water demand, which is crucial for understanding exactly how the Specific Plan’s land uses and associated impacts will differ from those under the General Plan.
The methods used to determine the water demand associated with the different land uses under the Specific and General Plans are not clear from the text of the EIR nor its supporting documents. The Water Supply Assessmet (WSA) used to inform the water supply projections in the EIR references a Hydraulic Analysis (HA) from 2022. (WSA at Table 2-1.) The HA states that the quantity of water associated with the various land use categories were “updated from 2010 Water System Master Plan… to reflect localized demands and flows, and confirmed by City Staff on February 17, 2022.” (HA at Table 5.) The 2010 Water System Master Plan is not accessable through the City of Fresno’s website, nor is it included in any of the applicable appendicies. The California Supreme Court has held that agencies must be able to show the “analytic route the administrative agency traveled from evidence to action” in order to “bridge the analytic gap from raw evidence and ultimate decision.” (Topanga Ass’n for a Scenic Cmty. v.
Cnty. of L.A. (1974) 11 Cal.3d 506, 515.) Simply including a statement that numbers, which are critical to the analysis of water supply and the ultimate conclusion of its sufficiency, were recalculated from a previous report and confirmed with the City is not a sufficient display of evidence.
It is the purpose of an EIR to give the public and agencies the information needed to make well informed decisions. (In re Bay-Delta etc., 43 Cal.4th 1143, 1162.) Without a clear basis for the information relied upon throughout the water supply discussion, the DEIR fails as an informational document. In order to fulfill its duty under CEQA, Fresno must recirculate an EIR with full transparency regarding how each of the land use’s associated water demands were determined.
ii. The EIR’s Discussions of Water Supply and Water Supply Reliability are Contradictory
The EIR contradicts itself at various points throughout its discussion of water supply sufficiency and impacts. At one point, the EIR states that there will be more than enough water to meet future demands, and on the same page, it states that the surface water supply could face constraints during dry years. (DEIR at 4.16-10.) Paired with the fact that the groundwater aquifer is already in a state of critical overdraft, and that climate change is likely to result in yearly reductions in surface flows and groundwater recharge, it is unclear how exactly there will be “more than enough water” to supply future developments in the Project Area.
Concerning groundwater supplies and recharge, the EIR consistently acknowledges that the Kings River Subbasin is overdrafted and that groundwater supplies have been declining over the past 80 years. (DEIR at 4.16-10, 11.) Despite that, the EIR concludes that groundwater will be used to supply developments under the Specific Plan through 2045. (DEIR at 4.16-10, 11.) It then states that reliance on groundwater supplies will continue to go down, yet includes plans to drill an additional 8 wells in the Project Area and states that the Fresno’s future groundwater production is projected to increase from 138,090 afy in 2025 to 154,490 afy in 2040. (DEIR at
4.10-21, 4.16-11.)
December 4, 2024
When a statement or finding in one place goes directly against a statement or finding in another place, and one cannot be true when the other is, those statements are contradictory and cannot be relied upon in an informational document like an EIR. (See King & Gardiner Farms, LLC v. County of Kern (2020) 45 Cal.App.5th 814, 874 [A court’s conclusion that a specific measure would not mitigate project’s effects directly contradicted the County’s finding that the same measure would reduce a significant impact to less than significant.]; see also Clover Valley Foundation v. City of Rocklin (2011) 197 Cal.App.4th 200, 244 [EIR’s conclusion was not contradictory because it was supported by substantial evidence.]) Here, the contradictions regarding the sufficiency of future surface and groundwater supplies in the Project area are not explained or supported by substantial evidence. The City must correct these contradictions in order to provide a factually sound EIR that fulfills its purpose as an informational document.
III. THE EIR’S ANALYSIS OF WATER QUALITY IMPACTS IS
INADEQUATE.
The EIR does not include adequate information about the Project’s water quality impacts.
