An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative.

Transcription

1 5.0 ALTERNATIVES This chapter sets forth alternatives to the 2018 RTP/SCS and provides an analysis of each alternative and a comparison of each alternative s impacts to the proposed Project s impacts. Key provisions of the State CEQA Guidelines Section pertaining to an EIR alternatives analysis are summarized below. An EIR shall describe a range of reasonable alternatives to the project, or the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider any conceivable alternative to a project. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment, the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly. The range of alternatives required in an EIR is governed by a rule of reason That requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The No Project Alternative should be evaluated along with its impacts to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. The No Project Alternative analysis shall discuss the existing conditions at the time the notice of preparation is published, as well as what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative. Among the factors that may be taken into account when addressing the feasibility of alternatives (as described in State CEQA Guidelines Section [f][1]) are environmental impacts, site suitability, economic viability, availability of infrastructure, general plan consistency, regulatory limitations, and jurisdictional boundaries. An EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are feasible, and, therefore, merit in-depth consideration. Alternatives may be eliminated from detailed consideration in the EIR if they fail to meet project objectives, are infeasible, or do not avoid any significant environmental effects. Impact Sciences, Inc TCAG RTP/SCS PEIR

2 5.1 PROJECT IMPACTS AND OBJECTIVES Project Impacts As described in Section 4.0 of this PEIR, implementation of the 2018 RTP/SCS would result in significant and unavoidable impacts to the following: Aesthetics: Implementation of the 2018 RTP/SCS would have a substantial adverse effect on a scenic vista (Impact AES-1) and would impair views of scenic resources such as mountains, rivers or significant manmade structures as seen from existing transportation facilities or other key public vantage points in Tulare County and alter the appearance of designated scenic resources along or near a state or County designated scenic highway or vista point (Impact AES-2). In addition, construction and implementation of the projects associated with the 2018 RTP/SCS could create significant contrasts with the visual character of the existing landscape setting (Impact AES-3), as well as create a new source of substantial light or glare, which could affect day or nighttime views (Impact AES-4). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Agricultural Resources: Implementation of the projects and land use strategies in the 2018 RTP/SCS would result in the conversion of prime, unique farmland or farmland of statewide importance to nonagricultural uses, either directly (Impact AG-1) or through other changes in the existing environment (impact AG-4). Additionally, the iimplementation of the projects and land use strategies in the 2018 RTP/SCS would result in development of agricultural lands (with active Williamson Act contracts) (Impact AG-2), and impact forest lands (Impact AG-3) The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Air Quality: Implementation of the 2018 RTP/SCS would result in a substantial increase in short-term emissions of criteria pollutants (construction of transportation and land use projects and) (Impact AIR-1), as well as an increase (greater than current emission levels) in projected long-term emissions of toxic air contaminants (diesel particulate matter from heavy duty trucks and other emissions from industrial activities);localized concentrations of toxic air contaminants at sensitive receptors (short term and long term) could be greater than existing conditions. (Impact AIR-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Biological Resources: Implementation of the 2018 RTP/SCS would have a substantial adverse effect on sensitive and special status wildlife and plant species (Impact BIO-1). It would also have a substantial adverse effect on riparian habitat and other sensitive natural communities (Impact BIO-2), and on federally-protected wetlands (Impact BIO-3), as well as on wildlife migration and migratory corridors (Impact BIO-4). Additionally, implementation of the 2018 RTP/SCS would conflict with local plans, Impact Sciences, Inc TCAG RTP/SCS PEIR

3 policies, (Impact BIO-5), and provisions of an HCP or NCCP (Impact BIO-6). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Cultural Resources: The Plan would result in the consumption of 8,884 acres of vacant land and focuses much of the growth in urban areas. The focused growth in urban areas could lead to significant impacts on historic structures (Impact CR-1). The consumption of undeveloped land would result in a significant risk of uncovering previously undisturbed archeological (Impact CR-2) and paleontological resources (Impact CR-3) resources, as well as human remains (Impact CR-4) and tribal cultural resources (Impacts TCR-1 and TCR-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Greenhouse Gas Emissions: Implementation of the 2018 RTP/SCS would directly and indirectly causes increases in GHG emissions over existing levels (Impact GHG-1), and would conflict with the State s ability to achieve emission reductions targets set by SB 32 and EO-S-3-05 (Impact GHG-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable.. Land Use: Implementation of the projects and land use pattern in the 2018 RTP/SCS could result in inconsistencies with currently applicable adopted local land use plans and policies including general plans, specific plans, or zoning ordinances Impact LU-1). Projects associated with the Plan have the potential to disrupt or divide established communities (Impact LU-2) and conflict with HCPs or NCCPs (Impact LU-3). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Noise: Projects associated with the Plan could expose persons or generate noise in levels in excess of standards established in the local general plan or noise ordinance (Impact NOISE-1), result in substantial temporary or periodic increases in ambient noise levels above existing levels (Impact NOISE-2), or result in a substantial permanent increase in ambient noise levels (Impact NOISE-3). The Plan also would expose people to or generate excessive groundborne vibration (Impact NOISE-4). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Population, Housing and Employment: The transportation investments and land use patterns in the 2018 RTP/SCS would foster economic and household growth and would remove some obstacles to growth in some parts of the region (Impact POP-1). The 2018 RTP/SCS would also require the acquisition of rights-of-way that could displace existing homes or businesses (Impact POP-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Public Services: Existing parks and recreational facilities and services would become overextended due to projected growth during the lifetime of the 2018 RTP/SCS resulting in substantial physical Impact Sciences, Inc TCAG RTP/SCS PEIR

