Dear Chairman Vang, Commissioners, and Staff,
I write today in opposition to Text Amendment P24-00794, which would introduce ministerial approvals for office-to-dwelling conversions, housing near bus stops in multi-family zones, infill residential development in mixed-use zones, and new residential in office zones. While addressing Fresno’s housing shortage is a valid concern, this proposed amendment takes an overly simplistic approach that prioritizes speed over thoughtful urban planning, community input, and responsible development.
Lack of Community Oversight and Accountability
Ministerial approvals remove essential public input from the development process. Under this proposal, residents and local stakeholders would have little to no say in projects that directly impact their neighborhoods. While proponents argue that all developments will still comply with existing zoning and environmental laws, this ignores the reality that projects vary significantly in their impact on infrastructure, parking, traffic, and community character. Bypassing discretionary review eliminates a necessary check to ensure developments are truly beneficial for Fresno’s long-term growth.
Strain on Infrastructure and Public Services
Fresno’s infrastructure—roads, water systems, schools, and emergency services—must be able to accommodate new development. Ministerial approvals could lead to rapid, unchecked residential growth in areas not adequately prepared to support an influx of residents. Without case- by-case analysis, we risk creating more traffic congestion, overburdened utilities, and inadequate public services, ultimately diminishing the quality of life for existing and future residents.
Risk of Poorly Planned Development
The push for rapid housing production should not come at the expense of responsible city planning.
Office-to-residential conversions, for example, may result in housing units that lack proper access to amenities, green space, or pedestrian-friendly environments. Simply repurposing office buildings into residences does not guarantee they will be suitable for long-term habitation or meet the needs of families.
Affordability Not Guaranteed
While proponents claim this amendment will reduce costs and make housing more affordable, there is no guarantee that fast-tracked development will lead to lower rents or home prices. Without affordability requirements, these projects could primarily serve higher-income tenants, exacerbating, rather than alleviating, Fresno’s affordability crisis. Additionally, by allowing residential development in office zones, this policy may reduce the availability of commercial space needed to sustain Fresno’s economic growth.
A More Balanced Approach is Needed
Rather than bypassing community engagement and thorough project review, Fresno should explore more balanced solutions, such as:
• Targeted incentives for developers who commit to building affordable housing while maintaining high community and environmental standards.
• Strengthening mixed-use development strategies that ensure commercial and residential uses complement each other without sacrificing office space. • Comprehensive infrastructure planning to ensure that new development does not outpace the city’s ability to provide essential services.
For these reasons, I strongly urge the Planning Commission to reject Text Amendment P24- 00794.
Fresno’s growth must be thoughtful, sustainable, and inclusive—values that are compromised when development is rushed at the expense of careful planning and community involvement.
Thank you for your time and consideration.
Sincerely,
Peter Núñez
From: Clerk Agendas
To: Adrienne Asadoorian
Cc: Toni Machado; Clerk Agendas; Bernard Canez
Subject: FW: converting office buildings to residences
Date: Thursday, March 20, 2025 2:53:02 PM
Good Afternoon,
Our office was forwarded the below email as public comment for the 9:15 A.M. item ID 25-294. Can this be attached to the item prior to publishing.
Kindly,
Mary Quinn
Senior Deputy City Clerk
Office of the City Clerk
From: District3 <[email protected]>
Sent: Thursday, March 20, 2025 2:41 PM
To: Clerk Agendas <[email protected]>; Clerk <[email protected]> Subject: FW: converting office buildings to residences
Comment for text amendment P24-00794 on the 3/27/25 Council agenda.
-Gabriela
From: Gabriele Case <[email protected]>
Sent: Thursday, March 20, 2025 2:03 PM
To: District3 <[email protected]>
Subject: converting office buildings to residences
External Email: Use caution with links and attachments
Dear Mr. Arias,
I'm writing to support converting office buildings into new housing. We have a housing shortage, and we need new multi-family homes in Fresno.
Kind regards,
Gabriele Case
From: Airola
To: Adrienne Asadoorian
Subject: Text Amendment Application No. P24-00794
Date: Monday, March 10, 2025 11:35:51 AM
External Email: Use caution with links and attachments
March 10, 2025
RE: Notice of Intent to Adopt a Mitigated Negative Declaration regarding Text Amendment P24-00794 Dear Ms. Asadoorian:
I am writing to object to the Notice of Intent to Adopt a Mitigated Negative Declaration regarding Text Amendment P24-00794 and any reconsideration of Building App. No. P21-00989 that previously failed to gain approval by the Fresno Planning Commission and the City Council for numerous problematic issues.
Regarding the proposed Mitigated Negative Declaration Application of Text Amendment P24-00794, I am concerned this amendment in large measure bypasses the numerous safeguards provided our community through the current Planning Commission project review process.
The requirement for notice of proposals and notice of public hearings provides citizens of Fresno the opportunity to voice their support and/or concerns regarding any and all projects in our community. This proposal in large measure bypasses that process and thereby bypasses the community safeguards for uncontrolled and potentially hazardous building projects provided by formal Planning Commission project review.
