Visalia City Council
July 20, 2026

The General Plan identified approximately 2,840 acres that have a moderate “shrink-swell” potential in the Visalia Planning Area. There are areas located near the SR 99/198 interchange, north of the St. Johns River, and in the northwest near the intersection of Road 80 and Avenue 328 (City of Visalia, 2014a). The Project site is located outside identified moderate shrink-swell potential areas and is not anticipated to be susceptible to expansive soils. Adherence to the California Building Code and City development standards required would allow the Project to develop the site and would not be subject to risk involving expansive soils. Therefore, the impact is considered less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.7e – Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems in areas where sewers are not available for the disposal of wastewater?
The Project proposes to connect to existing public infrastructure for sewer services, and no septic system is proposed. Development of the site will comply with required design standards for connection to existing public infrastructure. Therefore, the Project will have no impact as the Project will not develop an alternative wastewater disposal system.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.7f – Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
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Paleontological resources are the mineralized (fossilized) remains of prehistoric plant and animal life, exclusive of human remains or artifacts. Fossil remains such as bones, teeth, shells, and leaves are found in geologic deposits (rock formations) where they were originally buried. Fossil remains are considered to be important as they provide indicators of the Earth’s chronology and history. These resources are afforded protection under CEQA and are considered to be limited and nonrenewable, and they provide invaluable scientific and educational data.

The Project site does not have any known paleontological resources or unique geologic features. There is no evidence that cultural resources of any type (including historical, archaeological, paleontological, or unique geologic features) exist on the Project site.

Nevertheless, there is some possibility that a buried site may exist in the area and be obscured by vegetation, fill, or other historical activities, leaving no surface evidence.

The adopted General Plan Policies OSC-O-11 and OSC-P-42 seek to preserve and protect paleontological resources that are known to occur or are found within the City. Although unlikely, if fossil remains are discovered during construction activities, the Project would implement MM GEO-1. With implementation, there would not be a significant impact on a unique geological or paleontological resource.

MITIGATION MEASURE(S)
MM GEO-1: If any paleontological resources are encountered during ground-disturbance activities, all work within 25 feet of the find shall halt until a qualified paleontologist, as defined by the Society of Vertebrate Paleontology Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (2010), can evaluate the find and make recommendations regarding treatment. Paleontological resource materials may include resources such as fossils, plant impressions, or animal tracks preserved in rock. The qualified paleontologist shall contact the Natural History Museum of Los Angeles County or another appropriate facility regarding any discoveries of paleontological resources.

If the qualified paleontologist determines that the discovery represents a potentially significant paleontological resource, additional investigations and fossil recovery may be required to mitigate adverse impacts from Project implementation. If avoidance is not feasible, the paleontological resources shall be evaluated for their significance. If the resources are not significant, avoidance is not necessary. If the resources are significant, they shall be avoided to ensure no adverse effects, or such effects must be mitigated. Construction in that area shall not resume until the resource-appropriate measures are recommended or the materials are determined to be less than significant. If the resource is significant and fossil recovery is the identified form of treatment, then the fossil shall be deposited in an accredited and permanent scientific institution. Copies of all correspondence and reports shall be submitted to the Lead Agency.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated. 1061
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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact
No
Impact

3.4.8 - GREENHOUSE GAS EMISSIONS
Would the Project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
b. Conflict with any applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse gases?
Discussion
The analysis in this section are largely substantiated by the Air Quality Impact Analysis (AQIA) prepared for this Project (QK, 2025a), attached as Appendix A.

Impact #3.4.8a – Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? The proposed Project’s construction and operational greenhouse gas (GHG) emissions were estimated using CalEEMod (QK, 2025a). The Project’s GHG emissions are primarily from mobile source activities. Not all GHGs exhibit the same ability to induce climate change; as a result, GHG contributions are commonly quantified as CO2e. Table 3.4.8-1 presents the Project’s annual GHG emissions.

Table 3.4.8-1
Estimated Annual GHG Emissions (MT/Year)
Source CO2e
Total Construction Emissions 1,291
Annualized Construction Emissions1 43
Total Operational Emissions 5,721
Total Project Emissions 5,764
(QK, 2025a)
The SJVAPCD, a CEQA Trustee Agency for this Project, has developed thresholds to determine the significance of a proposed project – either implement Best Performance Standards or achieve a 29 percent reduction from BAU (business as usual, specific numerical threshold) (QK, 2025a). However, the SJVAPCD has established their BAU and baseline emissions based on the years 2002-2004 and 2020, respectively. The 2020 projected baseline has passed, and at this time, no new guidance has been approved for determining the BAU and projected □ □ □
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baseline for the next target year. Therefore, the 29 percent reduction from BAU cannot be applied to the subject Project in order to determine significance. Additionally, a Best Performance Standards threshold has not been established. For this Project, compliance with locally adopted climate plans will be used to determine the level of significance for GHG.

Therefore, the GHG analysis for this Project follows the suggestions from the Court’s ruling on the Newhall Ranch development project in order to determine the significance of using the project design features.

In the Court’s final ruling, it offered suggestions that were deemed appropriate use of the BAU methodology:
• Lead agencies can use the comparison to the BAU methodology if they determine what reduction a particular project must achieve in order to comply with statewide goals.
• Project design features that comply with regulations to reduce emissions may demonstrate that those components of emissions are less than significant. • Lead agencies could also demonstrate compliance with locally adopted climate plans or apply specific numerical thresholds developed by some local agencies.

Neither the City nor Tulare County has developed specific thresholds for GHGs. In the decade after SJVAPCD adopted their Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA, several new laws and executive orders were adopted that require additional reductions in years after 2020. For instance, SB 32 requires that GHG emissions be 40 percent less than 1990 levels by 2030. More drastic still, SB 100, which was signed by the Governor recently, requires 100 percent zero-carbon electricity by 2045. On the day SB 100 was signed into law, the Governor also signed Executive Order B55-18, which commits California to total, economy-wide carbon neutrality by 2045. Clearly, the 2009 Guidance may be somewhat inadequate in producing a meaningful comparison by today’s standards, which propose a grand vision that, if achieved, would fundamentally change how business is conducted and citizens live in the State. Thus, as discussed in the most recent updates to the Scoping Plan, the objectives of the Scoping Plan affect entire sectors of the economy, and it no longer makes sense to evaluate GHG emissions on a project level.

For these reasons, Project GHG emissions levels presented in Table 3.4.8-1 are primarily for disclosure purposes. The Project’s largest contributors to GHG emissions are from electricity and exhaust from transportation fuels. Electricity and transportation fuels are, in effect, regulated by requiring providers and importers of electricity and fuel to participate in the GHG Cap-and-Trade Program and other programs (e.g., low-carbon fuel standard, renewable portfolio standard). Each such sector-wide program exists within the framework of AB 32 and its descendant laws, the purpose of which is to achieve GHG emissions reductions consistent with the AB 32 Scoping Plan.

The Project would generate GHGs from electricity use and combustion of gasoline/diesel fuels, each of which is regulated near the top of the supply chain. As such, each citizen of California (including those creating emissions of this Project) will have no choice but to 1063
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purchase electricity and fuels produced in a way that is acceptable to the California market.

Thus, Project GHG emissions will be consistent with the relevant plan (i.e., AB 32 Scoping Plan). The Project would meet its fair share of the cost to mitigate the cumulative impact of global climate change because energy purchases are from the California market. Thus, consumers of electricity and transportation fuels are, in effect, regulated by higher-level emissions restrictions on the producers of these energy sources. Therefore, the Project would have a less-than-significant impact on applicable GHG reduction plans, and the Project’s contribution to cumulative global climate change impacts would not be cumulatively considerable, and impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.8b – Would the Project conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? California passed the California Global Warming Solutions Act of 2006. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. Under AB 32, CARB must adopt regulations by January 1, 2011, to achieve reductions in GHGs to meet the 1990 emission cap by 2020. On December 11, 2008, CARB adopted its initial Scoping Plan, which functions as a roadmap of CARB’s plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations. CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan.

SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt a Sustainable Communities Strategy (SCS) or Alternative Planning Strategy (APS) that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the TCAG region, CARB set targets at a 13 percent per capita decrease in 2020 and a 16 percent per capita decrease in 2035 from a base year of 2005.

Executive Order B-30-15 establishes a California GHG reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing GHG emissions to 80 percent below 1990 levels by 2050. Executive Order B-30-15 requires MPOs to implement measures that will achieve reductions of GHG emissions to meet the 2030 and 2050 GHG emissions reduction targets.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth and that designates locations for land uses to regulate growth. TCAG uses 1064
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the growth projections and land use information in adopted General Plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in the AQPs.

TCAG uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in the AQPs. Existing and future pollutant emissions computed in the AQP are based on land uses from the area’s general plans. AQPs detail the control measures and emission reductions required for reaching attainment of the air standards. A project would be consistent with the SJVAPCD’s air quality plan(s) if the pollutants emitted from the construction and operation of the project would not exceed the SJVAPCD emission thresholds or cause a significant impact on air quality.

The Project is consistent with the City of Visalia 2030 General Plan upon approval of the General Plan Amendment, as the GPA would not add or remove the General Plan land uses currently designated, it would allow for the developer to shift the location of the existing map code designations to improve utilization of the Project site. Therefore, the Project is consistent with the growth assumptions used in the applicable AQP.

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan, which will not conflict with these Plans. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit. Furthermore, the City’s Climate Action Plan provides the strategies required to achieve the State’s 2030 mitigation targets (City of Visalia, 2013). Certain GHG emissions reduction measures can be incorporated into an individual project to contribute to the collective GHG reduction goals of the City. As discussed in Impact #3.4.6, the proposed Project will utilize ENERGY STAR appliances, not utilize natural gas, all residential units will be equipped with 450-watt solar panels, utilize all electric appliances, and will be EV-ready (pre-wired during construction to allow for installation of EV residential charger in the future). The Project is consistent with the City’s adopted CALGreen building standards and the California Model Water Efficient Landscape Ordinance, which includes but is not limited to incorporating low-flow lavatory faucets, kitchen faucets, toilets, and urinals, and low-water-use landscaping and highefficiency irrigation systems. The proposed Project includes a high-density residential neighborhood that is within 550 feet of a transit stop, and the Project will construct a Class II Bikeway along the Project’s frontage to Lovers Lane and a Class I Bikeway along the Project's frontage to Cameron Creek to increase the neighborhood's Transit Oriented Design (TOD) factors. Therefore, the proposed Project is consistent with all applicable GHG emissions reduction measures within the City’s Climate Action Plan.

Based on the assessment above, and the assessment discussed in Impact #3.4.8a, the Project will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. The Project furthers the achievement of the County’s greenhouse gas reduction goals. Therefore, impacts would be less than significant. 1065
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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.9 - HAZARDS AND HAZARDOUS MATERIALS
Would the Project:
a. Create a significant hazard to the public or the
environment through the routine transport,
use, or disposal of hazardous materials?
b. Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
c. Emit hazardous emissions or involve
handling hazardous or acutely hazardous
materials, substances, or waste within onequarter mile of an existing or proposed school?
d. Be located on a site that is included on a list of
hazardous materials sites compiled pursuant
to Government Code Section 65962.5 and, as
a result, would it create a significant hazard
to the public or the environment?
e. For a Project located within an airport land
use plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the Project result
in a safety hazard or excessive noise for
people residing or working in the Project
area?
f. Impair implementation of, or physically
interfere with, an adopted emergency
response plan or emergency evacuation plan?
g. Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury, or death involving wildland fires?
Discussion
Impact #3.4.9a – Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? □ □ □
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Project Construction
Construction of the Project would involve the temporary transport and use of minor quantities of hazardous materials such as fuels, oils, lubricants, hydraulic fluids, paints, and solvents. The types and quantities of hazardous materials to be used and stored on-site would not be of a significant amount to create a reasonably foreseeable upset or accident condition. Transportation, storage, use, and disposal of hazardous materials during construction activities will be required to comply with applicable federal, State, and local statutes and regulations. The U.S. Department of Transportation and Caltrans regulate the transportation of hazardous materials. Any hazardous waste or debris that is generated during the construction of the proposed Project would be collected and transported away from the site and disposed of at an approved off-site landfill or other such facilities. In addition, sanitary waste generated during construction would be managed through portable toilets located at reasonably accessible on-site locations.

In addition to moving people, the roadway system in Visalia carries a substantial number of trucks moving goods. These routes are designed to allow truck traffic to pass through the City with minimal impact on residential neighborhoods, as well as local vehicular and pedestrian traffic (City of Visalia, 2014a). The City has not designated certain routes in the City as hazardous material routes. The Project is located and accessed via Lovers Lane, which is a designated truck route. Close proximity to a designated truck route could allow for quick access and reduced travel distance of temporary hazardous materials along designated truck routes. The VFD would respond to any hazardous materials incident, and additional fire department units would respond as necessary.

A review of the EnviroStor database and the Geotracker database did not identify any active or historic hazardous material site or hazardous material cleanup site on or within 1,000 feet of the Project site
State and local regulatory compliance would require that the use of hazardous materials in excess of certain thresholds (generally 55 gallons of liquid, 200 cubic feet of gas, and 500 pounds of solids) would require the preparation, submission, and receipt of approval of a Hazardous Materials Business Plan (HMBP). The HMBP would contain detailed information, including an inventory of hazardous materials at the facility, emergency response plans and procedures in the event of a reportable release or threatened release of a hazardous material, and safety training for employees. Any operation established on the Project site would be required to comply with an approved HMBP as per State requirements, and compliance would allow operational activities to result in a less-than-significant impact.

Operations
Once constructed, the use of such materials as paint, bleach, etc., is considered common for residential developments. Residential developments are unlikely to have hazardous materials stored or used in such quantities that would be considered a significant hazard.

The Project itself will not generate or use hazardous materials outside of Tulare County Environmental Health Department requirements.
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Based on the analysis above, Project construction and operation are not anticipated to result in significant impacts due to the transportation, use, or disposal of hazardous materials.

Therefore, Project impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9b – Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
See the discussion on Impact #3.4.9a above.

A review of historical aerial photographs indicates that the Project site was historically utilized for agricultural cultivation as early as 1994, including dwelling-type structures and smaller outbuildings located in the center of the Project site. Although the potential exists that environmentally persistent pesticides/herbicides may have been historically applied to crops grown on the subject site, it is anticipated that residual pesticides/herbicides potentially located on-site will be dislocated and diluted as a result of the grading and trenching operations that will be conducted in connection with the planned residential development of the property. Typically, this does not result in concentrations reported above regulatory screening levels.

There are no historical records or indications that an underground storage tank (UST) is located on the Project site (United States Environmental Protection Agency, 2025). Although there is no evidence of the presence of an underground storage tank, a very low possibility of an unregistered UST can exist due to the historical agricultural nature of the site. Should an unknown underground tank be found during construction activities, MM HAZ-1 requires the developer to stop work in that area and contact the State Water Resources Control Board and the Tulare County Environmental Health Division to discuss the next appropriate steps for the safe removal of the tank.

Per the California Department of Toxic Substances Control (DTSC) EnviroStor database (Cortese List), the Project site is not located on or within 100 feet of a listed hazardous materials/waste facility (California Department of Toxic Substances Control, 2025).

There are no active California Geologic Energy Management Division (CalGEM) identified oil or gas fields on or within 1,000 feet of the Project site (CalGEM, 2025).

Consequently, the Project is not anticipated to create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions. However, should an unknown UST or septic system be uncovered during construction of the Project, 1069
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implementation of MM HAZ-1 would reduce impacts that could result in upset or accidental hazardous material spills, which would be less than significant. Furthermore, the contractor or developer would be required to adhere to associated local and State guidelines when removing the existing agricultural well, which are intended to prevent significant upset or accident from potentially hazardous materials.

MITIGATION MEASURE(S)
MM HAZ-1: In the event that unknown underground storage tank(s) or a septic system are uncovered or damaged during excavation or grading activities, all work in that area shall cease. The State Water Resources Control Board (SWRCB) and the Tulare County Environmental Health Division shall be contacted to determine what appropriate remediation may be required and to identify the appropriate requirements and approvals.

A report of all communication and the determination made by the SWRCB and the County Health Division shall be submitted to the City.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.9c – Would the Project emit hazardous emissions or involve handling hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
The nearest school to the Project is Annie R. Mitchell Elementary School, located approximately 0.5 miles northwest. There are no schools, existing or proposed, within onequarter mile of the Project site. As noted in Impact #3.4.9a, above, construction activities for the Project could result in the temporary use of hazardous materials and or substances, such as lubricant and diesel fuel during construction. Exhaust from construction and related activities is expected to be minimal and not significant. All future construction-related activities as a result of the proposed Project would be subject to local, State, and federal laws related to emissions of hazardous materials and substances. However, construction of the Project would require implementation of BMPs when handling any hazardous materials, substances, or waste. Once constructed, the residential development is highly unlikely to generate hazardous materials over an established reporting threshold. Therefore, the Project would comply with State and local regulations for hazardous material handling and would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Impact #3.4.9d – Would the Project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, and, as a result, would it create a significant hazard to the public or the environment? As discussed in Impact #3.4.9b, the DTSC EnviroStor database (Cortese List), the Project site is not located on or within 100 feet of a listed hazardous materials/waste facility (California Department of Toxic Substances Control, 2025).

As such, the Project site will not create a significant hazard to the public or the environment and therefore has no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.9e – Would the Project be located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, and would the Project result in a safety hazard or excessive noise for people residing or working in the Project area?
The Project site is located approximately 6.75 miles east of the Visalia Municipal Airport and, therefore, is not located within the Airport Influence Area or Safety Compatibility Zone as indicated in the Tulare County Comprehensive Airport Land Use Plan (Tulare County, 2012).

Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area from an airport within two miles of the Project.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.9f – Would the Project impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan? The City of Visalia adopted their most recent Safety Element in February 2025. The purpose of the Safety Element is to identify natural and man-made public health and safety hazards within the City and to establish preventive and responsive policies and programs to mitigate their potential impacts. This Element addresses, among other things, emergency services. It also includes policies on natural hazards mitigation planning, in alignment with the Federal Disaster Mitigation Act of 2000 and the Federal Emergency Management Agency’s 1071
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implementing regulations, and supports the County’s Multi- Jurisdictional Local Hazard Mitigation Plan (City of Visalia, 2025a). The Emergency Operations Plan includes policies that would prevent new development from interfering with emergency response and evacuation plans.

The General Plan also provides guidance to City staff in the event of an extraordinary emergency situation associated with natural disasters and technological incidents. The Project would also comply with the appropriate local and State requirements regarding emergency response plans and access. The proposed Project would not inhibit the ability of local roadways to accommodate emergency response and evacuation activities.

Additionally, the proposed Project is required to adhere to the standards set forth in the City Municipal Code, which identifies the design standards for emergency access during both the Project’s construction and operational phases. The Project would also comply with the appropriate local and State requirements regarding emergency response plans and access.

The proposed Project would not inhibit the ability of local roadways to continue to accommodate emergency response and evacuation activities.

The proposed Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.9g – Would the Project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? The risk of wildfires is on the rise in California and the Tulare County region. While the possibility of fire within the limits of Visalia is relatively low, the neighboring areas, especially those situated to the east of the City, are expected to experience an increase in risk as climate change exacerbates conditions like prolonged drought and extreme temperatures.

There are no State Responsibility Areas (SRAs) within the vicinity of the Project site, and the Project site is not categorized as a “Very High” Fire Hazard Severity Zone (FHSZ) by Cal Fire (Cal Fire, 2023). The closest location, designated as Moderate Fire Hazard Zone, is located eight miles east of the foothills adjacent to Exeter. The Wildland Urban Interface (WUI) is the zone of transition between unoccupied land and human development. It is the line, area, or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels (U.S. Fire Administration, 2022). The Project site is not located within the WUI (ESRI, Mark Gilbert, 2021). Furthermore, the Project areas are generally flat, and by implementing State and local fire code requirements, the Project would 1072
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not exacerbate the risk of exposure of Project occupants to wildfire. Therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact
No
Impact

3.4.10 - HYDROLOGY AND WATER QUALITY
Would the Project:
a. Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or ground
water quality?
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the Project
may impede sustainable groundwater
management of the basin?
c. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would?
i. Result in substantial erosion or
siltation on- or off-site;
ii. Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site;
iii. Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or
iv. Impede or redirect flood flows?
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to Project
inundation?
e. Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
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Discussion
The discussion below is based, in part, on the Water Supply Assessment (WSA) completed for the Project, attached as Appendix E (Woodard & Curran, 2026).

Impact #3.4.10a – Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Construction
The proposed Project construction and groundbreaking activities have the potential to cause erosion, sedimentation, and discharge of construction debris from the Project site. Clearing of vegetation and grading activities, for example, could lead to exposed or stockpiled soils susceptible to peak stormwater runoff flows. Also, the compaction of soils by heavy equipment may minimally reduce the infiltration capacity of soils (exposed during construction) and increase runoff and erosion potential. The presence of significant amounts of raw materials for construction, including concrete and asphalt, may lead to stormwater runoff contamination. If uncontrolled, these materials could lead to water quality problems, including sediment-laden runoff, prohibited non-stormwater discharges, and ultimately the degradation of downstream receiving water bodies. Materials that could contribute to this impact include, but are not limited to, diesel fuel, gasoline, lubricant oils, hydraulic fluid, antifreeze, transmission fluid, lubricant grease, cement slurry, and other fluids utilized by construction and maintenance vehicles and equipment. Motorized equipment could leak hazardous materials such as motor oil, transmission fluid, or antifreeze due to inadequate or improper maintenance, unnoticed or unrepaired damage, improper refueling, or operator error. To avoid impacts to water quality, the Project would disturb more than one acre and would be required to prepare a SWPPP and ensure implementation of BMPs that address potential issues related to soil erosion and contaminated runoff in local waterways during construction. Implementing BMPs for construction activities, such as the use of straw waddle sandbags, silt fencing, swales, street sweeping, etc., and adherence to local requirements related to storm drain construction and maintenance, will reduce stormwater runoff to a less-than-significant impact during construction activities.

Operation (post-construction)
Water quality could also be degraded by typical residential pollutants, such as lawn fertilizers, residential-grade pesticides, and detergents. During dry periods, impervious surfaces (i.e., hardscape surfaces such as foundations and buildings) can collect grease, oils, and other vehicle-related pollutants. During storm events, these pollutants can mix with stormwater and degrade downstream water quality. The Project will comply with all applicable local requirements related to storm drains and drainage improvement fees, such as Visalia Municipal Code Section 16.36.110, which requires, “Storm drains shall be installed as required by the city engineer, or as required by a specific adopted master storm drain plan,” (City of Visalia, 2025b). Compliance with the adopted City improvement standards would result in a less-than-significant impact on waste discharge requirements associated with the operation of the Project.
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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10b – Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
The Project site is located in the Visalia Water District (District) of the California Water Service Company (Cal Water). The District is located within the Mid-Kaweah and Tule Subbasins within the Greater San Joaquin Valley Kaweah Subbasin. Groundwater is the sole source of water supply for the Visalia District (Woodard & Curran, 2026).

Historically, the groundwater available to the Visalia District from the underlying Kaweah and Tule Subbasins has consistently met the District’s needs. Due to successful conservation efforts and response to the historic drought spanning water years 2012-2015, water demand (and thus District groundwater pumping volumes) were significantly lower from 2014 through 2019 (i.e., averaging 27,736 AFY) than they had been in the previous 10 years (i.e., averaging 32,502 AFY). Most groundwater pumping in the Kaweah Subbasin is for agricultural use. From a regional perspective, Visalia District pumping represents only a small fraction of total groundwater pumping. It is therefore likely that management of agricultural groundwater use, rather than Municipal and Industrial use, will be a much larger determining factor in maintaining groundwater sustainability in both the Kaweah and Tule Subbasins in the future. Given the District’s proven ability to meet historical and the absence of any indication from Groundwater Sustainability Agencies (GSAs) in the Tule or Kaweah Subbasins that urban pumping will be restricted under Groundwater Sustainability Plan (GSP) implementation, it is reasonable to conclude that groundwater from the Subbasins will be sufficient to meet the District’s needs, including the proposed Project.

Although a significant amount of growth is projected in the Visalia District over the planning horizon (i.e., the District is projecting that service area population will increase by more than 50 percent over the next 25 years), as discussed in the District’s Urban Water Management Plan (UWMP), it is anticipated that some land currently used for agricultural production will be converted to residential and nonresidential urban uses to accommodate future growth.

Irrigated agriculture typically uses more water on a per-acre basis than urban uses; thus, some future growth within the District will likely result in a net decrease in water use within the subbasins. Although the 2020 UWMP anticipates sufficient groundwater supply under all conditions for the District as a whole, given that the demands associated with the proposed Project were not included in the 2020 UWMP demand projections for the District, an analysis of the sufficiency of the groundwater supply to meet Project demands is required pursuant to California Water Code (CWC) Section 10910(f)(5) and California Government Code (CGC) Section 66473.7(a)(2)(E).
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Proposed Project Water Supply and Demand Comparisons
The proposed Project site has historically been used for irrigated agricultural production, relying exclusively on groundwater pumped from the underlying Subbasin. A WSA was prepared for the Project (Appendix E), estimating the anticipated amount of water necessary for the proposed Project, and determining if there is sufficient water supply available to service the Project based on available data provided in Cal Water’s Visalia District 2020 UWMP. At full buildout, assumed to be 2030, the proposed Project is estimated to have a total water demand of approximately 209 AFY from the water uses described below in Table

3.4.10-1 (Woodard & Curran, 2026). Tables 3.4.10-2 through 3.4.10-4 demonstrate the District’s projected normal year water, single dry year and multiple dry year comparison of water supply and demand.
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Table 3.4.10-1
Estimated Annual Proposed Project Water Demand (AFY)
Water Use
Project Characteristics Demand
Factor Units GPD
Total Water Demand (AFY)
Area (SF) Area
(acres)
# of
Units 2030 2035 2040 2045 2050
SingleFamily
Residential
1,964,556 45 292 409 GPD/unit 119,428 134 134 134 134 134 MultiFamily
Residential
949,608 22 370 148 GPD/unit 54,760 61 61 61 61 61
Landscape 152,460 4 N/A 2,784,414 Gallons/year N/A 9 9 9 9 9 Water Loss 6 6 6 6 6
Existing Site Demand* 0 0 0 0 0
Net Annual Water Demand 209 209 209 209 209
Source: (Woodard & Curran, 2026)
Notes: GPD = Gallons Per Day, values rounded, *The average historical agricultural demand associated with the Project site was calculated to be 264 AFY; as historical water demands were not supplied by Cal Water, the total Project demands do not consider existing site demands.

