of White Flight and redlining with racial covenants excluding many demographics from renting or owning homes or businesses north of Olive.
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 250
structure loss with industrial expansion.
massing and materials of both do not respect or reflect the buildings adjacent to them. A good example of context sensitive design is 541 @ South Tower. It is new construction but with urban massing and art deco design built in 2016. But it does not appear anywhere in the Specific Plan or Design Standards
Page #44: CHP 1.5 The historic survey of South of Belmont West of Broadway should place priority on identifying historic buildings and assets at risk from industrial expansion and deferred maintenance.
CHP 1.7
● comment: The Belmont phoenix palms and the deodar cedars should be mentioned here or under 2.2
Page #47: CHP 2.1
● comment: This would be stronger if it said “hold accountable property owners…” instead of the more passive “work to preserve…”
03 Land Use
During the land use map initiation meeting with Fresno City Council, Councilmember Nelson Esparza motioned to study 604 N. San Pablo Ave for rezone from RS-5 to Mixed Use. That motion was seconded and voted affirmatively by all councilmembers. That rezone does not appear to be included on any map or text in the plan or EIR. The 604 N. San Pablo Ave. The property is owned by South Tower CLT and we have aspirations to develop a mixed use development on site. We would like to see that Council vote honored and included in this plan.
Table 3.B in the EIR on page 3-21 the table assumes the loss of 6 housing units. However a total of 24 units of existing housing are zoned industrial. We don’t understand why any homes should be lost for industrial expansion especially in the context that there are few mitigations to protect other housing that will become adjacent to industrial when those homes are lost and converted to industrial uses.
Table 3-B states there are 13 acres of vacant or underutilized Light Industrial with 6 units of housing to be removed. Can the plan identify the vacant / underutilized industrial land? Also of note during the planning process one industrial business Patton Air Conditioning purchased an existing home zoned industrial adjacent to other housing, they demolished the home and built a parking lot with bright lights and storage containers that are not appropriate for residential areas. Producers Dairy demolished several agricultural buildings from early 1900’s that were eligible for historic designation for a planned parking lot.
EIR 3.6.2.3 states “Light industrial uses are located along the southwest boundary of the Specific Plan Area. These areas are important historical and economic centers, as they bring employment
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 251
opportunities. Some of these businesses have been in the neighborhood for many decades and have long-standing relationships with local residents and institutions.”
Page #66 : Figure 3.2
● Comment: “Please show the community feedback that requested this downzoning.” ● Comment: The Cheese building and properties to its south need to be Public Facility with a NMX or CMS dual designation. It’s original designation should have been considered spot zoning.
Keeping it industrial today is not incentivizing the property owner to maintain it per their covenant; instead it is incentivizing the continued use of the lot as an industrial parking lot in a residential neighborhood.
● Comment: Light industrial zoning needs to have an asterisk similar to the Southwest Fresno Specific Plan to indicate the zoning will change when existing users leave. Or, there needs to be a policy committing the City to rezone this area should that occur. Office and Business Park should be examined as more neighborhood friendly alternatives.
Page #67: 3.6 Industrial and Employment Compatibility
● Comment: This statement is out of balance. While they are an old company, they haven’t always benefited the community. Instead they have a history of expansion into the neighborhood.
Quantify “important” and what is the value of that importance compared to the health of their neighbors? Or opportunity costs of lack of space for other uses and lowered property values for the neighborhood?
Page #67: 3.6 Industrial and Employment Compatibility
● Comment: How many employees? I’ve only heard a statistic referencing a distance of ten miles which includes Clovis and therefore is not just the neighborhood.
Page #67: 3.6 Industrial and Employment Compatibility
● Comment: Can the City verify that a dairy plant is a light industrial use and not a heavy industrial use and what keeps it from being considered a heavy use? Page #79: LU 4.3
● Comment: Drive throughs should not be allowed anywhere in the Tower District. Also, they are already not allowed in CMS.
Page #81: LU 6.1 Maintain industrial zoning for existing industrial uses, while striving to mitigate their negative effects on residential areas.
● Comment: “Striving” is not a commitment. There is no try only do. “Consider…consider…explore…” this policy has no teeth and is simply lip service to the residents.
● Comment: Why aren’t there any design standards for Employment Uses including Industrial? Page #81: LU 6.2 Allow light industrial uses to have neighborhood-serving retail.
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 252
● Comment: What about requiring CBAs anytime an industrial business wants to expand in the Tower?
Page #82: LU 6.4 Support the San Joaquin Valley Air Pollution Control District in monitoring emissions. ● Comment: What is the point of this policy if it doesn’t require more than what’s already required?
04 Parks and Public Spaces.
Per the EIR page 81, the Specific Plan area currently has 8 acres of parks accounting for 0.33 park acres per 1,000 residents short of the 3 acre per 1,000 residents standard in the 2035 General Plan and Parks Master Plan. This means the Tower District Specific Plan has a deficit of 64 acres of parks. The proposed policies and “park opportunities for study” identified on Figure 4.1 fall far short of filling the need for 64 acres of new park in the Tower District. This plan should identify at least 64 acres of new park within the plan area. It is appropriate to identify more that 64 acres of potential parks space knowing that some opportunities will not come to fruition.
