agricultural conversion study example

City of Tulare - Tulare Motor Sports Complex Draft EIR

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Appendix B: Agricultural Land Conversion Study

Agricultural Land Conversion Study Tulare Motor Sports Complex

City of Tulare, Tulare County, California

Prepared for:

City of Tulare 411 East Kern Avenue

Tulare, CA 93274 559.684.4217

Contact: Mr. Mark S. Kielty A.I.C.P., Planning and Building Director

Prepared by:

Michael Brandman Associates 2444 W. Main Street, Suite 215

Fresno, CA 93721 559.497.0310

Contact: Dave Mitchell, Senior Project Manager

January 30, 2008

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Table of Contents

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TABLE OF CONTENTS

Section 1: Executive Summary............................................................................................1

Section 2: Introduction .........................................................................................................3 2.1 - Project Location and Setting .............................................................................................3 2.2 - Purpose of Study...............................................................................................................6 2.3 - Farmland Designations .....................................................................................................6 2.4 - Land Conservation (Williamson) Act .................................................................................9 2.5 - Land under the Williamson Land Use Contract in the County of Tulare.........................12 2.6 - Trends of Agricultural Conversion in Tulare County .......................................................12 2.7 - City of Tulare and County of Tulare Provisions...............................................................14

2.7.1 - City of Tulare..........................................................................................................14 2.7.2 - County of Tulare ....................................................................................................17

Section 3: Regional Setting................................................................................................20 3.1 - State of California Agricultural Production ......................................................................20 3.2 - Tulare County Agricultural Production ............................................................................20

Section 4: Project Setting...................................................................................................21 4.1 - Existing Site Conditions...................................................................................................21 4.2 - Historical Aerial Photographs..........................................................................................21 4.3 - Soils.................................................................................................................................22 4.4 - Water ...............................................................................................................................26 4.5 - Climate ............................................................................................................................27

Section 5: Agricultural Land Conversion Impacts...........................................................28 5.1 - City of Tulare General Plan Factors................................................................................28 5.2 - California Agricultural Land Evaluation and Site Assessment Model .............................29

5.2.1 - Land Evaluation Factors ........................................................................................30 5.2.2 - Site Assessment Factors .......................................................................................31 5.2.3 - Final LESA Scoring................................................................................................33 5.2.4 - Threshold of Significance ......................................................................................34

Section 6: Conclusions ......................................................................................................35

Section 7: Resources..........................................................................................................36

LIST OF TABLES

Table 1: Summary of Adjacent Streets and Property Usage ................................................................. 6 Table 2: Acreage of Agricultural Lands under Contract in Tulare County............................................ 12 Table 3: Acreage of New Enrollment for Agricultural Lands under Contract in Tulare County............ 13 Table 4: Acreage of Farmland Security Transfers in Tulare County .................................................... 13 Table 5: Acreage of Cumulative Non-Renewal for Agricultural Lands under Contract in

Tulare County ..................................................................................................................... 13 Table 6: Current and Projected Important Farmland Land Use within the City of Tulare .................... 15 Table 7: City of Tulare Goals and Policies for the Protection of Agriculture ........................................ 16

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Table of Contents

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Table 8: County of Tulare Policies for the Protection of Agriculture..................................................... 17 Table 9: Aerial Photography Summary ................................................................................................ 21 Table 10: Average Precipitation and Temperature for City of Tulare................................................... 27 Table 11: Project Consistency with City of Tulare Goals and Policies for the Protection of

Agriculture........................................................................................................................... 28 Table 12: LESA Factors and Percentages ........................................................................................... 33 Table 13: LESA Scores ........................................................................................................................ 33 Table 14: California Agricultural LESA Model Scoring Thresholds ...................................................... 34

LIST OF EXHIBITS

Exhibit 1: Regional Location Map........................................................................................................... 4 Exhibit 2: Local Vicinity Map Topographic Base .................................................................................... 5 Exhibit 3: Local Vicinity Map Aerial Base ............................................................................................... 7 Exhibit 4: Important Farmland Designations ........................................................................................ 10 Exhibit 5: Williamson Act Contracts within the Project Site.................................................................. 11 Exhibit 6: USDA Soils Map ................................................................................................................... 23 Exhibit 7: Parcels within Zone of Influence........................................................................................... 32

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Executive Summary

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SECTION 1: EXECUTIVE SUMMARY

This Agricultural Land Conversion Study addresses the conversion of 751.35 acres of agricultural land, located within the unincorporated portion of Tulare County and within the City of Tulare Urban Area Boundary (Planning Area), to entertainment commercial land uses. With the conversion of agricultural land to non-agricultural uses comes the potential for socioeconomic and environmental impacts, which until recently were not qualitatively and consistently considered in the environmental review process. This study intends to provide a determination of the project’s potential to significantly impact agricultural resources, using the Land Evaluation and Site Assessment (LESA) system, an analytical approach for rating the relative quality of land resources, based upon specific measurable features. Furthermore, this agricultural land conversion study evaluates the proposed project’s potential impact to agricultural lands, utilizing factors identified in the City of Tulare 2030 General Plan Update; the City of Tulare General Plan Update Goals & Policies Report, December 2007; the Draft EIR for the City of Tulare 2030 General Plan Update; and the 1993 City of Tulare General Plan. Because of a significant lack of agricultural land within the City of Tulare city limits, the City’s General Plan does not contain an Agricultural Element. To gain a regional perspective, the 2007 County of Tulare General Plan Update, the 2007 County of Tulare General Plan Update Background Report, and 2007 Draft EIR for the County of Tulare General Plan Update were also reviewed.

The California Legislature passed the Williamson Act in 1965 to preserve agricultural and open space lands by discouraging premature and unnecessary conversion to urban uses. The Williamson Act creates an arrangement whereby private landowners contract with counties and cities to voluntarily restrict land to agricultural and open-space uses. The vehicle for these agreements is a rolling-term, 10-year contract. In return, restricted parcels are assessed property taxes at a rate consistent with their actual use, rather than potential market value.

The project site contains 418.72 acres of land under Williamson Act contracts (Agricultural Preserve No. 0000277), which will need to be cancelled in order to implement the development. Implementation of the proposed project would result in a significant impact from the conversion of 751.35 acres of agricultural land; however, the loss of agricultural land within the City and County as a result of urban development is part of an overall trend within the San Joaquin Valley. A statement of overriding considerations would be necessary for the development of the proposed project.

According to the California Agricultural LESA Model Threshold of Significance, the total score of 85.6 points for the subject property shows that the conversion of agricultural land to non-agricultural use resulting from the proposed project would be considered a potentially significant environmental impact. The significant impact is due largely to the soil quality (prime farmland), availability of irrigation water, and project size. Because of the significance of the conversion of the subject property to non-agricultural uses, mitigation measures are recommended. The City of Tulare has

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Executive Summary


incorporated specific policies into its General Plan Update with which the proposed project will be required to comply, including suggested mitigation measures.

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Introduction


SECTION 2: INTRODUCTION

The City of Tulare and the County of Tulare, along with the rest of the fertile San Joaquin Valley, continue to see rapid population growth. Balancing the demand for development with the need to conserve important agricultural resources is becoming increasingly challenging. Converting agricultural lands for urban uses requires a careful, project-specific evaluation of direct, indirect, and cumulative impacts. This agricultural land conversion study evaluates the proposed project’s potential impact to agricultural lands, utilizing factors identified in the 1993 City of Tulare General Plan, the City of Tulare 2030 General Plan Update, the County of Tulare 2025 General Plan Update, and the California Department of Conservation’s California Agricultural Land Evaluation and Site Assessment Model (LESA).