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Table 3.4.10-2
Projected Normal Year Water Supply and Demand (AFY)
2025 2030 2035 2040 2045
Total Supply 32,520 36,305 39,517 42,923 46,361
Visalia District
Demand
32,520 35,276 38,310 41,258 44,529
Clements Ranch
Demand
0 209 209 209 209
Other
Developments
0 821 999 1,456 1,623
Total Potable
Water Demand
Inclusive of
Project
32,520 36,305 39,517 42,923 46,361
Difference 0 0 0 0 0
Supply Shortfall
(% of Demand)
None None None None None
Source: (Woodard & Curran, 2026)

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Table 3.4.10-3
Projected Single Dry Year Water Supply and Demand (AFY) Start Year 2025 2030 2035 2040 2045
Total Supply 33,152 36,992 40,265 43,728 47,232
Visalia District
Demand
33,152 35,962 39,057 42,063 45,400
Clements Ranch
Demand
0 209 209 209 209
Other
Developments
0 821 999 1,456 1,623
Total Potable
Water Demand
Inclusive of
Project
33,152 36,992 40,265 43,728 47,232
Difference 0 0 0 0 0
Supply Shortfall
(% of Demand)
None None None None None
Source: (Woodard & Curran, 2026)
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Table 3.4.10-4
Projected Multiple Dry Year Water Supply and Demand (AFY) 2025 2030 2035 2040 2045
Total Supply 33,543 37,417 40,728 44,227 47,771
Visalia District
Demand
33,543 36,387 39,520 42,562 45,939
Clements Ranch
Demand
0 209 209 209 209
Other
Developments
0 821 999 1,456 1,623
Total Potable
Water Demand
Inclusive of
Project
33,543 37,417 40,728 44,227 47,771
Difference 0 0 0 0 0
Supply Shortfall
(% of Demand)
None None None None None
Source: (Woodard & Curran, 2026)
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Conclusion
The District pumps groundwater within the jurisdictions of the Mid-Kaweah GSA, the Greater Kaweah GSA, and the Eastern Tule Groundwater Sustainability Agency (ETGSA).

Groundwater use is consistent with the applicable GSPs. As demonstrated in Tables 3.4.10-1 through 3.4.10-4, the WSA concludes that sufficient water supply is available to the District to meet all future demands associated with current and planned development within its service area, including demands of the proposed Project. The WSA prepared for this Project concludes that sufficient water supply is available to the District to meet all future demands associated with current and planned development within its service area, including those of the proposed Project. As demonstrated in Tables 3.4.10-1 through 3.4.10-4, the District is projected to continue meeting future water demands under normal, single dry, and multiple dry year conditions.

Furthermore, the City of Visalia has adopted green building standards and water-efficient landscaping ordinances consistent with previous versions of the CALGreen Building Standards Code and the California Model Water Efficient Landscape Ordinance (MWELO) (23 CCR 2.2.7 Section 490-495, 2025; CALGreen, 2022). Landscaping will also comply with AB 1572. As part of State requirements, all new developments within the City of Visalia must meet these efficiency standards. Accordingly, the proposed Project will incorporate low-flow lavatory faucets, kitchen faucets, toilets, and urinals in accordance with the CALGreen Code, and include low-water-use landscaping and high-efficiency irrigation systems to minimize outdoor water use in compliance with MWELO.

As concluded above, the proposed Project’s estimated water demand would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge, such that the Project may impede sustainable groundwater management of the basin. Therefore, the Project would result in a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(i) – Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
The existing drainage pattern of the site and area would be affected by Project development because of the increase in impervious surfaces at the site, such as residential rooftops, driveways, and sidewalks. As discussed in Impact #3.4.10a above, potential impacts on water quality from erosion and sedimentation are expected to be localized and temporary during 1082
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construction. Outlot G will be developed as an approximately 2.5-acre stormwater basin that will be maintained by the City, which will retain stormwater on site and provide intentional pervious surfaces for it to percolate and recharge the groundwater aquifer.

The Project, as designed, complies with the City’s Open Space and Conservation Policy OSCP-23, which requires setbacks from Cameron Creek to protect riparian areas (City of Visalia, 2014a). The Project will not impact this waterway or the vegetation along the creek.

The Project does not propose to alter the course of a stream or river through the addition of impervious surfaces, in a manner that would result in substantial erosion or siltation on- or off-site. The Project would connect to the existing City stormwater sewer infrastructure. The Project will comply with all applicable local building codes and regulations to minimize impacts during construction and post-construction. Construction-related erosion and sedimentation impacts due to soil disturbance would be less than significant after implementing a SWPPP and BMPs required by the NPDES, as well as City standards and requirements. Given this, the Project would result in a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(ii) – Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? See discussion in Impact #3.4.10c(i).

Ground‐disturbing activities related to Project construction, such as grading, excavation, placing fill, and trenching, could change existing surface drainage patterns and increase the potential for flooding, particularly during storm events. Regulatory mechanisms in place that would reduce the effects of construction activities on drainage patterns that would result in flooding on or off the construction site include compliance with the City’s grading plan check process and the NPDES Construction General Permit.

The potential for the construction of the proposed Project to alter existing drainage patterns would be minimized through compliance with the preparation of an SWPPP and the design and construction of an on-site stormwater basin. With the implementation of such measures, the Project would not substantially increase the amount of runoff to result in flooding on- or off-site. Development of the Project would include landscaping and open space, as well as lawns, which will allow stormwater to percolate back into the groundwater system in addition to the construction of City-compliant storm drain lines that would direct 1083
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stormwater into the City’s existing system to reduce the rate of surface runoff and avoid flooding on- or off-site. Therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(iii) – Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? See Impact #3.4.7b and c and Impact #3.4.10a, c(i), and c(ii).

The Project would comply with all applicable State and City codes and regulations. The Project will construct a stormwater retention basin on-site to capture stormwater, and engineering calculations will support the storm drainage plan to ensure that the Project does not create or contribute to runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Therefore, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10c(iv) – Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows?
As discussed under Impact #3.4.10(a) through (c)(iii), Project construction activities could potentially alter the course of the existing drainage pattern on the site. The Project would be required to comply with the NPDES Construction General Permit by preparing a SWPPP to specify BMPs to prevent construction pollutants.
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As discussed in Impact #3.4.10c(i), Outlot G will be developed as approximately a 2.5-acre stormwater basin that will maintain stormwater on the site, and provide intentional pervious surfaces for runoff to recharge into the groundwater.

The majority of the Project site is located within the Federal Emergency Management Agency (FEMA) 500-year flood hazard (0.2 percent chance flood hazard) zone, and a small portion of the southwest corner of the site is within Zone AE for Special Flood Hazard Area (Figure

3.4.10-1). Nevertheless, all structures within the Special Flood Hazard Area would be required to adhere to Visalia Municipal Code Chapter 15.60 (Floodplain Management Regulations) and California Building Code, which require structures to be built at or above base flood elevation, so as not to alter the mapped flood hazard area and reduce the risk of flooding to structures. Therefore, the Project Impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10d – Would the Project in flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundation?
The Project site is not located near the ocean or a steep topographic feature (i.e., mountain, hill, bluff, etc.). Tsunamis are waves generated in oceans from seismic activity. Due to the inland location of the site, tsunamis are not considered a hazard for the site. Therefore, there is no potential for the site to be inundated by a tsunami or mudflow.

A seiche is a wave generated by the periodic oscillation of a body of water whose period is a function of the resonant characteristics of the containing basin as controlled by its physical dimensions. The Project site is not adjacent to a large body of water that would be vulnerable to the development of a seiche. There is no potential for the inundation of the Project site by seiche.

According to the Tulare Multi-Jurisdictional Local Hazard Mitigation Plan, dam failure is extremely unlikely (County of Tulare, 2023).

As noted above, the Project site is within the 500-year and AE flood hazard zones. The Project will comply with applicable local, State, and federal requirements for construction in a flood zone, thereby reducing the impacts of flooding. Therefore, the Project would not contribute to inundation by flood hazard, tsunami, seiche or mudflow. As a result, the impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.
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LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.10e – Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? See Impact #3.4.10a regarding water quality.

Since the Project site is not within Cal Water District boundaries, the Project was not included in the 2020 UWMP demand projections for the District, and a WSA was prepared for this Project. The proposed Project water demands of 209 AFY represent less than one percent of the District's annual water demands. As demonstrated in Tables 3.4.10-1 through

3.4.10-4, the District is projected to continue meeting future water demands under normal, single dry, and multiple dry year conditions. Furthermore, as part of State requirements, from CALGreen and MWELO, all new developments within the City of Visalia must meet these efficiency standards. Accordingly, the proposed Project will incorporate low-flow lavatory faucets, kitchen faucets, toilets, and urinals in accordance with CALGreen Code, and include low-water-use landscaping and high-efficiency irrigation systems to minimize outdoor water use in compliance with MWELO.

Implementation of the General Plan policies, California Water Service’s 2020 Urban Water Management Plan, the Kaweah Delta Water Conservation District (KDWCD) 2010 Groundwater Management Plan and the City’s involvement with the KDWCD Integrated Regional Water Management Planning (IRWM) program, in addition to the City’s Stormwater Master Plan and Management Program and the Waterways and Trails Master Plan, will address the issues of providing an adequate, reliable and sustainable water supply for the Project’s future urban domestic and public safety consumptive purposes. The proposed Project is consistent with the Central Valley RWQCB and will comply with all applicable rules and regulations regarding water quality and groundwater management. As such, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Figure 3.4.10-1
FEMA Flood Hazard Zone
National Flood Hazard La y e r Fl RMette ,,!ik,FEMA
~,'
0 250 500 1,000 1,500
B""'"""'P llmJ[l.,,y so"'"": us as Natirrna/ Mtp 2 Q.23' Legend
SPECIAL FLOOD I HAZA.RD A REAS

OTHER AREAS OF
FI.DOD HAZARD

OTHERAREAS
Without B.as• f'lood EleHtlon (81"1;'.) ~•A,Y, Jl.:119
with BR or Depth zo.1 ■ M, M,A.-.; w,AA
Regulator~ rloodwa,
o .2911- An nu.al c h.anee Flood H.1:r.11rd .. Are.as:
o1t94annualohan~ 11oxl with average depth less th...-. one foot or with dr.ain.ac• areas ofle:s:s than me square mile J',wt ■ ,c - ~~~~:ec;,::i~i~n:a1;: ::~~al
~ ~;::::~:=~u:s~z:.!:~d Risk due to
".,,, .""1 Are.a with f'lood Risk du• to LeH1e.z,:,,u, o 11a•c11111:1 Are,11 of Minim.al Flood H.azard z,a,.- Jl E:ffectiYe LOMR:s:

Area of undetermined flood Hazard zo),. o
GENERAL Channel .. C:ulYert .. orStorm Sewer
STRUCTURES I I I I I I I Levee;, Dike., or rloodw.al I
i
Cross:Sectlons with 1'N,Annu.a1Chanee
W.ater $ urf.aoe Eleu1tion
- coastal Ir .an:s:ec:t
- Base P'lood Eleution Line (8:FE) = Limit ofStud,
- Jurisdi.:=tion eoundar,
- c oa. :nal n .anseet easel ine
OTHER -- Pro1ileaaseline
FEATURES ___ H,drographic:f' .atur■
Di Cl t.al D• t-1 .CW.allabl,a
No OIClt.al D.at.a AHll.abl•
unmapped
The pin displ cJ¥ed on the map Is an approximate
point selected b' the user and does not represent
an authoritatiY e pro pert, I oc.ation.

This m.ap compiles- with f"EMA':s: st.and.ards for ti- us ■ o1 digital 1'ood maps i1it is not •oid .as desoribed below.

The b.a.sern.ap shown ccrnplles with FEMA1s bas.an.ap
aoourao, standards
The flood h.az.ard inform.ation Is deriYed direct I, kom th■ authoritatiYe Nf'H. web serYioes provided b' fl!:MA. This map was e:ported on e/1:2f202e: at 2:~e: PM and does not ret eot c h.ances or .amendments s ub:s:equent to this d.ate and time. Th e Nf'HL and el'fe:otiYe intlrmation ma, ohange or become super ■ d bl' new d.at.a c,.,iar time.

This map imac• is '-'Old if the one or more of the follow inc m.ap elements do not appear: b.asem.ap im.a-•r11., 1lood ;rone labels ~ legend_. scale bar,. map creation dMe.,. .:=ommuni t, ldentl 1iers,. l'IRM p.an lnumb•, ,and f'IRM • .,,.OtiYed,ate.M,ap im.a1&•s for unmapped and unmodernized areas oann ~ be w:ed tlr reO,ilator, purpos:es. 1087
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Discussion
Impact #3.4.11a – Would the Project physically divide an established community? The physical division of an established community typically refers to the construction of a physical feature (such as an interstate highway or railroad tracks) or the removal of a means of access (such as a local road or bridge) that would impair mobility within an existing community, or between a community and outlying areas. For instance, the construction of an interstate highway through an existing community may constrain travel from one side of the community to another; similarly, such construction may also impair travel to areas outside of the community.

The Project site is surrounded by agricultural uses on the north, east, and south sides and a mix of high-density and low-density housing types to the west. The Project site is located directly east of the City limits, within the City’s Urban Growth Boundary – Tier II, and has residential General Plan designations (Low-, Medium-, and High-Density Residential) by the City General Plan. The proposed mixed-density housing development is a logical progression of urban development anticipated by the City, and would be compatible with housing development to the west. The Project proposes to convert existing agricultural land to residential use, so the proposed Project would not physically divide an established community. Furthermore, residential development on the Project site has been planned for by the City’s General Plan and would not divide an established community. The Project is not being built in a pre-existing community area, and would not create any physical barrier between an established community. These improvements would not affect connectivity and would not divide an established community. Therefore, the Project would have no impact.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.11 - LAND USE AND PLANNING
Would the Project:
a. Physically divide an established
community?
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?
□ □ □
□ □ □
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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.11b – Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The 2030 General Plan includes the policies related to land use that correlate to the proposed Project:
• LU-P-19: Ensure that growth occurs in a compact and concentric fashion by implementing the General Plan’s phased growth strategy. • LU-P-21: Allow annexation and development of residential, commercial, and industrial land to occur within the Tier II UGB and the Tier III Urban Growth Boundary consistent with the City’s Land Use Diagram, according to the following phasing thresholds:
o Tier II: The expansion criteria for land in Tier II to become available for annexation and development are that such annexation and development shall only occur if it does not result in excess of a 10-year supply of undeveloped residential land within the new Tier I. This is intended to be consistent with LAFCo policies discouraging residential annexations exceeding a 10-year housing inventory. Thus, the ‘‘inner’’ tier is distinguished from the GPURC-recommended Tier I in that it is not based on projected capacity and need, but rather on a requirement to be able to demonstrate that less than a 10-year inventory of residential land exists.
• LU-P-40: Use Mill, Packwood, and Cameron Creeks and other waterways as natural amenities and links between neighborhoods.
• LU-P-47: Establish criteria and standards for pedestrian, bicycle, and vehicle circulation networks within new subdivisions and non-residential development. • LU-P-58: Ensure that natural and open space features, such as Valley Oak trees and community waterways, are treated as special site amenities as part of any residential development.
• LU-P-71: Ensure that noise, traffic, and other potential conflicts that may arise in a mix of commercial and residential uses are mitigated through good site planning, building design, and/or appropriate operational measures. • OSC-P-23: Where no urban development exists, maintain a minimum riparian habitat development setback from the discernible top of the bank—50 feet for both sides of the Mill, Packwood and Cameron Creek corridors and 25 feet for both sides of Modoc, Persian and Mill Creek Ditches—provided that where riparian trees are located within 100 feet of the discernible top of the banks of the Creek corridors and 50 from the banks for the ditches, the setback shall be wide enough to include five feet outside 1089
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the drip line of such trees. Restore and enhance the area within the setback with native vegetation.

As proposed, the Project will be consistent with all relevant General Plan goals, objectives, and policies for Land Use. The Project accomplishes compliance with the General Plan policies listed above through compliance with phased growth thresholds for the UDB, comply with City circulation standards for new subdivisions, designing the Project to include buffers from the Tulare Irrigation Ditch and Cameron Creek in order to protect and highlight the natural features of the waterways and ensure compliance of all applicable local standards for noise related construction activities. Considering the Project would comply with all applicable General Plan policies, city and state regulations, the Project would have a lessthan-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Discussion
Impact #3.4.12a – Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? Surface mining in California is regulated through the Surface Mining and Reclamation Act (SMARA), a State law adopted in 1975 to address the dual goals of protecting the State’s need for a continuing supply of mineral resources, while protecting public and environmental health. SMARA requires that all cities incorporate into their general plans mapped mineral resource designations approved by the State Mining and Geology Board.

The Visalia Planning Area contains three former sand and gravel mines, but no currently operating mines and no designated Mineral Resource Zones (City of Visalia, 2014b).

According to CalGEM, there are no active, inactive, or capped oil wells located within the Project site, and it is not within a recognized oilfield. The Project will not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State. Therefore, there would be no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

Impact #3.4.12b – Would the Project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less–thanSignificant
Impact

No
Impact

3.4.12 - MINERAL RESOURCES
Would the Project:

a. Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state?
b. Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan?
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See discussion in Impact #3.4.12a, which discusses Project compliance with relevant elements of the General Plan.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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Discussion
Impact #3.4.13a – Would the Project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Noise is often described as unwanted sound. Sound is defined as any pressure variation in air that the human ear can detect. The perceived loudness of sounds is dependent upon many factors, including sound pressure level and frequency content. Community noise is commonly described in terms of the ambient noise level, which is defined as the allencompassing noise level associated with a given noise environment. The City establishes land use compatibility standards and noise policies in the Safety and Noise Chapter of the City’s General Plan. The following Policies are relevant to the proposed Project:
• N-O-1: Strive to achieve an acceptable noise environment for present and future residents of Visalia.
• N-O-2: Protect the City’s economic base by preventing the encroachment of incompatible land uses near known noise-producing industries, railroads, airports, and other sources.
• N-O-3: Protect noise-sensitive land uses such as schools, hospitals, and senior care facilities from encroachment of and exposure to excessive levels of noise.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.13 - NOISE
Would the Project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the Project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?
b. Generation of excessive groundborne
vibration or groundborne noise levels?
c. For a Project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been adopted,
within two miles of a public airport or public
use airport, would the Project expose people
residing or working in the Project area to
excessive noise levels?
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• N-P-2: Promote the use of noise attenuation measures to improve the acoustic environment inside residences where existing single-family residential development is located in a noise-impacted environment, such as along an arterial street or adjacent to a noise-producing use.
• N-P-3: Establish performance standards for noise reduction for new housing that may be exposed to community noise levels above 65 dB Day-Night Average Sound Level (DNL)/Community Noise Equivalent Level (CNEL), as shown on the Noise Contour Maps, based on the target acceptable noise levels for outdoor activity levels and interior spaces in Tables 8-2 and 8-3 [of the Noise Element of the General Plan]. Noise mitigation measures that may be considered to achieve these noise level targets include, but are not limited to, the following:
o Construct façades with substantial weight and insulation. o Use sound-rated windows with enhanced noise reduction for primary sleeping and activity areas.
o Use sound-rated doors for all exterior entries at primary sleeping and activity areas.
o Use minimum setbacks and exterior barriers.
o Use acoustic baffling of vents for chimneys, attic, and gable ends. o Install a mechanical ventilation system that provides fresh air under closed window conditions.
o Alternative acoustical designs that achieve the prescribed noise level standards may be approved, provided that a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces. • N-P-4: Where new development of industrial, commercial or other noise-generating land uses (including roadways, railroads and airports) may result in noise levels that exceed the noise level exposure criteria established by Tables 8-2 and 8-3 [of the Noise Element of the General Plan], require a noise study to determine impacts and require developers to mitigate these impacts in conformance with Tables 8-2 and 8- 3 as a condition of permit approval through appropriate means. Noise mitigation measures may include, but are not limited to:
o Screen and control noise sources, such as parking and loading facilities, outdoor activities, and mechanical equipment.
o Increase setbacks for noise sources from adjacent dwellings. o Retain fences, walls, and landscaping that serve as noise buffers. o Use soundproofing materials and double-glazed windows. o Use open space, building orientation and design, landscaping, and running water to mask sounds.
o Control hours of operation, including deliveries and trash pickup, to minimize noise impacts.
o Alternative acoustical designs that achieve the prescribed noise level reduction may be approved, provided a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces. As a last resort, developers may propose to construct noise walls along State highways and arterials when 1094
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compatible with aesthetic concerns and neighborhood character. This would be a developer's responsibility, with no City funding.
• N-P-5: Continue to enforce applicable State Noise Insulation Standards (California Administrative Code, Title 24) and Uniform Building Code (UBC) noise requirements. • N-P-7: Use the land use compatibility zone guidelines contained in the Airport Master Plan or more current information on airport noise to assess noise compatibility of airport operation with proposed land uses.

The Project will comply with all applicable City General Plan Policies, such as those notated above, through demonstrating compliance with local and State regulations, such as the Noise Ordinance (Chapter 8.36), the Project site being located a considerable distance from incompatible uses and sensitive receptors, construction of sound barriers along Lovers Lane (adjacent arterial street) and compliance with applicable State Noise Insulation Standards (California Administrative Code, Title 24) and UBC noise requirements in order to reduce noise impacts to future residences in the proposed subdivision.

Construction Noise
During Project construction, heavy equipment would be used for grading, excavation, paving, and building construction, which would increase ambient noise levels when in use. Noise levels would vary depending on the type of equipment used, how it is operated, and how well it is maintained. Noise exposure at any single point outside the Project work area would also vary depending upon the proximity of equipment activities to that point. The nearest existing sensitive uses (single-family and multi-family residential subdivisions) are located approximately 120 feet away from where construction activities could occur within the Project area.

It is possible that Project construction equipment could result in short-term increases over ambient maximum noise levels at nearby existing residential uses, but would remain within the limits defined by the City of Visalia Noise Ordinance. Pursuant to Visalia Municipal Code Section 8.36.050(C), the operation of construction equipment, including jackhammers, portable generators, pneumatic equipment, trenchers, or other such equipment, shall not be operated on the Project site between the weekday hours of 7:00 p.m. and 6:00 a.m. and between the weekend hours of 7:00 p.m. and 9:00 a.m.

Furthermore, a majority of the street frontages on Lovers Lane have existing sound barrier walls and vegetative screening materials, such as trees and shrubs, which could help reduce the temporary increase in sound levels experienced during the 18-24 months construction period.

Operations Noise
Once construction is complete, operational noise will be minimal and limited to usual noises exhibited from residential neighborhoods, which would be required to be within the limits outlined by the City’s Noise Ordinance.
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Therefore, through compliance with local and State noise standards, the temporary increase in noise levels caused by construction activities would be considered less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.13b – Would the Project result in generation of excessive groundborne vibration or groundborne noise levels?
See discussion in Impact #3.4.13a.

Groundborne vibrations or noise levels would increase during the temporary 18-24-month construction period. Pursuant to Visalia Municipal Code Section 8.36.050(C), the operation of construction equipment, including jackhammers, portable generators, pneumatic equipment, trenchers, or other such equipment, shall not be operated on the Project site between the weekday hours of 7:00 p.m. and 6:00 a.m. and between the weekend hours of 7:00 p.m. and 9:00 a.m. Therefore, on-site construction within the Project area is not expected to result in excessive groundborne vibration levels at nearby existing sensitive uses. Given the Project’s compliance with local regulations and the temporary nature of construction, there will not be long-term generation of excessive groundborne vibration or groundborne noise levels; therefore, this impact is less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.13c – Would the Project result in a Project located within the vicinity of a private airstrip or an airport land use plan, or, where such a plan has not been adopted, within two miles of a public airport or public use airport? Would the Project expose people residing or working in the Project area to excessive noise levels?
The Project is not within the vicinity of a private airstrip. The Project is located approximately 6.80 miles east of Visalia Municipal Airport, which is not within the airport influence area as identified in the Tulare County Airport Land Use Compatibility Plan (ALUCP) (County of Tulare, 2012). The ALUCP guides local jurisdictions in determining appropriate compatible land uses with detailed findings and policies. The General Plan, other City land use plans, and all City land use decisions must be compatible with the adopted ALUCP. The ALUCP includes CNEL noise contours based on projected airport and aircraft 1096
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operations, and the Project site is outside of the 60 dB CNEL noise contour. Therefore, there would be no impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less- than
Significant
Impact

No
Impact

3.4.14 - POPULATION AND HOUSING
Would the Project:
a. Induce substantial population unplanned
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?

Discussion
Impact #3.4.14a – Would the Project induce substantial population unplanned growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Population forecasts adopted by the City’s General Plan indicate growth for the City population of 210,000 people by 2030, with an average annual growth rate of 2.6 percent (City of Visalia, 2014b). As of 2020, the total population of the City of Visalia is 141,384 people, and the average of 2.94 persons per household (City of Visalia, 2024). Given that the Project proposes 662 units, the Project would generate approximately 1,946.28 persons. The General Plan designation is Low-, Medium-, and High-Density Residential, which the Project will be compatible with once the General Plan Amendment and Planned Unit Development are approved.

As noted previously, the City General Plan has designated the Project site for future urban uses under the Urban Growth Development Tier II. General Plan Policy LU-P-21 outlines that the expansion criteria for land in Tier II to become available for annexation and development is that such annexation and development shall only occur if it does not result in excess of a 10-year supply of undeveloped residential land within the new Tier I. This is intended to be consistent with LAFCo policies discouraging residential annexations exceeding a 10-year housing inventory (City of Visalia, 2014b). The City determined in 2023 that additional residential capacity was needed in Tier II.

