Exhibit L - Plan comments received after the Public Review Period

Exhibit L
Plan Comments Received
After Public Review Period
List of Commenters on the Plan after the Public Review Period Ended On October 7, 2024, the City of Fresno sent a letter to all 300 property owners within the Plan Area whose property is proposed to change land use classifications. Property owners were encouraged to contact City staff by November 14, 2024, with any questions or to express opposition to the proposed land use change to their property. On November 8, 2024, the City also sent a letter to all 714 property owners within the Plan Area to notify them that the Plan may change development standards on their property. Table 2 presents the list of commenters, including the numerical designation for each comment letter received on the Plan, the author of the comment letter, the date of the comment letter, and the page number the comment begins on for the comment letters and emails received after the Public Review Period ended on July 30, 2024, and after the October 7th letter was sent.

Table 2 List of Commenters
Letter No. Commenter Date Page

COMPANIES, BUSINESS ASSOCIATIONS, LABOR, OTHER

ORGANIZATIONS

33 D & I Farms, Daniel Barandalla
Dirk Poeschel
10/22/2024 1
34 Agro Plantae , Mr. Angeloe Paolussi & Mrs Rosanna DiLallo Dirk Poeschel
10/28/2024 8
35 Jaspreet Singh and Gurinder Panaych 10/30/2024 12
36 Wolfson Bolton Kochis
Thomas J Howlett
11/06/2024 13
37 Wanger Jones Helsley
John P. Kinsey
11/11/2024 15
38 Wanger Jones Helsley
John P. Kinsey
11/12/2024 18
39 Diversified Development Group 11/13/2024 20
40 Robert V. Jensen, Inc.

William V. Jensen
ND 22
41 Avina Ralph J Trustee De Avina Maria Cervantes
Ralph Avina
11/13/2024 25
42 Western Terminals LLC
Perman Sihota
11/13/2024 26
43 Valley Iron, Inc
Noel Briscoe
ND 27
44 Tri Valley Investments, LLC
Kenea Bains
11/13/2024 29
45 Heather Mooney 11/13/2024 30
46 Jonathan Thomas 11/13/2024 31
47 Fowler Packing
Susan Galdding
11/13/2024 32
48 Formax LLC
Mark Ford
11/13/2024 33
49 Grace Truck Parking
Manreet Ladham
11/13/2024 35
50 Tarlton and Sons 11/13/2024 36
L ist of Commenters on the Plan after the Public Review Period Ended Letter No. Commenter Date Page
Clifton Wahlberg
51 Wanger Jones Helsley
John P. Kinsey
11/8/2024 39
52 Affinity Trucking
Kim Mesfin
11/14/2024 41
53 Jason and Jamie Thomas 11/14/2024 43
54 Span Development Company
Timothy Mitchell
11/14/2024 44
55 Fortune Associates Commercial Real Estate
Amir Dehlan
11/14/2024 46
56 Valley Wide Beverage
John Amendola
11/14/2024 48
57 Valley Wide Beverage
John Amendola
11/14/2024 50
58 TRICOZ LLC
Bryan Cossette
11/14/2024 52
59 Fowler Packing
Leland Parnagian
11/14/2024 53
60 Tavares Family Trust
Elisabeth Balcom
11/14/2024 55
61 3 G Containers
Daniel Mosto
11/14/2024 57
62 Jason Thomas 11/18/2024 59
63 Heather Mooney 11/18/2024 61
64 Invest Fresno et al.

Ben Granhom
11/19/2024 63
65 Center for Biological Diversity
Frances Tinney
11/19/2024 70
33 1
2 3
4 5
6 7
■
■ ■
DIRK POESCHEL 923 Van Ness Avenue, Suite 200 • Fresno, California 93721 ■■ l..Arul Development Services, Inc. 559/445-0374 • Fax: 559/445-0551 • email: [email protected] October 28, 2024
Ms. Michelle Zumwalt, Architect
City of Freno Planning & Development Department
2600 Fresno Street, Room 3034
Fresno, CA 93721-3604
SUBJECT: AgroPlantae Property Proposed South Central Specific Plan Land Use Change Re: APNs 316-071-36, 37, 38 & 75
Dear Ms. Zumwalt:

Reference is made to the two letters dated October 7, 2024, to my clients Mr. Angelo Paolucci & Ms. Rosanna DiLallo. One letter proposes to change the land use designation and zoning of APN 316-071-36 from a single land use designation of Business Park on the entire 3.46-acre parcel to Business Park on 2.46 acres and Low Density Residential on 1.0 acre resulting in split zoning on the parcel. The map attached to the letter incorrectly identifies the parcel as entirely Low Density Residential which does not match the proposed change described in the letter.

The second letter proposes to change the land use designation of the 19.65+/- acreAPN 316- 071-75 from Light Industrial which is incorrect as that parcel is currently designated Business Park on the City of Fresno Official General Plan Land Use and Circulation Map. My clients also own APN 316-071-38 which was not mentioned in either letter but is presumed to remain designated Business Park by the city. Please see the attached assessor's map depicting the aforementioned parcels.

Angelo and Rosanna own and operate AgroPlantae, a fertilizer manufacturing company that has been in business at the present location since 2012 without incident. AgroPlantae produces specialty fertilizers sold to wholesalers as far east as Texas.

The company has been actively planning for project expansion for some time. AgroPlantae has acquired APN 319-171-75 totaling 19 .65+/- for the express purpose of expanding project operations and improving project production efficiency. This expansion would allow a valuable niche product that serves the agricultural industry, formulated at a local facility, by a local workforce.

Expansion of the AgroPlantae facility represents opportunities for additional job creation in the short-term during project construction and long-term associated with increased production.

The city and county will also benefit from increased tax revenues and the multiplier effect from the facility on the local and regional economy.

To place the contribution in perspective, 20% of all Fresno County jobs are related to agriculture while contributing 8.6 billion dollars to the local economy. Simply, the project is 34 8
9 10
11 Email sent 10/30/2024
Dear Ms. Zumwalt,
Subject: Objection to Proposed Zoning Change to “Business Park” for Property [33021118] I am writing in response to the notiﬁcation dated October 7, 2024, regarding the proposed change of zoning for my property located at 4531 S Maple Ave 330-211-18 to “Business Park” under the Draft South Central Speciﬁc Plan (SCSP). While I respect the city’s efforts to plan and develop Fresno’s growth, I must respectfully oppose this zoning change due to signiﬁcant ongoing investments and plans that have been in place since 2021.

Since 2021, I have been actively pursuing a rezoning of this property to “Light Industrial” to support our intended use and business objectives. This effort has already involved a substantial ﬁnancial investment of approximately $100,000, covering planning, consultations, and necessary adjustments to align with “Light Industrial” standards. A sudden shift to a “Business Park” designation is inconsistent with our current and planned land use and would undermine the resources and time we have committed to this project.

I urge the Planning and Development Department to reconsider this rezoning proposal, taking into account the investments and the speciﬁc land use needs for my business.

Thank you for your attention to this matter.

Sincerely,
Jaspreet Singh & Gurinder Panaych
[email protected]
35 12
Wolfson Bolton Kochi
s PLLC
3150 Livernois, Suite 275
Troy, Michigan 48083
www.wolfsonbolton.com
Thomas J. Howlett
(248)
247-7107
[email protected]
November 6, 2024
Via Email
City of Fresno
Attn: M
ichelle Zumwalt, Architect
Planning and Development Department
[email protected]
Re: Crown Enterprises,
LLC Property (32910001) and Proposed Draft South Central Specific Plan
Dear Ms. Zumwalt:

This firm represent
s Crown Enterprises, LLC. I am writing in response to your October 7, 2024, letter concerning the potential land use changes to Crown’s property (Property ID 3291001) within the proposed Draft South Central Specific Plan (SCSP) area. Crown would like to schedule a meeting with you, as suggested in your letter, as soon as possible.

