Environmental Assessment No. 2026-04 for Conditional Use Permit Application No. 2026-01
Summary
SCH Number
2026061027
Public Agency
City of Reedley
Document Title
Environmental Assessment No. 2026-04 for Conditional Use Permit Application No. 2026-01
Document Type
NOE - Notice of Exemption
Received
Posted
6/23/2026
Document Description
The Applicant proposes Conditional Use Permit (CUP) 2026-01 for
tenant improvements on approximately 2.61 acres located at 1485 East
Curtis Avenue, Reedley, CA 93654. The site is currently developed
with an existing industrial building with parking, outdoor storage areas,
and accessory areas. See Figure 5 for the aerial image of the site.
Proposed improvements are limited to approximately 2.61 acres,
including approximately 1.44 acres of exterior improvements and
approximately 1.17 acres within the interior of the existing building,
totaling 2.61 acres.
Exterior Improvements and Construction
The exterior improvements include repaving and restriping to provide
18 new standard and 2 new accessible parking stalls, and a concrete
containment area. No work is proposed along the site frontage, existing
driveways, structures, or trees.
Interior Improvements and Operations
The Project proposes interior improvements to accommodate 51,132
square feet / 1.17 acres of an existing industrial building for chemical
manufacturing and warehousing, operated by BioSafe Systems, LLC
for the manufacturing, packaging, storage, and distribution of
biodegradable crop protection, sanitation, and water treatment
products. The Project includes the storage and use of hazardous
materials typical of industrial chemical manufacturing operations, which
are conditionally permitted in the heavy industrial zone district and will
be managed in compliance with applicable regulatory requirements.
The facility serves agricultural, horticultural, and water treatment
markets in North America, with a primary focus on peracetic acid
(peroxyacetic acid, “PAA”) formulations.
Project operations involve a liquid blending process in which bulk raw
materials are combined to produce PAA products in various
concentrations. These activities, including manufacturing, packaging,
warehousing, and distribution, occur within the existing building and
associated outdoor storage areas.
The Project includes on-site storage and handling of raw materials and
finished products, as outlined below:
• Bulk storage of raw materials (70% Hydrogen Peroxide, 99%
Glacial Acetic Acid and Pelargonic Acid) in outdoor stainless
steel tanks within concrete containment areas, including
hydrogen peroxide and glacial acetic acid, with regular tanker
deliveries (multiple times per week).
• Storage of additional materials or hazmat ingredients (Hydroxy
ethylidene Diphosphonic Acid, 19% Aqua Ammonia and Sodium
Percarbonate) in totes, drums, supersacks, and bags.
• Packaging of finished products in UN-rated containers, including
jerricans, drums, totes, and bags.
• Warehouse storage of finished PAA products, sodium
percarbonate, sulfuric acid, and sodium hydroxide.
• Indoor production activities, including mixing, formulation, and
packaging using stainless steel tanks and piping systems.
The operating hours are Monday through Friday, from 6:30 a.m. to 4:00
p.m., with no evening or weekend operations.
See Figure 6 for the Project site plan and Figure 7 for floor plan.
Contact Information
Name
Rodney L. Horton
Agency Name
City of Reedley
Job Title
Community Development Director
Contact Types
Lead/Public Agency
Phone
Name
Armen Devejian
Agency Name
Associated Design & Engineering Inc.
Job Title
Project Applicant
Contact Types
Project Applicant
Phone
Email
Location
Cities
Reedley
Counties
Fresno
Regions
Citywide
Cross Streets
East Curtis Avenue and South Buttonwillow Avenue
Zip
93654
Total Acres
2.61
Jobs
6
Parcel #
370-070-92
Other Location Info
1485 East Curtis Avenue, Reedley, CA 93654
South side of East Curtis Avenue and west side of South Buttonwillow
Avenue
Notice of Exemption
Exempt Status
Categorical Exemption
Type, Section or Code
Sections 15332 (Class 32/Infill Development Projects) of the California Environmental Quality Act (CEQA) Guidelines
Reasons for Exemption
This project is exempt under Section 15332/Class 32 of the California Environmental
Quality Act (CEQA) Guidelines.
