesser Similar Similar
Wildfire Lesser Similar Similar
Source: FirstCarbon Solutions (FCS) 2023.

CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other alternatives.

Of the two remaining alternatives, the Reduced Footprint Alternative (Alternative 2) has the greatest potential to yield reductions in the severity of the proposed significant and unavoidable impacts because the significant and unavoidable off-site mobile source operational noise impacts from traffic generation would be reduced under this alternative. However, this alternative would not meet the project objectives of maximizing development of the site to generate increased revenue and economic development, and would only partially meet the project objective of creating employment-generating businesses to reduce commuting and improve the jobs-to-housing balance. 2975

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Exh ibit6-1
ProjectAlternativ es-SiteBoundary
Source:Bing AerialIm ag ery.Cityof Visalia,March 2024.

CITYOFVISALIA

SHIR K&R IGGININDUSTR IALPR OJECT

ENVIR ONMENTALIMPACTR EPOR T
2,000 1,000 0 2,000
Feet
Legend
Project Site
City of Visalia
Unincorporated Tulare County
Project Alternatives
Alternative 2
Alternative 3
City of Visalia Urban Growth Boundary
Tiers
Tier 1
Tier 2
Tier 3
41150039•03/2024|6-1_project_alternativ es.m xd
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City of Visalia—Shirk and Riggin Industrial Project Persons and Organizations Consulted/ Draft EIR List of Preparers
7-1
CHAPTER 7: PERSONS AND ORGANIZATIONS CONSULTED/LIST OF

PREPARERS

7.1 - Persons and Organizations Consulted

7.1.1 - CEQA Lead Agency
City of Visalia
Planning Division
Principal Planner............................................................................................................... Brandon Smith Economic Development Division
Economic Development Manager........................................................................................Devon Jones Community Development Department
Community Development Director ........................................................................................ Paul Bernal CEQA Consultant- QK
Principal Planner.............................................................................................................Jaymie L. Brauer

7.1.2 - Other Agency Support
State Agencies
California Department of Fish and Wildlife
Regional Manager................................................................................................................... Julie Vance Environmental Scientist....................................................................................................Jaime Marquez Native American Heritage Commission
Cultural Resources Analyst .................................................................................................Cameron Vela San Joaquin Valley Air Pollution Control District
Director of Permit Services...............................................................................................Brian Clements Air Quality Specialist........................................................................................................ Michael Corder

7.2 - Project Sponsor and Project Consultants

7.2.1 - Seefried Industrial Properties
Vice President.......................................................................................................................Bryan Frarey

7.2.2 - Kimley-Horn (Transportation Impact Analysis)
Project Engineer ..................................................................................................................... Joe Schultz 2979
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7-2

7.2.3 - 4Creeks (Water Supply Assessment)
Assistant Planner............................................................................................................ Nate Antepenko Planner/Project Manager............................................................................................. Molly Baumeister

7.2.4 - Ninyo & Moore (Phase I and II Environmental Site Assessment and Geotechnical Report)
Senior Staff Geologist........................................................................................................... Shayna Avila Principal Environmental Operations Manager..................................................................Jeff Aguilar, PG Principal Toxicologist........................................................................... Heriberto Robles, MS, PhD, DABT

7.3 - City of Visalia Consultants

7.3.1 - FirstCarbon Solutions (Environmental Impact Report) Project Director....................................................................................................................... Mary Bean Project Manager.................................................................................................................... Yael Marcus Project Manager.............................................................................................................................. Tsui Li Assistant Project Manager ......................................................................................... Stephanie Shepard Environmental Services Intern ......................................................................................Spencer Churchill Legal Counsel .................................................................................................................. Megan Starr, JD Director of Cultural Resources..........................................................................Dana DePietro, PhD, RPA Archaeologist ................................................................................................................... Stefanie Griffin Director of Noise and Air Quality ...............................................................................Phil Ault, LEED® AP Senior Air Quality Scientist..............................................................................................Kimber Johnson Senior Noise and Air Quality Scientist................................................................................... Noah Tanski Air Quality Associate ...................................................................................................... Spencer Pignotti Senior Biologist .................................................................................................................. Robert Carroll Intern....................................................................................................................................... Kelly Evans Publications Manager ............................................................................................................Susie Harris Publications Coordinator ........................................................................................................ Alec Harris Document Specialist....................................................................................................... Melissa Ramirez GIS/Graphics ................................................................................................................Karlee McCracken GIS Specialist.................................................................................................................Sebastian Macias