Since 2021, Crown has acti
vely developed this Property, fully cooperating with the City and working closely with Fresno’s Planning Commission. Crown has pursued its truck terminal development under the permitted uses of the Property’s original Industrial zoning and the proposed SCSP “Business Park” zoning. Any modifications under the SCSP that would impede or obstruct Crown’s development plans, which have been known to the City for over three years, would significantly and irreparably impact Crown’s investment. Therefore, Crown respectfully requests that the City of Fresno refrain from altering the Property’s existing zoning designation or imposing the SCSP’s requirements on the Property. The SCSP’s application to Crown’s Property would constitute a considerable attack on Crown’s property rights.

Crown acquired the Pr
operty specifically to build a terminal facility—a permitted use under both the existing and proposed zoning guidelines. In fact, the Property was acquired because Crown’s previous facility was condemned to make way for the CAHSR project. As part of that taking, Crown was assured that the City would expedite Crown’s terminal development of its new site. That did not happen, and now the development itself may be at risk. Further, delays related to the City’s 36 13
proposed annexation of the pr
operty have created additional hurdles for Crown – and more delays outside of Crown’s control. All of these delays are why Crown now faces potential issues related to the SCSP.

The Property’s immedi
ate area contains similar truck terminal and industrial facilities, including a truck and trailer repair business on the adjacent northern lot, which is neither subject to rezoning nor incorporated into the SCSP. Crown has committed substantial resources toward developing its state- of-the-art facility and seeks to continue this effort. Throughout this process, Crown has collaborated closely with the City and the Planning Commission, despite facing notable delays on the City’s part.

Crown simply wishes to complete the development it has consistently advanced in partnership with the City since 2021.

Crown is commit
ted to working with the City of Fresno and continuing its long term investment there, hoping to reach a solution that benefits both parties. We propose a meeting to discuss your October 7 letter, this response, the City imposed delays, and the SCSP’s impact on Crown’s Property at your earliest convenience. Once again, Crown requests that the SCSP not apply its land use restrictions to its current and ongoing development.

Thank you for your att
ention to this matter. We look forward to your prompt response and to completing construction under the existing plans.

Sincerely,
Thomas J. Howlett
14 O L I V E R W . W A N G E R
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WANGER JONES HELSLEY PC

A T T O R N E Y S
265 E. RIVER PARK CIRCLE, SUITE 310
FRESNO, CALIFORNIA 93720

M A I L I N G A D D R E S S
P O S T O F F I C E B O X 2 8 3 4 0
F R E S N O , C A L I F O R N I A 9 3 7 2 9

T E L E P H O N E
( 5 5 9 ) 2 3 3- 4 8 0 0
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November 11, 2024
VIA US MAIL and EMAIL [[email protected]]
Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Proposed Land Use Change
Dear Ms. Zumwalt:

My law firm represents Orange Avenue Disposal Company, Inc. (“OAD”) and Frank S. Caglia Family Limited Partnership (the “Caglia Partnership”). OAD and the Caglia Partnership received several letters dated October 7, 2024, from the City of Fresno (the “City”) concerning several of its properties in South Central Fresno, including Fresno County Assessor’s Parcel No. (“APN”) 330-021-02, 330-021-09, 330-021-16, 330-021-30, 330-021-55, and 330-021- 57 (collectively, the “Properties”).

The October 7, 2024, letter advises that the City, through its South Central Specific Plan (the “SCSP”), is contemplating the downzoning of those properties to other zone districts, as follows:
37 15

WANGER JONES HELSLEY PC
Michelle Zumwalt
City of Fresno
November 11, 2024

Page 2 ends

4885-1181-9254, v. 4
APN Existing Zoning Proposed SCSP Zoning
330-021-02 Heavy Industrial Light Industrial
330-021-09 Heavy Industrial Business Park
330-021-16 Heavy Industrial Light Industrial
330-021-30 Heavy Industrial Business Park
330-021-55 Heavy Industrial Light Industrial
330-021-57 Heavy Industrial Business Park
OAD and the Caglia Partnership oppose any efforts to change the zoning of real property against the wishes of any landowner, and they strongly object to the downzoning of the above Properties in the SCSP.

OAD and the Caglia Partnership have owned the Properties many decades and have long intended to develop the Properties consistent with the Heavy Industrial zoning. OAD and the Caglia Partnership have previously sought entitlements for the Properties, and have recently submitted applications to the City of Fresno for land uses consistent with the current zoning. OAD and Caglia are also under a lease agreement with a Fortune 100 company, with the existing zoning being one of the core underlying assumptions for both parties under the agreement.

Downzoning the Properties would make little sense in light of the fact that the City has contemplated since the 1940s or earlier that South Central Fresno would remain an industrial reserve. Industrial development is also consistent with the surrounding land uses. The Properties enjoy convenient access to both State Route 41 and State Route 99, and trips traveling to and from the Properties would not need to pass through or adjacent to established residential neighborhoods.

The Properties are adjacent to other Heavy Industrial uses to the north and east, the Amazon distribution facility to the west, and a mix of truck parking facilities, salvage yards, and a small number of rural residential land uses across Central Canal to the south.

In light of this setting, there has been nothing to suggest to the landowners or the community at large that the Properties would be zoned something other than Heavy Industrial.

The proposed downzoning completely would undermine those investment-backed expectations, as well as job creation and economic development.
///
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16 17
O L I V E R W . W A N G E R
T I M O T H Y J O N E S *
M I C H A E L S . H E L S L E Y
R I L E Y C . W A L T E R
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†† A l s o a d m i t t e d i n T e x a s

WANGER JONES HELSLEY PC

A T T O R N E Y S
265 E. RIVER PARK CIRCLE, SUITE 310
FRESNO, CALIFORNIA 93720

M A I L I N G A D D R E S S
P O S T O F F I C E B O X 2 8 3 4 0
F R E S N O , C A L I F O R N I A 9 3 7 2 9

T E L E P H O N E
( 5 5 9 ) 2 3 3- 4 8 0 0
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( 5 5 9 ) 2 3 3- 9 3 3 0
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O F F I C E A D M I N I S T R A T O R
L Y N N M . H O F F M A N
W r i t e r ’ s E- M a i l A d d r e s s :
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W e b s i t e :
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November 12, 2024
Via Email [[email protected]] and United States Mail Michelle Zumwalt, Architect
Planning & Development Department

CITY OF FRESNO
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Notice to Affected Landowners
Dear Ms. Zumwalt:

As you are aware, my law firm represents numerous businesses and landowners located within the boundaries of the proposed South Central Specific Plan (the “SCSP”). In letters dated October 7, 2024, I understand the City of Fresno (the “City”) has endeavored to contact landowners whose properties are the subject of potential zoning and land use designation changes under the SCSP. I understand the Cit y has issued these letters to, inter alia, notify landowners whose rights may be affected by the SCSP, and whose existing land uses may become legal non - conforming uses.

This effort, while appreciated, is not sufficient to alert landowners within the SCSP area to the significant constraints on their properties and businesses that the SCSP would create.

As a result, to protect the constitutional rights of landowners and business owners within the SCSP area, the City should engage in significant additional outreach to affected members of the public. 38 18
19 sified
roup
Via Email [[email protected]] and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Dear Ms. Zumwalt:

November 12, 2024
Re: Objection to Proposed Land Use Change
On behalf of Cast N Blast, LP, Diversified Development Group, Inc., is writing in response to the October 7, 2024, letter we received from the City of Fresno's Planning and Development Department advising that Cast N Blast, LP's property, identified as APN 329-110-07 would be downzoned under the City's Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline the downzoning of properties against the wishes of the underlying landowners.

Diversified Development Group, Inc has been developing industrial warehouse projects in the City of Fresno for over 45 years. Some of our tenants include Kraft Foods, Pepsi, Mission Foods, Electronic Recyclers and Lyons Magnus just to name a few. These companies and many others employee thousands of Fresno residents.