4 deterioration (Impact REC-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Transportation: Implementation of projects included in the 2018 RTP/SCS would substantially increase total daily VMT in 2042 compared to current daily VMT (Impact TR-1). The 2018 RTP/SCS would increase congestion, and thus the 2018 RTP/SCS has the potential to conflict with the CMP (Impact TR-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Utilities: Energy: The 2018 RTP/SCS would result in the use of substantial amounts of electricity and natural gas, thereby requiring the construction of new facilities and new sources of energy or major improvements to local infrastructure (Impact ENERGY-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Wastewater: Implementation of the 2018 RTP/SCS would increase population which could result in exceeding the capacity of the existing wastewater treatment systems resulting in the need for new or expanded infrastructure (Impacts WW-2 and WW-3). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Solid waste: Implementation of the 2018 RTP/SCS could result in an increase in the amount of solid waste that could exceed the region s available landfill capacity to handle and dispose of the waste (Impact SW-2). The 2018 RTP/SCS s contribution to such impacts would also be cumulatively considerable. Water Supply and Hydrology: Implementation of the 2018 RTP/SCS would degrade local surface water quality due to increased runoff from transportation and development projects, potentially resulting in violations of water quality standards or waste discharge requirements (Impact W-1). New development could substantially deplete existing groundwater supplies, and increased impervious surfaces would reduce groundwater infiltration, reducing recharge and potentially affecting aquifer volume (Impact W- 2). The Plan would contribute to the conversion of undeveloped land to urban areas, substantially altering drainage patterns, including potentially altering stream courses such that substantial erosion or siltation could occur (Impact W-3). Substantially alterations of existing drainage patterns, including alteration of the course of a stream or river, could result in flooding (Impact W-4). Also, the 2018 RTP/SCS would create or contribute substantial runoff water that could exceed the capacity of existing or planned stormwater drainage systems; in addition, this runoff could include substantial pollution (Impact W-5). The 2018 RTP/SCS could otherwise degrade water quality as a result of a variety of activities including agricultural, industrial and urban runoff (Impact W-6). A portion of the transportation projects and land use developments under the 2018 RTP/SCS could take place within 100- year flood hazard areas; therefore the 2018 RTP/SCS could result in housing being placed within a 100- year flood hazard area (Impact W-7) or result other structures that could impede or redirect flows (Impact Impact Sciences, Inc TCAG RTP/SCS PEIR

5 W-8). In addition, the increased urbanization would contribute to an increased demand for water supply, requiring new or expanded entitlements (Impact W-9). The 2018 RTP/SCS s contribution to such water supply and hydrology impacts would also be cumulatively considerable Project Objectives The objectives of the 2018 RTP/SCS are as follows: 1 Provide an efficient, integrated, multi-modal transportation system for the movement of people and goods that enhances the physical, economic, and social environment in the Tulare county region System Performance: Develop an efficient, maintained, and safe circulation network that maximizes circulation, longevity, and fiscal responsibility while minimizing environmental impacts. Transit: Provide a safe, secure, coordinated and efficient public transit system that can reasonably meet the needs of residents. Aviation: Support development of a regional system of airports that meets the air commerce and general aviation needs of the county. Rail: Promote safe, economical, convenient rail systems and schedules that meet the needs of passenger and freight services in the region. Goods Movement: Provide a transportation system that efficiently and effectively transports goods to, from, within, and through Tulare County. Active Transportation: Improve, enhance, and expand the region s bicycle and pedestrian systems and connectivity to those systems, while keeping them safe and convenient. Regional Roads and Corridors: Preserve and enhance regional transportation roads and corridors. Air Quality and Greenhouse Gases: Promote the improvement of air quality and GHG reductions through congestion management, coordination of land use, housing, and transportation systems, provision of alternative modes of transportation, and provision of incentives that reduce vehicle miles traveled. Public Health: Promote public health in the region by providing opportunities for residents to bicycle and walk to destinations such as home, work, school, medical facilities, and commercial and service businesses. TSM Strategies, TDM Measures, TCMS, and ITS Programs: Improve transportation mobility and operations by improving and utilizing TSM strategies, TDM measures, TCMS and ITS programs. Environmental Justice: Ensure that transportation investments do not discriminate on the basis of race, color, national origin, sex, age or disability. 1 TCAG 2018 RTP/SCS Goals and Objectives Impact Sciences, Inc TCAG RTP/SCS PEIR