Under Section 15332/Class 32, the Project is exempt from CEQA requirements. Section
15332/Class 32 consists of projects characterized as in-fill development meeting conditions
described below.
a) The project is consistent with the applicable general plan designation and all applicable
general plan policies as well as with applicable zoning designation and regulations.
b) The proposed development occurs within city limits on a project site of no more than five
acres substantially surrounded by urban uses.
c) The project site has no value as habitat for endangered, rare, or threatened species.
d) Approval of the project would not result in any significant effects relating to traffic, noise,
air quality, or water quality.
e) The site can be adequately served by all required utilities and public services.
The following is an analysis of how the Project meets all conditions required to be exempt under
Section 15332/Class 32 of the CEQA Guidelines.
a) The project is consistent with the applicable general plan designation and all
applicable general plan policies as well as with applicable zoning designation and
regulations.
General Plan Land Use and Policies
According to the City of Reedley General Plan, the Project site has a planned land use
designation of General (Heavy) Industrial. The General (Heavy) Industrial land use
designation “is an area identified for more intense industrial uses. This highest intensification
of land use is also typically surrounded by light industrial land use designation as a potential
buffer to protect commercial and residential areas of the City. This land use must be
conveniently accessible to transportation networks available to move raw and manufactured
products.” The proposed use, industrial chemical manufacturing and warehousing facility, is
consistent with this land use designation. The Project site is located within an established
industrial area served by existing roadway infrastructure and utility systems, and no
expansion into undeveloped or non-industrial areas is proposed.
As shown in Table 1 below, the Project is consistent with applicable General Plan Land Use
Element policies governing heavy industrial development, including policies related to land
use intensity, infrastructure access, compatibility, and environmental protection.
Table 1. Project Consistency with Applicable General Plan Policies (Land Use Element)
Heavy Industrial
Implementing Policies Project Consistency
LU 2.7.53. Shall mean land designated for the
full range of manufacturing, processing, and
storage activities.
Consistent. The Project is consistent with this
policy as it involves manufacturing, processing,
and storage activities within an existing industrial
facility, which are permitted under the Heavy
Industrial designation.
LU 2.7.54. During review of development
plans for any proposed new heavy industry,
the City shall determine whether pretreatment
of industrial wastes shall be required.
Consistent. The Project will be subject to City
review and will comply with all applicable
wastewater discharge and pretreatment
requirements, if required.
LU 2.7.55. The City may establish conditions
on new heavy industrial development to
ensure compatibility with surrounding land
uses.
Consistent. The Project is located within an
established industrial area and will comply with all
conditions of approval imposed by the City during
the Conditional Use Permit (CUP) entitlement
process.
LU 2.7.56. Access to industrial areas should
be by streets designed to carry heavy
industrial traffic in accordance with
development standards found in the
Circulation Element.
Consistent. The Project would utilize the existing
site access from East Curtis Avenue. The Project
does not propose modifications to access points
or circulation patterns and would continue to rely
on the existing roadway network.
LU 2.7.57. Planned heavy industrial uses
adjacent to roads carrying significant
nonindustrial traffic should be designed to
have landscaping and building setbacks.
Consistent. The Project is surrounded by
industrial uses; therefore, the surrounding roads
primarily carry industrial traffic. Additionally,
building setbacks and landscaping comply with
the applicable code requirements.
LU 2.7.58. Heavy industrial planned land uses
should be clustered based upon compatibility
and operational efficiencies to maximize
available infrastructure.
Consistent. The Project is located within an
established industrial area where similar uses are
clustered, supporting compatibility and efficient
use of existing infrastructure.
LU 2.7.59. New heavy industrial uses should
be encouraged to concentrate in the
southeastern portion of the Planning Area
where they are downwind from other less
intensive uses.
Consistent. The Project is located within an
existing industrial area planned for heavy
industrial uses. No expansion into new areas is
proposed.
LU 2.7.60. Heavy Industrial uses shall be
planned to minimize health risks to people
resulting from toxic or hazardous air pollutant
emissions.