It mentions that Fresno’s groundwater is contaminated. (DEIR at 4.9-16) But it does not mention that the groundwater under the Plan area is contaminated with a dibromochloropropane (“DBCP”) plume, a nitrate plume, and a 1,2,3-trichloropropane (“TCP”) plume. (UWMP 2020.) One of those chemicals, 1,2,3-TCP, is a manufactured chemical used for cleaning and degreasing in industrial contexts that is usually found at industrial or hazardous waste sites. (SWRCB 2017.) Because of its chemical properties, 1,2,3-TCP moves easily through soil into groundwater, is quickly transported within an aquifer, and may remain in groundwater for long periods of time. (Ibid.) Exposure to 1,2,3-TCP can cause liver and kidney damage and cancer. (Ibid.) The plume of 1,2,3-TCP under the Project site reaches concentrations of fifty ppt—ten times above the state’s limit for drinking water. (UWMP 2020.)
The EIR does not explain what any of the chemicals in the groundwater under the Project site are, or the health risks of exposure. Neither does it describe, either qualitatively or quantitatively, the severity of the contamination. The only information the EIR provides about the groundwater contaminates is that “most [of them] are being addressed.” (DEIR 4.10-12.) It does not say how successful those efforts have been. In fact, the only citation for any of the information about remediation is to the Fresno Irrigation District’s 2006 Fresno Area Regional Groundwater Management Plan, leaving open the question of what progress has been made in the last eighteen years. (DEIR at 9-10.) The failure to disclose adequate, up-to-date information about the current level of contamination means that the EIR does not establish environmental baseline, invalidating its analysis. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 320 [holding that use of the proper baseline is critical to a meaningful assessment of a project’s environmental impacts], Save Our Peninsula Comm. v Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 119.)
The EIR acknowledges, as it must, a risk that the Project “could adversely affect quality of surface water and groundwater.” (DEIR at 4.10-20.) As the EIR admits that construction could degrade water quality through runoff, that construction materials like solvents and fuels could enter the water system, that that construction materials and equipment could release hazardous materials into the storm drains, that operations of the Project could release petroleum products, December 4, 2024
heavy metals, and roadway contaminants and treated wastewater into the land and water. (DEIR at 4.10-19, 20.) However, it concludes that the risk to water quality is not significant and does not need to be mitigated merely because future development will follow the law. (DEIR at 4.10- 19, 21, 22, 24, 25.) The existence of state and federal standards does not absolve the City from the duty to do everything that is within its power to mitigate the impacts of this Project. A lead agency cannot rely on existing law to make a finding of no significant impact absent Project- and site-specific substantial evidence that the impacts will not be significant. (See Save Our Capitol! v Department of Gen. Servs. (2023) 87 Cal.App.5th 655, 696 (agency could not rely on compliance with LEED and CAL-Green building standards to mitigate light and glare impacts in absence of project-specific analysis of impacts and effect of compliance); Californians for Alternatives to Toxics v Department of Food & Agric. (2005) 136 Cal.App.4th 1 (EIR failed to analyze environmental and health risks of crop disease control program and instead presumed that no adverse impacts would occur from use of pesticides in accordance with the registration and labeling program of the California Department of Pesticide Regulation). See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 Cal.4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain registered herbicides in general not excuse its failure to assess effects of their use for specific timber harvesting project).)
The City’s claim that a full analysis of water quality impacts is not necessary because there is no evidence that the plan will increase contamination is not true. In fact, heavy industry often pollutes surrounding water through stormwater runoff, wastewater discharges, tire dust, or diesel exhaust. (Robbins 2023; British Geological Survey 2007; Li et al. 2021; Kriech & Osborn 2022; Mayer 2024; Müller 2020.) As discussed, the groundwater under the site is already contaminated by industrial pollutants like 1,2,3-TCP. The Project could very well add more contaminants though a variety of mechanisms. The City has not done anything to ensure the industrial pollution of Fresno’s water does get worse.
IV. THE EIR’S ANALYSIS AND MITIGATION OF AIR QUALITY IMPACTS IS INADEQUATE.
Air quality is a significant environmental and public health concern in California.
Unhealthy, polluted air contributes to and exacerbates many diseases and increases mortality rates. The U.S. government has estimated that between 10 to 12 percent of total health costs can be attributed to air pollution. (VCAPCD 2003.) Greenhouse gases, such as the air pollutant carbon dioxide, which is released by fossil fuel combustion, contribute directly to human- induced climate change (EPA 2016), and in a positive feedback loop, poor air quality that contributes to climate change will in turn worsen the impacts of climate change and attendant air pollution. (BAAQMD 2016.)