7.3.2 - FirstCarbon Solutions Subconsultants
South Environmental (Jurisdictional Delineation)
Principal Biologist...............................................................................................Matthew R. South, CWB 2980
FINAL
Environmental Impact Report
Shirk and Riggin Industrial Project
City of Visalia, Tulare County, California
State Clearinghouse Number 2022080658
Prepared for:

City of Visalia
315 E. Acequia Avenue
Visalia, CA 93291
559.713.4636
Contact: Brandon Smith, Principal Planner
Prepared by:

FirstCarbon Solutions
7726 N. First Street, #413
Fresno, CA 93720
714.508.4100
Contact: Mary Bean, Project Director
Yael Marcus, Project Manager
Report Date: January 17, 2025
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Final EIR Table of Contents
iii
Table of Contents
Section 1: Introduction ............................................................................................................... 1-1 Section 2: Responses to Written Comments................................................................................ 2-1

2.1 - List of Commenters ........................................................................................................ 2-1

2.2 - Response to Comments.................................................................................................. 2-2 Errata.......................................................................................................................... 3-1 Changes in Response to Specific Comments..................................................................3-1 List of Appendices
Appendix B: Air Quality, Greenhouse Gas, and Energy Supporting Information Appendix I: Revised Appendix M of the Transportation Impact Analysis List of Figures
Figure 2-1: Terrestrial Connectivity Map .........................................................................................2-197 2983

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Final EIR Introduction
1-1
SECTION 1: INTRODUCTION
The City of Visalia (City) is the Lead Agency for the Environmental Impact Report (EIR) (State Clearinghouse No. 2022080658) for the Shirk and Riggin Industrial Project (proposed project). In accordance with California Environmental Quality Act (CEQA) Guidelines Sections 15084 and 15087, the City prepared the Shirk and Riggin Industrial Project Draft Environmental Impact Report and appendices attached thereto (collectively, Draft EIR) and circulated the Draft EIR for public review in full compliance with CEQA Guidelines. The Draft EIR identifies significant effects on the environment which may occur as a result of implementation of the proposed project. After circulating the Draft EIR for the required 45-day public review and comment period, and pursuant to CEQA Guidelines Section 15088, the City has evaluated the comments received on the Draft EIR and prepared this Final Environmental Impact Report (Final EIR).

Pursuant to CEQA Guidelines Section 15132, this Final EIR includes: a list of persons, organizations, and agencies that provided comments on the Draft EIR during the public review and comment period that ran from April 11, 2024, to May 28, 2024; the Responses to Comments containing the responses to the comments received regarding the Draft EIR; an Errata containing revisions to the Draft EIR; and a Mitigation Monitoring and Reporting Program (MMRP) for the purpose of ensuring the enforceability of the identified mitigation measures to be utilized by the City of Visalia in connection therewith. This document is organized into three sections:
• Section 1—Introduction. Provides an introduction to the Final EIR. • Section 2—Responses to Written Comments. Provides a list of the agencies, organizations, and individuals who commented on the Draft EIR. Copies of all of the letters received regarding the Draft EIR, annotated with numbered comments, and responses thereto are included in this section.
• Section 3—Errata. Includes an addendum listing refinements and clarifications on the Draft EIR which have been incorporated.

The Final EIR consists of, collectively, the following contents:
• Draft EIR (provided under separate cover)
• Draft EIR Appendices (provided under separate cover)
• Introduction and Responses to Written Comments on the Draft EIR (Sections 1 and 2 of this document)
• Errata (Section 3 of this document)
• Mitigation Monitoring and Reporting Program (provided under separate cover) The EIR consists, collectively, of the Draft EIR and the Final EIR. 2985

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Final EIR Responses to Written Comments
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SECTION 2: RESPONSES TO WRITTEN COMMENTS

2.1 - List of Commenters
A list of public agencies, organizations, and individuals that provided comments during the public review period, which ran from April 11, 2024, to May 28, 2024, on the Shirk and Riggin Industrial Project Draft EIR (Draft EIR) is presented below. Each comment has been assigned a code. Individual comments within each communication have been numbered so comments can be cross-referenced with responses. Following this list, the text of the communication is reprinted and followed by the corresponding response.