The Project will comply with all applicable General Plan policies, and the Project will undergo review by City staff to ensure compliance. Given that the Project proposes to develop in areas where planned residential growth is anticipated in the General Plan, the Project would not □ □ □
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likely induce substantial unplanned population growth. Implementation of this Project will support the General Plan designation for future growth of residential land. Therefore, Project impacts are considered to be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.14b – Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? The Project site is currently undeveloped agricultural land under row crop and orchard cultivation.

Construction of the Project would likely be completed by construction workers residing in the City or the surrounding area, which would not require new housing. The Project will not result in the displacement of any persons as there are no habitable residential units on the Project site. As such, no impact associated with the displacement of housing or people would occur, and there would be no impacts.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.15 - PUBLIC SERVICES
Would the Project:
a. Result in substantial adverse physical
impacts associated with the provision of new
or physically altered governmental facilities,
need for new or physically altered
governmental facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times, or to other
performance objectives for any of the public
services:
i. Fire protection?
ii. Police protection?
iii. Schools?
iv. Parks?
v. Other public facilities?

Discussion
Impact #3.4.15a(i) – Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or to other performance objectives for any of the public services - Fire Protection? The City Fire Department (VFD) Fire Station 56 is approximately one mile north of the Project site.

Prior to the issuance of any building permits related to future development of the site, the developer will be required to pay development impact fees. A portion of those funds will be specifically earmarked for the use of the VFD to maintain an adequate level of service within its service boundary. The entire Project, whether submitted in phases or not, will be subject to review by the City Engineering, Public Works, and Fire Department in order to determine whether the Project's infrastructure design is in compliance with City policies for development. The Project’s water system will be reviewed to verify that the system can □
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supply the required fire flow for fire protection purposes. The establishment of gallons-perminute requirements for fire flow shall be based on the review of the VFD.

An Insurance Services Office (ISO) is a private company that inspects and ranks fire departments across the country to help insurance companies determine premiums for homeowners in the areas they serve. The ISO collects and analyzes firefighting capability information on nearly 46,000 areas and rates departments on fire suppression ability, water availability, and communications. ISO's methodology, known as the Fire Suppression Rating Schedule, assigns a class rating on a scale of 1 to 10, with Class 1 given to exemplary fire departments and Class 10 to departments that do not meet minimum criteria (City of Visalia, 2014b). The General Plan, adopted in 2014, states that the VFD had an ISO rating of 4 (City of Visalia, 2014b). In 2021, the Annual Report produced by the Visalia Fire Department stated that the VFD rating was 3, showing improvements in Visalia’s ability to be prepared for a fire response.

As previously stated, the Project is within the Tier II UDB, which is an area planned for future residential growth. Furthermore, the Project will be required to adhere to any conditions/policies pertaining to the construction of infrastructure needed for the Fire Department to provide an adequate level of fire protection service and pay development impact fees; therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(ii) – Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or to other performance objectives for any of the public services – Police Protection? The City of Visalia Police Department (VPD) Station is approximately 2.60 miles northwest of the Project site. The VPD provides police protection in the City and collaborates with other law enforcement agencies and the District Attorney’s office on crime prevention. According to the General Plan, adopted in 2014, the VFD has 143 sworn officers working out of two districts (City of Visalia, 2014b). According to the VFD 2023 Annual Report, there was an increase to 167 sworn officers working out of two districts (Visalia Police Department, 2023). Police headquarters is at 303 South Johnson Street in Downtown Visalia, adjacent to City Hall West. In 2007, the Department opened two substations and shifted to district-based operations. The District 1 substation, serving northern Visalia, is located at 204 Northwest 3rd Avenue, near Lincoln Oval. District 2, at 4100 South County Center Drive, serves the southern part of the city.
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As previously stated, the Project is within the Tier II UDB, which is an area planned for future residential growth. Furthermore, the Project will be required to adhere to any conditions/policies pertaining to the construction of infrastructure needed for the Police Department to provide an adequate level of fire protection service and pay development impact fees; therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(iii) – Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or to other performance objectives for any of the public services – Schools? Visalia Unified School District (VUSD or District) provides public education from kindergarten through 12th grade in the Planning Area. According to VUSD, the Project site is within the boundaries of Annie R. Mitchell Elementary School (approximately 0.46 miles northwest), Divisadero Middle School (approximately 2.75 miles northwest), and Mt.

Whitney High School (approximately 2.25 miles northwest) (Visalia Unified School District, 2025). Additionally, Blue Oak Academy, which is a public charter school, is located 0.71 miles east of the Project site.

The City’s 2023-2031 Certified Housing Element notes that there were 2.94 persons per household (City of Visalia, 2024). Assuming a two-parent household, the remaining .94 individuals are assumed to be school-age children. Given that the Project is estimating the development of 662 units, the Project would account for approximately 622.28 students who would utilize school services within the City.

In 2024, the VUSD developed a Facilities Plan that proposed school boundary changes to reduce the utilization of overutilized schools. This Plan considered future planned growth near schools in its development (Visalia Unified School District, 2024). As a result of boundary changes, Annie R Mitchell Elementary School’s projected 2027-28 utilization rate was reduced from 119.9 percent to 83.5 percent, while both Divisadero Middle School and Mt. Whitney High School would remain below full utilization for 2027-28 at a utilization rate of 69.6 percent and 92.6 percent, respectively.

The Project will be subject to school impact fees to mitigate any impacts on school facilities.

Given that the designated schools are projected to have utilization rates under capacity, the developer would need to pay school impact fees to help support future growth of schools, and the Project site area is in a planned residential growth area of the General Plan. Through 1102
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local funding, the school district is in a position to accommodate planned population growth for the foreseeable future through the payment and use of developer impact fees. Per Government Code Section 65996, impacts to school facilities are mitigated by Level 1, 2, and 3 developer fee legislative provisions. The Project developer will pay appropriate impact fees at the time of building permits. Therefore, with implementation of standard local requirements for development Projects related to school fees, the Project does not require new or physically altered school facilities to address the increase in the student population associated with the Project. Impacts are considered less than significant.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(iv) – Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or to other performance objectives for any of the public services – Parks? The City’s park standard for neighborhood and community parks in the General Plan is 5.0 acres per 1,000 residents (City of Visalia, 2014a). The buildout of the General Plan Land Use Diagram would result in approximately 85,000 new residents in Visalia, with a total population of about 210,000. To meet the General Plan parks standard, the additional population would require an additional 430 acres of parkland. There are three parks within a mile radius of the Project site (Neighborhood Park, Cherry Meadow Park, and Majestic Park). Parkland is designated directly east of the Project site, which may allow for park development in the future.

As discussed in Impact #3.4.14a, the Project would generate approximately 1,946.28 persons. This would mean that the Project would be required to provide approximately 9.73 acres of open space for recreational purposes (.005 acres per resident x 1,946.28 residents).

The Project includes 0.80 acres in open space within the medium-density gated community and 2.73 acres in open space and trail connections in the non-gated low-density single-family neighborhood. The Project’s development of open space and trail connections could be used for recreational purposes, which would support the City’s residents per park acres ratio in the UDB areas.

Furthermore, prior to issuance of a building permit for construction of a new dwelling unit, as defined by Chapter 12.36 (Park and Recreation Development Fees) of the City Municipal Code, or recordation of a final map or parcel map, where applicable, a fee shall be paid to the City for the purpose of constructing park and recreation facilities (City of Visalia, 2025b). Payment of development fees will help the City meet their parkland ratio. 1103
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Given the intentional design to add open space features to the proposed Project to support the City’s resident-to-parkland ratio and the requirement to pay development fees for parks, the Project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.15a(v) – Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or to other performance objectives for any of the public services – Other Public Facilities?
See Impact #3.4.15a(i) through (iv) above.

Community facilities are the network of public and private institutions that support the civic, social, and health needs of the population. They offer a variety of recreational, artistic, and educational programs and special events. The City also provides animal control services, refuse pick-up (via an agreement with Tulare County Resource Management Agency and Consolidated Waste Management Authority), and drainage management (City of Visalia, 2014b). These services receive funds allocated through the General Fund, usage fees, penalties, or impact fees.

The closest library (Tulare County Library) is located approximately 2.60 miles northwest of the Project site. The nearest healthcare centers (Kaweah Health Medical Clinic and Apria Healthcare) are located 1.40 and 1.70 miles northwest of the Project site, respectively. The nearest hospital (Kaweah Delta Hospital) is 2.20 miles northwest of the Project site.

As discussed in Impact #3.4.14a, the Project proposes to develop in areas where planned residential growth is anticipated in the General Plan. Development fees will be paid to offset the increased demand for public services such as animal control, libraries, and other government facilities. The proposed Project would support the General Plan designation for future growth of residential land in the UDB and would be required to offset the increased demand through the payment of development impact fees; therefore, the Project would have a less-than-significant impact as a result of this criterion.

MITIGATION MEASURE(S)
No mitigation measures are required.
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LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.16 - RECREATION
Would the Project:
a. Increase the use of existing neighborhood
and regional parks or other recreational
facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
b. Include recreational facilities or require the
construction or expansion of recreational
facilities that might have an adverse physical
effect on the environment?

Discussion
Impact #3.4.16a – Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
See discussion in Impact #3.4.15a(iv) regarding parks.

There are three parks within a mile radius of the Project site (Neighborhood Park, Cherry Meadow Park, and Majestic Park). The Project proposes to develop open space and trail connections to serve future residences of the subdivision, and would be required to pay development impact fees to offset the planned growth of the proposed Project.

According to the City’s Waterways and Trails Master Plan, the St. Johns River, Mill, Packwood, and Cameron Creeks are part of the community’s heritage and provide habitat to many species of flora and fauna, and available irrigation water to adjacent farmlands. The preservation and restoration of these waterways for public recreation, habitat, and community enjoyment is a high priority (City of Visalia , 2010). The Project site includes portions of the Cameron Creek Segment 3 trail, which is a preferred Class I Bike trail. Any trail construction or alterations would conform to design criteria in the City’s Waterways and Trails Master Plan and Municipal Code.

Given this discussion, there would be a less-than-significant impact on existing neighborhood parks, regional parks, or other recreational facilities.

MITIGATION MEASURE(S)
No mitigation measures are required.
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LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.16b – Would the Project include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
See Section 2 – Project Description, the proposed Project does not include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment; therefore, no impact is anticipated.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
There would be no impact.

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Discussion
The analysis in this section is substantiated a Traffic Impact Analysis (TIA) completed for the Project (JLB Traffic Engineering, Inc., 2026) and a Vehicle Miles Traveled (VMT) Analysis (VRPA Technologies, Inc., 2026), attached as Appendix D.

Impact #3.4.17a – Would the Project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Transit System
Visalia Transit and Tulare County Regional Transportation Agency (TCRTA) are the transit operators in this area of the City of Visalia. Visalia Transit has one transit route that operates in the vicinity of the proposed Project site. Route 9 operates on 45-minute intervals between 6:00 a.m. and 8:45 p.m. on weekdays and on 90-minute intervals between 8:00 a.m. and 6:15 p.m. on weekends. The nearest stop to the proposed Project site is located on the east side of Ben Maddox Way, approximately 550 feet north of Walnut Avenue. Retention of the existing and expansion of future transit routes are dependent on transit ridership demand and available funding.

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.17 - TRANSPORTATION AND TRAFFIC
Would the Project:
a. Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?
b. Conflict or be inconsistent with CEQA
Guidelines Section 15064.3, Subdivision
(b)?
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
d. Result in inadequate emergency access?
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Bicycle and Pedestrian Network
There are Class I and Class III bikeways in the vicinity of the proposed Project site. The Visalia ATP recommends that Class I, Class II, and Class III Bikeways be implemented adjacent to and in the vicinity of the Project site (JLB Traffic Engineering, Inc., 2026). In the vicinity of and adjacent to the Project site, Class I Bikeways are planned on Cameron Creek and K Avenue. Class II Bikeways are planned on Lovers Lane, Caldwell Avenue, and Walnut Avenue.

Class III Bikeways along Walnut Avenue. Therefore, it is recommended that the Project construct a Class II Bikeway along the Project’s frontage to Lovers Lane and a Class I Bikeway along the Project's frontage to Cameron Creek. As mentioned in Impact #3.4.16a, this bikeway segment is referred to as the Cameron Creek Segment 3 trail. Any trail construction or alterations would conform to design criteria in the City’s Waterways and Trails Master Plan and Municipal Code.

Roadway Network
Important roadways serving the Project are discussed below:
• Pinkham Street is an existing north-south two-lane undivided collector in the vicinity of the Project site. In this area, Pinkham Street exists between State Route 198 and Caldwell Avenue. The Visalia General Plan Circulation Element designates Pinkham Street as a collector between Avenue 320 and Avenue 272. • Lovers Lane is an existing north-south four-lane divided arterial adjacent to the Project site. In this area, Lovers Lane exists between the St. Johns River and Avenue 272. The Visalia General Plan Circulation Element designates Lovers Lane as an arterial between Avenue 320 and Avenue 272.
• Road 148 is an existing north-south two-lane undivided roadway in the vicinity of the Project site. In this area, Road 148 exists between Avenue 288 and Avenue 272. The Visalia General Plan Circulation Element designates Lovers Lane as a local roadway between Avenue 288 and Avenue 272.
• Walnut Avenue is an existing east-west two-lane undivided arterial in the vicinity of the Project site. In this area, Walnut Avenue exists between Road 86 and the eastern boundary of the City of Visalia. The Visalia General Plan Circulation Element designates Walnut Avenue as an arterial between Road 86 through the eastern boundary of the City of Visalia.
• K Avenue is an existing east-west two-lane undivided collector in the vicinity of the Project site. In this area, K Avenue exists between Santa Fe Street and Lovers Lane.

The Visalia General Plan Circulation Element designates K Avenue as a collector between Santa Fe Street and Road 148.
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• Sunnyside Avenue is an existing east-west two-lane undivided local roadway adjacent to the Project site. In this area, Sunnyside Avenue exists in segments throughout the City of Visalia SOI. The Visalia General Plan Circulation Element designates Sunnyside Avenue as a local roadway throughout the City of Visalia SOI. As part of this Project, Sunnyside Avenue will be extended east of Lovers Lane through the Project site. This Project reassigns Sunnyside Avenue as a collector.
• Caldwell Avenue is an existing east-west divided arterial in the vicinity of the Project site. In this area, Caldwell Avenue exists throughout the City of Visalia SOI. The Visalia General Plan Circulation Element designates Caldwell Avenue as an arterial throughout the City of Visalia SOI.

Project Traffic Analysis
Study intersections analyzed in the referenced TIA were performed under the jurisdiction of Caltrans, City of Visalia, and County of Tulare. Based on the comments received from these agencies, the TIA includes the study intersection of Road 148 at Caldwell Avenue, Project driveways along Sunnyside Avenue, Warrant 1 and Warrant 2 in all study scenarios, corner sight distance evaluations for all Project driveways, and a trip trace for the State Route 198 at Lovers Lane interchange.

The following intersections were studied:
• Lovers Lane/Walnut Avenue
• Pinkham Street/K Avenue
• Lovers Lane/K Avenue
• Lovers Lane/Project Driveway A
• Lovers Lane/Sunnyside Avenue
• Project Driveway B/Sunnyside Avenue
• Project Driveway C/Sunnyside Avenue
• Project Driveway D/Sunnyside Avenue
• Lovers Lane/Project Driveway E
• Pinkham Street/Caldwell Avenue
• Lovers Lane/Caldwell Avenue
• Road 148/Caldwell Avenue

LEVEL OF SERVICE (LOS) THRESHOLD
The potential traffic impacts of the proposed Project were evaluated in accordance with the standards set forth by the LOS policies of the City of Visalia, County of Tulare, and Caltrans.

While LOS is no longer the criterion of significance for traffic impacts under CEQA, the Visalia General Plan includes policies that utilize LOS to determine traffic-related improvements that are needed for a project. The Tulare County General Plan has established LOS D as the acceptable level of traffic congestion on county roads and streets that fall entirely outside the SOI of a city. The Visalia General Plan has established LOS D as the acceptable level of 1110
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traffic congestion on most major streets that fall within the SOI of the City of Visalia. All but one study intersection falls completely within the City of Visalia SOI.

Project Trip Generation
The trip generation rates for the proposed Project were obtained from the 11th Edition of the Trip Generation Manual published by the Institute of Transportation Engineers (ITE).

Table 3.4.17-1 presents the trip generation for the proposed Project with trip generation rates for Single Family Detached Housing and Multi-family Housing (Low-Rise). At buildout, the proposed Project is estimated to generate approximately 5,248 daily trips, 352 AM peak hour trips, and 463 PM peak hour trips. Table 3.4.17-1 summarizes the Project trip generation.

Traffic Signal Warrants
The California Manual on Uniform Traffic Control Devices (CA MUTCD) indicates that an engineering study of traffic conditions, pedestrian characteristics, and physical features of an intersection shall be conducted to determine whether installation of traffic signal controls is justified. The CA MUTCD provides a total of nine warrants to evaluate the need for traffic signal controls. Signalization of an intersection may be appropriate if one or more of the signal warrants are satisfied. These warrants include:
• Eight-Hour Vehicular Volume
• Four-Hour Vehicular Volume
• Peak Hour
• Pedestrian Volume
• School Crossing
• Coordinated Signal System
• Crash Experience
• Roadway Network
• Intersection Near a Grade Crossing.

Existing Conditions
The existing intersection peak hour turning movement counts were conducted at the study facilities in September 2025 and October 2025, while schools in the vicinity of the Project site were in session. The intersection turning movement counts included pedestrian and bicycle volumes. Results of the existing conditions intersection analysis are shown in Table

3.4.17-2. At present, the study intersection of Lovers Lane at Walnut Avenue generates an LOS of E, which exceeds the LOS D threshold during the AM peak period. 1111
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Table 3.4.17-1
Project Trip Generation Estimate
(JLB Traffic Engineering, Inc., 2026), d.u. = dwelling unit Land Use Size Unit
Daily A.M. Peak Hour PM Peak Hour
Rate Total Trip
Rate
In % Out
%
In Out Total Trip
Rate
In % Out
%
In Out Total
Phases 1 & 2: SingleFamily Detached
Housing (210)
292 d.u. 9.43 2,754 0.70 26 74 53 151 204 0.94 63 37 173 101 274 Phase 3: Multifamily Housing
(Low-Rise)
375 d.u. 6.24 2,494 0.40 24 76 36 112 148 0.51 63 37 119 70 189 TOTAL 5,248 89 263 352 292 171 463
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Table 3.4.17-2
Existing Intersection LOS Results
S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane/Walnut Avenue – 1
S 60.3 E 44.6 D
S (Improved) 32.4 C 27.2 C
Pinkham Street/K Avenue – 2 AWS 12.5 B 9.4 A
Lovers Lane/K Avenue – 3 TWS 14.2 B 13.4 B
Lovers Lane/Driveway A – 4 Doesn’t Exist - - - -
Lovers Lane/Sunnyside Avenue – 5 TWS 19.4 C 17.9 C
Driveway B/Sunnyside Avenue – 6 Doesn’t Exist - - - -
Driveway C/Sunnyside Avenue – 7 Doesn’t Exist - - - -
Driveway D/Sunnyside Avenue – 8 Doesn’t Exist - - - -
Lovers Lane/Driveway E – 9 Doesn’t Exist - - - -
Pinkham Street/Caldwell Avenue – 10 TWS 12.6 B 11.8 B
Lovers Lane/Caldwell Avenue – 11 S 25.2 C 26.1 C
Road 148/Caldwell Avenue – 12 TWS 24.1 C 16.0 C
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Opening Year No Project Traffic Conditions
The Opening Year No Project traffic volumes were obtained by using a combination of a portion of the TCAG model (Base Year 2015 and Cumulative Year 2046), a portion of the near-term traffic, and existing traffic volumes. The opening year for this Project is anticipated to be 2028. The Opening Year No Project traffic conditions scenario assumes the same roadway geometrics and traffic controls as those assumed in the existing traffic conditions scenario. It is anticipated that the intersection of Lovers Lane at Walnut Avenue will be constructed with additional lanes in the Year 2028, but these additional lanes were not assumed to take place in this scenario as a conservative measure. Table 3.4.17-3 presents a summary of the Opening Year No Project peak hour LOS at the study intersections. Under this scenario, the study intersection of Lovers Lane at Walnut Avenue is projected to continue exceeding its LOS threshold during the AM peak period.

OPENING YEAR PLUS PHASES 1 & 2 TRAFFIC CONDITIONS
This scenario evaluates total traffic volumes and roadway conditions based on the opening year (2028), plus Phase 1 (292 single-family units) traffic conditions. The opening year plus Phase 1 traffic volumes were obtained by adding the Phase 1 Project only trips to the opening year no Project traffic volumes. The Phases 1 & 2 Project Only Trips to the study facilities were developed based on existing travel patterns, the Project Select Zone, the surrounding roadway network, engineering judgment, existing residential and commercial densities, and the Visalia General Plan Circulation Element in the vicinity of the Project site. Table 3.4.17-4 presents a summary of the Opening Year plus Phases 1 & 2 peak hour LOS at the study intersections. Under this scenario, the study intersections of Lovers Lane at Walnut Avenue and Lovers Lane at Sunnyside Avenue are projected to exceed their LOS threshold during one of the peak periods. With improvements, both intersections achieve an LOS less than the threshold, as reflected in Table 3.4.17-4.

CUMULATIVE 5-YEAR NO PROJECT TRAFFIC CONDITIONS
The cumulative 5-year No Project traffic volumes were obtained by using a combination of a portion of the TCAG model (Base Year 2015 and Cumulative Year 2046), the near-term traffic, and existing traffic volumes. Under this scenario, the increment method was utilized to determine the growth in the area. Table 3.4.17-5 illustrates the summary of the Cumulative 5-Year No Project LOS at the study intersections. Under this scenario, the study intersection of Road 148 at Caldwell Avenue is projected to exceed its LOS threshold during the AM peak period. Cumulative 5-Year plus Phases 1 & 2 Project Traffic Conditions. 1114
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Table 3.4.17-3
Opening Year No Project Intersection LOS Results
S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane/Walnut Avenue – 1
S 65.3 E 47.0 D
S (Improved) 34.8 C 28.4 C
Pinkham Street/K Avenue – 2 AWS 13.1 B 9.6 A
Lovers Lane/K Avenue – 3 TWS 14.7 B 13.9 B
Lovers Lane/Driveway A – 4 Doesn’t Exist - - - -
Lovers Lane/Sunnyside Avenue – 5 TWS 20.8 C 18.8 C
Driveway B/Sunnyside Avenue – 6 Doesn’t Exist - - - -
Driveway C/Sunnyside Avenue – 7 Doesn’t Exist - - - -
Driveway D/Sunnyside Avenue – 8 Doesn’t Exist - - - -
Lovers Lane/Driveway E – 9 Doesn’t Exist - - - -
Pinkham Street/Caldwell Avenue – 10 TWS 13.0 B 12.1 B
Lovers Lane/Caldwell Avenue – 11 S 25.9 C 26.7 C
Road 148/Caldwell Avenue – 12 TWS 31.6 D 18.6 C
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Table 3.4.17-4
Opening Year (2028) Plus Phases 1 & 2 LOS Intersection Results S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane/Walnut Avenue – 1
S 66.8 E 49.8 D
S (Improved) 35.8 D 30.0 C
Pinkham Street/K Avenue – 2 AWS 14.2 B 9.6 A
Lovers Lane/K Avenue – 3 TWS 16.6 C 15.9 C
Lovers Lane/Driveway A – 4 Doesn’t Exist - - - -
Lovers Lane/Sunnyside Avenue – 5 TWS 34.0 D 41.0 E
S (Improved) 16.0 B 16.1 B
Driveway B/Sunnyside Avenue – 6 Doesn’t Exist - - - -
Driveway C/Sunnyside Avenue – 7 TWS 8.9 A 8.7 A
Driveway D/Sunnyside Avenue – 8 TWS 9.3 A 10.2 B
Lovers Lane/Driveway E – 9 TWS 10.1 B 10.9 B
Pinkham Street/Caldwell Avenue – 10 TWS 13.5 B 12.5 B
Lovers Lane/Caldwell Avenue – 11 S 26.6 C 27.5 C
Road 148/Caldwell Avenue – 12 TWS 32.9 D 19.1 C
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Table 3.4.17-5
Cumulative 5-Year No Project Intersection LOS Results
S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane/Walnut Avenue – 1 S 27.2 C 24.6 C
Pinkham Street/K Avenue – 2 AWS 14.1 B 10.0 A
Lovers Lane/K Avenue – 3 TWS 15.9 C 14.9 B
Lovers Lane/Driveway A – 4 Doesn’t Exist - - - -
Lovers Lane/Sunnyside Avenue – 5 TWS 23.4 C 20.8 C
Driveway B/Sunnyside Avenue – 6 Doesn’t Exist - - - -
Driveway C/Sunnyside Avenue – 7 Doesn’t Exist - - - -
Driveway D/Sunnyside Avenue – 8 Doesn’t Exist - - - -
Lovers Lane/Driveway E – 9 Doesn’t Exist - - - -
Pinkham Street/Caldwell Avenue – 10 TWS 13.7 B 12.7 B
Lovers Lane/Caldwell Avenue – 11 S 27.2 C 26.8 D
Road 148/Caldwell Avenue – 12
TWS 65.2 F 26.3 D
TWS (Improved) 32.7 D 22.7 C
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This scenario evaluates total traffic volumes and roadway conditions based on the cumulative 5-year plus Phases 1 & 2 traffic conditions. The cumulative 5-year period for this Project is anticipated to be 2033. The cumulative 5-year plus Phases 1 & 2 traffic volumes were obtained by adding Phases 1 & 2 Project only trips to the cumulative 5-year no Project traffic volumes. The Phases 1 & 2 Project only trips to the study facilities were developed based on existing travel patterns, the Project Select Zone, the surrounding roadway network, engineering judgment, existing residential and commercial densities, and the Visalia General Plan Circulation Element in the vicinity of the Project site. Table 3.4.17-6 presents a summary of the cumulative 5-year-plus Phases 1 & 2 peak-hour LOS at the study intersections. Under this scenario, the study intersections of Lovers Lane at Sunnyside Avenue and Road 148 at Caldwell Avenue are projected to exceed their LOS threshold during one or both peak periods. With improvements, both intersections achieve an LOS less than the threshold, as reflected in Table 3.4.17-6.