It is vital for a prosperous City to have readily available industrial buildings to attract both new companies and existing companies that are expanding. These companies bring jobs to the City of Fresno which increases the tax base and benefits everyone.

Cast N Blast, LP objects to the proposed downzoning of the Property. Cast N Blast, LP purchased the Property with the understanding and expectation that South Central Fresno had long been set aside by the City as an industrial preserve. The City of Fresno urged us to buy the property and was 100% in supp01i of the annexation into the City and rezone to M3. It is an outrage that the City would seek to downzone the Property in the future. The proposed downzoning completely undermines those expectations in a manner that destabilizes future development potential, job creation, and land value.
,_ ___ 7519 N. Ingram, Suite 104, Fresno, California 93711 • (559) 225-6363 • www.ddginc.net ---- 39 20
21 rf \ fu m_p..1
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ROBBR'I" V. JBJ!ISBII. IIIC . ... �,.. , .... ,1 '!If&':=1;� . flt"= PETROLEUM DISTRIBUTOR SINCE 1952
P.O BOX 12907 • FRESNO, CA 93779-2907
PHONE: (559) 485-8210 • FAX: (559) 485-8503
TOLL FREE: (800) 366-8210
Via Email [email protected]! and United States Mail Michelle Zumwalt, Architect
Planning & Development Department

CITY OF FRESNO
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Objection to Proposed Land Use Change Under SCSP
Dear Ms. Zumwalt:

I am writing on behalf ofRVJ Equipment Leasing LLC ("RVJ") and Robert V. Jensen Inc. (collectively, ''RV Jensen'') in response to your October 7, 2024, letter advising that RV J's real property identified as Fresno County Assessor's Parcel No. 330-031-11 (the ·'Property") may be changed under the City of Fresno's proposed South Central Specific Plan (the "SCSP") from its current land use and zoning designation of Heavy industrial to Medium Density Residential. For the reasons detailed below, RV Jensen strongly ohjects to the proposed rezoning of the Property.

A. Background on RV Jensen
RV Jensen is a family-owned and -operated business serving wholesale and retail clients with high quality bulk lubricants, bulk fuel delivery, fleet fueling, and emission solutions for nearly 75 years. RV Jensen's founder, Robert V. Jensen, began operations in 1952 as a Chevron Tenninal Agent serving Fresno wholesale commercial business and farm owners. However, when Chevron converted its highest yielding agents to independent petroleum jobbers in J 979, the business expanded to offer multiple brands of oil products and emission solutions for customers across California. Today, RV Jensen is an industry leader that provides innovative and environmentally friendly products from national brands like Chevron. Shell, Pennzoil, Quaker State, 76, and Valero to customers in cow1ties across California, including Fresno, Madera, Kings, Tulare, Kern, Stanjslaus, Monterey, Merced, Mariposa, and Santa Barbara.

In recent years, we have leveraged our success with traditional petroleum fuel to become among the first in Fresno to offer a wide range of high quality, low- and zero-emission products and services. For instance, we offer renewable diesel fuel and biodiesel, which are derived solely from agricultural waste and completely eliminate dependency on petroleum diesel fuel while improving operational efficiency and reducing impacts to air quality. Further, in association with Advanced Emission Control Solutions (AECS). we offer California Air Resources Board compliant emissions solutions, including regulatory consultation. diesel pai1iculate filter cleaning,
maintenance, and diagnostics, and emergency generator service, among other things. But this is 4856_g1J��!�SJ'fi CHEVRON FUELS ANO LUBRICANTS • PENNZOIL·QUAKER STATE LUBRICANTS • SHELL LUBRICANTS • 76 FUELS • VALERO FUELS • • SERVING THE SAN JOAQUIN VALLEY AND CENTRAL COAST
40 22
23 24
Email sent November 13, 2024
Hello Miche
lle, this is Ralph Avina and I oppose this new planned rezoning of my property. I would like to remain on my current zoning. APN numbers for my two parcels are as follows:

APN: 31607
167 & 31607168
41 25
Emailed 11/8/2024
Good Afternoon Michelle,
I am just trying to follow up on this request from last year. I’ve called your office and left a voicemail also. I had sent the letter to your office last year regarding the rezoning because there was a certain portion of our property that was still being zoned for residential.

We recently got the attached letter in the mail, so I just want to make sure that our concern of zoning the WHOLE property as Business Park.

I look forward to hearing back from you.

Thanks
Perman Sihota
559-977-8993
Emailed 6/
29/2023
Good Afternoon Michelle,
My name is Perman Sihota and I am with Western Terminals LLC. I also called and left you a voicemail. We have a property located at 3451 S Cherry Ave, Fresno CA 93725 that is part of the South Central Speciﬁc Plan. On the property itself, there is a small portion of the property that has an abandoned home on it that is designated to be “Residential” . We’d like to see if we can have that residential portion to be included with the rest of the property as a “Business Park” designation, as we will be demolishing the house.

I’ve marked the subject property with a red line in the attached map.

Please let me know if this can be done and if there’s any other info you’ll need from me.

Thank You,
Perman Sihota
559-977-8993
42 26
43 27
28 Email subject: Tri Valley Investments, LLC - Malaga Ranch; County APN 330-150-36 Hi Michelle,
I am in receipt of your correspondence regarding a proposed zoning change to our parcel by the City from heavy industrial to business park. We oppose such change to the zoning and desire to retain the heavy industrial zoning. Thank you.

Kenea Bains, Manager
Tri Valley Investments, LLC
44 29
November 13, 2024
Michelle Zumwalt
Architect
City of Fresno
Planning and Development Department
Dear Michel
le Zumwalt,
I am writing this letter regarding the Draft South Central Speciﬁc Plan.

I currently own 4 properties that are within the area of this proposed plan.

The APN’s are the following:
33013007
33013008
33013009
33013018S
I strongly oppose the proposed land use change.

My grandfather purchased these properties in the 1960’s and it was always his desire that these properties would one day be used to the full extent of their zoning capacity. My family has paid the much higher Heavy industrial use property taxes on these properties for decades waiting for the city sewer and water to be completed to our properties. One property alone costs us $6875.20 per year.

Now that we are ﬁnally getting great interest in our Heavy Industrial land, the city is trying to change our zoning.

Again I say, I want the zoning to remain as is.

Sincerely,
H
eather Mooney
559-999-1400
[email protected]
8510 E. Alluvial, Clovis, CA 93619
45 30
November 13, 2024
Michelle Zumwalt
Architect
City of Fresno
Planning and Development Department
Dear Michel
le Zumwalt,
I am writing this letter regarding the Draft South Central Speciﬁc Plan.

I currently own 4 properties that are within the area of this proposed plan.

The APN’s are the following:
33013007
33013008
33013009
33013018S
I strongly oppose the proposed land use change.

Now that we are ﬁnally getting great interest in our Heavy Industrial land, the city is trying to change our zoning.

Again I say, I want the zoning to remain as is.

Sincerely,
J
onathan Thomas
559-351-1257
[email protected]
8510 E. Alluvial, Clovis, CA 93619
46 31
Email received 11/13/2024
Hi Michelle,
I am responding to your letters dated October 7, 2024, regarding the Draft SCSP planned land use changes to the following Properties:

APN: 316-090-53S
APN: 316-071-42
APN: 330-031-20
APN: 330-031-45S
APN: 330-031-40S
APN: 330-031-46S
APN: 329-100-44
We are in opposition to the planned land use change to each of the properties and want to retain the exiting General Plan land use. I will be following up tomorrow with a letter that more speciﬁcally addresses our concerns.