In my Fresno district, Councilman Karbassi’s District 2, the Project Review Committee, staffed by citizen volunteers, hasn’t met for over a year.
Loss of this preliminary review committee has already weakened citizen input into development of potentially unsafe project development in Fresno District 2. I’m hopeful not only that the proposed Text Amendment P24-00794 will be voted down, but also that the District 2 Project Review Committee will be reformed and begin meeting on a regular basis in the near future.
One example of an unsafe proposed project in District 2 is contained in Building Application No. P21-00989. Happily, that building application was denied several times by the Fresno Planning Commission and subsequently by the Fresno City Council. That proposal for an 82 unit 3 and 4 story apartment complex at Herndon Avenue and N. Prospect Avenue should not be built as initially planned for a number of significant reasons that present several potential risks and liability for future residents of the facility.
These include:
1. Building evacuation in case of fire,
2. Access to the proposed project off Prospect by the fire department,
3. Safe pedestrian pathways from the proposed project to the H. Roger Tatarian elementary school,
4. Increased traffic thru the poorly configured and too small traffic circle on Prospect, north of Herndon, and
5. Inadequate parking spaces for the proposed complex.
The developer’s representative at one of the Planning Commission meetings stated that the target clientele of the proposed project would be senior citizens.
Many elderly individuals have limited mobility and some seniors are easily confused when placed in stressful situations, particularly if they have mild dementia. During a building evacuation because of fire when elevator use is prohibited, many senior citizens may be unable to quickly negotiate third and fourth floor stairways to move to safety outside the buildings. In addition , the four-story portion will not have windows on the eastern side of the building thereby limiting rescue access by firefighters using ladder trucks.
N. Prospect Avenue itself is too narrow at the level of the tiny turn-around circle to accommodate a pickup truck towing a moderate-sized trailer.
I question the ability of a fire ladder truck to negotiate a turn into the proposed complex especially if and when facility residents are attempting to move their vehicles to safety. These difficulties would certainly delay both fire fighter evacuations of facility residents and delay implementation of fire fighting efforts.
Despite the developer’s belief that the proposed complex would be largely inhabited by senior citizens, one must assume that given its proximity to an elementary school, any number of families with children would also be residents of the complex. Safe pedestrian pathways do not exist currently between the proposed complex and H. Roger Tatarian elementary school; rather children would need to either walk along the gravel shoulder of the narrow two lane portion of N. Valentine Avenue that parallels Herndon Avenue or traverse the open field north of that side road.
Placing those young children at risk from drivers hurrying to work along the already congested road seems unwise when increased traffic along N. Prospect from the proposed complex must be assumed.
The poorly designed connection of N. Valentine Avenue to Herndon Avenue, where N. Valentine becomes a frontage road that enters Prospect Avenue from the West, has already created a significant obstacle to the smooth flow of traffic from N. Valentine onto Herndon Avenue.
Complicating the flow of traffic further at N. Prospect and Herndon by adding additional traffic from an 82 unit apartment complex will lead to undue congestion and innumerable fender-bender accidents along N. Prospect.
One must expect that most of the target clientele (senior citizens) of the proposed project will be moving into the apartments to “down- size” their remaining years and will have two vehicles or the residents will be working parents with two vehicles. The proposed apartment complex does not have adequate parking facilities to accommodate even 150 vehicles, much less 164 cars and trucks. Local street parking lacks the capacity to support more than a few extra vehicles.
If that building application for this parcel were to be reconsidered or reactivated, may I suggest that several changes be made to either or both the proposed complex and the surrounding street traffic infrastructure. Certainly, anticipating the numerous problems noted above and providing solutions prospectively would seem wise. I remember that the traffic signal at Marks and Herndon Avenue was constructed to replace the 4-way stop signs only after a Supervisor’s teenage daughter was killed in a traffic accident at that intersection.
Prospectively dealing with the above mentioned problems might save lives in the future.
I humbly suggest several potential solutions if the building application for this parcel were to be reconsidered or reactivated:
1. Down-size the proposed project to a maximum of two-story buildings
2. Move the entrance and exit from the proposed complex to W. Fir Avenue instead of N. Prospect Avenue.
3. Widen the frontage road portion of N. Valentine Avenue that parallels Herndon Avenue and add a sidewalk along the northern portion of that road and along N. Prospect Avenue while widening N. Prospect Avenue itself along with the construction of a larger traffic turning circle to N. Prospect Avenue.
4. Maintain or increase the number of parking spaces in the proposed complex despite down-sizing the number of proposed housing units themselves.
These corrective suggestions surely might be implemented by either the city or the developer of Parcel Number P24-00794 if the City of Fresno were concerned for any future residents of any development project on the aforementioned parcel of land.
In conclusion, I strenuously object to the Notice of Intent to Adopt a Mitigated Negative Declaration as a city wide code amendment and more specifically for application of any such declaration in regard to Parcel Number P24-00794 for the reasons stated above because development of the parcel per Building App. No. P21-00989 without significant corrective measures would place future resident adults and their children at significant risk of injury.