CUMULATIVE 5-YEAR PLUS PROJECT BUILDOUT LOS
This scenario evaluates total traffic volumes and roadway conditions based on the cumulative 5-year plus buildout Project traffic conditions. The cumulative 5-year plus buildout traffic volumes were obtained by adding the Phase 3 Project only trips to the cumulative 5-year plus Phases 1 & 2 traffic volumes. The Phase 3 Project only trips to the study facilities were developed based on existing travel patterns, the Project Select Zone, the surrounding roadway network, engineering judgment, existing residential and commercial densities, and the Visalia General Plan Circulation Element in the vicinity of the Project site.

Table 3.4.17-7 illustrates a summary of the Cumulative 5-Year Plus Buildout LOS at the study intersections. Under this scenario, the study intersections of Lovers Lane at Sunnyside Avenue and Road 148 at Caldwell Avenue are projected to exceed their LOS threshold during one or both peak periods. With improvements, both intersections achieve an LOS less than the threshold, as reflected in Table 3.4.17-7.
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Table 3.4.17-6
Cumulative 5-Year Plus Phases 1 & 2 Intersection LOS Results S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane /Walnut Avenue – 1 S 28.4 C 25.4 C
Pinkham Street/K Avenue – 2 AWS 15.6 C 10.1 B
Lovers Lane/K Avenue – 3 TWS 18.3 C 17.3 C
Lovers Lane/Driveway A – 4 Doesn’t Exist - - - -
Lovers Lane/Sunnyside Avenue – 5
TWS 41.6 E 49.5 E
S (Improved) 16.0 B 17.1 B
Driveway B/Sunnyside Avenue – 6 Doesn’t Exist - - - -
Driveway C/Sunnyside Avenue – 7 TWS 8.9 A 8.7 A
Driveway D/Sunnyside Avenue – 8 TWS 9.3 A 10.2 B
Lovers Lane/Driveway E – 9 TWS 10.3 B 11.1 B
Pinkham Street/Caldwell Avenue – 10 TWS 14.4 B 13.2 B
Lovers Lane/Caldwell Avenue – 11 S 27.8 C 29.0 C
Road 148/Caldwell Avenue – 12
TWS 69.8 F 27.3 D
TWS (Improved) 33.8 D 23.2 C
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Table 3.4.17-7
Cumulative 5-Year Plus Project Buildout Intersection LOS Results S – Signalized, AWS- All-Way Stop, TWS – Two-Way Stop, LOS = Level of Service based on average delay on signalized intersections, and All-Way STOP Controls LOS for two-way and one-way STOP-controlled intersections are based on the worst approach/movement of the minor street.

Intersection – ID No. Intersection Control
A.M. (7-9) Peak Hour P.M. Peak Hour
Av. Delay (sec/veh) LOS Delay (sec) LOS
Lovers Lane/Walnut Avenue – 1 S 30.3 C 26.2 C
Pinkham Street/K Avenue – 2 AWS 17.5 C 10.2 B
Lovers Lane/K Avenue – 3 TWS 22.1 C 20.1 C
Lovers Lane/Driveway A – 4 TWS 11.2 B 11.4 B
Lovers Lane/Sunnyside Avenue – 5
TWS 62.6 F >120.0 F
S (Improved) 15.8 B 21.6 C
Driveway B/Sunnyside Avenue – 6 TWS 9.5 A 9.0 A
Driveway C/Sunnyside Avenue – 7 TWS 8.9 A 8.7 A
Driveway D/Sunnyside Avenue – 8 TWS 9.3 A 10.2 B
Lovers Lane/Driveway E – 9 TWS 10.4 B 11.4 B
Pinkham Street/Caldwell Avenue – 10 TWS 15.0 C 13.6 B
Lovers Lane/Caldwell Avenue – 11 S 28.4 C 30.4 C
Road 148/Caldwell Avenue – 12
TWS 73.9 F 27.8 D
TWS (Improved) 34.8 D 23.5 C
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PROJECT’S PRO-RATA FAIR SHARE OF FUTURE TRANSPORTATION IMPROVEMENTS The Project’s fair share percentage impact on study intersections projected to fall below their LOS threshold and which are not covered by an existing impact fee program is provided in Table 3.4.17-8 and Table 3.4.17-9. The pro-rata fair shares were calculated using the Existing, Project-Only Trips, and Cumulative 2046 Year plus Buildout volumes. Since the critical peak period for the study facilities was determined to be during the AM peak, the AM peak volumes are used to determine the Project’s pro-rata fair share.

It is recommended that the Project contribute its equitable fair share as listed in Table

3.4.17-8 and Table 3.4.17-9 for the future improvements necessary to maintain an acceptable LOS. However, fair share contributions should only be made for those facilities or portions thereof currently not funded by the responsible agencies' roadway impact fee program(s) or grant funding, as appropriate. For those improvements not presently covered by local and regional roadway impact fee programs or grant funding, it is recommended that the Project contribute its equitable fair share. Payment of the Project’s equitable fair share, in addition to the local and regional impact fee programs, would satisfy the Project’s traffic impacts.

Table 3.4.17-8
Single-Family Residential Fair Share of Future Roadway Improvements Note: Project’s Fair Share (%) = ((Project Only Trips) / (Cumulative 2046 Year + Buildout Traffic Volumes) – (Existing Traffic Volumes)) x 100
Table 3.4.17-9
Multi-Family Residential Fair Share of Future Roadway Improvements Multi-family development of this Project has been included in the Project for environmental analysis purposes only. Phases 1 & 2 (Single-Family Residential Development) will be constructed by the applicant, and Phase 3 (Multi-Family Residential Development) will be constructed by a different developer. Therefore, Table 3.4.17-8 demonstrates the Fair Share Intersection
Existing
Traffic
Volumes
(AM Peak)
Project Only Trips
(PM Peak)
Cumulative 5-Year
Plus Buildout Traffic
Volumes
(AM Peak)
Project’s Fair
Share (%)
Road 148/
Caldwell
Avenue
814 13 1,236 3.1
Intersection
Existing
Traffic
Volumes
(AM Peak)
Project Only Trips
(PM Peak)
Cumulative 5-Year
Plus Buildout Traffic
Volumes
(AM Peak)
Project’s Fair
Share (%)
Road 148/
Caldwell
Avenue
814 10 1,236 2.4
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percentage of improvement costs for Phases 1 & 2, and Table 3.4.17-9 demonstrates the Fair Share percentage of improvement costs for Phase 3.

To mitigate for the Project’s direct transportation impacts and off-site road improvements, MM TRA-1 and TRA-2 has been incorporated, which requires that the Project applicant/developer responsible for the construction of each phase will pay their pro-rata fair share percentage of 3.1 percent for Phases 1 & 2 (Single-Family Residential Development) and the 2.4 percent for Phase 3 (Multi-Family Residential Development), assuming a full buildout of 375 units per the TIA prepared for this Project, prior to the issuance of building permits. If at the time of development of Phase 3 (Multi-Family Residential Development), the unit count is less than 375, the developer may submit a revised TIA showing the appropriate pro-rate fair share percentage for the reduced number of units. With mitigation incorporated, impacts will be reduced to less than significant, and the proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

MITIGATION MEASURE(S)
MM TRA-1: Prior to the issuance of building permits, the Project applicant/developer responsible for the construction of the Single-Family Residential Development will pay their pro-rate fair share percentage of 3.1 percent.

MM TRA-2: Prior to the issuance of building permits, the Project applicant/developer responsible for the construction of the Multi-Family Residential Development will pay their pro-rata fair share percentage of 2.4 percent. If at the time of development of the MultiFamily phase, the unit count is less than 375, the developer may submit a revised TIA showing the appropriate pro-rate fair share percentage for the reduced number of units.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.17b – Would the Project conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b)?
Under SB 743, VMT is a key measure used for gauging the environmental impacts of projects under CEQA. As part of the SB 375 land use/transportation integration process and the GHG goal setting, the State and Regional Transportation Planning Agencies (RTPA) have agreed to reduce GHG through integrated land use and transportation planning by a statewide average of approximately 15 percent by 2035 (City of Visalia, 2025c). According to the City’s VMT Threshold and Implementation Guidelines, a proposed (residential) project exceeding a level of 15 percent below the existing regional average VMT per capita may indicate a significant transportation impact. The VMT per capita threshold for residential projects in Tulare County is 11.1.
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The Project site is located in traffic impact zone 1421 and does not qualify for screening out of a VMT analysis because the Project site is in an area of the City where there is currently no population. The VMT analysis used the average of adjacent traffic impact zones (1402, 1439, 1440, and 1478) to determine that the Project’s VMT per capita is 11.03, which is below the 11.1 VMT per capita threshold for residential projects in Tulare County (VRPA Technologies, Inc., 2026). Therefore, the Project would not conflict with or be inconsistent with CEQA Guidelines Section 15064.3 Subdivision (b) and would result in a less-thansignificant impact.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.17c – Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
The Project does not propose any incompatible uses or include any design features that could increase traffic hazards. Future development of the site will be designed to meet current standards and safety regulations for transportation. All right-of-way and internal circulation improvements will be constructed to comply with the State and local regulations and design and safety standards of Chapter 33 of the CBC and Title 24 guidelines to create safe and accessible roadways.

Specific circulation patterns and roadway designs will incorporate all applicable safety measures to ensure that hazardous design features or inadequate emergency access to the site or other areas surrounding the Project area would not occur. The TIA prepared for this Project analyzed and recommended, “To ensure that motorists have the appropriate corner sight distance, the Project should ensure that it does not build any obstructions greater than two feet above street grade within the hatched triangular areas as depicted in the figures included in Appendix H of the TIA.”
Therefore, with the incorporated design features and compliance with all applicable rules and regulations, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Impact #3.4.17d – Would the Project result in inadequate emergency access? See the discussion in Impact #3.4.9f, regarding emergency response plans.

State and City Fire Codes establish standards by which emergency access may be determined and designed. Furthermore, Visalia Municipal Code 16.36.120 (Water mains, fire hydrants, and Fire Department access) requires that subdividers provide fire department access, as required by the current Fire Code. A network of local roads within the proposed Project property provides full access to all buildings within the development.

As previously discussed, the Project includes a General Plan Amendment which would modify the existing General Plan designations to optimize the residential development on the parcel and amend the Visalia Circulation Element to remove the “K” Avenue new onemile-long, two-lane collector from Lovers Lane to Road 248, as referenced in Figure 4-1 Roadway Classifications and Table 4-5 Planned Circulation Improvements of the City’s General Plan. An SCE substation, approximately 0.50 miles east of the Project site, is directly in the planned pathway of “K” Avenue, which would not allow for the extension of “K” Avenue. A new Sunnyside Avenue, one-mile-long, two-lane collector from the Lovers Lane/Sunnyside Avenue intersection to Road 248, is to be added to Figure 4-1 and Table 4-

5. All roadway development and design will meet State and City requirements.

The proposed Project site would have adequate internal circulation capacity, including entrance and exit routes to provide adequate unobstructed space for fire trucks and other emergency vehicles to gain access and to turn around. The proposed Project would not inhibit the ability of local roadways to continue to accommodate emergency response and evacuation activities. Therefore, the impacts of the Project would be less than significant regarding emergency access.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less–thanSignificant
Impact

No
Impact

3.4.18 - TRIBAL CULTURAL RESOURCES
Would the Project:
a. Would the Project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code
Section 21074 as either a site, feature, place,
cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native American
tribe and that is:
i. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
Public Resources Code Section
5020.1(k), or
ii. A resource determined by the lead
agency, in its discretion and
supported by substantial evidence,
to be significant pursuant to criteria
set forth in subdivision (c) of Public
Resources Code Section 5024.1. In
applying the criteria set forth in
subdivision (c) of Public Resources
Code Section 5024.1, the lead agency
shall consider the significance of the
resource to a California Native
American tribe.

Discussion
Impact #3.4.18a(i) – Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)?
See the discussion presented in Section 3.4.5 - Cultural Resources, Impacts #3.4.5a through

3.4.5c. SB 18/AB 52 early tribal consultation letters were prepared and distributed by the □ □ □
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City, on September 26, 2025, pursuant to Public Resources Code Section 21080.3.1 and Government Code Section 65300 et seq, Senate Bill 18 and Assembly Bill 52, letters were sent to each of the Native American tribes within the geographic area as identified by the NAHC (see Appendix C). The letters included a Project description and location maps. Tribal consultation under AB 52 and SB 18 closed on December 31, 2025. To date, no response has been received. Should the City receive communication with a tribal group, they will work in good faith to address any potential cultural resources concerns.

Upon any ground-breaking activity, there is the possibility of uncovering an object of cultural value. Mitigation Measures MM CUL-1 and MM CUL-2 must be implemented if any artifacts or human remains are discovered. Therefore, the Project would have a less-than-significant impact with mitigation incorporated.

MITIGATION MEASURE(S)
Implement MM CUL-1 and MM CUL-2.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.18a(ii) – Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

See discussion in Section 3.4.5, Cultural Resources and Impact #3.41.18(i) above.

With implemented mitigation measures CUL-1 and CUL-2, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource. Therefore, impacts are considered less than significant with mitigation measures incorporated.

MITIGATION MEASURE(S)
Implement MM CUL-1 and MM CUL-2

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated. 1126
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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.19 - UTILITIES AND SERVICE SYSTEMS
Would the Project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which would
cause significant environmental effects?
b. Have sufficient water supplies available to
serve the Project and reasonably foreseeable
future development during normal, dry and
multiple dry years?
c. Result in a determination by the wastewater
treatment provider that serves or may serve
the Project that it has adequate capacity to
serve the Project’s projected demand in
addition to the provider’s existing
commitments?
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity of
local infrastructure, or otherwise impair the
attainment of solid waste reduction goals?
e. Comply with federal, state and local
management and reduction statutes and
regulations related to solid waste?
The discussion below is based, in part, on the Water Supply Assessment (WSA) completed for the Project, attached as Appendix E (Woodard & Curran, 2026).

Discussion
Impact #3.4.19a – Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which would cause significant environmental effects?
The Project proposes a gated medium-density neighborhood and non-gated low-density and high-density residential neighborhoods. The gated community would have a Homeowners □ □ □
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Association (HOA), responsible for some services, such as road maintenance, open space maintenance, etc.

Sanitary Sewer System
Sewer services are provided to the Project site by the City. The Sewer System Master Plan for the City, completed in 1994, divided the system into eight service areas based on existing and proposed sewer trunklines, based on the growth pattern established by the previous General Plan. Visalia owns a Water Conservation Plant (WCP), located West of State Route 99 and South of State Route 198 (City of Visalia, 2014b). The General Plan Draft EIR concludes, based on the 2005 Sanitary Sewer Collection System Master Plan, the total load of the General Plan at full build-out would be 25,034,050 gallons per day (gpd), which would be below the total system capacity of 25,949,996 gpd.

The City uses the most current General Plan to aid in the development of its Capital Improvement Program for sanitary sewer facilities in subsequent years. This program is funded through the payment of Impact Fees associated with new development. The Project is in an area of the UGB that is planned for mixed-density residential growth and would pay development and connection fees. As previously mentioned, the Project is requesting a General Plan Amendment (GPA No. 2025-04) to modify existing General Plan designations to optimize the residential development on the parcel and amend the Circulation Element.

The residential land use designations are not changing in acreage value, only shifting in the location of the subject parcel. The Circulation Element amendment will not impact sanitary sewer systems. The Project’s land use designations were within the sanitary sewer system capacity analysis performed in the General Plan EIR, and the Project would contribute to the Capital Improvement Program through the payment of Impact Fees. The Project would not directly require or result in the relocation or construction of new or expanded wastewater treatment facilities. Therefore, the Project would generate a less-than-significant impact on City sanitary sewer systems.

Wastewater or Stormwater Drainage
In the Planning Area, storm and urban runoff drainage is provided by natural rivers and watercourses, irrigation ditches, storage reservoirs, and discharge locations (City of Visalia, 2014a). Components of the drainage system on private property, or within private drainage easements, are maintained by the underlying property owner. The City’s Storm Water Master Plan (SWMP), from 1994, identified seven waterways as well as the Goshen Drain that convey stormwater toward the southeast into a number of large basins on the west side of the City. The stormwater system is sufficient to accommodate the classifications and densities in the proposed General Plan without any substantial changes or additional improvements beyond those already identified in the SWMP (City of Visalia, 2014b).

The Project proposes to develop approximately 1.50 acres for a storm basin to accommodate runoff from impervious surfaces created as a result of the additional built environment the Project is proposing. The Project would be required to install City storm water drainage lines and street runoff that is consistent with the current SWMP. The Project’s land use 1128
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designations were within the stormwater drainage system capacity analysis performed in the General Plan EIR, and the Project would contribute to the Capital Improvement Program through the payment of Impact Fees. Therefore, the Project’s impact on the City’s stormwater drainage system would be less than significant.

Water
As discussed in Impact #3.4.10b, the Visalia District of Cal Water would provide water to the Project site. The 2020 UWMP anticipates sufficient groundwater supply under all conditions for the District as a whole, given that the demands associated with the proposed Project were not included in the 2020 UWMP demand projections for the District, an analysis of the sufficiency of the groundwater supply to meet Project demands is required pursuant to CWC Section 10910(f)(5) and CGC Section 66473.7(a)(2)(E). This WSA concludes that sufficient water supply is available to the District to meet all future demands associated with current and planned development within its service area, including those of the proposed Project. As demonstrated in Tables 3.4.10-1 through 3.4.10-4, the District is projected to continue meeting future water demands under normal, single dry, and multiple dry year conditions, with inclusion of the proposed Project. The proper sizing and placement of water lines will be designed per the City and other utility development design standards.

Electricity, Natural Gas, and Telecommunications
Southern California Edison provides electric service to Visalia residents. The electrical facilities network includes both overhead and underground lines, with new development required to install underground service lines. The Project is not anticipated to use natural gas services, as all appliances will be electric. There are three major companies that provide communications services in Visalia: AT&T, Sprint, and Verizon. Comcast is the primary cable television and internet provider.

The Project is expected to connect to SCE utilities via infrastructure extensions and connections that are acceptable to both SCE and the City. All residential units will be equipped with 450-watt solar panels, utilize all electric appliances, and will be EV-ready (pre-wired during construction to allow for installation of an EV residential charger in the future). Therefore, the Project’s electricity use will be offset by the rooftop solar, and natural gas will not be utilized by residences. The Project is not anticipated to result in additional construction related to new or expanded electrical facilities.

Conclusion
The Project site area is within the City’s SOI and UDB – Tier II. Low-, medium-, and highdensity residential land uses are planned under the City’s General Plan and adopted Environmental Impact Report. Given the discussions above in various utility categories, the Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which would cause significant environmental effects, as utilities in the region have reasonable capacity to 1129
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accommodate the proposed residential development. Therefore, the impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation measures are required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19b – Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years?
As discussed in Impact 3.4.10b, Tables 3.4.10-2 through 3.4.10-4 demonstrate that the District’s projected normal year water, single dry year, and multiple dry year comparison of water supply and demand would have sufficient water supplies available to serve the Project and District for the reasonable foreseeable future. Therefore, the impacts are considered to be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19c – Would the Project result in a determination by the wastewater treatment provider that serves or may serve the Project that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments? See Impact #3.4.19a, subsection Wastewater.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19d – Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
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Solid Waste
Project construction and operational activities that generate solid waste are handled, transported, and disposed of in accordance with applicable federal, State, and local regulations pertaining to municipal waste. The 1989 California Integrated Waste Management Act requires jurisdictions to attain specific waste diversion goals (AB 939, 2019). In addition, the California Solid Waste Reuse and Recycling Access Act of 1991, as amended, requires expanded or new development Projects to incorporate storage areas for recycling bins into the proposed Project design. Reuse and recycling of construction debris would reduce operating expenses and save valuable landfill space. With development in accordance with the General Plan, solid waste will continue to be handled, transported, and disposed of according to all applicable federal, State, and local regulations pertaining to municipal waste disposal. The City has a number of provisions that require or promote recycling and waste reduction, including the Construction and Demolition Recycling Ordinance that requires contractors to recycle construction and demolition debris. AB 939 requires the implementation of integrated waste management plans and mandates that local jurisdictions divert at least 50 percent of all solid waste. The recycling of construction and demolition materials is required for any City-issued building, relocation, or demolition permit that generates at least eight cubic yards of material by volume. The Project would generate solid waste during the construction and operation of the new residences. Common construction waste may include metals, masonry, plastic pipe, rocks, dirt, cardboard, or green waste related to land development.

The Consolidated Waste Management Authority (CWMA) is a joint powers authority that is recognized by the State and collectively manages the solid waste recycling and diversion activities for eight local area members, including Tulare County, Tulare, Visalia, Dinuba, Exeter, Farmersville, Lindsay, and Porterville (City of Visalia, 2014b). The CWMA has continued to improve its diversion rate as established by the State. The State recently changed its diversion calculation method from a percentage of waste diverted from the landfill to a calculation of pounds per person per day (PPD) that goes to the landfills. Most recent data shows that the CWMA has a base rate to achieve of 6.2 PPD, and the CWMA has been able to successfully achieve an annual PPD significantly lower than the benchmark established by the State. In 2008, the CWMA achieved a diversion rate of 5.2 PPD, and in 2009, it lowered it even further to 4.4PPD. Visalia waste collection efforts indicate that the city’s recycling rate calculated as PPD is consistently decreasing year to year and is consistently below the PPD calculated for the CWMA (note that there is no established benchmark for the City of Visalia so a determination cannot be made as to whether or not the City of Visalia is meeting State goals for diversion on its own).

Sunset Waste Systems provides solid waste collection in Visalia, and the County of Tulare Resource Management Agency provides disposal services at three landfills (the Visalia Disposal Site, northwest of Visalia; the Woodville Disposal Site, southeast of Tulare; and the Teapot Dome Disposal Site, southwest of Porterville). Solid Waste collection and disposal are in accordance with the Tulare County Integrated Waste Management Plan. Programs include household hazardous waste disposal, electronics recycling, tire recovery, yard waste recycling, metal recycling, and appliance recovery programs. According to the General Plan, 1131
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the three County landfills receive approximately 300,000 tons of waste per year, which is equivalent to about five pounds per person per day or one ton per county resident per year.

The Teapot Dome Disposal Site was in the closure process and set to cease accepting municipal solid waste on July 11, 2025, according to CalRecycle (CalRecycle, 2025a). The Visalia Disposal Site and the Woodville Disposal Site have a combined total remaining capacity of 18,810,624 cubic yards, with a maximum capacity of 31,750,866 cubic yards (CalRecyle, 2025b).

The Project proposes to develop a maximum of 662 units, with an average of 2.94 persons per household and an average of one ton of solid waste produced per county resident per year, the Project would produce approximately 1,946.28 tons annually. Given the available capacity at the Visalia Disposal Site and the Woodville Disposal Site, which have a combined total remaining capacity of 18,810,624 cubic yards, the additional solid waste generated by the proposed Project is not anticipated to cause the facility to exceed capacity. The proposed Project would comply with Cal Green, the City’s Construction and Demolition (C&D) Waste Management Guide, and with waste management policies and recommendations from the General Plan. The Project does not propose any new or expanded uses and is therefore not anticipated to result in increased generation of solid waste beyond what has already been analyzed in the City’s General Plan EIR. Because the City’s existing infrastructure has the capacity to accommodate the solid waste currently planned for UDB Tier II growth, and given the calculation performed above, the existing solid waste infrastructure has adequate capacity to serve the proposed Project. The Project would comply with any applicable city and state requirements for waste collection and attainment of local State solid waste reduction goals. Therefore, impacts would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.19e – Would the Project comply with federal, state and local statutes and regulations related to solid waste?
See Impact #3.4.19a, subsection Solid Waste and Impact #3.4.19d.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less-thanSignificant
Impact

No
Impact

3.4.20 - WILDFIRE
If located in or near state responsibility areas or
lands classified as very high fire hazard severity
zones, would the Project:
a. Substantially impair an adopted emergency
response plan or emergency evacuation
plan?
b. Due to slope, prevailing winds and other
factors, exacerbate wildfire risks and thereby
expose Project occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?
c. Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power
lines or other utilities) that may exacerbate
fire risk or that may result in temporary or
ongoing impacts to the environment?
d. Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
Discussion
Impact #3.4.20a – Would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
See Impact #3.4.9f regarding emergency response.

According to available data from Cal Fire, the Project site is within the Local Responsibility Area (LRA) of the Visalia Fire Department. The site is not within a Fire Hazard Severity Zones (FHSZ) categorized as Very High, High or Moderate, as the area is either urban or agricultural with a low risk of wildfire (Cal Fire, 2023). The Project is within the Planning Area of the 2025 Safety Element Update and 2023 Tulare County Multi-Jurisdictional Hazard Mitigation.

The Project site is adjacent to an existing mixed density subdivision to the west. Access for emergency vehicles to the site would be maintained throughout the construction period and would comply with any applicable requirements, such as an encroachment permit. The □ □ □
□ □ □
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Project would not interfere with any local or regional emergency response or evacuation plans and would not result in a substantial alteration to the adjacent area circulation system.

The City has established emergency response and evacuation plans based on the 2023 Tulare County Multi-Jurisdictional Hazard Mitigation and any other applicable plans. Impacts related to fire hazards and emergency response plans would be less than significant.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20b – Would the Project due to slope, prevailing winds and other factors, exacerbate wildfire risks and thereby expose Project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? See discussion in Impact #3.4.4g regarding wildland fire risk analysis. The Project site has relatively no slope or is historically known for prevailing winds. Therefore, the Project would have a less-than-significant impact on the pollutant concentrations from wildfire or the uncontrolled spread of wildfire.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20c – Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
See discussion in Impact #3.4.20a-b.