6 Emerging Technologies: Support the development and implementation of emerging technologies in the surface transportation system. SCS: Develop an integrated land use plan that meets CARB targets. A feasible alternative must meet most of the basic project objectives. 5.2 ALTERNATIVES TO THE PROPOSED PROJECT The State CEQA Guidelines state that an EIR should identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are (i) failure to meet most of the basic project objectives, (ii), infeasibility, or (iii) inability to avoid significant environmental impacts. (State CEQA Guidelines Section (a)(c).) For this EIR, there were no alternatives that were considered by TCAG and rejected as infeasible during the scoping process Alternative 1 No Project The No Project Alternative is required by Section (e)(2) of the State CEQA Guidelines and assumes that the 2018 RTP/SCS would not be implemented. The No Project Alternative allows decision-makers to compare the impacts of approving the proposed Project with the impacts of not approving the proposed Project. However, no project does not mean no development. The No Project Alternative includes what would be reasonably expected to occur if the Project were not approved, based on current plans and consistent with available infrastructure and community services. 2 For purposes of this PEIR, the No Project Alternative includes only those transportation projects that are included in the first year of the constrained project list included in the 2014 RTP/SCS and/or transportation improvement program (TIP), or have completed environmental review by January The growth scenario included in the No Project Alternative is based on local general plans and assumes a land use pattern that is more dispersed than the Blueprint (or the Old Plan) along the lines of past trends Alternative 2 Trend Alternative The Trend Alternative includes a land use forecast based on designations from existing local agency general plans and linear trends in growth on a sub-regional basis. This means that the projected pattern of development will be generally consistent with the development pattern seen currently. (Local general plans now include policies that will move away from the Trend Alternative to some extent -- away from a 2 State CEQA Guidelines [e][2] Impact Sciences, Inc TCAG RTP/SCS PEIR

7 pure extrapolation of current development types and densities. This is especially true of the most recently updated plans (Porterville, 2007; Tulare County, 2012; Tulare, Visalia, 2014).) This alternative includes a modified transportation network with fewer investments (no new transit) as compared to the 2018 RTP/SCS and greater focus on maintenance of the existing network Alternative 3 Old Plan Alternative The Old Plan Alternative is a second type of no project alternative, based on implementation of the current 2014 RTP. The Old Plan Alternative is an update of the adopted 2014 RTP reflecting the most recent growth distribution and transportation planning decisions and assumptions, extrapolated from the 2040 horizon year in the 2014 RTP/SCS out to 2042, the horizon year of the 2018 RTP/SCS. This Old Plan alternative includes many of the same development pattern strategies included within the 2018 SCS, and includes all of the transportation projects in the 2014 RTP Alternative 4 Blueprint Plus The Blueprint Plus Alternative was requested by the RTP Roundtable 3 in 2013 to explore the ramifications of a change in future development patterns more pronounced than that envisioned by the Regional Blueprint. Blueprint Plus has an objective of overall density of new development five percent higher than Blueprint and a maximum feasible emphasis on transit and active transportation modes Summary Comparison A summary comparison of impacts of the 2018 RTP/SCS and alternatives is included in Table 5.0-1, Comparison of Impact Significance Plan vs. Alternatives. Please note that this table and the following text compare all impacts of the 2018 RTP/SCS analyzed in Chapter 4 to impacts of the alternatives, including less than significant Plan impacts. This table does not separately compare cumulative impacts of the 2018 RTP/SCS and alternatives, but the alternatives would have similar incremental contributions to cumulative impacts (i.e., less, similar, or greater). 3 The RTP Roundtable Committee includes a range of important stakeholders who guide the RTP process and made recommendations to the TCAG Governing Board with respect to RTP/SCS policies and ultimately the preferred Blueprint Scenario. Impact Sciences, Inc TCAG RTP/SCS PEIR

8 Table Comparison of Impact Significance Plan vs. Alternatives Impact Project Impact Alternative 1 No Project Alternative Alternative 2 Trend Alternative Alternative 3 Old Plan Alternative 4 Blueprint Plus Aesthetics AES -1 Scenic Vistas Significant Less AES-2 Scenic Resources Significant Less AES-3 Visual Character Significant AES-4 Light and Glare Significant Less Agriculture and Forest Lands AG-1 Convert Farmland Significant Less Less AG-2 Conflict with Land Use/Williamson Act Significant Less Less AG-3 Convert Forest land Significant (less than (less than (less than significant Less AG-4 Changes in Environment Convert Farmland Significant Less Air Quality AIR-1 Long Term Criteria Pollutants Less than Significant (Less than Significant) (Less than Significant) (Less than Significant) (less than AIR-1 Short Term Criteria Pollutants Significant Less Less Less AIR-2 Long Term Regional Air Toxics Significant Less AIR-2 Short Term Air Toxics Significant Less Less Less AIR-3 Consistent with Air Quality Plans Less than Significant (less than (less than (less than (less than Biological Resources BIO-1 Sensitive Species Significant BIO-2 Riparian Communities Significant Less BIO-3 Wetlands Significant Less BIO-4 Migratory Species Significant BIO-5 Local policies Significant BIO-6 HCPs Significant Less Cultural Resources CR-1 Historical Resources Significant Less Less Less Impact Sciences, Inc TCAG RTP/SCS PEIR