Yours Sincerely,
Virgil M. Airola
From: trave
To: Clerk
Cc: Adrienne
Subject: Comment on Fresno City Council Agenda item: ID-25-294 Date: Tuesday, March 25, 2025 4:15:47 PM
External Email: Use caution with links and attachments
TO:
Fresno City Council President Michael Karbassi,
Fresno City Clerk’s Office
[email protected]
CC:
Adrienne Asadoorian-Gilbert,
Supervising Planner,
City of Fresno
Planning and Development Dept.,
2600 Fresno St.
Fresno CA 93721-3604
Dear Councilman Karbassi,
My wife and I are writing in opposition to the proposed Text Amendment Application P24-00794 and Mitigated Negative Declaration (SCH NO. 2024110662) for the City of Fresno. Although these proposals affect the whole city, my comments are primarily in reference to the current vacant lots bordering the North and South sides of Herndon Avenue between the streets of North Marks Avenue and North Milburn Avenue.
Please
enter these comments into the public record regarding these proposals.
Specifically:
We are against the repeal of Fresno Municipal Code Section 15-1106 as proposed in the Text Amendment Application P24-00794.
Removal
of this section of the Municipal Code would give the City a green light to
ignore required road, parking, pedestrian/bicycle route and traffic signal upgrades under the Fresno Complete Street Policy dated Sept 26, 2019 with new RM-1, RM-2 and RM-3 developments. Fresno Municipal Code Section 15-1106 also requires the City to do traffic impact studies for all development with 300 or more peak hour new vehicle trips.
This
would be done away with if this section is repealed.
Regarding the Text Amendment Application P24-00794, I have the following concerns/comments specifically relating to the vacant lots running along both the North and South sides of Herndon Avenue, between N. Marks Avenue and N. Milburn Avenue:
Section 4.1a “Aesthetics”. The study is flawed when it states that there would be less than significant impacts to scenic vistas with RM-3 developments.
RM-3 allows for the construction of up to 45 living units per acre (which could easily house 4 people per unit) and up to 60 feet in height. Apartment units that are 60 feet in height would be a blight on a neighborhood that consists of primarily single story dwellings (houses, apartments, condos and townhomes).
If any of the vacant lots along
both sides of Herndon Avenue between Marks and Milburn Avenues were converted to RM-3, it would create an aesthetically unpleasant situation for current residents and for the city.
As an example, I will
refer the Planning Commission to how much the Clinton Avenue Apartments (at 1538 E. Clinton) stand out like a sore thumb when compared to the surrounding neighborhood of single family homes, and they are only 4 stories high (see attached photo).
Section 4.11. “Land Use Planning”. If RM-3 development is allowed in these lots along the Herndon corridor, it would physically constrict travel between the already established neighborhoods along the North side of Herndon Avenue with access to Herndon Avenue along Marks, Valentine and Brawley Avenues.
RM-3 development in these lots would
introduce new, incompatible uses that are inconsistent with the current land use planning.
I specifically note that the Text Amendment
Application P24-00794 does not propose the construction of any new roadways which may be needed to handle increased traffic flow if RM-3 zoning is allowed.
Section 4.13. “Noise”. The study is flawed in that there would be a significant negative impact due to increased traffic noise, especially during key commute hours.
Section 4.14. “Population and Housing”. The Text Amendment Application P24-00794 would significantly negatively impact the inducement of unplanned population growth in an area originally planned for offices.
Section 4.15. “Public Services”. The allowance of RM construction in these lots currently zoned for office space would exasperate overcrowding in Tatarian Elementary School.
Impaired access of
Ladder Fire Trucks at the traffic circle along N. Prospect Avenue has already been addressed in earlier hearings.
There are limited public
services, such as medical clinics, grocery stores and pharmacies, along Herndon Avenue between Marks Avenue and Milburn Avenue.
Sections 4.17 a, c and d. “Transportation”. As pointed out above, there already is inadequate emergency vehicle access along the traffic circle on North Prospect Avenue.
Large fire ladder trucks would have a
difficult time negotiating the current traffic flow along North Prospect and the frontage road (called North Valentine Ave). If RM3 is approved for this street, traffic flow will be impeded during peak traffic hours, including any emergency vehicles coming into the area during these times.
The finding in Section 4.17 (a) is flawed in that there are no sidewalks (or bike path) along the Herndon frontage road between North Prospect Ave and N. Valentine Avenue allowing for safe passage of pedestrians and bicyclists.
Allowing the development of RM3 units that are 60 feet tall are totally incompatible with the Herndon corridor and all neighborhoods in Fresno with the exception of downtown where there are other high rise buildings.
Let’s keep the buildings along this section of the Herndon avenue corridor to two stories or less to fit in with the current neighborhood.
The nearest tall building (4 story) along Herndon
Avenue is the Marriott property east of Fresno Street.
Adoption of the Mitigated Negative Declaration Sch No 2024110662 for