The Project proposes to develop public and private roadways, emergency water sources, electrical connections, and other utilities commonly found in a residential subdivision, all of which will be developed to local and state regulations.

The design of all proposed utilities will be subject to the review and approval of the City. This will ensure the viability of the utility infrastructure's ability for fire protection and suppression activities. Therefore, the impact would be considered less than significant with adherence to all applicable local and State regulations. 1134
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MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.

Impact #3.4.20d – Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
As discussed in Impact #3.4.7a(iii), the Project site is flat, and a small portion of the lower southwest area of the Project site is recognized by FEMA to be within the Zone AE for Special Flood Hazard Area (Figure 3-1).

Nevertheless, all structures within the Special Flood Hazard Area would be required to adhere to Visalia Municipal Code Chapter 15.60 (Floodplain Management Regulations) and California Building Code, which require compaction and soil tests, when applicable.

As discussed in Impact # 3.4.7b, erosion generated during construction would be controlled through implementation of a General Construction Permit from the State of California Central Valley RWQCB. Under the NPDES, the preparation and implementation of a SWPPP are required for construction activities that would disturb an area of one acre or more. A SWPPP must identify potential sources of erosion or sedimentation and identify and implement BMPs that ensure reduced erosion.

Given Project adherence to local and state regulations that govern Flood Hazard Areas and erosion control, the Project would have a less-than-significant impact.

MITIGATION MEASURE(S)
No mitigation is required.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant.
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Discussion
Impact #3.4.21a – Does the Project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
As evaluated in this IS/MND, the proposed Project would not substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or animal community; reduce the number or restrict the range of an endangered, rare, or

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated

Less than
Significant
Impact

No
Impact

3.4.21 - MANDATORY FINDINGS OF

SIGNIFICANCE
a. Does the Project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below
self-sustaining levels, threaten to eliminate
a plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal, or
eliminate important examples of the major
periods of California history or prehistory?
b. Does the Project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
Project are significant when viewed in
connection with the effects of past Projects,
the effects of other current Projects and the
effects of probable future Projects.)
c. Does the Project have environmental effects
that would cause substantial adverse effects
on human beings, either directly or
indirectly?
□ □ □
□ □ □
□ □ □
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threatened species; or eliminate important examples of the major periods of California history or prehistory. With implementation of the Mitigation Measures BIO-1 through BIO-9 and CUL-1 and CUL-2, the proposed Project would not have the potential to degrade the quality of the environment, significantly impact biological resources, or eliminate important examples of the major periods of California's history or prehistory. Therefore, with the following mitigation measures, the Project would have a less-than-significant impact.

MITIGATION MEASURE(S)
Implement MM BIO-1 through BIO-9 and MM CUL-1 and MM CUL-2.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.21b - Does the Project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a Project are significant when viewed in connection with the effects of past Projects, the effects of other current Projects and the effects of probable future Projects.)? As described in the impact analyses in Impact Sections 3.4.1 through 3.4.21 of this IS/MND, any potentially significant impacts of the proposed Project would be reduced to a less-thansignificant level following the incorporation of the mitigation measures listed. The proposed Project would not otherwise combine with the impacts of related development to add considerably to any cumulative impacts in the region. With the implementation of MM AG-1 and AG-2, BIO-1 through BIO-9, CUL-1 and CUL-2, GEO-1, HAZ-1, TRA-1 and TRA-2, the proposed Project would not have impacts that are individually limited but cumulatively considerable. Therefore, the Project would have a less than cumulatively considerable impact with mitigation incorporated.

MITIGATION MEASURE(S)
Implement MM AG-1 and MM AG-2, MM BIO-1 through MM BIO-9, MM CUL-1 and MM CUL2, MM GEO-1, MM HAZ-1, MM TRA-1 and MM TRA-2.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated.

Impact #3.4.21c - Does the Project have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly? All of the Project’s impacts, both direct and indirect, that are attributable to the Project were identified and mitigated. Implementation of Project Mitigation Measures AG-1 and AG-2, BIO-1 through BIO-9, CUL-1 and CUL-2, GEO-1, HAZ-1, TRA-1 and TRA-2 will substantially reduce or eliminate the impacts of the Project. Therefore, the proposed Project would not either directly or indirectly cause substantial adverse effects on human beings because all 1137
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potentially adverse direct impacts of the proposed Project are identified as having no impact, less-than-significant impact, or less-than-significant impact with mitigation.

MITIGATION MEASURE(S)
Implement MM AG-1 and MM AG-2, MM BIO-1 through MM BIO-9, MM CUL-1 and MM CUL2, MM GEO-1, MM HAZ-1, MM TRA-1 and MM TRA-2.

LEVEL OF SIGNIFICANCE
Impacts would be less than significant with mitigation incorporated. 1138
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SECTION 4 - LIST OF PREPARERS

4.1 - Lead Agency – City of Visalia
• Jarred Olsen, AICP – Principal Planner

4.2 - QK
• Jaymie Brauer – Project Manager/QAQC
• Bella Hedtke – Lead Author
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References

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SECTION 5 - REFERENCES
Cal Fire. (2023, June 15). Tulare County State Responsibility Area Fire Hazard Severity Zones. Retrieved January 2025, from https://34c031f8-c9fd-4018-8c5a4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/what-wedo/community-wildfire-preparedness-and-mitigation/fire-hazard-severityzones/fire-hazard-severity-zones-map-2022/fire-hazard-severity-zones-maps2022-file CalGEM. (2025). Well Finder. Retrieved June 2025, from
https://maps.conservation.ca.gov/doggr/wellfinder/
California Department of Conservation. (2022). Farmland Mapping and Monitoring Program. Retrieved from Important Farmland Finder:
https://maps.conservation.ca.gov/DLRP/CIFF/
California Department of Toxic Substances Control. (2025, August 25). California Department of Toxic Substances Control, Envirorstor. Retrieved January 2025, from California Department of Toxic Substances Control, Envirorstor:
https://www.envirostor.dtsc.ca.gov/public/map/
CalRecycle. (2025a, July 7). SWIS Facility/Site Inspection Details Teapot Dome Disposal Site (54-AA-0004). Retrieved from
https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/387611?siteID =3834
CalRecyle. (2025b, August). CalRecycle. Retrieved from Solid Waste Information System (SWIS) >> Sites: https://www2.calrecycle.ca.gov/SolidWaste/Site/Search City of Visalia . (2010). Visalia Waterway & Trail Master Plan.

City of Visalia. (2013). Climate Action Plan.

City of Visalia. (2014a). Visalia General Plan Update.

City of Visalia. (2014b, January). General Plan Draft Environmental Impact Report. Retrieved from https://www.visalia.city/civicax/filebank/blobdload.aspx?BlobID=30499 City of Visalia. (2024). 2023-2031 Housing Element Update.

City of Visalia. (2025a, February 18). City of Visalia General Plan - Safety Element. Retrieved from https://www.visalia.city/depts/community_development/planning/gp.asp City of Visalia. (2025b). American Legal Publishing, Visalia, CA Municipal Code. Retrieved from https://codelibrary.amlegal.com/codes/visalia/latest/visalia_ca/0-0-0-22201 City of Visalia. (2025c). VMT Threshold and Implementation Guidelines. 1140
References

Clements Ranch TTM No. 5606 May 2026
City of Visalia Page 5-2
County of Tulare. (2023). Tulare County Multi-Jurisdictional Local Hazard Mitigation Plan.

ESRI, Mark Gilbert. (2021, July 13). Wildland Urban Interface. Retrieved from https://www.arcgis.com/home/item.html?id=a4985d64969743db8feddf01c96c94 35 JLB Traffic Engineering, Inc. (2026). Traffic Impact Analysis Clements Ranch.

QK. (2025a). Air Quality Impact Analysis (AQIA)- Clements Ranch TTM 5606.

QK. (2025b). Biological Resource Evaluation for Clements Ranch Project.

QK. (2025c). Cultural Resources Technical Memo- Clement Ranch Project. Techincal Memorandum.

Tulare County. (2012). Tulare County Airport Land Use Compatability Plan.

U.S. Fire Administration. (2022, June 8). What is the WUI? Retrieved from https://www.usfa.fema.gov/wui/what-is-thewui/#:~:text=Share%20on:,Institute%20of%20Standards%20and%20Technology United States Environmental Protection Agency. (2025, August 25). UST Finder: National Web Map of Underground Storage Tanks. Retrieved from
https://epa.maps.arcgis.com/apps/webappviewer/index.html?id=b03763d3f2754 461adf86f121345d7bc
United States Geological Survey. (2025, February 3). U.S. Landslide Inventory and Susceptibility Map . Retrieved from https://www.usgs.gov/tools/us-landslideinventory-and-susceptibility-map Visalia Police Department. (2023). 2023 Annual Report.

Visalia Unified School District. (2024, November 19). Visalia Unified School District Board Meetings. Retrieved from Agenda Item 11.1 Facilities Plan Short Term Options:
https://vusd.diligent.community/Portal/MeetingInformation.aspx?Org=Cal&Id=16 6 Visalia Unified School District. (2025, August 22). School Boundaries GIS Map. Retrieved from
https://visaliausd.maps.arcgis.com/apps/webappviewer/index.html?id=ecffdf4f12 1045aca8f13dc0fc1d30dd
VRPA Technologies, Inc. (2026). Clements Ranch Vehicles Miles Traveled (VMT) Analysis.

Woodard & Curran. (2026). Clements Ranch Water Supply Assessment. 1141
Mitigation Monitoring and Reporting Program

Clements Ranch TTM No. 5606 May 2026
City of Visalia Page 6-1
SECTION 6 - MITIGATION MONITORING AND REPORTING PROGRAM 1142
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Aesthetics
No Mitigation required.

Agriculture and Forest Resources
#1 AG-1: Prior to the issuance of grading or building permits, the Project proponent shall mitigate impacts for loss of up to 78 acres of Prime Farmland on the Project site at a 1:1 ratio. The amount of land requiring mitigation shall correspond to the amount of land associated with the issuance of the grading or building permit, or for residential land associated with a subdivision map, the amount of land associated with the subdivision map. The Project proponent shall implement one or more of the following measures to mitigate the loss: Payment of in-lieu fees, mitigation banks, fee title acquisition, and/or conservation easements on land(s) within the Southern San Joaquin Valley of California, specifically within Kern County, Tulare County, Kings County, Fresno County, or Madera County. The City shall require, at a minimum, evidence that the preserved land has an adequate water supply, agricultural zoning, evidence of land encumbrance documentation, documentation that the
easement/regulations are permanent and monitored, and documentation that the mitigation strategy is appropriately endowed. This mitigation shall be verified by the City prior to issuance of grading or building permits. The Project proponent, at its election, may mitigate for the loss of agricultural land through compliance with the Agricultural Mitigation Program that is adopted by the City in lieu of mitigating on a 1:1 ratio.

Prior to the
issuance of
grading or
building
permits
Project developer and
Lead Agency
#2 AG-2: In order to reduce potential conflicts between urban and agricultural uses, the following measures shall be implemented:
a. Potential residents shall be notified about possible exposure to agricultural chemicals at the time of purchase/lease of property within the development.

Prior to Final
Map Approval
Project developer and
Lead Agency
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b. A Right-to-Farm Covenant shall be recorded on each residential tract map or be made a condition of each tract map to protect continued agricultural practices in the area.
c. Potential residents shall be informed of the Right-to-Farm Covenant at the time of purchase/lease of property within the development.

Air Quality
No Mitigation required.

Biological Resources
#3 BIO-1: Prior to the issuance of grading permits or ground disturbance, a preconstruction clearance survey of the Project footprint shall be conducted for special-status wildlife species and nesting migratory birds and raptors. The survey shall occur no less than 14 days prior to the start of construction activities. If construction is delayed beyond 30 days from the time of the survey or there is a lapse in construction of more than 30 days, then another survey shall be conducted. The survey shall be conducted by a biologist with adequate training and prior experience conducting surveys for special-status wildlife species. If no special-status species are observed, no further action is warranted.

If dens or burrows that could support special-status species and/or nesting birds and raptors are discovered during the pre-construction survey, appropriate avoidance buffers shall be established. If no special-status species are observed on or near the Project site, no further surveys are required. A report outlining the results of the preconstruction survey shall be submitted to the lead agency as evidence of compliance.
.

Within 14 days
prior to any
constructionrelated
activities.

Project developer and
Lead Agency
Steps to Compliance:

A. A qualified biologist shall be responsible for a
preconstruction survey.

B. If necessary, the qualified biologist shall contact
CDFW and USFWS to determine next steps.

C. If necessary, the qualified biologist shall implement next steps in consultation with the wildlife agencies.

Next steps may include implementing avoidance
buffers.

D. The qualified biologist shall prepare a brief report to be submitted to the wildlife agencies within 5 days of
completion of the preconstruction survey.

E. Lead Agency shall verify compliance.
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#4 BIO-2: If construction is planned during the nesting season for migratory birds (February 15 to August 31) and nesting birds are identified during the preconstruction survey, an active Swainson’s hawk nest shall be avoided by 0.5 miles, other raptor nests shall be avoided by 500 feet, and all other migratory bird nests shall be avoided by 250 feet. Avoidance buffers may be reduced if a qualified biological monitor determines that encroachment into the buffer area is not affecting nest building, the rearing of young, or otherwise affecting the breeding behaviors of the resident birds. Because nesting birds can establish new nests or produce a second or even third clutch at any time during the nesting season, nesting bird surveys shall be repeated every 30 days as construction activities are occurring throughout the nesting season. If no nesting birds are observed on or near the Project site, no further surveys are required.

Prior to and
during
construction
activities
occurring
between
February 15
and August 31
Project developer and
Lead Agency
Steps to Compliance:

A. If active nests are found during pre-construction
surveys required in MM BIO-1 or at any time
during construction of the Project, an avoidance
buffer range may be required. Active Swainson’s
hawk nests shall be avoided by 0.5 miles, other
raptor nests shall be avoided by 500 feet, and all
other migratory bird nests shall be avoided by 250
feet.

B. Nesting bird surveys shall be repeated every 30
days as construction activities are occurring
throughout the nesting season.

C. Work is to continue under the approval and
guidance of a qualified biologist.
#5 BIO-3: A Worker Environmental Awareness Program shall be developed and implemented for all personnel who could access the site prior to commencing any disturbance activities. The program shall consist of an on-site or center presentation that will describe the locations and types of sensitive plant, wildlife, and sensitive natural communities (collectively, “Biological Resources”) on and near the site, an overview of the laws and regulations Prior to
commencing
any disturbance
activities or
within one
week of being
Project developer and
Lead Agency

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governing the protection of Biological Resources, the reasons for protecting the Biological Resources, the specific protection and avoidance measures that are applicable to the site, and the identity of designated points of contact should questions or issues arise, including the qualified biologist. The program shall provide training to recognize, avoid, and report to applicable qualified biologists any Biological Resources on the site.
a. The Worker Environmental Awareness Program shall emphasize the need to avoid contact with on-site wildlife and avoid entry into areas where Biological Resources have been identified based on predisturbance field surveys, and to implement the buffer avoidance or other protection measures established by the United States Fish and Wildlife Service (USFWS) shall be identified by the California Department of Fish and Wildlife (CDFW) or required by the Biological Resource mitigation measures. The training shall emphasize the importance of not feeding or domesticating wildlife and the need to avoid any trash, micro-trash, or potential food waste on-site, except in animalproof containers emptied daily, to avoid attracting or causing adverse impacts to special-status wildlife.
b. All on-site personnel must sign a statement verifying that they have completed the Worker Environmental Awareness Program and that they understand and agree to implement the biological requirements for the worksite. If signed employee statements are not available, documentation may be provided by Worker Environmental Awareness Program training records, which shall be kept by the applicant for a minimum of five years. Each applicant shall maintain a list of all persons who have completed the training program and shall provide the list to the County or to State and federal wildlife agency representatives upon request.
deployed to the
Project site
Steps to Compliance:

A. A Worker Environmental Awareness Training and
Education Program will be developed and
presented to all construction works prior to them
starting work on the site.

B. A sign-in sheet will be submitted to the lead
agency as evidence of compliance.

C. A copy of the training will be maintained on the
Project site throughout construction.
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#6 BIO-4: If protected or special-status species are identified on the Project site during pre-construction surveys, protective buffers shall be used, where effective in the opinion of the qualified biologist. These measures are created to avoid any unauthorized incidental take of these species and to minimize any incidental take. Protective buffers shall be delineated using brightly colored stakes and/or flagging or similar materials and remain until construction activities are complete, at which time of completion, the buffers must be removed. Protective buffers shall be established around active dens and/or burrows of special-status animal species or populations of special-status plant species to avoid unauthorized take of Protected Species as listed in the table below. The protective buffer distance shall be increased if required to avoid unauthorized incidental take of any Protected Species as determined by a qualified biologist. Protective buffer distances and other avoidance measures that may be implemented to avoid impacts to Protected Species or Sensitive Species must be consistent with the United States Fish and Wildlife Service and/or the California Department of Fish and Wildlife requirements and shall be implemented and overseen by a qualified biologist.

Disturbance Buffers for Sensitive Resources
Sensitive Resource Buffer Zone from Disturbance (feet)
Potential San Joaquin kit fox
den 50
Known San Joaquin kit fox den 100
Natal San Joaquin kit fox den 500
Atypical San Joaquin kit fox den 50
Rodent burrows 50
Special-status bird species'
active nests
500 feet to 0.5 miles depending on species
and sight line
Prior to and
during
construction
Project developer and
Lead Agency

Steps to Compliance:

A. If protected or special-status species are found
during pre-construction surveys required in MM
BIO-1 or at any time during construction of the
Project, an avoidance buffer range may be
required. Protective buffers shall be established
around active dens and/or burrows of specialstatus animal species or populations of specialstatus plant species to avoid unauthorized take of Protected Species as listed in the table list in this
mitigation measure.

B. Work is to continue under approval and guidance
of qualified biologist.
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American badger: Nonmaternity dens 50
American badger: Maternity
dens 200
#7 BIO-5: If Project activities must occur during the Swainson’s hawk nesting season (February 15 to September 31), pre-activity surveys shall be conducted for Swainson’s hawk nests in accordance with the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (CDFG 2000). The surveys shall be conducted on the Project site plus a 0.5-mile buffer. To meet the minimum level of protection for the species, surveys shall be conducted during at least two survey periods prior to the start of construction.

The survey shall be conducted in accordance with the methodology outlined in existing protocols and should be phased with the construction of the Project.

If no Swainson’s hawk nests are found, no further action is required.

Prior to and
during
construction
activities
between
February 15
and September
31 Project developer and
Lead Agency
Steps to Compliance:

A. The preconstruction survey required in MM BIO-1
shall be performed in compliance with
methodologies and resources identified in this
mitigation measure for Swainson hawk nests.

B. If a Swainson’s hawk nest is discovered during the
preconstruction survey required in MM BIO-1, an
avoidance buffer range may be required, with the
avoidance buffer from any specific nest being
determined by a qualified biologist and existing
protocols.

C. Work is to continue under the approval and
guidance of a qualified biologist.
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#8 BIO-6: If an active Swainson’s hawk nest is discovered at any time within 0.5 miles of active construction, a qualified biologist shall complete an assessment of the potential for current construction activities to impact the nest. The assessment shall consider the type of construction activities, the location of construction relative to the nest, the visibility of construction activities from the nest location, and other existing disturbances in the area that are not related to construction activities of this Project. Based on this assessment, the biologist shall determine if construction activities can proceed and the level of nest monitoring required. Construction activities shall not occur within 500 feet of an active nest, but depending upon conditions at the site, this distance may be reduced. Full-time monitoring to evaluate the effects of construction activities on nesting Swainson’s hawks may be required. The qualified biologist shall have the authority to stop work if it is determined that Project construction is disturbing the nest. These buffers may need to be increased depending on the sensitivity of the nesting Swainson’s hawk to disturbances and at the discretion of the qualified biologist.

Prior to and
during
construction
Project developer and
Lead Agency
Steps to Compliance:

A. If an active Swainson’s hawk nest is found at any
time during construction of the Project, an
avoidance buffer range may be required, with the
avoidance buffer from any specific nest being
determined by a qualified biologist and existing
protocols. Construction activities shall not occur
within 500 feet of an active nest.

B. Work is to continue under the approval and
guidance of a qualified biologist.
#9 BIO-7: If burrows that could support the burrowing owl species are discovered during the pre-construction clearance survey conducted under Measure BIO-1, the avoidance buffers outlined below shall be established, and burrow monitoring shall be conducted in accordance with the California Department of Fish and Game (CDFG) Staff Report on Burrowing Owl Mitigation (CDFG 2012).

No work would occur within these buffers. If occupied burrowing owl burrows cannot be avoided by the appropriate buffer below, an ITP issued by the CDFW under the California Endangered Species Act (CESA) to authorize "take" that is incidental to an otherwise lawful activity, may be required before any work within the buffer.

Location Time of Year Level of Disturbance
Low Med High
Prior to and
during
construction
Project developer and
Lead Agency
Steps to Compliance:

A. If burrows that could support the burrowing owl
species are found during the preconstruction
survey required in BIO-1 or at any time during
construction of the Project, an avoidance buffer
range may be required, with the avoidance buffer
from any specific burrow being determined by a
qualified biologist and existing protocols.

I I
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Nesting sites April 1 -Aug 15 200 m* 500 m 500 m
Nesting sites Aug 16 – Oct 15 200 m 200 m 500 m
Nesting sites Oct 16- Mar 31 50 m 100 m 500 m
*Meters (m)
Protective buffers shall be established as listed in
the table in this mitigation measure.

B. Work is to continue under the approval and
guidance of a qualified biologist.
#10 BIO-8: Occupied American badger dens detected during pre-disturbance surveys shall be flagged, and ground-disturbing activities shall be avoided within 50 feet of the den. Maternity dens shall be avoided, and a minimum 200- foot buffer from disturbance shall be maintained during the pup-rearing season (February 15 through July 1). Maternity dens shall be avoided to the maximum extent feasible in the opinion of a qualified biologist. If an active maternity den is proposed to be disturbed, the qualified biologist shall consult with the CDFW to identify any appropriate additional minimization measures that the qualified biologist determines, with the wildlife agencies, can actually be implemented based on field conditions. All such measures shall be implemented for Project activities.

Prior to and
during
construction
Project developer and
Lead Agency

Steps to Compliance:

A. If dens that could support the American badger
species are found during the preconstruction
survey required in MM BIO-1 or at any time during
construction of the Project, an avoidance buffer
range may be required. Ground-disturbing
activities are avoided within 50 feet of the den.

Maternity dens shall be avoided, and a minimum
200-foot buffer from disturbance shall be
maintained during the pup-rearing season
(February 15 through July 1.

B. Work is to continue under the approval and
guidance of a qualified biologist.

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#11 BIO-9: The following additional measures shall be implemented during construction to avoid and minimize potential significant adverse impacts to Protected and Sensitive Species:
a. All vehicles shall observe a 15-mile-per-hour speed limit in all areas of disturbance and on unpaved roads unless otherwise posted. Off-road traffic outside of designated access routes is prohibited. Speed limit signs shall be posted in visible locations at the point of site entry and at regular intervals on all unpaved access roads.
b. All disturbance activities, except emergency situations or drilling that may require continuous operations, shall only occur during daylight hours. Nighttime disturbance activity for drilling purposes shall use directed lighting and shielding methods and comply with applicable lighting mitigation measures.
c. All food-related trash items and all forms of micro trash, such as wrappers, cans, bottles, bottle tops, and food scraps, shall be disposed of in closed, animal-proof containers and removed daily from the site. d. Excavations, spoil piles, access roadways, and parking and staging areas shall be subject to dust control as set forth in the dust control mitigation measures.
e. The use of herbicides for vegetation control shall be restricted to those approved by the United States Fish and Wildlife Service and the California Department of Fish and Wildlife. No rodenticides shall be used on any site unless approved by the United States Fish and Wildlife Service and the California Department of Fish and Wildlife, and shall observe label and other restrictions mandated by the United States Environmental Protection Agency, California Department of Food and Agriculture, and State and federal laws and regulations. For split estates, no herbicides for vegetation control may occur in Tier 2 areas without surface owner approval.

Prior to and
during
construction
Project developer and
Lead Agency
Steps to Compliance:

A. The Project proponent and/or developer shall
ensure compliance with applicable construction
rules and regulations, including but not limited to,
those set forth in the mitigation.
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f. No plants or wildlife shall be collected, taken, or removed from the site or any adjacent locations except as necessary for Project-related vegetation removal or wildlife relocation by a qualified biologist and subject to all applicable permits and authorizations.
g. All open trenches or excavations shall be covered at the end of each workday to prevent wildlife entrapment. If an excavation is too large to cover, escape ramps shall be installed at an incline ratio of no greater than 2:1. All trenches and pipes shall be inspected for the presence of wildlife each day prior to the commencement of work.
h. To enable San Joaquin kit foxes and other wildlife to pass through the Project site, any perimeter fencing shall include a four- to eight-inch opening between the fence mesh and the ground, or the fence shall be raised four inches above the ground except for blunt-nosed leopard lizard exclusion fencing. The bottom of the fence fabric shall be knuckled (wrapped back to form a smooth edge) to protect wildlife. i. All vertical tubes used in Project construction and chain link fencing poles shall be temporarily or permanently capped to avoid the entrapment and death of special-status wildlife and birds. All pipes 1.5 inches or greater in diameter stored overnight on a Project location must have end caps or other physical barriers that prevent wildlife from entering the pipe.
j. All dead or injured special-status wildlife shall be left in place and reported to the United States Fish and Wildlife Service and the California Department of Fish and Wildlife within 48 hours of discovery for rescue or salvage. Discovery of State or federal listed species that are injured or dead shall also be managed consistent with regulatory requirements, including being reported immediately via telephone and within 24 hours in writing, and with a copy to the lead agency.
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k. During pre-construction surveys, the qualified biologist shall delineate previously disturbed areas to be used by the applicant to minimize the amount of new disturbance.
l. No vehicles or construction equipment shall be parked within a wetland or waterbody/dry wash.
m. Tracked vehicles and other construction equipment must be washed or maintained to be weed-free prior to entering and working within areas of a new disturbance.
n. All washing of trucks, paint, equipment, or similar activities should occur in areas where runoff is fully contained for collection and off-site disposal. Wash water may not be discharged from the site and shall be located at least 100 feet from any water body or sensitive Biological Resources.
o. Locate all extra work areas (such as staging areas and additional spoil storage areas) at least 50 feet away from wetland boundaries or waterbody, except where the adjacent upland consists of cultivated or rotated cropland or other disturbed land.
p. All areas that must be avoided as a result of the pre-disturbance surveys and areas where new disturbance will occur shall be clearly delineated by fencing or staking and flagging and/or rope or cord. q. No pets shall be allowed on any site.
r. No smoking may occur except in designated areas.

