From:
To:
Subject: FW: Action Pertaining to 1302 Fulton Street Public Comment Letter, Oppose Unless Amended Date: Tuesday, May 20, 2025 8:20:08 AM
Attachments: City of Fresno Downtown Development.pdf
From: Eric Payne
Sent: Monday, May 19, 2025 5:24 PM
To: Jennifer Clark ; Miguel Arias ; Jerry Dyer
; Georgeanne White >; Gabriela Olea
>; Clerk >
Cc: Tammy Townsend ; Michael Duarte
>; Tyrone R. Williams
Subject: Action Pertaining to 1302 Fulton Street Public Comment Letter, Oppose Unless Amended
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Good Afternoon,
I have attached to this communication a letter of concern for your records and consideration.
In Community,
Eric Payne
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable law including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication
City of Fresno
2600 Fresno Street
Fresno, CA 93721
May 18, 2025
Board of Commissioners
Housing Authority of the City of Fresno
1331 Fulton Street
Fresno, CA 93721
Dear Members of the Board and City of Fresno,
I write to express profound concern regarding the Housing Authority’s acquisition of the former CVS property at 1302 Fulton Mall and the proposed development of an affordable housing project on this site.
While the intent to address Fresno’s housing crisis is commendable, the process and commitments surrounding this project raise significant legal, ethical, and social issues that merit immediate and thorough reconsideration.
Displacement of Essential Community Services:
Historically, the Helm Building served as a vital hub for low-income families, providing essential services and programs. The sale of this property and the subsequent eviction and displacement of these programs have left a void in services that many residents rely on Fresno Unified’s Dual Language Pre TK program, Youth Leadership Institute (YLI), Every Neighborhood Partnership (ENP), Lowell Community Development Corporation, and other essential services. The Housing Authority’s commitment at that time to reinstate these programs or similar programs offerings through the proposed development was commendable; however, the Fresno Housing Authority has since rescinded its commitment and the lack of a clear, enforceable plan to fulfill this commitment raises concerns about accountability and transparency we have made several attempts to reconcile our concerns with the Agency but they have made no effort to mitigate this issue or others.
Potential Violations of CEQA
The California Environmental Quality Act (CEQA) mandates that public agencies assess and mitigate potential environmental impacts of proposed projects. The Housing Authority’s Notice of Exemption for the 1302 Fulton acquisition cites a “common sense exemption,” asserting that the project involves no significant environmental impact. However, this assertion overlooks the potential cumulative impacts of the proposed development, including increased traffic, strain on local infrastructure, and effects on air
quality. Given the project’s scale and location in a historically significant area, a comprehensive Environmental Impact Report (EIR) is warranted to fully assess these potential impacts and explore feasible mitigation measures .
Non-Compliance with HUD Obligations:
The U.S. Department of Housing and Urban Development (HUD) requires that public housing authorities maintain and operate properties in a manner consistent with their obligations to low-income communities.
The displacement of essential services without a clear plan for their reinstatement may constitute a breach of these obligations. Furthermore, the proposed development must demonstrate that it will not exacerbate existing disparities in housing access or quality, particularly for historically marginalized communities.
Legal Precedents and Community Rights:
Legal precedents underscore the necessity for public agencies to adhere to environmental and social justice principles. In Citizens etc. L Street v. City of Fresno, the court emphasized the importance of thorough environmental review processes to ensure that development projects do not adversely affect community resources and historical sites. Additionally, the recent appellate court decision striking down Fresno’s master environmental impact report highlights the judiciary’s role in holding public agencies accountable for inadequate environmental assessments
Call to Action In light of these concerns, I urge the City of Fresno to approve with the following conditions for the Housing Authority to:
Develop a Transparent, Enforceable Plan, and Community Benefits Agreement:
Clearly outline how the proposed development will reinstate and expand upon the community programs previously housed in the Helm Building, with specific timelines and accountability measures. We, the undersigned members of the Central Valley Urban Institute, along with residents in the impacted Downtown Neighborhoods, issue a public statement to reaffirm our expectations and demand full accountability from the Fresno Housing Authority regarding the Community Benefits Agreement (CBA) tied to the 1302 Fulton Development (The Old CVS Building).
This agreement was established not as a symbolic gesture, but as a binding and community-driven commitment to ensure that the 1302 Fulton Street Development (The Old CVS Building) serves the people it impacts the most, the existing residents of our community. The CBA outlines specific, measurable benefits including but not limited to:
• Affordable housing guarantees for low- and moderate-income residents • Local hiring and job training opportunities for community members • Displacement protections and tenant support services
• Equitable access to amenities and green space
• Transparent and ongoing community engagement
To date, we have observed significant gaps, delays, and broken promises. These shortcomings represent not only a breach of trust but a failure to uphold the principles of equity and justice that underpinned the agreement.
We call on the Fresno Housing Authority to immediately take the following actions:
Publicly release a progress report on all CBA commitments, with clear data, timelines, and next steps.
Convene a community oversight meeting within 30 days, including CBA signatories and independent observers appointed by the City of Fresno Mayors Office and District 3 Council Office. Address and remedy any unmet obligations as identified by community feedback and independent review.
We remind the Fresno Housing Authority that this development is being built in our neighborhoods, on public land, with a significant capital stack of public dollars. As such, our voices and our wellbeing are not optional, they are central. We will continue to organize, advocate, and hold every stakeholder accountable until every provision of the CBA is fulfilled.
Conduct a Comprehensive Environmental Review: Prepare a full Environmental Impact Report to assess the potential impacts of the proposed development and identify feasible mitigation strategies.
Engage with the Community: Initiate a robust public consultation process to ensure that the voices of affected residents are heard and considered in the planning and development process, residents within 1,000 ft of the Helm Building were not noticed by the agency of the one public meeting that was held.
Ensure Compliance with HUD Obligations: Demonstrate that the proposed development will meet all federal requirements for public housing authorities and will not exacerbate housing inequities.
The Housing Authority has a profound responsibility to serve the community’s needs. Upholding legal obligations, ensuring environmental justice, and prioritizing the well-being of residents are paramount. I trust that the City Council will consider these concerns seriously and take appropriate action to address them.
In Community,
Eric Payne
Executive Director
The Central Valley Urban Institute
Fresno, CA 93727