Best Regards,
Susan Gladding
Director, Development
559-834-5911 Direct
559-349-4058 Cell
FowlerPacking.com
47 32
48 33
34 49
35 50
36 37
38 51
39 40
Via Email [[email protected]] and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of Affinity Truck Center and Affinity Properties, LLC, (the “Property”), I am writing in response to the November 2024 letter Affinity Truck Center received from the City of Fresno’s Planning and Development Department advising that Affinity Properties, LLC’s property—identified as APN 48705051S and 78S and 48708005S and 37S (Property)—would be downzoned under the City’s Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline to downzone properties against the wishes of the underlying landowners.

Affinity Truck Center has proudly served the Fresno community for 44 years, creating stable job opportunities for Fresnans and residents in nearby areas. As a major contributor to the local economy, Affinity Truck Center not only supports local employment, but also drives growth through partnerships with Fresno-area businesses and initiatives. Over the past 15 years, Affinity Truck Center has actively supported community programs like the Boys and Girls Club, Career Technical Education at both the high school and junior college levels, and the Center for Advancing Research Technology. These efforts reflect Affinity Truck Center’s commitment to fostering education, skill development, and economic progress in Fresno, making a lasting impact on the community it calls home. We employ 90 staff members, many residing in local neighborhoods. We take on many interns from Duncan Poly Tech and Fresno City College each semester and run an in-house Technician Apprentice Program. We hire many interns and apprentices into high paying careers permitting many to lift themselves and their families out of poverty. I am a member of the Fresno Business Council and CEO Roundtable.

I am a founding member of Heartland Compass; an organization formed to support and serve our employees as they navigate common challenges in life and barriers to employment. My days are spent identifying new opportunities to grow our business, strengthen our team, and uplift the communities we serve.

I am investing $250,000 in commercial level electric vehicle chargers meant to serve our heavy truck industry’s transformation to greener goods movement. In 2024, I have taken on representing Bollinger Motors medium duty electric vehicles and Autocar electric yard tractors to develop our areas cleaner, greener EV offerings. This zoning change threatens my future investment in our ongoing growth and any future resale of our thriving operation. 52 41
Affinity Truck Center and Affinity Properties, LLC object to the proposed downzoning of the Property. Affinity Properties, LLC purchased the Property with the understanding and expectation that South Central Fresno had long been set aside by the City as an industrial preserve. There was simply nothing that would have signaled to the Company that the City would at some point seek to downzone the Property in the future. The proposed downzoning completely undermines those expectations in a manner that undermines future development potential, job creation, and land value.

The letter states that businesses that “were legally established under older regulations may continue indefinitely, even if the SCSP is adopted” as “legal non-conforming” uses. These “protections,” however, do little to resolve Affinity Properties, LLC’s significant concerns. The City’s Development Code does not allow the transition from one legal non-conforming use to another. Legal non- conforming status does not apply to new or expanded uses; and the Development Code provides that a property can lose its legal non-conforming status if a property is vacant for even a short period of time.

All of these restrictions limit the ability of a business to grow. They likewise restrict the ability of a landowner to obtain new tenants at the end of a lease.

Legal non-conforming status also has significant practical effects. A property with a land use that is converted from “permitted” to “legal non-conforming” loses most of its value the moment the land use changes; it essentially becomes unsellable. Legal non-conforming status also creates significant risk and uncertainty for potential tenants, undermining the ability of landowners in South Central Fresno to attract high-value reputable tenants.

Because zoning affects the value of real property, and the underlying real property serves as the collateral for any loan, conformity with a property’s zoning is usually a condition of real estate financing. In practice, this means that the downzoning of a property will trigger an event of default in existing loan documents. It will also cause a lender to decline to issue a new loan. In addition to limiting the ability of a buyer to obtain a loan to purchase a downzoned property, the lack of access to capital also frustrates the ability to obtain financing to upgrade to electric/green infrastructure.

For each of these reasons, Affinity Truck Center and Affinity Properties, LLC opposes the proposed rezoning of the Property, and requests that the City decline to change the zoning of the Property.

Respectfully submitted,
Kim Mesfin
President Affinity Truck Center
Manager
Affinity Properties, LLC
42 November 14, 2024
Via E-Mail Only: [email protected]
Ms. Michelle Zumwalt
City of Fresno Planning and Development Department
2600 Fresno Street, Room 3043
Fresno, California 93 721
Re: Land Use Change/ South Central Specific Plan ("Specific Plan") / City of Fresno ("City")
Dear Ms. Zumwalt:

The undersigned are two owners of properties located at (i) 1647 E. Central Avenue, Fresno, California 93725; (ii) 1515 E. Central Avenue, Fresno, California 93725; (iii) 1625 E. Central Avenue, Fresno, California 93725; and (iv) 4082 S. Orange Avenue, Fresno, California 93725 (the "Thomas Properties"). The APNs for the four Thomas Properties are:

1. APN 330-130-07

2. APN 330-130-08

3. APN 330-130-09

APN 330-130-07; APN 330-130-08; and APN 330-130-18s ("Three Properties") from 'Heavy Industrial' to 'Business Park.'
Our family has owned the Thomas Properties for decades, with the intended use for 'Heavy Industrial.' Our position is that the Three Properties mentioned above should remain 'Heavy Industrial.'
In regard to APN 330-130-09 ("] 647 E. Central"), the proposed change is from 'Heavy Industrial' to 'Low Density Residential'. 1647 E. Central is adjacent to our other Three Properties and the intended use/zoning should remain the same, 'Heavy Industrial.' on Thomas
1 e Thomas
, t dated April 8, 2021
53 43
Via Email [[email protected]] and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of SPAN Development Company LLC, a California limited liability company, I am writing in response to the October 7, 2024, letter SPAN Development received from the City of Fresno's Planning and Development Department advising that SPAN Development Company's property-identified as Assessor Parcel Number 329-130-05 consisting of approximately 19.54 acres of vacant land (Property)-would be downzoned from Light Industrial ("IL") to Business Park ("BP") under the City's Draft South Central Specific Plan (SCSP). I am writing to insist the the property not be downzoned against our wishes.

SPAN purchased the property in 2017 specifically to develop light industrial buildings as the property was designated under the City of Fresno General Plan (legally passed by council).

Furthermore, representatives of SPAN and its marketing team met with top officials of the City of Fresno in person, at City Hall, to make sure its planned development was consistent with the City's desire for the area. Included in the meeting from the city were the Director of Planning, Jennifer Clark (who still holds that position) and the Economic Development Director, Larry Westerlund (no longer working for the City). Not only were we told by the City that our plans were consist with the City's desire for the area, but that the City had plans to annex the property into the city ( currently in the county but in the City sphere), ratify the Light Industrial zoning and were using taxpayer money to install the backbone infrastructure ( sewer and water) to service future development. All of this to support the employment district in the plan area.

This outrageous action being considered by the city is intolerable. Why would the City tell us one thing, we rely on the information make investments only to have the same bureaucracy completely pull the rug out from under us seven years later? Who would want to do business in a place like this?
SPAN Development based out of Madera, CA. has been in business for 10 years, but its principals King Hussein and I have developed all types of properties (industrial, retail, office and multifamily) primarily in the United State but across the globe for over 50 years. To be honest Fresno has become the toughest place to do business compared to other markets we operate in.

I'm sure you are aware of the nightmare that was done to us on Elm Avenue as part of another poorly conceived specific plan (SWSP). Yet here we are again.

There was simply nothing that would have signaled to SPAN that the City would at some point seek to downzone the Property in the future. The proposed downzoning completely undermines 4883-4184-0628, V. 1
54 44
45 Hello Michelle,
My name is A
mir Dehlan and I am a broker with Fortune Associates Commercial Real Estate. I had the opportunity to speak with you over the phone and via Zoom as well as meet in person at the public hearing that was held at the Orange Center School. At that time I was working on another parcel (APN 329-140-29), but now I have been in communication with another property owner that is within the South Central Plan. I have identiﬁed the subject property below:

APNs
• 329-110-04
• 329-110-05
• 329-110-03
Per the map
on the City's website, it appears that the site will be designated as an IL (Light Industrial) zoned property. The owner is looking forward to the zoning change to this new designation as it would conform to much of the improvements in the immediate proximity of the subject property. I wanted to also conﬁrm whether this plan would also include annexation of the 55 46
subject properties into the city and therefore incorporating it within the city limits? Previous discussions showed that the subject properties were included, but if we can get a conﬁrmation on that, we would greatly appreciate it.