Biological Resources
#12 MM BIO-10: Prior to the issuance of any grading or building permit, the Project proponent/developer shall conduct a delineation of the Tulare Irrigation Canal and prepare an Aquatic Resources Delineation Report (ARDR). The ARDR shall be submitted with a formal notification to the US Army Corps of Engineers (ACOE), Water Resources Control Board (SWRCB), and California Department of Fish and Wildlife (CDFW). If no comments or requests for additional Prior to
issuance of
grading or
building
permits
Project developer and
Lead Agency
Steps to Compliance:
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permitting are received by the agencies, no further action is necessary. A copy of all correspondence shall be submitted to the lead agency.

If a regulatory agency comments or requests additional permitting, the following actions may be taken. A copy of all correspondence and subsequent permitting and/or reports shall be made available to the Lead Agency. The report shall include information as shown below, as a plan if necessary, and shall outline compliance with the following:
a. Delineation of all jurisdictional features at the project site. Potential jurisdictional features within the project boundary identified in the jurisdictional delineation report may be shown in plan form. b. If the Project has a potential to directly or indirectly impact jurisdictional aquatic resources, a formal aquatic resource delineation of these areas shall be performed by a qualified professional to determine the extent of agency jurisdiction and permits/authorizations from the appropriate regulating agencies (Central Valley Regional Water Quality Control Board (RWQCB), CDFW and US Army Corps of Engineers (USACE) shall be obtained prior to disturbance to jurisdictional features.

If it is determined that drainage is jurisdictional and cannot be avoided, the Project proponent shall obtain a Section 401 Water Quality Certification from the RWQCB, a Section 404 permit from USACE, and a Lake and Streambed Alteration Agreement under Section 1602 from the CDFW, if required, prior to impacting any waters.

As part of these authorizations, compensatory mitigation may be required by the regulating agencies to offset the loss of aquatic resources. If so, and as part of the permit application process, a qualified professional shall draft a Mitigation and Monitoring Plan to address implementation and monitoring requirements under the permit to ensure that the Project would result in no net loss of habitat functions and values. The Plan shall contain, at a minimum, mitigation goals and objectives, mitigation location, a discussion of actions to be • A delineation of the Tulare Irrigation Canal will be
conducted by a qualified biologist.
• An Aquatic Resources Delineation Report (ARDR)
will be prepared and submitted to the appropriate
regulatory agencies for comment.
• Implementation of the outlined requirements will
be completed.
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implemented to mitigate the impact, monitoring methods and performance criteria, extent of monitoring to be conducted, actions to be taken in the event that the mitigation is not successful, and reporting requirements. The Plan shall be approved by the appropriate regulating agencies, and compensatory mitigation shall take place either on-site or at an appropriate off-site location.
c. Any material/spoils generated from project activities containing hazardous materials shall be located away from jurisdictional areas or special-status habitat and protected from storm water run-off using temporary perimeter sediment barriers such as berms, silt fences, fiber rolls, covers, sand/gravel bags, and straw bale barriers, as appropriate.

Protection measures should follow project-specific criteria as developed in a Stormwater Pollution Prevention and Protection Plan (SWPPP). d. Equipment containing hazardous liquid materials shall be stored on impervious surfaces or plastic ground covers to prevent any spills or leakage from contaminating the ground and at least 50 feet outside the delineated boundary of jurisdictional water features.
e. Any spillage of material shall be stopped if it can be done safely. The contaminated area shall be cleaned, and any contaminated materials properly disposed. For all spills, the project foreman or designated environmental representative shall be notified.

Cultural Resources
#13 CUL-1: If prehistoric or historic-era cultural materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt During
construction
Project developer and
Lead Agency
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until a qualified archaeologist can evaluate the find and make recommendations.

Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock, as well as historic resources such as glass, metal, wood, brick, or structural remnants. If the qualified archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from Project implementation.

These additional studies may include avoidance, testing, and evaluation, or data recovery excavation.

Steps to Compliance:

A. If necessary, work shall cease and the project
proponent shall retain a qualified archaeologist to
assess finds and recommended procedures.

B. The qualified archaeologist and/or paleontologist
shall assess the significance of the find and determine next steps.

C. A copy of the additional studies shall be submitted to the Lead Agency to verify compliance.
#14 CUL-2: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code. The specific protocol, guidelines, and channels of communication outlined by the Native American Heritage Commission, in accordance with Section 7050.5 of the Health and Safety Code, Section 5097.98 of the Public Resources Code (Chapter 1492, Statutes of 1982, Senate Bill 297), and Senate Bill 447 (Chapter 44, Statutes of 1987), shall be followed. Section 7050.05(c) shall guide the potential Native American involvement, in the event of a discovery of human remains, at the direction of the county coroner.

During
construction
Project developer and
Lead Agency
Steps to Compliance:

A. If necessary, work shall cease and the project
proponent shall retain a qualified archaeologist to
assess finds and recommended procedures.

B. The qualified archaeologist and/or paleontologist
shall assess the significance of the find and
determine next steps.

C. The Lead Agency shall verify compliance.

Energy
No Mitigation required.

Geology and Soils
#15 GEO-1: If any paleontological resources are encountered during grounddisturbance activities, all work within 25 feet of the find shall halt until a qualified paleontologist, as defined by the Society of Vertebrate Paleontology During
construction
Project developer and
Lead Agency
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Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources, can evaluate the find and make recommendations regarding treatment. Paleontological resource materials may include resources such as fossils, plant impressions, or animal tracks preserved in rock. The qualified paleontologist shall contact the Natural History Museum of Los Angeles County or another appropriate facility regarding any discoveries of paleontological resources.

If the qualified paleontologist determines that the discovery represents a potentially significant paleontological resource, additional investigations and fossil recovery may be required to mitigate adverse impacts from Project implementation. If avoidance is not feasible, the paleontological resources shall be evaluated for their significance. If the resources are not significant, avoidance is not necessary. If the resources are significant, they shall be avoided to ensure no adverse effects, or such effects must be mitigated. Construction in that area shall not resume until the resource-appropriate measures are recommended or the materials are determined to be less than significant. If the resource is significant and fossil recovery is the identified form of treatment, then the fossil shall be deposited in an accredited and permanent scientific institution. Copies of all correspondence and reports shall be submitted to the Lead Agency.

Steps to Compliance:

A. In the event that paleontological resources are
encountered during ground disturbance activities, all
work within 25 feet shall halt.

B. If required, the project proponent shall contact the qualified paleontologist to assess the find.

C. The operator shall include a standard inadvertent
discovery clause in every construction contract to
inform contractors of this requirement.

D. The Lead Agency shall verify compliance with the
mitigation measure.

Greenhouse Gas Emissions
No Mitigation required.

Hazardous Materials
#16 HAZ-1: In the event that unknown underground storage tank(s) or a septic system are uncovered or damaged during excavation or grading activities, all work in that area shall cease. The State Water Resources Control Board (SWRCB) and the Tulare County Environmental Health Division shall be contacted to determine what appropriate remediation may be required and to identify the During
construction
Project developer and
Lead Agency

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Draft Mitigation Measure and Reporting Program May 2026 Clements Ranch TTM No. 5606 Page 16 of 18
Mitigation Monitoring Program
Impact Mitigation Measure Time Frame for
Implementation
Responsible
Monitoring Agency Date Initials
appropriate requirements and approvals. A report of all communication and the determination made by the SWRCB and the County Health Division shall be submitted to the City.

Steps to Compliance:

A. In the event unknown underground storage tank(s)
are uncovered or damaged during excavation or
grading activities, all work in that area shall cease.

B. The Lead Agency, State Water Resources Control
Board, and Tulare County Environmental Health
Division shall be contacted to determine appropriate
remediation and to identify necessary permits and
approvals.

C. All correspondence and determinations made by the
SWRCB and County Health Division shall be provided
to the Lead Agency to provide evidence of
compliance.

Hydrology and Water Quality
No mitigation required.

Land Use and Planning
No Mitigation required.

Mineral Resources
No Mitigation required.

Noise
No Mitigation required.

Population and Housing
No Mitigation required.
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Draft Mitigation Measure and Reporting Program May 2026 Clements Ranch TTM No. 5606 Page 17 of 18
Mitigation Monitoring Program
Impact Mitigation Measure Time Frame for
Implementation
Responsible
Monitoring Agency Date Initials
Public Services
No Mitigation required.

Recreation
No Mitigation required.

Traffic and Transportation
#17 MM TRA-1: Prior to the issuance of building permits, the Project applicant/developer responsible for the construction of the Single-Family Residential Development will pay their pro-rate fair share percentage of 3.1 percent.

Prior to
issuance of
building permit
Project
proponent/developer,
Lead agency
Steps to Compliance:

A. The Project proponent shall pay their fair share
cost for intersection improvements and roadway
segment improvements as indicated in the
Mitigation Measure prior to issuance of building
permits.
#18 MM TRA-2: Prior to the issuance of building permits, the Project applicant/developer responsible for the construction of the Multi-Family Residential Development will pay their pro-rata fair share percentage of 2.4 percent. If at the time of development of the Multi-Family phase, the unit count is less than 375, the developer may submit a revised TIA showing the appropriate pro-rate fair share percentage for the reduced number of units.

Prior to
issuance of
building permit
Project
proponent/developer,
Lead agency

Steps to Compliance:

A. The Project proponent shall pay their fair share
cost for intersection improvements and roadway
segment improvements as indicated in the
Mitigation Measure prior to issuance of building
permits.

Tribal Cultural Resources
Implementation of MM CUL-1 and MM CUL-2.
1159
Draft Mitigation Measure and Reporting Program May 2026 Clements Ranch TTM No. 5606 Page 18 of 18
Mitigation Monitoring Program
Impact Mitigation Measure Time Frame for
Implementation
Responsible
Monitoring Agency Date Initials
Utilities and Service Systems
No Mitigation required.

Wildfire
No Mitigation required.
1160

APPENDIX A

AIR QUALITY IMPACT ANALYSIS (AQIA)
1161

AIR QUALITY IMPACT ANALYSIS

CLEMENTS RANCH TENTATIVE TRACT MAP
NO. 5606

OCTOBER 2025

VISALIA
1162

AIR QUALITY IMPACT ANALYSIS

CLEMENTS RANCH CLEMENTS RANCH
TENTATIVE TRACT MAP NO. 5606

PROJECT
Prepared for:

D.R. Horton
419 W. Murray Avenue
Visalia, CA 93291
Contact Person: Aman Narwal
Phone: (559) 636-9850
Consultant:
5080 California Avenue, Suite 220
Bakersfield, CA 93309
Contact: Jaymie Brauer
Phone: (661) 616-2600
October 2025
© Copyright by Quad Knopf, Inc.

Unauthorized use prohibited.

Project #240208
1163
Clements Ranch Residential Project – Air Quality Impact Analysis October 2025 Page i
Table of Contents
List of Acronyms and Abbreviations ....................................................................................................... iv SECTION 1 - Executive Summary .......................................................................................................... 1-1 SECTION 2 - Introduction ........................................................................................................................ 2-1

2.1 - Purpose .......................................................................................................................................................2-1

2.2 - General Project Description................................................................................................................2-1 SECTION 3 - Setting ................................................................................................................................... 3-1

3.1 - Air Quality Standards ............................................................................................................................3-1

3.2 - Existing Air Quality.................................................................................................................................3-5

3.2.1 - Ozone (O3) ...............................................................................................................................3-6

3.2.2 - Suspended Particulate Matter (PM10 and PM2.5) ......................................................3-6

3.2.3 - Carbon Monoxide (CO) .......................................................................................................3-6

3.2.4 - Nitrogen Dioxide (NO2) and Hydrocarbons................................................................3-7

3.2.5 - Sulfur Dioxide .........................................................................................................................3-7

3.2.6 - Lead (Pb) and Suspended Sulfate...................................................................................3-8

3.3 - Climate.........................................................................................................................................................3-8

3.4 - Climate Change and Greenhouse Gases..........................................................................................3-9

3.4.1 - Global Climate Change.........................................................................................................3-9

3.4.2 - Effects of Global Climate Change..................................................................................3-12

3.4.3 - Global Climate Change Regulatory Issues ................................................................3-13 SECTION 4 - Impact Assessment ........................................................................................................... 4-1

4.1 - Significance Criteria ...............................................................................................................................4-1

4.1.1 - Thresholds Adopted for the Evaluation of Air Quality Impacts under CEQA 4-1

4.1.2 - Threshold for Ambient Air Quality Impacts ...............................................................4-2

4.1.3 - Thresholds for Hazardous Air Pollutants ....................................................................4-2

4.1.4 - Global Climate Change Thresholds of Significance ..................................................4-3

4.2 - Project Related Emissions ...................................................................................................................4-4

4.2.1 - Short-Term Emissions.........................................................................................................4-5

4.2.2 - Long-Term Operational Emissions.................................................................................4-6

4.3 - Potential Impacts on Sensitive Receptors .....................................................................................4-7

4.4 - Potential Impacts to Visibility to Nearby Class 1 Areas ...........................................................4-8

4.5 - Potential Impacts from Carbon Monoxide ....................................................................................4-8

4.6 - Predicted Health Impacts.....................................................................................................................4-9

4.7 - Potential Impacts from Valley Fever ............................................................................................4-11

4.8 - Potential Impacts from Asbestos ...................................................................................................4-12

4.9 - Odor Impacts and Mitigation...........................................................................................................4-12 1164
Clements Ranch Residential Project – Air Quality Impact Analysis October 2025 Page ii

4.10 - Impacts to Ambient Air Quality ...................................................................................................4-13

4.11 - Impacts to Greenhouse Gases and Climate Change..............................................................4-15 SECTION 5 - Cumulative Impacts .......................................................................................................... 5-1

5.1 - Cumulative Regional Air Quality Impacts......................................................................................5-1

5.2 - Cumulative Local Air Quality Impacts.............................................................................................5-3

5.3 - Cumulative Hazardous Air Pollutants.............................................................................................5-3

5.4 - Cumulative Carbon Monoxide (CO) – Mobile Sources..............................................................5-3 SECTION 6 - Consistency with the Air Quality Attainment Plan ................................................. 6-1

6.1 - Required Evaluation Guidelines........................................................................................................6-1

6.2 - Consistency with the Tulare Council of Government’s Regional Conformity Analysis6-2 SECTION 7 - Mitigation and Other Recommended Measures ...................................................... 7-1

7.1 - Applicable PM10 Reduction Measures.............................................................................................7-1

7.2 - Recommended Measures to Reduce Equipment Exhaust.......................................................7-2

7.3 - Recommended Measures to Reduce Equipment Exhaust.......................................................7-2 SECTION 8 - Level of Significance After Mitigation ......................................................................... 8-1 SECTION 9 - References ........................................................................................................................... 9-1 Appendices
Appendix A – Project Emission Calculations
Appendix B – Health Risk Assessment Modeling Files (Electronic) Appendix C – Ambient Air Quality Analysis Modeling Files (Electronic) List of Figures
Figure 2-1 Regional Location 2-2
Figure 2-2 Project Location 2-3
Figure 2-3 Project Site Topography 2-4
Figure 3-1 CARB Monitoring Network 3-4
Figure 6-1 Tulare County Zoning 6-4
List of Tables
Table 3-1 Federal and California Standards 3-2
Table 3-2 SJVAB Attainment Status 3-3
Table 3-3 Existing Air Quality Monitoring Data in Project Area 3-5 Table 3-4 Bakerfield, California Weather Data 3-9
Table 4-1 SJVAPCD CEQA Thresholds of Significance 4-2
Table 4-2 Measures of Significance – Toxic Air Contaminants 4-3 1165
Clements Ranch Residential Project – Air Quality Impact Analysis October 2025 Page iii
Table 4-3 Short-Term Project Emissions 4-6
Table 4-4 Post-Project Max Year (Operational Emissions) 4-7 Table 4-5 Sensitive Receptors Located < 1 miles from Project 4-8 Table 4-5 Potential Maximum Impacts Predicted by HARP 4-11 Table 4-6 Estimated Annual GHG Emissions (MT/Year) 4-15 Table 5-1 Comparative Analysis Based on SJVAB 2024 Inventory 5-2 Table 5-2 Emission Inventory SJVAB 2030 Projection – Tons per Year 5-2 Table 5-3 Emission Inventory Tulare County 2030 Projection – Tons per Year 5-2 Table 5-4 2030 Emissions Projections – Proposed Project, Tulare County and SJVAB 5-3

1166
Clements Ranch Residential Project – Air Quality Impact Analysis October 2025 Page iv

LIST OF ACRONYMS AND ABBREVIATIONS
°C degrees Celsius
°F degrees Fahrenheit
AAQA Ambient Air Quality Analysis
AB Assembly Bill
AERMOD Air Dispersion Modeling and Risk Assessment Tool AQAP Air Quality Attainment Plans
AQIA Air Quality Impact Analysis
BACT best available control technology
BAU business as usual
BMCM Bulk Material Control Measures
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAT Climate Action Team
CCAA California Clean Air Act
CEQA California Environmental Quality Act
CFCs chlorofluorocarbons
CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e CO2 equivalents
EGR exhaust gas recirculation
EIR Environmental Impact Report
EPA Environmental Protection Agency
GAMAQI Guidance for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
GPA General Plan Amendments
GWP Global Warming Potential
H2S hydrogen sulfide
HAPs hazardous air pollutants
HARP Hotspots Analysis and Reporting Program
HI hazard index
IPCC Intergovernmental Panel on Climate Change
TulareCOG Tulare Council of Governments
LOS Level of Service
M-1 Light Manufacturing
M-2 General Manufacturing
M-3 Heavy Industrial
MMT CO2e million metric tons of CO2 equivalent
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
1167
Clements Ranch Residential Project – Air Quality Impact Analysis October 2025 Page v
NO2 nitrogen dioxide
NOx nitrogen oxides
NSR New Source Review
O3 ozone
OEHHA Office of Environmental Health Hazard Assessment
Pb lead
PM particulate matter
PM10 particulate matter 10 micrometers
PM2.5 particulate matter 2.5 micrometers
PMI point of maximum impact
PSD Prevention of Significant Deterioration
RACM Reasonably Available Control Measures
ROG reactive organic gases
RPS Renewables Portfolio Standard
SB Senate Bill
SIL significant impact levels
SIPs State Implementation Plans
SJVAB San Joaquin Valley Air Basin
SJVAPCD San Joaquin Valley Air Pollution Control District SO2 sulfur dioxide
SOx sulfur oxides
USGCRP United States Global Change Research Program
USGS United States Geological Survey
VDE visible dust emissions
VERA Voluntary Emission Reduction Agreement

1168
Executive Summary

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

SECTION 1 - EXECUTIVE SUMMARY
Quad Knopf, Inc. (QK) has completed an Air Quality Impact Analysis (AQIA) for the Clements Ranch Residential Project (Project). The Project is generally bound by Union Pacific Railroad to the north, Road 148 to the east, East Caldwell Avenue to the South and South Lovers Lane to the west. The project is located in southeast Visalia, CA within the County of Tulare.

The project site is located on approximately 75-acres parcels (APN 127-020-20 & -21) to be developed as part of Tentative Tract Map No. 5606. The Project proposes to develop approximately 153 single-family medium density units,139 single-family low-density units and 375 multi-family units for a total of approximately 667 units. For purposes of environmental review, an additional 375 multi-family units that could be built in the future is included in the analysis.

The proposed Project’s construction and operations would include the following criteria pollutant emissions: reactive organic gases (ROG), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), and suspended particulate matter (PM10 and PM2.5). Project operations would generate air pollutant emissions from mobile (vehicle activity from delivery trucks, consumers, and employees), energy sources (natural gas and electricity usage), and area sources (incidental activities related to architectural coating, consumer products, and landscape maintenance). Project construction and operational activities would also generate greenhouse gas (GHG) emissions. Criteria and GHG emissions were estimated using the California Emissions Estimator Model (CalEEMod) version 2022.1.1.30 (California Air Pollution Control Officers Association (CAPCOA), 2025), which is the most current version of the model approved for use by the San Joaquin Valley Air Pollution Control District (SJVAPCD).

Table 4-3 presents the Project’s construction emissions and provides substantial evidence to support a less-than-significant air quality impact on the San Joaquin Valley Air Basin (SJVAB).

Table 4-4 presents the Project’s operations emissions and provides substantial evidence to support a less-than-significant air quality impact on the SJVAB after mitigation.

SJVAPCD uses a single threshold for the determination of significance for both projectspecific and cumulative impacts. As such, a qualitative evaluation of the cumulative projects supports the finding that the Project’s contribution would not be cumulatively considerable because the proposed Project’s incremental emissions would be less than significant. 1169
Introduction

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

SECTION 2 - INTRODUCTION

2.1 - Purpose
This AQIA was prepared pursuant to the SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI) (SJVAPCD, 2015) and the California Environmental Quality Act (CEQA) Statute and Guidelines (CEQA, 2025).

2.2 - General Project Description
The Project is generally bound by Union Pacific Railroad to the north, Road 148 to the east, East Caldwell Avenue to the South and South Lovers Lane to the west. The project is located in southeast Visalia, CA within the County of Tulare.

The project site is located on approximately 75-acres parcels (APN 127-020-20 & -21) to be developed as part of Tentative Tract Map No. 5606. The Project proposes to develop a mixed density residential subdivision on an approximately 78-acre site that would consist of approximately 153 single-family medium density units and 139 single-family low-density units, for a total of approximately 667 units. An additional 375 multi-family units that could be built in the future is included in the analysis.

All residential units will be equipped with 450-watt solar panels, utilize all electric appliances and will be EV-ready, pre-wired during construction to allow for installation of EV residential charger in the future.

Figure 2-1 depicts the regional location and Figure 2-2 depicts an aerial view of the Project location.

Figure 2-3 depicts the Project site’s topography. The Project site is located at an elevation of approximately 350 feet above mean sea level and is surrounded by residential, industrial, and empty parcels.
1170
Introduction

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Figure 2-1
Regional Location
Medford
0 D State County Boundaries
~---: State Boundary
0 Miles 100
I
Dill
E Ca ldwell Ave

0.35 Mojave
Desert
Las Vegas 0
t. I"," -- __ _
1171
Introduction

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Figure 2-2
Project Location
1172
Introduction

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Figure 2-3
Project Site Topography
0 ~
,,,,,
lo Feet 990 1
I CJ Project Site I
1173
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

SECTION 3 - SETTING
Protection of public health is maintained through the attainment and maintenance of ambient air quality standards for various atmospheric compounds and the enforcement of emissions limits for individual stationary sources. The Federal Clean Air Act requires that the U.S. Environmental Protection Agency (EPA) establish National Ambient Air Quality Standards (NAAQS) to protect the health, safety, and welfare of the public. NAAQS have been established for ozone (O3), CO, NO2, SO2, PM10 and PM2.5, and lead (Pb). California has also adopted ambient air quality standards (CAAQS) for these "criteria" air pollutants. CAAQS are more stringent than the corresponding NAAQS and include standards for hydrogen sulfide (H2S), vinyl chloride (chloroethene), and visibility-reducing particles. The U.S. Clean Air Act Amendments of 1977 required each state to identify areas that were in non-attainment of the NAAQS and to develop State Implementation Plans (SIPs) containing strategies to bring these non-attainment areas into compliance. NAAQS and CAAQS designation/classification for Tulare County are presented in Section 3.1 below.

Responsibility for the regulation of air quality in California lies with the California Air Resources Board (CARB) and the 35 local air districts, with oversight responsibility held by the EPA. CARB is responsible for regulating mobile source emissions, establishing CAAQS, conducting research, managing regulation development, and providing oversight and coordination of the activities of the 35 air districts. The air districts are primarily responsible for regulating stationary source emissions and monitoring ambient pollutant concentrations. CARB also determines whether air basins, or portions thereof, are “unclassified,” in “attainment,” or in “non-attainment” for the NAAQS and CAAQS relying on statewide air quality monitoring data.

3.1 - Air Quality Standards
The Project area is located within Tulare County in the San Joaquin Valley Air Basin (SJVAB or Basin). Tulare County is included among the eight counties that comprise the SJVAPCD.

The SJVAPCD acts as the regulatory agency for air pollution control in the Basin and is the local agency empowered to regulate air pollutant emissions for the Project area. Table 3-1 provides the NAAQS and CAAQS.
1174
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Table 3-1
Federal and California Standards
Pollutant Averaging Time NAAQS CAAQS
Concentration
O3
8-hour 0.070 ppm (137 µg/m3)a 0.070 ppm (137 µg/m3)
1-hour 0.09 ppm (180 µg/m3)
CO
8-hour 9 ppm (10 µg/m3) 9 ppm (10 µg/m3)
1-hour 35 ppm (40 µg/m3) 20 ppm (23 µg/m3)
NO2
Annual Average 53 ppb (100 µg/m3) 0.030 ppm (57 µg/m3)
1-Hour 100 ppb (188.68 µg/m3) 0.18 ppm (339 µg/m3)
SO2
3-Hour 0.5 ppm (1,300 µg/m3)
24 Hour 0.14 ppm (365 µg/m3) 0.04 ppm (105 µg/m3)
1-Hour 75 ppb (196 µg/m3) 0.25 ppm (655 µg/m3)
Particulate Matter
(PM10)
Annual Arithmetic
Mean 20 µg/m3
24-Hour 150 µg/m3 50 µg/m3
Fine Particulate
Matter (PM2.5)
Annual Arithmetic
Mean 12 µg/m3 12 µg/m3
24-Hour 35 µg/m3
Sulfates 24-Hour 25 µg/m3
Pbd
Rolling Three-Month
Average 0.15 µg/m3
30 Day Average 1.5 µg/m3
H2S 1-Hour 0.03 ppm (42 µg/m3)
Vinyl Chloride
(chloroethene) 24-Hour 0.010 ppm (26 µg/m3)
Visibility Reducing
particles
8 Hour (1000 to 1800
PST)
b
ppm = parts per
million
ppb = parts per billion
mg/m3 = milligrams per cubic
meter
µg/m3 = micrograms per cubic
meter
Source: CARB 2024b
a. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm
b. In 1989, CARB converted both the general statewide 10-mile visibility standards and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.