9 Impact Project Impact Alternative 1 No Project Alternative Alternative 2 Trend Alternative Alternative 3 Old Plan Alternative 4 Blueprint Plus CR-2 Archeological Resources Significant Less CR-3 Paleontological Resources Significant Less CR-4 Disturb Human Remains Significant Less TCR1/TCR-2 Tribal Cultural Resources Significant Less Greenhouse Gas Emissions GHG-1 Significantly Increase GHG Emissions Significant Less GHG-2 Conflict with Applicable Plans, Policies, and Regulations Significant Less Land Use LU-1 Conflict with Plans Significant Less LU-2 Divide a Community Significant Less LU-3 Conflict with HCPs (BIO-6) Significant Less Noise NOISE -1 Expose Persons to Noise Levels in Excess of Established Standards Significant NOISE-2 Substantial Temporary or Periodic Increase in Noise Significant Less Less Less NOISE-3 Substantial Permanent Increase in Noise Significant NOISE-4 Groundborne Noise and Vibration Significant NOISE-5/NOISE-6 Airport Noise Less than Significant (less than (less than (less than (less than Population, Housing, and Employment POP-1 Induce Population Growth Significant POP-2 Displacement Significant Public Services Fire & Police FIRE_1 Construction of New Facilities Less than Significant (less (less than (less than (less than POLICE-1 Construction of New Facilities Less than Significant (less (less than (less than (less than EDU-1 Construction of New Facilities Less than Significant (less (less than (less than (less than REC-1 Construction of New Facilities Less than Significant (less (less than (less than Less (less than REC-2 Deterioration of Facilities Significant Less Less (less than (less than Impact Sciences, Inc TCAG RTP/SCS PEIR

10 Impact Project Impact Alternative 1 No Project Alternative Alternative 2 Trend Alternative Alternative 3 Old Plan Alternative 4 Blueprint Plus Transportation and Traffic TR-1 Substantial Increase in VMT Significant Less TR-2Conflict with CMP Significant Less TR-3 Change Air Traffic Less than significant (less than (less than (less than (less than TR-4 Increase Design Hazards Less than significant (less than (less than (less than (less than TR-5 Inadequate Emergency Access Less than significant (less than (less than (less than (less than TR-6 Conflict with Policies Less than significant Significant (greater) Significant (greater) Significant (greater) Less (less than Utilities Energy ENERGY-1 Conflict with Adopted Plans Less than significant (less than (Significant) Less ENERGY-1 Wasteful Use of Energy Less than significant (less than (Significant) Less ENERGY-2 Construction of New Facilities Significant (Significant) Less Utilities Wastewater WW-1 Exceed Wastewater Treatment Requirements Less than significant (Less than (Less than (Less than (Less than WW-2 Construction of New Facilities Significant (Significant) WW-3 Exceed the Capacity of Existing or Planned Facilities Significant Utilities Solid Waste SW-1 Generate Solid Waste Exceeding landfill capacity Significant (Significant) Less SW-2 Comply with Regulations Less than significant (less than (less than (less than (less than Water Supply and Hydrology W-1 Violate Water Quality Standards Significant W-2 Interfere with Groundwater Recharge Significant W-3 Erosion and Sedimentation Significant W-4 Flooding and Floodplains Significant W-5 Exceed Stormwater Drainage Capacity Significant Less W-6 Degrade Water Quality Significant W-7 Housing in 100-year Flood Hazard Areas Significant W-8 Structures in 100-year Flood Hazard Areas Redirecting Flow Significant Impact Sciences, Inc TCAG RTP/SCS PEIR