Air pollution and its impacts are felt most heavily by young children, the elderly, pregnant women and people with existing heart and lung disease. People living in poverty are also more susceptible to air pollution as they are less able to relocate to less polluted areas, and their homes and places of work are more likely to be located near sources of pollution, such as freeways or ports, as these areas are more affordable. (ALA 2024.) Some of the nation’s most polluted counties are in the Central Valley. (ALA 2024.) According to the American Lung December 4, 2024
Association’s 2024 “State of the Air” report, Fresno County is the second-worst county in the country for particle pollution and sixth-worst county in the country for ozone pollution. (Id.) Even more disturbing, the same report found that Fresno County is one of only thirty counties in the country that received a “Fail” grade in all air quality metrics. (Id.)
Although there are many different types of air pollution, ozone, PM2.5, and toxic air contaminants (TACs) are of greatest concern in Fresno County. These three air pollutants have been linked to an increased incidence and risk of cancer, birth defects, low birth weights and premature death, in addition to a variety of cardiac and lung diseases such as asthma, COPD, stroke and heart attack. (Laurent 2016; ALA 2022.) Ozone (commonly referred to as smog) is created by the atmospheric mixing of chemicals released from fossil fuel combustion – such as reactive organic gases (ROG) and nitrogen oxides (NOx) – and sunlight. Although it is invisible, ozone poses one of the greatest health risks, prompting the EPA to strengthen its National Ambient Air Quality Standard for Ozone in 2015. (ALA 2024.) PM2.5 is a common component of vehicle exhaust emissions and contributes to visible air pollution. These tiny particles are dangerous because they are small enough to escape our body’s natural defenses and enter the blood stream. Fugitive dust is a term used for fine particulate matter that results from disturbance by human activity such as construction and road-building operations. (VCAPCD 2003.) TACs are released from vehicle fuels, especially diesel, which accounts for 70% of the cancer risk from TACs. (CARB 2022.)
Warehouse projects are well-documented sources of air quality degradation that can create serious, negative health outcomes for surrounding communities. (Betancourt 2012, pp. 4-
5.) Particulate emissions from diesel vehicles that carry freight to and from warehouses contribute to “cardiovascular problems, cancer, asthma, decreased lung function and capacity, reproductive health problems, and premature death.” (Id. at 5.)
This Project is one in an extensive line in which local decisionmakers approve industrial development close to homes, despite health warnings from state air quality officials about the elevated asthma and cancer risks caused by industrial development, primarily due to diesel truck pollution. (Esquivel 2019.) The land use decisions the City makes now will affect the City’s air quality for decades.
A. The Project’s Air Quality Mitigation is Vague and Improperly Deferred.
Mitigation must include concrete, specific, and enforceable actions. (California Clean Energy Committee v. City of Woodland (2014) 225 Cal.App.4th 173 [City’s urban decay mitigation measures were inadequate under CEQA to address the impact from the development of a 234-acre regional shopping center on undeveloped agricultural land because the measures did not ensure the city would take concrete, measurable actions].) In the limited circumstances in which deferred mitigation is appropriate, the agency must meet all of the following elements: (1) practical considerations prevented the formulation of mitigation measures during the planning process; (2) the agency committed itself to developing mitigation measures in the future; (3) the agency adopted specific performance criteria prior to project approval; and (4) the EIR lists the mitigation measures to be considered, analyzed, and possibly incorporated into the mitigation plan. (14 Cal. Code Regs §15126.4(a)(1)(B); POET, LLC v. State Air Resources Bd. (2013) 218 December 4, 2024
Cal.App.4th 681, 736-37 [review denied]; San Joaquin Raptor Rescue Ctr. v County of Merced (2007) 149 Cal.App.4th 645, 670; Cleveland Nat’l Forest Found. v San Diego Ass’n of Gov’ts (2017) 17 Cal.App.5th 413, 442.) Unfortunately, the EIR’s proposed mitigation fails to meet these standards.