Under the provisions of the U.S. Clean Air Act, the Tulare County portion of the SJVAB has been classified as non-attainment/extreme, non-attainment/severe, non-attainment, attainment/ unclassified, attainment, or unclassified under the established NAAQS and CAAQS for various criteria pollutants. Table 3-2 provides the SJVAB’s designation and classification based on the various criteria pollutants under both NAAQS and CAAQS. 1175
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Table 3-2
SJVAB Attainment Status
Pollutant NAAQSa CAAQSb
Ozone – 1 Hour No Federal Standardf Non-attainment/Severe Ozone – 8 Hour8 Non-attainment/Extremee Non-attainment
PM10 Attainmentc Non-attainment
PM2.5 Non-attainmentd Non-attainment
Carbon Monoxide Attainment/Unclassified Attainment/Unclassified Nitrogen Dioxide Attainment/Unclassified Attainment
Sulfur Dioxide Attainment/Unclassified Attainment
Lead Particulates No Designation/Classification Attainment H2S No Federal Standard Unclassified
Sulfates No Federal Standard Attainment
Visibility Reducing Particulates No Federal Standard Unclassified Vinyl Chloride No Federal Standard Attainment
[Source: SJVAPCD 2025a
Notes:
a. See 40 CFR Part 81
b. See CCR Title 17 Sections 60200-60210
c. On September 25, 2008, EPA redesignated the San Joaquin Valley to attainment for the PM10 National Ambient Air Quality Standard (NAAQS) and approved the PM10 Maintenance Plan. d. The Valley is designated non-attainment for the 1997 PM2.5 NAAQS. EPA designated the Valley as non-attainment for the 2006 PM2.5 NAAQS on November 13, 2009 (effective December 14, 2009). e. Though the Valley was initially classified as serious non-attainment for the 1997 8-hour O3 standard, EPA approved Valley reclassification to extreme non-attainment in the Federal Register on May 5, 2010 (effective June 4, 2010). f. Effective June 15, 2005, the EPA revoked the federal 1-hour O3 standard, including associated designations and classifications. EPA had previously classified the SJVAB as extreme non-attainment for this standard. EPA approved the 2004 Extreme Ozone Attainment Demonstration Plan on March 8, 2010 (effective April 7, 2010). Many applicable requirements for extreme 1-hour O3 non-attainment areas continue to apply to the SJVAB.

The SJVACPD, along with CARB, operates an air quality monitoring network that provides average concentrations of those pollutants for which State or federal agencies have established ambient air quality standards. Information from the various monitoring stations is available from the corresponding agency’s websites. A map of the monitoring stations in the SJVAB is provided in Figure 3-1 below.
1176
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

Figure 3-1
CARB Monitoring Network
Asof July 2021
San Joaquin Valley - AIR POLLUTION CONTROL DISTRICT

SAN JOAQUIN COUNTY
• 1 Stockton•Ha~ehcn: G, M, P, F, T
• 2 Trxy-Aupon.G. P.f • 3 Manteca: P. F. M

STANISLAUS COUNTY
• 4 Modcsto-14thS G,M,P,F
• S Tutloc G,M,P,F
MERC£0 COUNTY
• 6 11.,rcc,d S ·P.F
• 7 Mer~~: G,F,M

MADERA COUNTY
• 8 Mlde~City-G.P.f.M
• 9 Madc~·PumpYard·G.M

FRESNO COUNTY
Oth" r':

Monache Tnbei1'oo!hl Yobn Indians
• 10 TlbleMount;,nAMS', G.F.P.
• 11 T~nquo hty. G. F, M
• 12 fresno-Skyl'm:G.M
• 13 CkMs:G.M.P.f • 14 fresno<;a,landG,M. P,F, T,
• 1 S Fresno-Pac.ilic F
• 16 Fresno-Drummond G. P. M
• 17 fresnc>f<lundry G. M. F
• 18Part 1.G.M
• 19 H ronf,M

MO ITOAI G DESIGNATIONS
f Fn, P"1lculotc (PMlS) P PartlCWle (PMIO)
G ~ N MIONIC<n
M Mo1<0<ologlcal T T

KINGS COUNTY
• 20 Hantord.G,F,M.P
• 21 Corcorat1: F, P
Othtr'
Tachl Yoblt T ~
• 22 Santa !Ima RanchenA G. M. P

TULARE COUNTY
• 23 Vrsa ia-Chu<ch S G, F, M. P
• 24 PorleMlle: G, f. M
Olhtr':
• 25 Lower~A.G.M
• 26 Ash Mouota • A. G, M. F

KERN COUNTY
• 27 Shafter. G. M
• 28 ()Ida G,M,P
• 29 Ba sfield-(;o!den/'M St F, P
• 30 Ba"'mfield•W~,nd G, M
• 31 Ba s6"1d<a forni.11. G, M. P. F. T
• 32 Ba1<1mfield•Muno G, M
• 33 Bakersfieid-AJrl)Oll (Planz): F
• 34 Ed-,on: G, M
• 35 AMn-O-Giorgo0: G,
• 36 Mancopa. G,
• 37 Leo«: F, M

MONITORING OPERATION
• S.t<!< op,ml!d by the Omrla • SolM optatl!d by I he, OlsuiCI &, CAR8 • Sacs - cd by CARS • 5'1Mo,x<acdbyothcf~
O!hc<'Tnbal
O!herN>UONIP 5ffltce
,., Monocorv,g Smoon (AMS}
1177
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

3.2 - Existing Air Quality
For the purposes of background data and this air quality assessment, this analysis relied on data collected in the last three years for the CARB monitoring stations that are located in closest proximity to the Project site. Table 3-3 provides the background concentrations for O3, particulate matter of 10 microns (PM10), particulate matter of less than 2.5 microns (PM2.5), CO, NO2, Pb and H2S as of 2023. Information is provided for the Visalia – W. Ashland Avenue, Porterville – Newcomb St., Hanford – S Irwin St, and Fresno - Garland monitoring stations for 2022 through 2024. No data is available for SO2, Vinyl Chloride, or other toxic air contaminants in the SJVAB.

Table 3-3
Existing Air Quality Monitoring Data in Project Area
Maximum Concentration Days Exceeding Standard
Pollutant and
Monitoring Station Location 2022 2023 2024 2022 2023 2024 O3 – 1-hour CAAQS (0.09 ppm)
Visalia – W. Ashland Ave 0.114 0.100 0.103 8 3 8
Porterville – Newcomb St 0.099 0.102 0.106 1 7 5
O3 – 8-hour CAAQS (0.07 ppm)
Visalia – W. Ashland Ave 0.099 0.087 0.094 64 30 63
Porterville – Newcomb St 0.085 0.089 0.094 25 22 27
O3 – 8-hour NAAQS (0.070 ppm)
Visalia – W. Ashland Ave 0.098 0.087 0.093 62 27 62
Porterville – Newcomb St 0.085 0.089 0.094 62 49 51
PM10 – 24-hour CAAQS (50 µg/m3)
Visalia – W. Ashland Ave 125.2 107.5 176.9 111 102 104
Hanford – S Irwin St. 251.6 159.3 169.0 141 114 112
PM10 – 24-hour NAAQS (150 µg/m3)
Visalia – W. Ashland Ave 132.7 108.8 173.0 0 0 1
Hanford – S Irwin St. 250.8 157.3 173.0 1 1 4
PM2.5 - 24-hour NAAQS (35 µg/m3)
Visalia – W. Ashland Ave 48.3 42.9 64.7 17 6 8
Hanford – S Irwin St. 62.9 54.4 53.7 27 11 8
CO - 8-Hour CAAQS & NAAQS (9.0 ppm)
No data collected * * * * * *
NO2 - 1-Hour CAAQS (0.18 ppm)
Visalia – W. Ashland Ave 0.049 0.039 0.042 0 0 0
Hanford – S Irwin St. 0.045 0.055 0.041 0 0 0
NO2 - 1-Hour NAAQS (0.10 ppm)
Visalia – W. Ashland Ave 0.0497 0.0399 0.0427 0 0 0
Hanford – S Irwin St. 0.0458 0.0552 0.0410 0 0 0
SO2 – 24-hour Concentration - CAAQS (0.04 ppm) & NAAQS (0.14 ppm) No data collected * * * * * *
Pb - Maximum 30-Day Concentration CAAQS (1500 ng/m3)
Fresno – Garland 42 6.5 6.5 * * *
Source: CARB 2025
Notes: ppm= parts per million
* There was insufficient (or no) data available to determine the value. 1178
Setting

Clements Ranch Residential Project – Air Quality Impact Analysis October 2025

The following describes criteria air pollutants, typical sources, health effects, and recently documented pollutant levels in the Project vicinity.

3.2.1 - OZONE (O3)
The SJVAB has high concentrations of O3, and these high levels are known to cause eye irritation and impair respiratory functions. High levels of O3 can also affect plants and materials. Grapes, lettuce, spinach, and many types of garden flowers and shrubs are particularly vulnerable to O3 damage. O3 is not directly emitted into the atmosphere; it is a secondary pollutant produced from a photochemical interaction between hydrocarbons and nitrogen oxides (NOx). One to three hours of strong sunlight in a stable atmosphere creates O3. The “O3 season,” therefore, typically spans from April through October. O3 is a regional pollutant; wind transports and diffuses the precursors while activating the photochemical reaction process. The data presented in Table 3-3 shows that the Project area monitoring stations exceeded the 1-hour average ambient O3 CAAQS and the 8-hour average ambient O3 NAAQS and CAAQS between 2022 through 2024.

3.2.2 - SUSPENDED PARTICULATE MATTER (PM10 AND PM2.5)
Both NAAQS and CAAQS now apply to particulates under 10 microns (PM10). Since the smaller diameter fraction of total suspended particulates is documented to represent the greatest health hazard, EPA has established NAAQS for particulates under 2.5 microns (PM2.5). The Project area is classified as attainment for PM10 and non-attainment for PM2.5 for NAAQS.

Dust and fumes from industrial and agricultural operations generate particulate matter.

Natural activities, such as wind-raised dust, fires, and ocean spray, also increase the level of particulates in the atmosphere. The largest source of PM10 and PM2.5 in Tulare County is vehicle movement over paved and unpaved roads from demolition and construction activities and farming operations. PM10 and PM2.5 are considered regional pollutants, with elevated levels typically occurring over a wide geographic area. Concentrations tend to be highest in the winter, during periods of high atmospheric stability and low wind speed. Very small particulates may contain absorbed gases that produce injury to the respiratory tract.

Particulates of aerosol size suspended in the air can both scatter and absorb sunlight, producing haze and reducing visibility. They can also damage a wide range of materials.

Table 3-3 shows that PM10 levels exceeded the CAAQS, and both PM10 and PM2.5 exceeded the NAAQS in 2022 and 2024, respectively. Similar levels can be expected to occur in the vicinity of the Project site.

3.2.3 - CARBON MONOXIDE (CO)
Ambient CO concentrations normally correspond closely to the spatial and temporal distributions of vehicular traffic. Relatively high concentrations of CO would be expected along heavily traveled roads and near busy intersections. Wind speed and atmospheric mixing also influence CO concentrations.
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Internal combustion engines, principally in vehicles, produce CO due to incomplete fuel combustion. Various industrial processes also produce CO emissions through incomplete combustion. Gasoline-powered motor vehicles are typically the major source of this contaminant. CO does not irritate the respiratory tract but passes through the lungs directly into the bloodstream, and by interfering with the transfer of fresh oxygen to the blood, deprives sensitive tissues of oxygen, thereby aggravating cardiovascular disease, causing fatigue, headaches, and dizziness. CO is not known to have adverse effects on vegetation, visibility, or materials. Table 3-3 reports insufficient data for the CO monitoring at any monitoring stations during the three-year period from 2022 through 2024.

3.2.4 - NITROGEN DIOXIDE (NO2) AND HYDROCARBONS
Tulare County has been designated as an unclassified area for the NAAQS for NO2. NO2 is the "whiskey brown" colored gas readily visible during periods of heavy air pollution. Mobile sources account for nearly all the County's NOx emissions, most of which are emitted as NO2.

Combustion in motor vehicle engines, power plants, refineries, and other industrial operations are the primary sources in the air basin. Railroads and aircraft are other potentially significant sources of combustion air contaminants. Oxides of nitrogen are direct participants in photochemical smog reactions. The emitted compound, nitric oxide, combines with oxygen in the atmosphere in the presence of hydrocarbons and sunlight to form NO2 and O3. NO2, the most significant of these pollutants, can color the atmosphere at concentrations as low as 0.5 ppm on days of 10-mile visibility. NOx is an important air pollutant in the region because it is a primary receptor of ultraviolet light, which initiates the reactions producing photochemical smog. It also reacts in the air to form nitrate particulates.

Motor vehicles are the major source of reactive hydrocarbons in the basin. Other sources include evaporation of organic solvents and petroleum production and refining operations.

Certain hydrocarbons can damage plants by inhibiting growth and by causing flowers and leaves to fall. Levels of hydrocarbons currently measured in urban areas are not known to cause adverse effects in humans. However, certain members of this contaminant group are important components in the reactions which produce photochemical oxidants. Table 3-3 shows that the NO2 NAAQS and CAAQS were not exceeded over the three-year period of 2022 through 2024. Hydrocarbons are not currently monitored.

3.2.5 - SULFUR DIOXIDE
Tulare County has been designated as an unclassified area for the NAAQS for SO2. SO2 is the primary combustion product of sulfur or sulfur-containing fuels. Fuel combustion is the major source of this pollutant, while chemical plants, sulfur recovery plants, and metal processing facilities are minor contributors. Gaseous fuels (natural gas, propane, etc.) typically have lower percentages of sulfur-containing compounds than liquid fuels such as diesel or crude oil. SO2 levels are generally higher in the winter months. Decreasing levels of SO2 in the atmosphere reflect the use of natural gas in power plants and boilers.

At high concentrations, SO2 irritates the upper respiratory tract. At lower concentrations, when respirated in combination with particulates, SO2 can result in greater harm by injuring 1180
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lung tissues. Sulfur oxides (SOx), in combination with moisture and oxygen, result in the formation of sulfuric acid, which can yellow the leaves of plants, dissolve marble, and oxidize iron and steel. SOx can also react to produce sulfates that reduce visibility and sunlight. Table 3-3 shows no data has been reported over the three-year period.

3.2.6 - LEAD (PB) AND SUSPENDED SULFATE
Ambient Pb levels have dropped dramatically due to the increase in the percentage of motor vehicles that run exclusively on unleaded fuel. Ambient Pb levels in Bakersfield (the closest monitoring station to the Project) are well below the ambient standard and are expected to continue to decline; the data reported in Table 3-3 only shows the highest concentration as the number of days exceeding standards is not reported. Suspended sulfate levels have stabilized to the point where no excesses of the State standard are expected in any given year.

3.3 - Climate
The most significant single control on the weather pattern of the San Joaquin Valley is the semi-permanent subtropical high-pressure cell, referred to as the "Pacific High." During the summer, the Pacific High is positioned off the coast of northern California, diverting oceanderived storms to the north. Hence, the summer months are virtually rainless. During the winter, the Pacific High moves southward, allowing storms to pass through the San Joaquin Valley. Almost all the precipitation expected during a given year occurs from December through April. During the summer, the predominant surface winds are out of the northwest.

Air enters the Valley through the Carquinez Strait and flows toward the Tehachapi Mountains. This up-valley (northwesterly) wind flow is interrupted in early fall by the emergence of nocturnal, down-valley (southeasterly) winds, which become progressively more predominant as winter approaches. Wind speeds are generally highest during the spring and lightest in fall and winter. The relatively cool air flowing through the Carquinez Strait is warmed on its journey south through the Valley. On reaching the southern end of the Valley, the average high temperature during the summer is nearly 100 degrees Fahrenheit (°F). Relative humidity during the summer is quite low, causing large diurnal temperature variations. Temperatures during the summer often drop into the upper 60s. In winter, the average high temperatures reach into the mid-50s, and the average low drops to the mid-30s. In addition, another high-pressure cell, known as the "Great Basin High," develops east of the Sierra Nevada Mountain Range during winter. When this cell is weak, a layer of cool, damp air becomes trapped in the basin, and extensive fog results. During inversions, vertical dispersion is restricted, and pollutant emissions are trapped beneath the inversion and pushed against the mountains, adversely affecting regional air quality.

Surface-based inversions, while shallow and typically short-lived, are present most mornings. Elevated inversions, while less frequent than ground-based inversions, are typically longer lasting and create more severe air stagnation problems. The winter season characteristically has the poorest conditions for vertical mixing of the entire year.

Meteorological data for various monitoring stations is maintained by the Western Regional Climate Center. Meteorological data for the Project site is expected to be similar to the data 1181
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recorded at the Visalia monitoring station. This data is provided in Table 3-4, which contains average precipitation data recorded at the Visalia monitoring station. Over the 121-year period from February of 1895 through June of 2016 (the most recent data available), the average annual precipitation was 10.15 inches.

Table 3-4
Visalia, California Weather Data
Period of Record Monthly Climate Summary for the Period 02/01/1895 to 6/10/2016 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual
Average Max.

Temperature (F) 56.0 62.6 68.0 74.6 82.6 91.1 97.5 96.2 90.1 80.2 67.3 56.8 76.9 Average Min.

Temperature (F) 36.9 40.8 43.7 47.5 53.1 59.0 63.5 61.6 57.3 50.2 41.6 36.8 49.3 Average Total
Precipitation (in.) 1.97 1.83 1.72 0.98 0.36 0.09 0.01 0.01 0.13 0.48 0.98 1.57 10.15 Average Total
SnowFall (in.) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Average Snow
Depth (in.) 0 0 0 0 0 0 0 0 0 0 0 0 0
Percent of possible observations for period of record:

Max. Temp.: 97.4% Min. Temp.: 97.4% Precipitation: 99.3% Snowfall: 97% Snow Depth: 96.8% Source: Western Regional Climate Center, 2025.

3.4 - Climate Change and Greenhouse Gases

3.4.1 - GLOBAL CLIMATE CHANGE
“Global climate change” refers to changes in average meteorological conditions on the earth with respect to temperature, precipitation, and storms, lasting for decades or longer. The term “global climate change” is often used interchangeably with the term “global warming,” but “global climate change” is preferred by some scientists and policymakers to “global warming” because it helps convey the notion that in addition to rising temperatures, other changes in global climate may occur. Climate change may result from the following influences:
• Natural factors, such as changes in the sun’s intensity or slow changes in the Earth’s orbit around the sun.
• Natural processes within the climate system (e.g., changes in ocean circulation). • Human activities that change the atmosphere’s composition (e.g., through burning fossil fuels) and the land surface (e.g., deforestation, reforestation, urbanization, and desertification).

As determined from worldwide meteorological measurements between 1990 and 2005, the primary observed effect of global climate change has been a rise in the average global tropospheric temperature of 0.36 degrees Fahrenheit (°F) per decade. Climate change modeling shows that further warming could occur, which could induce additional changes in the global climate system during the current century. Changes to the global climate system, 1182
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ecosystems, and the environment of California could include higher sea levels, drier or wetter weather, changes in ocean salinity, changes in wind patterns, or more energetic aspects of extreme weather (e.g., droughts, heavy precipitation, heat waves, extreme cold, and increased intensity of tropical cyclones). Specific effects from climate change in California may include a decline in the Sierra Nevada snowpack, erosion of California’s coastline, and seawater intrusion in the Sacramento-San Joaquin River Delta.

Human activities, including fossil fuel combustion and land use changes, release carbon dioxide (CO2) and other compounds cumulatively termed greenhouse gases. GHGs are effective at trapping radiation that would otherwise escape the atmosphere. This trapped radiation warms the atmosphere, the oceans, and the earth’s surface (USGCRP, 2014). Many scientists believe most of the warming observed over the last 50 years is attributable to human activities” (IPCC, 2014). The increased amount of CO2 and other GHGs in the atmosphere is the alleged primary result of human-induced warming.

GHGs are present in the atmosphere naturally, released by natural sources, or formed from secondary reactions taking place in the atmosphere. They include CO2, methane (CH4), nitrous oxide (N2O), and O3. In the last 200 years, substantial quantities of GHGs have been released into the atmosphere, primarily from fossil fuel combustion. These human-induced emissions are increasing GHG concentrations in the atmosphere, therefore enhancing the natural greenhouse effect. The GHGs resulting from human activity are believed to be causing global climate change. While human-made GHGs include CO2, CH4, and N2O, some (like chlorofluorocarbons [CFCs]) are completely new to the atmosphere. GHGs vary considerably in terms of Global Warming Potential (GWP), the comparative ability of each GHG to trap heat in the atmosphere. The GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and the length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to CO2, the most abundant GHG. The definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e).

Natural sources of CO2 include the respiration (breathing) of animals and plants and evaporation from the oceans. Together, these natural sources release approximately 150 billion metric tons of CO2 each year, far outweighing the seven billion metric tons of GHG emissions from fossil fuel burning, waste incineration, deforestation, cement manufacturing, and other human activity. Nevertheless, natural GHG removal processes such as photosynthesis cannot keep pace with the additional output of CO2 from human activities.

Consequently, GHGs are building up in the atmosphere (Enviropedia, 2019).

Methane is produced when organic matter decomposes in environments lacking sufficient oxygen. Natural sources of CH4 production include wetlands, termites, and oceans. Human activity accounts for the majority of the approximately 500 million metric tons of CH4 emitted annually. These anthropogenic sources include the mining and burning of fossil fuels, digestive processes in ruminant livestock such as cattle, rice cultivation, and the decomposition of waste in landfills. The major removal process for atmospheric CH4, the 1183
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chemical breakdown in the atmosphere, cannot keep pace with source emissions; therefore, CH4 concentrations in the atmosphere are rising.

Worldwide emissions of GHGs in 2008 were 30.1 billion metric tons of CO2e and have increased considerably since that time (United Nations, 2011). Emissions from the top five emitting countries (China, the United States, India, the Russian Federation, and Japan) and the European Union accounted for approximately 70 percent of total global GHG emissions in 2014. The United States was the number two producer of GHG emissions, behind China.

The primary GHG emitted by human activities was CO2, representing approximately 80 percent of total GHG emissions (U.S. EPA, 2024).

In 2022, the United States emitted approximately 6,343.2 million metric tons of CO2e.

Between 1990 and 2022, CO2 emissions from fossil fuel combustion decreased by 1.1 percent; emissions decreased by 18.2 percent (1,044.7 MMT CO2e) from 2005 levels; and from 2021 to 2022, these emissions increased by 1.0 percent (45.1 MMT CO2e). (U.S. EPA, 2024).

Worldwide, energy-related CO2 emissions are expected to increase through 2050.

Projections indicate that resources, demand, and technology costs will drive the shift from fossil to non-fossil energy sources, but current policies are not enough to decrease global energy-sector emissions. This outcome is largely due to population growth, regional economic shifts toward more manufacturing, and increased energy consumption as living standards improve. Globally, we project increases in energy consumption to outpace efficiency improvements. China remains the primary source of energy-related CO2 emissions through 2050 across all cases, although its share of total global CO2 emissions declines.

Further, across all cases we project India to displace the United States and our Other AsiaPacific modeling region to displace Western Europe as the second- and third-highest emitters of energy-related CO2 emissions by 2050, respectively. (U.S. EIA, 2023).

CARB is responsible for developing and maintaining the California GHG emissions inventory.

This inventory estimates the amount of GHGs emitted into and removed from the atmosphere by human activities within California and supports the Assembly Bill (AB) 32 Climate Change Program. CARB’s current GHG emission inventory covers the years 2000 through 2017 and is based on fuel use, equipment activity, industrial processes, and other relevant data (e.g., housing, landfill activity, and agricultural lands).

In 2022, emissions from statewide emitting activities were 371.1 million metric tons of CO2 equivalent (MMT CO2e), which is 9.3 MMT CO2e lower than 2021 levels. 2022 emissions have decreased by 24 percent since peak levels in 2004 and are 59.9 MMT CO2e below the 1990 emissions level and the State’s 2020 GHG limit (CARB 2024a).

CARB estimates that transportation was the source of approximately 39 percent of California’s GHG emissions in 2022, followed by industrial sources at 23 percent. Other sources of GHG emissions were electricity sources at 16 percent, residential plus commercial activities at 14 percent, and agriculture at 8 percent (CARB, 2024a). 1184
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3.4.2 - EFFECTS OF GLOBAL CLIMATE CHANGE
Changes in the global climate are assessed using historical records of temperature changes that have occurred in the past. Climate change scientists use this temperature data to extrapolate a level of statistical significance, specifically focusing on temperature records from the last 150 years (the Industrial Age) that differ from past climate changes in rate and magnitude.

The Intergovernmental Panel on Climate Change (IPCC) constructed several emission trajectories of GHGs needed to stabilize global temperatures and climate change impacts. In its Fifth Assessment Report, the IPCC predicted that the global mean temperature change from 1990 to 2100, could range from 1.1 degree Celsius (°C) to 6.4°C (8 to 10.4°Fahrenheit) (IPCC, 2013). Global average temperatures and sea levels are expected to rise under all scenarios (IPCC, 2014). The IPCC concluded that global climate change was largely the result of human activity, mainly the burning of fossil fuels. However, the scientific literature is not consistent regarding many aspects of climate change, the actual temperature changes during the 20th century, and contributions from human versus non-human activities.