After the close of the public comment period, two additional comment letters were received. A letter from the California Department of Fish and Wildlife (CDFW) was received by the City of Visalia (City) on June 4, 2024, and a letter from the San Joaquin Valley Air Pollution Control District (SJVAPCD) was received on June 6, 2024. Although not required to do so under California Environmental Quality Act (CEQA) Guidelines, the City chose to respond to these late comment letters as though they had been submitted during the regular public comment period. Accordingly, although the City is not required to provide a written response to late comment letter(s), the City has elected to respond, but without waiving its position that written responses to late comment letters are not required by law.

Commenter Commenter Code
State Agencies
California Department of Conservation ..........................................................................................CDOC Organizations
Advocates for the Environment........................................................................................................ AFTE Golden State Environmental Justice Alliance ................................................................................. GSEJA Laborers International Union of North America, Local 294 ........................................................... LIUNA Carpenters Union Local 1109 ................................................................................................. LOCAL1109 Comments Received after the May 29, 2024 Close of Public Comment Period California Department of Fish and Wildlife .................................................................................... CDFW San Joaquin Valley Air Pollution Control District........................................................................ SJVAPCD 2987
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Responses to Written Comments Final EIR
2-2

2.2 - Response to Comments

2.2.1 - Introduction
In accordance with CEQA Guidelines Section 15088, the City of Visalia, as the Lead Agency, evaluated the comments received on the Draft EIR (State Clearinghouse [SCH] No. 2022080658) for the Shirk and Riggin Industrial Project (proposed project) and has prepared the following responses to the comments received. This Response to Comments document becomes part of the Final EIR for the proposed project in accordance with CEQA Guidelines Section 15132.

2.2.2 - Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the List of Commenters.

CEQA requires recirculation of a Draft EIR when the Lead Agency adds “significant new information” to an EIR after public notice is given of the availability of a Draft EIR for public review, but before EIR certification (CEQA Guidelines § 15088.5). Recirculation is not required unless the EIR is changed in a way that would deprive the public of the opportunity to comment on significant new information, including a new significant impact for which no feasible mitigation is available to fully mitigate the impact (thus resulting in a significant and unavoidable impact), a substantial increase in the severity of a disclosed environmental impact, or development of a new feasible alternative or mitigation measures that would clearly lessen environmental impacts but which the project proponent declines to adopt (CEQA Guidelines § 15088.5(a)). Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR (CEQA Guidelines § 15088.5(b)).

These responses to comments include discussion providing clarification, amplification and/or minor modifications to specific environmental analyses. Neither the clarifications, amplifications, nor modifications constitute “significant new information” requiring recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.
2988
Gavin Newsom, Governor
David Shabazian, Director
State of California Natural Resources Agency | Department of Conservation 715 P Street, MS 1904, Sacramento, CA 95814
conservation.ca.gov | T: (916) 324-0850 | F: (916) 327-3430 MAY 16, 2024
VIA EMAIL: [email protected]

CITY OF VISALIA
ATTN: BRANDON SMITH, PRINCIPAL PLANNER
315 E. ACEQUIA AVENUE
VISALIA, CA 93291
Dear Mr. Smith:

ENVIRONMENTAL IMPACT REPORT FOR THE SHIRK AND RIGGIN INDUSTRIAL PROJECT, SCH# 2022080658
The Department of Conservation’s (Department) Division of Land Resource Protection (Division) has reviewed the Environmental Impact Report for the Shirk and Riggin Industrial Project (Project).

The Division monitors and maps farmland conversion on a statewide basis, provides technical assistance regarding the Williamson Act, and administers various agricultural land conservation programs. Public Resources Code, section 614, subdivision (b) authorizes the Department to provide soil conservation advisory services to local governments, including review of CEQA documents.

Protection of the state’s agricultural land resources is part of the Department’s mission and central to many of its programs. The CEQA process gives the Department an opportunity to acknowledge the value of the resource, identify areas of Department interest, and offer information on how to assess potential impacts or mitigation opportunities.

The Department respects local decision-making by informing the CEQA process, and is not taking a position or providing legal or policy interpretation.

We offer the following comments for consideration with respect to the project’s potential impacts on agricultural land and resources within the Department’s purview.

PROJECT ATTRIBUTES
The project applicant proposes to convert existing agricultural lands and develop the approximately 284-acre project site into an industrial park, consisting of eight industrial buildings used for warehouse, distribution, and light manufacturing; six flex industrial buildings; two drive-through restaurants; a convenience store; a recreational vehicle and self-storage facility; gas station; and a car wash.

CDOC

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Visalia City CouncilMarch 17, 2025

Visalia City Council
March 17, 2025