2.1 - Project Location and Setting

The proposed 751.35-acre Tulare Motor Sports Complex is located in Tulare County, California in the San Joaquin Valley (Exhibit 1). The project site is situated on existing agricultural land along the southeastern city limits of the City of Tulare and is located between Laspina Street (west) and Turner Drive (east, northeast), Paige Avenue (north), Road 124 (east), and Hosfield Road (south). The site is adjacent to the International Agri-Center site along its eastern boundary and north of the Tulare Golf Course and Tulare Airport (Mefford Field). Elk Bayou, forms the southern boundary of the proposed site, which is entirely located within unincorporated Tulare County but within the City of Tulare’s Urban Area Boundary (Planning Area).The site is located on portions of the following Tulare, California, United States Geologic Survey 7.5 minute topographical maps within the Mount Diablo Baseline and Meridian (Exhibit 2).

• Section 24, Township 20S, Range 24E • Section 19 Township 20S, Range 25E • Section 25, Township 20S, Range 24E • Section 30, Township 20S, Range 25E

The project site is situated on the north bank of Elk Bayou, which flows northeast to southwest through the County of Tulare. The proposed site is characterized by flat relief, gently sloping toward the southwest, resulting in a slope of elevation from approximately 285 feet to 275 feet above mean sea level.

The majority of the site is owned or under contract for development by the Tulare Motor Sports Complex, L.P. The site, currently under agricultural production, primarily grows crops consisting of corn/silage and cotton. The project site contains 418.72 acres within a portion of Agricultural Preserve 0000277 and is currently under Williamson Act Contracts, which will require contract cancellation prior to project initiation.



The site contains three residential dwellings on its mid-eastern boundary and one residential structure on the southern boundary. No other structures are present onsite.

The footprint of the proposed project is a 751.35-acre area and primarily contains field crops throughout the site. Approximately 8.5 acres contain disturbed plant communities from residential use. Bates Slough drainage ditch travels through the site in a north to south direction on the eastern side of the project footprint and discharges into retention basins located at the end of each drainage ditch. A vicinity map is included as Exhibit 3. Table 1 identifies adjacent streets and property uses. Properties along the east contain irrigated agriculture with scattered homes. Properties to the west contain agriculture, a housing development, and commercial mixed use. Irrigated agricultural lands and homes border the north and south.

Table 1: Summary of Adjacent Streets and Property Usage

Direction Adjacent Street Adjacent Property Use

North East Page Avenue Agriculture, homes

South Avenue 200 Agriculture, homes, dairies

East Road 124 Agriculture, homes, dairies

West South Laspina Street International Agri-Center, golf course, Tulare Municipal Airport, Elk Bayou Soccer Complex

Source: Michael Brandman Associates, 2007.

2.2 - Purpose of Study

The conversion of agricultural land to non-agricultural uses has the potential for socioeconomic and environmental impacts, which until recently were not qualitatively and consistently considered in the environmental review process. This study intends to provide a determination of the project’s potential to significantly impact agricultural resources, using the Land Evaluation and Site Assessment (LESA) system, which is an analytical approach for rating the relative quality of land resources based upon specific measurable features.

2.3 - Farmland Designations

The California Department of Conservation has designated seven categories of Important Farmland:

Prime Farmland has the best combination of physical and chemical characteristics for crop production. It has the soil quality, growing seasons, and moisture supply needed to produce sustained high yield crops when treated and managed, including water management, according to current farming methods. According to the Natural Resources Conservation Service Web Soil Survey, approximately 88.5-percent of the site is in this category.



Farmland of Statewide Importance is land other than prime farmland that has a good combination of physical and chemical characteristics for the production of crops, and has been used for the production of irrigated crops within the last 3 years. This is farmland similar to Prime Farmland but with minor shortcomings, such as greater slopes or less ability to store soil moisture. Approximately 11.5-percent of the project site is in this category.

Unique Farmland does not meet the criteria for Prime Farmland or Farmland of Statewide Importance; it is land that is currently used for the production of specific crops of high economic value. It is farmland with soils of lesser quality, used for the production of the State’s leading agricultural crops. This land is usually irrigated but may include non-irrigated orchards or vineyards as found in some climatic zones in California. It has the special combination of soil quality, location, growing season and moisture supply needed to produce sustained high quality or high yields of specific crops (e.g., oranges, olives, avocados, cut flowers) when treated and managed according to current farming methods. This category excludes abandoned orchards or vineyards. No portion of the project site is in this category.

Farmland of Local Importance produces crops or has the capability of production. It is other than Prime, Statewide Importance, or Unique Farmland. It may be important to the local economy because of its productivity. A local advisory committee set up by the Soil Conservation Service (SCS) in each county initially identified Farmland of Local Importance. No portion of the project site is in this category.

Grazing Land is land on which the existing vegetation, whether grown naturally or through management, is suitable for grazing or browsing of livestock. It is identified in minimum mapping units of 40 acres and does not include land previously identified above. No portion of the project site is in this category.

Urban and Built-up Land is occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. This land is used for residential, industrial, commercial, construction, institutional, public administration, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes. No portion of the project site is in this category.

Other Land is not included in any of the other mapping categories and generally includes low-density rural developments; brush, timber, wetland, and riparian areas not suitable for livestock grazing; confined livestock, poultry, or aquaculture facilities; strip mines; borrow pits; and water bodies smaller than 40 acres. Vacant and nonagricultural land surrounded on all sides by urban development and greater than 40 acres is mapped as Other Land. No portion of the project site is in this category.



2.4 - Land Conservation (Williamson) Act

The California Legislature passed the Williamson Act in 1965 to preserve agricultural and open space lands by discouraging premature and unnecessary conversion to urban uses. The Act creates an arrangement whereby private landowners contract with counties and cities to voluntarily restrict land to agricultural and open-space uses. The vehicle for these agreements is a rolling-term, 10-year contract (that is, unless either party files a “notice of nonrenewal,” the contract is automatically renewed annually for an additional year, in keeping with the 10-year term). In return, restricted parcels are assessed property taxes at a rate consistent with their actual use, rather than at potential market value.

Land Conservation Act contracts are difficult to cancel, and owners wishing to cancel existing contracts must petition the Tulare County Board of Supervisors. To approve a tentative contract cancellation, the County Board of Supervisors must determine that such action is in the public benefit and that no other non-contracted land is available that can be used for the purpose. The existence of an opportunity for another use of the property is not sufficient reason for cancellation. In addition, the uneconomic character of an existing agricultural use shall not be, by itself, a sufficient reason to cancel a contract. Withdrawing lands from the contract before the end of the 10-year contract period means that a substantial financial penalty will be levied by the County to the landowner. The landowner must pay a cancellation fee equal to 12.5 percent of the unrestricted, current fair-market valuation of the property.

The State Department of Conservation passed legislation in 1998 to further encourage the preservation of agricultural and open space lands at the local level, through Farmland Security Zones. A Farmland Security Zone is an area created within an agricultural preserve by the Board of Supervisors upon request by a landowner or group of landowners. An agricultural preserve defines the boundary of an area within which a city or county will enter into contracts with landowners. The legislation allows individual counties to establish an additional program for farmlands to enter into contract with the State to receive a similar benefit as the Williamson Act Contract. The Farmland Security Zone Contract is a 20-year, self-renewing contract that allows property owners with qualifying parcels to receive an additional 35-percent tax savings above what is received under the Williamson Act Contract.

The site contains two parcels with Williamson Act Contracts. APN 191-130-005 and APN 191-400-001 are under contract number 02689 and are located in agricultural preserve #0000277. No other contracts exist onsite. Exhibit 4 shows the Important Farmland Designations for the project site. Exhibit 5 shows the parcels under Williamson Act Contract within the project site.



2.5 - Land under the Williamson Land Use Contract in the County of Tulare

As shown in Table 2, there were 1,102,477 acres of land in Tulare County under the Williamson Act Land Use Contract as of 2005 and 11,072 acres under the Farmland Security Zone Contract. Both contracts require that lands be within an established Agricultural Preserve. Agricultural lands that are not in a preserve face the greatest threat for conversion, as they are assessed higher property taxes because of their proximity to urbanization.