Effects from global climate change may arise from temperature increases, climate-sensitive diseases, extreme weather events, and degradation of air quality. There may be direct temperature effects through increases in average temperature leading to more extreme heat waves and less extreme cold spells. Those living in warmer climates are likely to experience more stress and heat-related problems. Heat-related problems include heat rash and heat stroke, drought, etc. In addition, climate-sensitive diseases may increase, such as those spread by mosquitoes and other disease-carrying insects. Such diseases include malaria, dengue fever, yellow fever, and encephalitis. Extreme events such as flooding and hurricanes can displace people and agriculture. Global warming may also contribute to air quality problems from increased frequency of smog and particulate air pollution.

According to the 2006 California Climate Action Team (CAT) Report, several climate change effects can be expected in California over the course of the next century (CalEPA, 2006).

These are based on trends established by the IPCC and are summarized below. • A diminishing Sierra snowpack declining by 70 percent to 90 percent, threatening the State’s water supply.
• A rise in sea levels, resulting in the displacement of coastal businesses and residences.

During the past century, sea levels along California’s coast have risen about seven inches. If emissions continue unabated and temperatures rise into the higher anticipated warming range, sea level is expected to rise an additional 22 to 35 inches by the end of the century. Sea level rises of this magnitude would inundate coastal areas with salt water, accelerate coastal erosion, threaten vital levees and inland water systems, and disrupt wetlands and natural habitats. (Note: This condition would not affect the proposed Project area, as it is a significant distance away from coastal areas.)
• An increase in temperature and extreme weather events. Climate change is expected to lead to increases in the frequency, intensity, and duration of extreme heat events 1185
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and heat waves in California. More heat waves can exacerbate chronic disease or heatrelated illness. • Increased risk of large wildfires if rain increases as temperatures rise. Wildfires in the grasslands and chaparral ecosystems of southern California are estimated to increase by approximately 30 percent toward the end of the 21st century because more winter rain will stimulate the growth of more plant fuel available to burn in the fall. In contrast, a hotter, drier climate could promote up to 90 percent more northern California fires by the end of the century by drying out and increasing the flammability of forest vegetation.
• Increasing temperatures from 8 to 10.4°F under the higher emission scenarios, leading to a 25 percent to 35 percent increase in the number of days that ozone pollution levels are exceeded in most urban areas (see below). • Increased vulnerability of forests due to forest fires, pest infestation, and increased temperatures.
• Reductions in the quality and quantity of certain agricultural products. The crops and products likely to be adversely affected include wine grapes, fruit, nuts, and milk. • Exacerbation of air quality problems. If temperatures rise to the medium warming range, there could be 75 to 85 percent more days with weather conducive to ozone formation in Los Angeles and the San Joaquin Valley, relative to today’s conditions.

This is more than twice the increase expected if rising temperatures remain in the lower warming range. This increase in air quality problems could result in an increase in asthma and other health-related problems.
• A decrease in the health and productivity of California’s forests. Climate change can cause an increase in wildfires, an enhanced insect population, and the establishment of non-native species.
• Increased electricity demand, particularly in the hot summer months. • Increased ground-level ozone formation due to higher reaction rates of ozone precursors.

3.4.3 - GLOBAL CLIMATE CHANGE REGULATORY ISSUES
In 1988, the United Nations established the Intergovernmental Panel on Climate Change to evaluate the impacts of global warming and to develop strategies that nations could implement to curtail global climate change. In 1992, the United Nations Framework Convention on Climate Change established an agreement with the goal of controlling GHG emissions, including methane. As a result, the Climate Change Action Plan was developed to address the reduction of GHGs in the United States. The plan consists of more than 50 voluntary programs. Additionally, the Montreal Protocol was originally signed in 1987 and substantially amended in 1990 and 1992. Pursuant to the Montreal Protocol, the production and consumption of compounds that deplete O3 in the stratosphere (chlorofluorocarbons [CFCs], halons, carbon tetrachloride, and methyl chloroform) were phased out by 2000 (methyl chloroform was phased out by 2005).

On September 27, 2006, Assembly Bill 32 (AB 32), the California Global Warming Solutions Act of 2006 (the Act), was enacted by the State of California. The legislature stated, “Global 1186
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warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California.” The Act caps California’s GHG emissions at 1990 levels by 2020. The Act defines GHG emissions as all of the following gases: carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. This agreement represents the first enforceable statewide program in the U.S. to cap all GHG emissions from major industries that include penalties for non-compliance. While acknowledging that national and international actions will be necessary to fully address the issue of global warming, AB 32 lays out a program to inventory and reduce GHG emissions in California and from power generation facilities located outside the State that serve California residents and businesses. According to CARB, California has met its 2020 GHG emission reduction target (CARB, 2021).

Subsequent legislation by the California legislature has included Senate Bill (SB) 32, which expanded on AB 32 to reduce GHG emissions to 40 percent below the 1990 levels by 2030; AB 197, which increased the legislative oversight of the CARB by adding two legislatively appointed non-voting members to the CARB Board and provided additional protection to disadvantaged communities; SB 350, which increased California’s renewable energy electricity procurement goal; and SB 100, which established a landmark policy requiring renewable energy and zero-carbon resources to supply 100 percent of electrical retail sales to end-use customers and 100 percent of electricity procured to serve State agencies by 2045.

Global warming and climate change have received substantial public attention for more than 20 years. For example, the United States Global Change Research Program was established by the Global Change Research Act of 1990 to enhance the understanding of natural and human-induced changes in the Earth’s global environmental system, to monitor, understand, and predict global change, and to provide a sound scientific basis for national and international decision-making. Even so, the analytical tools have not been developed to determine the effect on global warming from a particular increase in GHG emissions, or the resulting effects on climate change in a particular locale. The scientific tools needed to evaluate the impacts that a specific project may have on the environment are even further in the future.

The California Supreme Court’s most recent CEQA decision on the Newhall Ranch development case, Center for Biological v. California Department of Fish and Wildlife (November 30, 2015, Case No. 217763), determined that the project’s Environmental Impact Report (EIR) did not substantiate the conclusion that the GHG cumulative impacts would be less than significant. The EIR determined that the Newhall Ranch development project would reduce GHG emissions by 31 percent from business as usual (BAU). This reduction was compared to California’s target of reducing GHG emissions statewide by 29 percent from business as usual. The Court determined that “the EIR’s deficiency stems from taking a quantitative comparison method developed by the Scoping Plan as a measure of the greenhouse gas reduction effort required by the State as a whole, and attempting to use that method, without adjustments, for a purpose very different from its original design.” In the Court’s final ruling, it offered suggestions that were deemed appropriate use of the BAU methodology:
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1. Lead agencies can use the comparison to BAU methodology if they determine what reduction a particular project must achieve in order to comply with statewide goals.

2. Project design features that comply with regulations to reduce emissions may demonstrate that those components of emissions are less than significant.

3. Lead agencies could also demonstrate compliance with locally adopted climate plans or apply specific numerical thresholds developed by some local agencies.

Neither the City of Visalia nor Tulare County have developed specific thresholds for GHGs.

As discussed in Section 4.1, the SJVAPCD, a CEQA Trustee Agency for this Project, has developed thresholds to determine the significance of a proposed project – either implement Best Performance Standards or achieve a 29 percent reduction from BAU (a specific numerical threshold). However, the SJVAPCD has established their BAU and baseline emissions based on the years 2002-2004 and 2020, respectively. The 2020 projected baseline has passed, and at this time, no new guidance has been approved for determining BAU and projected baseline for the next target year. Therefore, the 29 percent reduction from BAU cannot be applied to the subject Project in order to determine significance.

Additionally, a Best Performance Standards threshold has not been established. For this Project, compliance with locally adopted climate plans will be used to determine the level of significance of GHG. Therefore, the GHG analysis for this Project follows the suggestions from the Court’s ruling on the Newhall Ranch development project in order to determine the significance of using the Project design features.
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SECTION 4 - IMPACT ASSESSMENT

4.1 - Significance Criteria
To determine whether a proposed Project could create a potential CEQA impact, local, State, and federal agencies have developed various means by which a project’s impacts may be measured and evaluated. Such means can generally be categorized as follows:
• Thresholds of significance adopted by air quality agencies to guide lead agencies in their evaluation of air quality impacts under the CEQA. • Regulations established by air districts, CARB, and EPA for the evaluation of stationary sources when applying for Authorities to Construct, Permits to Operate, and other permit program requirements (e.g., New Source Review). • Thresholds utilized to determine if a project would cause or contribute significantly to violations of the ambient air quality standards or other concentration-based limits. • Regulations applied in areas where severe air quality problems exist.

Below are summary tables of these emission-based and concentration-based thresholds of significance for each pollutant, along with a discussion of their applicability.

4.1.1 - THRESHOLDS ADOPTED FOR THE EVALUATION OF AIR QUALITY IMPACTS UNDER CEQA In order to maintain consistency with CEQA, the SJVAPCD (2015) adopted guidelines to assist applicants in complying with the various requirements. According to the SJVAPCD’s GAMAQI, a project would have potentially significant air quality impacts when the project:
• Creates a conflict with or obstructs implementation of the applicable air quality plan. • Causes a violation of any air quality standard or generates substantial contribution towards exceeding an existing or projected air quality standard. • Results in a cumulatively considerable net increase of any criteria pollutant for which the project region is designated non-attainment under a NAAQS and CAAQS (including emissions that exceed quantitative thresholds for O3 precursors). • Exposes sensitive receptors to substantial pollutant concentrations. • Creates objectionable odors that affect a substantial number of people.

The SJVAPCD GAMAQI thresholds are designed to implement the general criteria for air quality emissions as required in the CEQA Guidelines, Appendix G, Paragraph III (Title 14 of the California Code of Regulations §15064.7) and CEQA (California Public Resources Code Sections 21000 et al.). SJVAPCD’s specific CEQA air quality thresholds are presented in Table 4-1.

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Table 4-1
SJVAPCD CEQA Thresholds of Significance
Criteria
Pollutant
Operational Emissions
Construction
Emissions
Permitted Equipment
and Activities
Non-Permitted
Equipment and Activities
NOx 10 tons/yr 10 tons/yr 10 tons/yr
ROG 10 tons/yr 10 tons/yr 10 tons/yr
SOx 27 tons/yr 27 tons/yr 27 tons/yr
PM10 15 tons/yr 15 tons/yr 15 tons/yr
PM2.5 15 tons/yr 15 tons/yr 15 tons/yr
CO 100 tons/yr 100 tons/yr 100 tons/yr
Source: SJVAPCD, 2015.

4.1.2 - THRESHOLD FOR AMBIENT AIR QUALITY IMPACTS
CEQA Guidelines – Appendix G (Environmental Checklist) states that a project that would “violate any air quality standard or contribute substantially to an existing or projected air quality violation” would be considered to create significant impacts on air quality. Therefore, an AQIA should determine whether the emissions from a project would cause or contribute significantly to violations of the NAAQS or CAAQS (presented above in Table 3-1) when added to existing ambient concentrations.

The EPA has established the federal Prevention of Significant Deterioration (PSD) program to determine what comprises “significant impact levels” (SIL) to NAAQS attainment areas. A project’s impacts are considered less than significant if emissions are below PSD SIL for a particular pollutant. When a SIL is exceeded, an additional “increment analysis” is required.

As the Project would not include modification to the stationary source under New Source Review (NSR), it would not be subject to either PSD or NSR review. The PSD SIL thresholds are used with ambient air quality modeling for a CEQA project to address whether the project would “violate any air quality standard or contribute substantially to an existing or projected air quality violation.” Ambient air quality emissions estimates below the PSD SIL thresholds would result in less-than-significant ambient air quality impacts on both a project and cumulative CEQA impact analysis. The SJVAB is classified as non-attainment/marginal for the 8-hour O3 NAAQS and, as such, is subject to non-attainment NSR. PSD SILs and increments are more stringent than the CAAQS or NAAQS and represent the most stringent thresholds of significance.

4.1.3 - THRESHOLDS FOR HAZARDOUS AIR POLLUTANTS
The SJVAPCD’s GAMAQI states, “From a health risk perspective, there are basically two types of land use projects that have the potential to cause long-term public health risk impacts:
• Type A Projects: Land use projects that will place new toxic sources in the vicinity of existing receptors.
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• Type B Projects: Land use projects that will place new receptors in the vicinity of existing toxic sources” (SJVAPCD, 2015).

Table 4-2 presents the thresholds of significance used with toxic air contaminants when evaluating hazardous air pollutants (HAPs).

Table 4-2
Measures of Significance – Toxic Air Contaminants
Agency Level Description
Significance Thresholds Adopted for the Evaluation of Impacts Under CEQA

SJVAPCD
Carcinogens Maximally Exposed Individual risk equals or exceeds 20 in one million.

NonCarcinogens
Acute: Hazard Index equals or exceeds 1.0 for the
Maximally Exposed Individual.

Chronic: Hazard Index equals or exceeds 1.0 for
the Maximally Exposed Individual.

Source: EKAPCD, 1996

4.1.4 - GLOBAL CLIMATE CHANGE THRESHOLDS OF SIGNIFICANCE On December 17, 2009, SJVAPCD adopted Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD, 2009); which outlined the SJVAPCD’s methodology for assessing a project’s significance for GHGs under CEQA. The following criteria were outlined in the document to determine whether a project could have a significant impact:
• Projects determined to be exempt from the requirements of CEQA would be determined to have a less-than-significant individual and cumulative impact for GHG emissions and would not require further environmental review, including analysis of project-specific GHG emissions. Projects exempt under CEQA would be evaluated consistent with established rules and regulations governing project approval and would not be required to implement BPS.
• Projects complying with an approved GHG emission reduction plan or GHG mitigation program that avoids or substantially reduces GHG emissions within the geographic area in which the project is located would be determined to have a less-thansignificant individual and cumulative impact for GHG emissions. Such plans or programs must be specified in law or approved by the lead agency with jurisdiction over the affected resource and supported by a CEQA-compliant environmental review document adopted by the lead agency. Projects complying with an approved GHG emission reduction plan or GHG mitigation program would not be required to implement BPS.
• Projects implementing Best Performance Standards would not require quantification of project-specific GHG emissions. Consistent with CEQA Guidelines, such projects would be determined to have a less-than-significant individual and cumulative impact for GHG emissions.
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• Projects not implementing Best Performance Standards would require quantification of project-specific GHG emissions and demonstration that project-specific GHG emissions would be reduced or mitigated by at least 29 percent, compared to business as usual (BAU), including GHG emission reductions achieved since the 2002- 2004 baseline period. Projects achieving at least a 29 percent GHG emission reduction compared to BAU would be determined to have a less-than-significant individual and cumulative impact for GHG.
• Notwithstanding any of the above provisions, projects requiring the preparation of an Environmental Impact Report for any other reason would require quantification of project-specific GHG emissions. Projects implementing BPS or achieving at least a 29 percent GHG emission reduction compared to BAU would be determined to have a less-than-significant individual and cumulative impact for GHG.

The SJVAPCD, a CEQA Trustee Agency for this Project, has developed thresholds to determine the significance of a proposed project – either implement Best Performance Standards or achieve a 29 percent reduction from BAU (a specific numerical threshold). However, the SJVAPCD has established their BAU and baseline emissions based on the years 2002-2004 and 2020, respectively. The 2020 projected baseline has passed, and at this time, no new guidance has been approved for determining BAU and projected baseline for the next target year. Therefore, the 29 percent reduction from BAU cannot be applied to the subject Project in order to determine significance. Additionally, a Best Performance Standards threshold has not been established. For this Project, compliance with locally adopted climate plans will be used to determine the level of significance for GHG. Therefore, the GHG analysis for this Project follows the suggestions from the Court’s ruling on the Newhall Ranch development project in order to determine the significance of using the project design features.

4.2 - Project Related Emissions
This document was prepared pursuant to the SJVAPCD’s GAMAQI. The GAMAQI identifies separate thresholds for a project’s short-term (construction) and long-term (operational) emissions.

Project emissions were estimated separately for each emission source. The California Emissions Estimator Model (CalEEMod) was used to estimate emissions for both short-term, construction-related sources and long-term, operations-related sources.

Project emissions were estimated for the following development stages:
• Short-term (Construction and Demolition) – Construction emissions of the proposed Project were estimated in CalEEMod using the default construction schedule and construction equipment for the development based on the 24-month estimated timeline. (See Appendix A.)
• Long-term (Operations) – Long-term emissions were also estimated in CalEEMod using model defaults for operations of the aforementioned land use types. (See Appendix A.)
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4.2.1 - SHORT-TERM EMISSIONS
Short-term emissions from the construction phases of a project would have temporary impacts on air quality.

The construction emissions were based on the default CalEEMod equipment list for the proposed Project’s land use type and development intensity and applying model defaults as well as a conservative analysis approach. In order to be conservative construction emissions were estimated under the assumption that construction would begin in 2026. The dates entered into the CalEEMod program represent the earliest construction timeline, which would estimate the worst-case emissions as construction equipment technology and emissions improve over time; therefore, all estimated emission totals are conservative and reflect a reasonable and legally sufficient estimate of potential impacts. All construction equipment activity levels assumed were based on CalEEMod default values for type, number of equipment, hours per day and horsepower.

Adjustments to the CalEEMod default values were as follows:
• Land use lot acreage was adjusted to match the Project description. • Demolition construction phase was removed as the Project Location is open land. • Total construction period was changed to 24 months.

SJVAPCD’s required measures for all projects were also applied:
• Water exposed area three times per day.
• Reduce vehicle speed to less than 15 miles per hour on unpaved roads.

Table 4-3 presents the Project’s short-term emissions based on the anticipated construction period.

As calculated with CalEEMod, the estimated short-term construction-related emissions would not exceed SJVAPCD significance threshold levels during any given year and would, therefore, be less than significant.

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Table 4-3
Short-Term Project Emissions
Emissions Source Pollutant (tons/year)
ROG NOx CO SO2 PM10 PM2.5
Construction - 2026 0.375 2.127 3.577 0.005 0.412 0.168 Construction – 2027 3.310 1.373 2.809 0.004 0.290 0.098 Significance Threshold 10 10 100 27 15 15
Is Threshold Exceeded for a Single
Year After Mitigation? No No No No No No
Source: QK 2025

4.2.2 - LONG-TERM OPERATIONAL EMISSIONS
Long-term emissions are caused by operational mobile sources and area source emissions from the on-site building.

Fugitive Dust Emissions
Operation of the Project site at full build-out is not expected to present a substantial source of fugitive dust (PM10) emissions. The main source of PM10 emissions would be from vehicular traffic associated with the Project site.

PM10, on its own as well as in combination with other pollutants, creates a health hazard.

SJVAPCD’s Regulation VIII establishes required controls to reduce and minimize fugitive dust emissions. The following SJVAPCD Rules and Regulations apply to the proposed Project (and all projects):
• Rule 4102 – Nuisance – prohibits a facility from posing as a nuisance to surrounding receptors and can impose penalties for nuisance issues such as dust, smoke, excess emissions, etc. Compliance with this rule ensures that the area around the Project site will not be adversely impacted by such issues.
• Regulation VIII – Fugitive PM10 Prohibitions – a series of regulations to reduce and/or eliminate the generation of particulate matter (PM) that can adversely impact visibility as well as the health and safety of people on-site or in the vicinity of the Project.
o Rule 8011 – General Requirements – this rule is to reduce ambient concentrations of fine particulate matter (PM10) by requiring actions to prevent, reduce, or mitigate anthropogenic (human-caused) fugitive dust emissions.
o Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities – restricts generation of airborne dust and visibility impacts from these activities. Places limits on opacity and equipment operation under certain adverse weather conditions.
o Rule 8041 – Carryout and Trackout – requires that equipment and vehicles leaving the construction site control the amount of dirt, soil, or mud that is 1194
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tracked offsite and onto public roadways. This helps eliminate or minimize dust generation and opacity degradation.
o Rule 8051 – Open Areas – limits fugitive dust from open areas, i.e., areas on a construction site that are not actively being constructed upon but may generate wind-blown dust.

The Project would comply with applicable SJVAPCD Rules and Regulations, the local zoning codes, and additional emissions reduction measures recommended later in this analysis, in Section 7, Mitigation and Other Recommended Measures.

Exhaust Emissions
Project-related transportation activities from residents would generate mobile source ROG, NOx, SOx, CO, PM10, and PM2.5 exhaust emissions. Exhaust emissions would vary substantially from day to day but would average out over the course of an operational year. The variables factored into estimating total Project emissions include level of activity, site characteristics, weather conditions, and number of visitors. As the Project is not expected to generate an adverse change in current activity levels, substantial emissions are not anticipated. The default trip rates in CalEEMod were used along with an adjusted fleet mix to reflect SJVAPCD approved residential fleet mix for year 2026.

Projected Emissions
The proposed Project is expected to have long-term air quality impacts as shown in Table 4-

4. Emission calculations are available in Appendix A.

Table 4-4
Post-Project Max Year (Operational Emissions)
Emissions Source Pollutant (tons/year)
ROG NOx CO SOx PM10 PM2.5
Operational Emissions 7.55 3.26 23.77 0.05 3.85 1.05
SJVAPCD Threshold 10 10 100 27 15 15
Is Threshold Exceeded After
Mitigation?
No No No No No No
As shown in Table 4-4, operations-related emissions, as calculated in Appendix A, would not exceed the SJVAPCD significant threshold levels. Therefore, the Project is less-thansignificant for operational emissions.

4.3 - Potential Impacts on Sensitive Receptors
Sensitive receptors are defined as locations where young children, chronically ill individuals, the elderly, or people who are more sensitive than the general population reside, such as schools, hospitals, nursing homes, and daycare centers. The nearest residential sensitive receptor to the proposed Project is located adjacent to portions of the Project’s sites. Table 1195
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4-5 lists the known non-residential sensitive receptors within one mile of the Project site.

Discussion of health risks and risks to sensitive receptors is addressed in detail below in Section 4.6.

Table 4-5
Sensitive Receptors Located < 1 miles from Project
Receptor Type of Facility Distance from
Project (miles)
Direction
from Project
Blue Oak Academy School 0.71 E
Annie R Mitchell Elementary School School 0.46 NW
Janet’s Day Care Visalia Daycare 0.27 W
Little Rainbows Daycare Daycare 0.36 W

4.4 - Potential Impacts to Visibility to Nearby Class 1 Areas Visibility impact analyses are intended for stationary sources of emissions which are subject to the PSD requirements in 40 CFR Part 60; they are not usually conducted for area sources.

Under the PSD program, all international parks, national wilderness areas and national memorial parks that exceed 5,000 acres, and of national parks that exceed 6,000 acres are designated as mandatory federal Class I areas which are provided visibility protection under the Clean Air Act. Because the Project’s PM10 emissions increases are predicted to be less than the PSD threshold levels, an impact at any Class 1 area or military/airspace operation within 100 kilometers of the Project is extremely unlikely. Therefore, based on the Project’s predicted less-than significant PM10 emissions, the Project would be expected to have a less than significant impact to visibility at any Class 1 area or military/airspace operation.

4.5 - Potential Impacts from Carbon Monoxide
Ambient CO concentrations normally correspond closely to the spatial and temporal distributions of vehicular traffic. Relatively high concentrations of CO would be expected along heavily traveled roads and near busy intersections. CO concentrations are also influenced by wind speed and atmospheric mixing. CO concentrations may be more uniformly distributed when inversion conditions are prevalent in the valley. Under certain meteorological conditions, CO concentrations along a congested roadway or intersection may reach unhealthful levels for sensitive receptors, e.g., children, the elderly, hospital patients, etc. This localized impact can result in elevated levels of CO, or “hotspots,” even though concentrations at the closest air quality monitoring station may be below NAAQS and CAAQS.

The localized project impacts depend on whether ambient CO levels in the Project vicinity would be above or below NAAQS. If ambient levels are below the standards, a project is considered to have significant impacts if a project’s emissions would exceed one or more of these standards. If ambient levels already exceed a State standard, a project’s emissions are considered significant if they would increase 1-hour CO concentrations by 10 ppm or more 1196
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or 8-hour CO concentrations by 0.45 ppm or more. There are two criteria established by the SJVAPCD’s GAMAQI by which CO “hotspot” modeling is required:

1. A traffic study for the project indicates that the Level of Service (LOS) on one or more streets or at one or more intersections in the project vicinity would be reduced to LOS E or F.

2. A traffic study indicates that the project would substantially worsen an already existing LOS F on one or more streets or at one or more intersections in the project vicinity.

Based on the size and location of the Project, the impacted intersections and roadway segments are anticipated to operate at a LOS of C or better. Therefore, CO “hotspot” modeling was not conducted for this Project, and no concentrated excessive CO emissions are expected to be caused once the proposed Project is completed. If a subsequent traffic study indicates LOS D or worse, a hotspot analysis will be conducted.

4.6 - Predicted Health Impacts
GAMAQI recommends that Lead Agencies consider situations wherein a new or modified source of HAPs is proposed for a location near an existing residential area or other sensitive receptors when evaluating potential impacts related to HAPs.

The proposed Project would result in emissions of HAPs from construction activities and would be located near existing residents; therefore, an assessment of the potential risk to the population attributable to emissions of hazardous air pollutants from the proposed Project is required.

To predict the potential health risk to the population attributable to emissions of HAPs from the proposed Project, ambient air concentrations were predicted with dispersion modeling to arrive at a conservative estimate of increased individual carcinogenic risk that might occur as a result of continuous exposure over the construction period for construction emissions.

Similarly, predicted concentrations were used to calculate non-cancer chronic and acute hazard indices, which are the ratio of expected exposure to acceptable exposure. The basis for evaluating potential health risks is the identification of sources with increased HAPs. HAP emissions from anticipated on-site construction activities were evaluated.

Health risk is determined using the Hotspots Analysis and Reporting Program (HARP) software distributed by the CARB. HARP2 requires peak 1-hour emission rates and annualaveraged emission rates for all pollutants for each modeling source. The assumptions used to calculate the emission rates for the proposed Project are outlined below.

The most recent version of EPA’s AMS/EPA Regulatory Model – AERMOD (recompiled for the Lakes ISC-AERMOD View) was used to predict the dispersion of emissions from the proposed Project. The analysis employed all of the regulatory default AERMOD model keyword parameters, including elevated terrain options. 1197
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