11 Impact Project Impact Alternative 1 No Project Alternative Alternative 2 Trend Alternative Alternative 3 Old Plan Alternative 4 Blueprint Plus W-9 Substantial increase in demand for water Significant Less Source: Impact Sciences, Analysis of Alternative 1 No Project Alternative Aesthetics Scenic Vistas and Resources Since the No Project Alternative includes fewer transportation projects than the proposed RTP/SCS, it would have less of an impact in terms of obstructing views and scenic resources. The No Project Alternative would not affect any eligible State Scenic Highways or County designated scenic highways, while the Plan includes projects located near scenic highways which could result in impacts. The No Project Alternative visual impacts would be greater than the Plan impacts for Impacts AES-1 because of the increased consumption of open space, vacant land, and interspersed transportation infrastructure. Visual Character Since the No Project Alternative includes fewer transportation projects than the proposed RTP/SCS, it would have less of an impact in terms of adding contrasting visual elements to existing natural, rural, and open space areas. The Plan includes strategies to focus growth in TPAs, which would help reduce the consumption and disturbance of natural lands and reduce impacts to visual character. Under the No Project Alternative, these land use strategies may not occur, although individual jurisdictions may still seek to reduce the urban footprint through their general plans. The Plan includes transportation improvements that facilitate access to undeveloped lands, making those lands more attractive for development than under the No Project Alternative; however, the Plan includes policies to dissuade such encroachment on open space and vacant lands and would result in far fewer impacts to open space. The land use planning strategies included in the proposed RTP/SCS would reduce consumption of vacant, open space/recreation and agricultural lands compared to the No Project Alternative (about 8,884 acres under the Plan and about 10,525 acres under the No Project Alternative). The No Project Alternative visual impacts would be greater than the Plan impacts for Impacts AES-2 because of the increased consumption of open space, vacant land, and interspersed transportation infrastructure. Impact Sciences, Inc TCAG RTP/SCS PEIR

12 Light and Glare The Plan includes strategies to focus growth in TPAs, which would help reduce impacts associated with light and glare by focusing development in urbanized areas. The plan does not specifically address lighting impacts, therefore, any policies to address light and glare would be implemented at the local level. Jurisdictions may also still seek to reduce the urban footprint through their general plans which would also reduce lighting impacts. The No Project Alternative visual impacts would be greater than the Plan impacts for Impacts AES-3 because of the increased consumption of open space, vacant land, and interspersed transportation infrastructure. Agricultural Resources Farmland Under the No Project Alternative, the population of the TCAG region would still increase by 133,127 people by 2042, however no regional transportation investments would be made above the existing programmed projects. The population distribution would follow past trends, uninfluenced by the Plan s emphasis on urban infill. The No Project Alternative includes fewer transportation projects than the Plan, and there would be no regional policies to focus development in existing urban areas and avoid agricultural land. The No Project Alternative would result in 10,525 acres of land consumed compared to 8,884 acres consumed under the Plan. The No Project Alternative would also result in 2,310.6 acres of farmland consumed compared to 1,518.3 under the Plan. Impacts under the No Project Alternative would be greater than the proposed 2018 RTP/SCS for Impacts AG-1, because of the increased consumption of agricultural, forest, and timberland land and the lack of a comprehensive regional plan. Williamson Act Initially, the No Project Alternative would have less potential for creating conflicts with General Plans and other land use regulations, as the only growth strategies that would occur would be subject to local land use controls. However, over time and without a regional strategy, there would be less influence on a coordinated pattern of development. Thus, the No Project Alternative could ultimately result in a more dispersed land use pattern across the region, which could have greater impacts related to conversion of agricultural land and create conflicts with Williamson Act contracts. The No Project Alternative includes fewer transportation projects than the Plan, and there would be no regional policies to focus development in existing urban areas and avoid Williamson Act lands. However, state and federal laws and locallyapproved plans and policies currently in place would continue to protect these resources. Impacts under the No Project Alternative would be greater than the proposed 2018 RTP/SCS for Impacts AG-2 because Impact Sciences, Inc TCAG RTP/SCS PEIR

13 of the increased consumption of agricultural, forest, and timberland land and the lack of a comprehensive regional plan. Forest and Timberland The No Project Alternative would accommodate the same increase in total population, households, and jobs as the Plan. However, the proposed 2018 RTP/SCS includes strategies to focus growth in TPAs which would help reduce the consumption and disturbance of natural lands and reduce impacts to forest lands, and timberland. Impacts under the No Project Alternative would be greater than the proposed 2018 RTP/SCS for Impacts AG-3, because of the increased consumption of agricultural, forest, and timberland land and the lack of a comprehensive regional plan. Changes in Environment Convert Farmland The 2018 RTP/SCS would direct more growth to already urbanized areas, thereby reducing the amount of agricultural lands that would be converted to non-agricultural uses. Under the No Project Alternative, this growth pattern would not occur and a greater amount of agricultural lands could be converted to non-agricultural uses. The No Project Alternative would not increase mobility choices and capacity within urban areas. Therefore, the pressure would be reduced under this alternative to convert agricultural lands located near the periphery of these built-out areas to urban land uses could increase as transportation improvements are made. Nevertheless, the impact from changes in environment which would result in conversion of farmland would be greater under this alternative. Air Quality Criteria Air Pollutants Short-Term Emissions Short-term construction emissions of criteria pollutants would occur with implementation of the No Project Alternative. These construction activities would result in short-term emissions of air pollutants including ROG, NOx, PM10, PM2.5 and fugitive dust. The sources associated with these emissions include construction equipment, employee and vendor vehicles, demolition, grading and other grounddisturbing activities, application of paint and other coatings, paving, and others. The level of emissions is generally proportional to the size of the construction project, with larger projects typically resulting in larger emissions during construction. Countywide, it is likely that more than one project would be under construction at any one time, resulting in greater emissions. However, short-term emissions would be Impact Sciences, Inc TCAG RTP/SCS PEIR