Table 2: Acreage of Agricultural Lands under Contract in Tulare County

Land Conservation Act Farmland Security Zone Year

Prime Non-Prime Total Urban Non-

Urban Total Total

2005 590,287 512,190 1,102,477 11,072 — 11,072 1,114,235

2004 590,492 511,894 1,102,386 10,727 — 10,727 1,113,113

2003 591,917 511,480 1,103,397 9,039 — 9,039 1,112,436

2002 593,597 511,536 1,105,133 9,001 — 9,001 1,114,134

2001 594,218 511,697 1,105,915 8,348 — 8,348 1,114,263

2000 599,132 511,544 1,110,676 2,550 — 2,550 1,113,226

Source: California Department of Conservation, 2002, 2004, 2006.

2.6 - Trends of Agricultural Conversion in Tulare County

Trends in Tulare County agricultural land conversion are shown in Table 3, Table 4 and Table 5. New enrollment of agricultural lands has fluctuated. In 2000, there were 900 acres enrolled into the Williamson Contract or Farmland Security Zone Contract in Tulare County. In 2001, new enrollment of agricultural lands into the Williamson Contract or Farmland Security Zone Contract increased to 3,888 acres in Tulare County. Over the past 6 years, the average amount of agricultural lands enrolled into the Williamson Contract or Farmland Security Zone Contract has been 1,550 acres per year. In 2000, 2,550 acres were transferred from the Williamson Contract to the Farmland Security Zone Contract; by 2005, transfers had decreased to 81 acres. In addition, there are 5,917 acres of prime farmland and 370 acres of non-prime farmland that were considered non-contract lands, meaning the respective landowners have requested non-renewal of their contract and are in the process of backing out of the contract.



Table 3: Acreage of New Enrollment for Agricultural Lands under Contract in Tulare County


Prime Non-Prime Urban Non-Urban Total

2005 583 456 264 — 1,303

2004 242 470 268 — 980

2003 86 472 38 — 596

2002 512 870 252 — 1,634

2001 1,698 1,821 369 — 3,888

2000 522 378 — — 900


Table 4: Acreage of Farmland Security Transfers in Tulare County


Prime Non-Prime Urban Non-Urban

2005 -81 — 81 —

2004 -1,420 — 1,420 —

2003 — — — —

2002 -401 — — 401

2001 -5,510 — 5,510 —

2000 -2,550 — 2,550 —


Table 5: Acreage of Cumulative Non-Renewal for Agricultural Lands under Contract in Tulare County


Prime Non-Prime Urban Non-Urban Total

2005 5,917 370 ― ― 6,287

2004 4,273 370 ― ― 4,643

2003 3,448 370 ― ― 3,818

2002 3,085 815 ― ― 3,900

2001 2,750 815 ― ― 3,565

2000 2,549 816 ― ― 3,365




2.7 - City of Tulare and County of Tulare Provisions

2.7.1 - City of Tulare The City of Tulare’s Environmental Impact Report for the 1993 General Plan included the following mitigation measures in its EIR to mitigate the loss of agricultural land:

• An urban reserve land use designation to avoid premature development.

• Elimination of the “large lot development designation” that was used in the previous land use element. This, in turn, may eliminate the County’s 1-acre size lot development within the City’s sphere of influence, because such development would be inconsistent with the City’s density limitation of 2 to 7 units per acre.

• The City’s industrial goal of maintaining and encouraging agriculture-related industries. Even with the incorporation of mitigation measures, the loss of agricultural land remained a significant impact. The City of Tulare adopted a statement of overriding considerations for adverse impacts due to the loss agricultural land for the Environmental Impact Report prepared for the 1993 General Plan.

The project site is currently under the County of Tulare’s jurisdiction. The portion of the site outside the City of Tulare’s Urban Growth Boundary is within the County’s Rural Valley Lands Plan (RVLP). The purpose of the RVLP is to protect and maintain the agricultural viability of rural valley areas by establishing requirements for exclusive agricultural zoning. The entire site is proposed for annexation into the City of Tulare. The project site is currently designated as A-Agricultural by the City of Tulare General Plan Land Use Diagram. APN 191-100-004 contains a County zoning of AE-20 – Exclusive Agricultural Zone 20 acre minimum, while the remainder of the site contains County zoning AE-40 – Exclusive Agricultural Zoning 40 acre minimum. The City of Tulare 2030 General Plan Update, the adoption of which is expected in April 2008, will change the site designation to Entertainment Commercial. The applicant proposes to change the zoning to C-4 (service commercial) and C-3 MU (retail commercial-mixed use).

Because of the lack of agricultural land within the City limits, the 1993 and the 2030 General Plans do not contain an agricultural element. The 1993 Tulare General Plan EIR, dated December 15, 1992, also did not contain an analysis of impacts to agricultural conversion because of the lack of agricultural land within the City.

The City of Tulare included several policies in its Conservation and Open Space Element of its 2030 General Plan Update (see Policies COS-3.2, COS-3.3, COS-3.9, COS-3.10, and COS-3.11) to conserve the City’s existing agricultural resources. Despite these policies, the City has projected that buildout of its General Plan will result in the conversion of 11,546 acres of agricultural land (see Table 6). The City of Tulare concluded that the loss of agricultural land from the buildout of the General Plan would be a significant and unavoidable impact. In order to approve the 2030 General



Plan Update and its associated EIR, the City will need to adopt a statement of overriding considerations. The statement of overriding considerations must be made on the basis of findings that specific economic, social, or other considerations make infeasible the mitigation measures or project alternatives identified in the EIR for the 2030 General Plan Update. The City will also have to find that changes or alterations have been required in, or incorporated into, the General Plan Update, which avoid or substantially lessen the significant environmental effect on agricultural land.

Table 6: Current and Projected Important Farmland Land Use within the City of Tulare

Land Type Existing Land (Acres)

General Plan Buildout Land

(Acres)

Land Converted to Non-Agricultural

Use (Acres)

Farmland of Local Importance 1,429.71 908.00 522.00

Prime Farmland 22,212.54 8,081.00 14,131.00

Farmland of Statewide Importance 4,082.09 2,520.00 1,562.00

Unique Farmland 193.87 37.00 157.00

TOTAL 27,918.21 11,546.00 16,372.00

Notes: Existing and future land acreages may not match because of rounding Source: City of Tulare 2007a.

Under the City of Tulare 2030 General Plan Update, select areas devoted to the production of irrigated crops, or having the potential for such use, are designated as either A-Agriculture or UR-Urban Reserve. The City of Tulare’s Municipal Code describes the purpose of the agricultural zone in Section 10.84.010 as a desire to preserve lands suited for agriculture from encroachment of incompatible uses, and to preserve agriculture and undeveloped lands around the City for future urban development. In comparison, the purpose of the Urban Reserve zoning located in Municipal Code Section 10.88.010 is to preserve undeveloped lands, including agricultural land around the City, until conversion to urban uses is determined appropriate and feasible.

The City of Tulare 2030 General Plan Update does not include an Agricultural Element; however, the protection of agricultural lands is a priority of the City’s Conservation and Open Space Element. The City of Tulare has identified agriculture as a vital component of its economic base and the region. The City of Tulare adopted a new goal COS-3, “…to promote the productivity of agricultural lands surrounding Tulare and the continued viability of Tulare County agriculture,” as part of its General Plan Update. A summary of applicable goals and policies is provided in Table 7.



Table 7: City of Tulare Goals and Policies for the Protection of Agriculture

Goal Source

COS-3: To promote the productivity of agricultural lands surrounding Tulare and the continued viability of Tulare County agriculture.