I had calle
d and left a message with Michelle regarding these APN's earlier today as well as late last week.

I hope yo
u have a great afternoon and I look forward to hearing from you today. --
Amir Deh
lan
Fortune Associates
Office: (559) 490-2500
Cell: (559) 217-2120
Email: [email protected]
470 E Herndon Ave, Fresno, CA 93720
CalDRE #01851777
fortuneassociates.com
47 Via Email [[email protected]) and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93 721
Re: Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of Fresno Beverage Company Inc dba Valley Wide Beverage, I am writing in response to the November 2024 letter Valley Wide Beverage received from the City of Fresno's Planning and Development Department advising that Valley Wide Beverage's property-identified as APN 32911012 and 13 (Property)-would be downzoned under the City's Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline to downzone properties against the wishes of the underlying landowners.

Valley Wide Beverage objects to the proposed downzoning of the Property. Valley Wide Beverage purchased the Property with the understanding and expectation that South Central Fresno had long been set-aside by the City as an industrial preserve. There was simply nothing that would have signaled to the Company that the City would at some point seek to downzone the Property in the future. The proposed downzoning completely undermines those expectations in a manner that undermines future development potential, job creation, and land value.

Valley Wide Beverage has proudly served Fresno and the Central Valley for over 40 years, employing over 400 people. The company is a strong advocate and supporter of numerous charitable organizations, making a significant positive impact on the community and strengthening our presence in the Fresno area.

The letter states that businesses that "were legally established under older regulations may continue indefinitely, even if the SCSP is adopted" as "legal non-conforming" uses. These "protections," however, do little to resolve Valley Wide Beverage's significant concerns. The City's Development Code does not allow the transition from one legal non-conforming use to another.

Legal non-conforming status does not apply to new or expanded uses. And the Development Code 3525 S. EAST AVENUE, FRESNO, CA 93725 I (559) 650-1500 I VALLEYWIDEBEVERAGE.COM 56 48
49 Via Email [[email protected]) and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93 721
Re: Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of Amendola Investments II LLC, I am writing in response to the November 2024 letter Amendola Investments II LLC received from the City of Fresno's Planning and Development Department advising that Amendola Investments II LLC's property-identified as APN 32913001 (Property)-would be downzoned under the City's Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline to downzone properties against the wishes of the underlying landowners.

Amendola Investments II LLC objects to the proposed downzoning of the Property. Amendola Investments II LLC purchased the Property with the understanding and expectation that South Central Fresno had long been set-aside by the City as an industrial preserve. There was simply nothing that would have signaled to the Company that the City would at some point seek to downzone the Property in the future. The proposed downzoning completely undermines those expectations in a manner that undermines future development potential, job creation, and land value.

The letter states that businesses that "were legally established under older regulations may continue indefinitely, even if the SCSP is adopted" as "legal non-conforming" uses. These "protections," however, do little to resolve Amendola Investments II LLC's significant concerns. The City's Development Code does not allow the transition from one legal non-conforming use to another.

Legal non-conforming status does not apply to new or expanded uses. And the Development Code provides that a Property can lose its legal non-conforming status if a property is vacant for even a short period of time. All of these restrictions limit the ability of a business to grow. They likewise restrict the ability of a landowner to obtain new tenants at the end of a lease. 3525 S. EAST AVENUE, FRESNO, CA 93725 I (559) 650-1500 I VALLEYWIDEBEVERAGE.COM 57 50
51 Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Objectio
n to Proposed Zoning Change
Dear Ms. Zumwalt:

O n b e h a l f o f T R I C O Z , L L C , I a m w r i ti n g i n r e s p o n s e t o t h e l e tt e r s r e c e i v e d f r o m the City of Fresno’s Planning and Development Department advising that TRICOZ, LLC properties —identiﬁed as APN 32830015, APN 32830016, APN 32830017 and APN 32830018 (Properties) —would be aﬀected by downzones proposed under the City’s Draft South Central Speciﬁc Plan (SCSP) for neighboring APN 32830006 and APN 32830007. I am writing to urge the City to decline to downzone these properties against the wishes of the surrounding landowners.

TRICOZ, LLC has been locally owned and operated since 1998 and has strong ties to the Central Valley, where 100% of the company’s investments have been made. Our company’s longstanding involvement in the Central Valley and particularly in South Central Fresno is why we feel the need to comment on this proposal.

TRICOZ, LLC strongly objects to the proposed downzoning of APN 32830006 and APN 32830007 from Heavy Industrial to Medium Low Density Residential. These parcels and their neighboring areas have been zoned industrially since they were annexed by the City in the 1970s, thus the entire surrounding landscape has been developed with this use in mind for decades. To rezone these two parcels to Medium Low Density Residential and consequently establish a buﬀer zone would disrupt business in every direction. A proposed 1,000 ft buﬀer radius, the most aggressive our company has ever encountered, set around these two parcels would adversely aﬀect 23 other industrially zoned properties including 4 of our own. The City’s proposal would disproportionately aﬀect industrial businesses as rezoning these two parcels containing just 0.50 acres of land in total to Medium Low Density Residential and adding such a buﬀer would negatively impact approximately 100 acres of Heavy Industrial zoned land.

TRICOZ, LLC purchased and developed the Properties with the understanding and expectation that South Central Fresno had been designated as an industrial area by the City. There were no indications made by the City to TRICOZ, LLC that the City would ever seek to downzone any parcels in the region at any point.

These proposed downzones and resulting buﬀer will not only undermine those expectations but will also have signiﬁcant reverberations on future job creation, investment and land value in the area.

For these reasons, TRICOZ, LLC opposes the proposed rezoning of APN 32830006 and APN 32830007, and requests that the City decline to change the zoning of these parcels.

Respectfully,
Bryan Cossette
President of TRICOZ, LLC
58 52
8570 S. Cedar Ave., Fresno CA 93725
4861-8822-3225, v. 1
Via Email [[email protected]] and United States Mail Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

I am writing on behalf of Parnagian Enterprises, G3 Development Co., and G4 Enterprises Ltd. (collectively, “Fowler Packing”) in response to the October 7, 2024, letters received from the City of Fresno concerning potential changes to zoning and land use designation under the South Central Specific Plan (the “SCSP”). Fowler Packing received letters for the following “Properties”:

Proposed Land Use/Zoning Changes Under the SCSP
Owner Property (APN) Current Zoning SCSP Proposed Zoning G4 Enterprises Ltd. 316-090-53S Light Industrial Business Park G4 Enterprises Ltd. 316-071-42 Light Industrial Business Park Parnagian Enterprises 330-031-20 Heavy Industrial Light Industrial Parnagian Enterprises 330-031-45S Heavy Industrial Light Industrial Parnagian Enterprises 330-031-40S Heavy Industrial Light Industrial Parnagian Enterprises 330-031-46S Heavy Industrial Light Industrial G3 Development Co. 329-100-44 Heavy Industrial Low Density Residential We object to the proposed zoning and land use changes listed above. Fowler Packing has held the Properties for many years—in some instances decades—with the express intention of developing those Properties into clean, state of the art, industrial facilities, similar to the nearby North Pointe Business Park. Fowler Packing has long understood and had a reasonable expectation that South Central Fresno would maintain its industrial zoning, consistent with the City’s past vision and planning documents. The proposed downzoning undermines future development potential, job creation, and land value.
59 53
Fowler Packing has specific concerns regarding the downzoning of property within the plan area to residential use. The residential zoning will have negative consequences to existing nearby businesses in the area as well as future development if the SCSP is adopted. We also have concerns with the 1,000-foot buffers contemplated within the SCSP, between sensitive receptors and certain industrial uses. These buffer zones prohibit numerous categories of land uses and require additional permitting (conditional use permits) for others. The buffer zones also impose significant additional building requirements and mitigation measures, studies (such as Health Risk Assessments), and restrictions on the siting of buildings.