Consistent. The Project would comply with all
applicable air quality regulations to minimize
potential health risks associated with emissions
from industrial operations.
LU 2.7.61. The City shall limit expansion of
manufacturing, industrial and processing
facilities that creates significant sources of air
pollution unless the impacts to adjacent
sensitive areas can be mitigated.
Consistent. The Project does not involve
expansion of the facility beyond the existing
developed area. Operations would be conducted
in compliance with applicable air quality standards
to avoid significant impacts.
LU 2.7.62. Protect heavy industrial sites from
encroachment by residential and other
sensitive uses through appropriate zoning and
interface standards.
Consistent. The Project is located within a fully
industrial area and does not introduce sensitive
uses.
LU 2.7.63. Planned unit development may be
permitted in all industrial land use
designations.
Not Applicable. The Project does not propose
planned unit development.
Therefore, the Project is consistent with the applicable general plan land use designation and
all applicable general plan land use policies.
As shown in Table 2 below, the Project is generally consistent with the applicable General
Plan policies to protect the public and the environment from exposure to hazardous materials
(Goal SE 5.6A).
Table 2. Project Consistency with Applicable General Plan Policies (Safety Element)
Hazardous Materials
Implementing Policies Project Consistency
SE 5.6.1 Assess the risk involving the
transportation, disposal, manufacture, storage
and handling of any hazardous materials at all
levels of planning.
Consistent. The Project involves the handling
and storage of hazardous materials within an
existing industrial facility. Potential risks are
addressed through engineered process safety
systems, including automated controls,
interlocked shutdown mechanisms, secondary
containment, spill response procedures,
employee safety training programs, and formal
emergency response procedures designed to
minimize the potential for accidental releases. The
facility would also operate in compliance with
applicable hazardous materials regulations,
including OSHA Process Safety Management
(PSM) and EPA Risk Management Program
(RMP) requirements.
SE 5.6.2 Residential development in close
proximity to heavy industrial zones shall be
avoided.
Consistent. The Project is located within an
established Heavy Industrial area and does not
introduce residential or other sensitive land uses,
thereby maintaining appropriate separation
between industrial operations and sensitive
receptors.
SE 5.6.3 Establish a program to obtain
hazardous materials control, technical
assistance and cleanup to response to
hazardous materials incidents.
Consistent. The Project incorporates formal
hazardous materials emergency response
procedures, including spill response protocols,
evacuation thresholds, incident reporting, and
coordination with emergency response agencies
in the event of a chemical incident.
Zoning Designation and Regulations
According to Section 10.14.020.B of the Reedley Municipal Code (RMC), the MH – Heavy
Industrial Zone District is intended to accommodate a wider variety of land uses that are moreCITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 13 of 18
land-intensive manufacturing uses than allowed in the Light Industrial (MI) Zone District.
Hazardous industrial uses are conditionally permitted within this zone, subject to applicable
review and compliance requirements. As part of the Conditional Use Permit entitlement
process, the Project would be required to comply with all applicable zoning regulations,
including development standards, general provisions, and parking requirements (RMC
Sections 10.14.030, 10.14.040, 10.14.050, 10.36.050.C, and 10.38.030). The Project does
not request any deviations from applicable development standards and would be required to
comply with all applicable provisions of the RMC. Accordingly, the Project is consistent with
applicable zoning and development regulations.
b) The proposed development occurs within city limits on a project site of no more than
five acres substantially surrounded by urban uses. The Project site is located on the
southwest corner of South Buttonwillow Avenue and East Curtis Avenue at 1485 East Curtis
Avenue, Reedley, CA 93654. The area proposed for physical construction and operations is
limited to approximately 2.61 acres of Assessor’s Parcel Number (APN) 370-070-92, a 13.21-
acre parcel located within the City of Reedley limits. The site is designated by the Reedley
General Plan for heavy industrial use. The Project site is surrounded by existing industrial
uses to the north, south, west, and east. Existing uses within the broader Project vicinity (i.e.,
0.25-mile radius) comprise a mix of industrial and agricultural uses. Thus, the Project occurs
within city limits on a site with an area of work that is no more than five (5) acres and is
substantially surrounded by urban uses.
c) The project site has no value as habitat for endangered, rare, or threatened species.