New Goal, 2030 General Plan Update

COS-3.1 Protect Interim Agricultural Activity: The City shall protect the viability of existing interim agricultural activity in the Planning Area to the extent possible.

Source: City of Tulare 1993 General Plan; Land Use Element; Agriculture: Goal 1

COS-3.2 Agricultural Buffers: The City shall require that agricultural land uses designated for long-term protection (in a Williamson Act contract or under a conservation easement located outside the City’s Planning Area) shall be buffered from urban land uses through the use of techniques including, but not limited to, spatial separations (e.g., greenbelts, open space setbacks, etc.), transitions in density, soundwalls, fencing, and/or berming.

New Policy, 2030 General Plan Update

COS-3.3 Agricultural Disclosures: The City shall require that developers of residential projects, which are within general proximity of agricultural operations in the city, to provide notification to new homeowners within their deeds of the City’s right to farm ordinance.


COS-3.4 Discourage Leapfrog Development: The City shall discourage leapfrog development (defined as urban development more than ½ mile from existing urban development) and development of peninsulas extending into agricultural lands to avoid adverse effects on agricultural operations and contribute to premature conversion.


COS-3.5 Support County Programs: The City shall encourage, support, and coordinate with Tulare County in the implementation of its agricultural programs, outside the city’s sphere of influence.


COS-3.6 Agricultural Business: The City shall continue to maintain and encourage agricultural-related businesses and industries in the city.

City of Tulare 1993 General Plan; Land Use Element; Agriculture: Goal 2-Revised

COS-3.7 Supportive Agricultural Services: The City shall continue to encourage the development of business and services necessary to support agriculture.

City of Tulare 1993 General Plan; Land Use Element; Agriculture: Policy 4

COS-3.8 World Ag Expo: The City shall continue to support the annual World Ag Expo within the Planning Area.

City of Tulare 1993 General Plan; Land Use Element; Agriculture: Policy 5

COS-3.9 Williamson Act Contracts: The City shall encourage the use of Williamson Act contracts on parcels located outside the Planning Area.


COS-3.10 Williamson Act Contracts near City Limits: The City shall protest the formation of new Williamson Act or Super Williamson Act contracts within the Planning Area.




Table 7 (Cont.): City of Tulare Goals and Policies for the Protection of Agriculture

Goal Source

COS-3.11 Williamson Act Non-Renewal in UDB: The City shall support non-renewal or cancellation processes for Williamson Act designated lands within the City of Tulare Urban Development Boundary (UDB)


Source: City of Tulare 2007b.

The City of Tulare concluded in its General Plan Update that future growth resulting from implementation of the General Plan would result in both the direct and indirect conversion of agricultural lands to urban and other non-farming uses. These converted lands included a variety of important farmlands (e.g., prime, unique, farmland of local importance, etc.) as defined by the Farmland Mapping and Monitoring Program of the California Resources Agency. The Draft EIR for the City of Tulare 2030 General Plan Update found that the buildout of the General Plan will result in a significant and unavoidable impact to agriculture through the conversion of agricultural land to non-agricultural uses.

2.7.2 - County of Tulare The County of Tulare prepared its 2030 General Plan Update and identified agricultural land on the Valley floor and in the foothills of Tulare County as an economic asset and a cultural, scenic, and environmental resource to be protected. One of the key, new principles of the County General Plan is to protect valuable agricultural uses from urban encroachment. The Elements within the General Plan that provide policies and implementation measures for the conservation and/or improvements on agricultural lands include the Agricultural Land Use, Economic Development, and Environmental Resource Management Elements. Additional policies have been developed for each of the County’s planning areas (e.g., Corridors, Valley, Foothills, etc.) to address their own unique agricultural-related issues. Table 8 summarizes the applicable policies adopted by Tulare County for the protection of agriculture.

Table 8: County of Tulare Policies for the Protection of Agriculture

Agriculture and Economic Development Elements

Policies designed to conserve agricultural resources within the County include the following:

AG-1.1 Primary Land Use AG-1.2 Coordination AG-1.3 Williamson Act AG-1.4 Williamson Act in UDBs and HDBs AG-1.5 Substandard Williamson Act Parcels AG-1.7 Preservation of Agricultural Lands

AG-1.8 Agriculture Within Urban Boundaries AG-1.9 Agricultural Preserves Outside Urban Boundaries AG-1.10 Extension of Infrastructure Into Agricultural Areas AG-1.11 Agricultural Buffers AG-1.12 Ranchettes AG-1.13 Agricultural Related Uses AG-1.14 Right-to-Farm Noticing



Table 8 (Cont.): County of Tulare Policies for the Protection of Agriculture

Policies designed to promote the continued productivity and employment of agricultural resources within the County include the following:

AG-2.1 Diversified Agriculture AG-2.2 Market Research AG-2.3 Technical Assistance AG-2.4 Crop Care Education AG-2.5 High-Value-Added Food Processing

AG-2.6 Biotechnology and Biofuels AG-2.8 Agricultural Education Programs AG-2.9 Global Marketing AG-2.10 Regional Transportation AG-2.11 Energy Production ED-2.10 Supporting Agricultural Industry

Implementation measures designed to protect and conserve agricultural resources within the County include the following:

Agriculture Implementation Measure #1: The County shall take the lead to work with cities and Tulare County Association of Governments (TCAG) to establish a comprehensive agricultural land mitigation program to offset impacts of agricultural land conversion to urban uses.

Agriculture Implementation Measure #2: The County shall review agricultural land preservation programs and assess their effectiveness in furthering the County’s agricultural goals and policies as part of an annual report.

Agriculture Implementation Measure #3: The County shall maintain a comprehensive database of contracted agricultural preserves located within UDBs of unincorporated communities and review these preserves at regular intervals. The purpose of the review is to determine whether any unincorporated community in the County is unduly constrained or confined by land contracted under the Williamson Act. If this has occurred, the County shall encourage the land owner to file a notice of non-renewal so that the contract on the property could be terminated nine years from that date. The Williamson Act review shall be closely coordinated with the review of UDBs.

Agriculture Implementation Measure #4: The County of Tulare shall serve Notices of Non-Renewal of Land Conservation Contracts in conformance with California Government Code §51245 through 51246, for properties that do not meet the minimum parcel sizes set forth under §51222 of the California Government Code (at least 10 acres in size for prime agricultural land, 40 acres in size for non prime agricultural land)

Agriculture Implementation Measure #5: The County shall work with TCAG and the cities to establish criteria for the locations for agricultural conservation easements.

Agriculture Implementation Measure #6: The County shall continue to use the Rural Valley Lands Plan Parcel Evaluation Procedure to evaluate changes to agricultural zoning and determine the expansions of UDBs.

Agriculture Implementation Measure #7: The County shall coordinate with Local Area Formation Commission (LAFCO) and TCAG to closely monitor the amount of agricultural lands converted annually to urban other non-agricultural uses.

ED Implementation Measure #4: The County, working in cooperation with the cities, shall develop criteria for the location of value-added agricultural processing facilities that are compatible with an agricultural setting. Such criteria shall take into account the service requirements of facilities for processing agricultural products and the capability and capacity of the cities to provide the services required.

LU Implementation Measure #13: The County shall, in cooperation with property owners, reinstitute Open Space and Land Conservation contracts for all parcels on prime agricultural land meeting the minimum land area as required under State law.