Instead of mitigating the significant air quality impacts by requiring specific mitigation measures, the EIR instead relies on mitigation measures 4.3-1a and 4.3-1m, which effectively amount to developing a mitigation plan in the future. Mitigation measure 4.3-1a merely promises a future Voluntary Emissions Reduction Agreement (“VERA”) that will be formulated by the applicant after the Project is approved. The EIR implausibly claims that after implementation of the VERA emissions of ROG, NOx, PM10 and PM2.5 will all be reduced to below the significant thresholds, through the funding of unspecified “feasible mitigation.” (DEIR at 4.3-
37.) Here, the EIR fails to meet the criteria for deferred mitigation. It does not attempt to explain why it is not possible to formulate and disclose a mitigation plan now, and it does not list the mitigation measures to be considered.
Further, an EIR is inadequate if “[t]he success or failure of mitigation efforts may largely depend upon management plans that have not yet been formulated, and have not been subject to analysis and review within the EIR.” (San Joaquin Raptor, supra, 149 Cal.App.4th at p. 670.) As courts have pointed out “[f]undamentally, the development of mitigation measures, as envisioned by CEQA, is not meant to be a bilateral negotiation between a project proponent and the lead agency after project approval, but rather, an open process that also involves other interested agencies and the public.” (Communities for a Better Environment v. City of Richmond, (2010) 184 Cal.App.4th 70, 93.) Here, the City proposes exactly that—a mitigation plan that will be developed by the City and the developer after Project approval, with no guarantee of success, for no clear reason.
Even more concerning is that mitigation measure 4.3-1m claims that compliance with the air quality threshold might be achieved through off-site reductions. The mitigation measure contains explanation of how the effectiveness of these off-site measures will be evaluated or monitored. It also contains no geographic limitations, leaving open the possibility that the developer could meet their obligation by funding programs of unknown effectiveness in another state or country. Offset schemes must be carefully tailored to comply with CEQA’s requirements (see generally Golden Door Properties, LLC v. County of San Diego (2020) 50 Cal.App.5th 467) and must be evaluated as a last option for mitigation where no other options are available or feasible. In this case, the City has not adequately considered alternatives that would avoid adding significant industrial development to an area with some of the worst air quality in the state.
Allowing a developer to build toxic land uses that will emit without limit as long as the developer pays for some environmental project somewhere else raises serious environmental justice concerns. The EIR has not established that this vague, undefined plan will effectively reduce the impact of this Project to less than significant. (Banning Ranch Conservancy v. City of Newport (2012) 211 Cal.App.4th 1209, 1232-34.)
V. CONCLUSION
December 4, 2024
Thank you for the opportunity to submit comments on the Environmental Impact Report for the Fresno South Central Specific Plan. We urge the City to revise the EIR to address the issues detailed here, and recirculate a legally compliant document.
Given the possibility that the Center will be required to pursue legal remedies in order to ensure that the City complies with its legal obligations including those arising under CEQA, we would like to remind the City of its statutory duty to maintain and preserve all documents and communications that may constitute part of the “administrative record” of this proceeding. (§ 21167.6(e); Golden Door Properties, LLC v. Superior Court (2020) 53 Cal.App.5th 733, 762-
65.) The administrative record encompasses any and all documents and communications that relate to any and all actions taken by the City with respect to the Project, and includes “pretty much everything that ever came near a proposed [project] or [] the agency’s compliance with CEQA…” (County of Orange v. Superior Court (2003) 113 Cal.App.4th 1, 8.) The administrative record further includes all correspondence, emails, and text messages sent to or received by the City’s representatives or employees, that relate to the Project, including any correspondence, emails, and text messages sent between the City’s representatives or employees and the Applicant’s representatives or employees. Maintenance and preservation of the administrative record requires that, inter alia, the City (1) suspend all data destruction policies; and (2) preserve all relevant hardware unless an exact replica of each file is made.
Please add the Center to your notice list for all future updates to the Project and do not hesitate to contact the Center with any questions at the number or email listed below.
Sincerely,
Frances Tinney Sofia Prado-Irwin
Attorney Scientist
Oakland, CA 94612
f g
December 4, 2024
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From:
To:
Subject: Stop polluting communities!!!
Date: Tuesday, December 3, 2024 1:22:28 PM
External Email: Use caution with links and attachments
Good afternoon,
I live in D3 and work near this area. I feel so bad for the poor school children and families that are breathing in these fumes and surrounded by industry. Why must our district be forced to house these industries, breathe this air, while all the investment goes to the north! Stop terrorizing poor people in south Fresno! This plan must protect people not others pocketbooks!!!