The Project site is developed with an existing industrial facility, including an industrial
building, parking areas, pavement, and associated improvements. The Project proposes
minor improvements to accommodate 51,132 square feet of an existing industrial building for
chemical manufacturing and warehousing for the manufacturing, packaging, storage, and
distribution of biodegradable crop protection, sanitation, and water treatment products.
Proposed improvements are proposed within the existing industrial building and pavement
areas, with no ground disturbance to undeveloped portions of the parcel.
The parcel contains a few trees and does not include landscaped areas, natural habitat
features, or undisturbed soils. As such, the site does not provide suitable habitat for specialstatus species. Due to the developed condition of the site, the lack of suitable habitat, and its
location within an established industrial area, the Project site has no value as habitat for
endangered, rare, or threatened species and does not support sensitive biological resources.
d) Approval of the project would not result in any significant effects relating to traffic,
noise, air quality, or water quality.
The Project proposes minor tenant improvements to accommodate 51,132 square feet of an
existing industrial facility and is located within an established industrial area. The proposed
Project involves parking stall, pavement, and interior improvements for chemical
manufacturing and warehousing for the manufacturing, packaging, storage, and distribution
of biodegradable crop protection, sanitation, and water treatment products. No expansion of
the building footprint and no changes to site access or circulation are proposed.CITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 14 of 18
The Project requires approval of a Conditional Use Permit (CUP) pursuant to the City’s
Municipal Code. Approval of the Project would not result in any significant impacts related to
traffic, noise, air quality, or water quality.
Traffic
The Project would utilize the existing industrial facility and existing site access from East
Curtis Avenue. No changes to site access points, circulation patterns, or roadway
improvements are proposed. The project is anticipated to generate approximately 181 daily
trips based on ITE trip generation rates, assuming an increase from 6 existing employees to
10 employees and a mix of manufacturing and warehouse uses. This level of trip generation
is consistent with moderate-to-heavy industrial development and is not expected to result in
significant traffic impacts within the surrounding industrial context. Truck deliveries and
employee trips would be consistent with the site’s industrial zoning and adjacent land uses.
Inbound and outbound truck activity would consist primarily of small parcel vans, tractor
trailers, and occasional tanker deliveries typical of industrial operations and would remain
consistent with surrounding industrial land uses. Therefore, the Project would not result in a
significant increase in traffic impacts or require roadway capacity improvements.
Noise
The Project would be located within an existing heavy industrial area where similar
manufacturing and warehouse uses are already present or permitted. Operational noise
would be limited to typical industrial activities such as material handling, mixing,
warehousing, and truck loading/unloading, all occurring within an existing facility. No new
sensitive receptors would be introduced, and operations would be subject to applicable local
noise standards. Given the industrial setting and existing development, the Project would not
result in a significant noise impact.
Air Quality
The Project is located within a fully developed industrial area that is consistent with the City’s
industrial land use designations and zoning, which allow for industrial operations, including
hazardous materials uses subject to approval of a Conditional Use Permit.
The Project involves the continued operation of an existing industrial facility engaged in the
formulation of peracetic acid (PAA) solutions. The process includes the controlled handling
of hydrogen peroxide, glacial acetic acid, and related formulation components within
enclosed tanks, piping, and batching systems.
These materials have recognized industrial hazards and may exhibit properties such as
corrosivity, oxidizing behavior, and limited volatility. In particular, glacial acetic acid may
contribute to minor volatile organic compound (VOC) emissions, and peracetic acid systems
may generate trace vapors under certain handling conditions. However, these materials are
processed within closed or semi-closed systems equipped with level controls, interlocks, and
automated shutdown features designed to minimize releases during normal operations.