Table 8 (Cont.): County of Tulare Policies for the Protection of Agriculture

Agriculture, Land Use and Environmental Resource Management Elements

Policies designed to promote future development patterns within areas of existing development include the following:

AG-1.15A Schools in Agricultural Zones LU-1.8 Encourage Infill Development LU-2.1 Agricultural Lands LU 2.2 Agricultural Parcel Splits

LU-2.5 Residential Agriculture Uses LU-2.6 Agricultural Support Facilities LU-2.6A Industrial Development LU-2.7 Timing of Conversion from Urban Reserve LU-2.8 Merger of Sub Standard Agricultural Parcels ERM-5.15 Open Space Preservation

Corridors, Rural Valley Lands Plan, Foothill Growth Management Plan, and Mountain Framework Plan

Similar policies designed to conserve and encourage the continued economic value of agricultural resources within the various planning areas include the following:

RVLP-1.1 Development Intensity RVLP-1.2 Existing Parcels and Approvals RVLP-1.4 Determination of Agriculture Land

C-1.5 Agricultural Enterprises F-1.12 Development in Success Valley F-6.1 Protect Agricultural Lands M-1.9 Agricultural Preserves

Source: County of Tulare, Goals and Policies Report, 2007. The County of Tulare concluded that growth associated with implementation of its draft General Plan 2025 Update along with development within Urban Development Boundaries of cities and communities within the County would result in a loss of some existing agricultural lands. The County of Tulare included policies in its General Plan Update to minimize this impact. (See Policies AG-1.1, AG-1.2, AG-1.3, AG-1.4, AG-1.6, AG-1.7, AG-1.10, AG-1.11, and AG-1.14.) The loss of agricultural lands was still considered a significant and unavoidable impact.

Implementation of the proposed project would result in a significant impact from the conversion of 751.35 acres of agricultural land. This represents 3 percent of the agricultural land within the City of Tulare’s Planning Area; however, the loss of agricultural land within the City and County as a result of urban development is part of an overall trend within the San Joaquin Valley. A statement of overriding considerations would be necessary for the development of the proposed project. According to the California Agricultural LESA Model Threshold of Significance, the total score of 85.6 points for the subject property shows that the conversion of agricultural land to non-agricultural use resulting from the proposed project would be considered a potentially significant environmental impact. The significant impact is due largely to the soil quality (prime farmland), availability of irrigation water, and project size. Because of the significance of the conversion of the subject property to non-agricultural uses, mitigation measures are recommended. The City of Tulare has incorporated specific policies into its General Plan Update to mitigate impacts to agriculture that will apply to the proposed project.

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Regional Setting


SECTION 3: REGIONAL SETTING

3.1 - State of California Agricultural Production

California exports agricultural products to almost 150 countries, but the 10 principal destinations accounted for 84 percent of the 2004 export value, and the main four destinations—the European Union, Canada, Japan, and Mexico—accounted for two-thirds of the total. California had 77,000 farms and ranches in 2004, less than 4 percent of the nation’s total. Although this represents a small percent of the nation’s total farming operations, these farms account for a fairly significant percent of the national gross cash receipts from farming. As the nation’s leading agricultural producer, California’s cash receipts represented 13.2 percent of the U.S. total, and were more than Texas and Iowa (the second and third leading states) combined. The average California operation had $413,000 in farm sales, compared with the U.S. average of $114,000 per farm.

In 2004, California’s land devoted to farming and ranching totaled 26.7 million acres. California has some of the most agriculturally productive counties in the nation. According to the 2002 Census of Agriculture’s market value ranking of agricultural products sold, nine of the nation’s top ten, and 12 of the top 20, producing counties are in California. California’s agricultural abundance includes 350 different crops. Among those, the State grows more than half of the nation’s total fruits, nuts, and vegetables. Many of these commodities are produced solely in California. California’s top 20 crop and livestock commodities accounted for 80 percent of the State’s gross farm income.

3.2 - Tulare County Agricultural Production

Agriculture has been and will continue to be vital to the economy of Tulare County. Tulare County is ranked second among California’s top agricultural counties (CDFA 2008). The 2006 Annual Crop and Livestock Report prepared by the Tulare County Agricultural Commissioner’s Office states that Tulare County contains 1,582,856 acres of harvested land. During the 2006 fiscal year, the gross agricultural production, according to the Annual Crop and Livestock Report, accounted for a revenue of $3,872,059,700. This represented a decrease of $490,678,300 or 11 percent when compared with the 2005 value of $4,362,738,000. Milk was the leading commodity with a total value of $1,179,394,000, followed by oranges, cattle/calves, grapes, alfalfa-hay/silage, and corn-grain/silage. Tulare County’s agricultural strength is based on the diversity of crops produced. The 2006 Annual Crop and Livestock Report covered more than 130 different commodities. Forty-six of the commodities had gross values in excess of $1,000,000. Although individual commodities may experience difficulty from year to year, Tulare County continues to thrive based on the diversity of the crops produced.

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Project Setting


SECTION 4: PROJECT SETTING

4.1 - Existing Site Conditions

The site is currently under agricultural production for cotton and corn. Scattered homes are contained within the project site. Residential sewage for the onsite residences is disposed of in septic tanks. Seven agricultural groundwater wells as well as domestic wells to serve onsite residential uses are dispersed within the site. Three drainage features as part of the irrigation system are contained within the project site, as well as two irrigation ditches within the central and eastern portions of the project site. These features converge in the eastern portion of the project site, becoming one irrigation ditch near the northern end of the east ditch. In addition, a small retention basin is located within the southeastern portion of the project site. Properties along the east contain irrigated agriculture with scattered homes. Properties to the west contain agriculture, a housing development, and commercial mixed use. Irrigated agricultural lands and homes border the north and south.

A Phase I Environmental Site Assessment (ESA) was performed by Michael Brandman Associates for the project site in November 2007. The ESA concluded the project site appears to have been historically used for agricultural purposes with limited residences. The ESA also indicated that there is a medium to high probability that the site contains recognized environmental conditions relative to hazardous materials and that further testing and analysis are warranted. The hazardous materials are related to the aging residential structures on the project site (lead-based paint, asbestos), abandoned underground storage tanks, aboveground storage tanks, irrigation and drinking water wells, and septic sewer systems. Recommendations for further testing and analysis have been included in the Phase I site assessment.

4.2 - Historical Aerial Photographs

Historic aerial photographs received from Environmental Data Resources were reviewed to identify land uses and to note land use changes over time (included in the Phase I Environmental Site Assessment). A historical aerial photography summary follows in Table 9.

Table 9: Aerial Photography Summary

Year Source Property Observation

1946 Fairchild The project site consists primarily of undeveloped, disturbed land. Structures are identified onsite near the northeastern border. Structures also are identified offsite to the north, east, and south. Elk Grove Bayou is visible along the southern border of the site.

1952 Robinson Agriculture is now the primary land use onsite. A new structure is visible in the southern end of the site. No other significant changes were observed.



Table 9 (Cont.): Aerial Photography Summary

Year Source Property Observation

1956 Aero Development of a golf course is visible near the southwestern border of the site. No other significant changes were observed.

1984 WSA New structures are identified to the south and east of the site. No other significant changes were observed.

1994 USGS New structures are identified near the northwestern border of the site. No other significant changes were observed.

2002 USGS No changes were observed.

Source: Environmental Data Resources, Inc., 2007.

4.3 - Soils

The Soil Survey of Tulare County, California, eastern part (United States Department of Agriculture – Soil Conservation Service website) presents a list of map units that meet the requirements for prime farmland if water for irrigation is available. The list includes most soil types encountered within the project area, including 665.65 acres of potential prime farmland if irrigated as classified by the USDA and 87.5 acres of Farmland of State Importance. However, as defined by the California Land Conservation Act (G.C. § 51201), prime agricultural soils include Class I and II soils, Storie Index 80-100 soils, vineyards and orchards, and soils yielding a minimum $200 per acre crop value per year; as such, 751.35 acres of the project are considered potential prime farmland. Exhibit 6 shows the USDA soils map for the project site.

Class 1 soils have few limitations that restrict their use. Class 2 soils have moderate limitations that reduce the choice of plants or that require moderate conservation practices. Class 3soils have severe limitations that reduce the choice of plants or that require special conservation practices, or both. Class 4 soils have very severe limitations that reduce the choice of plants or that require very careful management, or both.