Fowler Packing supports the continued and future economic vitality of South Fresno and opposes these proposed changes that would cause adverse economic consequences.

Respectfully submitted,
Leland Parnagian
President, Fowler Packing
54 **For Properties Being Downzoned**
Via Email [[email protected]] and United States Mail Michelle Zumw
alt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Re: Object
ion to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of 3 G Containers, I am writing in response to the October 2024, letter 3 G Containers received from the City of Fresno ’s Planning and Development Department advising that 3 G Containers property—identified as 487-070- 46 and 487-070- 45 (Property) —would be downzoned under the City’s Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline to downzone properties against the wishes of the underlying landowners.

Our family has had property near the above location for over 65 years. The property is located at 3428 S. Cherry and has been scheduled as part of the Business Park with zoning allowing new businesses due to its central location. This location is near both Highway 41 and Highway 99 in central California.

This property is perfectly allocated as a future site for employing many people or possibly housing utility trucks or trailers for the distribution of goods. An increase in revenue for the City of Fresno is guaranteed if this property becomes a useful industrial part of the Business park. 3 G containers has been in Fresno for almost 10 years and currently employs 4 full time positions with employees that reside in Fresno. Our company is instrumental in the necessary steps to reuse “mini-bulk” containers preventing them from going to landfills. Our current location is centrally located not only for us, but also for our clients ultimately reducing the amount of miles traveled for pickup and deliveries.
3 G Containers objects to the proposed downzoning of the Property. 3 G Containers purchased the Property with the understanding and expectation that South Central Fresno had long been set- aside by the City as an industrial preserve. There was simply nothing that would have signaled to the Company that the City would at some point seek to downzone the Property in the future.

The proposed downzoning completely undermines those expectations in a manner that undermines future development potential, job creation, and land value.

Legal non- conforming status does not apply to new or expanded uses. And the Development 60 55
Code provides tha
t a Property can lose its legal non- conforming status if a property is vacant for even a short period of time. All of these restrictions limit the ability of a business to grow. They likewise restrict the ability of a landowner to obtain new tenants at the end of a lease.

Legal non-conforming status also has significant practical effects. A property with a land use that is converted from “permitted” to “legal non-conforming” loses most of its value the moment the land use changes; it essentially becomes unsellable. Legal non- conforming status also creates significant risk and uncertainty for potential tenants, undermining the ability of landowners in South Central Fresno to attract high-value reputable tenants.

Because zoning effects the value of real property, and the underlying real property serves as the collateral for any loan, conformity with a property’ s zoning is usually a condition of real estate financing. In practice, this means that the downzoning a property will trigger an event of default in existing loan documents. It will also cause a lender to decline to issue a new loan. In addition to limiting the ability of a buyer to obtain a loan to purchase the property, the lack of access to capital also frustrates the ability to obtain financing to upgrade to electric/green infrastructure.

For each of these reasons, 3 G Containers and our family opposes the proposed rezoning of the Property, and requests that the City decline to change the zoning of the Property.

Respectfully submitted,
Elisabeth Balcom
Respentative of the Tavares Family Trust
56 Michelle Zumwalt
City of Fresno
Planning & Development Department
2600 Fresno Street, Room 3043
Fresno, CA 93721
Objection to Proposed Land Use Change
Dear Ms. Zumwalt:

On behalf of 3G Container Exchange LLC/ The Mostos LLC, I am writing in response to the October 2024, letter The Mostos LLC received from the City of Fresno’s Planning and Development Department advising that 3G Container Exchange LLC/The Mostos LLC property —identified as 487-070-46 and 487-070-45 (Property)—would be downzoned under the City’s Draft South Central Specific Plan (SCSP). I am writing to urge the City to decline to downzone properties against the wishes of the underlying landowners.

Our property located at 4646 E. Jensen Ave. has been scheduled as part of the Business Park with zoning allowing new businesses due to it’s central location. This location is near both Highway 41 and Highway 99 in central California.

This property is perfectly allocated as a future site for employing many people 3G Container Exchange LLC. has been in Fresno for almost 10 years and currently employs 8 full time positions with employees that reside in Fresno. Our company is instrumental in the necessary steps to reuse “mini-bulk” containers preventing them from going to landfills. Our current location is centrally located not only for us, but also for our clients ultimately reducing the amount of miles traveled for pickup and deliveries. 3G Container Exchange LLC/ The Mostos LLC. objects to the proposed downzoning of the Property. The Mostos LLC purchased the Property with the understanding and expectation that South Central Fresno had long been set-aside by the City as an industrial preserve. There was simply nothing that would have signaled to the Company that the City would at some point seek to downzone the Property in the future. The proposed downzoning completely undermines those expectations in a manner that undermines future development potential, job creation, and land value.

The City’s Development Code does not allow the transition from one legal non-conforming use to another. Legal non-conforming status does not apply to new or expanded uses. And the 61 57
Development Code provides that a Property can lose its legal non-conforming status if a property is vacant for even a short period of time. All of these restrictions limit the ability of a business to grow. They likewise restrict the ability of a landowner to obtain new tenants at the end of a lease.

Because zoning effects the value of real property, and the underlying real property serves as the collateral for any loan, conformity with a property’s zoning is usually a condition of real estate financing. In practice, this means that the downzoning a property will trigger an event of default in existing loan documents. It will also cause a lender to decline to issue a new loan. In addition to limiting the ability of a buyer to obtain a loan to purchase the property, the lack of access to capital also frustrates the ability to obtain financing to upgrade to electric/green infrastructure.

For each of these reasons, 3G Container Exchange LLC./The Mostos LLC opposes the proposed rezoning of the Property, and requests that the City decline to change the zoning of the Property.

Respectfully submitted,
Daniel Mosto
3G Container Exchange LLC/ The Mostos LLC.

President/CEO
58 November 18, 2024
JASON THOMAS, Trustee of the Jason Thomas
Living Trust, u/d/t dated April 8, 2021
1783 West Celeste Avenue
Fresno, California 93711-2333
Via E-Mail Only: [email protected]
Ms. Michelle Zumwalt
City of Fresno Planning and Development Department
2600 Fresno Street, Room 3043
Fresno, California 93 721
Re: Land Use Change/ South Central Specific Plan ("Specific Plan")/ City of Fresno ("City")
Dear Ms. Zumwalt:

My parents, Patrick and Judy Thomas, own APN 330-150-34 which is located within the Specific Plan area. They recently received a letter from the City regarding possible land use changes. This letter differs from the letters I received regarding my properties in the area. This letter includes the statement, "If an individual challenges the above applications in court, they may be limited to raising only those issues that were raised at the public hearings described in this notice, or in written correspondence ... ". This is concerning to me. I therefore would like to bring to attention a few more issues that were not included in my prior letter dated 11/14/2024.

I own four properties in the area possibly being rezoned out of Heavy Industrial. These property APNs are the following:

1. APN 330-130-07

2. APN 330-130-08

3. APN 330-130-09

4. APN 330-130-18s
(1515 E. Central Avenue, Fresno, California 93725)
(1625 E. Central Avenue, Fresno, California 93725)
(1647 E. Central Avenue, Fresno, California 93725)
(4082 S. Orange Avenue, Fresno, California 93725)
Three of these properties were purchased by my grandfather many decades ago as an investment due to their "Heavy Industrial" zoning. Approximately a decade ago the location at 1647 E. Central Avenue, Fresno, California 93725 (APN 330-130-09} was purchased by my family as an investment due to its location and zoning. All four of these properties are adjacent to each other. I, and my family, have been waiting for the city to build infrastructure in the area to develop these properties as one large property using the current zoning of Heavy Industrial. One of these properties, 1515 E. Central Avenue, Fresno, California 93725 (APN 330- 130-07) is currently zoned and in use as Heavy Industrial. 62 59
Also, my parents own APN 330-140-19S which consists of approximately 19.5 acres and is located within 1,000 feet of my properties being addressed in this letter. It is zoned and in use as Light Industrial. My parents recently received asubstantial offer for purchase of this property. Industrial zoning in this area is highly sought after. Low Density Residential and Business Park are not.