The facility operates under established safety procedures governing chemical storage,
transfer, and batching, including containment systems, emergency quench controls forCITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 15 of 18
reactive materials, and spill response protocols. These measures, combined with regulatory
oversight under applicable air district, hazardous materials, OSHA Process Safety
Management (PSM), and EPA Risk Management Program (RMP) requirements, are
intended to reduce potential air quality and accidental release impacts. Bulk storage and
mixing equipment would utilize secondary containment systems designed to minimize the
potential for accidental releases, and employees would receive ongoing hazardous material
handling and safety training.
Operational emissions are primarily associated with routine industrial activities such as
equipment operation, material transfer, and truck deliveries, and are consistent with other
industrial uses in the surrounding area. Any potential air quality impacts, including criteria
pollutants and minor VOC contributions, are subject to applicable regulatory standards and
permitting requirements.
The Project would not expand the existing facility footprint and would occur within an
established industrial setting served by existing infrastructure. Truck activity and operational
intensity would remain consistent with surrounding industrial land uses.
Based on these characteristics, The Project involves regulated industrial materials and
processes; however, these operations occur within engineered containment systems and
established regulatory frameworks designed to manage potential environmental effects. No
unusual circumstances are anticipated that would result in environmental impacts beyond
those typical of similar industrial facilities in the area.
Small Project Analysis Level (SPAL)2:
Consistent with the San Joaquin Valley Air Pollution Control District’s Guidance for Assessing
and Mitigating Air Quality Impacts (GAMAQI), the Project qualifies for Small Project Analysis
Level (SPAL) screening. The Project is categorized as a heavy industrial land use and is
below the applicable SPAL screening thresholds for project size and trip generation.
Under SPAL Table 4a (Industrial – Heavy Industrial), projects up to 900,000 square feet and
generating fewer than 550 average daily one-way trips (excluding heavy-heavy duty truck
(HHDT)) and fewer than 70 HHDT trips are considered to have a less-than-significant impact
for criteria pollutants without the need for detailed emission quantification using CalEEMod.
The Project is well below these screening thresholds based on its existing facility footprint
and anticipated trip generation. Accordingly, criteria pollutant emissions are considered less
than significant under SPAL screening criteria. Toxic air contaminant emissions are also
expected to be minimal due to enclosed processing systems and required regulatory
controls.
Therefore, the Project would not result in significant air quality impacts.
2 San Joaquin Valley Air Pollution Control District. Small Project Analysis Levels (SPAL). Accessed April 29, 2026,
https://www.valleyair.org/media/5jppiwed/cms-format-spal.pdfCITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 16 of 18
Water Quality
The Project would utilize existing site infrastructure, including drainage and utility systems,
and would not expand impervious surface area beyond the previously developed industrial
site footprint. On-site chemical storage, handling, and containment systems (including
secondary containment for bulk materials such as hydrogen peroxide and glacial acetic acid)
are designed to prevent releases to stormwater or surrounding areas. The facility would be
required to comply with all applicable industrial stormwater permitting requirements and
hazardous materials containment standards. The Project would also utilize an existing
Reverse Osmosis (RO) water system associated with the facility’s operations, with
wastewater directed to the existing sewer system in compliance with applicable regulatory
requirements. Production processes are designed to minimize waste generation through
reuse and recirculation practices within the facility’s operations. The Project would therefore
not result in significant impacts to water quality.
Given the limited scope of improvements, the use of an existing facility, industry standard
practices, and compliance with applicable standards, approval of the Project would not result
in any significant effects relating to traffic, noise, air quality, or water quality.
e) The site can be adequately served by all required utilities and public services.
The Project site is located in an area served by existing public utilities and services. The site
has been developed and operated as an industrial facility for many years and is currently
served by established roadway access, water, wastewater, stormwater, and utility
infrastructure. The Project would continue to rely on these existing services, which are
maintained by the City and applicable utility providers. Therefore, the site can be adequately
served by all required utilities and public services.
