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.
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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 City of Visalia—Shirk and Riggin Industrial Project
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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 NO
X 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 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.
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.
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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 City of Visalia—Shirk and Riggin Industrial Project
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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-to- housing 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.
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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 soil- related 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.
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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.
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, as well as 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.
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 City of Visalia—Shirk and Riggin Industrial Project
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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 City of Visalia—Shirk and Riggin Industrial Project
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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 City of Visalia—Shirk and Riggin Industrial Project
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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 heavy- duty 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 City of Visalia—Shirk and Riggin Industrial Project
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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, City of Visalia—Shirk and Riggin Industrial Project
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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, City of Visalia—Shirk and Riggin Industrial Project
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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 noise- sensitive 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 City of Visalia—Shirk and Riggin Industrial Project
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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 City of Visalia—Shirk and Riggin Industrial Project
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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.
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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.
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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.
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. Under the proposed project, odor impacts were less than significant.
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, NO X, 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.
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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, City of Visalia—Shirk and Riggin Industrial Project
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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.
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 3 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.
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 City of Visalia—Shirk and Riggin Industrial Project
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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).
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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.
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 noise- sensitive receptors. However, impacts related to off-site mobile source operational noise impact from traffic generation would be significant and unavoidable.
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.
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, as well as 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.
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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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.
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.
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 City of Visalia—Shirk and Riggin Industrial Project
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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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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.
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P r o j e c t A l t e r n a t i v e s - S i t e B o u n d a r y S o u r c e : B i n g A e r i a l I m a g e r y . C i t y o f V i s a l i a , M a r c h 2 0 2 4 . C I T Y O F V I S A L I A
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Project Site
City of Visalia
Unincorporated Tulare County
Project Alternatives
Alternative 2
Alternative 3
City of Visalia Urban Growth Boundary
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City of Visalia—Shirk and Riggin Industrial Project Persons and Organizations Consulted/ Draft EIR List of Preparers
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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 Persons and Organizations Consulted/ City of Visalia—Shirk and Riggin Industrial Project List of Preparers Draft EIR
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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