14 reduced as compared to the 2018 RTP/SCS due to the reduction in transportation construction projects related to implementation of the 2018 RTP/SCS. Long-Term Emissions Emissions of long-term criteria pollutants from mobile sources would be affected by implementation of the No Project Alternative. In order to analyze the net impact of implementation, existing year (2017) emissions were compared to horizon year (2042) emissions. Results of modeling are presented in Table 5.0-2, Criteria Pollutant Emissions from Mobile Sources. As shown, both the Plan and the No Project Alternative would result in reductions of reactive organic gases (ROG), sulfur oxides (SOx), oxides of nitrogen (NOx) and carbon monoxide (CO), and reductions of emissions of fine particulate matter (PM2.5). These would be beneficial impacts. Emissions of respirable particulate matter (PM10) from mobile sources show a slight increase over existing conditions. However, as shown in Table 5.0-2, the 2018 RTP/SCS would result in greater reductions (i.e., fewer total emissions) for ROG, NOx, CO, PM2.5, and SOx. PM10 would increase under both Alternatives. Therefore, impacts related to criteria pollutants would be greater under the No Project Alternative. Table Criteria Pollutant Emissions from Mobile Sources No Project Alternative (2042) vs. Plan (2042) Scenario Tons/Day ROG NOx CO PM10 PM2.5 SOx Existing RTP/SCS RTP/SCS Net No Project No Project Net Source: TCAG 2018, EMFAC14. A conformity analysis was prepared for the 2018 RTP/SCS that analyzes emissions of ozone precursors (ROG and NOx), CO, PM10 and PM2.5 compared to the approved emissions budgets for mobile sources in Tulare County. The analysis found that emissions of all pollutants under the Plan passed the applicable conformity tests and would be in conformity with the State Implementation Plans (SIPs). However, both the Plan and No Project Alternatives would generate greater PM10 emissions by Consequently, the impact from PM10 emissions would be a significant impact. However, the 2007 PM-10 Maintenance Plan allows for trading of NOx and PM10 emissions at a 1.5 to 1 ratio. Since the PM10 increase associated with the Plan and No Project alternative are relatively small, this would allow PM10 emissions to pass the Impact Sciences, Inc TCAG RTP/SCS PEIR

15 conformity test under this alternative. Consequently, the increase would not be considered substantial, and the impact related to criteria pollutant emissions would remain less than significant. Toxic Air Contaminants Short-Term Emissions The specific location of future construction activity within the County was not known when the air quality analysis was completed, and therefore many variables related to characterizing potential exposures to air toxics during construction activities could not be determined, such as proximity to the emissions sources and duration of exposure. A construction health risk analysis would be speculative given the lack of a construction location and construction activities. However, it is reasonable to assume that some level of construction activity would occur adjacent to sensitive receptors (e.g., residences and schools). The significant construction emissions identified above could result in adverse health effects to sensitive receptors. As such, it is likely that intense construction activities (e.g., from development projects that involve a high volume of haul trucks) would exceed the health risk significance thresholds due to equipment and truck exhaust emissions. However, short-term construction emissions would be reduced under the No Project Alternative due to a reduction of transportation project construction activity within Tulare County as compared to the 2018 RTP/SCS. Long-Term Emissions Diesel particulate matter (DPM) generated from diesel-fueled engines and found in diesel exhaust, has been determined by CARB to be a toxic air contaminant as defined under Section of the Health and Safety Code. The long-term health effects of DPM include cancer, increased incidences of asthma, allergies, and respiratory disease and the short-term health impacts include dizziness, headaches, nausea, and irritation of the eyes, nose, and throat. PM2.5 emissions will be used as a proxy for DPM emissions in this analysis as further described in Section, 4.3 Air Quality. As shown in Table 5.0-2, above, emissions of PM2.5 for all mobile sources will be reduced under the No Project Alternative. However, in order to more closely approximate DPM emissions, PM2.5 emissions specifically from heavy-duty diesel vehicles were estimated. The emissions generated under existing conditions as compared to the No Project Alternative are shown in Table 5.0-3, PM2.5 Emissions from Heavy Duty Diesel Vehicles. Impact Sciences, Inc TCAG RTP/SCS PEIR