The Storie Index is a soil rating based on soil properties that govern a soil’s potential for cultivated agriculture in California. The Storie Index assesses the productivity of a soil from the following four characteristics: Factor A, degree of soil profile development; Factor B, texture of the surface layer; Factor C, slope; and Factor X, manageable features, including drainage, microrelief, fertility, acidity, erosion, and salt content. A score ranging from 0 to 100 percent is determined for each factor, and the scores are then multiplied together to derive an index rating. For simplification, Storie Index ratings have been combined into six grade classes as follows: Grade 1 (excellent), 100 to 80; Grade 2 (good), 79 to 60; Grade 3 (fair), 59 to 40; Grade 4 (poor), 39 to 20; Grade 5 (very poor), 19 to 10; and Grade 6 (nonagricultural), less than 10.



Land capability classification shows, in a general way, the suitability of soils for most kinds of field crops. Crops that require special management are excluded. The soils are grouped according to their limitations for field crops, the risk of damage if they are used for crops, and the way they respond to management. The criteria used in grouping the soils do not include major and generally expensive landforming that would change slope, depth, or other characteristics of the soils, nor do they include possible but unlikely major reclamation projects. Capability classification is not a substitute for interpretations that show suitability and limitations of groups of soils for rangeland, for woodland, or for engineering purposes.

In the capability system, soils are generally grouped at three levels: capability class, subclass, and unit. Only class and subclass are included in this data set. Capability subclasses are soil groups within one capability class. They are designated by adding a small letter, “e,” “w,” “s,” or “c,” to the class numeral, for example, 2e. The letter “e” shows that the main hazard is the risk of erosion unless close-growing plant cover is maintained; “w” shows that water in or on the soil interferes with plant growth or cultivation (in some soils the wetness can be partly corrected by artificial drainage); “s” shows that the soil is limited mainly because it is shallow, droughty, or stony; and “c,” used in only some parts of the United States, shows that the chief limitation is climate that is very cold or very dry.

In Class 1, there are no subclasses because the soils of this class have few limitations. Class 5 contains only the subclasses indicated by “w,” “s,” or “c” because the soils in Class 5 are subject to little or no erosion. They have other limitations that restrict their use to pasture, rangeland, forestland, or wildlife habitat.

The proposed project site includes five types of soils classified by the United States Department of Agriculture Soil Conservation Service as Grade I soils having Storie Indexes above 80, thereby meeting the California Land Conservation Act (G.C. § 51201). These map units are Akers-Akers, Colpien loam, Crosscreek-Kai association, Flamen loam, and Tagus loam.

• Akers-Akers (map symbol unit 101) – The Akers component is on fan remnants and valleys. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer is greater than 60 inches. The natural drainage class is well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is high. Shrink-swell potential is low. This soil is very rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 1 percent. Nonirrigated land capability classification is 4c. Irrigated land capability classification is 1. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 6 percent. The soil has a slightly sodic horizon within 30 inches of the soil surface.

The Akers, saline-sodic component of the map contains slopes of 0 to 2 percent. This component is on valleys and fan remnants. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer is greater than 60 inches. The



natural drainage class is well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is high. Shrink-swell potential is low. This soil is very rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 1 percent. Nonirrigated land capability classification is 4s. Irrigated land capability classification is 2s. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 6 percent. The soil has a slightly saline horizon within 30 inches of the soil surface. The soil has a moderately sodic horizon within 30 inches of the soil surface. Approximately 22.3 percent of the project site is in this category. This unit is in capability Class I irrigated and capability Class IV non-irrigated.

• Colpien loam (map symbol unit 108) – The Colpien component is on valleys, fan remnants. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer is greater than 60 inches. The natural drainage class is moderately well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is high. Shrink-swell potential is moderate. This soil is rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 2 percent. Nonirrigated land capability classification is 4c. Irrigated land capability classification is 1. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 3 percent. The soil has a slightly sodic horizon within 30 inches of the soil surface.

Approximately 26.3 percent of the project site is in this category. This unit is in capability Class I irrigated and capability Class IV non-irrigated.

• Crosscreek-Kai association (map symbol unit 109) – The Crosscreek component slopes are 0 to 2 percent. This component is on fan remnants, valleys. Formed by the chemical and mechanical alteration of the Kai series, which originally formed in alluvium derived from granitic rock. Depth to a root restrictive layer, duripan, is 40 to 60 inches. The natural drainage class is well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is moderate. Shrink-swell potential is moderate. This soil is very rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 1 percent. Nonirrigated land capability classification is 6s. Irrigated land capability classification is 2s. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 6 percent. The soil has a slightly saline horizon within 30 inches of the soil surface. The soil has a slightly sodic horizon within 30 inches of the soil surface.

• The Kai component slopes are 0 to 2 percent. This component is on fan remnants, valleys. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer, duripan, is 20 to 40 inches. The natural drainage class is moderately well drained. Water movement in the most restrictive layer is low. Available water to a depth of 60 inches is moderate. Shrink-swell potential is moderate. This soil is very rarely flooded. It is



not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 0 percent. Nonirrigated land capability classification is 7s. Irrigated land capability classification is 3s. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 5 percent. The soil has a moderately saline horizon within 30 inches of the soil surface. The soil has a strongly sodic horizon within 30 inches of the soil surface.

• Approximately 11.5 percent of the project site is in this soil map unit. This unit is in capability Class II irrigated and capability Class VI non-irrigated.

• Flamen loam (map symbol unit 116) – The Flamen component slopes are 0 to 2 percent. This component is on fan remnants, valleys. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer, duripan, is 40 to 60 inches. The natural drainage class is moderately well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is moderate. Shrink-swell potential is moderate. This soil is very rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 2 percent. Nonirrigated land capability classification is 4e. Irrigated land capability classification is 2s. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 1 percent. The soil has a slightly sodic horizon within 30 inches of the soil surface. Approximately 35.5 percent of the project site is in this category. These soils are in capability Class II irrigated and capability Class IV non-irrigated.

• Tagus loam (map symbol unit 137) - The Tagus component slopes are 0 to 2 percent. This component is on fan remnants, valleys. The parent material consists of alluvium derived from granitic rock sources. Depth to a root restrictive layer is greater than 60 inches. The natural drainage class is well drained. Water movement in the most restrictive layer is moderately high. Available water to a depth of 60 inches is moderate. Shrink-swell potential is low. This soil is very rarely flooded. It is not ponded. There is no zone of water saturation within a depth of 72 inches. Organic matter content in the surface horizon is about 2 percent. Nonirrigated land capability classification is 4c. Irrigated land capability classification is 1. This soil does not meet hydric criteria. The calcium carbonate equivalent within 40 inches, typically, does not exceed 8 percent. The soil has a slightly sodic horizon within 30 inches of the soil surface. Approximately 4.4 percent of the project site is in this category. These soils are in capability Class I irrigated and capability Class IV non-irrigated.

4.4 - Water

Farmers Consolidated Water provides surface water to the site for irrigation when available. When surface water is not available for irrigation, water is provided by seven agricultural groundwater wells. The wells are currently active and powered by electricity provided by Southern California Edison or diesel-powered engines. Potable water is provided through onsite domestic wells.



The existing site consumes water mainly for agricultural purposes, with limited domestic use for the few homes in the area. The estimated annual water demand for the existing land use is approximately 2,405.2 acre-feet, which is broken down into 781.4 acre-feet provided by surface water and 1,623.8 acre-feet provided by groundwater wells. The planned development annual water demand, based on the total demand for domestic water and landscape irrigation, is estimated to be 571.9 acre-feet. The planned development will result in a net reduction of 1,051.9 acre-feet per year groundwater use, or approximately a 65-percent reduction of groundwater use.