● Comment: Bradway Parque is complete and should not be noted as “planned” ● The vacant property on Clinton on the western edge of the plan area is under development now.
Page #93: Figure 4.3 Measure P Park Prioritization for Future Parks ● Comment: The data shows that there needs to be a stronger commitment to parks. Potential new parks should be shown on the land use map to give the City more opportunities to potentially add park space.
Page #94: Planned Parks
● Comment: disagree, the original subway was probably better Page #96: Canalside Parks
● Comment: herndon
Page #97: 4.4 Public Schools and Libraries
● Comment: highlighted typo of the word, “currently”
Page #101: POS 1.5 Pursue joint-use partnerships with schools in the Tower District. ● Comment: parking or parks?
1. Circulation
Page #119: 5.5 Pedestrians
● Comment: highlighted text of unfinished sentence under image in margin, “Sidewalk gaps, as in the south Tower District area, are a barrier to…” incomplete sentence
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 253
05 Circulation
H Street and Weber are ideal for bicycle and pedestrian traffic to and from Tower District and Downtown. These roads should include pedestrian oriented lighting standards and protected bike lanes to keep those active transportation methods safe from truck traffic.
06 Utilities
Canal. The right of way along the canal has not been kept open to allow for a trail adjacent to the canal in many places. Undergrounding the canal into a pipe would allow for a trail above the canal and would reduce drowning risk, water contamination and evaporation. FID would be an essential partner in that work. Also FID is a potential blocker for development. Their requirements nearly stopped the development of the 541 @ South Tower development. FID needs to be proactively engaged.
Although the City does not have direct control over electricity provision, it may be worthwhile to provide information on it since it can inhibit the development of new housing units, including ADUs. It also factors into sustainability and affordability. a. Recommendation: Work with PG&E to determine priorities for transformer replacement and undergrounding of power lines.
6.4 Solid Waste - Trash enclosure requirements for commercial and multifamily residential or mixed use projects can be a barrier to designing quality urban site plans. a.
Recommendation: Allow for flexibility for urban developments on tight in-fill sites to utilize hand cart for solid waste, recycling and green waste rather than dumpsters. This will free up precious square footage for other uses while also encourage limiting waste produced on site.
Recommendation: Add publicly accessible trash cans on sidewalks throughout the commercial corridors that can be emptied with automated lift of existing garbage trucks to reduce cost of trash collection and limit trash overflows and littering.
Broadband internet access is a key equity issue.
Recommendation: Identify areas of Tower District that lack broadband access.
Work with broadband providers to encourage full coverage.
07 Implementation
committee of citizens appointed by the Mayor and City Councilmembers is not listed among the review
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 254
bodies. Will that committee be dissolved? This may have some overlapping purpose with the description of the Tower District Specific Plan Implementation Committee and the Council District Project Review Committee. Additionally, the Council District Project Review Committees are listed twice.
Community Land Trust [South Tower CLT]
Appendix B Health and Equity Evaluation
Page #190: Policy recommendations grid (orange)
● Comment: This row should have more negatives by to reflect the negative healthy and equity outcomes of keeping industrial in the neighborhood.
Noise Pollution - Despite public comments about noise pollution from the Producers Dairy industrial facility at Palm & Belmont, the three noise monitoring locations included in the EIR are nowhere near the Producers Dairy or an industrial zoned facility adjacent to residentials. Without proper study of the existing noise levels near the industrial section of South Tower, there is no baseline for noise mitigation measures. Only 3 sound monitors were included in this plan. We believe an additional monitor should be included at Palm & Franklin to capture the industrial noise levels adjacent to residential. Given other comments about concern of night life noise levels on the Olive corridor, it is appropriate to capture data somewhere along the Olive corridor.
Light Pollution - The bright lights at Light Industrial businesses adjacent to residential uses has been uplifted during public comments as inappropriate for the peaceful enjoyment of those homes. A study of light pollution should be include in the EIR and mitigation measures should be proposed to limit light pollution bleeding from Industrial properties to residential ones.
EIR
Table 4.1.A does not include pollutants known to be included at the Producer’s Dairy facility. See 2019 settlement between EPA and Producers Dairy related to anhydrous ammonia. “Producers Dairy Foods’ industrial refrigeration system uses large quantities of anhydrous ammonia, a toxic chemical highly corrosive to skin, eyes and lungs.”
https://www.epa.gov/newsreleases/us-epa-settlement-producers-dairy-foods-improves-chemical-safety- fresno-california
Design Standards - Most notably the design standards & guidelines contain no section for Industrial Districts. A large amount of residential single family and mixed-use zones are adjacent to light industrial zones. The conflict and lack of mitigation of negative impacts by industrial has been the topic of many public comments through this process. The Design Standards are an excellent places to include standards for those mitigations but that opportunity is completely ignored.
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 255
Thanks again for the opportunity to comment and we hope these comments will be thoughtfully considered for their impact of health and equity of Tower District residents and for the advancement of developments being led by South Tower CLT.
With gratitude,
Kiel Lopez-Schmidt
Executive Director
South Tower Community Land Trust
South Tower Community Land Trust 115 N. Calaveras St. Fresno, CA 93701 EIN:88-3488608 256