Please understand the detrimental effects to our long-term plans and the severity of ﬁnancial loss Iand my family will suffer if these properties are rezoned out of the existent plan of Heavy Industrial.

Sincerel
stee
rptsC u/d/t dated April 8, 2021
homas;oN Th(
Livin
60 November 18, 2024
Michelle Zumwalt
Architect
City of Fresno
Planning and Development Department
Dear M
ichelle Zumwalt,
I am writing a second letter regarding the Draft South Central Speciﬁc Plan with a few additional points that I would like to make for the record.

I currently own 4 properties that are within the area of this proposed plan.

The APN’s are the following:
33013007
33013008
33013009
33013018S
I strongly oppose the proposed land use change. My heavy industrial property at Central and Orange is 700 yards from the 78 acre amazon fulﬁllment center and 800 yards from the Orange avenue Disposal company. My property is at the epicenter of this industrial region and yet it is proposed to have its zone reduced from heavy industrial to low density residential and business park. Myself and my family have owned our land for over 60 years.

In January of 2021 we tried to start the process of developing the parcels, only to be told that the city was not issuing any new building permits until the environmental impact study was completed.

Meanwhile, just 2 months later, in March of 2021, fresno city council member Miguel Arias conﬁrmed to channel 30 news that Amazon was expanding by 420,000 sq ft. right across the street from my property.

And now the proposed zoning change will not allow us to develop our property to its full potential, we will be losing substantial value on the land, and we also paid premium property tax rates to maintain our heavy industrial zoning.

According to Table 4-2 in the South Central Speciﬁc plan: There are1674 acres of vacant/agricultural land affected by this proposed rezone.

I am in this category.

Currently, under the adopted general plan, the majority of people own vacant land with heavy industrial zoning , 65% of them.

The speciﬁc plan would change what the people own.
63 61
The group of 65% of people with heavy industrial would be reduced from 65% to just 26% people.

So 39% of people owning vacant land will lose substantial value on their land.

The remaining 35% vacant land owners with less permissive zoning, will receive upgraded zoning or maintain current zoning. So none will lose any value on their land.

From our perspective, It is not acceptable to take away value from landowners by reducing their zoning, especially when our property is so incredibly close to major existing Heavy Industrial uses .

Therefore we are ﬁrmly against any change to the existing land use zoning for our properties.

Sincerely,
Heather Mooney
559-999-1400
[email protected]
8510 E. Alluvial, Clovis, CA 93619
62 1
November 19, 2024
Jennifer K. Clark, AICP Submitted Electronically
Director, Planning & Development Department
City of Fresno
2600 Fresno Street, Room 3065
Fresno, CA 93721
ATTN: Sophia Pagoulatos, Planning Manager
[email protected]
RE: South Central Specific Plan and Draft Environmental Impact Report – as proposed November 2024
Dear Director Clark and members of the Planning Commission:

I write today on behalf of INVEST Fresno and the undersigned organizations and businesses to express our strong concern with and opposition to the South Central Specific Plan (SCSP) and the related Draft Environmental Impact Report (DEIR), as 64 63
2 released for public comment in November 2024 and noticed for public hearing on November 8, 2024.

INVEST Fresno is aligned in our position with the letter and recommendations submitted by John Kinsey, with Wanger Jones Helsley PC.

As currently proposed, the SCSP contains several provisions that are highly concerning to the continued operation and future expansion of existing businesses in South Central Fresno, including, but not limited to, the downzoning of various properties, the inclusion of 1,000-foot buffer zones, and onerous mitigation requirements. The consequences of these changes could destroy living wage jobs and significantly reduce vital tax revenue in Fresno.

DOWNZONING
The SCSP proposes downzoning numerous properties from Heavy Industrial to Light Industrial and other properties from Light Industrial to Business Park, Regional Business Park, or even residential. The proposed downzoning will have wide- ranging impacts on the current and future operations of existing businesses as well as the ability of Fresno to attract new businesses.

Downzoning severely affects landowners and employers by making their properties inconsistent with the new zoning regulations. This change reduces Fresno’s attractiveness to reputable and well-capitalized businesses who want to invest in Fresno. Rezoning that creates non-conformities makes obtaining conventional financing nearly impossible — impacting capital improvements necessary for maintenance, beautification, and clean energy upgrades.

Legal non-conforming uses make it incredibly difficult for landowners to change tenants even in favorable conditions, and during an economic downturn, it almost guarantees the loss of legal non-conforming status. Additionally, landowners cannot switch from one legal non-conforming use to another. Any enlargement of a legal non-conforming use requires a conditional use permit (CUP), which hampers the ability to attract reputable, national industrial tenants, and further reduces the potential to re-let industrial properties.

Additionally, the proposed downzoning throughout the plan would be devastating to Fresno’s manufacturing sector. The Central Valley has long prided itself in being an epicenter for career-technical and vocational education and workforce development.

The State Center Community College District has invested hundreds of millions to ensure thousands of students each year receive the hands-on education and skill training local employers need. Limiting the growth of these businesses not only reduces the opportunities for these graduates but directly affects the future of Fresno’s workforce and the city’s economy.

BUFFER ZONES
The inclusion of 1,000-foot buffer zones in the SCSP is quite alarming. The proposed downzoning of numerous properties, combined with the proposed buffer zones, results in nearly 50% of the SCSP area being impacted by and subject to the proposed onerous requirements.
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The buffers would prohibit certain warehousing and distribution activities, such as chemical and mineral storage and freight/truck terminals, and reclassify other activities, including "Limited Industrial" and most warehousing and distribution uses, as conditional uses. Additionally, Health Risk Assessments would be required for all industrial processes, construction, and operations of businesses, regardless of the land use intensity or the probability of adverse health impacts. This will substantially increase costs and, as a result, drive businesses out of Fresno or drive up prices for consumers.

A 1,000-foot buffer zone is far outside the norm and three times greater than the standard endorsed by California Attorney General Rob Bonta. In 2022, the California Department of Justice reached a settlement agreement with the City of Fontana relative to their approval of warehouse developments, requiring warehouses that are 400,000 square feet or larger to establish a setback of 300 feet from the property line of the nearest sensitive receptor. In a statement announcing the agreement, Attorney General Bonta stated, “… the City of Fontana has adopted the most stringent environmental standards in California for new warehouse projects. This ordinance should serve as a model for other local governments across the state to build upon.”
Additionally, the 2022 agreement with the City of Stockton required that logistics uses and their associated loading docks are no closer than 300 feet from sensitive receptors. In response to the agreement, California Attorney General Rob Bonta stated, “I hope this serves as a model for future warehouse projects across the state.”
Finally, the California State Legislature has repeatedly rejected recent efforts (AB 1000, Reyes, 2023, and AB 2840, Reyes, 2022), which would have prohibited public agencies in San Bernardino and Riverside Counties from approving the development or expansion of a warehouse of 100,000 square feet or more within 1,000 feet of a sensitive receptor. Furthermore, the State Legislature recently adopted and the Governor signed AB 98, which, among other things, establishes a 300-foot buffer zone for warehouses of 250,000 square feet or larger. Once again proving that a 1,000-foot buffer zone is far and above the scientifically accepted or reasonable distance from sensitive receptors.