4.5 - Climate

The climate in Tulare is relatively warm and dry, typical of a Mediterranean climate. Summers are hot and dry, and winters are cool with an annual average precipitation of approximately 10.26 inches. Climate data averaged over years 1927 to 2007 indicate normal daily maximum temperatures range from 56.1 degrees Fahrenheit (°F) in December to 97.2°F in July. Annually, 101.5 days on average reach a daily maximum temperature over 90°F. Normal daily minimum temperatures range from 37.2°F in January to 64.5°F in July. Annually, an average of 17.4 days attain below-freezing temperatures in Tulare. Precipitation ranges from 0.01 inch in July and August to 1.96 inches in January, with an average annual precipitation of 10.26 inches. Annually, there is an average of 40 days with measurable (0.01 inches or more) precipitation. A summary of precipitation and temperature is provided in Table 10.

Table 10: Average Precipitation and Temperature for City of Tulare

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Average Precipitation (inches)

1.96 1.85 1.71 1.03 0.33 0.09 0.01 0.01 0.13 0.51 1.02 1.61 10.26

Average Temperature (°F)

46.3 51.6 56.3 61.9 68.6 75.6 80.9 79.3 74.3 65.7 54.4 46.7 63.5

Source: National Weather Service, 2007.

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Agricultural Land Conversion Impacts


SECTION 5: AGRICULTURAL LAND CONVERSION IMPACTS

This study analyzes several factors provided in the 1993 City of Tulare General Plan, the recently released City of Tulare 2030 General Plan Update, and the California Agricultural Land Evaluation and Site Assessment Model (LESA, California Department of Conservation – Office of Land Conservation, 1997) to identify the proposed project’s potential impact to agricultural lands.

5.1 - City of Tulare General Plan Factors

As discussed previously in Section 2.7, the City of Tulare 2030 General Plan Update was released in December 2007, with adoption anticipated in April 2008. Although the General Plan does not include an agricultural element, the protection of agricultural lands is a priority of the City’s Conservation and Open Space Element. The City of Tulare adopted a new goal, COS-3, to promote the productivity of agricultural lands surrounding Tulare and the continued viability of Tulare County agriculture.

The project can be evaluated based on its consistency with applicable goals and policies established by the City of Tulare for the protection of agriculture. A summary of the evaluation is included in Table 11.

Table 11: Project Consistency with City of Tulare Goals and Policies for the Protection of Agriculture

Goal Source Consistency Finding

COS-3 New Goal, 2030 General Plan Update

Not Consistent. The removal of 751.35 acres of agricultural land would not be consistent with the goal of promoting the productivity of agricultural lands surrounding Tulare and the continued viability of Tulare County Agriculture.

COS-3.1 Source: City of Tulare 1993 General Plan; Land Use Element; Agriculture: Goal 1

Not Consistent. The removal of 751.35 acres of agricultural land would not be consistent with the goal of protecting the viability of existing interim agricultural activity in the Planning Area to the extent possible.

COS-3.2 Agricultural Buffers New Policy, 2030 General Plan Update

Not Applicable. The project site is located within the Planning Area.

COS-3.3 Agricultural Disclosures New Policy, 2030 General Plan Update

Consistent. The project will need to include an agricultural disclosure for the residential portion of the project in order to be consistent with this policy. The residents will need to be informed of their proximity to agricultural operations near the project site.



Table 11 (Cont.): Project Consistency with City of Tulare Goals and Policies for the Protection of Agriculture

Goal Source Consistency Finding

COS-3.4 Discourage Leapfrog Development: The City shall discourage leapfrog development (defined as urban development more than ½ mile from existing urban development) and development of peninsulas extending into agricultural lands to avoid adverse effects on agricultural operations and contribute to premature conversion.


Not applicable. The project is within 0.5 mile of urban development and would be located near other industrial/institutional uses, the World Ag Expo and Mefford Field.

COS-3.9 Williamson Act Contracts New Policy, 2030 General Plan Update

Not applicable. The project site is proposed to be annexed to the City and will be a part of the Planning Area.

COS-3.11 Williamson Act Non-Renewal in UDB


Consistent. The project is consistent with the policy for Williamson Act cancellation with the City of Tulare’s Urban Development Boundary.

The City also determined that the significance criteria for the analysis of impacts to agricultural resources should be based on criteria presented in Section 15065 and Appendix G, Environmental Checklist Form of the CEQA Guidelines. These criteria include:

• Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use;

• Conflict with existing zoning for agricultural use, or conflict with a Williamson Act contract; or

• Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Important Farmland, to non-agricultural uses.

5.2 - California Agricultural Land Evaluation and Site Assessment Model

Land Evaluation and Site Assessment (LESA) is a term used to define an approach for rating the relative quality of land resources based upon specific measurable features. The formulation of the California Agricultural LESA Model is the result of Senate Bill 850 (Chapter 812/1993), which charges the Resources Agency, in consultation with the Governor’s Office of Planning and Research, to develop an amendment to Appendix G of the California Environmental Quality Act (CEQA) Guidelines. Such an amendment is intended “to provide lead agencies with an optional methodology to ensure significant effects on the environment of agricultural land conversions are quantitatively and



consistently considered in the environmental review process.” (Public Resources Code Section 21095)

The California Agricultural LESA Model is composed of six different factors, which are divided into two sets: Land Evaluation and Site Assessment factors. Two Land Evaluation factors (Land Capability Classification Rating and Storie Index Rating) are based upon measures of soil resources quality and intended to measure the inherent, soil-based qualities of land as they relate to agricultural suitability. Four Site Assessment factors (Project Size Rating, Water Resource Availability Rating, Surrounding Agricultural Lands Rating, and Surrounding Protected Resource Lands Rating) are intended to measure social, economic, and geographic attributes that also contribute to the overall value of agricultural land.

The two sets of factors are evenly weighted, meaning the two Land Evaluation factors and four Site Assessment factors are of equal importance. However, for a given project, each of these six factors is separately rated in a 100-point scale. The factors are then weighted relative to one another and combined, resulting in a single numeric score for a given project, with a maximum attainable score of 100 points. This final project score becomes the basis for making a determination of the potential impacts’ level of significance for the project, based upon a range of established scoring thresholds.

5.2.1 - Land Evaluation Factors The California LESA Model includes two Land Evaluation factors, discussed below, that are separately rated.

The Land Capability Classification Rating (LCC)

The LCC indicates the suitability of soils for most kinds of crops. Groupings are made according to the limitations of the soils when used to grow crops and the risk of damage to soils when used in agriculture. Soils are rated from Class I to Class VIII, with soils having the fewest limitations receiving the highest rating (Class I). Specific subclasses are also utilized to further characterize soils.

The Storie Index Rating

The Storie Index provides a numeric rating (based upon a zero to 100 scale) of the relative degree of suitability or value of a given soil for intensive agriculture. The rating is based upon soil characteristics only. Four factors that represent the inherent characteristics and qualities of the soil are considered in the Storie Index rating: profile characteristics, texture of the surface layer, slope, and other factors such as drainage or salinity. In some situations, only the United States Department of Agriculture’s LCC information may be available. In those cases, the Storie Index ratings can be calculated from information contained in soil surveys by qualified soil scientists; however, if limitation of time and/or resources restrict the derivation of the Storie Index rating for a given project, it may be possible to adapt the Land Evaluation by relying solely upon the LCC rating.



5.2.2 - Site Assessment Factors The four Site Assessment factors that are separately rated and included in the California LESA Model are discussed below.

The Project Size Rating

The Project Size rating is based upon identifying acreage figures for three separate grouping of soil classes within the project site, and then determining what grouping generates the highest Project Size score. The Project Size Rating relies upon acreage figures that were tabulated under the Land Capability Classification Rating.

The Water Resources Availability Rating

The Water Resources Availability rating is based upon identifying the various water sources that may supply a given property, and then determining whether different restrictions in supply are likely to take place in years that are characterized as being periods of drought and non-drought.