16 Table PM2.5 Emissions from Heavy Duty Diesel Vehicles (tons/day) No Project (2042) vs. Plan (2042) Existing Plan 2042 No Project Alternative Source: TCAG 2018, EMFAC14 As shown in Table 5.0-3, the No Project Alternative would generate similar PM2.5 emissions compared to the 2018 RTP/SCS but would be less than under existing conditions. CARB has several programs and regulations in place to reduce DPM emissions state-wide. This includes enforced retrofit of diesel particulate filters, replacement of older trucks and buses, requirements for lower emissions on new diesel vehicles, inspection programs, idling restrictions, and other programs for marine and off-road diesel vehicles. These programs and regulations would reduce DPM emissions over the period of the 2018 RTP/SCS. Consequently, it can be assumed that the reductions in PM2.5 emissions include reductions in DPM emissions region-wide. However, on a case-by-case basis RTP/SCS transportation improvements may also bring sources of DPM closer to sensitive receptors through construction of new facilities or widened roadways, which could increase exposure of sensitive receptors. To provide a qualitative measure of this impact, highways in Tulare County were given an Air Quality Index (AQI), based on three factors: (1) average daily traffic (2) percentage of truck traffic and (3) level of service (which is a measure of traffic delays). A high index indicates that a roadway has a relatively high amount of traffic and percentage of trucks with a low level of service. A low index reflects a relatively low amount of traffic with fewer trucks, and a high level of service. Medium would be somewhere between high and low. In this way, a high index would qualitatively show a higher health risk as well, since roadways with a high index would tend to have higher DPM concentrations due to the higher number of trucks and lower traffic speeds. The indices for highways in Tulare County and locations of sensitive receptors under existing conditions, 2018 RTP/SCS, and the No Project Alternative are shown in Figures through There are more highways identified as having a higher AQI rank under the No Project Alternative versus the existing conditions in The total receptors affected by higher AQI highways for the No Project Alternative would be less than the 2018 RTP/SCS. Regarding sensitive receptor locations, the 2018 RTP/SCS would locate more housing, and schools near higher traffic highways, but would not change the amount of hospitals near high AQI highways. However, under the No Project Alternative, there would be less hospitals located near medium AQI highways. Therefore, this qualitative measure indicates that an Impact Sciences, Inc TCAG RTP/SCS PEIR

17 increased heath risk impact could result from implementation of the 2018 RTP/SCS as more sensitive receptors would be located relatively close to increased truck traffic. Although PM2.5 emissions would be reduced in Tulare County under the No Project Alternatives, more sensitive receptors located next to highways in 2042 than under existing conditions. The projected higher volume of truck traffic would potentially be increased health risk to certain populations in Tulare County. In addition, given the lack of data regarding industrial and other stationary sources of TACs, it is unknown whether these sources would result in increased emissions of TACs in 2042 compared to existing conditions, and therefore it is unknown what their impact on health risks in Tulare County would be. Consequently, this impact would be considered significant. Overall impacts from the No Project alternative would be similar to those under the 2018 RTP/SCS, but would remain significant. Biological Resources Species Identified as a Candidate, Sensitive, or Special-Status Species The No Project Alternative would result in a less concentrated growth pattern, which would affect a greater amount of vacant land and critical habitat. The No Project would result in the consumption of 176 acres of critical habitat and 10,525 acres of vacant land, while the 2018 RTP/SCS would result in the consumption of 144 acres of critical habitat and 8,884 acres of vacant land 4. As such a greater number of sensitive species could be affected under the No Project. No Project impacts would be greater than the plan. Sensitive Natural Communities and Federally-Protected Wetlands Because the No Project Alternative includes a greater amount of critical habitat consumed and a more dispersed land use pattern, it is likely that a greater amount of wetlands and sensitive natural communities would be affected with the No Project than under the Plan. Wildlife Movement Direct impacts to wildlife movement include increased noise and human presence during construction, as well as increased trash, which may attract predators to the project site and discourage wildlife use of surrounding natural habitat. Increased roadway traffic, due to the division of habitat and corridors, may affect surrounding wildlife and lead to increased wildlife mortality. The No Project Alternative includes fewer projects (such as widenings) than the 2018 RTP/SCS and therefore would be less likely to result in direct impacts to wildlife movement; however, the more dispersed growth pattern of the No Project could 4 TCAG 2018, Envision Tomorrow, SJV Greenprint Impact Sciences, Inc TCAG RTP/SCS PEIR

18 result in greater impacts to wildlife movement by habitat modification. Therefore, impacts under the No Project would be significant and similar to the 2018 RTP/SCS. Preservation Plans The No Project Alternative would result in greater vacant land and critical habitat consumption that would increase biological resources impacts and the potential to conflict with ordinances and plans regarding biological resources. This impact would be greater than impacts under the 2018 RTP/SCS. Cultural Resources Historical Resources The proposed 2018 RTP/SCS would result in concentration of development in previously developed urban areas, which could lead to greater impacts to historic structures, such as those located in downtown historic districts. However, many communities, including the County and the City of Visalia, have in place policies to protect historic resources, and even under the No Project Alternative, these areas could still redevelop, although possibly not at the same intensity as under the plan. Therefore, the No Project impacts would be lesser than the Plan s impacts, but would likely still be significant and development in historic cores would continue to occur. All projects (including those under the No Project Alternative and Project) would be required to comply with the same local, state, and federal regulations in place to protect identified cultural resources. Archeological Resources Under the No Project Alternative, fewer areas would be impacted by excavation and construction activities related to transportation projects because there would be fewer transportation projects. However, the No Project Alternative would result in a less concentrated form of growth, which would affect an increased amount of currently undisturbed land (10,525 acres as compared to 8,884 acres with the proposed Project). Thus, the No Project Alternative would result in greater vacant land consumption that could, in turn, increase the chance to uncover a greater number of previously undisturbed resources, including archeological resources. Impact would be significant. Paleontological Resources Under the No Project Alternative, fewer areas would be impacted by excavation and construction activities related to transportation projects because there would be fewer transportation projects. However, the No Project Alternative would result in a less concentrated form of growth, which would affect an increased amount of currently undisturbed land (10,525 acres as compared to 8,884 acres with Impact Sciences, Inc TCAG RTP/SCS PEIR