We are currently unaware of any city or county near Fresno that has implemented 1,000-foot buffers. Given the significant demand for industrial development within the city and the limited available locations for such projects, adopting these buffers would likely push new industrial developments—and the jobs and tax revenue they bring—to neighboring municipalities. We cannot support any policy that would jeopardize Fresno's success as an industrial hub or encourage our workforce to relocate.

SCSP ECONOMIC & COMMUNTIY BENEFITS
South Central Fresno is the city's economic engine and delivers an outsize impact for the entire city, while fewer than a quarter of one percent of residents live within the 5,629-acre planning area. In 2022, this area, which represents 7.5% of the city’s land, generated approximately $13 billion in economic activity (35% of the city’s total economic output) and more than $102 million in tax revenue (21% of 65 4
the city’s general fund). A full breakdown of the SCSP’s economic benefit to the entire city can be found at: INVESTFresnoCA.com/EconomicImpact.

Home to more than 440 businesses, the SCSP directly provides approximately 22,070 full-time equivalent (FTE) jobs and creates nearly 48,000 FTE jobs citywide (25% of the City’s FTE employment). Additionally, the average annual wage for the provided FTE jobs is slightly higher than the rest of the city at $68,000.

In the past six years, Fresno’s new retail distribution economy has taken flight — increasing the city’s sales tax revenue at unprecedented levels. It took the preceding 20 years for Fresno to experience a similar amount of growth in sales tax revenue. Unlike traditional sales tax revenue that is only generated from purchases within the city, Fresno receives sales tax revenue from items that are shipped from local retail distribution centers regardless of whether the shopper lives in Fresno, Los Angeles, or another state.

Source: City of Fresno, FY 2025 Mayors Proposed Budget
Bolstering the city’s General Fund provides benefits for all Fresno residents – all of which support essential city and community services like public safety, parks, infrastructure improvements, and numerous other critical programs that residents rely on every day.

AIR QUALITY IMPROVEMENTS
Due to the Valley’s topography and meteorology, surrounded by mountains and subject to frequent temperature inversions, pollutants become trapped, and, as a result, cities like Fresno, Visalia, and Bakersfield wind up at the top of the state’s most polluted cities. While ominous, this is not the end of the story.

The primary pollutants of concern in the Central Valley are ground-level ozone, and fine particulate matter (PM2.5), including diesel particulate matter (DPM). Since 1980, the Central Valley has reduced emissions of these pollutants from stationary sources (i.e., oil production and refining, boilers, and other stationary equipment) by 85%. According to the EPA, regulations on mobile sources such as cars and light trucks have reduced emissions by 99 percent since 1970. Heavy-duty trucks are roughly 99 percent cleaner than 1970 models.
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Source: San Joaquin Valley Air Pollution Control District, 2023 Annual Report Whereas, Valley residents’ exposure to elevated ozone and fine particulate matter (PM2.5), often cited as one of the most harmful to the lungs, has also fallen by 90% and 85% respectively. In total, this has led to a 95% reduction in cancer risk for Valley residents from exposure to air pollutants according to the San Joaquin Valley Air Pollution Control District.

Source: San Joaquin Valley Air Pollution Control District, 2023 Annual Report These historic reductions in air pollution over the past 40 years were accomplished at the same time Fresno’s population grew 2.5 times larger and our local economy more than doubled in size.

Since 1992, the San Joaquin Valley Air Pollution Control District has implemented roughly 650 rules and regulations that, along with California’s nation-leading regulations on cars and trucks, are helping to steadily improve the air quality in the Valley.

All this illustrates that the key to clean air and a healthy community is a strong and growing economy.
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CONCLUSION
The proposed downzoning, buffer zones, mitigation requirements, and limited protection from legal non-conforming use provisions will result in existing businesses abandoning the city and repel new businesses from entering – along with the countless jobs and significant tax revenue they generate.

A recent public opinion survey commissioned by INVEST Fresno, representative of the voting electorate across all seven council districts, showed overwhelming support for the city’s retail distribution and warehousing business sector. 71% of respondents stated they believe retail distribution and warehousing to be a net positive for the local community, with 39% identifying jobs and wages as their top reason for supporting the industry.

Additional findings from the survey can be found at: INVESTFresnoCA.com/Survey.

As the community of Fresno, if we are going to continue the progress we are making and redouble our commitment to raising the standard of living for low- income families, then we must do all that we can to support a diverse and growing economy. A pivot away from a growth-oriented economy here in Fresno would reverse the incredible success our community has seen and risk more families falling into poverty.

A growing economy and sensible air quality regulations have to work in tandem.

The transition to zero-emission heavy-duty trucks cannot be achieved if policies are enacted that discourage and limit Fresno’s economic growth, which is necessary to afford this new technology.

We appreciate your time and consideration and respectfully urge the Commission to reject the SCSP as currently proposed and implement policies that support and encourage investment in Fresno’s infrastructure that result in community improvement, encourage economic development, and ensure that Fresno can continue to thrive for generations to come.

If you would like to discuss this matter further, please do not hesitate to contact Ben Granholm at [email protected]. We look forward to working with you and staff to help keep Fresno’s economy moving.
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Sincerely,
Ben Granholm
INVEST Fresno
Advanced Emission Control Solutions, LP
Betts Company
Buzz Oates
Cedar Avenue Recycling & Transfer Station
Central Valley Business Federation
Certified Meat Products
Cossette Investment Company, Inc.

Cushman & Wakefield
Don Pickett & Associates
Diversified Development Group
Fowler Packing
Fresno Business Council
Fresno Chamber of Commerce
Fresno County Farm Bureau
JD Food
La Tapatia Tortilleria, Inc.

Legacy Construction
Newmark Pearson Commercial
North Pointe Business Park
Pickett Solar
Precision Civil Engineering, Inc.

Robert V. Jensen, Inc.

San Joaquin Valley Manufacturing Alliance
Strategic Freight Network
Sunnyland Mills
Tank Specialties of California
Valley Iron, Inc.

Valley Wide Beverage
cc: Jerry Dyer, Mayor
Georgeanne White, City Manager
Councilmembers, City of Fresno
Planning Commission, City of Fresno
69 November 19, 2024
Sent via email
Jennifer K. Clark, AICP
Director, Planning & Development Department
Fresno City Hall
2600 Fresno Street, Rm. 3065
Fresno, CA 93721
Re: Comments for the November 20, 2024 Fresno City Planning Commission Meeting on the Fresno South Central Specific Plan Environmental Impact Report SCH #2019079022 Good evening,
I’m Frances Tinney, an attorney with the Center for Biological Diversity. The Center is a non- profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has over 1.7 million members and online activists throughout California and the United States.

The City of Fresno’s plan to further industrialize a community that faces some of the worst environmental burdens in the state is a serious environmental injustice. Doing so without disclosing or mitigating the attendant harms is a violation of CEQA. After circulating the Draft EIR for the South Central Specific Plan, the City received numerous substantive comments pointing out serious flaws in the DEIR’s analysis and mitigation of impacts to air pollution, traffic safety, greenhouse gas emissions, and biological resources, among other impacts, and its unsupported dismissal of the Community Plan alternative. Despite those comments, the City made minimal changes to the EIR and now proposes to approve the project based on a Final EIR that remains inadequate. We urge the Planning Commission not to recommend approval until the EIR is revised and recirculated.

I appreciate the opportunity to submit written comments and to watch the meeting remotely.

Unfortunately, even though the meeting is streamed via zoom, there was no opportunity to give this comment over zoom. Since the pandemic, more and more public meetings, administrative processes, and court hearings allow people to call in via video or phone. This increased accessibility facilitates public participation—an “essential part of the CEQA process.” (Cal. Code Regs., tit. 14, § 15201.) I urge the City to create a way for members of the public to appear at public meetings remotely.

Thank you,
Frances Tinney
Attorney
1212 Broadway, Suite #800 Oakland, CA 94612
Tel: (509) 432-9256
[email protected]
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Fresno City CouncilDecember 5, 2024

Fresno City Council
December 5, 2024