The Surrounding Agricultural Land Rating

Determination of the Surrounding Agricultural Land rating is based upon identification of a project’s Zone of Influence (ZOI), which is defined as that land near a given project, both directly adjoining and within a defined distance away, that is likely to influence, and be influenced by, the agricultural land use of the subject project site. The Surrounding Agricultural Land rating is designed to provide a measurement of the level of agricultural land use for lands close to a given project. The California Agricultural LESA Model rates the potential significance of the conversion of an agricultural parcel that has a large proportion of surrounding land in agricultural production more highly than one that has relatively small percentage of surrounding land in agricultural production. The definition of the ZOI that accounts for surrounding lands (up to a minimum of 0.25 mile from the project boundary) is the result of several iterations during model development for assessing an area that will generally be a representative sample of surrounding land use. Exhibit 7 shows the zone of influence surrounding the project site. There are 2762.29 acres of land within the zone of influence of the project site; of those lands, 498 acres comprise the International Agri-Center, Tulare Golf Coarse, Tulare Municipal Airport (Mefford Field), and Elk Bayou Soccer Complex. The remaining 2,264.29 acres consist of agricultural land.

The Surrounding Protected Resource Land Rating

The Surrounding Protected Resource Land rating is essentially an extension of the Surrounding Agricultural Land rating, and it is scored in a similar manner. Protected resource lands are those lands with long-term use restrictions that are compatible with or supportive of agricultural uses of land. Included among them are the following:

• Williamson Act contracted lands

• Publicly owned lands maintained as a park, forest, or watershed resources



• Lands with agricultural, wildlife habitat, open space, or other natural resource easements that restrict the conversion of such land to urban and industrial uses

5.2.3 - Final LESA Scoring A single LESA score is generated for a given project after all the individual Land Evaluation and Site Assessment factors have been scored and weighted. The California Agricultural LESA Model is weighted so that 50 percent of the total LESA score of a given project is derived from the Land Evaluation factors and 50 percent is derived from the Site Assessment factors. Individual factor weights are listed below, with the sum of the factor weights required to equal 100 percent.

Table 12: LESA Factors and Percentages

LESA Factors Percentages

Land Evaluation Factors

Land Capability Classification (LCC) 25

Storie Index Rating 25

Land Evaluation Subtotal 50

Site Assessment Factors

Project Size Rating 15

Water Resource Availability Rating 15

Surrounding Agricultural Lands Rating 15

Surrounding Protected Resource Lands Rating 5

Site Assessment Subtotal 50

Total LESA Factor Weighting 100 For the subject property, the final LESA score was determined as shown in Table 13:

Table 13: LESA Scores

Factor Name Factor Rating (0-100 Points)

Factor Weighting (Total=1.0)

Weighted Factor Rating

Land Evaluation

Land Capability Classification 89.800 0.25 22.45

Storie Index Rating 86.958 0.25 21.70

LE Subtotal 44.20

Site Assessment

Project Size 100.0 0.15 15.00

Water Resource Availability 79.2 0.15 11.88

Surrounding Agricultural Lands 90.0 0.15 13.50



Table 13 (Cont.): LESA Scores

Factor Name Factor Rating (0-100 Points)

Factor Weighting (Total=1.0)

Weighted Factor Rating

Protected Resource Lands 20.0 0.05 1.00

SA Subtotal 41.38

Total LESA Score 85.57 5.2.4 - Threshold of Significance The California Agricultural LESA Model is designed to make determinations of the potential significance of a project’s conversion of agricultural lands during the Initial Study phase of the CEQA process. Scoring thresholds are based upon both the total LESA score and the component Land Evaluation (LE) and Site Assessment (SA) separate subscores. In this manner, the scoring thresholds are dependent upon the attainment of a minimum score for the LE and SA subscores so that a single threshold is not the result of heavily skewed subscores (i.e., a site with a very high LE score but a very low SA score, or vice-versa). The California Agricultural LESA Model scoring thresholds are as follows:

Table 14: California Agricultural LESA Model Scoring Thresholds

Total LESA Score Scoring Decision

0 to 39 points Not considered significant

40 to 59 points Considered significant only if LE and SA subscores are each greater than or equal to 20 points

60 to 79 points Considered significant unless either LE or SA subscore is less than 20 points

80 to 100 points Considered significant

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Conclusions


SECTION 6: CONCLUSIONS

It is assumed that further development of the City of Tulare and the County of Tulare will occur, and most likely on prime agricultural soils that exist on the valley floor. The 1993 City of Tulare General Plan Environmental Impact Report concluded that a significant impact would occur as a result of the buildout of the 1993 General Plan and adopted a Statement of Overriding Considerations for approval of the plan and its environmental report. The General Plan Update Draft EIR has also determined that impacts to agricultural lands will be significant and unavoidable. The City will need to adopt a Statement of Overriding Considerations for approval of the plan and its environmental report.

According to the California Agricultural LESA Model Threshold of Significance, the total score of 85.57 for the subject property shows that the conversion of agricultural land to non-agricultural use resulting from the proposed project would be considered a potentially significant environmental impact. The significant impact is due largely to the soil quality (prime farmland), availability of irrigation water, and project size.

According to the significance criteria established by the City of Tulare, implementation of the project would result in a significant conversion of 751.35 acres of agricultural land. Additionally, the project site includes 418.72 acres of land under Williamson Act Contracts. A Statement of Overriding Considerations would be necessary for the development of the proposed project.

With respect to cumulative growth-inducing impacts, this report identifies the potential impact of the conversion of 751.35 acres of agricultural land. The conversion of this property from agricultural use to non-agricultural use may be expected to create growth-inducing impacts to other nearby agricultural lands. Because of the significance of the conversion of the subject property to non-agricultural uses, mitigation measures and project alternatives are recommended.

Mitigation Measure One: The applicant shall be responsible for contributing mitigation fees to a Tulare County land trust, such as the Sequoia Riverlands Trust, for the creation of a conservation easement of 3 acres of equally good, equally at-risk agricultural land, for every acre of agricultural land converted by the project. It should be noted that a portion of the site has been developed with residential and commercial uses and is not usable as agricultural land.

The California Department of Conservation recommends that the ratio of conservation easements to lost agricultural land be increased where a Williamson Act contract will be terminated, or if growth-inducing or cumulative agricultural impacts are involved.

City of Tulare - Tulare Motor Sports Complex Agricultural Land Conversion Study Resources


SECTION 7: RESOURCES

California Department of Conservation. 2002. The California Land Conservation (Williamson) Act Status Report. August.

California Department of Conservation.2004. The California Land Conservation (Williamson) Act Status Report. May.

California Department of Conservation. 2006. The California Land Conservation (Williamson) Act Status Report. May.

California Department of Food and Agriculture. 2008. 2006 California Agricultural Statistical Review. Website http://www.cdfa.ca.gov/files/pdf/card/ResDir06_Overview.pdf. Accessed January 24, 2008.

City of Tulare. 2007a. City of Tulare 2007 General Plan Update DEIR. Website http://www.westplanning.com/docs/cityoftulare/libary.htm. Accessed February 18, 2008.

City of Tulare. 2007b. City of Tulare General Plan; Goals and Policy Report. Website http://www.westplanning.com/docs/cityoftulare/documents/tularecity_gpr_cc_pc_version_2007_06_05.pdf. Accessed February 18, 2008.

Environmental Data Resources, Inc. (EDR). 2007. The EDR Radius Map, Aerial Photograph Decade Package, and Historic Topographical Map Report, Tulare Motor Sports Complex. August.

National Weather Service. 2008. Website http://www.wrcc.dri.edu for Visalia. Accessed January 30, 2008, California weather station No. 049367. Period of Record: 1927-2007.

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