19 the proposed Project). Thus, the No Project Alternative would result in greater vacant land consumption that could, in turn, increase the chance to uncover a greater number of previously undisturbed resources, including paleontological resources. Impacts would be significant. Human Remains Under the No Project Alternative, fewer areas would be impacted by excavation and construction activities related to transportation projects because there would be fewer transportation projects. However, the No Project Alternative would result in a less concentrated form of growth, which would affect an increased amount of currently undisturbed land (10,525 acres as compared to 8,884 acres with the proposed Project). Thus, the No Project Alternative would result in greater vacant land consumption that could, in turn, increase the chance to uncover a greater number of previously undisturbed resources, including human remains. Impacts would be significant. Tribal Cultural Resources Under the No Project Alternative, fewer areas would be impacted by excavation and construction activities related to transportation projects because there would be fewer transportation projects. However, the No Project Alternative would result in a less concentrated form of growth, which would affect an increased amount of currently undisturbed land (10,525 acres as compared to 8,884 acres with the proposed Project). Thus, the No Project Alternative would result in greater vacant land consumption that could, in turn, increase the chance to uncover a greater number of previously undisturbed resources, including tribal cultural resources. Impacts would be significant. Greenhouse Gas Emissions GHG Emissions Estimates The 2018 RTP/SCS includes strategies aimed at increasing the density of land use in Tulare County, thereby reducing per capita VMT and GHG emissions. In all analysis years, emissions would be higher under the No Project Alternative. The first significance threshold for GHG emissions is whether the project would result in emissions that could have a significant impact on the environment. In 2042 mobile source emissions would be 1,669,134 MTCO2e/yr under the No Project Alternative, compared to 1,664,730 MTCO2e/yr under the 2018 RTP/SCS, which is a 0.3 percent increase compared to the 2018 RTP/SCS. Mobile source emissions under 2017 existing conditions are approximately 2,229,808 MTCO2e/yr. 5 Both alternatives would result in greater GHG mobile source emissions than under existing conditions. 5 TCAG, 2018 and EMFAC14 Impact Sciences, Inc TCAG RTP/SCS PEIR

20 The 2018 RTP per capita GHG emissions from cars and light duty trucks would be reduced by 12.8 percent in 2020 and 16.6 percent in 2035 compared to the SB base year. This compares with reductions of 12.1 percent, and 16.1 percent respectively for the No Project Alternative. Consequently, TCAG would meet its targets for GHG reductions under SB 375 with and without the 2018 RTP/SCS. Therefore, impacts would be less than significant for SB 375 and AB 32 for both the Plan and No Project Alternative. The second significance threshold for GHG emissions is whether the project would result in greater emissions than under existing conditions (i.e., would emissions in 2042 be greater than in 2017). As shown in Table 5.0-4, in 2042 daily mobile source GHG emissions would be 4,573 metric tons of CO2 equivalents (MTCO2e) under the No Project Alternative, compared to 4,561 MTCO2e under the 2018 RTP/SCS. The No Project Alternative would generate less emissions than under existing conditions, but generate more emissions compared to the 2018 RTP/SCS. Table Per Capita GHG Mobile Source Emissions (1990, 2005, 2017, 2042) Source Population Total Mobile Source Emissions (MTCO2e/Day) GHG Per Capita (Pounds/Day of CO2e) % GHG Per Capita Reduction from 2017 (MTCO2e/Year) 1990 Conditions 311,921 5, N/A 2005 Conditions 404,148 6, N/A 2017 Existing Conditions 471,842 6, N/A 2042 No Project Alternative 604,969 4, % 2042 Old Plan Alternative 604,969 4, % 2042 Trend Alternative 604,969 4, % 2042 RTP/SCS 604,969 4, % 2042 Blueprint Plus Alternative 604,969 4, % Note: 1990 emissions estimated as approximately 15% below 2005 emission levels. Source: Emissions and population (2005, 2017, 2042) data provided by TCAG, 2018; 1990 population data provided by US Census Bureau, Consistency With Plans The third threshold asks whether the project would hinder progress toward the goals of applicable GHG reductions plans such as AB 32, SB 375, and SB 32 (i.e., would emissions in 2020 be the same as emissions in 1990). Impact Sciences, Inc TCAG RTP/SCS PEIR