Based on the analysis contained above, none of the exceptions to Categorical
Exemptions set forth in the CEQA Guidelines, Section 15300.2 apply to this Project as
analyzed in the following:
a) Location. Classes 3, 4, 5, 6, and 11 are qualified by consideration of where the project is
to be located – a project that is ordinarily insignificant in its impact on the environment
may in a particularly sensitive environment be significant. Therefore, these classes are
considered to apply all instances, except where the project may impact on an
environmental resource of hazardous or critical concern where designated, precisely
mapped, and officially adopted pursuant to law by federal, state, or local agencies.
Classes 3 (New Construction or Conversion of Small Structures), 4 (Minor Alterations to
Land), 5 (Minor Alterations in Land Use Limitations), 6 (Information Collection), and 11
(Accessory Structures) are not applicable to the proposed Project. Therefore, the
location-based exceptions associated with these classes do not apply.
b) Cumulative Impact. All exemptions for this class are inapplicable when the cumulative
impact of successive projects of the same type in the same place, over time is significant.
(“Cumulative Impact” is defined as the condition under which “two or more individualCITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 17 of 18
effects which, when considered together, are considerable or which compound or
increase other environmental impacts,” pursuant to CEQA Guidelines Section 15355)
The Project proposes a use that is consistent with and permitted by the Reedley General
Plan and RMC. Adherence to the applicable policies and regulations would ensure that
implementation of successive projects of the same type in the same place, over time
would not constitute a significant, cumulative impact.
c) Significant Effect. A categorical exemption shall not be used for an activity where there is
a reasonable possibility that the activity will have a significant effect on the environment
due to unusual circumstances.
The Project consists of industrial chemical manufacturing, blending, storage, and
warehousing operations within an existing industrial facility. While the Project involves
regulated hazardous materials, such uses are consistent with the heavy industrial zoning
designation and are commonly anticipated within this type of land use environment. The
facility incorporates engineered safety systems, containment measures, and operational
procedures designed to comply with applicable local, state, and federal safety and
hazardous materials regulations. The Project does not present any unusual
circumstances that would result in a significant environmental effect beyond those
typically associated with permitted heavy industrial uses. Therefore, this exception does
not apply.
d) Scenic Highways. A categorical exemption shall not be used for a project which may
result in damage to scenic resources within a highway officially designated as a state
scenic highway.
According to the California State Scenic Highway System Map3, the Project is not located
near a state-designated scenic highway. Therefore, the Project would not damage scenic
resources within the state scenic highway.
e) Hazardous Waste Sites. A categorical exemption shall not be used for a project located
on a site which is included on any list compiled pursuant to Section 65962.5 of the
Government Code. The Project is not located on a site that is included in any list compiled
pursuant to Section 65962.5 of the Government Code.
A search of the California Department of Toxic Substance Control’s EnviroStor database
4 and the State Water Resources Control Board’s GeoTracker database 5 reveal no
hazardous material release sites on the Project site. Thus, no impact would occur.
3 California Department of Transportation. Statewide Scenic Highway. Accessed April 29, 2026,
https://experience.arcgis.com/experience/47e2009986264718a5a13a2c81382774
4 California Department of Toxic Substances Control. Envirostor. Accessed April 22, 2026,
https://www.envirostor.dtsc.ca.gov/public/
5 California State Water Resources Control Board. GeoTracker. Accessed April 22, 2026,
https://geotracker.waterboards.ca.gov/CITY OF REEDLEY – Biosafe Systems Tenant Improvements Page 18 of 18
f) Historical Resources. A categorical exemption shall not be used for a project which may
cause a substantial adverse change in the significance of a historical resource.
According to the Reedley General Plan, there are no local, state, or federal designated
historical resources on the Project site.
Overall, the Project is consistent with the applicable general plan designation and policies as
well as the applicable zoning designation and regulations. It occurs within city limits on a site
less than five (5)-acres in size within an urbanized area. The highly disturbed site within an
urbanized area has no value as habitat for endangered, rare, or threatened species. Further, the
Project would not result in any significant effects relating to traffic, noise, air quality, or water
quality and can be adequately served by all required utilities and public services. As such, the
proposed Project is not expected to have a significant effect on the environment. Accordingly, a
categorical exemption, as noted above, has been prepared for the Project.
County Clerk
Fresno
Attachments
Notice of Exemption
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